Dan Marks, a professional city planner who has worked on numerous projects of all types, has written a detailed letter to the Piedmont City Council describing the many reasons why the City’s approach to the EIR process for the Moraga Canyon sports complex is deeply flawed. He also includes a brief assessment of some major problems with the current plan.

His full letter is available as a PDF; here are some brief extracts from the letter.

Many people have written eloquently on the flawed process the City has followed to get to this point in regard to the proposed project for Blair Park. As a city planner who has spent much of my career managing planning processes, I’m shocked at the lack of open public forums where a matter of this importance to the community and to neighbors could be discussed. The City of Piedmont engages in more process in regard to a simple home addition than it has for this massive project that would have profound and detrimental impacts on neighbors, and which would fundamentally change the character of this community. We don’t need an EIR to tell us that. City Council meetings where citizens are given two minutes to speak are not a substitute for open dialogue.

As a professional planner who has worked on Parks and Recreation Master Plans, Parks and Open Space Elements of General Plans, and on planning studies for parks and recreation facilities, I’m also disturbed by the City’s backwards approach to this major capital improvement project. A standard process that would eventually lead to a $8-10 M investment in a sports park (not to mention a half million dollars in studies for the sports park) would begin with a needs assessment and an assessment of alternatives for meeting that need.

…

As someone who has written, managed or supervised the production of dozens of EIRs, I want to say as emphatically as I can that an EIR is not a substitute for a reasonable planning process. EIRs do not generate an alternatives assessment of the type I’ve described; they only look at alternatives from a very narrow environmental impact point of view. At the end of the day, the EIR will tell the Council that one alternative has less or more significant detrimental environmental affects; it cannot tell you whether one alternative has a better chance of meeting the City’s needs at less cost than another. CEQA is a very expensive and poor substitute for good planning.

Read the full letter here (PDF).