PUBLIC HEARING on the Consideration of Approval of a Resolution Adopting an Initial Study-Negative Declaration for the 6th Cycle Housing Element pursuant to the California Environmental Quality Act and a Resolution Amending the Piedmont General Plan — Piedmont City Council, March 20, 2023 (part 1 of 3)

City of Piedmont

COUNCIL AGENDA REPORT
DATE: March 20, 2023
TO: Mayor and Council
FROM: Sara Lillevand, City Administrator
SUBJECT: Consideration of Approval of a Resolution Adopting an Initial StudyNegative Declaration for the 6th Cycle Housing Element pursuant to the California Environmental Quality Act (CEQA) and a Resolution Amending the Piedmont General Plan by Adopting the 6th Cycle Housing Element and Repealing the 5th Cycle Housing Element

RECOMMENDATION

1. Approve a resolution (Attachment 1) adopting an Initial Study and Negative Declaration for the 6th Cycle Housing Element pursuant to the California Environmental Quality Act (“CEQA Resolution”).

2. Approve a resolution (Attachment 2) amending the Piedmont General Plan by adopting the 6th Cycle Housing Element (“Housing Element Resolution”) and repealing the 5th cycle Housing Element.

EXECUTIVE SUMMARY
Pursuant to City Council direction, on November 18, 2022, staff submitted the first draft of the 6th Cycle Housing Element to the California Department of Housing and Community Development (HCD). On February 16, 2023, HCD completed its 90-day review, and provided a comment letter to the City with 29 comments. Staff has now revised the draft 6th Cycle Housing Element in response to HCD’s comments. The resulting revisions to the draft Housing Element are shown in track-changes formatting in Exhibit A to the Housing Element Resolution (Attachment 2). Specific responses to each of HCD’s 29 comments are enumerated and illustrated in Exhibit B to the Housing Element Resolution.

In order for the City to remain on the path to compliance and certification in May 2023, this staff report recommends City Council: (1) adopt the attached CEQA Resolution and (2) adopt the attached Housing Element Resolution which directs staff to submit the 6th Cycle Housing Element published March 17, 2023, to HCD after the required 7-day public review period, and also authorizes staff to make any non-substantive changes to the Housing Element that may be required by the State to achieve certification or that may be necessary to ensure internal consistency with other planning documents.

BACKGROUND
In the Fall of 2021, the City began the 6th Cycle Housing Element update process. The history of the update process is outlined in Appendix E of the Housing Element and in prior staff reports to the City Council and Planning Commission, available on PiedmontIsHome.org. The following section describes key dates for the environmental review pursuant to CEQA and for draft Housing Element revisions that have been made in response to HCD comments.

On November 15, 2022, the City Council held a special meeting to consider the draft 6th Cycle Housing Element published April 8, 2022, with revisions recommended by staff in response to public comments and the Council’s direction to staff on June 20, 2022, and August 1, 2022, to complete further analysis. At the conclusion of the meeting, the City Council directed staff to make the revisions to the draft 6th Cycle Housing Element document, submit it to HCD for review, and make additional edits to the text, tables, and diagrams of the draft Housing Element requested by the HCD reviewers that were consistent with the Council’s direction.

On November 18, 2022, the City submitted the draft 6th Cycle Housing Element to HCD for its review. In December 2022 and in January and February 2023, HCD reached out to the City with a number of questions about the draft 6th Cycle Housing Element.

On December 9, 2022, the City published the complete draft 6th Cycle Housing Element on the City website and requested public comment on those changes. The City received additional public comment including 10 comment letters during the public review period (Attachments 3 and 4). Concurrently, the City issued a Notice of Intent (NOI) to adopt an Initial Study and Negative Declaration (IS-ND) prepared by City staff and consultants for the 6th Cycle Housing Element pursuant to CEQA. The NOI was published on the City websites (Piedmont.ca.gov and PiedmontIsHome.org), posted to bulletin boards at City Hall and the Police Station, and published in the legal notices section of the Piedmonter newspaper. Copies of the NOI and links to the IS-ND were emailed to subscribers to the City’s electronic newsletters, and physical copies were made available at the public counters at City Hall and at the Montclair Branch of the Oakland Public Library.

On January 12, 2023, the Planning Commission held a public hearing and a special meeting to consider the draft 6th Cycle Housing Element and the IS-ND prepared pursuant to CEQA. During the public hearing, one person addressed her comments to the Commission. At the conclusion of the public hearing, the Planning Commission adopted a resolution recommending that the City Council adopt the IS-ND and recommending that the City Council amend the General Plan by adopting the 6th Cycle Housing Element in a manner that authorizes staff to continue to work with HCD to respond to comments and expedite the review. The Planning Commission staff report is included in this report as Attachment 5 and minutes for the Planning Commission meeting are available on the City website.

On February 16, 2023, HCD sent the City of Piedmont a comment letter which outlined 29 comments. These comments are required to be addressed in order for HCD to issue a letter of substantial compliance.

On March 13, 2023, the Planning Commission held a regular meeting during which City staff presented each of the 29 comments from HCD and the City’s proposed approach to each of the comments.

Agenda Report Page 2

RESOLUTIONS AND RECOMMENDED REVISIONS
City staff has prepared two resolutions for City Council consideration. The first resolution covers the Initial Study-Negative Declaration (IS-ND). Action on the IS-ND is required prior to taking action on the second resolution which adopts the 6th Cycle Housing Element.

CEQA RESOLUTION: Initial Study and Negative Declaration (IS-ND) prepared for the 6th Cycle Housing Element pursuant to the California Environmental Quality Act (CEQA).

The resolution adopting the IS-ND with findings as to the Housing Element Update is Attachment 1 to this staff report. The IS-ND is attached as Exhibit A to the CEQA Resolution.

The City of Piedmont has prepared the necessary environmental review, consistent with CEQA, for the draft 2023–2031 6th Cycle Housing Element. The proposed project consists of a comprehensive update to the Piedmont Housing Element. The City of Piedmont has prepared the 2023-2031 6th Cycle Housing Element update to comply with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing and projected housing needs for varying income-levels in the community. It provides the City of Piedmont with a comprehensive strategy for promoting the production of safe, decent, and affordable housing, and for affirmatively furthering fair housing during the housing cycle. The 6th Cycle Housing Element update establishes goals, policies, and actions to address the existing and projected housing needs in Piedmont. The 6th Cycle Housing Element does not propose any specific development project and adoption of the proposed 6th Cycle Housing Element would not approve any physical development (e.g., construction of housing or infrastructure). The goals, policies, and actions in the 6th Cycle Housing Element are required to meet Piedmont’s Regional Housing Needs Allocation (RHNA). Piedmont’s RHNA requires 587 new housing units, including 257 new units for residents in the extremely low-, very low-, and low-income categories.

The City of Piedmont completed an IS-ND for the 2023-2031 Housing Element that was circulated for public and agency review from December 9, 2022, to January 8, 2023. The IS-ND concluded that the project would have no impacts in the various topic areas required by CEQA Guidelines Appendix G, including Aesthetics, Agriculture / Forestry Resources, Air Quality, Biological Resources, Cultural Resources, Energy, Geology / Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology/Water Quality, Land Use / Planning, Mineral Resources, Noise, Population/Housing, Public Services, Recreation, Transportation, Tribal Cultural Resources, Utilities/Service Systems, and Wildfire as the project involves only feasibility or planning studies for possible future actions which have not been approved or adopted. As such, the City of Piedmont has determined that an Initial Study and Negative Declaration is the appropriate CEQA assessment for the adoption of the 6th Cycle Housing Element.

The City received eight (8) comment letters during the IS-ND comment period which are included as Attachment 3. Two of the letters were from public agencies including the East Bay Municipal Utility District (EBMUD) and the Department of Toxic Substances Control (DTSC).

These letters are typical of the agencies’ standard comments and do not raise specific concerns about the information or analysis in the IS-ND. The EMBUD comment letter summarizes EBMUD requirements for water and wastewater service for new development. As explained in the IS-ND, development proposals for individual projects would be subject to adopted Agenda Report Page 3
development guidelines, including standards that govern utility services. The DTSC comment letter explains procedures for future development that may occur on sites containing hazardous materials. As explained in the IS-ND, in accordance with existing regulations, for future development that could occur on hazardous materials sites the City would coordinate with other agencies to address contamination of soil and groundwater from hazardous materials on various sites and require that contamination be cleaned up to the satisfaction of the City and other responsible agencies prior to issuance of any permits for new development.

Six of the letters were from Piedmont community members. Many of the comments pertain to the merits of or policies and programs in the proposed Housing Element itself and do not raise specific issues with the information or analysis in the IS-ND. Comments on the IS-ND pertained to topics including aesthetics, geology and soils (seismic safety and landslides), hydrology and water quality, transportation, wildfire, public services, noise, and traffic safety. Most of the concerns raised were about the Moraga Canyon Specific Plan area. As noted in the IS-ND, the proposed Housing Element is a policy document and does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the draft 6th Cycle Housing Element Update would not, in and of itself, result in impacts related to these issue areas.

For issues related to seismic safety, future development would be subject to adopted development guidelines and required to adhere to California Building Code requirements, policies in the Environmental Hazards Element of the Piedmont General Plan, and applicable State and local regulations. PCC Section 8.02.020(W) and Policy 18.4 of the Environmental Hazards Element of the Piedmont General Plan would require site-specific soils reports and geologic studies in instances where development may be exposed to substantial geologic or seismic hazards, including ground shaking and landslides, and would ensure any identified hazards are properly mitigated. Further, several commenters suggested an environmental impact report (EIR) should be prepared. According to CEQA Guidelines Section 15063(b), an EIR is required if significant environmental effects would occur. As stated previously, the Housing Element itself is a policy document that does not include changes to land use controls. The ISND for the draft 6th Cycle Housing Element did not identify any significant effects requiring preparation of an EIR.

Separate and apart from the IS-ND for the draft 6th Cycle Housing Element policy document (Exhibit A to Attachment 1), the City is currently preparing a programmatic EIR to analyze the effects associated with the General Plan amendments and zoning changes that would occur with implementation of the policies and programs included in the Housing Element.

HOUSING ELEMENT RESOLUTION: 2023-2031 Piedmont Housing Element The resolution to amend the General Plan by adopting the 6th Cycle Housing Element is Attachment 2 to this staff report. This resolution contains legal findings which are supported by multiple attached exhibits.

A. Exhibit A is a redline “tracked change” version of the 6th Cycle Housing Element dated March 2023, reflecting revisions in response to HCD’s comments.

B. Exhibit B supports the conclusion that the 6th Cycle Housing Element is in substantial compliance with State Law. It does this by indicating how the City has addressed and responded to each comment in HCD’s February 16, 2023 comment letter.

C. Exhibit C supports the conclusion that the 6th Cycle Housing Element is in Agenda Report Page 4
substantial compliance with State law. It does this by listing each provision of the Government Code for Housing Elements and indicating where in the document the relevant statutory requirement has been satisfied.

Upon receipt of HCD’s comment letter on February 16, 2023, city staff and consulting team completed an analysis of the 29 discrete comments made by HCD and a course of action was developed to address each comment.

HCD comments may be broadly characterized as follows:
• Request for narrative to be added to the evaluation of the 5th Cycle Housing Element in Appendix D describing its success in addressing the housing needs of special needs populations.
• Request for specific additions to the fair housing analysis in Appendix F, including additional discussions of fair housing practices, housing trends both in Piedmont and the region, the distribution of lower-income housing sites relative to mobility and access to amenities, local data and knowledge about fair housing issues, and other factors relevant to fair housing issues such as governmental policies and land use history. • Request for additional information and narrative about demographics and housing needs in Appendix A describing the cost of housing for lower-income households, the availability and cost of housing for rent or sale, and the housing challenges for special needs populations.
• Multiple comments relate to the analysis contained in the sites inventory, including additional analysis and discussion of the capacity of sites to develop with housing, the adequacy of sewer and water infrastructure, the parcelization and development of sites larger than ten acres, existing uses as an impediment to development, existing uses on publicly-owned sites, development trends that support the sites identified in the inventory, environmental constraints, and the availability of ADUs for occupancy. • Several comments address the need for programs to mitigate specific housing constraints, such as by-right permitting of emergency shelters, requirements for on- and off-site improvements, barriers to housing for persons with disabilities, and reasonable accommodation permitting.
• A request for additional discussion of public comments and how they were incorporated into the Housing Element.
• Several of the comments address the need for programs that are more specific and proactive, including metrics and timelines. HCD objected to programs directing the City to “consider” various actions in the future, or to implement programs on an “ongoing” basis. Their findings indicated the City should use more committal language (e.g., “require”, “enact”, “complete” rather than “consider” or “study”), have more specific timeframes, and set measurable targets wherever feasible. • Several programs were specifically listed by HCD as needing more actionable language.

These have been strengthened with timelines and specific actions to be achieved. In editing these programs, staff has made every effort to be realistic and recognize the City’s limited staff and resources.
• HCD sought new or enhanced programs related to a shortfall of lower-income sites, the Moraga Canyon Specific Plan, permanent supportive housing, assistance provided to nonprofit housing developers, persons with development disabilities, extremely-low income households, housing support for families in crisis, assistance to faith-based community organizations, development in zone C (multi-family), the City Charter, Agenda Report Page 5
residential care facilities, housing mobility and affordability, and the monitoring of ADUs.

The City responded to these comments by preparing a “tracked change” version of the 6th Cycle Housing Element dated March 2023, incorporating new text, tables and maps (see Exhibit A to Attachment 2). Most of the changes required adding data and analysis to the Housing Element.

Exhibit B to the Housing Element Resolution demonstrates how the City has responded to each HCD comment. The exhibit repeats each finding in the HCD letter verbatim, and then indicates how (and where) the City has addressed the finding. Every comment in HCD’s findings letter has been comprehensively addressed, enabling the City to find that its new draft is now in substantial compliance with State law.

Non-Vacant Sites Analysis
When a jurisdiction relies on non-vacant sites to meet more than 50 percent of the RHNA for lower-income households, it must make findings that the existing use on the non-vacant site is not an impediment to residential development during the planning period. Given the scarcity of vacant parcels in Piedmont, it is not surprising that more than 50% of the lower-income units in the sites inventory are on non-vacant sites.

In order to render this finding, the City studied the underutilization of sites (e.g. land developed with large areas of surface parking, single-story buildings, low improvement values), existing building age and condition, and/or uses of marginal economic viability on identified housing sites, combined with the significant demand for housing, the local trends for converting existing non-vacant land into residential and residential mixed-use, and the new 2023-2031 6th Cycle Housing Element programs to encourage the redevelopment of non-vacant sites with higherdensity housing. Accordingly, as described in the 2023-2031 6th Cycle Housing Element and documented its Appendix B, Sites Inventory and Methodology, the existing uses on the sites identified in the sites inventory to accommodate the lower income RHNA housing goals are likely to be discontinued in their current form and location and relocated during the planning period, and therefore these existing uses do not constitute an impediment to additional residential development during the planning period.. Substantial evidence to support this finding is documented in section B.2.5 Suitability of Nonvacant Sites on pages B-11 through B-22 of the Housing Element.

Community Engagement and Public Comment
Community engagement for the Draft Housing Element has been robust and critical to development of the 6th Cycle Housing Element over the past 24 months. Piedmont residents, property owners, business owners, and workers all contributed to the development of 6th Cycle Housing Element goals, policies, and programs. The City’s engagement efforts are summarized in the prior staff reports and in Appendix E of the 6th Cycle Housing Element.

Since the January 12, 2023, Planning Commission meeting, the City has received 11 public comment letters. These are included in Attachment 4 to this report. The City’s response to the latest public comments include the 6th Cycle Housing Element, dated March 2023, which was prepared after consideration of the perspectives and suggestions raised by members of the community, including residents, housing proponent organizations, and the PREC Housing Committee.

Agenda Report Page 6
All public comments received on or before March 24, 2022, are included in the Draft Housing Element Appendix E. Public comments received from December 16, 2021 through November 15, 2022, are included in Attachment 6. Public comments received from November 15, 2022 through March 15, 2023 are provided in Attachment 4.

Since the draft 6th Cycle Housing Element was released on April 8, 2022 there have been three opportunities for the community to comment on the 6th Cycle Housing Element in public meetings of the City Council (June 20, August 1, and November 15, 2022).

In addition, the City conducted extensive community outreach in support of the Housing Element update process over the past 24 months with an innovative and robust public engagement process, including two community workshops, 13 Planning Commission meetings, two meetings of the Housing Advisory Committee, a meeting of the Recreation Commission, a meeting of the Park Commission, two online forums, two open houses, and tables at community events, as well as online engagement tools, regular news stories in local media, email newsletters to over 4,000 email subscribers, emails to Native American tribes, School District employees and City employees, correspondence with Piedmont religious institutions, meetings with property owners in Zones A, B, C, and D, citywide streetlight banners announcing the Housing Element website, and posters at local businesses. For the purposes of making the staff report concise and to share Housing Element information broadly, the presentations, staff reports, recordings, and public comment for each of these meetings is readily available on the Get Involved/Past Events page at Piedmontishome.org.

As a result of the broad public engagement conducted by the City for the Housing Element, over 1,000 community members participated in the development of the Element. The City received hundreds of thoughtful comments and suggestions from members of the Piedmont community. The City has prepared additional analysis of issues that have been raised in public comments. Many of the revisions to the draft 6th Cycle Housing Element recommended in this staff report are the result of perspectives, ideas, comments, and concerns expressed by members of the public, as well as HCD staff.

CONFORMANCE WITH THE 2009 PIEDMONT GENERAL PLAN
The Housing Element is one of seven mandatory Elements of the City’s General Plan, a longrange vision document that provides guidance for future development in Piedmont. City Council adopted its revised General Plan in 2009. For the General Plan to provide effective guidance on land use issues, the goals, policies, and programs of each Element must be internally consistent with other Elements. The draft 6th Cycle Housing Element builds upon the existing General Plan and is consistent with its goals and policies. Proposed Housing Element program 1.P (page 49 of Exhibit A to attachment 2) directs the City to study amendments to the Land Use Element and other Elements to ensure consistency with the General Plan. Various Housing Element programs direct the City to prepare City Code amendments, and some can be implemented after amendments to the General Plan for consistency (e.g., permitted residential density and housing associated with religious institutions). As those 6th Cycle Housing Element programs are implemented, the General Plan will be amended concurrently to ensure consistency across planning documents. In the event that an Element of the General Plan is amended, the City will consider the impacts of the amendment on the other Elements to maintain consistency across all documents.

Agenda Report Page 7

CONCLUSION
The 6th Cycle Housing Element update meets the requirements of State law and addresses Piedmont’s housing needs. Staff recommends the City Council adopt the attached CEQA Resolution which includes findings to support the Initial Study and Negative Declaration prepared by staff for the 6th Cycle Housing Element. Staff also recommends the City Council adopt the Housing Element Resolution as well as findings to support amending the General Plan by adopting the 2023-2031 6th Cycle Housing Element. Additionally, the Housing Element Resolution provides authorization to City staff to make any non-substantive changes to the Housing Element that may be required by the State to achieve certification or that may be necessary to ensure internal consistency with other planning documents.

ATTACHMENTS:

1. Resolution adopting an Initial Study/Negative Declaration prepared for the 6th Cycle Housing Element, including the following exhibit:

Exhibit A Initial Study – Negative Declaration prepared for the 2023-2031 Housing Element, December 2022

2. Resolution approving the Public Hearing Draft Piedmont 2023-2031 Housing Element, including the following exhibits:

Exhibit A Public Hearing Draft 6th Cycle Piedmont Housing Element, dated 2023 (tracked changes)
Exhibit B Support for substantial compliance finding based on response to HCD comments
Exhibit C Support for substantial compliance finding based on conformance to Government Code

3. Public comment on the Initial Study/Negative Declaration received by January 9, 2023 (link)

4. Public comment on the Draft 6th Cycle Housing Element received November 15, 2022 to March 15, 2023 (link)

5. Planning Commission staff reports, January 12, 2023 (link)

6. Public comment on the Draft 6th Cycle Housing Element received December 16, 2021 through November 15, 2022 (link)
By: Kevin Jackson, Director of Planning & Building
Pierce Macdonald, Senior Planner
Agenda Report Page 8
RESOLUTION No.____

A RESOLUTION MAKING CERTAIN FINDINGS AND

ADOPTING AN INITIAL STUDY-NEGATIVE DECLARATION AS REQUIRED BY THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) IN CONNECTION

WITH THE APPROVAL OF A GENERAL PLAN AMENDMENT ADOPTING AN UPDATE OF THE HOUSING ELEMENT FOR THE PERIOD OF 2023-2031 WHEREAS, State of California housing element law, as set forth in Government Code §§ 65302 and 65580, et seq., requires the City of Piedmont to periodically prepare and update its Housing Element in its General Plan, and to establish goals, policies, and programs to accommodate the maintenance, diversification, and expansion of the City’s housing supply to accommodate the City of Piedmont’s regional housing needs allocation (RHNA) of 587 housing units, comprised of 238 above moderate income units, 92 moderate income units, 94 low income units, and 163 extremely and very low income units; and WHEREAS, Piedmont’s prior 5th Cycle Housing Element was last certified by the California Department of Housing and Community Development (HCD) in 2014, and Government Code section 65588 requires local agencies to update their housing element at least every eight years; and
WHEREAS, in compliance with State housing element law, the City of Piedmont has prepared the 2023-2031 6th Cycle Housing Element (the “6th Cycle Housing Element” or “Housing Element”); and
WHEREAS, pursuant to the California Environmental Quality Act (“CEQA”) an Initial Study was completed and following completion of the initial study, the City, acting as Lead Agency, determined that there was no substantial evidence that the project could have a significant effect on the environment. As a result, City staff prepared a Negative Declaration for the project pursuant to CEQA, which is attached as Exhibit A to this Resolution and incorporated herein by reference; and
WHEREAS, the Notice of Intent to Adopt an Initial Study and Negative Declaration for the City of Piedmont Housing Element Update was sent to the California State Clearinghouse, Alameda County Clerk, responsible agencies, trustee agencies, adjacent cities and was made available to members of the public for public comment on December 9, 2022; and WHEREAS, the 30-day public review period for the Notice of Intent to Adopt an Initial Study and Negative Declaration for the City of Piedmont Housing Element Update closed on January 8, 2023 and eight comments were received; and
WHEREAS, the comments do not require any revisions to the Negative Declaration, as set forth in detail in the staff report for this item; and
Attachment 1 Agenda Report Page 9
WHEREAS, as provided in Government Code Sections 65352 – 65352.5, the City of Piedmont referred the Housing Element to all California Native American tribes on the contact list provided by the Native American Heritage Commission and to other entities listed, and no California Native American tribe requested consultation; and WHEREAS, the City of Piedmont’s 6th Cycle Housing Element includes updated data in compliance with the State of California housing laws and provides a wide range of programs and strategies to address citywide housing needs and priorities; and WHEREAS, in accordance with Government Code Section 65585 (b), on November 18, 2022, the City submitted the draft Housing Element to the State Department of Housing and Community Development (HCD) for its review; and
WHEREAS, on December 9, 2022, the City of Piedmont published on the City website the draft 6th Cycle Housing Element submitted to the California Department of Housing and Community Development and published a Notice of Intent to Adopt an Initial Study and Negative Declaration in the newspaper of record, at City Hall bulletin boards, and in the local branch of the Oakland public library, via email to interested members of the public, and via mail to local and regional agencies, utilities, school district, tribal governments, neighboring jurisdiction, air quality district, and others; and
WHEREAS, on January 12, 2023, the Planning Commission conducted a duly and properly noticed public hearing, reviewed the Initial Study and Negative Declaration, the staff report and all attachments, and oral and written public comments; and determined the Housing Element to be consistent with State law and the General Plan of the City of Piedmont, and recommended that the City Council adopt the 2023-2031 6th Cycle Housing Element with revisions necessary to obtain certification from HCD; and
WHEREAS, on February 16, 2022, the City received a letter from HCD providing its findings regarding the draft Housing Element; and
WHEREAS, City staff reviewed the findings and revised the draft Housing Element to incorporate requested changes; and
WHEREAS, the revisions to the Housing Element do not create any new impacts not already analyzed or affect the analysis in the Negative Declaration; and WHEREAS, the City Council has reviewed and considered the information contained in the staff report, the Negative Declaration, the draft 2023-2031 Housing Element and related materials and held a duly noticed public hearing on March 20, 2023. At the hearing, all interested persons were given an opportunity to be heard. The City Council received and considered the staff report and all the information, evidence, and testimony presented in connection with this project.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Piedmont does hereby resolve, declare, determine, and order as follows:

Attachment 1 Agenda Report Page 10

1. The above recitations are true and correct and are incorporated by reference into this action.

2. In accordance with the requirements of CEQA, the City Council hereby finds as follows:

A. The City Council has considered the Initial Study-Negative Declaration and other information in the record, prior to acting upon the Housing Element Update.

B. The Initial Study-Negative Declaration prepared for the Housing Element Update have been completed in accordance with the requirements of CEQA.

C. The Initial Study-Negative Declaration prepared for the Housing Element Update represent the independent judgment and analysis of the City as lead agency for the Project.

D. The revisions to the Housing Element made after circulation of the Initial Study-Negative Declaration do not alter the analysis set forth in the Initial Study-Negative Declaration and no revisions are required to the Initial Study-Negative Declaration.

E. There is no substantial evidence in the record that the Housing Element Update will have a significant effect on the environment.

3. The City Council hereby adopts the Initial Study-Negative Declaration (Exhibit A) prepared by staff pursuant to CEQA for the 6th Cycle Housing Element for the period of 2023-2031.

4. Pursuant to CEQA Guidelines section 15091(e), the documents and other materials that constitute the record of proceedings upon which the City Council has based its adoption are located in and may be obtained from the City Clerk’s Office, City Hall, 120 Vista Avenue, Piedmont, CA 94611.

5. Staff is hereby directed to file a Notice of Determination with respect to the Initial StudyNegative Declaration with the County Clerk of the County of Alameda. [END OF RESOLUTION]
Attachment 1 Agenda Report Page 11
2023-2031 Housing Element
Initial Study – Negative Declaration
prepared by
City of Piedmont
120 Vista Avenue
Piedmont, California 94611
Contact: Kevin Jackson, AICP, Director of Planning & Building prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
December 2022
Agenda Report Page 12 Attachment 1 Exhibit A
2023-2031 Housing Element
Initial Study – Negative Declaration
prepared by
City of Piedmont
120 Vista Avenue
Piedmont, California 94611
Contact: Kevin Jackson, AICP, Director of Planning & Building prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
December 2022
Agenda Report Page 13 Attachment 1 Exhibit A
This report prepared on 50% recycled paper with 50% post-consumer content.

Agenda Report Page 14 Attachment 1 Exhibit A
Table of Contents
Acronyms and Abbreviations................................................................................................................. iii Initial Study.............................................................................................................................................1

1. Project Title.........................................................................................................................1

2. Lead Agency/Project Sponsor Name and Address..............................................................1

3. Contact Person and Phone Number ...................................................................................1

4. Project Location and Existing Setting..................................................................................1

5. 2023-2031 Housing Element Description ...........................................................................4

6. Required Approvals.......................................................................................................... 11

7. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area Requested Consultation Pursuant to Public Resources Code Section 21080.3.1? ....................................................................................................................... 12

8. Cumulative Scenario ........................................................................................................ 12 Environmental Factors Potentially Affected........................................................................................ 15 Determination ..................................................................................................................................... 15 Environmental Checklist...................................................................................................................... 17 1 Aesthetics......................................................................................................................... 17 2 Agriculture and Forestry Resources................................................................................. 21 3 Air Quality ........................................................................................................................ 25 4 Biological Resources......................................................................................................... 29 5 Cultural Resources ........................................................................................................... 33 6 Energy .............................................................................................................................. 37 7 Geology and Soils............................................................................................................. 39 8 Greenhouse Gas Emissions.............................................................................................. 45 9 Hazards and Hazardous Materials ................................................................................... 47 10 Hydrology and Water Quality .......................................................................................... 53 11 Land Use and Planning..................................................................................................... 59 12 Mineral Resources ........................................................................................................... 61 13 Noise ................................................................................................................................ 63 14 Population and Housing................................................................................................... 67 15 Public Services .................................................................................................................. 69 16 Recreation........................................................................................................................ 71 17 Transportation ................................................................................................................. 73 18 Tribal Cultural Resources................................................................................................. 77 19 Utilities and Service Systems ........................................................................................... 81 20 Wildfire ............................................................................................................................ 85 21 Mandatory Findings of Significance................................................................................. 89 Agenda Report Page 15 Attachment 1 Exhibit A
References ........................................................................................................................................... 91 Bibliography................................................................................................................................. 91 List of Preparers........................................................................................................................... 94 Tables
Table 1 RHNA Allocation and Percentage of Income Distribution for Piedmont............................5 Table 2 Strategy to Address Regional Housing Needs.....................................................................6 Table 3 Piedmont Housing Element Goals and Policies ..................................................................8 Table 4 Current Population and Housing Stock for Piedmont...................................................... 67 Table 5 2050 Plan Bay Area Population, Housing, and Employment Projections for North Alameda County............................................................................................................... 67 Figures
Figure 1 Regional Location................................................................................................................2 Figure 2 City of Piedmont Location...................................................................................................3 Agenda Report Page 16 Attachment 1 Exhibit A
Acronyms and Abbreviations
AB Assembly Bill
ABAG Association of Bay Area Governments
ADU Accessory Dwelling Unit
BAAQMD Bay Area Air Quality Management District
BFE Base Flood Elevations
BMPs best management practices
CBC California Building Code
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CFGC California Fish and Game Code
CH4 Methane
CNDDB California Natural Diversity Database
CNEL community noise equivalent level
CO2 CarbonDioxide
CO2e Carbon Dioxide Equivalent
CRHR California Register of Historical Resources
CWA Clean Water Act
DOC California Department of Conservation
DOF Department of Finance
DTSC Department of Toxic Substances Control
EBCE East Bay Community Energy
EDMUD East Bay Municipal Utility District
EPA US Environmental Protection Agency
FEMA Federal Emergency Management Agency
GHG Greenhouse Gas
GIS Geospatial Information Systems
GSA Groundwater Sustainability Agency
GWP Global Warming Potential
HCD California Departing of Housing and Community Development HFCs Hydrofluorocarbons
IPCC Intergovernmental Panel on Climate Change
LHMP Local Hazard Mitigation Plan
Agenda Report Page 17 Attachment 1 Exhibit A
LRA Local Responsibility Area
MGD Million Gallons per Day
MRP Municipal Regional Stormwater Permit
MT Million tons
N2O Nitrous Oxides
NAHC California Native American Heritage Commission
NAHC Native American Heritage Commission
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
OHP California Office of Historic Preservation
PCC Piedmont City Code
PFCs perfluorocarbons
PFD Piedmont Fire Department
PG&E Pacific Gas and Electric
PPV Peak Particle Velocity
PUSD Piedmont Unified School District
RHNA Regional Housing Needs Allocation
RMS root mean square
SB Senate Bill
SEMS Standardized Emergency Management System
SF6 sulfur hexafluoride
SFAAB San Francisco Bay Area Air Basin
SFHA Special Flood Hazard Areas
SFWQCB San Francisco Bay Regional Water Quality Control Board SLF Sacred Land File
SR State Route
SVP Society of Vertebrate Paleontology
SWPPP Storm Water Pollution Prevention Plan
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
VFHSZ Very High Fire Hazard Severity Zone
VMT Vehicle Miles Traveled
WTP Water Treatment Plan
WUI Wildland Urban Interface
Agenda Report Page 18 Attachment 1 Exhibit A
Initial Study

1. Project Title
City of Piedmont 2023-2031 Housing Element

2. Lead Agency/Project Sponsor Name and Address
City of Piedmont
120 Vista Avenue
Piedmont, California 94611
(510) 420-3040

3. Contact Person and Phone Number
Kevin Jackson, AICP, Director of Planning & Building
[email protected]
(510) 420-3039

4. Project Location and Existing Setting
The study area includes the entire City of Piedmont (hereinafter referred to as “City” or “Piedmont”). Piedmont is located in the East Bay region of the San Francisco Bay Area in northern Alameda County and encompasses approximately 1.7 square miles. Piedmont is completely surrounded by the City of Oakland, bordering the Oakland neighborhoods of the Piedmont Avenue District to the northwest, Montclair District to the east, and Crocker Highlands, Lakeshore, and Grand Lake Districts to the south and west.

The regional location of Piedmont is shown in Figure 1 and the city limits are show in Figure 2.

Existing Setting
Piedmont includes primarily single-family residential uses (approximately 68 percent of Piedmont) with the remainder occupied by schools, civic buildings, religious institutions, parks and open space, and commercial uses. There are no industrial uses in the city. Piedmont contains five city parks and other landscaped areas with wooded paths, tennis courts, children’s playgrounds, and picnic facilities. Topography in the city is variable due to its setting within the greater East Bay Hills area.

Land in Piedmont is almost entirely developed; its landlocked setting has influenced its historic development patterns and affects its potential for new housing and employment.

The housing stock of Piedmont in 2020 was made up of 3,714 (93.3 percent) single-family detached homes, 69 (1.7 percent) single-family attached homes, 117 (2.9 percent) multifamily homes with 2 to 4 units, 79 (2.0 percent) multifamily homes with 5 or more units, and no mobile homes.

The greatest concentration of non-residential uses is in the Civic Center area, where a mix of commercial, public, open space, religious, and residential uses is present. The only other area with a concentration of non-residential uses is along Grand Avenue, extending west to Beach School, Linda Agenda Report Page 19 Attachment 1 Exhibit A
Figure 1 Regional Location
Agenda Report Page 20 Attachment 1 Exhibit A
Figure 2 City of Piedmont Location
Agenda Report Page 21 Attachment 1 Exhibit A
Park, and the new Piedmont Station townhouses on the site of a former Pacific Gas & Electric (PG&E) substation. This is also where most of Piedmont’s multi-family housing is located. Open space uses are scattered around Piedmont, with the highest acreage in Moraga Canyon (City of Piedmont 2009).

5. 2023-2031 Housing Element Description
The proposed project, herein referred to as the “proposed Housing Element Update” or “proposed project,” would amend the City of Piedmont’s General Plan (hereinafter referred to as the “2009 General Plan”) by replacing the current Housing Element with the proposed 2023-2031 Housing Element. The proposed Housing Element establishes programs, policies, and actions to further the goal of meeting the existing and projected housing needs of all income levels of households in the Piedmont community and provides evidence of the City’s ability to accommodate the Regional Housing Needs Allocation (RHNA) through the year 2031, as established by the Association of Bay Area Governments (ABAG).

Background and History
The Housing Element is one of the State-mandated elements of the General Plan. The current Housing Element was adopted in December 2014 and is in effect through 2023. The Housing Element identifies Piedmont’s housing conditions and needs, and establishes the goals, objectives, and policies that comprise the City’s housing strategy to accommodate projected housing needs, including the provision of adequate housing for low-income households and for special-needs populations (e.g., unhoused people, seniors, single-parent households, large families, and persons with disabilities).

The proposed Housing Element Update would bring the element into compliance with State legislation passed since adoption of the 2015-2023 Housing Element and with the current RHNA. In December 2021, the ABAG Executive Board adopted the 6th Cycle Final RHNA, which includes a fair share allocation for meeting regional housing needs for each community in the ABAG region.

Housing Element Update Components
The proposed 2023-2031 Housing Element Update includes the following components, as required by State law:
 Evaluation of the 2015-2023 Housing Element: An evaluation of the results of the goals, policies, and programs adopted in the 2015 Housing Element that compares projected outcomes with actual achieved results.
 Demographics and Housing Needs Assessment: An analysis of the existing and projected housing needs of the community. It provides a profile of socio-demographic information, such as population characteristics, household information, housing stock, tenure, and housing affordability. The assessment also considers local special housing needs, such as seniors, farmworkers, unhoused persons, large households, and female-headed households.  Housing Capacity Analysis and Methodology: An inventory listing adequate sites that are suitably zoned and available within the planning period to meet the City’s fair share of regional housing needs across all income levels.
 Housing Resources: An identification of resources to support the development, preservation, and rehabilitation of housing.

Agenda Report Page 22 Attachment 1 Exhibit A
 Constraints to Housing Production: An assessment of impediments to housing production across all income levels covering both governmental (e.g., zoning, fees, etc.) and nongovernmental (e.g., market, environmental, etc.).
 Housing Plan: This section provides a statement of the community’s goals, quantified objectives, and policies to maintain, preserve, improve, and develop housing, as well as a schedule of implementable actions to be taken during the planning period to achieve the goals, objectives, and policies. Quantified objectives for new construction, rehabilitation, and conserved units by income category (i.e., very low, low, moderate, and above moderate) are included to make sure that both the existing and the projected housing needs are met, consistent with the City’s share of the RHNA.

Regional Housing Needs Allocation
The RHNA is a California State Housing Law requirement that is part of the periodic process of updating local general plan housing elements. It is a process that determines existing and projected housing need (i.e., RHNA allocation) for all jurisdictions in the state (including cities and unincorporated county areas) with the intent to provide opportunities for a mix of unit types, tenure, affordability, and help achieve greenhouse gas (GHG) emission reductions from cars and light trucks. The RHNA allocates housing need based on future estimates of housing unit growth need over the RHNA planning period (2023-2031).

The proposed Housing Element Update would bring the element into compliance with State legislation passed since adoption of the 2014-2023 Housing Element and with the current ABAG RHNA. ABAG has allocated the region’s 441,176 housing unit growth needs among each city and county in its region through a process called the RHNA. Piedmont’s RHNA allocation for the 2023- 2031 planning period (6th RHNA cycle) is 587 units, as shown in Table 1, which is distributed among four income categories (ABAG 2021). This allocation would be met partially with accessory dwelling units (ADU). ADUs are built on properties with existing single-family or multi-family residences and are limited in terms of square footage and location. The City estimates that ADUs would add 160 dwelling units to housing inventory by 2023.

Table 1 RHNA Allocation and Percentage of Income Distribution for Piedmont Income Level Percent of Area Median Income (AMI) Units Percent Extremely Low and Very Low <50% 163 27.8%
Low 50-80% 94 16.0%
Moderate 80-120% 92 15.7%
Above Moderate >120% 238 40.5%
Total – 587 100.0%
Source: ABAG 2021
Agenda Report Page 23 Attachment 1 Exhibit A
Meeting the RHNA
Table 2 summarizes the City’s methods for satisfying its RHNA. The City has not identified enough units through RHNA credits (projected ADU development and approved or entitled projects) to meet its 6th Cycle RHNA for the four income categories and for total units. To identify enough sites for RHNA, the City prepared an inventory of sites available and suitable for housing development.

The Sites Inventory includes capacity for 484 units. Overall, the City has capacity for 644 units across all income categories, resulting in a 10 percent, or 58 unit, excess over RHNA.

Table 2 Strategy to Address Regional Housing Needs
Extremely Low/
Very Low Income
Low
Income
Moderate
Income
Above
Moderate Income Total
RHNA 163 94 92 238 587
Approved/Entitled Projects – – – 1 1
Accessory Dwelling Units (ADUs) 48 48 48 16 160
Sites Inventory1,2 1803 67 237 484
Total Capacity 276 115 253 644
Surplus 19 23 16 58

1. See Appendix B of the Housing Element, Table B-10 for the complete inventory

2. See Appendix B of the Housing Element, Section B.3.1 for information on the Specific Plan

3. For calculation purposes, extremely low, very low, and low-income totals were grouped.

Source: City of Piedmont, LWC 2022
The Housing Element discusses meeting the City’s RHNA through the following means:
 Vacant and non-vacant sites identified in the Housing Element Sites Inventory  Permitted density changes
 Specific Plan for four City-owned parcels in northeastern Piedmont  ADUs
These are further discussed in the following sections.

Vacant and Underutilized Sites
The proposed Housing Element Update identifies vacant and underutilized parcels suitable to meet the RHNA allocation during the 2023-2031 period. Parcels were determined to be vacant based on City GIS data, which classified vacant parcels from a previous vacant land inventory. Then City staff reviewed each parcel by APN and address to confirm vacant status of all parcels.

Since land in Piedmont is generally developed, the City also identified nonvacant sites to analyze in the sites inventory. Parcels that were considered during this phase included:
 Churches and church parking lots (AB 1851: Bill signed on September 28, 2020, outlining parking requirements for religious institution affiliated housing development projects)  City-owned land (subject to replacement or relocation of facilities for city operations)  Multiple sites under the same ownership
 Parking lots
 Public land (e.g., EBMUD properties)
Agenda Report Page 24 Attachment 1 Exhibit A
 Underutilized commercial and mixed-use sites
Nonvacant sites are relied on to accommodate more than 50 percent of Piedmont’s lower income RHNA. Nonvacant parcels primarily include relatively large properties (over 0.5 acre) irrespective of current use, underutilized sites with surface parking and commercial buildings where the existing uses are of marginal economic viability, or the structures are at or near the end of their useful life.

To count toward the RHNA allocation, sites must be in a land use category that meets a minimum residential density standard, have a minimum lot size, and be either vacant or not been developed to the maximum capacity allowed by the zoning category and can provide the potential for more residences on a site. Minimum residential density includes proposed increases to zoning parameters, including 20 percent density bonus, as discussed below.

Proposed Density Changes
Under State law, when a local jurisdiction cannot demonstrate that there are sufficient vacant or underutilized sites to adequately meet their RHNA allocation, a ‘rezoning program’ must be put into place. A zoning amendments program ensures that there are enough sites with sufficient densities to address the housing need identified through the RHNA. Rezoning means changing the zoning designation of land to increase areas or zoning districts with higher permitted residential densities (changing land from a single-family zone to multi-family zone, for example).

The proposed Housing Element Update does not involve rezoning but does include programs that call for increasing density allowances for housing in zones A, B, C, and D to facilitate the construction of new housing. These programs would take place after adoption of the Housing Element and will require additional environmental compliance.

The programs include:
 Religious Institution Affiliated Housing in Zone A: Program 1.D of the proposed Housing Element calls for amendments to the Zoning Ordinance to allow religious institution affiliated housing development projects by right in Zone A as accessory to a permitted religious institution use, allow these uses at densities up to 21 units per acre, and update the parking requirements consistent with State law.
 Increasing Allowed Density in Zone B (Public Facilities Zone): Program 1.F of the proposed Housing Element calls for a Zoning Ordinance amendment to increase the allowed density in Zone B to 60 dwelling units per acre maximum.
 Increasing Allowed Density in Zone C (Multi-Family Residential): Program 1.G of the proposed Housing Element calls for a Zoning Ordinance amendment to increase the maximum allowed residential density in Zone C to 60 dwelling units per acre.  Increasing Allowed Density in Zone D (Commercial/Mixed Use Zone). Program 1.H of the Housing Element calls for a Zoning Ordinance amendment to allow residential densities up to 81 units per acre in Zone D.

Specific Plan
Program 1.L in Section IV of the proposed Housing Element Update includes a potential Specific Plan for four City-owned parcels in Moraga Canyon located in the northeastern portion of Piedmont. One approximately 12-acre site on the northern side of Moraga Avenue is currently utilized for a combination of uses such as City vehicle storage, Coaches Field (soccer/soft ball fields), a skate park, recreational parking, and temporary sales including a tree lot. Nearly 7 acres of this site is Agenda Report Page 25 Attachment 1 Exhibit A
undeveloped, with a significant portion with steep grades extending north to the city limits. The site is off of Moraga Avenue at Red Rock Road. Directly to the east, along and north of Moraga Avenue is another City-owned 1.5-acre site which is currently vacant and partially developed with a small parking lot. On the south side of Moraga Avenue are two City-owned parcels that together total just under 5 acres that comprise an open space area known as Blair Park. In conjunction with on-going on-site City facilities and services, these four sites provide a viable development opportunity for mixed-income residential uses in a variety of house forms, including single family, duplex, and multifamily types.

Accessory Dwelling Units (ADUs)
ADUs, also referred to as granny flats or secondary units, provide an affordable housing option and are an important tool to help meet the housing needs in communities.1 The proposed Housing Element Update includes programs for the City to incentivize and promote ADUs, such as by new incentives for rent-restriction ADUs that are affordable to low and very low income households and by requiring the construction of an ADU or Junior ADU with the construction of a new residence, whether on vacant property or on any property that is proposed to be redeveloped.

Housing Element Update Goals and Policies
Table 3 includes a full list of Housing Element Update goals and associated policies.

Table 3 Piedmont Housing Element Goals and Policies
Topic Goals and Supportive Policies
Goal 1: New Housing Construction
Policy 1.1: Adequate Sites Maintain an adequate number of sites and opportunities for the development of housing consistent with the Regional Housing Needs Allocation.

Policy 1.2: Housing Diversity Continue to maintain planning, zoning, and building regulations that accommodate the development of housing for households at all income levels.

Policy 1.3: Promoting Residential
Use
Continue to allow residential uses in all of Piedmont’s zoning districts.

Policy 1.4: Context-Appropriate
Programs
Participate in those State and federal housing assistance programs that are most appropriate to Piedmont’s character and that recognize the unique nature of affordable housing opportunities in the City.

Policy 1.5: Accessory Dwelling Units Continue to allow accessory dwelling units “by right” in all residential zones within the City, subject to dimensional and size requirements, parking standards, and an owner occupancy requirement for either the primary or secondary unit.

Policy 1.6: Accessory Dwelling Units
in New or Expanded Homes
Strongly encourage the inclusion of accessory dwelling units when new homes are built and when existing homes are expanded.

Policy 1.7: Housing in Commercial
Districts
Ensure that local zoning regulations accommodate multi-family residential uses on commercial properties in the City, including the addition of apartments to existing commercial buildings.

Policy 1.8: Mobile and
Manufactured Housing
As required by State law, allow mobile and manufactured housing on all residential areas in the City, subject to the same standards as other homes in that Zone.
1 The State enacted legislation in both 2017 and 2019 to further assist and support the development of ADUs, including “by right” approval for one-bedroom units less than 850 square feet and two-bedroom units less than 1,000 square feet. In January 2020, the City Council adopted an ordinance amending the City’s Zoning Ordinance to comply with the latest State laws governing ADUs and Junior ADUs (JADUs). The City’s ADU ordinance allows (City Code Division 17.38 Accessory Dwelling Units) for units up to 1,000 square feet and up to 50 percent of the living area of the primary unit.

Agenda Report Page 26 Attachment 1 Exhibit A
Topic Goals and Supportive Policies
Policy 1.9: Maintaining Buildable
Lots
Discourage lot mergers, lot line adjustments, and other changes to legally conforming parcels which would reduce the number of buildable lots in the City, except when consolidating lots for multi-family housing production. Encourage lot splits where feasible.

Policy 1.10: Intergovernmental
Coordination
Coordinate local housing efforts with the California Department of Housing and Community Development, the County of Alameda, and adjacent cities. Where City-sponsored housing programs are infeasible due to limited local resources, explore the feasibility of participating in programs initiated by other jurisdictions.

Policy 1.11: Intergovernmental
Coordination
Coordinate local housing efforts with the California Department of Housing and Community Development, the County of Alameda, and adjacent cities. Where City-sponsored housing programs are infeasible due to limited local resources, explore the feasibility of participating in programs initiated by other jurisdictions.

Policy 1.12: Multi-family Housing
City Service Fee
Require developers of multi-family housing, including mixed-use multi-family housing, to contribute to the costs of City services and infrastructure.

Policy 1.13: Remediation Grants Pursue grants to support remediation and the study feasibility of redevelopment of non-vacant sites, including brownfields, gas stations, and other sites with reuse opportunities.

Goal 2: Housing Conservation
Policy 2.1: Encouraging Private
Reinvestment
Strongly encourage private property owner reinvestment in the City’s housing stock.

