Issues with July 2010 Draft EIR
Last updated: 7/21/10

Friends of Moraga Canyon has reviewed the Draft Environmental Impact Report (DEIR) for the Moraga Canyon Sports FIeld project. While the DEIR as it stands has identified a number of significant and unavoidable impacts of the proposed project that cannot be mitigated, there are a large number of issues that are incorrectly or incompletely addressed by the DEIR. Here is a list of issues that need to be properly addressed before the EIR is certified. (Click on the links below to jump to individual sections.)

Project Objective
Project Description
Land Use & Planning Policy
Aesthetics
Biological Resources
Geology, Soils and Seismicity
Hazards and Hazardous Materials
Hydrology & Water Quality
Traffic & Circulation
Noise
Air Quality
Global Climate Change
Public Services
Parks & Recreation
Alternatives Analysis

Project Objective:

  • Too vague as to need; in Piedmont only is too restrictive

Project Description:

  • Pedestrian walkway is at elevated field level
  • What are the hours of safety lighting in parking lots, walkway and bridge
  • Pedestrian bridge locked at night?
  • What are hours of community-wide access?

Land Use & Planning Policy:

  • Clearly violates numerous policies of the Piedmont General Plan especially relating to views, noise and emphasis on open space and retention of native trees
  • Requires revision of the General Plan in order for Council to approve the project
  • Requires modification of City Code to allow lighting at Coaches Field and to permit recreational facilities at Blair Park
  • Re Policy 9.2, no bus lines travel on Moraga Avenue past Coaches Field or Blair Park.
  • Re Policy 9.5, it is an inaccurate statement that there are bus lines that travel to the fields on Moraga thereby encouraging travel to and from the project site by bus.

Aesthetics:

  • Does not consider loss of home value due to loss of canyon views and alternation of night time views
  • Considers only impacts of entire project but not of components (Coaches only)
  • Destruction of scenic vistas driving along Moraga Avenue were not considered
  • What is the visual impact for through traffic because of the 25 foot high landscape berm, fencing and the proposed sound wall on top?
  • What affect on visuals does the mitigation to not allow vegetation of 3.5’ on the landscape berm in order to improve sight-line distance when exiting driveways?
  • There is a building height restriction in Piedmont of 35’ – retaining walls should be no higher
  • Has security lighting at Blair Park been considered?
  • Retaining wall at Coaches Field is about 10 years old at Coaches Field and is still quite bare, why will vegetation cover the retaining wall at Blair Park when it is 3 times greater in height?

Biological Resources:

  • Retention ponds at Mt. View Cemetery are water source for wildlife (especially first unfenced pond that drains from Coaches Field) – how will runoff and drainage into those ponds affect wildlife?
  • Coaches Field already compromised the Moraga Canyon oak woodland; will Blair Park cause further fragmentation of the oak woodland?
  • There are red tail hawk and owls in the canyon whose nests are protected, how will this be assessed?
  • Regarding water quality, does runoff eventually reach the bay through Lake Merritt and therefore should other agencies be concerned with drainage?
  • Re wildlife movement, EIR states that the canyon below Coaches Field is isolated from Blair Park by Moraga Avenue.  However, residents witness the wildlife corridor crossing at Moraga Avenue daily.  This is further evidenced by the 2 fox and 1 fawn that have been hit and killed by cars in the past 6 months crossing Moraga Avenue.
  • Agree that the substantial loss of oak trees and its oak woodland habitat cannot be mitigated.
  • Any tree protection during construction should be continuously monitored by an independent Certified Arborist.
  • Preserve and protect the last open space in Piedmont
  • Where would the 86 oak trees be planted if not in Piedmont and how would the city maintain them through their lifespan?  This is not a reasonable mitigation.

Geology, Soils and Seismicity:

  • Cost of safe retaining walls and liability of city in case of failure of hillside or foundations of houses above.
  • Liability to city for earthquake or heavy rains damage during or after construction of retaining walls
  • Not enough data on fill materials in Blair Park – mentioned that fill dates back to 1947 and is from 13 to 23 feet deep

Hazards and Hazardous Materials:

  • Vector control mitigation states that vegetation clearing will start at the top and move down – how will those on the north side of Moraga be protected from the rodents that are forced across the street?
  • Providing neighbors with a contact phone number if rodent issues arise is a suitable mitigation?
  • Retaining natural grass fields at Coaches Field was not considered.

Hydrology and Water Quality:

Traffic & Circulation:

