The Moraga Canyon Sports Fields Draft Environmental Impact Report (DEIR) is finally out, and the City of Piedmont is taking comments on it until Aug. 9, 2010.  Now is the time to speak up – in person, by email or letter. The DEIR can be viewed or downloaded from the city’s website. Copies may also be available at Piedmont City Hall.

As the DEIR stands, it has identified six areas in which the project has significant and unavoidable impacts that cannot be mitigated. However, there are many additional areas where the DEIR itself is incorrect or incomplete, as described below. It is critical that the community provide detailed feedback on these deficiencies in the DEIR in order to ensure that the final EIR is complete and accurate. Issues that are not raised now will not be considered in the final project decision.

FOMC has identified an extensive list of issues that have not been properly addressed in the current DEIR. In your comments, please focus on the issues of particular interest and concern to you and include your personal experience on how they impact you.  It is essential that the City hear from as many people as possible. Please respond!

The City Council held an initial public hearing for comments on the DEIR on July 19, and will hold a second public hearing on Monday, Aug. 2, 2010, at 7:30 p.m. at City Hall.   You may send comments by mail to the City of Piedmont, 120 Vista Avenue, Piedmont, CA  94611 (to the attention of Ann Swift, City Clerk), or by email to aswift@ci.piedmont.ca.us.  All comments on the DEIR must be submitted by 5 p.m. Monday, Aug. 9, 2010.

Here is a quick summary of the impacts found by the DEIR and the issues FOMC feels are inadequately addressed.

The DEIR found “significant and unavoidable impacts” that cannot be mitigated or improved in six areas:

• Land Use and Planning (loss of open space in conflict with the Piedmont General Plan)
• Aesthetics (loss of canyon views, intrusive lighting)
• Biological Resources (loss of trees and oak woodland habitat)
• Hazards and Hazardous Materials (regarding use of synthetic turf)
• Traffic and Circulation (excessive speeds on Moraga and inadequate sight lines for west driveway)
• Parks and Recreation (contradicts General Plan’s criteria for open space and existing passive recreation).

Due to these impacts, the City Council would have to make a “Statement of Overriding Considerations” determining that the benefits of the project outweigh the negative environment impacts before it could approve the project.

The DEIR also found other significant impacts that the report asserts could be mitigated. FOMC disagrees with a number of these proposed mitigations as being inadequate and/or based on inaccurate and erroneous information, particularly those regarding noise and traffic. For more detail, refer to Issues with the July 2010 Draft EIR — we will continue to update this page as we discover new issues.

FOMC retained an expert in CEQA (California Environmental Quality Act), Richard Grassetti of Grassetti Environmental Consulting, to review the draft EIR. Mr. Grassetti found the draft EIR substantively incomplete and out of compliance with CEQA regulations, and prepared a detailed response (PDF, 16 MB) listing many areas of concern.

In summary, Mr. Grassetti found the project objectives to be vague and without quantitative measures and the range of project alternatives to be inadequate to meet even the most minimal CEQA standards. He also found deficiencies regarding Aesthetics, Geology Soils & Seismicity (safety of homes above retaining wall during construction), Hazardous Materials and Water Quality as well as numerous errors and deficiencies in the Noise and Traffic assessments. For more detail, please refer to Mr. Grassetti’s letter.