Policy 2.2: Public Funds for Housing
Maintenance
Support housing stock maintenance and repair through government funding such as Community Development Block Grants when private funding is not available.

Policy 2.3: Availability of Small,
More Affordable Homes
Encourage the preservation of Piedmont’s existing stock of small homes and historic homes. Promote the affordability of smaller-sized homes Policy 2.4: Code Enforcement Enforce local building codes to ensure that housing is safe and sanitary and to protect the character of Piedmont neighborhoods. Promptly investigate all reports of nuisances and require the abatement of such situations, as needed.

Policy 2.5: Use of Original Materials Allow the use of original materials and methods of construction when alterations to homes are proposed unless a health or safety hazard would occur.

Policy 2.6: Preservation of MultiFamily HousingPreserve existing multi-family rental housing, including non-conforming multifamily units in the single-family zone. Require the review of permits that would demolish a housing unit, including non-conforming units in the single-family zone.

Policy 2.7: Home Occupations Continue to encourage Piedmont residents to maintain home offices as a means of making housing more affordable for persons who would otherwise need to rent office space outside the home.

Policy 2.8: Conservation of Rental
Housing Opportunities
Conserve rental housing opportunities by monitoring and limiting the use of existing or potential rental properties, such as accessory dwelling units and rooms in shared homes, for short-term stays.

Goal 3: Affordable Housing Opportunities
Policy 3.1: Rent-Restricted
Accessory Dwelling Units
Encourage the creation of rent restricted accessory dwelling units for low and very low-income households through incentive-based programs such as reduced parking requirements and more lenient floor area standards.

Policy 3.2: Occupancy of Permitted
Accessory Dwelling Units
Encourage property owners with registered accessory dwelling units to actively use these units as rental housing rather than leaving them vacant or using them for other purposes.

Policy 3.3: Legalization of ADUs Allow for and offer incentives for owners of unintended and/or illegal accessory dwelling units to apply for permits to convert into a permitted unit.

Agenda Report Page 27 Attachment 1 Exhibit A
Topic Goals and Supportive Policies
Policy 3.4: Accessory Dwelling Unit
Building Regulations
Maintain building code regulations which ensure the health and safety of accessory dwelling unit occupants and the occupants of the adjacent primary residence. Implement Building Code regulations intended to facilitate “tiny home” construction.

Policy 3.5: Density Bonuses Consistent with State law, allow density bonuses (such as allowances for additional square footage or lot coverage) for multi-family projects which incorporate affordable or special needs housing units.

Policy 3.7: Room Rentals Continue to allow the renting of rooms in private homes to provide housing opportunities for single people. Recognize the potential for rented rooms to meet the housing needs of single low income, very low income, and extremely low-income Piedmont residents.

Policy 3.8: Inclusionary Housing Encourage the provision of affordable housing as part of market rate multifamily housing projects.

Goal 4: Elimination of Housing Constraints
Policy 4.1: Communicating Planning
and Building Information
Encourage public understanding of the planning and building processes in Piedmont to facilitate permit processing and reduce project costs and delays.

Policy 4.2: Planning and Building
Standards
Ensure that planning and building standards, development review procedures, and fees do not form a constraint to the development, conservation, and rehabilitation of housing, or add unnecessarily to the cost of building or improving housing.

Policy 4.3: Expeditious Permitting Promote the expeditious processing and approval of residential projects that are consistent with the General Plan, the Zoning Ordinance, and Objective Design Standards and Design Guidelines (for projects that do not add a new housing unit).

Policy 4.4: Updating Standards and
Codes
Maintain updated codes and standards for residential development to reflect changes in State and federal law, new technology, and market trends.

Policy 4.5: Code Flexibility Allow certain development standards to be relaxed to accommodate affordable housing, where there is no threat the health, safety, and welfare of the City or potential for adverse impacts on the surrounding neighborhood.

Policy 4.6: Housing Coordinator Designate the Planning and Building Director as the City’s Housing Coordinator.

Policy 4.7: Infrastructure
Maintenance
Support the regular maintenance of infrastructure, including water, sewer, drainage, streets, and sidewalks, so that these facilities are available when new housing is proposed.

Policy 4.8: Infrastructure
Prioritization for Lower Income
Housing.

Consistent with Government Code §65589.7, prioritize water and sewer services to help meet Piedmont’s share of the regional share of lower-income housing units. Work with East Bay Municipal Utility District (EBMUD) water service.

Policy 4.9: Housing Finance
Programs
Participate in appropriate County programs which address financial constraints for first time homebuyers, including down payment assistance, silent second mortgages, Mortgage Credit Certificates, and Mortgage Revenue Bonds.

Goal 5: Special Needs Populations
Policy 5.1: Retrofits for Diminished
Mobility of Piedmont Residents
Ensure that planning and building regulations accommodate the retrofitting of homes to meet the needs of aging or disabled residents.

Policy 5.2: Accessory Dwelling
Units, Shared Housing, and Seniors
Encourage accessory dwelling units and shared housing as strategies to help seniors age in place. Accessory dwelling units and shared housing can provide sources of additional income for senior homeowners and housing resources for seniors seeking to downsize but remain in Piedmont.

Policy 5.3: Reasonable
Accommodation
Provide reasonable accommodation for people with disabilities, including developmental disabilities, in the City’s rules, policies, practices and procedures related to zoning, permit processing and building codes.

Agenda Report Page 28 Attachment 1 Exhibit A
Topic Goals and Supportive Policies
Policy 5.4: Extremely Low-Income
Residents
Strive to meet the needs of extremely low income Piedmont residents, especially single parents, seniors on fixed incomes, and persons in financial crisis or at risk of losing their homes.

Policy 5.5: Regional Approaches to
Homelessness
Actively cooperate with and participate in regional discussions and programs addressing homelessness and the need for emergency shelter and supportive housing in the East Bay.

Policy 5.6: Foreclosure Support State, regional, and countywide initiatives to reduce the risk of foreclosure and to assist those facing foreclosure.

Policy 5.7: Persons with Disabilities Address the unique housing needs of Piedmont residents with disabilities, including those with developmental disabilities.

Goal 6: Sustainability and Energy
Policy 6.1: Energy-Efficient Design Require all new housing to be designed to encourage energy efficiency. Building design and construction methods should promote and support energy conservation.

Policy 6.2: Energy-Efficient
Materials
Encourage major additions and remodeling projects to use windows, building materials, ventilation systems, and appliances which reduce home heating and cooling costs and conserve energy resources.

Policy 6.3: Weatherization Encourage weatherization of existing homes to reduce heating and cooling costs and lower home energy bills.

Policy 6.4: Renewable Energy Maintain development regulations which accommodate the installation of solar panels and other devices which result in lower energy costs for homeowners and renters.

Policy 6.5: Energy Retrofits Support the use of federal, State, county, and utility-sponsored programs which provide financial assistance or incentives for energy retrofits.

Policy 6.6: Housing and Climate
Change
Recognize the link between housing and climate change in the City’s decisionmaking process. Specifically, the City should strive to create additional local housing opportunities for persons employed within Piedmont in order to reduce commuting and associated greenhouse gas emissions. A particular emphasis should be placed on housing for municipal and school district employees, since these are the largest employers in the City.

Policy 6.7: Water Conservation Encourage drought-tolerant and bay friendly landscaping as a way to conserve water, reduce greenhouse gas emissions associated with water transportation, and reduce homeowner water bills, thereby freeing up more income for other purposes.

Source: City of Piedmont. Piedmont Draft 2023-2031 Housing Element.

6. Required Approvals
With recommendations from the Planning Commission, the City Council would need to take the following future discretionary actions in conjunction with the Housing Element Update:
 Adoption of the 2023-2031 Housing Element of the General Plan The Draft Housing Element has been submitted to the HCD for review and comment. The City will seek certification of the Final Housing Element from the HCD subsequent to the City’s adoption.

Agenda Report Page 29 Attachment 1 Exhibit A

7. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area
Requested Consultation Pursuant to Public Resources
Code Section 21080.3.1?
On December 9, 2021, the City of Piedmont contacted California Native American Tribal governments by sending an Assembly Bill (AB) 52 and Senate Bill (SB) 18 notification letter via email to tribes with an affiliation with the project area based on a list provided by the Native American Heritage Commission (NAHC). Under AB 52, Native American tribes have 30 days to respond and request further project information and request formal consultation. Under SB 18, Native American tribes have 90 days to respond to request consultation. The City did not receive a request for formal consultation under AB 52 or SB 18. Therefore, no California Native American Tribes traditionally or culturally affiliated with the project area have requested consultation pursuant to Public Resources Code Section 21080.3.1.

8. Cumulative Scenario
In addition to the specific impacts of individual plans or projects, CEQA requires environmental documents to consider potential cumulative impacts of the proposed plan. CEQA defines “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts. Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed plan or project and other nearby plans and projects. For example, traffic impacts of two nearby plans or projects may be less than significant when analyzed separately but could have a significant impact when analyzed together. Cumulative impact analysis allows the environmental document to provide a reasonable forecast of future environmental conditions and can more accurately gauge the effects of a series of plans or projects.

CEQA requires cumulative impact analysis to consider either a list of planned and pending plans and projects that may contribute to cumulative effects, or a forecast of future development potential.

Because the proposed plan is a General Plan Housing Element update, cumulative impacts are treated differently than they would be for a specific development. For general plan amendments, CEQA Guidelines Section 15130 provides the following direction relative to cumulative impact analysis:

Impacts should be based on a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or areawide conditions contributing to the cumulative impact.

Because the proposed Housing Element Update is essentially a set of goals and policies to enable future projects that could occur within the timeframe of the General Plan, the proposed Housing Element Update itself represents the cumulative development scenario for the reasonably foreseeable future in the City. Therefore, the analysis presented in this Initial Study generally represents a cumulative analysis of the City and the surrounding region over the Housing Element planning horizon of 2031.

Agenda Report Page 30 Attachment 1 Exhibit A
In instances where other cumulative development in neighboring cities or a specific region (e.g., hydrologic region or air basin) could contribute to impacts generated by the proposed Housing Element Update, those impacts, as well as the context, are discussed in the cumulative impact discussion that follows the plan-specific impacts in each section.

The analysis included in each cumulative impact section analyzes whether, after implementation of mitigation that minimize environmental effects, the residual impacts of the proposed Housing Element Update would cause a cumulatively significant impact or would contribute considerably to existing or anticipated cumulatively significant effects. Where the proposed Housing Element Update would so contribute, additional mitigation is recommended where feasible.

Agenda Report Page 31 Attachment 1 Exhibit A
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Agenda Report Page 32 Attachment 1 Exhibit A
Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse Gas
Emissions
□ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources □ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire □ Mandatory Findings of Significance
Determination
Based on this initial evaluation:
■ I find that the proposed plan COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
□ I find that although the proposed plan could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed plan MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed plan MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

Agenda Report Page 33 Attachment 1 Exhibit A
□ I find that although the proposed plan could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed plan, nothing further is required.

Agenda Report Page 34 Attachment 1 Exhibit A
Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Except as provided in Public Resources Code
Section 21099, would the project:
a. Have a substantial adverse effect on a
scenic vista? □ □ □ ■
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway? □ □ □ ■
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project is
in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality? □ □ □ ■
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ □ ■
Environmental Setting
Scenic views generally refer to visual access to, or the visibility of, a particular natural or man-made visual resource from a given vantage point or corridor. Focal views focus on a particular object, scene, setting, or feature of visual interest. Panoramic views, or vistas, provide visual access to a large geographic area, for which the field of view can be wide and extend into the distance.

Panoramic views are usually associated with vantage points looking out over urban or natural areas that provide a geographic orientation and view not commonly available. Examples of panoramic views might include an urban skyline, a valley, a mountain range, the ocean, or other water bodies.

The City’s terrain rises gently from west to east, with the steepest slopes located along canyons and ravines. The combination of knolls, low ridges, and valleys creates scenic vistas throughout the city (City of Piedmont 2009a).

Piedmont’s visual image is largely defined by relatively large single-family homes constructed during the early 20th century. This is characterized by spacious front and rear yards, pedestrian oriented streets with sidewalks, large street trees, and a traditional development scale. Five neighborhood Agenda Report Page 35 Attachment 1 Exhibit A
typologies with different architectural styles are commonly found in the city: bungalow and cottage neighborhoods, streetcar suburbs, estate neighborhoods, hillside neighborhoods, and mid-century neighborhoods.

There are no designated or eligible State scenic highways in the City. The closest designated State scenic highway is Interstate 580 (I-580) located 0.3 mile west of the City, and the closest eligible State scenic highway is State Route 13 (SR 13), located 0.6 mile east of the City.

Impact Analysis
a. Would the project have a substantial adverse effect on a scenic vista? A scenic vista is a view from a public place (roadway, designated scenic viewing spot, etc.) that is expansive and considered important. It can be obtained from an elevated position (such as from the top of a hillside) or it can be seen from a roadway with a longer-range view of the landscape. A viewshed is an area of the landscape visible from a particular location or series of points (e.g., an overlook or a trail, respectively).2A viewshed may be divided into viewing distances called foreground, middle ground, and background. Usually, the closer a resource is to the viewer, the more dominant it appears visually, and thus it has greater importance to the viewer than something farther away. A common set of criteria identifies the foreground as 0.25 to 0.5 mile from the viewer; the middle ground is 3 to 5 miles away, and the background extends away to the horizon.

An adverse effect would occur if a proposed plan would block or otherwise damage a scenic vista upon implementation. While the varying topography of Piedmont can block surrounding views, some long range scenic views are visible from public places throughout Piedmont. In particular, some of the housing sites may have background long-range views of the San Francisco Bay to the west.

Because the Housing Element Update is a policy document that does not involve or approve physical development (e.g., construction of housing or infrastructure), it would not result in impacts to scenic vistas. Further, future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific development review, including design review pursuant to Piedmont City Code (PCC) Division 17.66, to address potential impacts related to aesthetics. Development proposals would be subject to City regulations, including standards that govern scenic vistas. Future development would be required to comply with Action 27.A (Viewshed Ordinance) and Action 27.B (Rooftop Structures) of the Design and Preservation Element of the Piedmont General Plan, which outlines standards for neighborhood compatibility and guidelines for rooftop structures so views are not unreasonably obstructed. There would be no impact.

NO IMPACT
2 United States Department of Transportation Federal Highway Administration. 2015. Guidelines for the Visual Impact Assessment of Highway Projects. https://www.environment.fhwa.dot.gov/env_topics/other_topics/VIA_Guidelines_for_Highway_Projects.aspx (accessed July 2022).

Agenda Report Page 36 Attachment 1 Exhibit A
b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Scenic corridors consist of land visible from the highway right-of-way and are comprised primarily of natural features and landforms. When a city or county nominates an eligible scenic highway for official designation, it must identify and define the scenic corridor of the highway. Scenic corridors are defined as corridors that possesses highly scenic and natural features, as viewed from the highway. Topography, vegetation, viewing distance, and/or jurisdictional lines determine the corridor boundaries. Under the “Corridor Protection Program,” a city must adopt ordinances, zoning, and/or planning policies that are designed to protect the scenic quality of an officially designated corridor.

Because the Housing Element Update is a policy document that does not involve or approve physical development, it would not result in impacts to scenic resources. Further, future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review to address potential impacts related to scenic resources.

Development proposals would be subject to City regulations, including standards that govern substantially damaging a state scenic corridor. There would be no impact.

NO IMPACT
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
The Housing Element Update does not propose specific projects but puts forth goals and policies that encourage housing and various aspects of new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not, in and of itself, result in impacts to visual character. Further, future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review, including design review, to address potential impacts related to visual character. Development proposals would be subject to the City’s Zoning Ordinance and adopted development guidelines, including standards that govern visual quality and community design. Goal 28 and associated policies of the Design and Preservation Element of the Piedmont General Plan aim to integrate new residential construction consistent with the neighborhood character, and outline requirements for scale, height, style, setbacks, garages, open space, and construction material. Future development would also be required to comply with PCC Section 3.22, which governs viewsheds and ensures the protection of views, as well as the City’s Zoning Ordinance, which lists design guidelines for Zones A through E of Piedmont. There would be no impact.

NO IMPACT
Agenda Report Page 37 Attachment 1 Exhibit A
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts to light and glare. In addition, future development would be reviewed for consistency with regulations related to light and glare contained in the Chapter 17 (Planning and Land Use) of the PCC, which incorporate extensive design guidelines for single-family and multi-family residential development. Specifically, pursuant to Section 17.66.060, future projects requiring discretionary approval may not be approved unless the design of the project has little or no effect on the neighboring properties’ access to direct and indirect light. Additionally, Policy 29.8 of the Design and Preservation Element of the Piedmont General Plan discourages excessive or overly bright exterior lighting that could interfere with motorist safety, and requires exterior lighting to be designed to avoid spillover on to adjacent properties. Therefore, there would be no impacts related to light and glare.

NO IMPACT
Agenda Report Page 38 Attachment 1 Exhibit A
2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest
use? □ □ □ ■
Environmental Setting
Piedmont is completely surrounded by the City of Oakland and is primarily a residential community.

According to the California Department of Conservation (DOC), Piedmont is entirely covered with urban and built-up land and does not contain agricultural land (DOC 2018).

Agenda Report Page 39 Attachment 1 Exhibit A
Impact Analysis
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
The Housing Element Update is a policy document and does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Furthermore, there is no active Farmland or Williamson Act contract lands in or adjacent to Piedmont. The most recent DOC California Important Farmland Finder maps show that there is no active farmland in Piedmont.

Piedmont consists of Urban and Built-Up Land (DOC 2018). Therefore, the Housing Element Update would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), or conflict with existing zoning and existing Williamson Act contracts, and no impact would occur.

NO IMPACT
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? “Forest land” is defined in PRC Section 12220(g) pursuant to the California Forest Legacy Program Act of 2007 as land that can support 10 percent or more native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.

The Housing Element Update is a policy document and does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Further, there is no land in Piedmont designated as forest land, or timberland zoned as Timberland Production (California Department of Fish and Wildlife [CDFW] 2022). The City’s zoning map indicates that there are no areas within Piedmont zoned for forestry, timberland, or timberland production. Therefore, the Housing Element Update would not conflict with existing zoning for, or cause rezoning of, forest land, or timberland zoned Timberland Production, and no impact would occur.

NO IMPACT
e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Further, there is no land in Piedmont designated as forest land, or timberland zoned as Timberland Production. Additionally, there is no land designated as Farmland (DOC 2018). Therefore, the Housing Element Update would not result in other changes in the existing environment which, due to their location or nature, could result in Agenda Report Page 40 Attachment 1 Exhibit A
conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use, and no impact would occur.

NO IMPACT
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3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Conflict with or obstruct implementation
of the applicable air quality plan? □ □ □ ■
b. Result in a cumulatively considerable net
increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality standard? □ □ □ ■
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ □ ■
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ □ ■
Environmental Setting
Piedmont is located in the San Francisco Bay Area Air Basin (SFBAAB). The SFBAAB is bordered on the west by the Pacific Ocean and extends to nine counties throughout the San Francisco Bay Area.

The SFBAAB is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD).

The BAAQMD is responsible for development of the regional Air Quality Management Plan (AQMP), which is a comprehensive program for compliance with all federal and State air quality planning requirements including California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). The most recently adopted AQMP is the 2017 Clean Air Plan (BAAQMD 2017a).

The BAAQMD is in non-attainment for the federal standards for ozone and PM2.5 and the State standards for ozone, PM10, and PM2.5 (BAAQMD 2017b). The San Francisco Bay Area Air Basin (The Basin) is designated unclassifiable or in attainment for all other federal and State standards. This analysis conforms to the methodologies recommended in the BAAQMD’s CEQA Air Quality Guidelines (2017) and supplemental guidance provided by the BAAQMD, including recommended thresholds for emissions associated with both construction and operation of the project (BAAQMD 2017c).

Impact Analysis
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not Agenda Report Page 43 Attachment 1 Exhibit A
result in impacts to air quality. In addition, Action 15B (Construction Dust Controls) of the Natural Resources and Sustainability Element of the Piedmont General Plan includes requirements to minimize airborne dust and particulate matter from construction activities, consistent with the BAAQMD CEQA Air Quality Guidelines, such as covering stockpiles and trucks that are hauling dirt and debris and avoiding earthmoving on windy days (City of Piedmont 2009a). Adherence to the BAAQMD Basic Construction Mitigation Measures for future development would further reduce fugitive dust emissions (PM10 and PM2.5). Future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review to address potential impacts related to air quality. There are no impacts associated with the Housing Element Update.

NO IMPACT
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
c. Would the project expose sensitive receptors to substantial pollutant concentrations? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. In addition, short-term air quality impacts resulting from construction of the sites, such as dust generated by clearing and grading activities, exhaust emissions from gas- and diesel-powered construction equipment, and vehicular emissions associated with the commuting of construction workers will be subject to BAAQMD rules and protocols. Similarly, operational impacts would be addressed by provisions in the General Plan and other regulations and standards that govern air quality in Piedmont. Any impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project.

Therefore, the adoption of the Housing Element Update would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard or expose sensitive receptors to substantial pollutant concentrations. There are no impacts associated with the Housing Element Update.

NO IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The occurrence and severity of potential odor impacts depends on a number of factors, including the nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity of the receiving location, each contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying and cause distress among the public and generate citizen complaints.

NO IMPACT
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4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ □ □ ■
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ □ ■
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ □ ■
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ □ ■
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ □ ■
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
Agenda Report Page 47 Attachment 1 Exhibit A
Environmental Setting
Although Piedmont is highly urbanized, the City still contains many natural open spaces and distinct ecological communities. Woodlands are one of the principal habitat types in Piedmont, which are generally located in Piedmont Park, along creeks and ravines, and on larger lots in the Estate Zone.

Common trees include live oak, black oak, redwood, bay laurel, buckeye, alder, willow, and sycamore; common shrubs include camelia, poison oak, blackberry, and English ivy. Woodlands support deer, opossums, skunks, raccoons, squirrels, and many types of birds. Grasslands are another principal habitat type which occur in the small portion of Mountain View Cemetery. Plant species commonly found include oat grasses, rye grasses, herbs, forbs, and bromes, while wildlife species commonly found include those similar to woodland species, as well as snakes, lizards, wild turkeys, and raptors such as turkey vultures and red-tailed hawks. Another principal habitat type located in Piedmont are wetlands. According to the U.S. Fish and Wildlife Service (USFWS), a freshwater forested shrub wetland is located on a linear five-acre area along Indian Gulch to the rear of residences in the 100 block of St. James Drive, the unit block of LaSalle, and the 200 block of Indian Road. Species found in freshwater wetland include frogs, newts, snails, water insects, and turtles (City of Piedmont 2009a).
“Endangered” species are those considered in imminent danger of extinction due their limited numbers. “Threatened” species refers to those likely to become endangered within the foreseeable future, primarily on a local scale. “Sensitive” species are those that are naturally rare or have been locally depleted or put at risk by human activities. According to the Natural Resources and Sustainability Element of the Piedmont General Plan, the only special-status species mapped as being potentially present in Piedmont on the California Natural Diversity Database (CNDDB) is the silver-haired bat, a coastal forest dweller that feeds over streams, ponds, and open brushy areas.

The silver-haired bat was last observed in Piedmont in October 1920.

Five main creeks traverse the city limits: Indian Gulch, Wildwood Creek, Bushy Dell Creek, Pleasant Valley Creek, and Cemetery Creek. Sausal Creek is located outside city limits but drains a small area along Park Boulevard. Piedmont’s creeks, with the exception of a narrow strip of land along Park Boulevard, drain to Lake Merritt. Much of the native vegetation surrounding the creeks, streams, and drainages within Piedmont has been removed and most of the streams and drainages have been funneled into underground storm drains (City of Piedmont 2009a).

Impact Analysis
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? c. Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Agenda Report Page 48 Attachment 1 Exhibit A
d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? The proposed Housing Element Update does not propose specific projects but puts forth goals and policies that encourage various aspects of new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts to biological resources. In addition, future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review to address potential impacts. Short-term impacts resulting from construction of the sites would be subject to State and City regulations. Similarly, operational impacts would be addressed by provisions in the Piedmont General Plan and other regulations and standards that govern biological resources in Piedmont and the region. Specifically, Policy 13.3 of the Natural Resources and Sustainability Element serves to protect creeks through enforcing setbacks for development near creek banks; Policy 13.4 aims to conserve native vegetation, particularly in woodland areas that support birds and wildlife; and Policy 13.5 aims to protect special-status species. Additionally, Action 13.A requires a biological assessment for projects that could alter or damage special-status species habitats, and Action 13.D enforces watercourse protection standards and requires a permit for projects that modify watercourse flow or carried out within a watercourse setback. Future projects would also be subject to permitting pursuant to the Clean Water Act and CFGC. Requirements commonly required under the CFGC and CWA include measures to protect streams and bodies of water along with riparian habitats.

Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project. The proposed Housing Element Update would have no impact to candidate, sensitive or special status species, riparian habitat, state or federally protected wetland or wildlife movement or corridors.

NO IMPACT
e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
The Housing Element Update, in and of itself, does not propose the development of any specific site, rather it includes policies and programs to encourage housing within the City. Piedmont currently has not implemented a Tree Preservation Ordinance and does not regulate tree removal on private property. However, Goals 13 and 14 of the Natural Resources and Sustainability Element of the Piedmont General Plan require the City to maintain and enhance street and park trees to improve the environment and provide habitat. On-going implementation of Piedmont General Plan goals and policies through site-specific design review and use permits would reduce any potential impact to locally significant trees. Therefore, the Housing Element Update would have not conflict with local policies or ordinances such as a Tree Preservation Ordinance and there would be no impact.

NO IMPACT
Agenda Report Page 49 Attachment 1 Exhibit A
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Piedmont has no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the draft Housing Element Update would not conflict with any local policies or ordinances protecting biological resources. All development would be required to comply with federal, State, and local regulations. There would be no impact.

NO IMPACT
Agenda Report Page 50 Attachment 1 Exhibit A
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5? □ □ □ ■
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ □ □ ■
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ □ □ ■
Environmental Setting
CEQA requires that a lead agency determine whether a project could have a significant effect on historical resources (PRC, Section 21084.1), unique archaeological resources (PRC Section 21083.2 [g]), and tribal cultural resources (PRC Section 21074 [a][1][A]-[B]). A historical resource is a resource listed in or determined to be eligible for listing in the California Register of Historical Resources (CRHR) (Section 21084.1), a resource included in a local register of historical resources (Section 15064.5[a][2]), or any object, building, structure, site, area, place, record, or manuscript that a lead agency determines to be historically significant (Section 15064.5[a][3]).

Impacts to significant cultural resources that affect the characteristics of any resource that qualify it for the NRHP or adversely alter the significance of a resource listed in or eligible for listing in the CRHR are considered a significant effect on the environment. These impacts could result from physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired (CEQA Guidelines Section 15064.5 [b][1]). Material impairment is defined as demolition or alteration in an adverse manner [of] those characteristics of a historical resource that convey its historical significance and that justify its inclusion or eligibility for inclusion in the CRHR (CEQA Guidelines Section 15064.5[b][2][A]).

Agenda Report Page 51 Attachment 1 Exhibit A
Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
A review of the NRHP, California Office of Historic Preservation (OHP) website, and the OHP Built Environment Resource Directory identifies three known historical resources located in Piedmont.

One is listed in the NRHP and the CRHR, Wetmore House at 342 Bonita Avenue. Two historical resources have been formally determined eligible for listing in the NRHP and, as a result, have been automatically listed in the CRHR: Piedmont City Hall and Fire Station at 120 Vista Avenue and Piedmont Community Church at 400 Highland Avenue. Piedmont also contains over 170 existing Centennial Houses that are over 100 years old, with the greatest concentration in Central Piedmont along streets such as Hillside, Bonita, Highland, Mesa, and Oakland Avenues, and in the area near Grand Avenue, particularly along Sunnyside, Rose, Lake, and Kingston (City of Piedmont 2009b).

There are also several estates on larger lots east of Piedmont Park that are over 100 years old.

Buildings over 45 years of age are required to be recorded and evaluated for historical resources eligibility under the CRHR, and buildings over 50 years of age can be evaluated for eligibility for listing in the NRHP.

The City of Piedmont requested a review of the Sacred Land File (SLF) and received a response from the NAHC on November 19, 2021, which indicated that Piedmont was negative for Sacred Lands.

The City does not maintain an inventory of archaeological sites, but it is assumed that archaeological sites are present in Piedmont and the surrounding areas. Therefore, there is potential to encounter unidentified resources on future sites. However, future development would be on sites that have been previously developed and disturbed, therefore, it is likely that prior grading and construction activities as well as modern use of the sites would have either removed or destroyed archaeological resources within surficial soils.

The Housing Element Update does not propose specific projects but puts forth goals and policies that encourage various aspects of new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not create adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5 or cause a substantial adverse change in the significance of an archaeological resource. In addition, future development would be required to comply with federal, State, and local regulations and policies, including those policies in the City’s General Plan.

Specifically, Goals 30 and 31 of the Design and Preservation Element of the Piedmont General Plan serves to preserve Piedmont’s archaeological and cultural resources and Goal 28 outlines design guidelines reinforced by zoning standards to ensure protection of older building stock and original architectural features. In addition, future development requiring discretionary approval accommodated under the Housing Element Update would be required to undergo project-specific developmental review to address potential impacts. Therefore, the adoption of the Housing Element Update would have no impact on historical and archaeological resources.

NO IMPACT
Agenda Report Page 52 Attachment 1 Exhibit A
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
The Housing Element Update does not propose the development of any specific sites, and future development requiring discretionary approval would be subject to developmental review and required to adhere to the City’s policies and goals designed to reduce impacts to historic and cultural resources. The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not disturb any human remains, including those interred outside of formal cemeteries.

Individual projects are not proposed as part of the Housing Element Update. Future development would be subject to federal, State, and local regulations and policies, including those policies in the City’s General Plan. Projects would be required to comply with CEQA Guidelines Section 15000 et seq. which set procedures for notifying the County Coroner and NAHC for identification and treatment of human remains if they are discovered during construction. Therefore, the adoption of the Housing Element Update would not disturb human remains and there would be no impacts.

NO IMPACT
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6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ □ ■
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ □ ■
Environmental Setting
Most of the electricity generated in California is from natural gas-fired power plants, which provided approximately 48 percent of total electricity generated in 2020. In 2020, California used 272,575 gigawatt hours (GWh) of electricity and produced 70 percent of the electricity it used and imported the rest from outside the state (California Energy Commission [CEC] 2020).

In 2018, Senate Bill 100 accelerated the State’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy and zero-carbon resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045. Two electricity providers serve Piedmont: East Bay Community Energy (EBCE) and Pacific Gas and Electric (PG&E). PG&E is also the natural gas provider for the City.

As of 2020, EBCE provided 54 percent of clean energy mostly sourced from renewable energy and large hydropower and aims to purchase 100 percent clean power by 2030 (EBCE 2020). EBCE offers 100 percent renewable energy services to member cities, and all residential customers in Piedmont would be placed in the Renewable 100 Plan (100 percent renewable) while commercial customers would be placed in the Bright Choice Plan (40 percent renewable) (EBCE 2021). However, residential customers have the option to opt out of the Renewable 100 program and enroll in the Bright Choice Program which would be supplied by 40 percent renewable energy. In 2020, PG&E’s default power mix offered 31 percent renewable energy and they also offered customers an option for power mix of 100 percent solar energy (PG&E 2022).

Agenda Report Page 55 Attachment 1 Exhibit A
Impact Analysis
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
The Housing Element Update is a policy document that does not involve or approve physical development and therefore would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. Future development requiring discretionary approval would be required to undergo project-specific evaluation to quantify specific impacts to energy consumption, which would occur during the permitting process for that project. Individual projects would be required to comply with PCC Section 8.02.010, which requires adherence to the California Building Code, Title 24, Part 6 known as the “California Energy Code.”, as well as Title 24, Part 11 which outlines the “Green Building Standards Code” or “CALGreen.” Additionally, pursuant to PCC Section 8.02.070 and the City’s Reach Code, future newly constructed low-rise buildings and new detached ADUs would be required to be all electric and would not include natural gas. Future development would also be required to adhere to requirements regarding solar systems pursuant to the most updated Title 24 standards. Moreover, Goal 6 and associated policies and programs of the Housing Element Update would encourage the use of energy efficient designs and materials, as well as renewable energy in order to reduce the consumption of electricity. The Housing Element Update would also prioritize future development projects close to transit areas and existing commercial/retail, recreational, and institutional land uses, which would reduce trip distances and encourage the use of alternative modes of transportation such as bicycling and walking. These factors would minimize the potential for future development to result in the wasteful or unnecessary consumption of vehicle fuels.

Therefore, there would be no impact.

NO IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. Future development would be subject to the energy conservation requirements of the California Energy Code, the California Green Building Standards Code, and local policies such as the PCC and the City’s Climate Action Plan

2.0 (CAP 2.0). Therefore, there would be no impact.

NO IMPACT
Agenda Report Page 56 Attachment 1 Exhibit A
7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:

1. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial evidence
of a known fault? □ □ □ ■

2. Strong seismic ground shaking? □ □ □ ■

3. Seismic-related ground failure,
including liquefaction? □ □ □ ■

4. Landslides? □ □ □ ■
b. Result in substantial soil erosion or the
loss of topsoil? □ □ □ ■
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ □ ■
d. Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building
Code (1994), creating substantial direct
or indirect risks to life or property? □ □ □ ■
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ □ ■
Agenda Report Page 57 Attachment 1 Exhibit A
Environmental Setting
Piedmont is located on the East Bay Plain (the Plain), a flat area that extends 50 miles from Richmond in the north to San Jose in the south. The Plain is part of the larger Coast Ranges geomorphic province, one of the eleven geomorphic provinces of California (California Geological Survey 2002). The Coast Ranges extend along the majority of California’s coast from the CaliforniaOregon border to Point Arguello in Santa Barbara County in the south and consist of northwesttrending mountain ranges and valleys. The Coast Ranges are composed of Mesozoic and Cenozoic sedimentary, igneous, and metamorphic strata. The eastern side is characterized by strike-ridges and valleys in the Upper Mesozoic strata. The Coast Ranges province runs parallel to and overlaps the San Andreas Fault in some areas, although not in Piedmont (California Geological Survey 2002).

Piedmont is located in the United States Geological Survey’s (USGS) Oakland East 7.5-minute topographic quadrangle. The area is typified by low topographic relief, with gentle slopes to the west in the direction of San Francisco Bay. Piedmont’s terrain rises gently from west to east, with the steepest slopes located along canyons and ravines (City of Piedmont 2009a). Geologic maps indicate that the Plain is underlain primarily by Quaternary alluvial deposits (Graymer 2000).

Piedmont is underlain with sandstone of the Novato Quarry terrane and Pleistocene alluvial fan and fluvial deposits.

Additionally, Piedmont is located near the San Andreas, Calaveras and Hayward faults, one of the most seismically active regions in the United States. The San Andreas Fault is located approximately 15 miles west of Piedmont. The Calaveras Fault lies on the edge of the Diablo Range, about 15 miles to the east. The main trace of the Hayward Fault runs about 0.25 mile east of Piedmont, along an alignment that roughly parallels SR 13. There are two primary fault zones, the Chabot Fault Zone and Hayward Fault Zone, that run nearest to Piedmont.

Impact Analysis
a.1. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? As discussed above under Environmental Setting, two primary fault zones, the Chabot Fault Zone and Hayward Fault Zone, run closest to Piedmont. The Hayward Fault and surrounding area is a designated Alquist-Priolo Zone. However, Piedmont is not directly in or above the Hayward Fault Zone.

NO IMPACT
Agenda Report Page 58 Attachment 1 Exhibit A
a.2. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? Although Piedmont is not directly in or above the Hayward Fault Zone, the Hayward Fault runs directly east of Piedmont, resulting in a potential for strong seismic ground shaking along its alignment. The most intense ground-shaking scenario mapped in Piedmont assumes a 6.9 magnitude earthquake on the Hayward Fault system. The predicted ground-shaking from such an earthquake would be “very violent” or “violent” throughout Piedmont (ABAG 2021).

The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to geologic hazards. Future development accommodated under the Housing Element Update would be subject to adopted development guidelines and required to adhere to California Building Code (Title 24, Part 2) requirements, policies in the Environmental Hazards Element of the Piedmont General Plan, and applicable State and local regulations. PCC Section 8.02.020(W) would require site-specific geotechnical evaluation for individual development projects located on sites with a slope of 20 percent or greater or at discretion of the City to identify the degree of potential hazards, design parameters for the project based on the hazard, and describe appropriate design measures to address hazards. Additionally, Policy 18.1 of the Environmental Hazards Element of the Piedmont General Plan serves to restrict development on unstable sites; Policy 18.2 enforces seismic design and construction standards which meet or exceed standards established by the CBC; and Policy 18.4 requires site-specific soils reports and geologic studies. Therefore, there would be no impacts related to earthquake faults and seismic ground shaking.

NO IMPACT
a.3. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction? a.4. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
According to the DOC, landslide risk is low throughout most of Piedmont (DOC 2015). Piedmont is not within an area that has many earthquake-induced landslide reports. According to the MTC/ABAG Hazard Viewer Map, Piedmont is considered to have low susceptibility to rain-induced landslides as well. Earthquake hazard maps produced by ABAG indicate that a large Hayward Fault quake would trigger violent shaking throughout Piedmont and a high risk of liquefaction across Piedmont (ABAG 2021).

The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to liquefaction or landslides. Development accommodated under the Housing Element Update would be subject to adopted development guidelines and required to adhere to CBC requirements, policies in the Environmental Hazards Element of the Piedmont General Plan, and applicable State and local regulations. PCC Section 8.02.020(W) and Policy 18.4 of the Environmental Hazards Element of the Piedmont General Plan would require site-specific soils reports and geologic studies in instances where development may be exposed to substantial geologic or seismic hazards, including ground shaking and landslides, and would ensure any Agenda Report Page 59 Attachment 1 Exhibit A
identified hazards are properly mitigated. Therefore, the Housing Element Update would result in no impacts.

NO IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to substantial soil erosion or the loss of topsoil. In addition, future development would be required to comply with CBC, Appendix Section J110, Erosion Control Standards, which ensures appropriate erosion and stormwater pollution control during grading and construction activities.

Additionally, future construction activities that occur on more than one acre are required to obtain a National Pollutant Discharge Elimination System (NPDES) Construction General Permit. NPDES requires the development of a storm water pollution prevention plan (SWPPP), which includes best management practices (BMPs) to reduce erosion and topsoil loss from stormwater runoff. BMPs generally include an effective combination of erosion and sediment controls, which include barriers such as silt fences, hay bales, drain inlet protection, or gravel bags. Furthermore, PCC Section 30.10 would require erosion and sediment control plans to be incorporated into building permits as applicable. Any impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project. The Housing Element Update would have no impact to substantial soil erosion or the loss of topsoil.

NO IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Impacts related to landslides and liquefaction are addressed under Impacts a.3. and a.4.; therefore, this discussion focuses on impacts related to unstable soils as a result of lateral spreading, subsidence, or collapse. Lateral spreading occurs as a result of liquefaction; accordingly, liquefaction-prone areas would also be susceptible to lateral spreading. Subsidence occurs at great depths below the surface when subsurface pressure is reduced by the withdrawal of fluids (e.g., groundwater, natural gas, or oil) resulting in sinking of the ground. Expansive soils swell with increases in moisture content and shrink with decreases in moisture content. These soils usually contain high clay content. Expansive soils can cause foundations, basement walls and floors to crack, causing substantial structural damage. As such, structural failure due to expansive soils near the ground surface is a potential hazard.

The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to lateral spreading, subsidence, or collapse. Further, future development would be required to comply with the CBC’s (California Building Code) minimum standards for structural design and site development. Therefore, CBC-required incorporation of soil treatment programs (replacement, grouting, compaction, drainage control, etc.) in the excavation and construction plans can achieve an acceptable degree of soil stability to address site-specific soil conditions. In addition, future development would be required to adhere to PCC Section 8.02.020(W) and Policy 18.4 of the Environmental Hazards Element of the Piedmont General Plan which would require site-specific Agenda Report Page 60 Attachment 1 Exhibit A
soils reports and geologic studies, minimizing impacts related to unstable soils. Therefore, the Housing Element Update would have no impacts related to unstable soils as a result of lateral spreading, subsidence, or collapse.

NO IMPACT
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Soils that volumetrically increase (swell) or expand when exposed to water and contract when dry (shrink) are considered expansive soils. The potential for soil to shrink and swell depends on the amount and types of clay in the soil. Highly expansive soils can cause structural damage to foundations and roads without proper structural engineering and are less suitable or desirable for development than non-expansive soils because of the necessity for detailed geologic investigations and costlier grading applications.

In addition, future projects would be required to adhere to State and local requirements, such as the CBC, and PCC Section 8.02.020(W) and Policy 18.4 of the Environmental Hazards Element of the Piedmont General Plan, which would ensure that impacts from development on expansive soils are minimized by requiring the submittal and review of site-specific soils reports and geologic studies prior to construction. Such evaluations must contain recommendations for ground preparation and earthwork specific to the site, which then become an integral part of the construction design. The CBC includes requirements to address soil-related hazards. Typical measures to treat hazardous soil conditions involve removal of soil or fill materials, proper fill selection, and compaction. In cases where soil remediation is not feasible, the CBC requires structural reinforcement of foundations to resist the forces of expansive soils. Therefore, the Housing Element Update would have no impacts related to expansive soils.

NO IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to septic tanks and wastewater disposal. In addition, future development is anticipated to be connected to the municipal waste disposal system. Therefore, the Housing Element Update would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater and no impact would occur.

NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Agenda Report Page 61 Attachment 1 Exhibit A
Paleontological resources, or fossils, are the evidence of once-living organisms preserved in the rock record. They include both the fossilized remains of ancient plants and animals and the traces thereof (e.g., trackways, imprints, burrows, etc.). Paleontological resources are not found in “soil” but are contained within the geologic deposits or bedrock that underlies the soil layer. According to Society of Vertebrate Paleontology (SVP) standards, four geologic units underlying Piedmont were assigned low paleontological sensitivity: Holocene alluvial fan and fluvial deposits (Qhaf), sandstone of the Novato Quarry terrane (Kfn), Franciscan Complex mélange (KJfm), and chert of the Franciscan Complex (fc), while one geologic unit was assigned high paleontological sensitivity, Pleistocene alluvial fan and fluvial deposits (Qpaf) (SVP 2010).

Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts to paleontological resources or unique geologic features. In addition, future development requiring discretionary approval would be subject to development plan review to determine potential concerns related to paleontological resources or unique geologic features based on site-specific locations and development design. Therefore, the adoption of the Housing Element Update would not directly or indirectly destroy a unique paleontological resource or site, or unique geologic feature and no impact would occur.

NO IMPACT
Agenda Report Page 62 Attachment 1 Exhibit A
8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment? □ □ □ ■
b. Conflict with an applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases? □ □ □ ■
Environmental Setting
Gases that absorb and re-emit infrared radiation in the atmosphere are called GHGs. The gases widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere, and natural processes, such as oceanic evaporation, largely determine its atmospheric concentrations. GHGs are emitted by natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are usually by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and landfills. Human-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6 (U.S. EPA 2021). Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP.

Carbon dioxide has a 100-year GWP of one. By contrast, methane has a GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis (IPCC 2021).3 Based on the City’s 2020 GHG inventory, Piedmont’s in-territory (i.e., emissions occurring within City boundaries) emissions totaled approximately 33,402 metric tons of CO2e (MT CO2e). This was a 32 percent reduction below 2005 levels of 48,818 MT CO2e, and 2.3 percent reduction compared to 2019 levels of 34,197 MT CO2e. The reduction is largely a result of Piedmont’s enrollment in EBCE’s 100 percent Renewable Energy service plan (carbon-free service). 97 percent of emissions for residential energy was attributed to natural gas use, and the remaining 3 percent to residential 3 The Intergovernmental Panel on Climate Change’s (2021) Sixth Assessment Report determined that methane has a GWP of 30. However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s (2007) Fourth Assessment Report. Therefore, this analysis utilizes a GWPs from the Fourth Assessment Report.

Agenda Report Page 63 Attachment 1 Exhibit A
electricity use. Residential electricity emissions have decreased by 95 percent since 2005 (City of Piedmont 2022a).

In 2020, the sectors that contributed the most to Piedmont’s community in-territory GHG emissions were transportation and mobile sources (50 percent) and residential energy (46 percent).

Transportation and mobile sources resulted in approximately 16,407 MT CO2e, while residential energy resulted in approximately 14,877 MT CO2e. The remaining sectors that contributed to Piedmont’s community in-territory GHG emissions include fugitive emissions (2 percent), solid waste (1 percent), commercial energy (1 percent), and water and wastewater (less than 1 percent) (City of Piedmont 2022a).

Impact Analysis
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
b. Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
In April 2017, BAAQMD adopted the 2017 Clean Air Plan. The goals of the plan are to protect public health and the climate. Consistent with the GHG reduction targets adopted by the state of California, the plan lays the groundwork for a long term effort to reduce Bay Area GHG emissions 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050 (BAAQMD 2017a). As of 2022, BAAQMD has updated their approach on evaluating communitywide planning documents, such as a General Plan or Housing Element Update. It is recommended that each plan is evaluated based on whether they would be consistent with California’s long-term goal of achieving carbon neutrality by 2045 (BAAQMD 2022). For impacts to be considered less than significant, the communitywide planning document must demonstrate that GHG emissions from the jurisdiction will decline consistent with California’s GHG reduction targets of 40 percent below 1990 levels by 2030 and carbon neutrality by 2045 (BAAQMD 2022).

6.4 of the Housing Element Update, which outlines requirements for the installation of solar panels and other devices which would also lower energy costs for future homeowners and renters.

Development within Piedmont would obtain electrical power from EBCE or PG&E. EBCE currently source all their power from renewable sources for residential customers under the Renewable 100 program. Customers that choose to opt out of the Renewable 100 Plan would be placed in the Bright Choice Plan which utilizes 40 percent renewable energy. The Housing Element Update would not generate GHG emissions that may have a significant impact on the environment and would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Therefore, there would be no impact related to GHGs.

NO IMPACT
Agenda Report Page 64 Attachment 1 Exhibit A
9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ □ ■
b. Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment? □ □ □ ■
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within

0.25 mile of an existing or proposed
school? □ □ □ ■
d. Be located on a site that is included on a
list of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ □ □ ■
e. For a project located in an airport land
use plan or, where such a plan has not
been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ □ ■
g. Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving wildland
fires? □ □ □ ■
Agenda Report Page 65 Attachment 1 Exhibit A
Environmental Setting
The Department of Toxic Substances Control (DTSC) regulates hazardous waste in California primarily under the authority of the Resource Conservation and Recovery Act and the California Health and Safety Code. The DTSC also administers the California Hazardous Waste Control Law to regulate hazardous wastes. The Hazardous Waste Control Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.

The DTSC EnviroStor database contains information on properties in California where hazardous substances have been released or where the potential for a release exists. The California State Water Resources Control Board (SWRCB) GeoTracker database contains information on properties in California for sites that require cleanup, such as leaking underground storage tank (LUST) sites, which may impact, or have potential impacts, to water quality, with emphasis on groundwater.

According to databases of hazardous material sites maintained by the DTSC (EnviroStor) and the SWRCB (GeoTracker), Piedmont has the following types of hazardous sites that are still active or need further investigation: underground storage tanks (USTs), voluntary cleanup, school investigation, tiered permit, and one state response site (DTSC 2021; SWRCB 2021). These sites are dispersed throughout Piedmont. Existing sites that may potentially contain hazardous land uses in Piedmont include large and small-quantity generators of hazardous waste, such as dry cleaners, gas stations and other industrial uses. According to DTSC and SWRCB, there are 17 open sites containing or potentially containing hazardous materials contamination located in Piedmont including four cleanup program sites, 12 LUST cleanup sites, and one school investigation program site which would focus on sites that have been cleaned up to a level that protects the students and staff who will occupy the new school.