  • Pedestrian and bicycle access should be improved
  • Unfair to subject Oakland to further degredation of their already LOS F intersections on Moraga with additional traffic
  • Diversion of traffic to other small side streets (Pala, Mesa, Monte) not addressed
  • Diversion of traffic to highly traveled routes (Highland, Oakland) not addressed
  • Effects of proposed crosswalk to through traffic on Moraga not addressed
  • Is proposed crosswalk ADA compliant?
  • Maxwelton intersection (Maxwelton to east Blair Park driveway) not assessed for pedestrian crossing
  • Maxwelton intersection has largest parking lot plus a passenger drop off area however trip distribution was split evenly between the 2 parking lots.
  • Must include the possibility of utilizing the large field for 2 half field practices going on at one time
  • Assumption that cars were parking at Coaches Field lots to use the skate park are unreasonable and should not contribute to the assertion that the number of cars parked is conservative
  • Using your assumption that there could be 188 people attending two games at Blair Park (p. 283) with an AVO of 2.1 (p. 241), that would equate to 89 parking spaces required.  This still does not take into account 2 teams arriving for pre-game warm-ups while the current games’ players were still at the park.  Explain how the requirement of 66 parking spaces was calculated.
  • Were left hand turns (going west on Moraga) into the Blair Park parking lots assessed?  Per the EIR 25% of traffic would exit to the east (p. 242) and therefore would originate from the east.
  • How will left hand turns out of the east parking lot affect residents making any turns out of Maxwelton onto Moraga?
  • Time gap surveys were not taken at peak traffic hours
  • Staggering game times and practices may limit the total time available to be played on the fields and it is unclear if it is taken into account that one team will be arriving before the current players leave the parking lots.
  • Sight distances for turns from Maxwelton onto Moraga are minimal to the west and to the east.  How will the entrance and exits to the west lot affect this intersection?  Who will have the right-of-way?
  • Reduction of vehicle speeds on Moraga has been attempted, but is still an average of 35 mph.  The mitigation to enforce the 25 mph speed limit has little chance of success.
  • Parking at Coaches Field is not sufficient for its demand.  Therefore, the assumptions for parking requirements for Blair Park are insufficient.
  • Vehicles parking to use the picnic areas or dog area were not included in the calculation for parking spaces.
  • It is an unsubstantiated assumption that children or parents will not walk back and forth across Moraga Avenue
  • Pedestrian bridge was included in the plan for pedestrian safety and now is proposed to be removed for the same reasons.  Please explain.
  • 1985 EIR resolved that no parking should be provided that would necessitate crossing Moraga Avenue on foot.  How has the situation changed since then?
  • Traffic forecasts prepared by the Alameda County Congestion Management Agency should be utilized to assess future traffic volumes
  • Accident rates should be noted and assessed for the affected area
  • The sight distance analysis does not mention ‘safe stopping distance’
  • Sight distance analysis should include these factors for pedestrians as well as vehicles entering the roadway
  • Gap analysis does not state anticipated duration of gaps during peak flow into and out of the new driveways?  Is a 7.5 second gap sufficient for a pedestrian to cross the road?  Is a 7.5 second gap sufficient for vehicles to exit the proposed new driveways?
  • Clarification is needed regarding the proposed illuminated crosswalk
  • What measures will be used to reduce vehicles’ speed to 25 mph?  What costs are involved?

Noise:

  • Testimony of actual existing noise disturbance from field activities has been given and basically ignored.
  • No noise study was taken to measure the canyon effect.  On-field measurements were taken in November over one weekend and residential measurements were taken on one day in March for a mere 15 minutes at each location.  (Game noise was atypically low on March 10th.)   Why not measure field noise at the same time as residential noise levels to measure a real differential?
  • Noise from practices until 9pm at Coaches Field and the associated vehicle noise will be significant (because it already is) especially during the sensitive evening hours.
  • Proposed sound wall to ‘protect’ residents on the north side of Moraga (Echo, Maxwelton, Nellie, Moraga) will instead intensify the vehicular noise to those residences.
  • Spectator noise calculations assumed 10 minutes of shouting in a 2 hour period.  This is so far from accurate – ever been to a soccer game?
  • Why would  sound monitoring results (Table 4.8.F, p. 266) be averaged over 24 hours (Lez or Ldn)?  What was the source of Lmax values of 102, 112, and 114?  Siren?  Helicopter?  Game noise?  Why was CNEL not used which takes into account more sensitive evening noise?
  • It has not been proven here that distance attenuates noise to the degree you assume.  According to this EIR, residents that are already disturbed by the existing noise would not have any significant impact if additional hours and players are introduced.  That proves the criteria is flawed.
  • What is the increase in traffic noise to residents along and above Moraga due to the berms along that road up to 25’ high?  Those levels were already measured at 65 dBA Ldn.  Although the traffic noise may be lower to those on the field, it would be higher to residents on the north side of Moraga.
  • Statement on p. 293 that “There would not be any measurable or perceptible canyon effect to the noise associated with activities at the proposed Blair Park” is in direct opposition to numerous residents’ testimony regarding the sound amplification effects they experience every day living in and above the canyon.  The canyon is already densely vegetated and does not attenuate the noise reflection.

Air Quality:

Global Climate Change:

Public Services:

  • Landscaping for aesthetics purposes seem to contradict landscaping for safety purposes.  How do these two issues affect each other?
  • Will elevated walkway be an unsafe area at night?
  • Will there be an impact on public works budget?

Parks & Recreation:

  • Why is Hampton (Piedmont Sports Field) designated as a neighborhood park rather than a special use park?

Alternatives Analysis:

  • Can degraded field conditions at Coaches Field be solved through other means?  I.e. correct grading and drainage problems.
  • Alternative should be assessed that does not include night lighting at Coaches Field
  • Eco/Organic Turf Infill is not an alternative; it is merely a mitigation
  • What is the effect of eco/organic infill on drainage water into Mt. View Cemetery ponds and the wildlife drinking water?
  • Where are the 33 parking spaces located for the reduced Blair Park alternative?  Are there still 2 parking lots?
  • How would aesthetics change when large field is still the same size with the same retaining walls?  The largest part of the project would remain the same.
  • Parking is still inadequate based on incorrect assumptions made at Coaches Field.  At least 45 spaces should be provided.