Emergency Preparedness
As required by State law, the City has adopted a Standardized Emergency Management System (SEMS) for managing response to multi-agency and multi-jurisdictional emergencies, and to facilitate communications and coordination among all levels of government and affected agencies (Fire Chief Dave Brannigan 2022). In addition, the City has prepared the Get Ready, Piedmont disaster preparedness guide which describes the planned response to emergencies associated with natural and man-made disasters and technological incidents. The Local Hazard Mitigation Plan (LHMP) also identifies all critical facilities and infrastructure and establishes goals to increase emergency response and enhance recovery (City of Piedmont 2019).

Impact Analysis
a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to hazardous material transport, use, or disposal. In addition, the use of potentially hazardous materials during construction of future development would be required to comply with all federal, State, and local regulations regarding the handling of potentially hazardous materials.

Agenda Report Page 66 Attachment 1 Exhibit A
Likewise, the transport, use, and storage of hazardous materials during any future construction would be required to comply with all applicable federal and State laws, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Material Management Act, and California Code of Regulations Title 22. Future development would also be guided by the Piedmont LHMP.

Use of any common household hazardous materials, such as cleaning and degreasing solvents, fertilizers, pesticides, and other materials used in regular property and landscaping maintenance, would also be subject to compliance with applicable federal and State laws, listed previously, as well as Policy 20.1 of the Environmental Hazards Element of the Piedmont General Plan, for handling, storage, and disposal of hazardous materials, as well as Policies 20.2 and 20.3, which outline requirements for transporting hazardous materials and requirements for ensuring hazardous building materials are properly handled and disposed. Potential for hazardous impacts from future development would be evaluated on a project-by-project basis. Therefore, there would be no impact.

NO IMPACT
b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to upset or accidental release of hazardous materials. Further, the transport, use, and storage of hazardous materials during the construction of future housing would be conducted in accordance with all applicable federal and State laws, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Material Management Act, and California Code of Regulations Title 22.

In addition, future development would be required to comply with Policy 20.1 of the Environmental Hazards Element of the Piedmont General Plan, which regulates handling, storage, and disposal of hazardous materials, as well as Policies 20.2 and 20.3, which outline requirements for transporting hazardous materials and ensuring hazardous building materials are properly handled and disposed.

Therefore, no impact would occur.

NO IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Piedmont currently has eight schools: six schools under the Piedmont Unified School District and two private schools (Corpus Christi School and Montessori School). The Housing Element Update in and of itself does not propose any development and therefore would have no impact on existing or proposed schools. As discussed above, the Housing Element Update would not involve the use or transport of large quantities of hazardous materials. Therefore, no impact would occur.

NO IMPACT
Agenda Report Page 67 Attachment 1 Exhibit A
d. Would the project be located on a site that is included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
As discussed in the Environmental Setting above, Piedmont contains hazardous sites that are still active or require further investigation. Existing sites that may potentially contain hazardous land uses in Piedmont include large and small-quantity generators of hazardous waste, such as former and existing dry cleaners, gas stations and other industrial uses. The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts on hazardous waste sites or create a hazard to the public or environment. In addition, for any future development that could occur on hazardous materials sites, in accordance with existing regulations, the City would coordinate with other agencies to address contamination of soil and groundwater from hazardous materials on various sites and require that contamination be cleaned up to the satisfaction of the City and other responsible agencies prior to issuance of any permits for new development.

Additionally, Policy 20.4 of the Environmental Hazards Element of the Piedmont General Plan maintains planning and zoning procedures to protect the public from possible exposure to hazardous chemicals, and Policy 20.6 ensures that any underground storage tanks containing hazardous materials are properly installed, used, removed, and monitored. Therefore, there would be no impact.

NO IMPACT
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? In addition to the Housing Element being a policy document that does not involve or approve physical development, Piedmont is not located within an airport land use plan, or within 2 miles of a public or private airstrip. The nearest airport is the Oakland International Airport which is located approximately 8 miles south of the city limits. Therefore, the Housing Element Update would not result in a safety hazard for people residing or working in Piedmont, and there would be no impact.

NO IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to emergency response plans and emergency evacuation plans. Further, implementation of the SEMS, Get Ready, Piedmont disaster preparedness guide, and LHMP would provide guidance during unique situations requiring an unusual or extraordinary emergency response. Additionally, as part of standard development procedures, plans would be submitted for review and approval to ensure that all new development would have adequate emergency access and escape routes in compliance with existing City regulations. Lastly, for the Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program includes a goal to improve pedestrian and vehicular movement to ensure safe evacuation routes and provide optimal Agenda Report Page 68 Attachment 1 Exhibit A
emergency response. The Housing Element Update would not introduce features or policies that would preclude implementation of or alter these policies or procedures. There would be no impact.

NO IMPACT
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
As discussed in Section 20, Wildfire, southeastern Piedmont lies within a Local Responsibility Area (LRA) Very High Fire Hazard Severity Zone (VHFHSZ) as designated by CalFire (CalFire 2022), and the entire City of Piedmont is designated a wildland urban interface (WUI), according to the Environmental Hazards Element of the Piedmont General Plan. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to loss, injury, or death caused by wildland fires. Further, future development would be required to comply with City Ordinance #505, Chapter 6.1, which enforces weed abatement regulations to reduce the loss of life and property by controlling fuels that could cause or support wildfire. Future development would also be required to adhere to Goal 19 and Policies 19.1, 19.2 and 19.4 of the Environmental Hazards Element of the Piedmont General Plan. Policy 19.1 enforces the use of fireresistant building materials, fire sprinklers, non-combustible roofing materials, and other fire suppression and risk-reduction measures; Policy 19.2 implements vegetation management programs to reduce the fuel load and potential for wildfires; and Policy 19.4 ensures review of development applications by the Piedmont Fire Department to verify that response times will be acceptable, emergency access will be adequate, water supply and fire flow will be sufficient, vegetation clearances will be maintained, and appropriate construction materials will be used.

Additionally, future development would be required to comply with PCC Chapter 8, which adopts the California Fire Code to ensure development is constructed to safeguard life and property from wildfire hazards. Therefore, there would be no impact.

NO IMPACT
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10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality? □ □ □ ■
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ □ ■
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
(i) Result in substantial erosion or
siltation on- or off-site; □ □ □ ■
(ii) Substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or off-site; □ □ □ ■
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or □ □ □ ■
(iv) Impede or redirect flood flows? □ □ □ ■
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ □ ■
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan? □ □ □ ■
Agenda Report Page 71 Attachment 1 Exhibit A
Environmental Setting
Water Supply
Piedmont’s potable water supply is provided by the East Bay Municipal Utility District (EBMUD).

Approximately 90 percent of the EBMUD water supply originates from the melting snowpack of the Sierra Nevada. The principal water source is the Mokelumne River watershed, a 575-square mile area located in Alpine, Amador, and Calaveras Counties. Water is stored in reservoirs in the Sierra foothills and is transported by aqueduct to filter plants and reservoirs in the East Bay Hills. The other 10 percent of EBMUD’s water comes from runoff on protected East Bay Area watershed lands (EBMUD 2020). The water is treated at one of six water treatment plants (WTP) before delivery to customers. EBMUD has water rights to 325 million gallons per day (MGD) from the Mokelumne River, subject to the availability of Mokelumne River runoff and numerous flow release obligations.

EBMUD’s secondary water supply comes from local runoff from the East Bay area watersheds, which is stored in the terminal reservoirs within EBMUD’s service area. Water from local runoff is dependent on hydrologic conditions and terminal reservoir storage availability. Local runoff supplies the East Bay, on average of 23 MGD during normal hydrologic years.

Surface Water
Piedmont is located on the eastern portion of the San Francisco Bay Area and is surrounded by the City of Oakland. There is one primary watershed within the city limits. The Indian Gulch/Pleasant Valley Creek Watershed covers about 3 square miles draining much of Piedmont and parts of the Lower Hills District in the City of Oakland. The watershed in Piedmont utilizes four small creeks that converge downstream and flow into eastern Lake Merritt, and from there into the San Francisco Bay (Alameda County 2022).

Piedmont contains six principal creeks: Indian Gulch, Wildwood Creek, Bushy Dell Creek, Pleasant Valley Creek, Cemetery Creek, and Sausal Creek, all of which flow west from Piedmont and into eastern Lake Merritt which later releases into the San Francisco Bay. Four of the six creeks located in Piedmont are part of the Indian Gulch/Pleasant Valley Creek Watershed.

Groundwater
Piedmont lies within the East Bay Plain Subbasin for which the EBMUD serves as the Groundwater Sustainability Agency (GSA). Water supply in Piedmont is also provided by EBMUD. Most of the water delivered by EBMUD originates from the Mokelumne River watershed, and the remaining water originates as runoff from the protected watershed lands and reservoirs in the East Bay Hills.

Supplemental groundwater projects would allow EBMUD to be flexible in response to changing external conditions, such as single-year or multiple-year droughts. For example, the Bayside Groundwater Project will allow EBMUD to bank water during wet years for extraction, treatment, and use during dry years. Construction of the project was completed in 2010, and the EBMUD operated in injection mode during wet years (2018 and 2019) when surplus water was available for storage. However, no groundwater pumping has been conducted from the project as a drinking water supply permit is required to extract groundwater for public water supply (EBMUD 2020).

Water Quality
The San Francisco Bay region’s immediate watershed is highly urbanized, resulting in contaminant loads from point and nonpoint sources. Stormwater runoff pollutants vary with land use, topography, and the amount of impervious surface, as well as the amount and frequency of rainfall Agenda Report Page 72 Attachment 1 Exhibit A
and irrigation practices. Typically, runoff in developed areas contains oil, grease, litter, and metals accumulated in streets, driveways, parking lots, and rooftop. It also contains pollutants applied to landscaped areas. All stormwater runoff generated in Piedmont eventually discharges into San Francisco Bay. The runoff is conveyed by storm drains, open channel creeks, and culverted creeks to the Bay. The San Francisco Bay Regional Water Quality Control Board (SFBRWQCB) is the primary agency charged with protecting and enhancing surface and ground water quality in the region (City of Piedmont 2009c).

The SFBRWQCB monitors surface water quality through implementation of the Basin Plan and designates beneficial uses for surface water bodies and groundwater. Four of the waterways within the Indian Gulch/Watershed are aboveground and have been assigned some beneficial uses by the SFBRWQCB.

Flooding
The Federal Emergency Management Agency (FEMA) establishes base flood elevations (BFE) for 100-year and 500-year flood zones and establishes Special Flood Hazard Areas (SFHA). SFHAs are those areas within 100-year flood zones or areas that will be inundated by a flood event having a one percent chance of being equaled or exceeded in any given year. The 500-year flood zone is defined as the area that could be inundated by the flood which has a 0.2 percent probability of occurring in any given year, or once in 500 years, and is not considered an SFHA. There are no portions of Piedmont located within the flood hazard zones as mapped by FEMA (City of Piedmont 2009c).

Dam Inundation
Flooding could potentially result from the failure of Tyson Lake dam or the collapse of EBMUD reservoir tanks in the hills above Piedmont. Estates Dam and Lake Temescal present additional risks, though only the Tyson Lake Dam inundation area intersects Piedmont. The probability of dam or tank failure is extremely low. Tyson Lake and its associated dam are below the size threshold requiring monitoring by the State Department of Water Resources Division of Dam Safety. The dam is periodically inspected on behalf of the Tyson Lake Homeowners Association. In the event of dam failure, water would cross Hampton Field Park and then follow LaSalle to Indian Gulch, potentially damaging homes in its path (City of Piedmont 2009c).

The probability of flooding from EBMUD tanks is greatly diminished by the fact that the Piedmont Reservoir (on Blair Avenue) is empty and the Dingee Reservoir is being decommissioned. Moreover, EBMUD Reservoir #1 on Estates Drive is planned for replacement with two reinforced concrete water tanks. In the event the Estates Reservoir (or the replacement tanks) collapsed, water would follow the streambed between Glen Alpine and Sea View, cross Hampton Road, and follow St. James to Indian Gulch. In the event the future Piedmont Reservoir tank collapsed, water would flow into Moraga Canyon (City of Piedmont 2009c
Agenda Report Page 73 Attachment 1 Exhibit A
Impact Analysis
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts that violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. In addition, future development would be subject to compliance with existing regulations, standards, and guidelines established by the federal, State, and local agencies in addition to the goals and policies in the General Plan and PCC related to water quality. This includes compliance with the requirements of the SWRCB Construction General Permit, which requires preparation and implementation of a SWPPP for projects that disturb one acre or more of land. The SWPPP must include erosion and sediment control BMPs that would meet or exceed measures required by the Construction General Permit, as well as those that control hydrocarbons, trash, debris, and other potential construction-related pollutants. Post-construction stormwater performance standards are also required to specifically address water quality and channel protection events. Implementation of these BMPs would prevent or minimize environmental impacts and ensure that discharges during the construction phase of new development would not cause or contribute to the degradation of water quality in receiving waters.

Future development would also be subject to the SFBWQCB Order No. R2-2012-0060, General Waste Discharge Requirements for Discharge or Reuse of Extracted Brackish Groundwater, Reverse Osmosis Concentrate Resulting from Treated Brackish Groundwater, and Extracted Groundwater from Structural Dewatering Requiring Treatment (Groundwater General Permit). The Groundwater General Permit requires dischargers to obtain an Authorization to Discharge, treat effluent to meet water quality-based effluent limitations, and comply with the Monitoring and Reporting Program.

Further, future development would be required to comply with existing programs and permits such as the Municipal Regional Stormwater NPDES Permit (No. CAS612008). Development design would include BMPs to avoid adverse effects associated with stormwater runoff quality. Specifically, future development would be required to implement LID Measures and on-site infiltration, as required under the C.3 provisions of the Municipal Regional Stormwater Permit (MRP). Additionally, future development would be required to comply with regulations outlined in Chapter 30, Stormwater Management and Discharge Control, of the PCC. Therefore, the Housing Element Update would not violate any water quality standards or waste discharge requirements, and there would be no impact.

NO IMPACT
Agenda Report Page 74 Attachment 1 Exhibit A
b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not, in and of itself, result in impacts that would substantially decrease groundwater supplies or interfere substantially with groundwater recharge that would impede sustainable groundwater management of the basin, or conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. In addition, future development would be required to comply with Provision C.3 of the MRP which promotes infiltration. Implementation of LID measures would increase absorption of stormwater runoff and the potential for groundwater recharge. Additionally, Piedmont is under the jurisdiction of the SFBRWQCB, which is responsible for preparing the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan designates beneficial uses of water in the region and establishes narrative and numerical water quality objectives. The Basin Plan serves as the basis for the SFBRWQCB’s regulatory programs and incorporates an implementation plan for achieving water quality objectives. Future development would be required to adhere to State and local water quality standards in order to ensure it would not substantially deplete groundwater supplies or interfere with the objectives and goals in the Basin Plan. Therefore, there would be no impact.

NO IMPACT
c(i) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
c(ii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? c(iii) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
c(iv) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts that would substantially alter the existing drainage pattern of a site or area, resulting in substantial Agenda Report Page 75 Attachment 1 Exhibit A
erosion, flooding, surface runoff, or redirection of flood flows. In addition, pursuant to PCC Section

30.7, future projects would be required to comply with a National Pollutant Discharge Elimination System (NPDES) permit issued for discharge, as well as BMPs for construction projects adopted by the Alameda Countywide Clean Water Program pursuant to PCC Section 30.10.3. Examples of BMPs include erosion control, non-stormwater erosion control, sediment control, slope stabilization guidance, tracking control, materials and waste management, and wind erosion control (Alameda Countywide Clean Water Program 2017). Operators of a construction site would also be responsible for preparing and implementing a SWPPP that outlines project specific BMPs to control erosion, sediment release, and otherwise reduce the potential for discharge of pollutants in stormwater.

Therefore, the Housing Element Update would not generate a substantial increase in runoff that would result in substantial erosion, siltation, flooding on- or off-site; or increase polluted runoff.

There would be no impact.

NO IMPACT
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not, in and of itself, result in impacts regarding flood hazards. In addition, future development would be reviewed for consistency with federal, State, and local requirements to limit flood hazards, including release of pollutants. As discussed in the Environmental Setting above, there are no portions of Piedmont located within the flood hazard zones as mapped by FEMA. Future development would be required to comply with PCC Section 5.14, which contains standards for construction in flood zones, including using building materials and techniques and ensures that flood-resistant design occurs per the most restrictive provisions available. Additionally, Policy 19.6 of the Environmental Hazards Element of the Piedmont General Plan serves to ensure that runoff from development is directed to places where it can be absorbed into the ground, detained in rain barrels or cisterns, or directed toward storm drains, which would reduce the risk of flooding. The City has also implemented the Piedmont LHMP which provides an analysis of potential hazards to assist the City in reducing risk and preventing loss from natural hazard events, including floods and mitigation strategies. Therefore, the Housing Element Update would not result in impacts related to the release of pollutants due to project inundation.

NO IMPACT
Agenda Report Page 76 Attachment 1 Exhibit A
11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect? □ □ □ ■
Environmental Setting
Piedmont is divided into five zones: Zone A (Single-Family Residential Zone), Zone B (Public Facilities Zone), Zone C (Multi-Family Residential Zone), Zone D (Commercial and Mixed-Use Commercial/Residential Zone), and Zone E (Single-Family Residential Estate Zone). More than 95 percent of Piedmont’s single-family homes are located in Zone A. Multi-family dwellings are generally located in Zone C (City of Piedmont 2022b). Open space uses are scattered around Piedmont, with the highest acreage in Moraga Canyon (City of Piedmont 2009d).

Impact Analysis
a. Would the project physically divide an established community? The Housing Element is a policy document that does not involve or approve physical development.

Therefore, it would have no impact on dividing an established community. Further, the Housing Element Update would prioritize the development of new housing on infill and appropriately zoned vacant sites within areas of Piedmont. The Housing Element Update includes Policy 2.6 which encourages the preservation of multi-family housing, Policy 2.8 which encourages the conservation of rental housing opportunities, and Policies 1.5 and 1.6 which encourage the inclusion of accessory dwelling units to existing residential units to help the City meet its RHNA requirement without displacing current residents. Future development would be located near public transportation, schools, retail, and other services and would not involve the construction of new roads, railroads, or other features that may physically divide established communities in Piedmont. Goals, policies, and objectives under the Housing Element Update would put a greater emphasis on preventing displacement and promoting housing stability to maintain and preserve the quality of Piedmont’s existing neighborhoods. Consequently, the Housing Element Update would not impact the physical division of an established community. No impact would occur.

NO IMPACT
Agenda Report Page 77 Attachment 1 Exhibit A
b. Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The Housing Element Update examines the City’s housing needs, as they exist today, and projects future housing needs. This Housing Element Update focuses on addressing Piedmont’s housing needs by providing objectives and policies associated with fair housing, the prevention of displacement, and promoting housing stability. The Housing Element Update includes proposed actions that the City would undertake to achieve its housing RHNA targets and would also implement ABAG’s land use goals and policies by encouraging new development in areas with access to transit and services, thus minimizing vehicle trips and GHG emissions.

Upon its adoption by the City, the Housing Element Update would serve as a comprehensive statement of the City’s housing policies and as a specific guide for program actions to be taken in support of those policies. The Housing Element Update is a policy document that would encourage housing development in infill areas and on appropriately zoned vacant and non-vacant sites. Any future development would be reviewed by the City for consistency with all adopted local and State laws, regulations, standards, and policies. Impacts related to conflicts with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect would have no impact.

NO IMPACT
Agenda Report Page 78 Attachment 1 Exhibit A
12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of
the state? □ □ □ ■
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan, or other land
use plan? □ □ □ ■
Environmental Setting
According to the Natural Resources and Sustainability Element of the Piedmont General Plan, Piedmont’s principal mineral resources are volcanic rocks such as basalt, andesite, and rhyolite which were mined during the early 1900s (City of Piedmont, 2009a). Currently, operation of these quarries is infeasible and not expected to resume. Additionally, the State Mining and Geology Board has not identified any regionally significant aggregate or other mineral resources in Piedmont (City of Piedmont, 2009a).

Impact Analysis
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? Piedmont does not contain any active mining sites nor any regionally significant minerals. Further, the Housing Element Update is a policy document that does not involve or approve physical development. Therefore, it would not result in the loss of availability of a known valuable mineral resource to the region, nor to a mineral resource recovery site. Therefore, there would be no impact related to mineral resources.

NO IMPACT
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13 Noise
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies? □ □ □ ■
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ □ ■
c. For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or
working in the project area to excessive
noise levels? □ □ □ ■
Environmental Setting
Noise
Environmental noise levels typically fluctuate over time, and different types of noise descriptors are used to account for this variability. The unit of measurement used to describe a noise level is the decibel (dB). Decibels are measured on a logarithmic scale that quantifies sound intensity. A doubling of the energy of a noise source, such as a doubling of traffic volume, would increase the noise level by 3 dB; similarly, dividing the energy in half would result in a decrease of 3 dB. Noise sensitive land uses generally include residences, hospitals, schools, churches, libraries, and parks.

Ground-borne Vibration
Typical outdoor sources of perceptible ground-borne vibration are construction equipment, steelwheeled trains, and traffic on rough roads. The primary concern from vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses. Vibration amplitudes are usually expressed in peak particle velocity (PPV) or root mean square (RMS) vibration velocity.

The PPV and RMS velocity are normally described in inches per second (in./sec.). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. A PPV of 0.035 is considered barely noticeable while a PPV of 2.00 is considered severe (Caltrans 2020). Vibration sensitive receivers, which are similar to noise-sensitive receivers, include residences and institutional uses, such as hospitals, schools, and churches. However, vibration-sensitive receivers Agenda Report Page 81 Attachment 1 Exhibit A
also include buildings where vibrations may interfere with vibration-sensitive equipment that is affected by vibration levels that may be well below those associated with human annoyance (e.g., recording studies or medical facilities with sensitive equipment).

Descriptors
The impact of noise is not a function of loudness alone. The time of day when noise occurs, and the duration of the noise are also important. In addition, most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors has been developed.

The noise descriptors used for this analysis is the community noise equivalent level (CNEL).  The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period. Typically, Leq is equivalent to a one-hour period, even when measured for shorter durations as the noise level of a 10- to 30-minute period would be the same as the hour if the noise source is relatively steady. Lmax is the highest Root Mean Squared (RMS) sound pressure level within the sampling period, and Lmin is the lowest RMS sound pressure level within the measuring period (Crocker 2007).  The CNEL is a 24-hour equivalent sound level with an additional 5 dBA penalty to noise occurring in the evening hours, between 7:00 p.m. and 10:00 p.m. and an additional 10 dBA penalty to noise occurring during the night, between 10:00 p.m. and 7:00 a.m., to account for the added sensitivity of humans to noise during these hours (Caltrans 2013). Quiet suburban areas typically have a CNEL in the range of 40 to 50 dBA, while areas near arterial streets are in the 50 to 70+ CNEL range (FTA 2018).

Impact Analysis
a. Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not, in and of itself, result in generation of a substantial temporary or permanent increase in ambient noise or vibration levels in Piedmont. In addition, residential uses typically do not generate substantial levels of noise or vibration. Development proposals for individual projects would be subject to adopted development guidelines. As required in PCC Chapter 12, Section 8 (Noise Declared Nuisances) future development projects would be required to comply with the City’s noise standards which declare that loud, unnecessary, and unusual noise is a nuisance that is unlawful. The Code specifically prohibits construction noise between 6:00 p.m. to 8:00 a.m. seven days a week, extending an extra hour (to 9:00 a.m.) on Sunday mornings. Therefore, future construction activities would not generate noise or vibration during regular sleep hours. Future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review. No impact would occur.

NO IMPACT
Agenda Report Page 82 Attachment 1 Exhibit A
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts involving airport safety. Furthermore, the nearest airport to Piedmont is the Oakland International Airport which is located approximately 8 miles south of Piedmont. According to the Oakland International Airport Land Use Compatibility Plan, Piedmont is located outside of the airport’s noise contours and the airport influence area illustrated in Figure 3-1 of the Airport Land Use Compatibility Plan (Alameda County 2010). No impact would occur.

NO IMPACT
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14 Population and Housing
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Induce substantial unplanned population
growth in an area, either directly (e.g., by
proposing new homes and businesses) or
indirectly (e.g., through extension of
roads or other infrastructure)? □ □ □ ■
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
Environmental Setting
Table 4 provides the 2022 estimates of population and housing for Piedmont. Piedmont has an estimated 2022 population of 10,977 and 3,964 housing units, with an average household size of

2.17 people (California Department of Finance 2022).

Table 4 Current Population and Housing Stock for Piedmont City of Piedmont Alameda County
Population (#of people) 10,977 1,651,979
Average Household Size (persons/household) 2.85 2.66
Total Housing Units (# of units) 3,964 633,198
Vacant Housing Units 118 (3%) 31,957 (5.0%)
Source: California Department of Finance 2022
Plan Bay Area 2050 is the most recent regional long-range plan and regional growth forecast for the Bay Area (ABAG and MTC 2021b). Though it does not include projections by city, it does include employment and housing projections for North Alameda County which includes Alameda, Oakland, and Piedmont. These projections are shown in Table 5.

Table 5 2050 Plan Bay Area Population, Housing, and Employment Projections for North Alameda County
2015 2050 (Projected) Projected Growth (Percent Increase) Housing (# of units) 181,000 287,000 107,000 (59%)
Employment (# of jobs) 275,000 358,000 83,000 (30%)
Source: ABAB and MTC 2021b
Agenda Report Page 85 Attachment 1 Exhibit A
Impacts related to population are generally social or economic in nature. Under CEQA, a social or economic change generally is not considered a significant effect on the environment unless the changes are directly linked to a physical change.

Impact Analysis
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Therefore, the Update would not induce substantial unplanned growth. Further, the State requires that all local governments adequately plan to meet the housing needs of their communities. The City of Piedmont had an estimated population of 10,977 residents as of 2022 (DOF 2022). The California Department of Housing and Community Development (HCD), ABAG, and the Metropolitan Transportation Commission (MTC) are responsible for identifying the projected RHNA and Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) for each jurisdiction in the Bay Area, including Alameda County.

These documents include population, employment, and housing projections for the region. ABAG estimates that the City's population will reach 11,040 in 2030 and 11,170 in 2040 (ABAG 2020). As discussed in the Project Description, the Housing Element Update identifies sites that have the capacity to meet the City’s RHNA, therefore, the Housing Element Update would be consistent with State requirements for the RHNA. In addition, the Housing Element Update, as a policy document, would not involve the extension of roads or other infrastructure that could indirectly lead to population growth. Thus, the Housing Element Update would not induce substantial unplanned population growth in an area, either directly or indirectly, and there would be no impact.

NO IMPACT
b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not displace substantial numbers of existing people or housing. In addition, the Housing Element Update includes Policies 1.5 and 1.6 which encourage the inclusion of accessory dwelling units to existing residential units to help the City meet its RHNA requirement without displacing current residents. Further, any future potential displacement that would occur is required by California Government Code Section 7261(a) to proactively provide relocation assistance advisory services to all persons displaced.

Therefore, the adoption of the Housing Element Update would not displace substantial numbers of existing people or housing and no impact would occur.

NO IMPACT
Agenda Report Page 86 Attachment 1 Exhibit A
15 Public Services
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
a. Would the project result in substantial
adverse physical impacts associated with
the provision of new or physically altered
governmental facilities, or the need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts,
in order to maintain acceptable service
ratios, response times or other
performance objectives for any of the
public services:
1 Fire protection? □ □ □ ■
2 Police protection? □ □ □ ■
3 Schools? □ □ □ ■
4 Parks? □ □ □ ■
5 Other public facilities? □ □ □ ■
Environmental Setting
The Piedmont Fire Department (PFD) provides fire protection and emergency medical services for Piedmont. This service area represents 1.7 square miles and approximately 10,977 residents. The PFD operates a single fire station including one engine, one truck, and an ambulance. The PFD is organized into two divisions: Fire Prevention Bureau and Operations and Training. Both divisions are under the Office of the Fire Chief.

The Piedmont Police Department provides police services including patrol, traffic services, investigations, and animal control to Piedmont with 19 sworn staff. The Police Department has one station located at 403 Highland Avenue.

The Piedmont Unified School District (PUSD) operates three elementary schools (grades K-5), one middle school (grades 6-8), one traditional high school, one alternative high school, and one adult education school (PUSD 2022).

Agenda Report Page 87 Attachment 1 Exhibit A
Impact Analysis
a.1. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
a.2. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
a.3. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered schools, or the need for new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? a.4. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered parks, or the need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? a.5. Would the project result in substantial adverse physical impacts associated with the provision of other new or physically altered public facilities, or the need for other new or physically altered public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to public facilities and services. In addition, future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review and would be subject to adopted development guidelines, including standards that govern public facilities, services, and adequate fire and public safety protections.

Additionally, General Plan Policy 34.1 ensures efficient organization, funding, and delivery of police, fire, and emergency medical services to Piedmont Residents (City of Piedmont 2009c).

Therefore, the Housing Element Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities and there would be no impact.

Impacts related to parks are discussed in Section 16, Recreation, and impacts related to other public facilities such as water, wastewater, stormwater, and solid waste infrastructure are discussed in Section 10, Hydrology and Water Quality, and Section 19, Utilities and Service Systems.

NO IMPACT
Agenda Report Page 88 Attachment 1 Exhibit A
16 Recreation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
a. Would the project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated? □ □ □ ■
b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment? □ □ □ ■
Environmental Setting
The City of Piedmont and Recreation Department administers recreation centers and maintains some of the parks within city limits. The Parks and Recreation Department oversees Hampton Park, Linda Beach Playfield, and Coaches Field. There are also six parks in Piedmont: Blair Park, Crocker Park, Dracena Quarry Park, Kennelly Skate Park, Linda Park, and Piedmont Park and Exedra Plaza.

Impact Analysis
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to recreational facilities. In addition, development proposals for individual projects would be subject to adopted development guidelines, including standards that govern recreational facilities.

Therefore, the Housing Element Update would not increase the use of existing recreational facilities or require the construction or expansion of recreational facilities. Thus, there would be no impact.

NO IMPACT
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Agenda Report Page 90 Attachment 1 Exhibit A
17 Transportation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Conflict with a program, plan, ordinance
or policy addressing the circulation
system, including transit, roadway,
bicycle and pedestrian facilities? □ □ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ □ ■
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ □ ■
d. Result in inadequate emergency access? □ □ □ ■
Environmental Setting
The City’s General Plan Circulation Element identifies the existing transportation conditions of the City, existing and future roadways, bicycle trails, and pedestrian trails. Transit service in the Piedmont area is provided by the Alameda-Contra Costa Transit District (AC Transit). AC Transit operates several bus lines providing local and Transbay connections to the Salesforce Transit Center in San Francisco, as well as school bus service on school days.

Piedmont is also located near several Bay Area Rapid Transit (BART) stations although they are not directly located in the City. There are four BART stations within 3 miles of Piedmont’s borders. The stations, and their approximate distance from Piedmont City Hall, are:
 Rockridge BART Station (2.3 miles)
 19th Street/Oakland BART Station (2.6 miles)
 MacArthur BART Station (2.7 miles)
 12th Street/Oakland City Center BART Station (3.0 miles) In 2018, CEQA Guidelines Section 15064.3 was finalized to help determine the significance of transportation impacts. Beginning on July 1, 2020, level of service (roadway congestion) is no longer considered an acceptable metric for analyzing transportation impacts under CEQA. Instead, jurisdictions must adopt vehicle miles traveled (VMT) thresholds to analyze impacts related to the number of automobile trips and miles traveled.

Agenda Report Page 91 Attachment 1 Exhibit A
Impact Analysis
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to conflicts with a program, plan, ordinance, or policy addressing the circulation system.

In addition, the Piedmont City Council adopted the Piedmont Safer Streets Plan in 2020 to develop an efficient and safe street network for Piedmont, with traffic safety considerations for all road users- pedestrians, cyclists and drivers. The Piedmont Safer Streets Plan provides a list of past, ongoing, and planned projects to improve pedestrian and bicycle access, mobility and safety throughout Piedmont. Modifications to or new transit, roadway, bicycle, and pedestrian facilities would be subject to and designed in accordance with applicable General Plan policies such as LHMP Policy 3.3 enhances emergency service capabilities and addresses adequate evacuation planning (City of Piedmont, 2009c). Future development would also be required to comply with Policy 7.3 which aims to reduce VMT, Policy 8.3 which discourages traffic congestion, Policy 10.5 which expands bicycle infrastructure in Piedmont, and Policy 11.1 which maintains off-street parking standards (City of Piedmont, 2009c).

Future development would also be required to adhere to federal, State, and local policies and regulations including those included in the General Plan. For the proposed Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program includes a goal to improve pedestrian and vehicular circulation to provide safe pedestrian, bicycle, and motor vehicle movements. Therefore, the Housing Element Update would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. There would be no impact.

NO IMPACT
b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to VMT. In addition, future development would be required to adhere to federal, State, and local policies and regulations including those included in the General Plan. Therefore, the Housing Element Update would not conflict with conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). There would be no impact.

NO IMPACT
Agenda Report Page 92 Attachment 1 Exhibit A
c. Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts related to hazards related to a geometric design feature or incompatible use. In addition, future development would be required to adhere to federal, State, and local policies and regulations including those policies included in the General Plan and would be reviewed and required to be consistent with appropriate regulations and design standards in effect at the time, such as adequate sight distance at new driveways between vehicles entering and exiting the driveways and pedestrians on the adjacent sidewalk, as well as motor vehicles and bicycles on the adjacent street, as outlined by General Plan Policy 29.9 (Sight Obstruction).

The proposed planning document would also set forth policies and goals to encourage additional residential uses in an area that currently primarily consists of residential uses. Thus, the proposed project would be consistent with the existing uses in the area and would not introduce incompatible uses in Piedmont.

For the proposed Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program includes goals to improve safety and include improvements to pedestrian and vehicular circulation.

Therefore, the Housing Element Update would not substantially increase hazards due to a geometric design feature or incompatible use, and there would be no impact.

NO IMPACT
d. Would the project result in inadequate emergency access? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in inadequate emergency access. In addition, the City maintains the roadway network which would provide access to new development sites in accordance with industry design standards, which ensures that the physical network would be free of obstructions to emergency responders.

Emergency access to new development sites would be subject to review by the City of Piedmont and responsible emergency service agencies, thus ensuring that future projects would be designed to meet all emergency access and design standards.

Additional vehicles associated with new development sites could increase delays for emergency response vehicles during peak commute hours. However, emergency responders maintain response plans which include use of alternate routes, sirens, and other methods to bypass congestion and minimize response times. In addition, California law requires drivers to yield the right-of-way to emergency vehicles and remain stopped until the emergency vehicle passes to ensure the safe and timely passage of emergency vehicles.

Future development requiring discretionary approval accommodated under the Housing Element Update would undergo project-specific developmental review to ensure consistency with the City’s existing and planned circulation network; and ensure that the construction of new features would not impede emergency access. These review processes would evaluate the design of future projects’ Agenda Report Page 93 Attachment 1 Exhibit A
emergency access schematics, which would minimize the potential for the creation of inadequate emergency access.

For the proposed Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program states the Specific Plan must include improvements to pedestrian and vehicular circulation, as determined necessary by the City Engineer, to provide safe pedestrian, bicycle, and motor vehicle movements, ensure safe evacuation routes, and provide optimal emergency response. No impact would occur.

NO IMPACT
Agenda Report Page 94 Attachment 1 Exhibit A
18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in a Public Resources Code
Section 21074 as either a site, feature, place,
or cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native American
tribe, and that is:
a. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in Public
Resources Code Section 5020.1(k)? □ □ □ ■
b. A resource determined by the lead
agency, in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1? In applying the criteria
set forth in subdivision (c) of Public
Resources Code Section 5024.1, the lead
agency shall consider the significance of
the resource to a California Native
American tribe. □ □ □ ■
Environmental Setting
AB 52 established that “A project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment” (PRC Section 21084.2). It further stated that the lead agency shall establish measures to avoid impacts that would alter the significant characteristics of a tribal cultural resource, when feasible (PRC Section 21084.3).

PRC Section 21074 (a)(1)(A) and (B) defines tribal cultural resources as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe” and is:

1. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or Agenda Report Page 95 Attachment 1 Exhibit A

2. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.

In applying these criteria, the lead agency shall consider the significance of the resource to a California Native American tribe.

AB 52 also establishes a formal consultation process for California tribes regarding those resources.

The consultation process must be completed before a CEQA document can be certified. Under AB 52, lead agencies are required to “begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.” Native American tribes to be included in the process are those that have requested notice of projects proposed within the jurisdiction of the lead agency.

California Government Code Section 65352.3 (adopted in 2004 pursuant to the requirements of SB 18 [SB 18]) requires local governments to contact, refer plans to, and consult with tribal organizations prior to making a decision to adopt or amend a general or specific plan. The tribal organizations eligible to consult have traditional lands in a local government’s jurisdiction, and are identified, upon request, by the NAHC. As noted in the California Office of Planning and Research’s Tribal Consultation Guidelines (2005), “The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places.” Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code Section 21074 that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code 21074 that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? The City sent notification letters on December 9, 2021 to twelve Native American organizations (Amah Mutsun Tribal Band of Mission San Juan Bautista, Costanoan Rumsen Carmel Tribe, Guidiville Indian Rancheria, Indian Canyon Mutsun Band of Costanoan, Muwekma Ohlone Indian Tribe of the SF Bay Area, North Valley Yokuts, Tamien Nation, the Confederated Villages of Lisjan, the Ohlone Indian Tribe, Tule River Indian Tribe, Wilton Rancheria, and the Wuksache Indian Tribe/Eshom Valley Band) who had previously requested formal notice to consult. The Tribal Chair of the Confederated Villages of Lisjan Tribe reached out to request more information on the project site and the SLF results; however, to date, the City has not received any responses requesting additional consultation under AB 52 or SB 18. The City of Piedmont also requested a review of the SLF by the NAHC and received a response on October 28, 2021, that the search of the SLF was negative.

Therefore, there would be no impact.

NO IMPACT
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Agenda Report Page 98 Attachment 1 Exhibit A
19 Utilities and Service Systems
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ □ ■
b. Have sufficient water supplies available
to serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years? □ □ □ ■
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
project’s projected demand in addition to
the provider’s existing commitments? □ □ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals? □ □ □ ■
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste? □ □ □ ■
Environmental Setting
Water service to Piedmont is provided by EBMUD, a public utility. Approximately 90 percent of the EBMUD water supply originates from the melting snowpack of the Sierra Nevada. The remainder of Piedmont’s water supply comes from the Mokelumne River and EBMUD’s secondary supply that comes from local runoff from the East Bay area watersheds, which is stored in the terminal reservoirs within EBMUD’s service area. The City of Piedmont owns and maintains its own sewage collection system. This system was developed by the Piedmont Sanitary District shortly after the City’s incorporation, and was completed in 1941. The City of Piedmont is a member of Republic Services which is a waste disposal company whose services include non-hazardous solid waste collection, waste transfer, and waste disposal, recycling, and energy services. Telecommunications Agenda Report Page 99 Attachment 1 Exhibit A
services in Piedmont are provided by private companies, including AT&T, Verizon, T-Mobile, and Comcast Cable which provides internet, phone, and television. EBCE supplies electricity to Piedmont using transmission infrastructure operated and maintained by PG&E. PG&E also provides natural gas to the City.

Impact Analysis
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
The Housing Element Update is a policy document that does not involve or approve physical development.

Further, future development would be subject to all utility service standards set in the PCC and Piedmont General Plan. Individual projects would also be individually reviewed to ensure that adequate utility services would be provided to each site. Future development would be concentrated in urban areas that are served by existing utilities infrastructure, including potable water, wastewater, stormwater drainage, electrical power, natural gas, and telecommunications facilities. Development proposals for individual projects would be subject to adopted development guidelines, including standards that govern utility services. Impacts identified for an individual project would be addressed through the project approval process.

Water Supply
The precise location and connection would be determined at the time development is proposed.

Should any new connections or upgrades be required, such upgrades would be subject to subsequent developmental review. Future line size modifications or connections, if needed, would be designed in accordance with applicable provisions of PCC Chapter 8, Building, Construction, and Fire Prevention. The Housing Element Update would not result in inadequate water supply.

Stormwater
Future development would be evaluated to determine adequacy of utility infrastructure as part of the standard City development review process. See also Section 10, Hydrology and Water Quality.

Wastewater Generation
Wastewater treatment for any future development would be provided by existing infrastructure within Piedmont. Project development would be required to comply with the regulations to maintain wastewater capacity in Piedmont. Future development would be evaluated to determine adequacy of utility infrastructure as part of the standard city development review process including approval by the Public Works Department. The Housing Element Update would not result in impacts to wastewater.

Agenda Report Page 100 Attachment 1 Exhibit A
Electricity, Natural Gas, and Telecommunications
Future residential development in conformance with the Housing Element Update would be evaluated to determine adequacy of utility infrastructure as part of the standard City development review process. The Housing Element Update would not result in impacts to electricity, natural gas, or telecommunications. No impact would occur.

NO IMPACT
d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e. Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Solid Waste
The Housing Element Update is a policy document that does not involve or approve physical development. Therefore, the Housing Element Update would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. In addition, future development would be required to comply with General Plan Policy 17.1 which promotes recycling, composting, and other programs to reduce the generation of solid waste. Further individual development projects would be required to comply with federal, state, and local management and reduction statues and regulations. This includes CalRecycle regulations found in Title 14 and Title 27 of the California Code of Regulations.

There would be no impact.

NO IMPACT
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Agenda Report Page 102 Attachment 1 Exhibit A
20 Wildfire
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
If located in or near state responsibility areas
or lands classified as very high fire hazard
severity zones, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ □ ■
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire? □ □ □ ■
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment? □ □ □ ■
d. Expose people or structures to significant
risks, including downslopes or
downstream flooding or landslides, as a
result of runoff, post-fire slope instability,
or drainage changes? □ □ □ ■
Environmental Setting
The Piedmont Fire Department is responsible for protecting life, property, and the environment. As needed, these Fire Services Officers are available 24/7 to respond to police incidents. The Environmental Hazards Element of the Piedmont General Plan includes policies to reduce, prevent, and fight wildfire. The Piedmont Public Safety Committee has prepared the Get Ready, Piedmont disaster preparedness guide. This document provides comprehensive information on preparation for, and response to, earthquakes, fires, landslides, and other emergencies.

Southeastern Piedmont lies within a LRA Very High Fire Hazard Severity Zone (VHFHSZ) as designated by CalFire (CalFire 2022). According to the Environmental Hazards Element of the Piedmont General Plan, the entire City of Piedmont is designated a wildland urban interface (WUI).

This identifies the zone of transition from urban land to wildland and the mixing of the two, which is commonly where wildfire impacts are felt the most and disproportionately impacts residential developments. The entire city being designated within the WUI means it is especially vulnerable to Agenda Report Page 103 Attachment 1 Exhibit A
significant wildfire events. The parts of Piedmont that are not in the CalFire VHFHSZ are still in the WUI and experience higher population density, as well as hilly terrain, that can exacerbate wildfire risk.

In addition, the location of the City and existing environmental factors do not promote a high risk for exposure to pollutant concentrations. Prevailing winds in Piedmont generally move from northwest to southeast across the City (NOAA 2022). The prevailing winds would generally move wildfire in the VHFHSZ to the east and southeast of the City and related smoke and air pollutants, southeastward, away from Piedmont.

Impact Analysis
a. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
The Housing Element Update is a policy document that does not involve or approve physical development. Because it is a policy document, the Housing Element Update would not, in and of itself, have an impact on adopted emergency response or evacuation plan. In addition, future development would go through the City’s design review to ensure consistency with the General Plan, including the Environmental Hazards Element, as well as ensuring the proposed project meets State and local requirements for development in wildfire hazard areas and would not impair emergency response or evacuation. Further, for the Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program includes a goal that improvements to pedestrian and vehicular safety must be included to ensure safe evacuation routes and provide optimal emergency response. There would be no impact.

NO IMPACT
b. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
The Housing Element Update does not propose specific projects but puts forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not, in and of itself, have an impact on wildfire safety. Additionally, future development would occur in compliance with PCC Chapter 8, that adopts the California Fire Code and includes fire hazard abatement, which would ensure that development is constructed to safeguard life and property from wildfire hazards.

Further, for the Moraga Canyon Specific Plan described under Program 1.L of the Housing Element Update, the program includes goals that new habitable structures be built to meet fire code requirements for the WUI and that landscape plans prioritize fire safety. Therefore, there would be no impact.

NO IMPACT
Agenda Report Page 104 Attachment 1 Exhibit A
c. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? The Housing Element Update does not propose specific projects but puts forth goals and policies that encourage various aspects of new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not have an impact on wildfire safety. In addition, most roads and utility infrastructure required for future development would be existing or would occur in currently developed areas.

Because this development would occur in urbanized areas of Piedmont, where large tracts of vegetation cover are not present, the risk of wildfire would not be exacerbated. Wildfire risk is greatest in the southeast corner of the City where there is an LRA VHFHSZ and vegetation and open space. The Housing Element Update would not include plans to extend the City’s sphere of influence or city limits into the adjacent eastern or southern FHSZs. Therefore, there would be no impact.

NO IMPACT
d. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
Piedmont is located in the East Bay Hills. If a wildfire were to occur, there could be the risk of isolated landslides afterwards because of the varying topography and exposure of soil or hillside slopes. No major water bodies are present, and the risk of flooding would be low. The Housing Element Update puts forth goals and policies that promote housing development in Piedmont to meet the City’s RHNA requirements. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not have an impact related to wildfire. Therefore, there would be no impact.

NO IMPACT
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21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Does the project:
a. Have the potential to substantially
degrade the quality of the environment,
substantially reduce the habitat of a fish
or wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, substantially reduce
the number or restrict the range of a rare
or endangered plant or animal or
eliminate important examples of the
major periods of California history or
prehistory? □ □ □ ■
b. Have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the
effects of other current projects, and the
effects of probable future projects)? □ □ □ ■
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or
indirectly? □ □ □ ■
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not have the potential to substantially degrade the quality of the environment. Adoption of the Housing Element Update would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species. In Agenda Report Page 107 Attachment 1 Exhibit A
addition, the Housing Element Update would not have a substantial adverse effect on any riparian habitat or sensitive natural community.

Through the City’s development review process, future development projects would be evaluated for potential direct and indirect impacts on biological and cultural resources. Therefore, the Housing Element Update would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory and no impacts would occur.

NO IMPACT
b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not result in impacts that are individually limited, but cumulatively considerable. In addition, through the City’s development review process, future development projects would be evaluated for potential cumulative impacts and for consistency with all applicable policies of the City’s General Plan, Zoning Ordinance, and City Code. Through this development review process, potential cumulative impacts to various natural and human-made resources would be evaluated. The Housing Element Update would not increase development potential above that already allowed under the City’s General Plan and Zoning Code. Adoption of the Housing Element Update would not have impacts that are individually limited or cumulatively considerable. No impact would occur.

NO IMPACT
c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
The Housing Element Update does not propose specific projects but sets forth goals and policies to encourage new housing development in Piedmont. Because it is a policy document that does not involve or approve physical development, the Housing Element Update would not have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly. Through the City’s development review process, future residential development projects would be evaluated for potential direct and indirect impacts on human beings. Therefore, the Housing Element Update would not have environmental effects which would cause substantial adverse effects on human beings, either directly or indirectly and no impacts would occur.

NO IMPACT
Agenda Report Page 108 Attachment 1 Exhibit A
References
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Agenda Report Page 109 Attachment 1 Exhibit A
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Agenda Report Page 110 Attachment 1 Exhibit A
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Design&Preservation.pdf?v=MfmiEPmbw&v=MfmiEPmbw. Accessed November 2022. ______. 2009c. City of Piedmont General Plan Environmental Hazards Element. https://cdn5- hosted.civiclive.com/UserFiles/Servers/Server_13659739/File/Government/Departments/Pl anning%20Division/General%20Plan/GP%20EHE%20adopted%202020-2-

18.pdf?v=DoBZIH6KG&v=DoBZIH6KG. Accessed November 2022. ______. 2009d. City of Piedmont General Plan Land Use Element. https://cdn5- hosted.civiclive.com/UserFiles/Servers/Server_13659739/File/Government/Projects/Genera l%20Plan%20and%20Housing%20Element/03-landuse.pdf?v=t6QTrfRUj&v=t6QTrfRUj.

Accessed November 2022.
______. 2019. Local Hazard Mitigation Plan.
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______. 2022a. Staff Report on the 2020 Greenhouse Gas Emissions Inventory and Piedmont’s Climate Action Plan 2.0 Implementation Status.
https://piedmont.ca.gov/common/pages/DisplayFile.aspx?itemId=18746216. Accessed November 2022.
______. 2022b. Zoning Ordinance.
https://piedmont.ca.gov/services___departments/planning___building/about_planning_/z oning_ordinance. Accessed November 2022.

Piedmont City Code (PCC). 2022. https://piedmont.ca.gov/government/charter___city_code Piedmont Unified School District. Schools in Piedmont Unified School District (PUSD). 2022. https://www.piedmont.k12.ca.us/schools/. Accessed November 2022.

Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Society of Vertebrate Paleontology Impact Mitigation Guidelines Revision Committee. https://vertpaleo.org/wpcontent/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf State Water Resources Control Board (SWRCB). 2021. GeoTracker Database. City of Piedmont. https://geotracker.waterboards.ca.gov/. Accessed November 2022.

Agenda Report Page 111 Attachment 1 Exhibit A
List of Preparers
Rincon Consultants, Inc. prepared this Initial Study under contract to the City of Piedmont. Persons involved in data gathering analysis, project management, and quality control are listed below.

RINCON CONSULTANTS, INC.

Darcy Kremin, AICP, Director
Karly Kaufman, MESM Project Manager
Nichole Yee, Environmental Planner
Hannah Bireschi, Environmental Planner
Gina Gerlich, GIS Analyst
Luis Apolinar, Publishing Specialist
Agenda Report Page 112 Attachment 1 Exhibit A
RESOLUTION No.____

A RESOLUTION ADOPTING A GENERAL PLAN AMENDMENT TO UPDATE THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE PERIOD OF 2023-2031,

INCLUDING POLICIES TO AFFIRMATIVELY FURTHER FAIR HOUSING, IN

COMPLIANCE WITH ALL APPLICABLE STATE LAWS
WHEREAS, State of California housing element law, as set forth in Government Code §§ 65302 and 65580, et seq., requires the City of Piedmont to periodically prepare and update its Housing Element in its General Plan, and to establish goals, policies, and programs to accommodate the maintenance, diversification, and expansion of the City’s housing supply to accommodate the City of Piedmont’s regional housing needs allocation (RHNA) of 587 housing units, comprised of 238 above moderate income units, 92 moderate income units, 94 low income units, and 163 extremely and very low income units; and WHEREAS, Piedmont’s prior 5th Cycle Housing Element was last certified by the California Department of Housing and Community Development (HCD) in 2014, and Government Code section 65588 requires local agencies to update their housing element at least every eight years; and
WHEREAS, the Association of Bay Area Governments (ABAG) adopted a final methodology and RHNA for every local government in the Bay Area Region in January 2022, and the RHNA assigned to Piedmont was 587 new housing units across various income categories; and WHEREAS, to comply with State housing element law, the City of Piedmont has prepared the 2023-2031 6th Cycle Housing Element (the 6th Cycle Housing Element); and WHEREAS, as provided in Government Code Section 65350 et. seq., the 6th Cycle Housing Element constitutes a General Plan Amendment; and
WHEREAS, as provided in Government Code Sections 65352 – 65352.5, the City of Piedmont referred the Housing Element to all California Native American tribes on the contact list provided by the Native American Heritage Commission and to other entities listed, and no California Native American tribe requested consultation; and WHEREAS, California Government Code Section 65583 requires that the Housing Element Update contain: (i) an assessment of the City’s housing needs and an analysis of the resources and constraints, both governmental and non-governmental, relevant to the meeting of these needs; (ii) an inventory of land suitable and available for residential development and an analysis of the development potential of such sites; (iii) a statement of the community's goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing; and (iv) programs that set forth a schedule of actions the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the 6th Cycle Housing Element; and Attachment 2 Agenda Report Page 113
WHEREAS, State law requires that the City take meaningful steps to promote and affirmatively further fair housing (Gov. Code Section 65583(c)(5)); and WHEREAS, State law requires that the City make zoning available for all types of housing, including multifamily housing (Gov. Code Sections 65583.2 and 65583(c)); and WHEREAS, the 6th Cycle Housing Element must be adopted to comply with State law, accommodate the RHNA, affirmatively further fair housing, and facilitate and encourage a variety of housing types for all income levels, including multifamily housing (Gov. Code Sections 65583.2 and 65583(c)); and
WHEREAS, the preparation, adoption, and implementation of the 6th Cycle Housing Element requires a diligent effort to include all economic segments of the community; and WHEREAS, the City conducted extensive community outreach in support of the Housing Element update process over the past 24 months with an innovative and robust public engagement process, including two community workshops, three City Council meetings, 13 Planning Commission meetings, two meetings of the Housing Advisory Committee, a meeting of the Recreation Commission, a meeting of the Park Commission, two online forums, two open houses, and tables at community events, as well as online engagement tools, regular news stories in local media, email newsletters to over 4,000 email subscribers, emails to the School District employees and City employees, correspondence with Piedmont religious institutions, meetings with property owners in Zones A, B, C, and D, citywide streetlight banners announcing the Housing Element website, and posters at local businesses; and WHEREAS, the 2023-2031 6th Cycle Housing Element was prepared for the City of Piedmont based on significant input from the public, the City Council, the Planning Commission, the Housing Advisory Committee, the Recreation Commission, the Park Commission, and the California Department of Housing and Community Development (HCD), and responded to public comment; and
WHEREAS, the City of Piedmont’s 2023-2031 6th Cycle Housing Element includes updated data in compliance with the State of California housing laws and provides a wide range of programs and strategies to address citywide housing needs and priorities; and WHEREAS, a draft City of Piedmont 2023-2031 6th Cycle Housing Element was released for 60-day public review on April 8, 2022, and the City received 380 public comments on this draft; and
WHEREAS, on May 12, 2022, the Planning Commission considered the draft 2023-2031 6th Cycle Housing Element, took public comment, and recommended City Council authorize staff to transmit the Draft Housing Element, along with Planning Commission-recommended revisions, to California HCD; and.

WHEREAS, on June 20, 2022, the City Council considered the 6th Cycle Housing Element at a public meeting, and instructed staff to make extensive revisions in response to public input, and Attachment 2 Agenda Report Page 114
6th Cycle Housing Element was discussed on the dates of June 20, 2022, and August 1, 2022; and
WHEREAS, the City Council considered the 6th Cycle Housing Element at a public meeting held on November 15, 2022, took public comments, and adopted a resolution authorizing staff to submit the 6th Cycle Housing Element to HCD with revisions outlined in the resolution; and WHEREAS, a draft 2023-2031 6th Cycle Housing Element was submitted to HCD on November 18, 2022, and staff has met several times since with the HCD reviewer, including on December 12 and December 19, 2022, and January 6, January 12, January 13, February 13, and February 16, 2023; and
WHEREAS, a revised Housing Element that integrated public comments received during public review and City Council direction was published for a second public review on December 9, 2022, in compliance with State law; and
WHEREAS, as HCD considered the City’s draft Housing Element, Urban Planning Partners, Inc. (UPP), prepared an independent, third-party review of the draft City of Piedmont 2023-2031 6th Cycle Housing Element in December 2022 and outlined how it was in substantial compliance with State of California housing law, and the City has prepared Exhibit C to this Resolution, which is based on UPP’s analysis; and
WHEREAS, on December 9, 2022, notification of the posting of the revised Housing Element sent to HCD and the Initial Study and Negative Declaration prepared pursuant to CEQA was emailed to all City of Piedmont email subscribers, including community members who had subscribed to receive updates about the Housing Element; on December 16, 2022, notification of the Planning Commission public hearing was emailed to all community members who had subscribed to receive updates about the Housing Element; on December 21, 2022, the City of Piedmont provided notice of the Planning Commission public hearing to California Native American tribes with traditional lands in Piedmont, utility companies, areawide planning agencies, transportation agencies, housing agencies, the City of Oakland, and the Piedmont Unified School District, in compliance with Government Code section 65352; and on December 30, 2023, the public hearing notice was published in The Piedmonter newspaper; and WHEREAS, on January 12, 2023, the Planning Commission held a duly noticed public hearing at which time it reviewed the 6th Cycle Housing Element and all pertinent maps, documents and exhibits, the staff report and all attachments, and oral and written public comments, and determined the Housing Element to be consistent with State law and the General Plan of the of the City of Piedmont, and adopted a Resolution recommending that the City Council adopt the 2023-2031 6th Cycle Housing Element with revisions necessary to obtain certification from HCD; and
WHEREAS, on February 16, 2023, HCD completed its review of the draft 6th Cycle Housing Element and sent the City of Piedmont a comment letter which stated that the 6th Cycle Housing Element addresses many statutory requirements and described four (4) sections of the 6th Cycle Housing Element that must be revised prior to certification to comply with State Housing Attachment 2 Agenda Report Page 115
Element law (Article 10.6 of the Government Code), and the draft 6th Cycle Housing Element has been revised in red-line format in response to HCD comments and included as Exhibit A to this Resolution; and
WHEREAS, the City systematically analyzed HCD’s findings and identified 29 comments requiring a response or revision; and
WHEREAS, on March 13, 2023, the Planning Commission held a regular meeting and received a staff presentation on the comments received from HCD on February 16, 2023, and the City’s proposed approach to each of the comments; and
WHEREAS, the City has responded to each of the comments raised by HCD and revised the Housing Element, as specified in Exhibit B attached to this Resolution and incorporated herein; and
WHEREAS, on March 17, 2023, the City of Piedmont published a revised draft 6th Cycle Housing Element with the text changes requested by HCD and requested public comment on the draft (the “Adoption Draft”); and
WHEREAS, on March 17, 2023, the City notified all interested parties of the availability of the “Adoption Draft,” the opportunity to provide comments, and the dates of upcoming public hearings; and
WHEREAS, on March 20, 2023, the City Council adopted an Initial Study and Negative Declaration prepared pursuant to California Environmental Quality Act (CEQA), Public Resources Code Section 21000 et seq., and CEQA Guidelines Section 15070, assessing the potential environmental impacts that might result from the adoption of the 2023-2031 6th Cycle Housing Element, and determining that there is no substantial evidence that adoption of the 2023-2031 6th Cycle Housing Element may have a significant effect on the environment for the reasons documented in the Notice of Intent to Adopt a Negative Declaration, the Initial-Study Negative Declaration, and the staff report; and
WHEREAS, on March 20, 2023, the City Council held a duly noticed public hearing at which time it reviewed the 6th Cycle Housing Element and all pertinent maps, documents and exhibits, including HCD’s findings, the City’s response to HCD’s findings, the staff report and all attachments, and oral and written public comments, and determined the Housing Element to be consistent with State law and the General Plan of the City of Piedmont; and WHEREAS, once adopted and certified, the 2023-2031 6th Cycle Housing Element would supersede and replace the existing 2014 5th Cycle Housing Element of the General Plan; and NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Piedmont does hereby resolve, declare, determine, and order, based on substantial evidence in the record, as follows:

Attachment 2 Agenda Report Page 116
SECTION 1. FINDINGS
A. The above recitations are true and correct.

B. The City Council finds and determines that adoption of the 2023-2031 6th Cycle Housing Element will not have a significant effect on the environment and that a Negative Declaration has been prepared and adopted for the project.

C. The proposed 2023-2031 6th Cycle Housing Element is consistent with the objectives, policies, general land uses and programs specified in the general plan. The Housing Element is consistent with the General Plan Land Use Element goals and policies set forth below:

1. Goal 1. Residential Character – Maintain the character of Piedmont as a residential community;

2. Goal 4. Special Sites – Maximize potential benefits to Piedmont residents on key opportunity sites, including Policy 4.3: Moraga Canyon – Retain open space and recreation as the primary uses in Moraga Canyon, including Blair Park, Coaches Field, and the Mountain View Cemetery Association property; Policy 4.4:

Availability of Services – Ensure that infrastructure and community facilities are adequate to handle any new development before approval is granted; and Policy

4.5: Environmental Review – Ensure that any land use changes on special sites in Piedmont … are accompanied by appropriate and comprehensive environmental review. All land use changes shall occur through an open and transparent public process;

3. Goal 6: Planning Administration – Maintain planning and building procedures which ensure the safety of all new construction, and which protect the quality and character of Piedmont; Policy 6.1: Planning Process - Ensure that all planning decisions are made in a clear, consistent, objective, transparent, and timely manner; Policy 6.2: Appropriateness of Planning Requirements - Periodically assess planning practices and requirements in response to community feedback; Policy 6.4: Community Input - Maintain a high level of public input in the permitting process, including opportunities for neighbors to comment on proposed plans; and Policy 6.5: Involving Community Organizations - Recognize the contribution of Piedmont’s organizations, clubs, and community groups to civic improvement, and engage these groups in the planning process; Furthermore, the 6th Cycle Housing Element is consistent with the following 5th Cycle Housing Element goals: Goal 1. New Housing Construction - Provide a range of new housing options in Piedmont to meet the needs of all household types in the community; Goal 2. Housing Conservation - Promote the conservation and maintenance of Piedmont’s housing stock; Goal 3. Affordable Housing Opportunities - Create additional housing opportunities for moderate, low, and very low income Piedmont residents; Goal

4. Elimination of Housing Constraints - Minimize constraints to the development of additional housing without compromising the high quality of Piedmont’s neighborhoods; Goal 5. Special Needs Populations - Provide adequate housing opportunities for Piedmonters with special needs, particularly seniors and disabled; Goal 6. Sustainability Attachment 2 Agenda Report Page 117
and Energy - Encourage “greener” construction to reduce household utility costs and create healthier living environments; and Goal 7. Equal Access to Housing - Ensure that all persons have equal access to housing opportunities in Piedmont.

D. The 2023-2031 6th Cycle Housing Element is consistent with the General Plan and City of Piedmont Municipal Code because the Housing Element includes implementation programs to study amendments to ensure consistency with the General Plan and Municipal Code.

E. The 2023-2031 6th Cycle Housing Element is consistent with the City Charter because Section 9.01 of the City Charter directs the City Council to adopt and modify the General Plan setting forth policies to govern the development of the City.

F. Based on substantial evidence in the record, the City Council finds that existing uses on the non-vacant sites identified in the site inventory to accommodate the RHNA are likely to be discontinued during the planning period and therefore do not constitute an impediment to planned residential development on the site during the planning period.

1. Section 65583.2(g)(2) of the Government Code requires that any jurisdiction relying on non-vacant sites to meet more than 50 percent of the RHNA for lowerincome households must make findings that the existing use on the non-vacant site is not an impediment to residential development during the planning period.

The findings must be made on substantial evidence that the existing use is likely to be discontinued during the planning period. In Piedmont, 72 percent of the lower-income capacity is on non-vacant sites. The City has provided such substantial evidence including Appendix B, pages B-11 to B-22 and others of the Housing Element. The City studied the underutilization of sites (e.g. land developed with large areas of surface parking, single-story buildings, low improvement values), existing building age and condition, and/or uses of marginal economic viability on identified housing sites, combined with property owner interest in redevelopment that includes housing, the significant demand for housing, the local trends for converting existing non-vacant land into residential and residential mixed-use, and the new 2023-2031 6th Cycle Housing Element programs to encourage the redevelopment of non-vacant sites with higher-density housing. Accordingly, as described in 6th Cycle Housing Element, the existing uses on the sites identified in the sites inventory to accommodate the lower income RHNA housing goals are likely to be discontinued in their current form and location during the planning period (as documented in the 2023-2031 6th Cycle Housing Element Appendix B, Sites Inventory and Methodology), and therefore, these existing uses do not constitute an impediment to additional residential development during the planning period.

G. As required by Government Code Section 65585(e), the City Council has considered the findings made by the Department of Housing and Community Development included in the Department’s letter to Piedmont dated February 16, 2022, as required by Government Attachment 2 Agenda Report Page 118
Code Section 65585(f). The City has revised the Housing Element to respond to HCD’s comments. Pursuant to the revisions, the Housing Element substantially complies with all requirements of State Housing Element Law as interpreted by HCD. The revisions, and the manner in which they address the HCD comments, have been listed in Exhibit “B” to this Resolution, which is incorporated herein by reference.

H. The Housing Element substantially complies with Housing Element Law, as provided in Government Code 65580 et seq. and contains all provisions required by State Housing Element Law, as set forth in Exhibit “C” to this Resolution, which is incorporated herein by this reference, and which identifies where each applicable requirement of the Government Code is addressed in the document.

I. The City has prepared a “tracked change” version of the November 18, 2022 document submitted to HCD to identify the edits made in response to the HCD’s findings. This is Exhibit “A” to this Resolution and is incorporated herein by reference.

J. The 2023-2031 6th Cycle Housing Element utilizes a sufficient realistic capacity for growth projections by using an 80% cap on projected growth, resulting from Draft Housing Element policies and programs, and by including a 10% buffer of surplus units above the RHNA of 587 housing units (58 housing units).

K. The public engagement conducted for the 2023-2031 6th Cycle Housing Element has successfully reached all segments of the community in and around Piedmont in all income categories, including residents in affected neighborhoods and people working, attending school, and visiting Piedmont from other areas.

L. The 2023-2031 6th Cycle Housing Element presents a reasonable and equitable approach to work with the private sector to enable the construction of new housing to meet the Regional Housing Needs Allocation of 587 new housing units in all income categories.

M. The 2023-2031 6th Cycle Housing Element presents a proactive and innovative approach to use City-owned surplus land to plan for the development of a minimum of 132 housing units, 60 of which will be affordable to resident households earning 80 percent or less of the Area Median Income.

N. The 2023-2031 6th Cycle Housing Element affirmatively furthers fair housing by providing sites, policies, and programs that assure households of all incomes and social and racial backgrounds have access to high resources areas, economic and educational opportunities, and areas with low exposure to environmental hazards.

O. As outlined in the 2023-2031 6th Cycle Housing Element, the staff report, presentation, and Exhibits B and C, the 6th Cycle Housing Element complies with housing element law, as set forth in Government Code §§ 65302 and 65580, et seq.

Attachment 2 Agenda Report Page 119
SECTION 2. ADOPTION
The City Council hereby repeals the 2015-2023 Housing Element in its entirety and approves and adopts the Adoption Draft Housing Element, dated March 2023, in substantially the form attached hereto as Exhibit “A”. The City Administrator is authorized to make any nonsubstantive changes to the Housing Element that may be required by the State to achieve certification or that may be necessary to ensure internal consistency with other planning documents. The Planning & Building Director or designee is hereby directed to distribute copies of the Housing Element in the manner provided in Government Code Sections 65357 and 65589.7.

SECTION 3. SEVERABILITY.

All portions of this resolution are severable. If an individual component of this Resolution is adjudged by a court to be invalid and unenforceable, then the remaining portions will continue in effect.
[END OF RESOLUTION]
Attachment 2 Agenda Report Page 120
Agenda Report Page 121 Attachment 2
Exhibit A
This Page Is Intentionally Left Blank
Agenda Report Page 122 Attachment 2 Exhibit A

HCD REVIEWPUBLIC HEARING DRAFT
i | City of Piedmont 2023-2031 Housing Element
ContentsContents .......................................................................................................................... i Executive Summary ......................................................................................................................1 Piedmont 6th Cycle Housing Element.....................................................................................1 Key Findings ...........................................................................................................................6 (For more information see Appendices A through F.)...................................................................6 How to Read and Review the Draft Housing Element ............................................................8 Section I Introduction..........................................................................................................11 I.A Community Context.............................................................................................11 I.B Housing Element Purpose...................................................................................11 I.C Organization of the Housing Element..................................................................12 I.D Data Sources and Methods.................................................................................13 I.E Summary of Public Participation..........................................................................14 I.F Relationship to Other General Plan Elements.....................................................22 I.G Other Statutory Requirements.............................................................................22 Section II Projected Housing Need .....................................................................................23 II.A Introduction and Overview of ABAG Methodology ..............................................23 II.B Alameda County Income Limits...........................................................................23 II.C Regional Housing Needs Allocation ....................................................................24 Section III Housing Resources .............................................................................................25 III.A Introduction..........................................................................................................25 III.B Land Resources ..................................................................................................25 III.C Financial and Administrative Resources .............................................................26 III.D Opportunities for Energy Conservation ...............................................................33 Section IV Housing Plan: Goals, Policies, and Programs.....................................................37 IV.A Introduction..........................................................................................................37 Goal 1: New Housing Construction.......................................................................................38 Goal 2: Housing Conservation ..............................................................................................51 Goal 3: Affordable Housing Opportunities.............................................................................54 Goal 4: Elimination of Housing Constraints...........................................................................60 Goal 5: Special Needs Populations.......................................................................................73 Goal 6: Sustainability and Energy .........................................................................................82 Goal 7: Equal Access to Housing..........................................................................................85 IV.B Quantified Objectives ..........................................................................................87 Agenda Report Page 123 Attachment 2 Exhibit A

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Executive Summary ......................................................................................................................1 Piedmont 6th Cycle Housing Element.....................................................................................1 Key Findings ...........................................................................................................................6 How to Read and Review the Draft Housing Element ............................................................8 Section I Introduction..........................................................................................................11 I.A Community Context.............................................................................................11 I.B Housing Element Purpose...................................................................................11 I.C Organization of the Housing Element..................................................................12 I.D Data Sources and Methods.................................................................................13 I.E Summary of Public Participation..........................................................................14 I.F Relationship to Other General Plan Elements.....................................................21 I.G Other Statutory Requirements.............................................................................21 Section II Projected Housing Need .....................................................................................22 II.A Introduction and Overview of ABAG Methodology ..............................................22 II.B Alameda County Income Limits...........................................................................22 II.C Regional Housing Needs Allocation ....................................................................23 Section III Housing Resources .............................................................................................24 III.A Introduction..........................................................................................................24 III.B Land Resources ..................................................................................................24 III.C Financial and Administrative Resources .............................................................25 III.D Opportunities for Energy Conservation ...............................................................32 Section IV Housing Plan: Goals, Policies, and Programs.....................................................36 IV.A Introduction..........................................................................................................36 Goal 1: New Housing Construction ....................................................................................37 Goal 2: Housing Conservation ...........................................................................................48 Goal 3: Affordable Housing Opportunities..........................................................................51 Goal 4: Elimination of Housing Constraints........................................................................57 Goal 5: Special Needs Populations....................................................................................68 Goal 6: Sustainability and Energy ......................................................................................76 Goal 7: Equal Access to Housing.......................................................................................78 IV.B Quantified Objectives ..........................................................................................80 Agenda Report Page 124 Attachment 2 Exhibit A

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iii | City of Piedmont 2023-2031 Housing Element
Appendix A: Demographics and Housing Needs Assessment
Appendix B: Housing Capacity Analysis and Methodology
Appendix C: Constraints to Housing Production
Appendix D: Evaluation of the 2015-2023 Housing Element Appendix E: Public Participation and Meeting Summaries
Appendix F: Affirmatively Furthering Fair Housing Assessment Agenda Report Page 125 Attachment 2 Exhibit A
This Page Is Intentionally Left Blank
Agenda Report Page 126 Attachment 2 Exhibit A

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1 | City of Piedmont 2023-2031 Housing Element
Executive Summary
Piedmont 6th Cycle Housing Element
A. What is the Housing Element and why does it have to be updated? • The Housing Element is a key part of a city’s General Plan and must be updated every eight years, per State law.
• This project will update the Housing Element for the period of 2023 to 2031. The time period of 2023 to 2031 is the 6th housing element cycle (6th cycle). • The Housing Element will set forth the City’s fair housing goals, policies, and programs to address the need for all housing and household types.
• By law the Housing Element must be certified by the California Department of Housing and Community Development (HCD) as meeting housing law requirements.

B. What are the components of the Housing Element?
The Housing Element will:
• Provide an analysis of development constraints and the immediate and long-term housing needs in Piedmont.
• Identify land and financial resources to meet the City’s fair share of housing growth.
• Establish policies that address those needs based on the collective vision and values of the Piedmont community. • Include programs that would help implement those
policies.

The Housing Element, per State Law, must include:
• Housing Element Review: A performance evaluation of policies and programs from previous housing elements. (See Appendix D.)
• Housing Needs Assessment: A review of the existing and projected housing needs, especially regarding special needs populations (e.g., large households, low-income households, seniors, people with disabilities, and others). The demographic and data packets used in this have been pre-approved by HCD. (See Appendix A.) • Adequate Sites Inventory: A record of suitable land with realistic capacity to accommodate the City’s fair share of regional housing needs. (See Appendix B.) “None of the employees
can live in Piedmont with
the exception of
teenagers who live at
home with their parents.”
-Businesses and Institutions
Focus Group Meeting
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• Housing Resources Assessment: A record of administrative and financial resources available to support the development, preservation, and rehabilitation of housing. (See Section III.)
• Housing Constraints Assessment: Identified governmental and non-governmental (market, environmental, and others) impediments to housing development. (See Appendix C.)
• Affirmatively Furthering Fair Housing: Analysis of existing fair housing and segregation issues and plan to address any identified disparities in housing needs, displacement, or access to opportunity. (See Appendix F.)
• Implementation Plan: Goals, policies, and programs dedicated to meeting the City’s housing needs. (See Section IV.)
Adoption of the Housing Element does not:
• Require property owners to do anything to their property. • Require the City government to physically construct new housing. • Implement specific controls for individual neighborhoods. • Amend the Zoning Map or City Code.

C. Why is it important that I participate in the 6th Cycle Housing Element Update?
• The analysis of Piedmont residents shows that a large portion of Piedmonters, both renters and homeowners, are cost-burdened, meaning that they pay more than 30 percent of their income on housing. People of color, seniors, and women are more cost-burdened relative to other groups of residents. Many people employed in Piedmont must travel long distances to work. In addition, as the Piedmont
community continues to age, there are few options for
seniors to 'downsize', move to smaller homes, and remain in the Piedmont community. Families with young children cannot find their first ‘starter homes’ in Piedmont.
• Your input will help shape Piedmont housing for the next 8 years and make sure policies and programs are inclusive and represent the values and ideas of the diverse
population. Your input will guide the development of key ideas, policies, and programs to ensure the future of
affordable and accessible housing in Piedmont.

Housing Element flyers
posted on a community
bulletin board
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3 | City of Piedmont 2023-2031 Housing Element
• The City considers all input received through the outreach process when developing the housing plan for the 6th Cycle Housing Element. For more information on public outreach, see Section I.E, titled “Summary of Public Participation”, or visit Piedmontishome.org.

D. Who is preparing and reviewing the Housing Element update? On May 3, 2021, the City Council selected a housing consultant team lead by Lisa Wise Consulting (LWC), to prepare the Housing Element update. The Planning Commission, Housing Advisory Committee (HAC), and City Council are reviewing and providing feedback on draft documents, as well as input and guidance on the development of tasks under the Housing Element update process. Ultimately, the Housing Element update must be adopted by the City Council and must be certified by the California Department of Housing and Community Development (CA HCD) by January 31, 2023.

E. What is the Regional Housing Needs Allocation (RHNA) and how does it relate to the Housing Element?
• Each region of the State is allocated a specific number of housing units to meet the projected housing needs of people in four income categories: very low, low, moderate, and above moderate. Income categories are measured based on Area Median Income (AMI). This allocation is termed the Regional Housing Needs Allocation or “RHNA.” • The RHNA determines how much housing each municipality must accommodate within city limits. Piedmont is tasked with creating a plan to ensure land use and zoning regulations allow for enough housing development to meet the needs of the community.

Piedmont does not have to provide, physically construct, or develop all the housing needed but must have a plan that allows the housing to be built.

Agenda Report Page 129 Attachment 2 Exhibit A

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• See Section II, Projected Housing Need, for more information. • Piedmont has a total RHNA of 587 units, categorized as follows:
o Extremely and Very Low Income: 163 units
o Low Income: 94 units
o Moderate Income: 92 units
o Above Moderate Income: 238 units
• The RHNA for the 6th cycle is more than 9 times larger than the goal from the 5th cycle.

Therefore, the 6th Cycle Housing Element includes new policies and programs to increase housing opportunities and reduce newly identified constraints to meeting the larger housing targets (see G, below).

F. What is the Housing Element Sites Inventory?
• The sites inventory (also called the available land inventory or land resources map) is a crucial part of the Housing Element. In the sites inventory, a jurisdiction identifies where it has capacity to meet the housing production quotas assigned to Piedmont by the State of California and the Association of Bay Area Governments (ABAG) for all income categories (the RHNA). It is typically in the form of a map and table listing features and characteristics of the properties that are suitable for residential development. State law establishes criteria to determine which sites are eligible for inclusion on the sites inventory, with additional restrictions for sites identified for lower income housing. See Appendix B for more information.
• Table ES-1 below demonstrates the City’s plan to accommodate the City’s RHNA on sites within the City:

Table ES-1: Residential Development Potential and RHNA
Extremely
Low
Very Low Low Moderate
Above
Moderate Total
RHNA See Very Low 163 94 92 238 587
ADUs See Very Low 48 48 48 16 160
Approved/Entitled
Projects - - - - 1 1
Site Inventory1,2 1803 67 237 484
Total Capacity 276 115 254 645
Surplus 19 23 16 58
Source: City of Piedmont, LWC

1. See Table B-10 in Appendix B for the complete inventory

2. See Section B.3.1 in Appendix B for information on the Specific Plan

3. For calculation purposes, extremely low, very low, and low income totals were grouped.

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5 | City of Piedmont 2023-2031 Housing Element
G. What are the housing goals Piedmont is working towards? What is meant by the term housing “programs”?
• The City of Piedmont’s Public Review Hearing Draft Housing Element contains seven goals, 56 policies, and 66 71 programs. The seven goals of the Housing Element are:

New Housing Construction
Housing Conservation
Affordable Housing
Opportunities
Elimination of Housing
Constraints
Special Housing Needs
Populations
Sustainability and Energy
Equal Access to Housing
• City programs are the actions and public services that City staff will undertake and provide to the community over the next eight years, including the modifications to regulations and procedures required to comply with State law. City programs in the Housing Element must be consistent with other direction in the General Plan. • Programs implement housing goals and policies and address housing needs, resources, and constraints, as identified in the Housing Element and through community input. For example:
o New housing programs are included in response to input from the Piedmont community indicating a need for housing opportunities for people of diverse ethnic and social backgrounds, seniors, persons with disabilities, people just starting their careers, and families.
o As noted above, the significant increase in the City’s RHNA compared to previous cycles has led to changes to the City’s policies and programs. The City proposes new policies and programs to update and amend development regulations and land use policies that were not previously considered a constraint, but now play a more significant role in hindering or facilitating housing development. o New policies and programs are included to implement the recommendations in the sites inventory analysis, prepared in Appendix B, and address constraints to facilitating fair housing, as identified in the analysis conducted in Appendix F. o Since the 5th cycle, the Governor has signed several new pieces of housing legislation (such as SB330, SB9, AB 2345, and AB1851) that affect housing Agenda Report Page 131 Attachment 2 Exhibit A

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elements and city regulations. To ensure compliance with State law, the City has proposed new policies and programs in this Housing Element.

Key Findings
(For more information see Appendices A through F.)
• Average Piedmont households make more than double the Alameda County area median income (AMI); however,
housing in Piedmont is only affordable to the highest earning households. In 2019, Piedmont’s median household income was $224,659 compared to an Alameda County median
income of $99,406.
• Over 80 percent of Piedmont households earn more than 100 percent of the AMI. Approximately 14 percent of
Piedmont households are very low- or low-income, earning 80 percent or less of AMI, compared to 39 percent of
households in Alameda County.

Figure ES-1: Households by Household Income Level
Notes:

Universe: Occupied housing units
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) “I work in Piedmont
but cannot afford to
live in the City.”
- Community Workshop
Participant
6%
6% 16% 15%
11% 11%
12% 13%
5%
9% 9%
81%
53% 52%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Piedmont Alameda County Bay Area
Percent of Households
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI
81%-100% of AMI Greater than 100% of AMI
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7 | City of Piedmont 2023-2031 Housing Element
• Approximately 84 percent of lower-income senior households are cost-burdened, while 10 percent of female-headed
households with children live below the poverty line.
• Approximately one-fifth of households in Piedmont pay more than 30 percent of their household income on housing costs, meaning they are cost-burdened. Special housing groups, such as seniors, female-headed households, and non-White
households, are more likely to face housing challenges (such as housing cost burden).

Figure ES-2: Cost Burden Severity
Notes:

Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract rent plus utilities).

For owners, housing cost is "select monthly owner costs", which includes mortgage payment, utilities, association fees, insurance, and real estate taxes. HUD defines cost-burdened households as those whose monthly housing costs exceed 30% of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50% of monthly income.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25070, B25091)
“We need affordable
housing for
firefighters, City
staff, and teachers.”
- Community
Workshop Participant
76%
61% 62%
12%
20% 20%
9% 17% 16%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Households
0%-30% of Income Used for Housing 30%-50% of Income Used for Housing 50%+ of Income Used for Housing Not Computed
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• There is limited opportunity currently for multi-family or residential mixed-use development, as Zone C and Zone D are relatively built-out under existing development
regulations. Single-family residential development makes up over 68 percent of the City’s land area.
• Zoning Code doesn’t allow for a variety of multi-family housing types, and development regulations for multi-family buildings are restrictive (e.g., height, setbacks, and parking). • Since the last Housing Element, the City has updated its programs for Accessory Dwelling Units (ADUs). The City has many programs and policies to encourage ADU construction, which have been effective in creating new market-rate and affordable housing opportunities in recent years, with 22 ADUs permitted in 2021, and 27 permitted in 2022.
• Since the last Housing Element, the City facilitated the redevelopment of the former PG&E substation site on Linda Avenue, which provided seven, new multi-family townhomes in Zone C at a residential density nearing of 20 dwelling units per acre.
• Piedmont is a community of great opportunity and is classified as an area of the highest resource, based on economic,
education, and environmental indicators. High resource areas are places that offer low-income residents the best chance of a high quality of life, whether through economic advancement, high educational attainment, or clean environmental health. • The City has lower levels of segregation and isolation between neighborhoods (intra-city segregation) than average cities in the Bay Area region. However, the Piedmont community has a low population of racial groups other than non-Hispanic White and Asian populations, which may indicate segregation between Piedmont and the region (inter-city segregation).

How to Read and Review the Draft Housing Element
Organization.
• This Housing Element is organized into four sections:

I. Introduction
Provides an overview of the Housing Element and a summary of public participation.
“We need young
families in Piedmont
to create a healthy
and diverse
community.”
- Community
Workshop Participant
“Having a diversified
housing stock helps
everyone, including
existing residents and
seniors.”
- Community and
Housing Advocates
Focus Group Meeting
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9 | City of Piedmont 2023-2031 Housing Element
II. Projected Housing Need
Summarizes the City’s Regional Housing Need Allocation (RHNA) by income category for the 6th Cycle.

III. Housing Resources
Documents available administrative and financial resources for housing-related activities and summarizes the available land resources to accommodate the RHNA as documented in Appendix B.

IV. Housing Plan: Goals, Policies, and Programs
The City’s roadmap to achieving established fair housing goals, which sets targets to facilitate housing of all types, at all income levels. • The draft Housing Element includes six appendices (Appendices A through F), which detail the City’s required technical analyses (Appendices A through D and Appendix F) and provide supplemental outreach information (Appendix E).

How to Provide Comments
• The City is seeking input from all perspectives on the contents of the draft Housing Element. Input will be considered in subsequent revised drafts including at the time of Housing Element adoption and throughout implementation. Some topics to consider when reviewing and providing feedback on this draft Housing Element may include:
o Are there any housing needs (including special needs), constraints, or opportunities that have not been identified in this Housing Element update? o Do I have any other ideas on fair housing policies or programs? o How can I or my organization support the housing in Piedmont? o Any other housing-related comments, questions, or concerns? • All interested persons are encouraged to provide comments. This can be done by participating at any upcoming meetings, providing comments through Piedmontishome.org, or emailing comments to [email protected].

What Has Happened/Happens Next
• The City of Piedmont will received community input on the draft Housing Element update through the Spring/ Summer of 2022 and make made necessary and substantial changes as directed by the Planning Commission and City Council in response to public comment, at that time.
• With City Council approval, the City will submitted the Housing Element to HCD for review in the Fall of 2022.
• The City will has make made changes, as necessary, in response to HCD feedback and is movinge through the Housing Element update adoption process with the Piedmont Agenda Report Page 135 Attachment 2 Exhibit A

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community, Planning Commission, and City Council. The City is targeting adopting a substantially compliant Housing Element by January March 2023. • Potential environmental impacts of the Housing Element, including Housing Element policies and programs, will be evaluated pursuant to the California Environmental Quality Act (CEQA).

Agenda Report Page 136 Attachment 2 Exhibit A

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11 | City of Piedmont 2023-2031 Housing Element
Section I Introduction
I.A Community Context
The City of Piedmont is a charter city of approximately 11,000 residents located in the East Bay Hills, overlooking San Francisco Bay. The City consists primarily of established single-family homes on quiet, tree-lined streets. Piedmont contains five city parks and numerous landscaped areas which offer wooded paths, tennis courts, children’s playgrounds, and picnic facilities.

Piedmont’s 1.7-square-mile area is virtually built-out; its landlocked setting has influenced its historic development patterns and affects its potential for new housing and employment today.

Piedmont is located approximately 10 miles east of San Francisco and is completely encompassed by the City of Oakland. Piedmont’s proximity to the Bay Area’s major employment centers, in addition to its schools, established neighborhoods, and well-maintained parks make Piedmont a desirable place to live.

I.B Housing Element Purpose
The State of California has stated that the availability of decent and suitable housing for every California family is “a priority of the highest order” (California Government Code §54220). This objective has become increasingly urgent in recent years as communities across the State, including Piedmont, endeavor to meet the housing needs of all their residents. State Housing Element Law, established in 1969, recognizes the vital role local governments play in the supply and affordability of housing and requires all cities and counties in California to establish a longrange plan to meet their fair share of regional housing needs. Cities are charged with planning for the welfare of their residents, including ensuring that the existing and projected demands for housing are adequately met.

High housing costs — and related housing instability issues — increase health care costs (for individuals and the State), decrease educational outcomes (affecting individuals, as well as the State’s productivity), and make it difficult for California businesses to attract and retain employees.
– State of California 2025 Statewide Housing Assessment The Housing Element is the primary tool used by the State to ensure local governments are appropriately planning for and accommodating enough housing across all income levels. This Housing Element covers the planning period 2023-2031. The Housing Element is a mandatory part of a jurisdiction’s General Plan, but it differs from other General Plan elements in two key Agenda Report Page 137 Attachment 2 Exhibit A

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aspects. The Housing Element must be updated every eight years for jurisdictions within a metropolitan planning organization (MPO), such as the Association of Bay Area Governments (ABAG), on a four-year regional transportation plan (RTP) cycle. The Housing Element must also be reviewed and approved (i.e., certified) by the California Department of Housing and Community Development (HCD) to ensure compliance with statutory requirements. Certification also ensures that the City remains eligible for various State and federal funding sources.

In practical terms, the Housing Element provides the City with an opportunity to assess its housing needs and to develop policies and actions that effectively respond to those needs. Amongst other groups, the Housing Element affects teachers in our schools, employees in our local businesses, older residents on fixed incomes, parents and their adult children who want to remain in or return to Piedmont, and young persons wishing to live in the community. Ultimately, the supply and cost of housing affects the entire Bay Area economy and people’s quality of life in the region.

At the time of publication, the COVID-19 crisis has impacted the Bay Area in significant ways.

The pandemic has made the issue of housing security even more acute as residents face job loss, housing cost pressures, and disparate health impacts from the pandemic. This Housing Element has had to respond to these conditions by transitioning the public outreach process to reflect the limitations brought on by COVID-19. These actions are detailed in this report.

I.C Organization of the Housing Element
Per California Government Code §65580-65589, a Housing Element must consist of the following components:
• Evaluation of the 2015-2023 Housing Element: An evaluation of the results of the goals, policies, and programs adopted in the previous Housing Element that compares projected outcomes with actual achieved results. • Demographics and Housing Needs Assessment: An analysis of the existing and projected housing needs of the community. It provides a profile of socio-demographic information, such as population characteristics, household information, housing stock, tenure, and housing affordability.

The assessment also considers local special housing needs, such as, seniors, farmworkers, homeless, large households, and female-headed households.
•
• Housing Capacity Analysis and Methodology: An inventory listing adequate sites that are suitably zoned and available within the planning period to meet the City’s fair share of regional housing needs across all income levels.

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13 | City of Piedmont 2023-2031 Housing Element
• Housing Resources: An identification of resources to support the development, preservation, and rehabilitation of housing. • Constraints to Housing Production: An assessment of impediments to housing production across all income levels covering both governmental (e.g., zoning, fees, etc.) and nongovernmental (e.g., market, environmental, etc.).
• Housing Plan: This section provides a statement of the community’s goals, quantified objectives, and policies to maintain, preserve, improve, and develop housing, as well as a schedule of implementable actions to be taken during the planning period to achieve the goals, objectives, and policies. Quantified objectives for new construction, rehabilitation, and conserved units by income category (i.e., very low, low, moderate, and above moderate) are included to make sure that both the existing and the projected housing needs are met, consistent with the City’s share of the Regional Housing Needs Allocation (RHNA).

Section II of this Housing Element provides a summary of the projected housing need. Section III summarizes the adequacy of housing sites and identifies housing resources. Section IV contains goals, policies, and actions related to housing in Piedmont. The comprehensive research and analysis supporting the development of Section IV, are compiled in appendices to this Housing Element. These appendices contain the full set of information used to inform the City’s goals, policies, and programs:
• Appendix A: Demographics and Housing Needs Assessment • Appendix B: Housing Capacity Analysis and Methodology • Appendix C: Constraints to Housing Production
• Appendix D: Evaluation of the 2015-2023 Housing Element • Appendix E: Public Participation and Meeting Summaries • Appendix F: Affirmatively Furthering Fair Housing Assessment I.D Data Sources and Methods
This Housing Element was updated in accordance with California Department of Housing and Community Development (HCD) guidelines for the 6th Housing Element Cycle, incorporating additional considerations required under new State housing-related legislation. Specific documents are referenced throughout the Housing Element, including but not limited to the Piedmont 2009 General Plan and Zoning Ordinance, as well as the U.S. Census Bureau’s Agenda Report Page 139 Attachment 2 Exhibit A

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OnTheMap mapping and reporting application. The analyses and findings in this document relied on data compiled from various sources, including:
• U.S. Census Bureau (American Community Survey)
• California Department of Housing and Community Development (HCD) • California Department of Finance (DOF)
• U.S. Department of Housing and Urban Development (HUD) • Consumer Financial Protection Bureau (CFPB)
• Association of Bay Area Governments (ABAG) pre-certified data This document was also informed by information provided by residents, business groups, local institutions, City staff, and elected and appointed officials.

I.E Summary of Public Participation
Public participation is crucial in shaping Piedmont’s housing strategy. Understanding the needs of the community enables the development of housing strategies that are most appropriate and effective. Public outreach also allows the City to identify concerns unique to certain stakeholders that may not have been initially apparent. The City’s public participation program included five focus group meetings; pop-up information tables at community events; public workshops and meetings; Town Hall meetings; Open House events; Housing Advisory Committee meetings; meetings of the Planning Commission, Park Commission, and Recreation Commission; City Council meetings; and a variety of online, print, and digital engagement tools. Additionally, while in-person meetings and events were challenging due to the COVID-19 pandemic the City held hybrid meetings, whenever possible, and also attended popular local community events, such as the Harvest Festival on September 19, 2021, and the Labor Day Car Show on September 6, 2021, to raise awareness about the update. Public input played a significant role in the 6th Cycle Housing Element, with public comment directly resulting in new, updated, and modified programs, and revisions to the sites inventory. Activities are summarized below. For detailed public outreach summaries and meeting materials, please see Appendix E.

Website
The Housing Element update website (Piedmontishome.org) was used to provide an overview of the Housing Element update process and timeline, resources for Housing Element information (e.g., FAQs, meeting notices and summaries, draft documents, etc.), and to provide City contact information. Interested parties could sign up to receive information about upcoming meetings and documents. The website was available in English, as well as Spanish (translated) and Mandarin (translated).

Piedmont Is Home
Banners, March 2022
Agenda Report Page 140 Attachment 2 Exhibit A

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As of August 22, 2022February 17, 2023, the website had received 11,00015,000 total visits, 7,90011,000 unique visitors, and 1,400582 visitors in the past 30 days. Throughout the process, the website saw a substantial increase in visits immediately before and after public events and after flyers were circulated and banners were hung throughout Piedmont, publicizing the Housing Element update.

Videos
Informational videos prepared as part of the Housing Element update are available at the following links:

Welcome from Mayor Teddy Gray King
• https://www.youtube.com/watch?v=I
qeilrdyvZA
Housing Element Introduction
• https://www.youtube.com/watch?v=
ShfKW1OFPEA
Regional Housing Needs Allocation
• https://www.youtube.com/watch?v=u
UotF5M6HwA
Housing Element Basics
• https://www.youtube.com/watch?v=
S1S5cwcXO98
Housing Element Components
• https://www.youtube.com/watch?v=y
OTpfd-Lrkc
Housing Element Basics Animated Video
• https://www.youtube.com/watch?v=a
96w9m6Dt7g
Agenda Report Page 141 Attachment 2 Exhibit A

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Stakeholder/Focus Group Meetings
The City conducted five focus group meetings over three days in preparation of the Housing Element update:
• Focus Group #1: Friday, July 23, 2021
• Focus Group #2 and #3: Monday, July 19, 2021
• Focus Groups #4 and #5: Thursday, July 22,
2021
Due to the ongoing COVID-19 crisis, the focus groups
were held over webinar. Invitations were distributed to 64 individuals representing multiple stakeholder groups (See Appendix E for list of contacted groups). Of the 27 individuals who RSVP’d, 23 participants attended. Two
participants who were unable to attend the scheduled
meetings were able to provide written feedback.

Community Workshops
The City conducted community workshops.
• Community Workshop #1: December 2, 2021
The purpose of the Housing Element Update Community Workshop #1 was to provide an overview of the Housing Element process and the components of a Housing Element, share background information and preliminary findings from housing needs and constraints assessments, and gather questions/comments from meeting participants about critical housing issues, and needs and goals for housing in the City of Piedmont. Approximately 63 participants attended. The community workshop was held over webinar. • Community Workshop #2: March 24, 2022
The purpose of Workshop #2 was to provide an update on the Housing Element progress and report the results from Workshop #1. Additionally, Workshop #2 was designed to present the Piedmont Housing Puzzle, an interactive online platform designed to allow community members the opportunity to develop their own housing plan to accommodate the City’s RHNA.

The workshop was centered around an introduction of the Piedmont Housing Puzzle and a live demonstration with workshop participants creating their own housing plans. Following the demonstration, participants had an opportunity to ask questions about how to use the tool or other questions about the Housing Element. Approximately 84 people participated in the virtual workshop. The Piedmont Housing Puzzle was widely publicized, accepted online submissions from March 24, 2022, to May 1, 2022, and generated 2,099 total page views and 1,050 new sessions. The City received 173 community member housing plans and comments.

Piedmont is Home free-standing sign
encourages community participation.

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Housing Advisory Committee
In February 2021, the City formed a Housing Advisory Committee (HAC) in part to review and provide feedback on draft documents prepared throughout the Housing Element update process.

The HAC is made up of five members, composed of four residents at large and one member of the Planning Commission. The HAC advised on several housing related initiatives in the City, including the Housing Element update. The HAC meetings on the Housing Element are summarized below.
• Housing Advisory Committee #1 Joint Study Session with Planning Commission:

September 29, 2021
The presentation included the purpose of the Housing Element, components of a Housing Element, and the project timeline. The presentation also provided discussion of the Regional Housing Needs Allocation (RHNA) for Piedmont broken down by income group, as set by the Association of Bay Area Governments (ABAG). The joint study session was held over webinar. • Housing Advisory Committee #2: April 19, 2022
The presentation included an overview of the Housing Element, findings from the housing constraints assessment, an overview of the available site inventory, and fair housing goals, policies, and programs. The meeting was held over webinar and encouraged public participation. There were approximately 30 attendees.

Park Commission and Recreation Commission Meetings
City staff presented the Housing Element to the following City commissions:
• Park Commission: May 4, 2022
• Recreation Commission: May 18, 2022
The purpose was to:
• Provide an informational report to Piedmont’s civic leaders about the Housing Element update
• Provide sources for Housing Element information
• Provide additional forums for public comment
• Highlight the opportunities and tradeoffs of the draft housing programs and sites inventory The presentations included a description of the Regional Housing Needs Assessment (RHNA) and the 5th Cycle Housing Element, an explanation of new 6th Cycle Housing Element requirements, the sites inventory and housing plan, next steps, and how to find more information.

The commission meetings were held both in the City Hall Council Chambers and over webinar and both accepted public comment.

Agenda Report Page 143 Attachment 2 Exhibit A

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Planning Commission Meetings
City staff presented the Housing Element to the Planning Commission on May 12, 2022, in addition to the joint Planning Commission/Housing Advisory Committee meeting described above. • Planning Commission Meeting: May 12, 2022
City staff presented key findings and recommendations of the Public Review Draft Housing Element (released April 2022) and solicited feedback from the Planning Commission and the general public. The presentation began with an overview of the Housing Element update, and then focused more specifically on the sites inventory and draft goals, policies, and programs.

The Planning Commission adopted Resolution 12-PL-22, recommending edits to the Draft Housing Element and recommending that the City Council direct staff to send the Draft Housing Element to the California Department of Housing and Community Development (HCD). The Planning Commission meeting was held both in-person and over webinar; approximately 50 members of the public attended.
• Planning Commission Meeting: January 12, 2023
City staff presented the Housing Element to the Planning Commission at a duly noticed public hearing in the City Council Chambers and on the Zoom and KCOM virtual meeting platforms.

The Planning Commission heard a presentation by City staff and consultants, and afterwards conducted the public hearing. Approximately 15 people participated in Council Chambers and an unknown number participated via virtual meeting format. One speaker addressed the Planning Commission and one item of late mail was described to the Planning Commission by staff. The Planning Commissioners deliberated and then adopted a recommendation that the City Council adopt the Housing Element and the Initial Study and Negative Declaration prepared pursuant to CEQA for the Housing Element. The motion passed 3-0 by the Planning Commission to recommend the City Council adopt the 6th cycle Housing Element Update with revisions necessary to address HCD comments and adopt the Initial Study and Negative Declaration prepared pursuant to CEQA for the 6th Cycle Housing Element project. • Planning Commission Meeting: March 13, 2023
City staff presented status report on the progress of the Housing Element update to the Planning Commission during a regular meeting held in the City Council Chambers and via the Zoom and KCOM virtual meeting formats. The Commission heard a presentation by staff which outlined the comment letter received by the California Department of Housing and Community Development (HCD) on February 16, 2023, and the City’s responses to each of the 29 comments included in the letter. The Planning Commission opened the floor to public comment. No speakers addressed the Commission. Approximately 10 people participated in the meeting in Council Chambers and an unknown number via virtual meeting format. After the close of the public comment segment, the Planning Commission discussed the City’s efforts.

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In addition to the meetings described above, City staff made presentations monthly at the Planning Commission to provide updates on the Housing Element’s progress.

Town Hall Meetings
City staff conducted two Town Hall meetings.
• Town Hall Meeting: June 7, 2022
City staff conducted a Town Hall meeting to answer common, recurring questions from Piedmont residents about the Draft Housing Element, and to provide a forum for additional questions. City staff presented answers to 27 questions selected from over 550 comments and questions the City received at various engagement events and by various means throughout the Housing Element update process. The Town Hall meeting was held over webinar.
• Housing Element 102 Session and Open House: August 18, 2022 City staff also conducted a Housing Element 102 Community Information Session. The presentation covered housing element basics, new State laws, penalties for noncompliance, the regional housing needs allocation (RHNA), the site inventory, recent direction from City Council, and the project schedule, and invited participants to an open house in the City Hall courtyard directly afterwards to discuss their questions with City staff.

City Council Meetings
City staff presented the Housing Element to the City Council. • City Council Meeting #1: June 20, 2022
City staff presented the Housing Element update to the City Council at a special meeting, soliciting comments and questions from the City Council. At the onset of the meeting, the City Administrator clarified that staff was not seeking a recommendation at this meeting. The presentation began with an overview of the Housing Element update, including key findings, community outreach and noticing, common public comment topics, site inventory, and the implementation plan. Then most of the meeting time was focused on Council discussion and hearing public comment. The City Council did not take action or vote on the Housing Element update, but rather, directed staff to conduct additional analysis regarding the sites inventory.

The June 20, 2022, City Council meeting was held both in-person and over webinar.

Approximately 60 members of the public attended.
• City Council Meeting #2: August 1, 2022
City staff returned to the City Council to present a high-level economic feasibility analysis for a housing plan that includes the Civic Center sites, as well as alternative sites to accommodate units to be moved from 120 Vista Avenue, 801 Magnolia Avenue, the Highland Avenue grassy strip, and Corey Reich Tennis Center. Staff sought additional direction from Agenda Report Page 145 Attachment 2 Exhibit A

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City Council with how to proceed in its preparation of the sites inventory. The August 1, 2022 City Council meeting was held both in-person and over webinar. • City Council Meeting #3: November 15, 2022
On November 15, 2022, the City Council held a special meeting to consider authorizing staff to submit the City’s Draft 6th Cycle Housing Element to the California HCD for review. The presentation by staff described the revisions in response to comments and ideas made by the Piedmont community to the Draft Housing Element, published April 8, 2022. Approximately 60 people participated in the meeting. At the close of the public comment at the meeting, the City Council granted authorization to City staff by unanimous vote.

Additional Outreach and Noticing
In addition to the outreach methods described above, the Housing Element was publicized to Piedmont residents and employees and regional visitors and commuters through the following:
• Piedmont Planning Bulletin: The City prepares and
sends regular email bulletins noticing recipients about Planning and housing-related news, updates, and
upcoming events.
• Balancing Act: The Piedmont Housing Puzzle, which
was demonstrated at Workshop #2, is a digital online
platform to provide comments directly to the City
regarding opportunities and challenges related to
housing in the City of Piedmont.
• Banners: The City posted banners throughout the City
along major roadways, such as Grand Avenue,
Highland Avenue, and Moraga Avenue to publicize the
Housing Element update process and the project
website to residents and inter-city commuters.
• Housing Element Table: The City set up a Housing
Element information table at local community events,
including the Harvest Festival on September 19, 2021 and the Labor Day Car Show on September 6, 2021, that were staffed by local officials. • Local Press Coverage: The Piedmont Post newspaper, Piedmonter newspaper, and Piedmont Exedra and Piedmont Civic Association websites advertised and posted links to the public review Draft Housing Element and informed readers about how to submit comments.

Summary of Public Comments
Comments received are documented comprehensively in Appendix E. Community input played a significant and integral role in crafting the Housing Element including the sites inventory and Piedmont is Home flyer in the
window of an educational
organization.

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programs. Some examples of how public outreach and repeated public comments resulted in meaningful program or sites edits to the Housing Element include, but are not limited to:
• Piedmont should allow and promote smaller, more affordable homes, especially to lowerincome individuals and households (Programs 2. B, Availability of Small Homes,; 4.J, Small Lot Housing Study,; 4.K, Small Lot Affordable Housing Study,; 5.H, Housing for Extremely Low-Income Individuals and Households,; 5.H, Housing for Extremely LowIncome Individuals and Households,; 5.I, Housing for Extremely Low-Income Families) • Piedmont should promote ADUs and make them easier to build on existing lots, or even require ADUs for new single-family residence construction (Program 1.B, Market-Rate Accessory Dwelling Units,; 1.C, Public Engagement for Accessory Dwelling Units,; 1.E, Require ADUs for New Single-Family Residence Construction,; 1.M, Manufactured and Mobile Homes,; 1.S, ADU Compliance; 3.B, Increase Number of Legal Accessory Dwelling Units,; 3.C, Monitoring Accessory Dwelling Unit Missed Opportunities,; 3.D, Monitoring Additional ADU Development Opportunities,; 3.E, Affordable Housing Fund,; 3.F, Incentives for Rent-Restricted ADUs,; 3.H, Monitor ADU Occupancy/Affordability) • Piedmont should allow missing middle housing, more multi-family housing, and denser development (Programs 1.F, Increase Allowances for Housing in Zone B,; 1.G, Facilitating Multi-family Development in Zone C,; 1.H, Increase Allowances for Housing in Zone D,;

1.L, Specific Plan)
• Religious facilities indicated interest in developing housing (Program 1.D, Allow Religious Institution Affiliated Housing Development in Zone A,; 4.V, Allow Emergency Shelters as Accessory uses to Religious Facilities in Zone A; 5.G, Faith Community Participation) • Members of the public expressed interest in an Affordable Housing Fund (Program 3.E, Affordable Housing Fund)
• The City should amend its development and permitting standards to make it easier to build housing, including transitional and supportive housing, housing for people with disabilities, and other special needs groups (Program 4.L, Allow Parking Reductions for Multi-Family, Mixed-Use, and Affordable Projects,; 4.M. Facilitate Multi-Family and Residential MixedUse Projects by Right Subject to Objective Standards,; 4.N, Allow Transitional and Supportive Housing by Right in Zones that Allow Residential Uses,; 4.Q, Parking Reductions for Persons with Disabilities, Seniors, and Other Housing Types,; 4.R, Permit Streamlining,; 5.D, Accommodations for Disabled Persons,; 5.J, Developmentally Disabled Residents,; 5.K ,Transitional and Supportive Housing for Extremely Low-Income Residents)
• The City should consider the role of Blair Park in supporting the City’s housing related goals (included Blair Park in the Moraga Specific Plan area after the Public Review Draft) • The City should consider the role of mixed-use properties in Zone D to support the City’s goals (included additional Zone D sites in the sites inventory after the Public Review Draft) • The sites inventory should focus on housing in areas with the greatest opportunity and avoid unnecessarily constraining improvements to City facilities in the Civic Center Agenda Report Page 147 Attachment 2 Exhibit A

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(removed city owned property in the civic center from the sites inventory after the Public Review Draft)
I.F Relationship to Other General Plan Elements
The Housing Element is one of seven mandatory elements of the City’s General Plan, a longrange vision document that provides guidance for future development in Piedmont. City Council adopted the most recent General Plan in 20091. For the General Plan to provide effective guidance on land use issues, the goals, policies, and programs of each element must be internally consistent with other elements. This Housing Element builds upon the existing General Plan and must be consistent with its goals and policies. To ensure consistency, the General Plan will be amended, as needed, to align with recommendations from the Housing Element. In the event an element of the General Plan is amended, the City will consider the impacts of the amendment on the other elements to maintain consistency across all documents.

I.G Other Statutory Requirements
Water and Sewer Priority
Government Code §65589.7 requires each public agency or private entity providing water or sewer services to grant a priority for the provision of these services to proposed developments that include lower income housing units. In Piedmont, sewer infrastructure services are provided by the City and water services are provided the East Bay Municipal Utility District (EBMUD). The City has not denied, applied conditions, or reduced the amount of sewer service for a development that includes housing affordable to lower-income households, consistent with State law. As part of this Housing Element, the City will adopt written policies and procedures that grant a priority for sewer hook-ups and service to developments that help meet Piedmont’s share of the regional need for lower-income housing (see Policy 4.8 and Program 4.S).

Government Code §65589.7 also requires adopted Housing Elements to be immediately delivered to all public agencies or private entities that provide water or sewer services for municipal and industrial uses, including residential. The City will provide the adopted Housing Element to EBMUD immediately upon adoption.
1 Piedmont approved its first Preliminary Master Plan in 1958, with amendments addressing noise and safety in 1974 and 1975, respectively. The City adopted its first General Plan in 1984. The 2009 General Plan was the first comprehensive update since 1984 Most recently, the City adopted its updated Environmental Hazard Element on February 18, 2020.

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Section II Projected Housing Need
II.A Introduction and Overview of ABAG Methodology
State Housing Element law (Government Code §65580 et. seq.) requires regional councils of governments to identify for each member jurisdiction its "“fair share allocation"” of the Regional Housing Needs assessment provided by the California Department of Housing and Community Development (HCD). In turn, each city and county must demonstrate the capacity to accommodate their local share of regional housing needs in the community’s Housing Element.

Each jurisdiction’s responsibility for meeting the overall regional housing need is established as a Regional Housing Needs Allocation (RHNA).

The Association of Bay Area Governments (ABAG), the council of governments for the Piedmont area, adopted its final 6
th Cycle RHNA allocation methodology in December 2021. ABAG considered several factors in preparing the methodology, which weighed both projected and existing need. Projected need was informed by the target vacancy rate, the rate of overcrowding, and the share of cost-burdened households, household growth, future vacancy need, and replacement need, while existing need considered transit accessibility and job accessibility. The distribution of the RHNA across the four income categories factored in a social equity adjustment, which allocated a lower proportion of lower-income RHNA to jurisdictions that already had a high concentration of such households in comparison to the County, as well as the goal to Affirmatively Further Fair Housing (AFFH), which adjusted the distribution of RHNA in jurisdictions considered either very low or very high resource areas. According to Appendix 6 of ABAG’s Final RHNA Plan, Piedmont had a net zero change in RHNA on account of the equity adjustment.

II.B Alameda County Income Limits
The projected housing needs are broken down by income category based on definitions in the California Health and Safety Code (§50079.5). HCD calculates “extremely low”, “very low”, “low”, “median”, “moderate”, and “above moderate” income limits, and publishes these limits at the county level. Alameda County’s 2021 income limits for households of one to four persons are shown in Table II-1. See Appendix A, Table A-5, for a table listing income limits for households of up to eight persons.

Table II-1: Alameda County 2021 Income Limits
Number of Persons in Household 1 2 3 4
Extremely Low (0-30% of AMI) $28,800 $32,900 $37,000 $41,100 Very Low (30-50% of AMI) $47,950 $54,800 $61,650 $68,500 Low (50-80% of AMI) $76,750 $87,700 $98,650 $109,600
Median (80-120% of AMI) $87,900 $100,500 $113,050 $125,600 Moderate (120% of AMI) $105,500 $120,550 $135,650 $150,700 Source: Department of Housing and Community Development, 2021 Agenda Report Page 149 Attachment 2 Exhibit A

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II.C Regional Housing Needs Allocation
The RHNA for Piedmont is shown in Table II-2. The City has a total allocation of 587 units for the 2023 to 2031 planning period.

Table II-2: 6th Cycle RHNA
Piedmont Alameda County ABAG
Area/Income Number of
Units
Percent Number of
Units
Percent Number of
Units
Percent
Total 587 100% 88,997 100% 441,176 100%
Extremely Low and Very
Low1 163 28% 23,606 27% 114,442 26%
Low 94 14% 13,591 15% 65,892 15%
Moderate 92 15% 14,438 16% 72,712 17%
Above Moderate 238 43% 37,362 42% 188,130 42%
1 “Extremely Low” included in “Very Low” Category, assumed to be 50% of the Very Low allocation.

Source: ABAG, LWC
The City of Piedmont is not responsible for the actual construction of these units. Piedmont is, however, responsible for creating a regulatory environment in which the private market could build unit types included in its State housing allocation. This includes the creation, adoption, and implementation of General Plan policies, zoning standards, and/or economic incentives to encourage the construction of various types of units.

Agenda Report Page 150 Attachment 2 Exhibit A

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Section III Housing Resources
III.A Introduction
There are a variety of resources available to support the City in implementing its housing strategy, including resources for landowners, developers, and residents. This Section provides a summary of land resources available to accommodate future housing in the City. The detailed housing capacity analysis and methodology is contained in Appendix B. This Section also includes a list of local, regional, State, and federal programs that provide financial and related assistance to support the City in meeting its housing goals.

III.B Land Resources
A critical part of the Housing Element is the sites inventory, which identifies a list of sites that are suitable for future residential development. State law mandates that each jurisdiction ensure availability of an adequate number of sites that have appropriate zoning, development standards, and infrastructure capacity to meet its fair share of regional housing need (i.e., RHNA) at all income levels. The inventory is a tool that assists in determining if the jurisdiction has enough land to meet its RHNA given its current regulatory framework.

Identification of Sites Suitable for Housing
The sites identified in the site inventory (Appendix B) are comprised of parcels located in various areas and zones within the City. Due to the nearly built-out nature of Piedmont, critical areas for housing and redevelopment are City-owned property, public land (including a park), and underutilized land used for commercial and/or mixed-uses. Each site has undergone an assessment to determine development potential and residential unit capacity given existing zoning standards, potential capacity under new zoning regulations, and development trends. For detailed information, please see Appendix B.

Summary of Adequate Sites
Table III-1 summarizes the City’s methods for satisfying its RHNA. Based on accessory dwelling unit (ADU) projections, entitled and proposed projects, available 6th Cycle sites (including a zoning amendment program), the City has capacity for 644 units across all income categories, resulting in a 10 percent, or 58-unit, excess over the RHNA.

Assumptions and methodology for this determination and a detailed list of sites are included in Appendix B.

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Table III-1: Residential Development Potential and RHNA Extremely
Low
Very Low Low Moderate
Above
Moderate
Total
RHNA See Very Low 163 94 92 238 587
Approved/Entitled Projects - - - - 1 1
Remaining RHNA 163 94 92 237 586
ADUs See Very Low 48 48 48 16 160
Site Inventory1,2 1803 67 237 484
Total Capacity 276 115 253 644
Surplus 19 23 16 58

1. See Appendix B, Table B-10 11 for the complete inventory

2. See Appendix B, Section B.3.1 for information on the Specific Plan

3. For calculation purposes, extremely low, very low, and low-income totals were grouped.

Source: City of Piedmont, LWC 2021
III.C Financial and Administrative Resources
The following Section contains a list of financial, administrative, and other resources at the local, regional, State, and federal levels to help the City address its housing needs. Availability of these resources is dependent on governmental priorities, legislation, and continued funding, which may be subject to change at any time.

City Resources
• SB 2 Housing Programs Grant: On
September 16, 2019, the City Council
approved the City’s application to participate in
the State of California SB 2 grants program.

The application included a scope of work,
which outlined the tasks and activities that the
City wished to pursue in order to accelerate the
production of housing in Piedmont. The grant
application’s scope focused efforts on the two
main strategies in the existing 2014 Piedmont
Housing Element: the construction of ADUs
and Junior ADUs on residential properties and
development of objective design standards for
mixed-use multi-family development in Zones C
and D (multi-family and mixed-use zones,
respectively).

City Center Plaza in Redwood City,
California, is a mixed-use affordable
housing development. It has 81 units
with a density of 46 du/ac.

Source:
http://www.carducciassociates.com/
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In 2020. The City’s SB 2 grant application was accepted by State of California Department of Housing and Community Development (HCD), and HCD awarded the City $160,000 in reimbursable funds to complete the project scope. On August 17, 2020, the City Council authorized a contract with Lisa Wise Consulting (LWC) to complete the SB 2 Housing Programs project. The scope of work for ADUs included the analysis of possible incentives for rent-restricted affordable ADUs, including consideration of State and regional grant opportunities, such as Measure A1 (2016). This work is on-going. • Recent Improvements to Housing Regulations: Piedmont’s Zone C, multi-family zoning district, consists of a cluster of parcels near the Oakland Avenue bridge and Linda Avenue, and a few lots scattered among the Zone A district. In 2013, the City modified its commercial zoning district (Zone D) along Grand Avenue and near Highland and Vista Avenues to include mixed-use, multi-family development. In 2017, the City updated the development standards for Zone D to better accommodate mixed-use, multi-family development. In 2020, the City completed comprehensive updates to the Accessory Dwelling Unit Ordinance, consistent with State law. These improvements created new ministerial development standards for both ADUs and Junior ADUs, as well as other changes. Since the 1990'’s and into the 5th Cycle Housing Element, the City has found that an effective housing program is to actively encourage the production of ADUs.

Regional Resources -– Alameda County
• Measure A1: Measure A1 is a low-interest loan program funded through a countywide parcel tax and administered by the Alameda County Department of Housing and Community Development (Alameda HCD). In 2016, Alameda County residents voted to adopt Measure A1, a $580 million property tax revenue bond for affordable housing. The City’s Measure A-1 allocation ($2.2 million) project application was originally set to be approved by the County of Alameda by December 31, 2021, with the funds be spent within 5 years after the application is approved. City staff have received an extension of the application deadline to December 2024.
• AC Boost – Down Payment Assistance Program: Funded by Measure A1 funds, the program offers shared appreciation loans of up to $210,000 to first-time homebuyers who live, work in, or have been displaced from Alameda County. There is limited preference for First Responders and Educators (including public school employees and childcare providers). This program is administered by the non-profit organization Hello Housing, on behalf of Alameda County Housing and Community Development Department. • Renew AC – Home Improvement Loan Assistance Program: Renew AC provides lowincome homeowners in Alameda County with one percent interest rate loans of $15,000 to $150,000 to complete home improvement projects ranging from correcting health and safety hazards to accessibility upgrades and structural rehabilitation. No monthly payments are required. Renew AC is operated by Habitat for Humanity East Bay/Silicon Agenda Report Page 153 Attachment 2 Exhibit A

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Valley, on behalf of Alameda County Housing and Community Development Department and funded by Measure A1.
• Mortgage Credit Certificate Program: This program provides income eligible first-time home buyers the opportunity to reduce the amount of federal income tax they owe each year they own and live in their home. The Mortgage Credit Certificate (MCC) assists a family in qualifying for a higher first mortgage with no effect on monthly expenses.

Refinanced Mortgage Credit Certificates (RMCC) are also available when the homeowner refinances their original MCC Loan. A RMCC must be issued for each refinance for the homeowner to continue receiving their federal tax credit. Funding for this program is provided by the California Debt Limit Allocation Committee (CDLAC).

Regional Resources -– Housing Authority of the County of Alameda (HACA) • Section 8 Housing Choice Voucher Program (HCVP): Over 7,000 families and 3,500 housing owners participate in the HCVP. The HCVP provides rental assistance to eligible families and guarantees monthly payments to owners. The family’s portion of the rent ranges from 30 to 40 percent of household income, and HACA pays the difference directly to the landlord, up to the established payment standards. Effective May 26, 2021, Section 8 Housing Choice Voucher households are eligible to enroll in an Emergency Broadband Benefit (EBB). The EBB will provide a discount of up to $50 per month towards broadband service for eligible households and up to $75 per month for households on qualifying Tribal lands. Eligible households can also receive a one-time discount of up to $100 to purchase a laptop, desktop computer, or tablet from participating providers if they contribute more than $10 and less than $50 toward the purchase price.
• Section 8 Project-Based Program: This program subsidizes the rent and utilities of a unit in a subsidized development. If the tenant in a Project-Based unit moves out of the development during the first year of the lease, the tenant’s assistance ends. If the tenant moves out of the development after the first year, the assistance continues and follows the tenant. HACA provides 713 units of Project-Based assistance in the various developments, none of which are currently in Piedmont.
• Section 8 Moderate Rehabilitation Program: This program subsidizes the rent and utilities of a unit in a subsidized development that has undergone some rehabilitation. If, at any time, the tenant in a Section 8 Moderate Rehabilitation unit moves out of the development, the tenant’s Section 8 assistance ends. HACA provides 18 units of Section 8 Moderate Rehabilitation assistance at two developments in Hayward and one in Emeryville.
• Section 8 VASH Program: Similar to the Section 8 Housing Choice Voucher Program, the Veterans Affairs Supportive Housing (VASH) Voucher Program helps homeless veterans lease safe, affordable housing. VASH is a partnership between the Veterans Administration (VA) and the U.S. Department of Housing and Urban Development Agenda Report Page 154 Attachment 2 Exhibit A

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(HUD). Participating veterans receive case management and clinical services provided by the VA to help them maintain healthy, productive lives. • Mainstream Voucher Program: HACA administers 189 vouchers under HUD’s Mainstream program. The program is targeted to households with at least one non-elderly disabled family member who is homeless, at-risk of homelessness, coming out of an institutional facility or at-risk of entering an institutional facility due to lack of housing. HACA partners with an array of supportive services organizations that provide appropriate services to program participants.
• Eden Council for Home and Opportunity, Inc. (ECHO Housing): ECHO Housing offers various programs including classes on how to find, qualify for and buy a home; debt and financial education and counseling; and a Rental Assistance Program (RAP) that assists with move-in costs or delinquent rent due to a temporary financial setback. They also provide tenant-landlord counseling and fair housing services to assist Piedmont renters to remain in their homes.

State Resources
• Accessory Dwelling Unit Grant Program: The ADU Grant Program, provided by the California Housing Finance Agency, provides a grant of up to $40,000 to reimburse predevelopment costs associated with the construction of the ADU. Pre-development costs include site prep, architectural designs, permits, soil tests, impact fees, property survey, and energy reports.
• Affordable Housing and Sustainable Communities Program (AHSC): Administered by the Strategic Growth Council, this program provides grants and/or loans to fund landuse, housing, transportation, or land preservation projects that support infill and compact development that reduce greenhouse gas emissions.
• CalHome: HCD provides grants to local public agencies and non-profit housing developers to assist first-time homebuyers with down payment assistance through deferred-payment loans, rehabilitation, homebuyer counseling, self-help mortgage assistance, or other technical assistance. $57 million available in State CalHome program. • California Emergency Solutions and Housing (CESH): This program provides funds for a variety of activities to assist persons experiencing or at risk of homelessness, such as housing relocation and stabilization services (including rental assistance), operating subsidies for permanent housing, flexible housing subsidies, emergency housing operating support, and homeless delivery systems.
• Homekey: This program provides funding to protect Californians experiencing homelessness who are impacted by COVID-19.

Agenda Report Page 155 Attachment 2 Exhibit A

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• Housing for a Healthy California (HHC) Program: This program creates supportive housing for recipients of or those eligible for healthcare provided through the California Department of Health Care Services’ Medi-Cal program.
• Housing Navigator’s Program: This grant program funds housing navigators to help young adults aged 18 to 21 years secure and maintain housing, with priority for individuals in the foster care system.
• Infill Infrastructure Grant Program (IIG): This program promotes infill housing development by providing grant funding, in the form of gap assistance, for infrastructure improvements required for qualifying multi-family or mixed-use residential development. • Joe Serna, Jr. Farmworker Housing Grant (FWHG) Program: This program provides deferred payment loans for both owner-occupied and rental housing for agricultural workers, with a priority for lower income households.
• Local Housing Trust Fund (LHTF) Program: This program provides matching funds to local or regional housing trust funds for the creation, preservation, and rehabilitation of affordable housing, transitional housing, or emergency shelters. • Mills Act: The Mills Act is an economic incentive programs for the restoration and preservation of qualified historic buildings by private property owners. It grants local governments the authority to enter into contracts with owners of qualified historic properties who actively participate in the restoration and maintenance of their historic properties while receiving property tax relief.
• Mobilehome Park Rehabilitation and Resident Ownership Program (MPRROP): This program provides financing to support the preservation of affordable mobilehome parks through conversion of the park to an ownership model.
• Multi-family Housing Program (MHP): This program provides deferred payment loans for the construction, preservation, and rehabilitation of permanent and transitional rental housing for lower-income households.
• National Housing Trust Fund: This program provides deferred payment or forgivable loans for the construction of permanent housing for extremely low-income households.

The covenant is for 55 years.
• Permanent Local Housing Allocation (PLHA) Program: This program provides a permanent source of funding to all local governments in California to help cities and counties implement plans to increase affordable housing stock. Funding for this program is provided through a $75 recording fee on real estate transactions. Also see discussion above under Local Resources.
• Predevelopment Loan Program (PDLP): This program provides financing to cover predevelopment costs to construct, preserve, or rehabilitate assisted housing.

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• Supportive Housing Multi-family Housing Program (SHMHP): This program provides low interest deferred loan payments to developers building affordable rental housing that contain supportive housing units.
• Transit-Oriented Development (TOD) Housing Program: This program provides lowinterest loans as gap financing for higher density affordable rental housing near transit. • Veterans Housing and Homelessness Prevention Program (VHHP): This program supports the acquisition, construction, rehabilitation, and preservation of affordable multifamily housing for veterans and their families. • Golden State Acquisition Fund: This $93 million fund provides low-cost financing aimed at supporting the creation and preservation of affordable housing across the State. • California Housing Finance Agency (CalHFA): CalHFA offers a variety of low-cost loan programs to support the development of affordable multi-family rental housing, mixedincome housing, and special needs housing. • California Housing Finance Agency (CalHFA), Mortgage Credit Certificate Program:

The MCC program is a homebuyer assistance program designed to help lower‐income families afford home ownership. The program allows home buyers to claim a dollar‐for‐ dollar tax credit for a portion of mortgage interest paid per year, up to $2,000. The remaining mortgage interest paid may still be calculated as an itemized deduction. • Elderlink: A senior care referral service licensed by the Department of Public Health. This organization provides independent and free personalized senior care placement services to fully screened and approved nursing home, board and care, and assisted living facilities.

Federal Resources
• HOME Program: Participating jurisdictions may use HOME funds for a variety of housing activities, according to local housing needs. Eligible uses of funds include tenant-based rental assistance; housing rehabilitation; assistance to homebuyers; and new construction of housing. HOME funding may also be used for site acquisition, site improvements, demolition, relocation, and other necessary and reasonable activities related to the development of non-luxury housing. Funds may not be used for public housing development, public housing operating costs, or for Section 8 tenant-based assistance, nor may they be used to provide non-federal matching contributions for other federal programs, for operating subsidies for rental housing, or for activities under the Low-Income Housing Preservation Act.
• Community Development Block Grant (CDBG): Federal funding for housing programs is available through the U.S. Department of Housing and Urban Development (HUD).

Piedmont participates in the CDBG program through the “Alameda County Urban County CDBG Grant”, which applies to HUD for funds on behalf of the City and other jurisdictions, including unincorporated Alameda County, Albany, Dublin, Emeryville, and Newark. The Agenda Report Page 157 Attachment 2 Exhibit A

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Alameda CDBG program funds community centers, food banks (including Meals on Wheels-type programs), housing rehabilitation programs, childcare facilities, and park and sidewalk improvements, among other items.
• Section 108 Loan Guarantee Program: Allows CDBG entitlement jurisdictions to leverage their annual grant allocations to access low-cost financing for capital improvement projects. Eligible activities include housing, economic development, public facility, and infrastructure. This program is often used to catalyze private investment in underserved communities or as gap financing.
• Section 811 Project Rental Assistance: HUD offers long-term project-based rental assistance through a NOFA published by the California Housing Finance Agency (CalHFA).
• Emergency Solutions Grants (ESG) Program: This program provides funding for cities, counties, and states to (1) engage homeless individuals and families living on the street; (2) improve the number and quality of emergency shelters for homeless individuals and families; (3) help operate these shelters; (4) provide essential services to shelter residents, (5) rapidly rehouse homeless individuals and families, and (6) prevent families/individuals from becoming homeless.
• Veterans Affairs Supportive Housing (VASH) Program: HUD-VASH is a collaborative program between HUD and VA that combines HUD housing vouchers with VA supportive services to help veterans who are homeless and their families find and sustain permanent housing.
• Low-Income Housing Preservation and Residential Home Ownership Act (LIHPRHA): This program requires all eligible HUD Section 236 and Section 221(d) projects at risk of conversion to market-rate rentals from mortgage pre-payments be subject to LIHPRHA incentives, which include subsidies to guarantee an eight percent annual return on equity.
• Low-Income Housing Tax Credit: Administered through the California Tax Credit Allocation Committee (TCAC), the Low-Income Housing Tax Credit (LIHTC) subsidizes the acquisition, construction, and rehabilitation of affordable housing by providing a tax credit to construct or rehabilitate affordable rental housing for low-income households. • Federal Historic Preservation Tax Program: The Federal Historic Preservation Tax Incentives program encourages private sector investment in the rehabilitation and re-use of historic buildings. The National Park Service and the Internal Revenue Service administer the program in partnership with State Historic Preservation Offices. • Continuum of Care (CoC) Program: The Continuum of Care (CoC) Program is designed to promote communitywide commitment towards ending homelessness. It provides funding to nonprofits, State, and local governments to provide shelter and services to Agenda Report Page 158 Attachment 2 Exhibit A

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people experiencing homelessness. CoC also establishes coordinated entry system policies, which are designed to ensure that all people experiencing a housing crisis have fair and equal access and are quickly identified, assessed for, referred, and connected to housing and assistance based on their strengths and needs. • U.S. Department of Agriculture (USDA) Housing Programs: This program provides homeownership opportunities for individuals and below market-rate loans/grants to public and non-profit organizations for new construction, preservation, or rehabilitation of farmworker/rural multi-family rental housing.

III.D Opportunities for Energy Conservation
The cost of energy can greatly impact housing affordability, as energy costs can constitute a significant portion of total housing costs. High energy costs also particularly impact low-income households that are less likely to have the ability to cover increased expenses. This section lists energy conservation programs available at the local, regional, State, and federal levels. Energy conservation programs are consistent with the City of Piedmont'’s Climate Action Plan (CAP 2.0) Pacific Gas & Electric and East Bay Community Energy
Pacific Gas & Electric (PG&E) and East Bay Community Energy (EBCE) provide electricity services for the City of Piedmont. PG&E and EBCE assist low-income customers through several programs. PG&E administers all the following programs, even for customers who receive service from EBCE.
• CARE (California Alternate Rates for Energy) Program: This program reduces monthly energy bills for qualified households by about 30 percent (for electricity; 20 percent for natural gas). Eligibility is based on whether any person living in the home participates in a list of public assistance programs or household income guidelines. • FERA (Family Electric Rate Assistance) Program: Family Electric Rate Assistance is PG&E’s rate reduction program for large households of three or more people with low- to middle-income. Qualifications are based on household income guidelines. FERA generally provides an 18 percent discount on electricity. • Energy Savings Assistance Program: The Energy Savings Assistance Program provides qualified low-income customers with energy-saving improvements at no charge, significantly reducing energy bills. Both renters and owners who live in a house, mobile home, or apartment that is at least 5 years old are eligible. Common improvements may include free weatherization measures and energy-efficient appliances to reduce gas and electricity use.
• Medical Baseline Program: Residential customers can get additional quantities of energy at the lowest (baseline) price. To qualify for Medical Baseline a full-time resident in the home must have a qualifying medical condition and/or require the use of a qualifying Agenda Report Page 159 Attachment 2 Exhibit A

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medical device to treat ongoing medical conditions. Only one Medical Baseline application per household is required.
• Relief for Energy Assistance through Community Help (REACH): This is a one-time energy-assistance program sponsored by PG&E and administered through non-profit organizations like the Salvation Army from 170 offices in Northern and Central California.

Those who have experienced an uncontrollable or unforeseen hardship may receive an energy credit for up to $300. Generally, recipients can receive REACH assistance only once within a 12-month period, but exceptions can be made for seniors, the physically challenged, and the terminally ill.
• Low-Income Home Energy Assistance Program (LIHEAP): LIHEAP is a federally funded program that helps low-income households pay their energy bills. The program offers a variety of services, including HEAP, which provides one-time financial assistance; LIWP, which provides weatherization services; and the Energy Crisis Intervention Program (ECIP), which assists low-income households that are in a crisis situation, such as receiving a disconnection notice. Qualifying customers receive up to $1,000 in assistance.
• Resilient Home: Resilient Home is a program from EBCE that provides quotes and prenegotiated pricing for property owners considering installing a solar and battery backup system for their home. To further lower customer cost, EBCE partner Sunrun will also pay property owners an additional incentive after installation for agreeing to share their stored energy with EBCE when the power grid is operating normally, but demand is high. For homeowners the incentive is $500. For multi-family property owners, the incentive will vary based on system size.
• Arrearage Management Plan (AMP): AMP is a debt assistance program eligible to customers enrolled in the CARE or FERMA financial assistance programs. Customers eligible to participate in the AMP program include those who owe at least $500 on their gas and electric bill, are more than 90 days past due, have made at least one on-time payment, and have been a PG&E or EBCE customer for at least 6 months. The maximum amount eligible for AMP forgiveness is $8,000.

City of Piedmont
The City has a Climate Action Plan (CAP 2.0), which was initially adopted in 2018. The CAP 2.0 was developed by City staff and a Climate Action Plan Task Force of Piedmont residents with expertise in various aspects of climate solutions, who were appointed by the City Council. The CAP 2.0’s building and energy objectives are as follows:
• Reduce residential and commercial building energy use • Increase renewable energy to 100 percent
• Partner with schools to reduce energy use
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• Reduce local air pollution and high global warming potential gases • Investigate infrastructure upgrades and new technologies • Serve as a foundation for future planning efforts such as General Plan updates, climate action plans, Housing Element updates, zoning ordinance updates, among others.

An implementing policy of CAP 2.0 is to monitor effectiveness of policies on greenhouse gas (GHG) emissions. The GHG inventory was last updated in 2021. Piedmont'’s municipal and residential accounts were enrolled into EBCE’s 100% renewable energy plan in November of 2018. The City and its residents being enrolled into a 100% renewable energy plan helps to reduce GHGs emissions the City produces; therefore, making significant steps towards reaching the CAP 2.0 objectives. The City of Piedmont has adopted Reach Codes which require all new detached dwelling units to be electric and requires energy improvements at certain building permit cost and size thresholds. Other conservation programs available on a regional, State, and federal level are described below.

Regional Energy Resources
• Alameda County Season of Sharing -– Critical Family Needs (CFN) Assistance: Onetime, merit-based assistance to applicants who demonstrate a critical need arising from emergency circumstances beyond their control.
• Alameda County Emergency Assistance: The Alameda County Housing Secure Emergency Rental Assistance Program (ACHS-ERAP) helps income-eligible households pay rent and utilities, both for past due and future payments. The federal Consolidated Appropriations Act of 2021 provides funding to support the program. Phase 1 of the program launched March 17, 2021. Phase 1 of the program will prioritize (1) tenant households making less than 30% of the area median income; (2) small rental property owners (5 units or less); and (3) tenants in subsidized affordable housing units. These priorities will be expanded in Phase 2.
• Bay Area Regional Energy Network (BayREN): BayREN provides energy efficiency rebates, no-cost energy consulting to Alameda County residents. Single family homeowners can receive rebates up to $5,000. BayREN also offers a program for multifamily property owners to qualify for $750 cash back per unit to save 15% of their building’s energy use.

State Energy Resources
• California Department of Community Services & Development Programs LowIncome Weatherization Program (LIWP): California’s Low-Income Weatherization Program (LIWP) provides low-income households with solar photovoltaic (PV) systems and energy efficiency upgrades at no cost to residents. LIWP is the only program of its kind in California that focuses exclusively on serving low-income households with solar PV and energy efficiency upgrades at no cost. The program reduces greenhouse gas Agenda Report Page 161 Attachment 2 Exhibit A

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emissions and household energy costs by saving energy and generating clean renewable power. LIWP currently operates three program components: Multi-Family, Community Solar, and Farmworker Housing. According to CDS’s Nov. 2020 Low-Income Weatherization Program Impact Report, LIWP has received $212 million from the Greenhouse Gas Reduction Fund since 2014. Note: The multi-family energy efficiency & renewables program component is estimated to end in June 2022. • California Public Utilities Commission Energy Savings Assistance Program (ESA):

ESA provides no-cost weatherization services to low-income households who meet the CARE income guidelines. Services provided include attic insulation, energy efficient refrigerators, energy efficient furnaces, weatherstripping, caulking, low-flow showerheads, water heater blankets, and door and building envelope repairs which reduce air infiltration. • GoGreen Home Energy Financing: The California State program administers financing loans for central heating and air conditioning, windows and appliances, cool roofs, and many other home improvements.
• Property Assessed Clean Energy (PACE): PACE financing allows property owners to borrow money to pay for renewable energy systems, energy efficient improvements, seismic retrofits, and more by spreading the cost of the upgrade over a period of time.

Payments are made through a special assessment on the property tax bill.

Federal Energy Resources
• Federal Housing Administration Energy Efficient Mortgage Program (EEM): This program helps families save money on their utility bills by enabling them to finance energy efficient improvements with their FHA-insured mortgage. The EEM program recognizes that an energy-efficient home will have lower operating costs, making it more affordable for the homeowners. Cost-effective energy improvements can lower utility bills and make more income available for the mortgage payment.

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Section IV Housing Plan: Goals, Policies, and Programs
IV.A Introduction
The Housing Plan of the Housing Element serves as the City’s strategy for addressing its housing needs. This section describes the housing goals, policies, and programs of the Housing Element for the City of Piedmont.

Goals are aspirational purpose statements that indicate the City’s direction on housing-related needs. Each goal encompasses several policies, which are statements that describe the City’s preferred course of action among a range of other options.

Each goal also includes programs, which provide actionable steps to implement the City’s goals and to further the City’s progress towards meeting its housing allocation. Some programs contain quantified objectives, which refer to the number of units that are expected to be constructed, preserved, or rehabilitated through the program during the planning period. These quantified objectives represent measurable outcomes that can be used to benchmark the success of each program.

This Housing Element contains comprehensive institutional changes intended to significantly increase the amount and type of housing for all income levels in Piedmont. These efforts are expected to be initiated throughout the planning period, which is from January 31, 2023, to January 31, 2031. In accordance with State law, the City will also evaluate the progress and effectiveness of these programs on an annual basis. Together, these initiatives reflect the City’s commitment to increasing affordable housing and improving existing housing conditions.

The City has fair housing goals, policies, and programs for the following topics:

1. New Housing Construction

2. Housing Conservation

3. Affordable Housing Opportunities

4. Elimination of Housing Constraints

5. Special Housing Needs Populations

6. Sustainability and Energy

7. Equal Access to Housing
The following list of goals, policies, and programs includes a combination of strategies, including a continuation of existing successful policies and programs, as well as new policies and programs to tackle emerging opportunities and constraints, address changes in State law, and provide innovative approaches to accommodate the larger RHNA in the 6th Cycle given Piedmont's size and relatively limited options for providing significantly more housing.

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Goal 1: New Housing Construction
Policies
Policy 1.1: Adequate Sites. Maintain an adequate number of sites and opportunities for the development of housing consistent with the Regional Housing Needs Allocation.

Policy 1.2: Housing Diversity. Continue to maintain planning, zoning, and building regulations that accommodate the development of housing for households at all income levels.

Policy 1.3: Promoting Residential Use. Continue to allow residential uses in all of Piedmont’s zoning districts.

Policy 1.4: Context-Appropriate Programs. Participate in those State and federal housing assistance programs that are most appropriate to Piedmont and that recognize the limited affordable housing opportunities in the City.

Policy 1.5: Accessory Dwelling Units. Continue to allow accessory dwelling units and junior accessory dwelling units “by right” in all residential zones within the City, subject to dimensional and size requirements, parking standards, and occupancy requirement for junior accessory dwelling units, as appropriate.

Policy 1.6: Accessory Dwelling Units in New or Expanded Homes. Consider amendments to the zoning ordinance to require the inclusion of accessory dwelling units when new homes are built and when existing homes are expanded.

Policy 1.7: Housing in Commercial Districts. Ensure that local zoning regulations, through density limitations and use allowances, accommodate multi-family residential uses on commercial properties in the City, including the addition of apartments to existing commercial buildings.

Policy 1.8: Mobile and Manufactured Housing. As required by State law, allow mobile and manufactured housing on all residential areas in the City, subject to the same standards as other homes in that Zone.

Policy 1.9: Maintaining Buildable Lots. Outside of Zones C and D, discourage lot mergers, lot line adjustments, and other changes to legally conforming parcels which would reduce the number of buildable lots in the City, except when consolidating lots for multi-family housing production, and encourage lot splits where feasible
Policy 1.10: Lot Mergers. Create incentives to merge lots for new multi-family and mixed-use housing in Zone D and multi-family in Zone C.

Policy 1.11: Intergovernmental Coordination. Coordinate local housing efforts with the California Department of Housing and Community Development, the County of Alameda, and adjacent cities. Where City-sponsored housing programs are infeasible due to limited local resources, explore the feasibility of participating in programs initiated by other jurisdictions.

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Policy 1.12: Multi-family Housing City Service Fee: Require developers of multi-family housing, including mixed-use multi-family housing, to contribute to meeting the costs of City services and infrastructure.

Policy 1.13: Remediation Grants. Pursue grants to support remediation and the study feasibility of redevelopment of non-vacant sites, including brownfields, gas stations, and other sites with reuse opportunities.

Programs

1.A Vacant Land Inventory
A vacant land inventory has been prepared as part of this Housing Element update (see Table B-9101). This inventory should be updated regularly, with an indication of the ownership, sites available for sale, and status of any pending construction projects.

Information about potential new parcels should be added if lot standards or subdivision regulations change or if lot mergers or splits occur.
• Objective: Prepare a regular update of the City’s vacant land inventory, indicating the status and availability of each site in Table B-10 11 for potential development.
• Timeframe: Annually.
• Responsible Agency: Planning & Building Department.

1.B Market-Rate Accessory Dwelling Units
This Housing Element includes program recommendations for two types of accessory dwelling units. The first recommendation, listed here, relates to market-rate accessory dwelling units. These units have no limit on the rent that may be charged and no restrictions on the income of the occupants. The second set of recommendations, listed under Goal 3, addresses rent-restricted accessory dwelling units, which are subject to deed restrictions that limit the rent that may be charged and the income of the occupants (see Program 3.F).

The City of Piedmont allows market-rate accessory dwelling units by right in all residential zones (including Zone D), provided they meet certain criteria. Such units are permitted through ministerial review, meaning they require no discretionary review by the Planning Commission or neighbors. Piedmont City Code Section 17.38.060 sets forth the development standards that relate to accessory dwelling units. Prior to 2005, a conditional use permit (CUP) was required for “secondary dwelling units.” The removal of this requirement, combined with the relaxation of standards consistent with State law, has increased the volume of applications and created important new housing opportunities in Piedmont.

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• Objective: Maintain and update zoning regulations and procedures that support the development of market-rate accessory dwelling units in Piedmont neighborhoods.
• Timeframe: Ongoing (maintain and update existing regulations). • Responsible Agency: Planning & Building Department with direction of City Council.

1.C Public Engagement for Accessory Dwelling Units
The City of Piedmont will expand publicity and public engagement for the ADU programs to reach underserved and racially and ethnically diverse members of the Piedmont community, including residents and employees (also see Program 3.A, Affordable Accessory Dwelling Unit Information Campaign). The City will identify groups and community organizations that have contact with and/or are representative of said groups (e.g., social/religious organizations, non-profit groups) and work with these groups to develop outreach materials to explain the City’s ADU program and opportunities with the intent to reach underserved and racially and ethnically diverse groups. • Objective: Increase awareness of the ADU program amongst underserved and racially and ethnically diverse members of the Piedmont community. o Timeframe:
o Establish goals and metrics for ADU program and identify underserved and racially and ethnically diverse groups and potential contacts and liaisons by the end of 2022.
o Coordinate with liaisons and groups to develop appropriate outreach and informational materials by mid July 2023.
o Distribute media and materials by the end ofDecember 2023. o Annually monitoring program success starting in January 2024. • Responsible Agency: Planning & Building Department.

1.D Allow Religious Institution Affiliated Housing
Development in Zone A
In 2020, the California legislature passed Assembly Bill (AB) 1851, and AB 2244 in 2022, which encourages the use
of religious facility sites (including parking lots) for housing developments and prohibits jurisdictions from
requiring replacement parking when used for qualified
development. State law defines “religious institution
affiliated housing” as housing that is on religious
institution property and is eligible for a State density bonus, meaning it has elements of affordability.

Consistent with AB 1851 and AB 2244, the City will
St. Paul’s Commons in Walnut
Creek, CA is an affordable housing
development sponsored by the
neighboring church. It houses 44
units and has a density of 69 du/ac.

Source:
https://www.housingfinance.com/
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amend the Zoning Ordinance to allow religious institution affiliated housing development projects by right in Zone A as accessory to a permitted religious institution use, allow these uses at densities up to 21 units per acre, and update the parking requirements consistent with State law (also see Program 4.V regarding allowing emergency shelters as accessory uses to religious facilities in Zone A).
• Objective: To facilitate affordable multi-family
housing development in all parts of the city by
allowing religious institution affiliated house by right in Zone A, accessory to religious facilities.
• Timeframe: Zoning amendmentAmend Zoning
Ordinance completed within 1 year of Housing
Element adoptionby March 2024.
• Responsible Agency: Planning & Building
Department with direction of City Council and
Planning Commission.

1.E Require ADUs for New Single-Family Residence Construction In order to increase the production of ADUs, the City will amend the Zoning Ordinance to require the construction of an ADU or JADU with the construction of a new residence, whether on vacant property or on any property that is proposed to be redeveloped, when the property meets certain size thresholds to be established in the implementing ordinance. As part of the Program, the City will study and develop an alternative which will allow an in-lieu fee to fund City affordable housing programs, including Programs 3.E and

3.F.
• Objective: To promote housing development, distribute housing growth across the community, and increase the production of housing through ADUs in single family areas.
• Timeframe: Zoning amendment completed within 3 years of the Housing Element rezoning deadlinewithin 3 years of Housing Element adoption, by January 2026.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

1.F Increase Allowances for Housing in Zone B
In order for the City to adequate capacity to meet its RHNA obligation throughout the planning period, it will consider expandingexpand residential development in publicly owned lands as necessary. To ensure these properties are viable for multi-family Jordan Court at 1601 Oxford
Street, Berkeley, CA, is
affordable housing,
sponsored by the
neighboring church. It
houses 35 units with a
density of 100 du/ac.

Source: Satellite Affordable
Housing Associates
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residential development, the City wants to accommodate at a minimum 20 units per site and will amend the Zoning Ordinance to increase the allowed density in the Public Facilities Zone (Zone B) to 60 dwelling units per acre maximum.

The City has set a target of producing a minimum of 60 132 units on properties in Zone B See Program 1.L, Specific Plan).
• Objective: To facilitate multi-family housing development in Zone B, • Timeframe: Zoning amendment completed within 3 years of the Housing Element rezoning deadlinewithin 3 years of Housing Element adoption, by January 2026.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

1.G Facilitating Multi-family Development in Zone C
The City of Piedmont continues to explore ways to encourage or incentivize multi-family development in Zone C. The City already provides rapid processing of development applications and has modified the development standards (i.e., reducing parking requirements for units less than 700 square feet and allowing greater hardscape coverage) to facilitate affordable housing development.

To help further reduce constraints, the City will consider amending the Zoning Ordinance to increase the maximum allowed residential density in Zone C to 60 dwelling units per acre, will consider increaseing the three-story maximum height limitation to 4 stories, and will consider allowing parking reductions for certain multi-family and affordable projects (see Program 4.L below). Reductions to front yard setbacks and increases in lot coverage allowances will also be consideredimplemented.

Provisions for fee reductions for multi-family projects that incorporate affordable units should continue to be explicitly provided in the Zoning regulations. As noted in Program

4.M, the City intends to replace the Residential Design Guidelines with objective design standards for multi-family and residential mixed-use development. Consistent with State law, housing projects in the City are eligible for a density bonus for projects with a percentage of affordable units.

This program is not necessary for meeting the City’s RHNA, but illustrates the City’s goodfaith efforts to produce additional housing. The City has set a target of producing 15 units on properties in Zone C.
• Objective: Continue to develop and implement possible incentives and reduce constraints to facilitate multi-family development in Zone C. • Timeframe: Consider and Ccomplete Zoning Amendments within 3 years of the Housing Element rezoning deadlinewithin 3 years of Housing Element adoption, by January 2026.

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• Responsible Agency: Planning & Building
Department with direction of the City Council
and the City Planning Commission.

1.H Increase Allowances for Housing in Zone D
The Piedmont Zoning Ordinance was amended in
December 2013 (effective 1/1/14) and updated in 2017
to allow multi-family housing in the Commercial Zone
(Zone D) when incorporated as a component of a mixeduse project at densities up to 21 units per acre. This 2017 amendment created an opportunity for residential
additions above stores or offices. For residential uses in Zone D, the City requires one parking space for a studio or one-bedroom dwelling unit, one and a half spaces per each two-bedroom dwelling unit, and two spaces for each dwelling unit with three bedrooms or more (accessory dwelling units do not require parking in Piedmont). The City considers requests for parking variances on a case-by-case basis, depending on the physical conditions of each site, heath, and public safety in the surrounding neighborhood, and whether the required parking would cause an unreasonable hardship in planning, design, or construction of the parking space. As required by State law, density bonuses would be allowed for projects incorporating affordable units.

Since the Ordinance was amended, the City has not seen redevelopment of any commercial properties in Zone D. To help facilitate future mixed-use redevelopment to achieve the City’s RHNA, the City will amend the Zoning Ordinance to allow residential densities up to 81 units per acre in Zone D, remove the Conditional Use Permit requirements for multi-family development in Zone D, and relax parking, setback, and lot coverage requirements in Zone D. The City will also consider waiveing ground floor commercial in Zone D for nonprofit affordable housing as an incentive for residential development. In addition, the City will increase allowable height to four stories and reduce parking requirements to minimum one space per unit to facilitate residential development up to 81 units per acre in Zone D. The feasibility analyses and massing study conducted for the hHousing eElement (see Section B.2.3 of Appendix B) found that 83 units per acre could be achieved in four stories of residential use over a podium level with commercial uses. Due to the high cost of podium-type construction and the program’s emphasis on 100 percent residential development with an affordable housing component, four-stories is a feasible development scenario within the 8-year planning cycle.

The City has set a target of producing 191 multi-family or mixed use units in Zone D by the close of the planning period (January 31, 2031).

Il Piemonte in Oakland, CA, is a
mixed-use development with all
26 units being market rate. This
four-story development has a
density of 89 du/ac.

Source: http://www.kpaarch.com
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• Objective: To facilitate redevelopment of commercial and residential sites in Zone D for mixed use and multi-family development, including new mixed-use projects on underutilized commercial and residential sites and the addition of residential units to existing commercial and residential structures • Timeframe: Zoning amendment completed within 3 years of the Housing Element rezoning deadline3 years of Housing Element adoption, by January 2026. Ongoing coordination with property owners.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

1.I Lot Mergers to Facilitate Housing in Zone C and Zone D The City is limited in the availability of sites suitable for higher density housing development, with few areas zoned for multi-family development. Of those sites, many are small (less than 0.5 acres). In order to help create viable housing sites and facilitate new multi-family and mixed-use housing in Zone C and Zone D, the City will amend the City Code to incentivize lot mergers and create lot merger standards. • Objective: To facilitate new multi-family and mixed-use housing in Zone C and Zone D.
• Timeframe: Zoning amendment completed within 3 years of the Housing Element rezoning deadline, by January 2026within 3 years of Housing Element adoption. Ongoing coordination with property owners.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.
•

1.J SB 9 Facilitation Amendments
Senate Bill (SB) 9, adopted in 2021, requires proposed housing developments containing no more than two residential units within a single-family residential zone to be considered ministerially, without discretionary review or hearing, if the proposed housing development meets certain criteria. SB 9 also requires local agencies to ministerially approve a parcel map for an urban lot split subject to certain criteria. The goals of the City’s program to implement SB 9 are up to four housing units in single-family zoning districts like Piedmont’s Zone A and Zone E.

To help create additional housing sites and additional housing, the City will adopt objective design standards for single-family zones (Zone A and Zone E) to help streamline review and approval of projects on properties that are eligible for lot splits and/or additional units under SB 9. In addition, the City will amend the Zoning Ordinance to encourage large lots to take advantage of opportunities under SB 9. Lastly, the City will develop factsheets and FAQs to explain SB 9 to eligible property owners.

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The City has set a target of producing 40 units as part of this program. • Objectives:
o Facilitate the implementation of SB 9 in Piedmont by adopting objective design standards for SB 9 units/lot splits.
o Encourage large lot splits per SB 9.
o Explain the SB 9 process and criteria to property owners to promote housing construction.
• Timeframe:
o Adopt objective design standards for SB 9 properties by mid JulyDecember 2023.
o Amend the Zoning Ordinance to encourage large lots splits under SB 9 by early April 2024.
o Develop SB 9 factsheets and FAQs by mid July 2024.
• Responsible Agency: Planning & Building Department.

1.K City Services Impact Fee for Multi-family Housing
The City has high standards for provision of services to community residents. In order to maintain the existing level of services, City will study the nexus between the impacts of new multi-family development on City services and infrastructure and the costs to provide the services and infrastructure. If warranted, such study would provide the basis for the City’s impact fees for developers of multi-family housing including mixed-use multi-family housing. Fees received will help fund continuation of service to offset potential impacts of the increased population envisioned in the Housing Element. • Objective: To ensure new projects help pay for the cost of maintaining City services and infrastructure.
• Timeframe: Review impact fees by end ofDecember 2024. Modify fees, as directed through study, by midJuly -2025
• Responsible Agency: Planning & Building Department with Public Works and Finance Departments with direction of City Council and Planning Commission.

1.L Specific Plan
As described in Appendix B, Section B.3.1, the City owns four sites (comprised of APN 050457901900, 050457908000, 048A700200303, and 050457906100) totaling about

18.25 acres on both the north and south sides of Moraga Avenue near Red Rock Road.

The City of Piedmont has the ability to subdivide the parcels and declare them to be surplus under the Surplus Land Act (SLA- California Government Code §54222 et seq.).

The intent of this process would be to facilitate the development of below-market-rate housing to help meet the demand for affordable housing in the City. In order for the City to meet its RHNA requirements, these sites need to accommodate at least 132 housing units at all income levels. Given the size of the site, existing constraints, and the desire to preserve the existing public uses (open space, recreation, and City Corporation Yard), the Agenda Report Page 171 Attachment 2 Exhibit A

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area will be planned using the specific plan process outlined in Government Code §65450 et seq. This process requires the orderly development of the area, including the following:
phasing; subdivision; adequate infrastructure; identification of financing; protection of amenities and City facilities; and production of affordable housing. The goals of the specific plan are as follows.

The first goal is to enable construction of housing at a minimum of 132 units, on portions of the site, totaling approximately 3.5 acres of land, yielding a minimum of 60 units of housing affordable to households earning less than 80 percent of the area median income (AMI) and a minimum of 72 units affordable to households earning more than 80 percent of the AMI.

In addition, specific plan goals include improved safety. New habitable structures shall be built to meet fire code requirements for Wildland Urban Interface Areas.

The specific plan must include replacement and/or modernization of existing Public Works Department facilities, offices, storage areas, vehicle storage areas, etc., so that service capacity is maintained or increased, and so that the facilities meet current building and fire code requirements.

The specific plan must include recreation facilities, including but not limited to an under14 soccer field, youth baseball/softball field, batting cages, artificial field turf, ballfield seating, a skate spot, a picnic area, and parking for these facilities.

The specific plan must provide all public utilities to new housing and all City facilities to be constructed within the specific plan area in a manner consistent with public safety standards and Piedmont Climate Action Plan goals and programs.

The specific plan must include improvements to pedestrian and vehicular circulation, as determined necessary by the City Engineer, to provide safe pedestrian, bicycle, and motor vehicle movements, ensure safe evacuation routes, and provide optimal emergency response.

The goals of the specific plan include a comprehensive landscape plan for areas planned for development. The landscape plan shall prioritize to the extent practicable: fire safety and the preservation of significant open space, scenic views, and native and heritage trees.

Density in the plan area will be determined at the time of plan development, and could range from 40 to 60 dwelling units per acre, including housing for seniors, disabled persons, single-parents, low-income families, and/or people requiring supportive services.

This program requires an amendment to the City’s General Plan and the preparation of a specific plan to accommodate the density and create development standards for the unique site conditions. The required amendments would be reviewed by the City Attorney Agenda Report Page 172 Attachment 2 Exhibit A

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for conformance with the City Charter and other legal requirements. If it is determined that it is infeasible to develop this site during the planning process, the City will consider utilizing other City-owned properties as alternative sites (See Appendix B).

The City will apply for grants and other funding sources to help fund the planning and development of affordable housing in this area. The City could also leverage local, State, and federal affordable housing funding sources.

The City issued a request for proposals (RFP) seeing professional services for the preparation of a Moraga Canyon Specific Plan on January 23, 2023. Proposals were received on March 13, 2023 and contract execution and project kick-off are expected to occur by the end of May 2023. There are no known impediments to the development of housing within the study area. The scope of services detailed in the RFP include but are not limited to the following:
• Detailed guidance on phasing and subdivision that accommodates the 60 units of lower-income housing and 72 units of above moderate-income housing identified for the study area in Housing Element program 1.L and the Sites Inventory (Housing Element Appendix B), and that prioritizes and expedites the identification of a site for the development of affordable housing that meets the criteria and timelines to secure Alameda County Measure A-1 funding. (The due date for the City to gain County approval of a project using Measure A-1 funding is December 31, 2024.);
• The preparation of a surplus land declaration;
• A program of implementation measures including regulations, programs, infrastructure projects, and financing measures necessary to implement the sSpecific pPlan; and
• An evaluation of the economic feasibility of the Specific Plan.

Necessary entitlements and the issuance of building permits will occur during the planning period and will be specified through the sSpecific pPlan process. As noted in Appendix F, any new housing in Piedmont represents increased access to opportunity and housing mobility, as the City is considered to be “highest resource” throughout. The Specific Plan will promote housing choice and affordability, given that it includes measures to provide housing for below-market rate households, which will help overcome existing patterns of income segregation within the Bay Area and East Bay region.

The City will issue a Request for Proposals (RFP) to planning firms, and market-rate and affordable housing developers, asking them for proposals for the specific plan area. The City will also determine appropriate partnership opportunities in order to ensure successful implementation of this program and adequate funding for the development of affordable housing. Proposals would be reviewed and approved by the City Council.

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• Objective: Develop a specific plan to accommodate at least 132 dwelling units at a density of 40 to 60 dwelling units per acre affordable to a variety of households, including seniors, disabled persons, single-parents, low-income families, and people requiring supportive services.
• Timeframe:
o Issue RFP by end of 2022/early 2023Receive responses to RFP seeking professional services for the preparation of the specific plan by March 13, 2023Award contract for professional services for the preparation of the specific plan and kick off project by May 2023. seeking professional services for the preparation of the specific plan. o Apply for available grant funding by mid-2024.
o Begin subdivision of site and Surplus Land declaration no later than early 2024.
o Prepare specific plan with the goal of completion by the end of 2025. o Adopt specific plan, General Plan amendments (See Program 1.P), and associated development standards by the end of 2026.
o Pursue goal of entering into exclusive negotiating agreement with development partners by the end of 2026.
• Responsible Agency: Planning & Building Department, with direction of City Council and Planning Commission.

1.M Manufactured and Mobile Homes
Though the City does not contain existing mobile home parks, mobile and manufactured homes can be an important source of housing choice and affordability. As manufactured homes that meet certain requirements must be permitted in mobile home parks and are frequently regulated by jurisdictions together, they are discussed here jointly.

Government Code §65852.3 requires cities to allow and permit manufactured and mobile homes on a permanent foundation in the same manner and in the same zone as a conventional stick-built structure, subject to the same development standards that a conventional single-family home on the same lot would be subject to. The sole reference to manufactured homes in the Zoning Ordinance is located in Chapter 17.38 (Accessory Dwelling Units), where manufactured homes are identified as being included in the definition of an ADU. During the 5th cycle, two manufactured ADUs on permanent foundations were built in Piedmont.

The 5th Cycle Housing Element Update carried forward a 4th Cycle recommendation, Policy 1.8 (Mobile and Manufactured Housing), to allow mobile and manufactured housing on all lots in the City subject to design standards which ensure that such housing is compatible in character with the community. To ensure compliance with State law and Agenda Report Page 174 Attachment 2 Exhibit A

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allowance of manufactured homes in single family zones as a primary structure, the Housing Element includes this program.
• Objective: Amend the Zoning Ordinance to allow manufactured homes consistent with State law.
• Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of City Council and Planning Commission.

1.N Municipal Services Parcel Tax Study
The City will study the local municipal services parcel tax to determine if the tax could be structured to collect an annual tax from each new unit created under Housing Element programs, including ADUs over 750 square feet (as allowed by State law). Potential revenue enhancements will be measured against the possibility of creating new constraints to housing production.
• Objective: Study local municipal services tax to potentially generate additional revenue from units created under Housing Element programs. • Timeframe: Conduct study by early April 2026.
• Responsible Agency: Planning & Building Department and Finance Department with direction of City Council and Planning Commission.

1.O Gas Station Remediation Study
The City will pursue a brownfields grant to study the remediation of gas stations in Zone D in Piedmont. If a study shows potential for successful remediation, gas station sites could be converted to residential opportunity sites consistent with Zone D regulations, as discussed in section 1.H. This program is not necessary for meeting the City’s RHNA, but illustrates the City’s good-faith efforts to produce additional housing. • Objective: Obtain grant to study gas station remediation to convert underutilized gas station sites to residential parcels. • Timeframe: Pursue funding and (if funding received) begin study within two years of adoption of final Housing Elementby March 2025. • Responsible Agency: Planning and Building Department with direction of City Council and Planning Commission.

1.P General Plan Amendments
To ensure consistency between the City’s General Plan and the Zoning Ordinance, the City will consider amendments to the General Plan to allow the uses and densities as proposed under the Housing Element in Programs 1.D, 1.F, 1.G, 1.H, and 1.L.

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• Objective: Maintain consistency in City regulatory and policy documents. • Timeframe: Concurrent with adoption of final Housing ElementAmend General Plan consistent with programs describe in Program 1.P above, by January 2026.
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission.

1.Q Density Bonus Ordinance
Consider development ofIssue a request for proposals for a consultant or consulting firm to develop a local density bonus that is inclusive of State of California density bonus incentives and considers creates incentives for local goals for affordable housing above the minimum requirements of State density bonus law.
• Objective: Encourage utilization of the density bonus to promote market-rate and affordable housing construction.
• Timeframe: RFP and Zoning amendment completed within 3 years of the Housing Element rezoning deadlinewithin 3 years of Housing Element adoption, by January 2026.
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission.

1.R Lower-Income Sites Modifications to Address Shortfall Because the standards are not in place to accommodate the RHNA obligation at the time of Housing Element adoption, the City has a shortfall of sites. Consistent with California Government Code Section 65583.2(h) and (i), sites identified in the sites inventory for lower income units will also be modified to:

1. Allow owner-occupied and rental multi-family use by-right for developments in which 20 percent or more of the units are affordable to lower-income households;

2. Accommodate a minimum of 16 units per site;

3. Establish a minimum density of 20 units per acre; and

4. Require residential use occupancy of at least 50 percent of the total floor area of any mixed-use project on these sites.

Lower income sites will also have zoning standard limitations relaxed according to the densities, development standards, and uses allowed by the various zoning standard relaxation programs, identified above under Goal 1 to facilitate achievement of the density targets.
• Objective: Accommodate the lower income shortfall as required by Government Code Section 55583.2(h) and (i).

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• Timeframe: Amend the Zoning Ordinance as described above by Aprilearly 2024.
• Responsible Agency: Planning and Building Department, with direction of City Council and Planning Commission.

1.S ADU Compliance
The City will revise its ADU ordinance for compliance with State law to address any issues that the California Department of Housing and Community Development (HCD) raises upon review of the City’s ordinance. The City anticipates that HCD will be providing comments to the City on its current ordinance.
• Objective: Encourage the creation of accessory dwelling units by adopting an ordinance that is compliant with State law.
• Timeframe: Zoning amendment completed within 6 months of receipt of the letter from HCD
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission.

Goal 2: Housing Conservation
Policies
Policy 2.1: Encouraging Private Reinvestment. Strongly encourage private property owner reinvestment in the City’s housing stock.

Policy 2.2: Public Funds for Housing Maintenance. Support housing stock maintenance and repair through government funding such as Community Development Block Grants when private funding is not available.

Policy 2.3: Availability of Small, More Affordable Homes. Encourage the creation of small homes within Piedmont’s existing stock of homes and historic houses. Promote the affordability of smaller-sized homes.

Policy 2.4: Code Enforcement. Enforce local building codes to ensure that housing is safe and sanitary and to protect the character of Piedmont neighborhoods. Promptly investigate all reports of nuisances and require the abatement of such situations, as needed.

Policy 2.5: Use of Original Materials. Allow the use of original materials and methods of construction when alterations to homes are proposed unless a health or safety hazard would occur.

Policy 2.6: Preservation of Multi-Family Housing. Preserve existing multi-family rental housing, including non-conforming multi-family units in the single-family zone. Require the review of permits that would demolish a housing unit, including non-conforming units in the single-family zone.

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Policy 2.7: Home Occupations. Continue to encourage Piedmont residents to maintain home offices as a means of making housing more affordable for persons who would otherwise need to rent office space outside the home.

Policy 2.8: Conservation of Rental Housing Opportunities. Conserve rental housing opportunities by monitoring and limiting the use of existing or potential rental properties, such as apartments, accessory dwelling units, and rooms in shared homes, for short-term stays.

Programs

2.A CDBG Funding
The Alameda Urban County CDBG program provides funds to assist lower income households with home repair and maintenance projects. A limited amount of funds are provided to local cities, with disbursal to qualifying lower income households. The City of Piedmont has participated in this program in the past and will continue to participate in the future.

During the 2014 Housing Element update, it was observed that many Piedmont households are unaware of this program. If the City is successful in obtaining funds, a public information campaign should be initiated to solicit applications for grants/loans by Piedmont households, with an emphasis on extremely low-income households. This should include feature stories in the local news media as well as announcements on the City’s website.

If sufficient funds are obtained to produce new affordable housing units, the City will work with non-profit developers to explore complementary measures to facilitate housing production, such as reduced permitting and environmental review costs. While there are no known properties in need of rehabilitation, the City has set a target of assisting 8 lowincome households with home rehabilitation by the close of the planning period (January 31, 2031).
• Objective: Apply for Community Development Block Grant (CDBG) funds for housing maintenance and production and establish a process for informing the public that such funds are available. If such funds are received, a priority should be placed on their use to assist households with incomes less than 30 percent of area median income.
• Timeframe: Apply for Community Development Block Grant (CDBG) funds for housing maintenance and production on an annual basis; Ongoing public awareness campaign, if funds are received.
• Responsible Agency: Planning & Building Department/Finance Director.

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2.B Availability of Small Homes
Small homes, due to a reduced square footage, may be more affordable than larger homes. Small homes serve a role in the City of Piedmont to promote housing opportunities for a variety of households including seniors, small families, and single person households.

In conjunction with SB 9 (see Program 1.J), the City seeks to accommodate small homes on small lots. The City’s existing supply of small homes is currently protected by:
• Floor area ratio and lot coverage requirements which limit the square footage and coverage of structures relative to lot size.
• Requirements to provide conforming off-street parking in the event that bedrooms are added (creating a disincentive to the expansion of two- and three-bedroom homes with one-car garages and limited driveway space). • Design Review Guidelines which strive to maintain the scale and mass of existing homes (See also Program 4.M).

All of these provisions should be retained, with the design guidelines for new homes replaced with objective standards (see Program 4.M). In addition, the City is proposing Program 4.J to study feasibility of development on smaller lots, which would accommodate smaller homes, and Program 4.K to study feasibility of affordable small lot projects. • Objective: Maintain zoning regulations that allow for small (less than 1,800 square feet) homes.
• Timeframe: Ongoing (see specific timeframes for other programs identified in Program 2.B).
• Responsible Agency: Planning & Building Department with direction of City Council and Planning Commission.

2.C Use of Original Materials and Construction Methods
The City’s design standards, plan checking, and building inspection processes currently allow the use of original materials and methods of construction when remodeling projects are proposed. These provisions can mean significant cost-savings for property owners, who might otherwise need to use more expensive materials. They also help support the City’s Climate Action Plan objectives, including increased use of recycled building materials and fixtures. The City applies the State Historic Building Code to structures that qualify as “historic,” including those properties listed in inventories of historic resources but not formally designated as historic. This Code allows the relaxation of certain UBC standards (such as staircase width) in order to preserve historic buildings. • Objective: Maintain Planning and Building standards which allow the use of original materials and construction methods in home remodeling. • Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department.

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2.D Condominium Conversions
The City’s Subdivision Ordinance includes a “no net loss” provision for apartment conversions. Section 19.63(C) of the code states that any apartments converted to condominiums must be replaced in kind by an equivalent number of equivalently priced rental units. If the units currently rent for very low-, low-, or moderate-income rents, the replacement units must remain rent restricted for at least 55 years. This requirement reduces the likelihood of condo conversions in the City and protects the multi-family rental housing supply.
• Objective: Maintain the existing requirement that the removal of any multifamily rental apartment must be matched by the creation of a new rental apartment elsewhere in the City.
• Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department.

Goal 3: Affordable Housing Opportunities
Policies
Policy 3.1: Rent-Restricted Accessory Dwelling Units. Encourage the creation of rent restricted accessory dwelling units for low and very low-income households through incentive-based programs such as increased height limits, additional number of ADUs, pre-approved plans, and more lenient lot coverage and floor area standards.

Policy 3.2: Occupancy of Permitted Accessory Dwelling Units. Encourage property owners with permitted accessory dwelling units to actively use these units as rental housing rather than leaving them vacant or using them for other purposes.

Policy 3.3: Legalization of ADUs. Allow for and offer incentives for owners of unintended and/or illegal accessory dwelling units to apply for permits to convert them into permitted unit(s).

Policy 3.4: Accessory Dwelling Unit Building Regulations. Maintain building code regulations which ensure the health and safety of accessory dwelling unit occupants and the occupants of the adjacent primary residence. Implement Building Code regulations intended to facilitate “tiny home” construction.

Policy 3.5: Density Bonuses. Consistent with State law, allow density bonuses (such as allowances for additional square footage or lot coverage) for housing projects which incorporate affordable or special needs housing units.

Policy 3.7: Room Rentals. Continue to allow the renting of rooms in private homes to provide housing opportunities for single people. Recognize the potential for rented rooms to meet the housing needs of single low-income, very low-income, and extremely low-income Piedmont residents.

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Policy 3.8: Inclusionary Housing. Encourage the provision of affordable housing as part of market rate multi-family housing projects.

Programs

3.A Affordable Accessory Dwelling Unit Public Information Campaign This program would use a variety of media to inform the community about Piedmont’s accessory dwelling unit program (Program 1.C, above, specifically targets underserved groups, as well). This includes maintaining and updating the dedicated page on the City’s website informing residents of what accessory dwelling units are and why they are an essential part of the City’s housing stock. The website describes the different types of accessory dwelling units in the City, the regulations that govern them, and the application process. Additionally, the City would continue to use FAQs, brochures, and other print media to explain the steps for applying for an accessory dwelling unit, with special attention given to the homeowner benefits of applying for a rent-restricted unit. The City’s local access cable station (KCOM) should also be used to convey this information.

Further positive news coverage about accessory dwelling units could be generated through press releases and articles in local news outlets. This should include human interest stories about accessory dwelling unit owners and tenants in the City. Accessory dwelling unit occupants should be contacted by the City and invited to tell their stories to local reporters in a way that illustrates the “real world” benefits of having accessory dwelling units in the community. In addition, the City should establish a category in its annual design awards for outstanding accessory dwelling units. • Objective: Initiate a public information and education campaign about accessory dwelling units, including definitions, regulations for their use, opportunities for their construction, and the various incentives offered by the City to create rent-restricted units. The campaign should add a “human interest” dimension by focusing on the stories of actual accessory dwelling unit owners and tenants in Piedmont.
• Timeframe: Complete campaign strategy and materials by 2024, ongoing advertising of materials in print and digital media.
• Responsible Agency: Planning & Building Department.

3.B Increase Number of Legal Accessory Dwelling Units
Work with owners of illegal and/or “unintended” accessory dwelling units to bring the unit into compliance with City standards, including single-family homes that have been reported by Alameda County as having two, on-site units despite City records indicating a single-family home. These are spaces that have the potential for conversion to accessory dwelling units based on their physical characteristics. Examples include pool houses with indoor cooking facilities; basements with kitchens, bathrooms, and separate entrances; Agenda Report Page 181 Attachment 2 Exhibit A

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and finished rooms over garages. City will monitor for indications that these spaces are being used for unauthorized short-term rentals (STR).

The City will contact owners of potential unintended ADUs with a letter informing them of the opportunity to apply for a legal market rate or rent-restricted accessory dwelling unit.

The City has set a target of converting at least 17 unintended accessory dwelling units into permitted accessory dwelling units during the planning period. These units are included in the totals shown in Table IV-1, as units preserved or conserved, and could include both market rate and rent-restricted units.

Efforts should also be made to contact the owners of suspected illegal accessory dwelling units, with a focus on legalizing these units as new rent-restricted units. The address data base of “suspected” accessory dwelling units is an important resource. The potentially illegal status of such units provides incentives to convert them into rent-restricted units.

The City will work with the owners of such units in order to convert them into legal apartments, on the condition that they be rent-restricted to a low or very low-income household.
• Objective: Increase the ADU stock with legal, complying units by offering incentives and waivers for unintended and/or existing non-permitted ADUs. • Timeframe: Initial contact of known unpermitted ADUs by December 2024, ongoing coordination.
• Responsible Agency: Planning & Building Department.

3.C Monitoring Accessory Dwelling Unit Missed Opportunities As noted in Program 3.B the City intends to pursue additional housing opportunities in “unintended” and/or and illegal accessory dwelling units.

In addition, the City should will also seek input from applicants who considered adding an accessory dwelling unit, but ultimately decided not to, and applicants who received approval for a unit but then decided not to build or rent it. Their perspectives would be informative and could lead to changes in the program which would encourage more households to participate.
• Objective: Increase the ADU stock and improve ADU policies and regulations through a better understanding of property owners that considered adding an ADU, but decided not to move forward.
• Timeframe: Ongoing
• Responsible Agency: Planning & Building Department, City Clerk, Building Official
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3.D Monitoring Additional Accessory Dwelling Unit Development Opportunities While Program 3.C addresses improving ADU policies and regulations based on applicant feedback, Program 3.D focuses on lots which are conducive to accessory dwelling unit creation due to their large size, location, or ability to accommodate additions or new structures (such as down-sloping lots with built out lower levels). This includes vacant lots, lots in the Estate Zone, and large lots in Zone A. As development applications for new homes or major home additions are received on these properties, the City will advise applicants of the opportunity to add an accessory dwelling unit.

The City has set a target of accommodating 10 new accessory dwelling units in new homes or homes that are expanded with major additions during the planning period. These would generally be market-rate (rather than rent-restricted) accessory dwelling units. • Objective: Monitor potential opportunities for accessory dwelling units with new home construction or as part of renovation or expansion of existing homes located on larger lots that are conducive to accessory dwelling unit creation. • Timeframe: Identify all sites which meet threshold by 2024. Contact property owners by 2025. Ongoing advertisement of ADU opportunities as applications are submitted.
• Responsible Agency: Planning & Building Department.

3.E Affordable Housing Fund
The City will create a Piedmont affordable housing fund to receive philanthropic donations, in-lieu fees, and other sources of funding. These funds could be used for affordable housing programs including a loan program for ADUs with Habitat for Humanity or other programs for other affordable housing types.

The affordable housing fund could be administered by a nonprofit affordable housing developer, such as Habitat for Humanity or other entity, to make low-interest loans (e.g., 4% interest rate) available to low or moderate-income property owners (e.g., up to approximately $135,650 for a household of three people), with a focus on members of protected classes.

Loans could be made available for the construction of new ADUs, Junior ADUs, and/or other small housing units with occupancy restricted to very-low-income (31% to 50% AMI) and extremely-low-income (30% or less of AMI) residents for a minimum period of 15 years.

Mabuhay Court in San Jose,
CA is an affordable senior
housing development by
Bridge Housing. It houses 96
units with a density of 56
dwelling units per acre.

Source:
https://bridgehousing.com/
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The City is targeting supporting approximately 10 new income-restricted ADUs, Junior ADUs, or other housing unit types during the planning period.

The Program could be extended to property owners with above moderate incomes with additional funding sources, such as fund-raising efforts, philanthropic contributions, or grant funding.
• Objective: Investigate Create Affordable Housing Fund for the construction of new ADUs and Junior ADUs and other affordable housing types with occupancy restricted to very-low-income (31% to 50% AMI) and extremely-low-income (30% or less of AMI) residents for a minimum period of 15 years. • Timeframe: Meet with City Council in by December 2023 to discuss potential risks and opportunities. Create affordable housing fund by July 2024. • Responsible Agency: Planning & Building Department, with direction of City Council and Planning Commission.

3.F Incentives for Rent-Restricted ADUs
Per State law (Gov. Code, § 65583, sub (c)(7)), the City is currently considering several measures to incentivize the production affordable ADUs, including ADUs that would be deed-restricted for a period of 10 years to lower income households. Consistent with the findings and recommendations from the City's SB2 grant program, and in order to incentivize ADUs, the City will:
• Provide architectural plans for ADUs and JADUs that are “pre-approved” for a planning permit, subject to deed restriction.
• Consider Iincreaseing the allowed height of ADUs above that permitted under State law. This may include increasing the 1618-foot height limit to 18 or 25 feet and/or measuring height to the average height of the highest roof surface to encourage sloped roof form (e.g. a gable or shed). This would enable twostory ADUs or second-story ADUs over a garage or living space in a primary residence in Piedmont’s hillside setting (also see below). • Allow a larger, 300-square-foot expansion of an existing accessory building. o Currently, conversion of an existing garage or other accessory structure into a JADU is currently limited to the existing square footage plus a maximum 150 square feet expansion to allow entry/exit from the unit.

With small existing structures this may severely limit the feasibility of a JADU.
• Allow three ADUs on a single-family property, under the following conditions:
o One is a standard ADU,
o One is a JADU, and
o One ADU is rent restricted for a period of 10 years and only if one of the following are met:

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▪ An additional ADU greater than 500 square feet by right on properties that have an existing ADU, where the primary residence is at least 45 years old.
▪ The developer of the additional ADU may take a 5% increase in permitted FAR for the purposes of building the additional ADU, meaning 60% for lots less than 5,000 square feet, 55% for lots between 5,000 and 10,000 square feet, and 50% for lots greater than 10,000 square feet.
▪ The developer of the additional ADU may take a 5% increase in permitted structure coverage for the purposes of building the additional ADU, meaning 45% structure coverage in most cases. ▪ The total number of dwelling units on each Zone A or Zone E property would be a maximum of four dwelling units.

Additionally, the City will continue to actively promote accessory dwelling unit construction in the 6th Cycle and expedite the review and approval of new ADUs. To the extent the City budget will allow, this will include keeping accessory dwelling unit application fees at less than one percent of construction costs as a way to encourage accessory dwelling unit production.

The City of Piedmont is targeting 20 new, income-restricted ADUs and/or Junior ADUs (JADUs) during the planning period.
• Objective: Consider amendments to the zoning regulations and procedures that create new incentives for rent and occupant income-restricted ADUs and streamline the review of all ADUs and JADUs.
• Timeframe: Amend ADU ordinance to increase within 3 years of the Housing Element rezoning deadlinewithin 3 years of Housing Element adoptionby January 2026.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

3.G Inclusionary Housing
Inclusionary housing is generally a program that requires provision of affordable housing on-site or off-site, or payment of an affordable housing in-lieu fee, as part of an otherwise market-rate housing development. The City will evaluate the potential to establish inclusionary housing requirements for new multi-family housing development, which would require affordable housing development. The City should also consider alternatives, such as land dedication and/or payment of an in lieu fee, with the fee adequately calibrated to be equivalent to the cost of constructing an affordable unit. • Objective: Provide additional affordable housing opportunities equally distributed and integrated with market-rate developments.

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• Timeframe: Issue RFP to hire consultant to evaluate inclusionary options by end ofDecember 2023. Finalize recommendations by end ofDecember 2024.

Adopt requirements early April 2025, if applicable and recommended by the analysis.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

3.H Monitor ADU Occupancy/Affordability
The City will monitor the occupancy and affordability of ADUs using its list of all permitted ADUs and any known unpermitted ADUs to determine whether they are occupied as an independent dwelling unit, and if so, at what income level is it rented. The City will conduct a survey to gather this information and will inform property owners of ADUs contacted through the survey of local incentives for affordable ADUs, as outlined in Program 3.F.

Moreover, the City will again monitor the affordability of ADUs midway through the planning period, by January 2027, to assess whether ADU assumptions regarding production are being realized, and make necessary changes to meet its ADU goals if they are not being met at that time.
• Objective: Issue survey to property owners of permitted and known unpermitted ADUs to determine occupancy/affordability of existing ADU stock, and based on the results of the survey, adjust city programs accordingly to ensure adequate capacity for the City’s sites inventory. • Timeframe: Issue survey to relevant property owners by April 2024. and again, no later than April 2027.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

Goal 4: Elimination of Housing Constraints
Policies
Policy 4.1: Communicating Planning and Building Information. Encourage public understanding of the planning and building processes in Piedmont to facilitate permit processing and reduce project costs and delays.

Policy 4.2: Planning and Building Standards. Ensure that planning and building standards, development review procedures, and fees do not form a constraint to the development, conservation, and rehabilitation of housing, or add unnecessarily to the cost of building or improving housing.

Policy 4.3: Expeditious Permitting. Promote the expeditious processing and approval of residential projects that are consistent with the General Plan, the Zoning Ordinance, and Agenda Report Page 186 Attachment 2 Exhibit A

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Objective Design Standards and Design Guidelines (for projects that do not add a new housing unit).

Policy 4.4: Updating Standards and Codes. Maintain updated codes and standards for residential development to reflect changes in State and federal law, new technology, and market trends.

Policy 4.5: Code Flexibility. Allow certain development standards to be relaxed to accommodate affordable housing, where there is no threat to the health, safety, and welfare of the City or potential for adverse impacts on the surrounding neighborhood.

Policy 4.6: Housing Coordinator. Designate the Planning & Building Director as the City’s Housing Coordinator.

Policy 4.7: Infrastructure Maintenance. Support the regular maintenance of infrastructure, including water, sewer, drainage, streets, and sidewalks, so that these facilities are available when new housing is proposed.

Policy 4.8: Infrastructure Prioritization for Lower Income Housing. Consistent with Government Code §65589.7, prioritize water and sewer services to lower income housing developments to help meet Piedmont’s share of the regional share of lower-income housing units.

Work with East Bay Municipal Utility District (EBMUD) water service.

Policy 4.9: Housing Finance Programs. Participate in appropriate County programs which address financial constraints for first-time homebuyers, including down payment assistance, silent second mortgages, Mortgage Credit Certificates, and Mortgage Revenue Bonds.

Programs

4.A Media Strategy
Several pamphlets and printed handouts have been prepared to explain Piedmont’s planning and permitting requirements. Over time, the City has improved and updated these materials to make them more readable and incorporate contemporary graphic design conventions. The City’s website also continues to expand and improve. In recent years, especially during the COVID-19 pandemic, the website and email bulletins have become a more important information resource and have overtaken printed pamphlets as the preferred means of obtaining information by most customers. Many application materials are now downloadable from the City’s website. Continued efforts should be made to improve the content and usability of information on the Planning homepage, and to use the web to assist residents and reduce the wait for permits. New tools such as YouTube video tutorials will be considered to inform applicants of permitting procedures and requirements.
• Objective: Prepare and update printed brochures and web-based materials which inform residents about the planning and building processes in Piedmont. • Timeframe:

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o Update all printed brochures with the most recent information as of Housing Element adoption by end of December 2023.
o Upload materials to the website by end ofDecember 2023. o Update materials as new processes, standards, or guidelines are adopted is ongoing.
• Responsible Agency: Planning & Building Department.

4.B Home Improvement Workshops
In the past, the City Planning Commission has held sessions on topics such as window replacement and upper story additions. Additional Planning Commission sessions on Bayfriendly landscaping, solar panel installation, energy conservation, and other home improvements would be helpful and could ultimately make home maintenance and improvement projects more affordable for Piedmont households. Such workshops should be aired on KCOM (local access cable) to reach as broad an audience as possible. The City has set a target of providing at least two workshops during the planning period. • Objective: Conduct City-sponsored meetings, programs, and workshops which inform residents on home improvement and maintenance practices in Piedmont.
• Timeframe: Seminars held in 2023 and 2024.
• Responsible Agency: Planning & Building Department.

4.C Building Code Updates and Ongoing Enforcement
As updates to the California Building Code of Regulations are published, the City should amend Chapter 8 of the City Code (the Building, Construction and Fire Prevention Code).

Amendments reflecting local concerns may also be made, as needed. Particular attention should be given to standards which would encourage creation of accessory dwelling units in the City. There may be instances where exceptions to the Code could be considered (for instance, lower ceiling heights or the design of existing staircases) to make it easier for property owners to convert unintended units/space into rental properties. • Objective: Continue to implement the California Building Code of Regulations, as locally amended. Update or amend the codes as State requirements change, and as conditions in Piedmont warrant.
• Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

4.D Fee Review
Fees should be reviewed annually to ensure that they cover operating costs only. Planning and building fees are not used to subsidize other City departments and services. The City should continue efforts to use a “sliding scale” for planning and building fees based on project value to reduce the cost burden on applicants for minor home improvements. Fees Agenda Report Page 188 Attachment 2 Exhibit A

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should also be structured to provide incentives for rent-restricted accessory dwelling units and other projects which provide opportunities for lower income households. • Objective: Review all planning and building fees annually to be sure that they cover required costs but are not more than is necessary to provide the required City services
• Timeframe: Ongoing.
• Responsible Agency: Finance Director, Planning & Building Director.

4.E Temporary Staff Additions
As a small city, Piedmont is susceptible to fluctuations in the volume of planning and building applications. With only one building inspector, one plan checker, and a small planning staff, processing of all applications at the same speed throughout the year can be a challenge. Vacation schedules, staff absences, and staff turnover add to this challenge. Because the City is committed to customer service in its Planning and Building functions, contract staff may be hired to provide building inspection, plan checking, and planning services during peak periods or prolonged staff absences. This will continue in the future.
• Objective: Add contract staff as needed to ensure prompt processing of all applications.
• Timeframe: Ongoing.
• Responsible Agency: Planning & Building Director.

4.F Capital Improvement Plan (CIP) Updates
The CIP update provides assurance that City-maintained facilities such as streets, sidewalks, and storm drains are kept in excellent condition, thereby avoiding deferred maintenance expenses for Piedmont residents. The City has created a CIP Committee to provide citizen input in this process. At least once a year, the CIP Committee should be briefed on the Piedmont General Plan, including the Housing Element, and the requirement that CIP decisions be consistent with Plan policies and priorities. Funding for the maintenance and replacement of City facilities also occurs through the Facilities Maintenance Fund. The Fund was established per City Council directive in FY 2007-08. It identifies annual maintenance needs for all buildings owned by the City as well as parks and recreational facilities.
• Objective: UAnnually update the Capital Improvements Plan (CIP) and Facilities Maintenance Fund to ensure that municipal systems are kept in good condition and that funding decisions are consistent the General Plan, including the Housing Element.
• Timeframe: Ongoing.Update the Capital Improvements Plan (CIP) and Facilities Maintenance Fund each fiscal year. Brief the CIP Committee on the Agenda Report Page 189 Attachment 2 Exhibit A

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General Plan, including the Housing Element and the requirement that CIP decisions be consistent with General Plan policies and priorities each fiscal year.
• Responsible Agency: Public Works Director.

4.G Monitoring the Effects of the City Charter
In the 5th Cycle Housing Element, Piedmont’s rent-restricted accessory dwelling unit program was successful in accommodating and achieving the City’s share of the regional housing need, including producing housing for very low-income households. However, given the substantial increase in the City’s fair share of housing in the 6th Cycle, and other new State laws, the City will need to expand residential opportunities.

It is important to note that neither the City Charter nor the City Code contains any restrictions on the authority of the Council to modify permitted and conditional uses within a zone. Additionally, the language in the Charter and the City Code do not preclude the Council from changing the densities allowed within each zone. In about 1961, the City of Piedmont Charter was amended to require a vote of the electorate to change the zoning boundaries, including changing zoning of land, from one to another. Section 9.02 of the City’s Charter provides that [t]he Council may classify and reclassify the zones established, but no existing zones shall be reduced or enlarged with respect to size or area, and no zones shall be reclassified, without submitting the question to a vote at a general or special election.

Section 9.02 does not apply to changes within existing zoning districts like those called for in Zone A, Zone B, Zone C, and Zone D in the 6th Cycle Housing Element. In fact, Section

17.02.010.C of the City Code make it clear that “reclassify” as used in the City Charter means changing a property from one zone to another. The Code provides: “the prohibition not to reduce, enlarge, or reclassify a zone without a vote is understood to mean the city may not change the zone boundaries, or change (reclassify) a property from one zone to another.” Moreover, the legislative history demonstrates that “reclassification” or “reclassify” has always referred to changing property from one zone to another.

The City Council may modify the permitted or conditional uses or densities within an established zone without submitting the question to a vote at a general or special election or amending the City Charter. In the 6th Cycle Housing Element, the City of Piedmont commits to programs to change zoning regulations to increase residential densities and modify land uses across and within existing zoning districts by more than 400 percent increased development potential.

The City Charter requires a citywide vote for zoning map changes or zone reclassification, which constrains the development of a variety of housing types, particularly high-density Agenda Report Page 190 Attachment 2 Exhibit A

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multi-family housing (See Appendix C) and has implications on the City’s ability to diversify housing optionsexpand zoning districts to meet fair housing goals (See Appendix F). To address this constraint, This Housing Element the Cityproposes allowings religious institution affiliated housing in Zone A (Program 1.D), increasing the density for multifamily housing in Zone B (Program 1.F), increasing density in Zone C (Program 1.G), and increasing density for multi-family housing in the commercial zone (Zone D), and has created creating new incentives for multi-family uses (for example see Program 1.H), all without amending the Charter.. This program supplements other programs by monitoring, and annually evaluating, and reporting on the effects of the City Charter on: (a) the cost and supply of housing, particularly multi-family housing and (b) the effectiveness of City strategies to mitigate related impacts of the Charter.

City Planning & Building Department staff will continue to track annual housing production and permit activity as they have in the past, and will prepare annual reports to the Council evaluating housing and building permitting trends, and the effects of the Charter, as described above. These reports will specifically evaluate the Charter for impacts on multifamily housing production and costs, based on various criteria such as:
• Any failure of a citywide ballot measure associated with a proposed Zoning Map change to multi-family housing.
• A multi-family development proposal which has been endorsed or approved by the Planning Commission or City Council but does not proceed because a citywide ballot measure to change the zoning would be required. • Conclusions of research done by a third-party finding that the City Charter constrains the ability to do multi-family housing.
• Lack of multi-family development proposals.
• Input from the development community, including non-profits, property owners, stakeholders and advocates on behalf of lower-income households such as the Non-Profit Housing Association of Northern California (NPH), EBHO and the League of Women Voters.

Based on the outcomes of the evaluation, the City will implement program and zoning changes within 12 months including, if necessary, a Charter amendment or other appropriate remedies not requiring voter approval. These remedies could include streamlining multi-family permit procedures and identifying and designating, additional sites for multi-family development within 12 months.
• Objective: Monitor, evaluate, and report on the effects of the City Charter on:
(a) the cost and supply of housing, particularly multi-family housing and (b) the effectiveness of City strategies to mitigate related impacts of the Charter. Adopt strategies to address and mitigate identified constraints.

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• Timeframe: Review the effects of the Charter annually each March to April, if constraints are identified, begin Charter modifications within 12 months. • Responsible Agency: Planning & Building Department with direction of City Council and Planning Commission.

4.H Consider Modifying Charter Regarding Zoning Amendments The City will consider hold an annual review of modifying Section 9.02 of its charter to determine if it should seek to eliminate the requirement that the reclassification of zones and/or reduction or enlargement of size or area of zones be subject to a majority vote at a general or special election, as this presents a potential constraint to the production of housing (Ssee Program 4.G above regarding the City’s ability to make zoning text amendments without an election).
• Objective: Facilitate housing development by authorizing the Piedmont City Council to make necessary zoning amendmentsAmend the City Charter to eliminate the requirement that that the reclassification of zones and/or reduction or enlargement of size or area of zones be subject to a majority vote at a general or special election.annually examining the potential benefits and viability of a charter amendment authorizing the Piedmont City Council to make the necessary zoning reclassifications and boundary changes. • Timeframe: Within 3 years of Housing Element adoption 2027, 2029 and 2031Annually in March or April in coordination with the Housing Element Annual Progress Report..
• Responsible Agency: Planning & Building Department and City Attorney with direction of the City Council and Planning Commission.

4.I Health and Safety Code 17021.5 Compliance
The California Legislature has established that cities must allow the development of employee housing commensurate with local needs. State Health and Safety Code (Section 17021.5) requires that cities treat employee housing for six or fewer employees as single-family residential uses and allowed by right in residential zones which allow single-family uses. Employee housing may not be defined as “a boarding house, rooming house, hotel, (or) dormitory.”
The City does not currently allow employee housing (also called farmworker housing) in any zoning districts. The 5th Cycle Housing Element Update included Program 4.I (Health and Safety Code 17021.5 Compliance; program number modified to reflect current numbering) to amend the City Code to ensure compliance with the employee housing provisions of California Health and Safety Code §17021.5. This program was not yet completed.

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• Objective: Amend the City Code to ensure compliance with the employee housing provisions of California Health and Safety Code 17021.5. • Timeframe: Within 1 year of Housing Element adoptionBy March 2024. • Responsible Agency: Planning & Building Department.

4.J Small Lot Housing Study
As discussed in Program 2.B, the City’s existing supply of small homes is currently protected by limitations on the square footage and coverage of structures and parking requirements. However, to further facilitate development of smaller homes, the City will study and develop standards for small lot/infill projects to facilitate small home projects.

The City should study measures that other cities are taking to retain smaller homes and determine if any of these measures might be transferable to Piedmont. One concept to be explored is to include a category in the City’s annual design awards program for outstanding small homes and accessory dwelling units. This program is not necessary for meeting the City’s RHNA, but illustrates the City’s good-faith efforts to produce additional housing.
• Objective: Explore other incentives to protect small homes, including design awards for exemplary small home improvement projects.
• Timeframe: Complete small lot/infill study by December 2025. • Responsible Agency: Planning & Building Department.

4.K Small Lot Affordable Housing Study
The City should seek funding to conduct a study to better understand viability of affordable housing development on small lots, or develop a program to help facilitate the consolidation of land to realize the potential of smaller building sites in this area. The study would analyze viability of small site and small project (e.g. <10 unit) affordable development projects. This program is not necessary for meeting the City’s RHNA, but illustrates the City’s good-faith efforts to produce additional housing. • Objective: Understand the viability of affordable housing on smaller, infill lots. • Timeframe: When grant funds become available or reconsider in March 2024. • Responsible Agency: Planning & Building Department.

4.L Allow Parking Reductions for Multi-Family, Mixed-Use, and Affordable Projects The City should allow parking reductions for certain multi-family, mixed-use, and affordable projects in order to reduce constraints that may adversely affect multi-family project feasibility. Priority reductions shall be granted for projects with affordable housing.

Parking reductions should be coupled with programs to prevent overflow parking or other impacts on city mobility and emergency vehicle access, such as centralized structured parking, regulated on-street parking, residential parking permits, transportation demand Agenda Report Page 193 Attachment 2 Exhibit A

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management, red curb parking restrictions on narrow or marginal streets, or other strategies.
• Objective: Reduce constraints to multi-family housing development and amend the Zoning Ordinance to reduce parking for multi-family, mixed-use, and affordable housing projects.
• Timeframe: Amend the Zoning Ordinance by within 1 year of Housing Element adoptionMarch 2024.
• Responsible Agency: Planning & Building Department

4.M Facilitate Multi-Family and Residential Mixed-Use Projects by Right Subject to Objective Standards
Consistent with State law, including SB 35
and SB 330, the City will adopt objective
design standards for multi-family and
residential mixed-use projects. The purpose
of these standards is to expedite the
approval and development process for such
projects and support the City in meeting its
housing goals.

The City is currently undergoing a study to
develop recommendations for objective
design standards for multi-family and
residential mixed-use projects in Zone C
and Zone D, with the intent of increasing
density and development potential, reducing level of review and allowing multi-family and residential mixed-use by right, subject to the objective standards. Updates are planned in two phases, first, to amend the Piedmont Design Guidelines, and second, to amend the City Code. Recommendations include upper story step-backs, articulation requirements, regulation of building placement, standards for frontage design, and standards for architectural elements. Code amendments for SB35 development will include consideration of relaxation of street yard setback, coverage, and height standards, as well as new provisions for required private and shared open space and transportation demand management standards. The City has a target of 50 multi-family housing units facilitated by program 4.M, during the planning period.
• Objective: Adopt objective design standards for multi-family and residential mixed-use projects and amend required findings for approval to eliminate subjectivity consistent with State law.

G Square Living is a market-rate, mixed-use
development in San Rafael, CA. It has 10 units
with a density of 59 dwelling units per acre.

Source: https://gsquare.today/
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• Timeframe: Adopt first phase of standards by midJuly-20222023. Complete second phase City Code amendments by end of 2023.

Responsible Agency: Planning & Building Department.

4.N Allow Transitional and Supportive Housing by Right in Zones that Allow Residential Uses
Consistent with AB 2162 and other State law provisions, the City will amend the Zoning Ordinance to permit transitional and supportive housing uses by-right in all zones which allow residential uses, subject to the same standards of similar dwellings. Currently, transitional and supportive housing are only allowed by right in Zone B (Public Facilities; see Piedmont City Code Section 17.22.020(F)). All other zones in the City allow for residential uses (i.e., Zone A, C, D, and E). The City will amend its Zoning Ordinance to permit permanent supportive housing without discretionary action in zones allowing multifamily and mixed-use development and comply with Government Code Section 65651. • Objective: Amend the Zoning Ordinance to facilitate transitional and supportive housing throughout the planning period as described in the program above. • Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

4.O Allow Low Barrier Navigation Centers by Right in Zones that Allow Residential Uses
The City’s Zoning Ordinance does not specifically address Low Barrier Navigation Centers pursuant to AB 101 (Government Code §65660 et seq.). Low Barrier Navigation Centers are Housing First, low-barrier, service-enriched shelters focused on moving people into permanent housing that provides temporary living facilities, while case managers connect individuals experiencing homelessness to income benefits, health services, shelter, and housing. Low Barrier Navigation Centers must be allowed by-right in all residential zones, areas zoned for mixed-uses, and non-residential zones permitting multi-family uses.

Therefore, the City must amend the Zoning Ordinance to allow Low Barrier Navigation Centers in all zones that allow residential and mixed-use, consistent with AB 101 (Government Code §65660 et seq.).
• Objective: Amend the Zoning Ordinance to facilitate low barrier navigation centers throughout the planning period.
• Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

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4.P Residential Care Facilities
State law requires local governments to treat licensed residential care facilities (sometimes called group homes) with six or fewer residents as a residential use and subject to the same development standards as a single-family dwelling. Furthermore, no conditional use permit, zoning variance, or other zoning clearance shall be required of a residential facility that serves six or fewer persons that is not required of a family dwelling of the same type in the same zone. The residents and operators of a residential care facility shall be considered a family for the purposes of any law or zoning ordinance that relates to the residential use of property. However, “six or fewer persons” does not include the operator, operator’s family, or persons employed as staff. These facilities are licensed and regulated by the State of California.

The City does not define or allow residential care facilities in the Zoning Ordinance. To comply with State law, the City adds this Program to amend the Zoning Ordinance to permit residential care facilities for six or fewer persons by right in all zones which allow residential uses. Develop objective design standards and appropriate conditional use permit findings for residential and consider other provisions for care facilities for seven or more persons in Zone B and Zone D.
• Objective: Amend the Zoning Ordinance to define and allow residential care facilities consistent with State law and consider provisions for care facilities for both up to six persons and for seven or more persons.
• Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

4.Q Parking Reductions for Persons with
Disabilities, Seniors, and Other Housing
Types
Persons with disabilities normally have certain
housing needs that include accessibility of
dwelling units, access to transportation,
employment, and commercial services; and
alternative living arrangements that include onsite or nearby supportive services. The Lanterman Developmental Disabilities Services Act of the
California Welfare and Institutions Code (§5115
and §5116) declares that mentally and physically
Hillcrest Gardens in Daly City, CA is an
affordable senior housing development
with 40 units. It has a density of 100
dwelling units per acre.

Source: https://www.vmwp.com/
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disabled persons are entitled to live in normal residential surroundings. This classification includes facilities that are licensed by the State of California to provide permanent living accommodations and 24-hour primarily non-medical care and supervision for persons in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living. It also includes hospices, nursing homes, convalescent facilities, and group homes for minors, persons with disabilities, and people in recovery from alcohol or drug addictions.

The City ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulations and the Americans with Disabilities Act (ADA)) and federal requirements for accessibility. The City’s definition of family includes unrelated individuals living as a single unit and does not unnecessarily constrain living configurations conducive to persons with disabilities. However, the Zoning Ordinance does not define or contain regulations for the provision of housing types designed for persons with disabilities. Also, as noted above, there are no parking reductions for housing types for persons with disabilities; neither are there parking reductions for senior or other housing types. As such, this program recommends amending the Zoning Ordinance to include parking reductions or waivers for housing for persons with disabilities, seniors, and other housing types which may not require the standard number of spaces.
• Objective: Allow parking reductions or waivers for housing for persons with disabilities, seniors, and other housing types to reduce development constraints.
• Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

4.R Permit Streamlining
California Senate Bill 35 (“SB 35”), codified at Government Code Section 65913.41, became effective January 1, 2018. The intent of SB 35 is to expedite and facilitate construction of affordable housing. SB 35 requires cities and counties that have not made sufficient progress toward meeting their affordable housing to streamline the review and approval of certain qualifying affordable housing projects through a ministerial process.

The City of Piedmont complies with State requirements of SB 35 as part of project review when projects are proposed.

However, the City proposes to adopt local procedures consistent with SB 35. The City will develop an application form, checklist, and written policy and/or project approval guidelines to specify the SB 35 streamlining approval process and requirements for Agenda Report Page 197 Attachment 2 Exhibit A

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eligible projects as set forth under Government Code §65913.4 and the HCD Updated Streamlined Ministerial Approval Process Guidelines.
• Objective: Permit streamlining consistent with SB 35. • Timeframe: Develop department application form, handouts, and checklists and provide on City’s website within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning & Building Department with direction of the City Council and Planning Commission.

4.S Prioritize Sewer Hookups for Residential Development for Lower-Income Housing Consistent with Government Code Section 65589.7, the City will adopt written policies and procedures that grant a priority for sewer hookups to developments that help meet Piedmont’s share of the regional need for lower-income housing. Government Code §65589.7 also requires adopted Housing Elements to be immediately delivered to all public agencies or private entities that provide water or sewer services for industrial and municipal uses, including residential. The City will provide the adopted Housing Element to EBMUD immediately upon adoption.
• Objective: Grant a priority for sewer hookups to developments that help meet Piedmont’s share of the regional need for lower-income housing. • Timeframe: MidAugust -2024.
• Responsible Agency: Planning and Building Department/Public Works Department.

4.T Establish Standards for Emergency Shelters
Consistent with SB 2 and Government Code Section 65583(a)(4), the City will amend the Zoning Ordinance to establish objective standards for emergency shelters including the maximum number of beds, parking requirements for shelter staff, provision of onsite management, length of stay, and security as allowed by SB 2. In addition, as part of its efforts to establish objective design standards for emergency shelters and to reduce constraints as identified in Appendix C, the City will eliminate the need for design review for emergency shelters that conform to the standards.
• Objective: Develop objective standards for Emergency shelters. • Timeframe: Amend the Zoning Ordinance within 1 year of Housing Element adoptionby March 2024.
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission
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4.U Amend Conditional Use Permit Findings
To eliminate a potential governmental constraint, the City of Piedmont proposes new program 4.U, Amend Conditional Use Permit findings. In implementing program 4.U, the City will develop a conditional use permit process that complies with State law and distinguishes between required findings for commercial uses and required findings for residential uses. The new conditional use permit findings for residential uses will no longer require a finding that “The use is primarily intended to serve Piedmont residents (rather than the larger region)”.
• Objective: Develop revised conditional use permit process and findings. • Timeframe: Implement Zoning amendments within 3 years of the Housing Element rezoning deadline (by January 2026).
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission.
•

4.V Allow Emergency Shelters As Accessory Uses to Religious Facilities in Zone A To facilitate the development of emergency shelters, the City will amend its Zoning Ordinance to allow emergency shelters by right as an accessory use to religious facilities. • Objective: Facilitate the development of emergency shelters at religious facilities in Zone A.
• Timeframe: Implement Zoning amendments within 3 years of the Housing Element rezoning deadline (by January 2026).
• Responsible Agency: Planning and Building Department with direction of the City Council and Planning Commission.

Goal 5: Special Needs Populations
Policies
Policy 5.1: Retrofits for Diminished Mobility of Piedmont Residents. Ensure that planning and building regulations accommodate the retrofitting of homes to meet the needs of aging or disabled residents.

Policy 5.2: Accessory Dwelling Units, Shared Housing, and Seniors. Encourage accessory dwelling units and shared housing as strategies to help seniors age in place. Accessory dwelling units and shared housing can provide sources of additional income for senior homeowners, housing for seniors wishing to move to Piedmont, and housing resources for seniors seeking to downsize but remain in Piedmont.

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Policy 5.3: Reasonable Accommodation. Continue to provide reasonable accommodation for people with disabilities, including developmental disabilities, in the City’s rules, policies, practices and procedures related to zoning, permit processing, and building codes.

Policy 5.4: Extremely Low-Income Residents. Strive to meet the needs of extremely lowincome Piedmont community members, including single parents, seniors on fixed incomes, and persons in financial crisis or at risk of losing their homes.

Policy 5.5: Regional Approaches to Homelessness. Actively cooperate with and participate in regional discussions and programs addressing homelessness and the need for emergency shelter and supportive housing in the East Bay.

Policy 5.6: Foreclosure. Support State, regional, and countywide initiatives to reduce the risk of foreclosure and to assist those facing foreclosure.

Policy 5.7: Persons with Disabilities. Address the unique housing needs of Piedmont community members with disabilities, including those with developmental disabilities.

Programs

5.A Shared Housing Publicity and Media Initiative
Piedmont City Code Section 17.40.020 authorizes homeowners to rent a room or multiple rooms to a tenant (under a single lease). The City continues to inform residents of the regulations for renting rooms. However, there are no handouts or FAQs (frequently asked questions) available to this effect, at this time.

Home sharing can enable a live-in caregiver, or simply provide for added security and assistance for a senior householder. It also provides potential affordable housing opportunities for very low- and extremely low-income households. Programs such as those named in 5.B, below, can help place housemates with Piedmont homeowners.

A public information campaign, including web-based information and news articles, is recommended to encourage additional room rentals during the planning period. The target audience for such a campaign would be persons living alone in large single-family homes. • Objective: Increase awareness of Piedmont’s shared housing regulations and encourage households to participate in the program.
• Timeframe: Initiate in 2022 and ongoing.
• Responsible Agency: Planning & Building Department.

5.B Shared Housing Matching Services
Some of Piedmont’s “empty nesters” or other residents who have surplus space in their homes may wish to rent that space in return for income or care, but they may be reluctant to rent to strangers. The non-profit Eden Council for Hope and Opportunity (ECHO Agenda Report Page 200 Attachment 2 Exhibit A

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Housing), which serves residents throughout Alameda County, operates a shared housing program, which could potentially benefit these residents. Organizations, such as Roomily and Covia Home Match, provide similar programs. These programs match persons needing housing with homeowners who have available space. Shared housing programs can also provide a resource for low-income households, including families and seniors.

The ECHO program includes counseling on shared living, supportive services, referrals, and educational workshops on home sharing.

To help increase awareness of home sharing options, the City of Piedmont will issue a request for proposals (RFP) to partner with an organization to provide shared housing matching services (such as counseling, referrals, educational workshops, and supportive services) in Piedmont. Any shared housing program in Piedmont should be designed to include extremely low-income families, as well as empty nesters and other seniors. In addition, the City will amend its zoning ordinance to relax the limits on the number of home sharing leases allowed per single-family residence to further promote affordable housing.

Any shared housing program in Piedmont should be designed to include extremely lowincome families, as well as empty nesters and other seniors. • Objective: Issue an RFP to partner with an organization to provide shared housing matching services, particularly to low-income households, including families and seniors.
• Timeframe: Mid September 2023. Amend Ordinance by August 2024. • Responsible Agency: Planning & Building Department, City Administrator with direction of City Council.

5.C Assistance to Nonprofit Developers
There are several nonprofit entities in the East Bay who are actively engaged in developing housing for low- and moderateincome households. These developers make an important contribution to the region’s housing market and are the largest producers of affordable housing units in the area. Although there are very few vacant sites in Piedmont, the City is committed to working collaboratively with the nonprofit sector, including developers who represent underserved and/or
racially and ethnically diverse communities.

As development opportunities arise, the City will provide technical assistance to nonprofits in the completion and/or cosponsoring of applications for State and federal housing funds and other grants. The City will also work with nonprofit applicants to identify and proactively address issues of concern Mackey Terrace is located in
Novato, CA. It is an affordable,
special needs housing
development that was sponsored
by Eden Housing Inc., a non-profit
developer. Mackey Terrace has 50
units with a density of 26 dwelling
units per acre.

Source:
https://merrittcap.org/property/mackeyterrace/
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in the community, such as traffic, parking, and design compatibility. Finally, the City will consider regulatory concessions, incentives, and other methods which reduce project costs and make the project more viable.

The City has begun assisting Habitat for Humanity in their plans to provide services to low-income residents and will be proactive to help nonprofit developers to develop housing. • Objective: Provide assistance to nonprofit entities interested in developing housing for low- and moderate-income Piedmont residents, including the elderly and others with special needs. Establish a package of incentives that will be ready to assist the development of housing for lower-income households such as funding, adopting priority processing, granting concessions and incentives beyond State Density Bonus Law (see Program

1.Q), waiving parking requirements, waiving fees, and assisting with site preparation or predevelopment.
• Timeframe: Ongoing. Biannual Annual proactive check-in with potential nonprofit applicants/developers beginning March 2024. Package of incentives to be established by March 2025, except as directed in Program 1.Q. • Responsible Agency: Planning & Building Department, City Administrator with direction of City Council and Planning Commission.

5.D Accommodations for Disabled Persons
The City will work with local advocates and service providers (such as the Center for Independent Living) to provide an explanation of the process to retrofit a home to meet the needs of persons with disabilities, including developmental disabilities, on an as requested basis. Links to the websites of key service providers and advocacy organizations should be provided on the City’s website. Printed information (such as brochures or FAQ handouts), produced by these organizations should be available at City Hall, on an as requested basis. This information should identify the range of features that might be incorporated in a barrier-free home, and the steps an applicant would need to take to add these features to a residence. Also see Programs 4.N and 5.K regarding City efforts to promote permanent supportive housing.
• Objective: Provide access to printed and web-based information on an as requested basis which describes the procedures for making a Piedmont home “barrier free”. Work with regional providers and non-profit developers to identify development opportunities (as identified in Program 5.C) • Timeframe: City website with links will be provided by December 2023. Printed materials available by December 2023, upon request, and updated annually (as appropriate). Meetings with advocates upon request. • Responsible Agency: Planning & Building Department.

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5.E Housing Support for Families in Crisis
Despite the absence of a visible (albeit present) homeless population in Piedmont, the City is located in an urban area where homelessness is a serious issue and families often keep hidden their experiences of homelessness or their risk of homelessness. For example, during the COVID-19 pandemic, approximately 41 Piedmont residents requested emergency rental assistance to remain in their apartments or homes.

Piedmont currently provides financial assistance to Alameda County to fund countywide programs to meet the needs of homeless persons and persons at risk of becoming homeless. The beneficiaries of these programs may include Piedmont residents, as well as those in other cities. On an on-going basis, the City will stay apprised of homelessness issues, work with homeless service providers, and offer referrals for any Piedmont resident faced with the risk of homelessness. The City will also identify additional capacity and funding to pursue permanent supportive housing.
• Objective: Support public and non-profit agencies in Alameda County which provide food and shelter for families in crisis. Seek grant funding that supports housing for families in crisis.for
• Timeframe: Ongoing.
• Responsible Agency: City Administrator.

5.F EveryOne Home
In October 2009, the City of Piedmont joined 13 other cities in committing to work with Alameda County to alleviate homelessness. The Countywide Plan has been prepared in response to federal requirements that mandate the development of subregional plans to end homelessness. It recognizes the regional nature of the problem and the need for regional solutions. The Plan was designed to end chronic homelessness and provide more secure and permanent housing for low-income people with mental illness, HIV/AIDS, and other disabilities or high risk of homelessness. It includes a 10-year action plan, within a broader 15-year implementation plan. More recently, Alameda County developed its own plan to address homelessness. Piedmont will work with Alameda County to understand potential opportunity to adopt a similar plan for the City of Piedmont, which would replace EveryOne Home.

Participating in an established homeless plan is an important part of Piedmont’s efforts to meet the housing needs of extremely low-income households, as required by State law.

Endorsement of the plan by the City establishes general agreement with its strategies and provides a guide to address homelessness in a way that is consistent with other communities in Alameda County. It also represents a funding commitment by the City to countywide homeless services. The City of Piedmont contributes a pro-rata share of the funds used for operation and administration of the program.

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• Objective: Participate in the Alameda County EveryOne Home Program, a Countywide planning effort to increase housing opportunities for extremely lowincome and disabled persons and strengthen the services the County provides to the homeless. Investigate opportunities to incorporate elements of the Alameda County plan, or develop a Piedmont specific plan. • Timeframe: OngoingInvestigate opportunities to participate in Alameda County EveryOne Home Program implementation plan action items by March 2026 or adopt a City-specific plan to address homelessness by March 2026. Provide funding for operation and administration of the EveryOne Home Program annually in July.
• Responsible Agency: Planning & Building Department, with direction of City Council.

5.G Faith Community Participation
Piedmont’s religious institutions, including but not limited to churches and synagogues, are potential partners in efforts to address the housing needs of extremely low-income residents in Piedmont and nearby cities. Across California, 38,800 acres of developable land held by faith-based organizations could (and very likely would) be developed for affordable housing, if local land-use regulations would permit them. Assembly Bill 1851 requires that local governments allow religious institution affiliated housing development projects by right and update their parking requirements for this use (i.e., not require a replacement of parking that the new housing has been constructed on). Updating the City’s regulations would remove constraints that currently make it difficult to build housing on property held by religious institutions (See also Program 1.D above).

Emergency shelters are also allowed by right as accessory uses to religious facilities in Zone A (per Program 4.V).

Additional efforts should be made to coordinate local housing programs with the faith community. Introduce the concept of the use of faith-based institutions as partners in the development of new income-restricted and supportive housing in Piedmont. The City will also continue to work with its congregations to promote charitable contributions and develop proactive solutions to avoid homelessness and help those at risk of becoming homeless. This includes not only housing-related programs, but those which help extremely low-income persons with other needs, such as food, medical assistance, and access to supportive services. This program is implemented on an on-going basis. Local houses of worship continue to provide volunteer-run services (house repairs, tiny home construction, financial support, food drives, etc.) for lower income persons. • Objective: Work with the local faith community to serve residents in need within Piedmont and the greater East Bay, and to identify potential partners for meeting local extremely low-income housing needs. Conduct two outreach Agenda Report Page 204 Attachment 2 Exhibit A

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meetings with local faith-based
organizations to inform them about AB
1851 and provide technical assistance.
• Timeframe: Work with local faith-based
institutions to assist extremely-low
income persons on an oOngoing basis;.

Conduct two outreach meetings with local
faith-based institutions to discuss AB
1851, AB 2244, and Housing Element
Program 1.D in June 2024 and September
2024.
• Responsible Agency: City Administrator,
Planning and Building Department with
direction of City Council and Planning
Commission.

5.H Housing for Extremely Low-Income Individuals and Households Pursuant to Assembly Bill 2634, local governments are required to assist in the development of a variety of housing types to meet the needs of these households. In larger communities, this is usually done by accommodating single room occupancy hotels (SROs), providing multi-family developments with units set aside for extremely low-income (ELI) households, and facilitating supportive and transitional housing. In smaller communities, provisions for shelters and supportive and transitional housing are required by State law, but additional steps must still be taken to meet the diverse housing needs of extremely low-income residents.

Based on the most recent data available from the U.S. Department of Housing and Urban Development’s Comprehensive Housing Affordability Strategy (CHAS) American Community Survey from 2013-2017, 47 percent of Piedmont’s households with incomes of $41,100 or less are headed by seniors (110 of 234 households). Several programs under this goal focus on these residents (Programs 5.B and 5.H). As these programs are administered, the City will place a priority on serving extremely low-income senior applicants.

For extremely low-income residents in Piedmont who are not seniors, accessory dwelling units, SROs, and shared housing are the best prospects for meeting housing needs.

Anecdotally, an unknown number of the City’s accessory dwelling units appear to be occupied by extremely low-income households who live rent-free in accessory dwelling units in exchange for assistance with home repair and other household chores. Such units are an important housing resource for extremely low-income households and should be sustained.

Warner Creek is located in Novato,
CA. This affordable housing
development has 61 units and a
density of 26.9 dwelling units per
acre.

Source: https://edenhousing.org/
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In addition, Single-Room Occupancy (SRO) units are also one of the most traditional forms of affordable housing for lower income individuals, including seniors, persons with disabilities, and extremely low-income persons. An SRO unit is usually small, between 80 and 250 square feet. These units provide a valuable source of affordable housing and can serve as an entry point into the housing market for formerly homeless people. Some SRO units are marketed as affordable co-housing, and micro-unit housing development types where residents share certain facilities, such as community rooms or kitchens. Typically, in today’s co-housing or micro-unit housing SRO developments, residents live independently and do not receive communal meals. Affordable student housing does not qualify if occupants must be students to be eligible for housing.

The City has applied for a Homekey grant with Bay Area Community Services (BACS) and several jurisdictions in Alameda County in the amount of $20 million, total, to provide shared housing with supportive services to extremely low-income members of the community.

In the future, the City will explore pursue and establish strategies options to increase the inventory of extremely low-income housing through a request for proposals from planning consultants to develop standards to encourage the development of SROs, co-housing, and additional extremely low-income accessory dwelling units through the City's affordable accessory dwelling unit program and other means. This is already being done through allowances for room rentals and units to be constructed without off-street parking if they are 500 square feet or less and comply with JADU development regulations. It could also be done through a waiver of the business license tax, fee reductions, parking reductions, or other incentives, so that some of the very low-income units produced through the affordable accessory dwelling unit program are suitable for extremely lowincome households, including seniors and persons with disabilities. • Objective: : Explore ways to expand the inventory of housing for ELI households and Issue a request for proposals from planning consultants to develop standards to encourage the development of SROs, shared housingcohousing, and additional extremely low-income accessory dwelling units through the City's affordable accessory dwelling unit program and other means.

Amend the Zoning Ordinance to allow SROs in Zone C and Zone D. • Timeframe: Consider Zoning amendmentsIssue RFP by March 2024 and amend the Zoning Ordinance to allow SROs in Zones C and D within 3 years of the Housing Element rezoning deadline within 3 years of Housing Element adoption(by January 2026).
o Exploring opportunities to expand the inventory for ELU households is ongoing.
• Responsible Agency: City Clerk, Planning and Building Department with direction of the City Council and Planning Commission.

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•

5.I Housing For Extremely Low-Income Families
The City will pursue new incentives for housing for extremely low-income families, including apartments, two-bedroom units, and larger ADU incentives. The intent of this Program is to provide larger housing configurations to serve families, whereas the actions in Program 5.H. are intended to serve individuals.

Piedmont presently allows accessory dwelling units to be as large as 1,200 square feet if the units are rent restricted to very low-income households, including extremely lowincome households. The allowance for larger units if the unit is rented to a very low-income household provides a strong incentive that benefits extremely low-income families. A unit of this size would typically be associated with a two-bedroom apartment or carriage house, which could accommodate a three- or four-person extremely low-income family.

The City will also pursue additional incentives to encourage the inclusion of units that are affordable to extremely low-income households in new multi-family development. This Housing Element includes programs to develop incentives, such as allowances for higher lot coverage and floor area ratios in Zone C for buildings that dedicate one or more units for extremely low-income families and amendments to land use regulations in Zone D to make multi-family housing more feasible for low-income residents, including extremely low- income residents. The City has a goal of facilitating 5 new units for ELI individuals. • Objective: Develop incentives to meet the needs of Piedmont's extremely lowincome families, potentially including modified development standards for ADUs.
• Timeframe: Investigate incentives by June December 2023 and pursue recommendations within 1 year (JuneDecember 2024).
• Responsible Agency: Planning & Building Department, Building Official with direction of the City Council and Planning Commission.

5.J Developmentally Disabled Residents
Developmentally disabled residents include those with cerebral palsy, autism, epilepsy, and other conditions that typically appear before an individual reaches 18. Supportive housing is often required for such individuals to lead independent lives upon adulthood.

As required by State law, the City will continue to work with social service providers to explore opportunities for such housing within Piedmont. The City will also maintain communication with the Regional Center of the East Bay to identify service needs within the City and to identify available resources for local residents. • Objective: Coordinate with the Regional Center for the East Bay, the East Bay Housing Consortium, and other organizations to better respond to the housing Agenda Report Page 207 Attachment 2 Exhibit A

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needs of developmentally disabled residents and ensure that sufficient resources exist within and around the community to meet these needs. • Timeframe: Ongoing.Contact the Regional Center for the East Bay, the East Bay Housing Consortium, and other organizations to identify the needs of developmentally disabled residents and to identify available resources for local residents by March 2026.
• Responsible Agency: Planning & Building Department, Building Official.

5.K Transitional and Supportive Housing for Extremely Low-Income Residents The City is pursuing collaborative Alameda County grant funding so that a local affordable housing organization may be able to purchase a single-family home in a single-family neighborhood in Piedmont to convert into transitional and supportive housing for six persons in a shared housing community. The house or houses will be limited to six extremely low-income residents who have experienced chronic homelessness. • Objective: Collaborate with nonprofit affordable housing organization to convert a home or homes to transitional housing for six persons. • Timeframe: Within 3 years of the Housing Element rezoning deadlineWithin 3 years of adoption of final Housing Element, by January 2026. • Responsible Agency: Planning and Building Department.

5.L Definition of Family
To ensure no potential constraints to housing for persons with disabilities persist in the Zoning Ordinance, Program 5.L (Definition of Family) is proposed to revise the definition of “family” and remove any implicit requirements that families be “traditional,” that members “share household activities,” and requiring a “single written lease.” • Objective: Update definition of “family” in zoning code. • Timeframe: Within 3 years of the Housing Element rezoning deadline, by January 2026.
• Responsible Agency: Planning and Building Department.

Goal 6: Sustainability and Energy
Policies
Policy 6.1: Energy-Efficient Design. Require all new housing to be designed to encourage energy efficiency. Building design and construction methods should promote and support energy conservation.

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Policy 6.2: Energy-Efficient Materials. Encourage major additions and remodeling projects to use windows, building materials, ventilation systems, and appliances which reduce home heating and cooling costs and conserve energy resources.

Policy 6.3: Weatherization. Encourage weatherization of existing homes to reduce heating and cooling costs and lower home energy bills.

Policy 6.4: Renewable Energy. Maintain development regulations which accommodate the installation of solar panels and other devices which result in lower energy costs for homeowners and renters.

Policy 6.5: Energy Retrofits. Support the use of federal, State, county, and utility-sponsored programs which provide financial assistance or incentives for energy retrofits.

Policy 6.6: Housing and Climate Change. Recognize the link between housing and climate change in the City’s decision-making process. Specifically, the City should strive to create additional local housing opportunities for persons employed within Piedmont in order to reduce commuting and associated greenhouse gas emissions. A particular emphasis should be placed on transportation and on housing for municipal and school district employees, since these are the largest employers in the City.

Policy 6.7: Water Conservation. Encourage drought-tolerant and Bay-friendly landscaping as a way to conserve water, reduce greenhouse gas emissions associated with water transportation, and reduce homeowner water bills, thereby freeing up more income for other purposes.

Programs

6.A Title 24 and Reach Codes
The City will continue to require compliance with the Title 24 energy efficiency standards established by the California Energy Commission and Reach Codes adopted by the City Council. Adhering to these standards can reduce energy costs in new construction and existing buildings undergoing renovations by as much as 50%. • Objective: Continue to enforce Title 24 requirements for energy conservation. • Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department, Plan Checker.

6.B Green Housing
“Green” construction has the potential to reduce home utility costs and produce healthier living environments. The City should use tools such as the “Build it Green” checklist to encourage greener housing construction. The City will also monitor proposed changes to the building code at the State level and amend its ordinances accordingly. • Objective: Explore ways to encourage and incentivize greener residential construction.
• Timeframe: Ongoing.

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• Responsible Agency: Planning & Building Department, Building Official.

6.C Renewable Energy Funding Assistance
In 2009, the City of Piedmont developed a Climate Action Plan (CAP) to help achieve local greenhouse gas reduction goals. Because it is a City of older single-family homes, Piedmont must find ways to improve the energy efficiency of its existing housing stock in order to meet these goals. In December 2009, the City voted to join the California Statewide Communities Development Authority (CSCDA) and the California FIRST Program. More recently, the City has been participating in Energy Upgrade California, a statewide program that provides financial assistance for homeowners for select energysaving home improvements. The program includes energy assessments and physical improvements that reduce energy loss and improve energy efficiency. It encompasses rebates and incentives, income-qualified assistance for energy bills, and financing assistance to households seeking to install renewable energy systems and similar improvements. Piedmont will continue to participate in such programs in the future, reducing the burden of utility costs on homeowners and renters, while advancing its climate action and sustainability objectives.
• Objective: Participate in Energy Upgrade California or equivalent programs which assist homeowners with renewable energy and energy efficiency improvements on their property.
• Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department.

6.D Financial Assistance
Financial assistance for energy efficiency include:
• Energy audits, which may be provided by PG&E or private vendors. • Rebates (sponsored by non-City entities) for the use of energy efficient appliances, and for the recycling of less efficient appliances. • The federal Low-income Home Energy Assistance program (LIHEAP), which offers qualifying low-income households financial assistance to offset energy costs (through weatherization or assistance in paying energy bills). • “REACH” (Relief for Energy Assistance through Community Help), which is a PG&E program administered by the Salvation Army that provides energy assistance to low-income customers in the form of onetime payments for energy costs.
• CARE (California Alternate Rates for Energy) and FERA (Family Electric Rate Assistance), both programs which provide rate discounts for lower income households
• A Medical Baseline Allowance for persons with high medically related electric bills.

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• Local rebate programs under consideration by the City of Piedmont, such as a new electrification rebate pilot program.

Information on these programs should be kept at the Planning and Building counter for interested residents and should be accessible via links on the City’s website.

The City promotes REACH Codes and energy reduction programs as a part of the Climate Action Plan. Building Permits for residential solar energy systems are expedited with a flat fee. The City also participates in Energy Upgrade California and PACE programs. • Objective: Promote the use of programs which reduce residential energy costs. • Timeframe: Ongoing.
• Responsible Agency: Planning & Building Department, Building Official.

Goal 7: Equal Access to Housing
Policies
Policy 7.1: Housing Choice. Promote the development of housing for all persons regardless of race, religion, ethnic background or other arbitrary factor.

Policy 7.2: County Fair Housing Programs. Support and participate in Alameda County programs which ensure that all persons have equal access to housing.

Policy 7.3: Fair Housing Enforcement. Implement and enforce relevant State of California and federal fair housing laws.

Policy 7.4: Fair Housing Education. Promote public education and awareness of fair housing requirements, and reduce public misconceptions about low-income housing.

Programs

7.A Public Information
This is an ongoing program that will be continued in the future. Pamphlets on fair housing laws and procedures are kept at the Planning and Building public counter. Materials should continue to be provided in English, Spanish, and Chinese to ensure that those in need are made aware of their fair housing rights. Vietnamese and Tagalog language material will be made available on request. This information, including links to ECHO housing’s website, should also be posted on the City’s website. In 2020, the City updated its website and created a fair housing programs webpage with information for residents.

The City should consider participation in countywide online affordable housing resources, such as participation in the Alameda County Housing Portal website that helps publicize the availability of affordable housing units and the process for obtaining housing.

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• Objective: Continue to provide and expand printed information on fair housing laws at City Hall and web-based information on the City’s website. • Timeframe: Ongoing
• Responsible Agency: Planning and Building Department.

7.B Fair Housing Referrals
The City presently refers discrimination complaints to the ECHO Housing, a Countywide non-profit agency. If mediation fails and enforcement is necessary, tenants may be referred to the State Department of Fair Employment and Housing or HUD, depending on the complaint.
• Objective: Continue the City’s referral arrangement with ECHO Housing on fair housing issues and discrimination complaints.
• Timeframe: Ongoing
• Responsible Agency: Planning & Building Department, City Clerk.

7.C Housing Equity
The City will pursue grants to expand its publicity campaign to underserved and racially and ethnically diverse communities, including graphics and photographs and other representation to publicize the benefits of the City’s affordable and fair housing programs to all Piedmont community members (See Program 1.C for ADU specific outreach). • Objective: Increase awareness of the City’s fair housing programs amongst underserved and racially and ethnically diverse members of the Piedmont community.
• Timeframe: End December 2023: Identify target underserved and racially and ethnically diverse groups. End December 2024: Distribute media for outreach. • Responsible Agency: Planning & Building Department.

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IV.B Quantified Objectives
Table IV-1 presents the City’s quantified objectives for construction, preservation, and rehabilitation for the 2023 – 2031 planning period that will be achieved through the policies and programs described above.

Table IV-1: Quantified Objectives
Program Type/Affordability Extremely
Low1
Very Low Low Moderate Above
Moderate
Total2
New Construction 65 98 134 171 236 704

1.B Market-rate ADUs - 20 46 46 16 128

1.D Religious Affiliated Housing - - - 70 - 70

1.E Inclusionary ADUs - - - 10 - 10

1.F Zoning B Changes - - - - - -

1.G Zone C Changes - - - - 15 15

1.H Zone D Changes 20 20 43 - 108 191

1.J Implementation SB 9 - - - 20 20 40

1.L Specific Plan 20 20 20 - 72 132

1.M Mobile and Manufactured
Homes - - - - 5 5

3.D ADU Missed Opportunities - - - 10 - 10

3.E Affordable Housing Fund 2 10 5 - - 17

3.F Incentives Affordable ADUs 5 5 5 5 - 20

4.M Objective Design Standards 10 15 15 10 - 50

5.H Single-Room Occupancy 5 5 - - - 10

5.K Supportive Housing 3 3 - - - 6
Rehabilitation - - 4 4 - 8

2.A CDBG Rehabilitation 4 4 8
Conservation/Preservation - - - 17 - 17

3.B Legalize Unpermitted ADUs - - - 17 - 17
Total 65 98 138 192 236 729
Notes:
1 The City estimates 50% of the Very Low households would qualify as extremely low-income. 2 The quantified objectives are separate from the housing capacity identified in the City’s site inventory, Appendix B.

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Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 1 Appendix A:Demographics and Housing
Needs Assessment
Contents
Appendix A: Housing Needs Assessment ............................................. A-1 Section A.1 Introduction and Summary ................................................................................ A-2 A.1.1 Introduction........................................................................................................ A-2 A.1.2 Summary ........................................................................................................... A-2 Section A.2 Population Characteristics................................................................................. A-4 A.2.1 Population ......................................................................................................... A-4 A.2.2 Age .................................................................................................................... A-5 A.2.3 Race/Ethnicity ................................................................................................... A-7 A.2.4 Employment ...................................................................................................... A-8 Section A.3 Household Characteristics............................................................................... A-15 A.3.1 Household Size ............................................................................................... A-15 A.3.2 Overcrowding .................................................................................................. A-15 A.3.3 Household Income .......................................................................................... A-19 A.3.4 Special Housing Needs ................................................................................... A-22 A.3.5 Displacement................................................................................................... A-42 Section A.4 Housing Stock Characteristics......................................................................... A-43 A.4.1 Housing Type and Vacancy ............................................................................ A-43 A.4.2 Housing Tenure............................................................................................... A-46 A.4.3 Housing Units Permitted.................................................................................. A-49 A.4.4 Housing Age and Condition............................................................................. A-50 Section A.5 Housing Costs and Affordability ...................................................................... A-52 A.5.1 Ownership Costs ........................................................................................... A-_52 A.5.2 Rental Costs.................................................................................................... A-53 A.5.3 Overpayment................................................................................................... A-60 A.5.4 At-Risk Housing Assessment .......................................................................... A-69 Agenda Report Page 215 Attachment 2 Exhibit A
A-2 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Section A.1 Introduction and Summary
A.1.1 Introduction
This Appendix forms the foundation for understanding Piedmont’s housing needs.

It analyzes a range of demographic, economic, and housing-related variables to determine the extent and context of the City’s housing-related need. Information gathered through this section provides a basis from which to build housing goals, policies, and programs to address those needs.

This needs assessment includes an analysis of the City’s population, special needs groups, employment, housing stock, and housing affordability.

The main source of data used to form the majority of this section is HCD pre-certified local housing data provided by ABAG, which relies primarily on the American Community Survey (ACS) 2015- 2019, California Department of Finance (DoF), and HUD’s Comprehensive Housing Affordability Strategy (“CHAS”) data.

A.1.2 Summary
Housing needs are determined by a city’s population and its existing housing stock and provide context for developing housing policy, such as which types of housing and its affordability levels are most needed in the community. The following summarizes key data from this housing needs assessment.
• Piedmont has a higher income population than Alameda County (county). Piedmont’s 2019 median household income was $224,659, 126 percent higher than the county ($99,406). However, nearly 6 percent of households in Piedmont are extremely lowAgenda Report Page 216 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 3 income, and approximately 16.1 percent of Piedmont households are low-income households (earn less than 80 percent of Area Median Income (AMI)) • Home prices are higher in Piedmont than in the county. Households must earn $251,200 (over 200 percent of AMI) to be able to afford to buy an average priced home in the city.

A household must have an annual income of $123,650 (120 percent of AMI) to be able to afford market rent in Piedmont.
• Approximately 21.29 percent of Piedmont homeowners and 21.08 percent of renters are cost burdened, meaning they spend 30 percent or more of gross income on housing costs, Additionally, 12.5 percent of renters spend 50 percent or more of their income on housing, compared to about 8.4 percent of homeowners. Piedmont has a lower proportion of costburdened households compared to the county (37 percent). • Renter householders are more likely to be living in overcrowded conditions than owneroccupied households. However, in Piedmont there is no reported overcrowding by renters. • Piedmont’s population is 71 percent White, 18 percent Asian, 6 percent two or more races,

4.15 percent Hispanic/Latino, and 1.4 percent African American. People of Color comprise a lower proportion of Piedmont’s population compared to the Bay Area. Hispanic or Latino identified residents experience the highest rates of poverty in Piedmont. • Piedmont’s median age is 47.4, nearly ten years higher than the county (38 years). Seniors (65 years and above) make up approximately 21.5 percent of the population. Out of the total senior population, approximately 33 percent are cost burdened. Seniors are designated a special needs population under housing element law. Seniors can face higher levels of housing insecurity because they are more likely to be on a fixed income while requiring higher levels of care.
• Piedmont’s other special housing needs populations include persons with a disability that may require accessible housing (7.1 percent of residents) and female-headed households who are often at greater risk of housing insecurity (5.6 percent of households). • Piedmont has 371 large households (five or more people), which are generally served by three-bedroom or larger units. Piedmont’s housing mix of three-bedroom or larger units (3,374 units) can sufficiently accommodate the number of larger families. • A variety of housing types is important to meet the needs of all members of the community.

Over 93 percent of Piedmont’s housing stock is single-family (attached and detached).

Single-family attached homes have experienced the most growth over the last decade. · • The rate of housing production is relatively slow, with only 55 units permitted in the past 10 years. The largest proportion of Piedmont’s housing units was built in 1939 or earlier.

This represents an aging housing stock.

Agenda Report Page 217 Attachment 2 Exhibit A
A-4 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Section A.2 Population Characteristics
A.2.1 Population
The Bay Area (Region) is the fifth-largest metropolitan area in the nation and has seen a steady increase in population since 1990, except for a dip during the Great Recession that began in 2007.

Many cities in the Region have experienced significant growth in jobs, wages and population.

While these trends have led to a corresponding increase in demand for housing across the Region, the regional production of housing has largely not kept pace with job and population growth. In 2020, the population of Piedmont was estimated to be 11,453 (see Table A-1). From 1990 to 2000, the population increased by 3.3 percent, while it decreased by 2.6 percent during the first decade of the 2000s. In the most recent decade (2010 to 2020), the population increased by 7.4 percent.

The population of Piedmont makes up 0.7 percent of Alameda County.

Since 2000, Piedmont’s population has increased by 4.6 percent, which is below the 14 percent increase experienced by the Region as a whole during the same period. In Piedmont, roughly 7.5 percent of its population moved during the past year, a number 5.9 percentage points smaller than the regional rate of 13.4 percent. This statistic shows the stability of the Piedmont community and the limited supply of homes that normally become available as homeowners move or downsize. (See Figure A-1).

Table A-1: Population Growth Trends
1990 1995 2000 2005 2010 2015 2020
Geography
Piedmont 10,602 11,129 10,952 11,088 10,667 11,291 11,453 Alameda County 1,276,702 1,344,157 1,443,939 1,498,963 1,510,271 1,613,528 1,670,834 Bay Area 6,020,147 6,381,961 6,784,348 7,073,912 7,150,739 7,595,694 7,790,537 Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Finance, E-5 series) Agenda Report Page 218 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 5 Figure A-1: Population Growth Trends
Note: The data shown on the graph represents population for the jurisdiction, county, and Region indexed to the population in the first year shown. The data points represent the relative population growth in each of these geographies relative to their populations in that year. For some jurisdictions, a break may appear at the end of each decade (1999, 2009) as estimates are compared to census counts. DOF uses the decennial census to benchmark subsequent population estimates.

Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Finance, E-5 series) A.2.2 Age
The distribution of age groups in a city influences the types of housing the community may need in the near future. An increase in the older population may mean there is a developing need for more senior housing options, while higher numbers of children and young families can point to the need for more family housing options and related services. Trends indicate an increased desire to age-in-place or downsize in order to stay within their communities, which can mean more multifamily and accessible units are also needed.

In Piedmont, the median age in 2000 was 42.4; by 2019 this figure had increased to around 47 years. In 2019, the median age in Alameda County was around 38 years old. The population of seniors (65 years and above) living in Piedmont increased by 72.5 percent since 2010 and makes up an estimated 21.5 percent of the total population. Conversely, the population of those under 14 in Piedmont has decreased since 2010.

Looking at the senior and youth population by race can add an additional layer of understanding, as families and seniors of color are even more likely to experience challenges finding affordable housing. People of Color (all non-white racial groups) make up 19.0 percent of seniors and 30.8 percent of youth under 18 years of age (see Figure A-3). 100
105
110
115
120
125
130
135
1990199119921993199419951996199719981999200020012002200320042005200620072008200920102011201220132014201520162017201820192020 Index (Year %s = Index 100)
Index
Piedmont
Index
Alameda County
Index
Bay Area
Agenda Report Page 219 Attachment 2 Exhibit A
A-6 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-2: Piedmont Population by Age, 2000-2019, City of Piedmont Notes:

Universe: Total population
Source: ABAG 2021 Pre-certified Housing Needs Data ((U.S. Census Bureau, Census 2000 SF1, Table P12; U.S.

Census Bureau, Census 2010 SF1, Table P12; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001)
Figure A-3: Senior and Youth Population by Race, City of Piedmont Notes:

Universe: Total population
In the sources for this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latino ethnicity, and an overlapping category of Hispanic / non-Hispanic groups has not been shown to avoid double counting in the stacked bar chart.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-G))
14% 20% 17%
16%
69% 74% 81%
0%
20%
40%
60%
80%
100%
Age 0-17 Age 18-64 Age 65+
Population
White (Hispanic and Non-Hispanic)
Other Race or Multiple Races (Hispanic and Non-Hispanic) Black or African American (Hispanic and Non-Hispanic)
Asian / API (Hispanic and Non-Hispanic)
American Indian or Alaska Native (Hispanic and Non-Hispanic)

0.6k

2.0k

1.1k

0.5k

1.5k

2.5k

1.2k

0.8k

0.5k

0.2k

0.5k

1.9k

1.1k

0.4k

1.2k

1.9k

2.0k

0.9k

0.5k

0.2k

0.4k

1.8k

1.2k

0.7k

1.1k

2.1k

1.6k

1.5k

0.5k

0.4k
0 500
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1,500
2,000
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Age 0-4 Age 5-14 Age 15-
24 Age 25-
34 Age 35-
44 Age 45-
54 Age 55-
64 Age 65-
74 Age 75-
84 Age 85+
Population
2000 2010 2019
Agenda Report Page 220 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 7 A.2.3 Race/Ethnicity
Understanding the racial and ethnic makeup of a city and Region is important for designing and implementing effective housing policies and programs. These patterns are shaped by both market factors and government actions, such as exclusionary zoning, discriminatory lending practices and displacement that has occurred over time and continues to impact communities of color today.

Piedmont has a higher share of residents identifying as White, Non-Hispanic than the county and region, and a smaller share of residents identifying as American Indian or Alaska Native, Asian/Asian Pacific Islander, Non-Hispanic, Black or African American, and Hispanic or Latino than compared to the county and region. (See Figure A-4) Figure A-4: Population by Race and Ethnicity, 2019, City of Piedmont Notes:

Data for 2019 represents 2015-2019 ACS estimates.

The Census Bureau defines Hispanic/Latino ethnicity separate from racial categories. For the purposes of this graph, the “Hispanic or Latino” racial/ethnic group represents those who identify as having Hispanic/Latino ethnicity and may also be members of any racial group. All other racial categories on this graph represent those who identify with that racial category and do not identify with Hispanic/Latino ethnicity.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, Census 2000, Table P004; U.S.

Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002) Since 2000, the percentage of residents in Piedmont identifying as White has decreased – and at the same time the percentage of residents of all other races and ethnicities has increased by 8.1 percentage points (see Figure A-5), with the total population of all other races and ethnicities at 3,292 in 2019. In absolute terms, the Other Race or Multiple Races, Non-Hispanic population increased the most while the Non-Hispanic White population decreased the most. 18%
31% 27%
10%
6%
71% 31%
39%
6%
5% 5%
4%
22% 24%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Population
American Indian or Alaska Native, Non-Hispanic Asian / API, Non-Hispanic Black or African American, Non-Hispanic White, Non-Hispanic Other Race or Multiple Races, Non-Hispanic Hispanic or Latinx Agenda Report Page 221 Attachment 2 Exhibit A
A-8 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-5: Population by Race and Ethnicity, 2000-2019, City of Piedmont Notes:

Data for 2019 represents 2015-2019 ACS estimates.

The values above do not add up to 100% as they are rounded to the nearest one-tenth.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, Census 2000, Table P004; U.S.

Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002) A.2.4 Employment
A city houses employed residents who either work in the community where they live or work elsewhere in the region. Conversely, a city may have job sites that employ residents from the same city, but more often employ workers commuting from outside of it. Smaller cities typically will have more employed residents than jobs there and export workers, while larger cities tend to have a surplus of jobs and import workers. To some extent the regional transportation system is set up for this flow of workers to the region’s core job centers. At the same time, as the housing affordability crisis has illustrated, local imbalances may be severe, where local jobs and worker populations are out of sync at a sub-regional scale. This imbalance burdens employees who must travel greater distances between their home and place of employment, which also strains the transportation system and has grave environmental implications. 16% 18% 18%
1% 1% 1%
79% 72% 71%
5% 6%
3% 4% 4%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2000 2010 2019
Share of Population
American Indian or Alaska Native, Non-Hispanic Asian / API, Non-Hispanic Black or African American, Non-Hispanic White, Non-Hispanic Other Race or Multiple Races, Non-Hispanic Hispanic or Latinx Agenda Report Page 222 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 9 One measure of this is the relationship between workers and jobs. A city with a surplus of workers (meaning more workers than jobs available) “exports” workers to other parts of the region, while a city with a surplus of jobs (meaning more jobs than can be filled with local workers) must conversely “import” them. There are 5,350 employed residents, and 3,622 jobs1in Piedmont - the ratio of jobs to resident workers is 0.68; Piedmont is a net exporter of workers. Overall, 3.4 percent of people employed in Piedmont also live in the city (Longitudinal Employer-Household Dynamics On the Map).

Between 2002 and 2018, the number of jobs in Piedmont decreased by 2.6 percent. However, there was a notable rebound in jobs in Piedmont between 2015 and 2018 (see Figure A-6).

Figure A-6: Jobs in the City of Piedmont
Notes:

Universe: Jobs from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment
The data is tabulated by place of work, regardless of where a worker lives. The source data is provided at the census block level.

These are crosswalked to jurisdictions and summarized.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files, 2002-2018) 1 Employed residents in a jurisdiction is counted by place of residence (they may work elsewhere) while jobs in a jurisdiction are counted by place of work (they may live elsewhere). The jobs may differ from those reported in Figure A-6 as the source for the time series is from administrative data, while the cross-sectional data is from a survey.

Agenda Report Page 223 Attachment 2 Exhibit A
A-10 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-7 shows the balance when comparing jobs to workers, broken down by different wage groups, offering additional insight into local dynamics. A community may offer employment opportunities for relatively low- income workers but have relatively few housing options for those workers. Conversely, it may house residents who are low wage workers but offer few employment opportunities for them. Such relationships may cast extra light on potentially unmet demand for housing in particular price categories. A relative surplus of jobs relative to residents in a given wage category suggests the need to import those workers, while conversely, surpluses of workers in a wage group relative to jobs means the community will export those workers to other jurisdictions. Such flows are not inherently bad, though over time, sub-regional imbalances may appear.

Piedmont has more low-wage jobs (1,253) than low- wage residents (811), where low-wage refers to jobs paying less than $25,000. At the other end of the wage spectrum, the city has more highwage residents than high-wage jobs (where high-wage refers to jobs paying more than $75,000) (see Figure A-7)2. The number of workers by wage category was supplied by ABAG and was sourced from the 2019 American Community Survey.

Figure A-7: Workers by Earnings, as Place of Work and Place of Residence, City of Piedmont Notes:

Universe: workers 16 years and over with earnings
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519)
2 The source table is top-coded at $75,000, precluding more fine grained analysis at the higher end of the wage spectrum.
446
365
512
486
3,541
411
842
799
372
1,198
0 500
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Less than $9,999 $10,000 to
$24,999
$25,000 to
$49,999
$50,000 to
$74,999
$75,000 or more
Worker Population
Place of Residence Place of Work
Agenda Report Page 224 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 11 Figure A-8 shows the balance of Piedmont’s resident workers to the jobs located there for different wage groups as a ratio instead - a value of 1 means that a city has the same number of jobs in a wage group as it has resident workers - in principle, a balance. Values close to 0 indicate a jurisdiction will need to export workers for jobs in a given wage group. At the regional scale, this ratio is 1.04 jobs for each worker, implying a modest import of workers from outside the Region (see Figure A-8).

Figure A-8: Jobs-Worker Ratios, by Wage Group, City of Piedmont Notes:

Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment The ratio compares job counts by wage group from two tabulations of LEHD data: Counts by place of work relative to counts by place of residence. See text for details.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence Area Characteristics (RAC) files (Employed Residents), 2010-2018)
Such balances between jobs and workers may directly influence the housing demand in a community. When there is high demand for housing relative to supply at different income levels, workers will compete for a limited supply. As already shown, many Piedmont workers may be unable to afford to live where they work, particularly when housing growth has been in higher income markets. This dynamic not only means many workers will need to prepare for long commutes and time spent on the road, but in the aggregate, it contributes to traffic congestion and time lost for all road users.

If there are more jobs than employed residents, it means a city is relatively jobs-rich, typically also with a high jobs-to-household ratio (over 1.0). The jobs-household ratio in Piedmont has remained fairly constant over time, from 0.49 in 2002 to 0.47 jobs per household in 2018 (see Figure A-9).

0.10 0.20

0.30 0.40

0.50 0.60

0.70 0.80

0.90 1.00
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Ratio
Wages Less Than $1,250/Mo Wages $1,250-$3,333/Mo
Wages More than $3,333/Mo
Agenda Report Page 225 Attachment 2 Exhibit A
A-12 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Piedmont’s ratio is significantly lower than both Alameda County (1.43) and the Region (1.47), suggesting the city has a lower ratio of jobs to housing units relative to the rest of the Bay Area and that while the county and Region are job rich, Piedmont houses more workers than it has jobs to support.

Figure A-9: Jobs-Household Ratio
Notes:

Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment; households in a jurisdiction The data is tabulated by place of work, regardless of where a worker lives. The source data is provided at the census block level.

These are crosswalked to jurisdictions and summarized. The ratio compares place of work wage and salary jobs with households, or occupied housing units. A similar measure is the ratio of jobs to housing units. However, this jobs-household ratio serves to compare the number of jobs in a jurisdiction to the number of housing units that are actually occupied.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs), 2002-2018; California Department of Finance, E-5 (Households))
In terms of sectoral composition, the largest industry in which Piedmont residents work is Financial & Professional Services, and the largest sector in which Alameda residents work is Health & Educational Services (see Figure A-10). For the Bay Area as a whole, the Health & Educational Services industry employs the most workers.

0.30 0.50

0.70 0.90

1.10 1.30

1.50 1.70
20022003200420052006200720082009201020112012201320142015201620172018 Ratio
Piedmont Alameda County Bay Area
Agenda Report Page 226 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 13 Figure A-10: Resident Employment by Industry
Notes:

Universe: Civilian employed population age 16 years and over The data displayed shows the industries in which jurisdiction residents work, regardless of the location where those residents are employed (whether within the jurisdiction or not).

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table C24030)
In Piedmont, there was a two percentage pointpercent decrease in the unemployment rate between January 2010 and January 2021. Jurisdictions throughout the Region experienced a sharp rise in unemployment in 2020 due to impacts related to the COVID-19 pandemic, with a general improvement and recovery in the later months of 2020. 4% 5% 6%
38% 26% 26%
29%
30% 30%
5%
4% 4%
12%
17% 17%
7% 9% 9%
6% 8% 8%

0.0%

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Share of Employed Residents
Piedmont Alameda County Bay Area
Agriculture & Natural Resources Construction
Financial & Professional Services Health & Educational Services Information Manufacturing, Wholesale & Transportation
Retail Other
Agenda Report Page 227 Attachment 2 Exhibit A
A-14 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-11: Unemployment Rate
Notes:

Universe: Civilian employed population age 16 years and over Unemployment rates for the jurisdiction level is derived from larger-geography estimates.

Source: ABAG 2021 Pre-certified Housing Needs Data (California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates, 2010-2021) 0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Percent of Labor Force that is Unemployed
Piedmont Alameda County Bay Area
Agenda Report Page 228 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 15 Section A.3 Household Characteristics
A.3.1 Household Size
In Piedmont, the largest share of households (32 percent) consists of a household with two people, while the lowest share of households (10 percent) consists of five-or-more persons (renters and owners combined). Three-person households make up 17 percent of the occupied housing stock and four-person households make up 26 percent (see Table A-2). According to the California Department of Finance, Piedmont had an average household size of 2.89 in 2021. For additional information on household size, see Section A.3.2 (Overcrowding) and A.3.4 (Special Housing Needs).

Table A-2: Household Size, City of Piedmont
Owner
Occupied
% Owner
Occupied
Renter
Occupied
% Renter
Occupied
1-person household 516 15.3% 111 23.9%
2-person household 1,110 32.9% 101 21.7%
3-person household 593 17.6% 57 12.3%
4-person household 802 23.8% 177 38.1%
5-or-more person household 352 10.4% 19 4.1%
Total occupied housing units 3,373 100.00% 465 100.00%
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25009) A.3.2 Overcrowding
Overcrowding occurs when the number of people living in a household is greater than the home was designed to hold. There are several different standards for defining overcrowding, but this report uses the Census Bureau definition, which is more than one occupant per room (not including bathrooms or kitchens). Additionally, the Census Bureau considers units with more than

1.5 occupants per room to be severely overcrowded.

Overcrowding is often related to the cost of housing and can occur when demand in a city or Region is high. In many cities, overcrowding is seen more amongst those that are renting, with multiple households sharing a unit to make it possible to stay in their communities. In Piedmont,

0.0 percent of households that rent are severely overcrowded (more than 1.5 occupants per room), compared to 0.1 percent of households that own (see Figure A-12). In Piedmont, 1.9 percent of renters experience moderate overcrowding (1 to 1.5 occupants per room), compared to 0.0 percent for those own.

Agenda Report Page 229 Attachment 2 Exhibit A
A-16 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-12: Overcrowding by Tenure and Severity, City of Piedmont Notes:

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) Overall, Piedmont has a lower rate of overcrowding than the rest of the region. Only a small fraction of Piedmont residents face overcrowded conditions, compared to eight percent of Alameda County residents and seven percent of Bay Area residents. 2%
.01%

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%
Owner Occupied Renter Occupied
Percent of Households

1.0 to 1.5 Occupants per Room More than 1.5 Occupants per Room Agenda Report Page 230 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 17 Figure A-13: Overcrowding Severity
Notes:

The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) Overcrowding often disproportionately impacts low-income households. 4.2 percent of very lowincome households (below 50 percent AMI) experience severe overcrowding, while 0.5 percent of households earning above 100 percent of the AMI experience this level of overcrowding (see Figure A-14).
100% 92% 93%
5% 4%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Households

1.00 occupants per room or less 1.01 to 1.50 occupants per room

1.50 occupants per room or more
Agenda Report Page 231 Attachment 2 Exhibit A
A-18 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-14: Overcrowding by Income Level and Severity, City of Piedmont Notes:

Universe: Occupied housing units
The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded. Income groups are based on HUD calculations for Area Median Income (AMI). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) Communities of color are more likely to experience overcrowding and are more likely to experience poverty, financial instability, and housing insecurity. People of Color tend to experience overcrowding at higher rates than White residents. In Piedmont, the racial group with the largest overcrowding rate is “Other Race or Multiple Races (Hispanic and Non-Hispanic)” (see Figure A-15).
5%
.01%
4%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI 81%-100% of AMI Greater than 100% of AMI
Percent of Households

1.0 to 1.5 Occupants per Room More than 1.5 Occupants per Room Agenda Report Page 232 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 19 Figure A-15: Overcrowding by Race, City of Piedmont
Notes:

Universe: Occupied housing units
The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded. For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latino ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latino. Since residents who identify as white and Hispanic/Latino may have very different experiences within the housing market and the economy from those who identify as white and non- Hispanic/Latino, data for multiple white sub-groups are reported here.

The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the total number of occupied housing units for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the total number of occupied housing units.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25014)
A.3.3 Household Income
Household income is a critical component of housing affordability. Income impacts the decision to rent versus own, the size of unit, and the location of housing. Overall, household income in Piedmont is higher than that of Alameda County. Piedmont’s median household income in 2019 was $224,659, which is 126 percent higher than the county’s median income of $99,406. The mean income in Piedmont ($311,922) is 138.6 percent higher than in Alameda County ($130,710).

Table A-3: Household Income, City of Piedmont
Piedmont Alameda County
Median Income $224,659 $99,406
Mean Income $311,922 $130,710
Source: ACS 5-year estimates (2019), S1901
9%
22%
0% 0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%
More than 1.0 Occupants per Room
Percent of Households
American Indian or Alaska Native (Hispanic and Non-Hispanic) Asian / API (Hispanic and Non-Hispanic) Black or African American (Hispanic and Non-Hispanic) Hispanic or Latinx Other Race or Multiple Races (Hispanic and Non-Hispanic) White (Hispanic and Non-Hispanic) White, Non-Hispanic
Agenda Report Page 233 Attachment 2 Exhibit A
A-20 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment The RHNA includes specific income categories defined by their respective proportion of the county area median income (AMI). Table A-4 defines these income categories.

Table A-4: Income Categories as a Percentage of AMI, City of Piedmont % of AMI
Extremely Low 0-30%
Very Low 30-50%
Low 50-80%
Moderate 80-120%
Above Moderate >120%
Source: Department of Housing and Community Development, 2021 Table A-5 shows the 2021 income limits for these income categories in Alameda County. The above moderate category includes all households earning above the upper limit of the moderateincome category.

Table A-5: Alameda County 2021 Annual Income Limits by Household Size Number of Persons in Household: 1 2 3 4 5 6 7 8
Alameda
County
Area Median Income:
$125,600
Extremely Low 28,800 32,900 37,000 41,100 44,400 47,700 51,000 54,300 Very Low Income 47,950 54,800 61,650 68,500 74,000 79,500 84,950 90,450 Low Income 76,750 87,700 98,650 109,600 118,400 127,150 135,950 144,700 Median Income 87,900 100,500 113,050 125,600 135,650 145,700 155,750 165,800 Moderate Income 105,500 120,550 135,650 150,700 162,750 174,800 186,850 198,900 Source: Department of Housing and Community Development, 2021 Despite the economic and job growth experienced throughout the Region since 1990, the income gap has continued to widen. California is one of the most economically unequal states in the nation, and the Bay Area has the highest income inequality between high- and low-income households in the State.

In Piedmont, 81.1 percent of households make more than 100 percent of AMI, compared to six percent making less than 30 percent of AMI, which is considered extremely low-income (see Figure A-16). Regionally, more than half of all households make more than 100 percent AMI, while 15 percent make less than 30 percent AMI. Of Piedmont’s total households, 13.6 percent are lower income (earning 80 percent of AMI or less), while around 38.5 percent of households in the county and Bay Area are lower income. Many households with multiple wage earners – including food service workers, full-time students, teachers, farmworkers, and healthcare professionals – can fall into lower AMI categories due to relatively stagnant wages in many industries. Examples of occupations in Alameda County where the median wage is less than 80% AMI include, Elementary School Teachers, Middle School Teachers, Child, Family, and School Social Workers and other occupations typically employed by PUSD, the city’s largest employer.

Agenda Report Page 234 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 21 Figure A-16: Households by Household Income Level
Notes:

Universe: Occupied housing units
Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), OaklandFremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. The data that is reported for the Bay Area is not based on a regional AMI but instead refers to the regional total of households in an income group relative to the AMI for the county where that household is located.

Typically, the number of low-income renters greatly outpaces the amount of housing available that is affordable for these households.

In Piedmont, the largest portion of both renters and owners falls in the “Greater than 100 percent of AMI” income group (see Figure A-17). There are no income groups in Piedmont with more renters than owners meaning Piedmont has a higher number of homeowners than renters. 6%
6% 16% 15%
11% 11%
12% 13%
5%
9% 9%
81%
53% 52%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Piedmont Alameda County Bay Area
Percent of Households
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI
81%-100% of AMI Greater than 100% of AMI
Agenda Report Page 235 Attachment 2 Exhibit A
A-22 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-17: Household Income Level by Tenure, City of Piedmont Notes:

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) A.3.4 Special Housing Needs
Large Families
Large households (5 five or more persons) often have different housing needs than smaller households. If a city’s housing stock does not include units with enough bedrooms, large households could end up living in overcrowded conditions and/or overpaying for housing. Of all households in Piedmont, 9.6 percent or 371 households, are considered large households.

As noted in Table A-2, above, a majority (94.9 percent) of large households in Piedmont live in owner -occupied housing. About 10 percent of households in Piedmont are large, 5five or more person households, which is similar to the household composition of the county and the Region (11 percent large households). In 2017, no large households in Piedmont were classified as very low-income, earning less than 50 percent of the area median income (AMIAMI (see Figure A-19).

Furthermore, only 0.1 percent of owner-occupied households are overcrowded (see Section A.3.2 – Overcrowding), indicating overpayment and overcrowding are not an issue for large households in Piedmont.
164
175
50 155
2,890
70 50
25 50
285
0 500
1,000
1,500
2,000
2,500
3,000
3,500
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI 81%-100% of AMI Greater than 100% of AMI
Households
Owner Occupied Renter Occupied
Agenda Report Page 236 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 23 Figure A-18: Household Size by Tenure
Notes:

Universe: Occupied housing units
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25009)
In 2017, no large households in Piedmont were classified as very low-income, earning less than 50 percent of the area median income (AMI (see Figure A-19). Furthermore, only 0.1 percent of owner-occupied households are overcrowded (see Section A.3.2 – Overcrowding), indicating overpayment and overcrowding are not an issue for large households in Piedmont. 16% 24% 25%
32%
30% 32%
42% 34% 33%
10% 11% 11%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Households
1-Person Household 2-Person Household
3-4-Person Household 5-Person or More Household
Agenda Report Page 237 Attachment 2 Exhibit A
A-24 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-19: Household Size by Household Income Level, City of Piedmont The unit sizes available in a community affect the households that can access that community.

Large families are generally served by housing units with 3 three or more bedrooms, of which there are 3,374 units, or 88 percent of all units in Piedmont (see Table A-6). Among these large units with 3 three or more bedrooms, 8.9 percent are renter-occupied, and 91.1 percent are owner-occupied (see Figure A-20). Compared to the number of large households, the housing mix of Piedmont is considered adequate to accommodate larger household sizes. However, the limited supply of rental housing for large families is a constraint which can be partially addressed by the City’s programs to increase housing opportunities in Zones A, B, C, and D, and target housing production.

Table A-6: Housing Units by Number of
Bedrooms, City of Piedmont
Number of Bedrooms Owner Occupied Renter
Occupied
0 Bedrooms 11 0
1 Bedrooms 53 30
2 Bedrooms 236 134
3-4 Bedrooms 2,589 239
5 Or More Bedrooms 484 62
6%
6%
8%
81%
92%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
All other household types Large Families of 5+ Persons
Percent of Households
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI
81%-100% of AMI Greater than 100% of AMI
Agenda Report Page 238 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 25 Table A-6: Housing Units by Number of
Bedrooms, City of Piedmont
Number of Bedrooms Owner Occupied Renter
Occupied
Totals 3,373 465
Source: Department of Housing and Community
Development, 2021
Figure A-20: Housing Units by Number of Bedrooms, City of Piedmont Notes:

Universe: Housing units
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25042)
Senior Households
Senior households often experience a combination of factors that can make accessing or keeping housing affordable a challenge. They frequently live on fixed incomes and are more likely to have disabilities, chronic health conditions, and/or reduced mobility.

Seniors who rent may be at even greater risk for housing challenges than those who own, due to housing cost differences between these groups. In Piedmont, 34 percent of senior renters are extremely low-income (earning 0-30 percent of the AMI), compared to only 5 percent of senior owners. A majority of seniors, both renters and owners, earn more than 100 percent of the AMI (see Figure A-21). However, extremely low- and very low-income seniors (both renters and owners) are more likely to be cost burdened compared to higher earning seniors, with 90 percent of seniors in these income categories overpaying for housing. See Table A-7. 1153236 2,589 484
30 134
239
62 0
500
1,000
1,500
2,000
2,500
3,000
0 Bedrooms 1 Bedrooms 2 Bedrooms 3-4 Bedrooms 5 Or More Bedrooms
Owner Occupied Renter Occupied
Agenda Report Page 239 Attachment 2 Exhibit A
A-26 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Table A-7: Cost-Burdened Senior Households by Income Level, City of Piedmont Income Level 0%-30% of Income Used
for Housing
30%-50% of Income Used
for Housing
50%+ of Income Used for
Housing
0%-30% of AMI 10 0 100
31%-50% of AMI 10 35 60
51%-80% of AMI 25 40 0
81%-100% of AMI 45 55 25
Greater than 100% of
AMI
855 145 4
Totals 945 275 189
Source: ABAG 2021 Pre-certified Housing Needs Data
Figure A-21: Senior Households by Income and Tenure, City of Piedmont Notes:

Universe: Senior households
For the purposes of this graph, senior households are those with a householder who is aged 62 or older. Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose- Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County).

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release) 68%
100%
85%
100% 94%
32%
15% 6%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
0%-30% of AMI 31%-50% of AMI 51%-80% of AMI 81%-100% of AMI Greater than 100% of AMI
Percent of Households
Owner Occupied Renter Occupied
Agenda Report Page 240 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 27 There are no senior living facilities in Piedmont. Given the cost burden experienced most acutely by senior renters, the City has proposed several Housing Element programs which aim to address the needs of renters and senior households and increase the amount of housing which can better serve them. These include:
• Program 2.B (Availability of Small Homes)
• Program 3.F (Incentives for Rent-Restricted ADUs)
• Program 4.Q (Parking Reductions for Persons with Disabilities, Seniors, and Other Housing Types)
• Program 5.A (Shared Housing Publicity and Media Initiative) • Program 5.B (Shared Housing Matching Services)
• Program 5.H (Housing for Extremely Low-Income Individuals and Households) Female-headed Households
Households headed by one person are often at greater risk of housing insecurity, particularly female-headed households, who may be supporting children or a family with only one income. In Piedmont, the largest proportion of households is “Married-couple Family Households” at 73.7 percent of total, followed by “Single person (no children) Households” at 16 percent, while Female-Headed Family Households make up only 5.8 percent of all households (see Figure A22).

Agenda Report Page 241 Attachment 2 Exhibit A
A-28 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Figure A-22: Household Type
Notes:

For data from the Census Bureau, a “family household” is a household where two or more people are related by birth, marriage, or adoption. “Non-family households” are households of one person living alone, as well as households where none of the people are related to each other.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B11001)
Female-headed households with children may face particular housing challenges, with pervasive gender inequality resulting in lower wages for women. Moreover, the added cost and need for childcare can make finding a home that is affordable more challenging.

Of the 212 female-headed households in Piedmont, 92 have children and 9.8 percent of these families fall below the federal poverty line. No female-headed households without children live in poverty (see Figure A-23).
6% 11% 10%
5% 5%
74%
51% 51%
9% 9%
16%
24% 25%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Households
Female-Headed Family Households Male-headed Family Households Married-couple Family Households Other Non-Family Households Single-person Households
Agenda Report Page 242 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 29 Figure A-23: Female-Headed Households by Poverty Status, City of Piedmont Notes:

The Census Bureau uses a federally defined poverty threshold that remains constant throughout the country and does not correspond to Area Median Income.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015- 2019), Table B17012)
There are no housing facilities in Piedmont which serve single parent households specifically, however, to address this population the City targets housing production, increasing housing affordability, and allowing more ADUs with more than one bedroom. To assist the handful of female-headed households with children that are living below the poverty level in Piedmont, the following Housing Element programs are proposed:
• Program 5.I (Housing for Extremely Low-Income Families) • Program 1.B: Market-Rate Accessory Dwelling Units
• Program 1.E: Require ADUs for New Single-Family Residence Construction • Program 1.M: Manufactured and Mobile Home
• Program 3.B: Increase Number of Legal Accessory Dwelling Units • Program 3.C: Monitoring Accessory Dwelling Unit Missed Opportunities • Program 3.D: Monitoring Additional ADU Development Opportunities • Program 3.E: Affordable Housing Fund
• Program 3.F: Incentives for Rent-Restricted ADUs
• Program 3.H: Monitor ADU Occupancy/Affordability
Persons with Disabilities
Persons with disabilities face additional housing challenges. Encompassing a broad group of individuals living with a variety of physical, cognitive and sensory impairments, many people with 83 129
9 0
20 40
60 80
100
120
140
With Children With No Children
Households
Above Poverty Level Below Poverty Level
Agenda Report Page 243 Attachment 2 Exhibit A
A-30 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment disabilities live on fixed incomes and are in need of specialized care, yet often rely on family members for assistance due to the high cost of care.

When it comes to housing, people with disabilities are not only in need of affordable housing but accessibly designed housing, which offers greater mobility and opportunity for independence.

Unfortunately, the need typically outweighs what is available, particularly in a housing market with such high demand. People with disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they lose caregivers (such as parents or family members) due to aging. Figure A-24 shows the rates at which different disabilities are present among residents of Piedmont. Overall, 808 persons, or 7.1 percent of people in Piedmont, have a disability of any kind.

State law also requires Housing Elements to examine the housing needs of people with developmental disabilities. Developmental disabilities are defined as severe, chronic, and attributed to a mental or physical impairment that begins before a person turns 18 years old. This can include Down’s Syndrome, autism, epilepsy, cerebral palsy, and mild to severe mental retardation. Some people with developmental disabilities are unable to work, rely on Supplemental Security Income, and live with family members. In addition to their specific housing needs, they are at increased risk of housing insecurity after an aging parent or family member is no longer able to care for them.

Figure A-24: Disability by Type, City of Piedmont
Notes:

Universe: Civilian noninstitutionalized population 18 years and over These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed. The Census Bureau provides the following definitions for these disability types: Hearing difficulty: deaf or has serious difficulty hearing. Vision difficulty: blind or has serious difficulty seeing even with glasses. Cognitive difficulty: has serious difficulty concentrating, remembering, or making decisions. Ambulatory difficulty: has serious difficulty walking or climbing stairs. Self-care difficulty: has difficulty

3.43%

2.93%

2.61%

2.12%

1.58%

1.26%

0.00%

0.50%

1.00%

1.50%

2.00%

2.50%

3.00%

3.50%

4.00%
With a hearing
difficulty
With an
independent
living difficulty
With an
ambulatory
difficulty
With a
cognitive
difficulty
With a selfcare difficultyWith a vision
difficulty
Proportion of Adult Population
Reporting Disability Type
Agenda Report Page 244 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 31 dressing or bathing. Independent living difficulty: has difficulty doing errands alone such as visiting a doctor’s office or shopping.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B18102, Table B18103, Table B18104, Table B18105, Table B18106, Table B18107) In Piedmont, of the 43 people with a developmental disability, children under the age of 18, make up 51.2 percent, while adults account for 48.8 percent (Ssee Table A-8). The most common living arrangement for individuals with developmental disabilities in Piedmont is the home of a parent, family member, or guardian. (Ssee Table A-9).

Table A-8: Population with Developmental Disabilities by Age, City of Piedmont Age Group Number of People with a Developmental Disability Age Under 18 22
Age 18+ 21
Notes:

Universe: Population with developmental disabilities
The California Department of Developmental Services is responsible for overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were crosswalked to jurisdictions using census block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.

Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Developmental Services, Consumer Count by California ZIP Code and Age Group (2020)) Table A-9: Population with Developmental Disabilities by Residence, City of Piedmont Residence Type Number of People with a Developmental Disability Home of Parent/Family/Guardian 34
Independent/Supported Living 4
Community Care Facility 3
Other 2
Foster/Family Home 1
Intermediate Care Facility 0
Notes:

The California Department of Developmental Services is responsible for overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were crosswalked to jurisdictions using census block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.

Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2020)) There are no care facilities for persons with disabilities in Piedmont. Because persons with disabilities may experience additional challenges finding appropriate housing and related care, persons with disabilities are the target of several Housing Element programs, including:

Agenda Report Page 245 Attachment 2 Exhibit A
A-32 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment • Program 4.N (Allow Transitional and Supportive Housing By-Right in Zones that Allow Residential Uses)
• Program 4.P (Residential Care Facilities)
• Program 4.Q (Parking Reductions for Persons with Disabilities, Seniors, and Other Housing Types)
• Program 5.D (Accommodations for Disabled Persons)
• Program 5.J (Developmentally Disabled Residents)
• Program 5.L (Definition of Family)
Residents Living Below the Poverty Level
The federal poverty level is an estimate of the minimum annual income a household would need to pay for essentials, such as food, housing, clothes, and transportation. This level considers the number of people in a household, their income, and the State in which they live. In Piedmont, 2.4 percent of the total population (275 people) experience poverty, a significant number, but and less than half the rate of poverty compared to Alameda County residents (9.9 percent).

Table A-10: Poverty Status
Piedmont Alameda County
% of Population Below Poverty Level 2.4% 9.9%
Source: ACS 5-year estimates (2019), S1701
As mentioned above, female-headed households with children experience poverty at a disproportionate rate than those without children or the overall population, with 9.8 percent of female-headed households with children living below the federal poverty level in Piedmont.

Currently, People of Color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to white White residents. These economic disparities also leave communities of color at higher risk for housing insecurity, displacement, or homelessness. In Piedmont, Hispanic or Latino residents experience the highest rates of poverty, followed by Asian/Asian Pacific Islander (Hispanic and Non-Hispanic) (see Figure A-25).

Agenda Report Page 246 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 33 Figure A-25: Poverty Status by Race, City of Piedmont
Notes:

Universe: Population for whom poverty status is determined The Census Bureau uses a federally defined poverty threshold that remains constant throughout the country and does not correspond to Area Median Income. For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latino ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latino. Since residents who identify as white and Hispanic/Latino may have very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latino, data for multiple white sub-groups are reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the population for whom poverty status is determined for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the population for whom poverty status is determined.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17001(A-I))
Given the disproportionate housing cost burden experienced by lower-income households in Piedmont, the following Housing Element programs are designed to support them:
• Program 2.B (Availability of Small Homes)
• Program 3.A (Affordable Accessory Dwelling Unit Public Information Campaign) • Program 3.E (Affordable Housing Fund)
• Program 3.F (Incentives for Rent-Restricted ADUs)
• Program 3.G (Inclusionary Housing)
• Program 4.L (Allow Parking Reductions for Multi-Family, Mixed-Use, and Affordable Projects)
• Program 4.S (Prioritize Sewer Hookups for Residential Development for Lower-Income Housing)
• Program 5.A (Shared Housing Publicity and Media Initiative) • Program 5.B (Shared Housing Matching Services)

7.0%

4.1%

2.2% 1.9%

1.3%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%
Hispanic or
Latinx
Asian / API
(Hispanic and
Non-Hispanic)
White (Hispanic
and NonHispanic)
White, NonHispanicOther Race or
Multiple Races
(Hispanic and
Non-Hispanic)
Black or African
American
(Hispanic and
Non-Hispanic)
American Indian
or Alaska Native
(Hispanic and
Non-Hispanic)
Percent of Households in Racial /
Ethnic Group
Agenda Report Page 247 Attachment 2 Exhibit A
A-34 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment • Program 5.C (Assistance to Nonprofit Developers)
• Program 5.H (Housing for Extremely Low-Income Individuals and Households) • Program 5.I (Housing for Extremely Low-Income Families) • Program 5.K (Transitional and Supportive Housing for Extremely Low-Income Residents) Farmworkers
Across the State, housing for farmworkers has been recognized as an important and unique concern. Agriculture remains an important economic engine as well as a sector that employed many low wage workers. Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary and changing housing needs. Finding decent and affordable housing can be challenging, particularly in the current housing market. Over the past two decades, there has been a shift to a more permanent workforce for many farms, which has shifted the bulk of the housing need from seasonal housing for migrant workers to permanently affordable housing for low wage working families. Because of the nature of housing is no longer solely a rural issue.

Farmworker populations have declined while at the same time trends for farmworkers have resulted in longer commutes (75 miles on average per the USDA) for this population.

As a result, there is not an explicit need for housing for farmworkers and their families. Other housing types promoted in the Housing Element, such as housing for low-income households and multi-family housing, can also serve farmworkers.

In Piedmont, there were no reported students of migrant workers in the 2019-20 school year. The trend for the Region for the past few years has been an overall decline of 2.4 percent in the number of migrant worker students since the 2016-17 school year. The change at the county level is a 9.6 percent decrease in the number of migrant worker students since the 2016-17 school year. (Ssee Table A-11).

According to the U.S. Department of Agriculture Census of Farmworkers, the number of permanent farm workers in Alameda County has decreased since 2002, totaling 305 in 2017. The number of seasonal farm workers has also decreased, totaling 288 in 2017 (see Figure A-26).

Table A-11: Migrant Worker Student Population
Academic Year Piedmont Alameda County Bay Area
2016-17 0 874 4,630
2017-18 0 1,037 4,607
2018-19 0 785 4,075
2019-20 0 790 3,976
Notes:

Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public schools
The data used for this table was obtained at the school site level, matched to a file containing school locations, geocoded and assigned to jurisdiction, and finally summarized by geography.

Agenda Report Page 248 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 35 Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019- 2020))
Figure A-26: Farm Operations and Farm Labor by County, Alameda County Notes:

Universe: Hired farm workers (including direct hires and agricultural service workers who are often hired through labor contractors) Farm workers are considered seasonal if they work on a farm less than 150 days in a year, while farm workers who work on a farm more than 150 days are considered to be permanent workers for that farm.

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Agriculture, Census of Farmworkers (2002, 2007, 2012, 2017), Table 7: Hired Farm Labor)
People Experiencing Homelessness
Homelessness remains an urgent challenge in many communities across California, reflecting a range of social, economic, and psychological factors. The Bay Area has some of the highest housing costs in the world, and an increasing number of low-income residents experiencing housing insecurity have found themselves unhoused as a result, either temporarily or long-term.

Rising housing costs result in increased risks of community members experiencing homelessness.

Far too many residents who have found themselves housing insecure have ended up unhoused or homeless in recent years, either temporarily or longer term. Addressing the specific housing needs for the unhoused population remains a priority throughout the Region, particularly since homelessness is disproportionately experienced by People of Color, people with disabilities, those struggling with addiction, and those dealing with traumatic life circumstances.

The Alameda County Point-in-Time (PIT) Count is a census and survey that identifies the sheltered and unsheltered homeless population. While the PIT Count is normally conducted every two years, the 2021 count was delayed to 2022 due to the COVID-19 pandemic. The 2022 PIT Count was conducted on February 22, 2022. Between 2019 and 2022, Alameda County saw a 22 percent increase in overall homelessness, , growing from 8,022 individuals in 2019 to 9,747 individuals in 2022 , and a 53 percent increase in the unhoused population, (see Table A-12). 577
369
465
737
355
449
305 288
0 100
200
300
400
500
600
700
800
Permanent Seasonal
Farm Workers
2002 2007 2012 2017
Agenda Report Page 249 Attachment 2 Exhibit A
A-36 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Of the 8,022 reported homeless persons in Alameda County, the majority of persons experiencing homelessness are households without children in their care, and an overwhelming majority of those (6,276, or 84 percent) are unsheltered. Of homeless households with children, 497 are sheltered in emergency shelter or transitional housing (see Table A-12).

Table A-12: Homelessness by Shelter Status and Subpopulation, Alameda County 2019 2022 Percent Change
Shelter Status
Sheltered 6,312 7,135 +13%
Unsheltered 1,710 2,612 +53%
Total 8,022 9,747 +22%
Subpopulation
Persons in Families with Children 524 844 +61%
Unaccompanied Children and Transition-Age Youth 731 832 +14% Chronically Homeless 2,236 2,728 +22%
Veterans 692 550 -21%
Adults with Serious Mental Illness 2,590 2,348 -9%
Adults with HIV/AIDS 207 98 -53%
This data is based on PIT information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during.

Source: 2022 Alameda County Homeless Count and Survey Comprehensive Report Table A-12: Homelessness by Household Type and Shelter Status, Alameda County Variable
People in Households
Composed Solely of
Children Under 18
People in Households
with Adults and Children
People in Households
without Children Under 18
Sheltered – Emergency
Shelter 16 322 825
Sheltered – Transitional
Housing 4 175 368
Unsheltered 9 27 6,276
Totals 29 524 7,469
This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January.

Each Bay Area county is its own CoC, and so the data for this table is provided at the county-level.

Per HCD's requirements, jurisdictions will need to supplement this county-level data with local estimates of people experiencing homelessness.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019)
Agenda Report Page 250 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 37 The PIT count also includes a breakdown of the homeless population by jurisdiction. No unsheltered individuals were recorded as living in Piedmont in 2017 or 2019. In 2022, 42 unsheltered homeless individuals were recorded in the City, representing less than one percent of unsheltered individuals in Alameda County. Broken down by location, four (10 percent) were living in a tent, nine (21 percent) in a car/van, 14 (33 percent) in an RV, and 15 (36 percent) on the street/outside.

As noted above, People of Color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to white residents. Consequently, People of Color are often disproportionately impacted by homelessness, particularly Black residents of the Bay Area.

In Alameda County, Black or African-AmericanAfrican American (Hispanic and Non-Hispanic) residents represent the largest proportion of residents experiencing homelessness and account for 47.3 percent of the homeless population, while only making up 10.6 percent of the overall population (see Figure A-27).

Figure A-27: Racial Group Share of General and Homeless Populations, Alameda County Notes:

Universe: Population experiencing homelessness
This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten 3.8% 3.2% 47.3% 31.4% 14.4% 0.7% 31.0% 10.6% 40.5% 17.3% 0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
American Indian or
Alaska Native
(Hispanic and NonHispanic)
Asian / API
(Hispanic and NonHispanic)
Black or African
American
(Hispanic and NonHispanic)
White (Hispanic
and Non-Hispanic)
Other Race or
Multiple Races
(Hispanic and NonHispanic)
Percent of Population
Share of Homeless Population Share of Overall Population Agenda Report Page 251 Attachment 2 Exhibit A
A-38 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment days in January. Each Bay Area county is its own CoC, and so the data for this table is provided at the county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people experiencing homelessness. HUD does not disaggregate racial demographic data by Hispanic/Latino ethnicity for people experiencing homelessness. Instead, HUD reports data on Hispanic/Latino ethnicity for people experiencing homelessness in a separate table.

Accordingly, the racial group data listed here includes both Hispanic/Latino and non-Hispanic/Latino individuals.

Figure A-28: Latino Share of General and Homeless Populations, Alameda County Notes:

Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I)) Many of those experiencing homelessness are dealing with severe health and safety issues – including mental illness, substance abuse, and domestic violence – that are potentially life threatening and require additional assistance. In Alameda County, homeless individuals are commonly challenged by severe mental illness, with 2,590 reporting this condition (see Figure A29). Of those, 78.3 percent are unsheltered, further adding to the challenge of supporting these individuals as it may be difficult to provide regular care or access to vital services.

17.3%

82.7%

22.5%

77.5%
0%
20%
40%
60%
80%
100%
Hispanic/Latinx Non-Hispanic/Latinx
Percent of Population
Share of Homeless Population Share of Overall Population Agenda Report Page 252 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 39 Figure A-29: Characteristics for the Population Experiencing Homelessness, Alameda County Notes:

By comparison, Alameda County has seen a 18.7 percent decrease in the population of students experiencing homelessness since the 2016-17 school year, and the Bay Area population of students experiencing homelessness decreased by 8.5 percent. During the 2019-2020 school year, there were still 13,718 students experiencing homelessness throughout the Region, adding undue burdens on learning and thriving, with the potential for longer term negative effects.

Table A-13: Students in Local Public Schools Experiencing Homelessness Academic Year Piedmont Alameda County Bay Area
2016-17 0 3,531 14,990
2017-18 0 3,309 15,142
2018-19 0 3,182 15,427
2019-20 0 2,870 13,718
Notes:

Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public schools
The California Department of Education considers students to be homeless if they are unsheltered, living in temporary shelters for people experiencing homelessness, living in hotels/motels, or temporarily doubled up and sharing the housing of other persons due to the loss of housing or economic hardship. The data used for this table was obtained at the school site level, matched to a file containing school locations, geocoded and assigned to jurisdiction, and finally summarized by geography.

Source: ABAG 2021 Pre-certified Housing Needs Data (California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019- 2020))
253 90
1,554
27 11 169
368
195
2,027
39 108
545
90 32
385
0 500
1,000
1,500
2,000
2,500
Sheltered - Emergency Shelter Sheltered - Transitional Housing Unsheltered Chronic Substance Abuse HIV/AIDS Severely Mentally Ill
Veterans Victims of Domestic Violence
Agenda Report Page 253 Attachment 2 Exhibit A
A-40 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment Emergency Shelters/Transitional Housing
At this time, there are currently no emergency shelters or shelters for domestic violence victims located in Piedmont. The Constraints analysis (Appendix C)Appendix C (Housing Constraints) describes how the City regulates emergency shelters and transitional and supportive housing.

Resources for People Experiencing Homelessness
The Alameda County Continuum of Care (CoC), whose lead agency is EveryOne Home, is a network of private and public sector homeless service providers, designed to promote communitywide planning and the strategic use of resources to address homelessness. EveryOne Home manages the county’s coordinated entry service to ensure equitable access to services for persons experiencing homelessness. The CoC seeks to improve access to and effect utilization of mainstream programs by people who are experiencing or are at-risk of becoming homeless.

These services include emergency shelters, transitional and permanent housing, homeless prevention rental assistance, and general wraparound supportive services. Additionally, the CoC seeks to improve and expand the collection of data across the county, develops performance measurements, and allows for each community to tailor its program to the particular strengths and challenges within that community.

To address the growing need for housing and services to support homeless individuals in Piedmont, the following Housing Element programs are proposed:
• Program 4.N (Allow Transitional and Supportive Housing by Right in Zones that Allow Residential Uses)
• Program 4.O (Allow Low Barrier Navigation Centers by Right in Zones that Allow Residential Uses)
• Program 4.T (Establish Standards for Emergency Shelters) • Program 4.V (Emergency Shelters as an Accessory Use)
• Program 5.E (Housing Support for Families in Crisis)
• Program 5.F (EveryOne Home)
• Program 5.H (Housing for Extremely Low-Income Individuals and Households) • Program 5.I (Housing for Extremely Low-Income Families) • Program 5.K (Transitional and Supportive Housing for Extremely Low-Income Residents) Agenda Report Page 254 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 41 Non-English Speakers
California adopted a bilingual state constitution in 18493 and has long been an immigration gateway to the United States, which means that many languages are spoken throughout the Bay Area. Since learning a new language is universally challenging, it is not uncommon for residents who have immigrated to the United States to have limited English proficiency. This limit can lead to additional disparities if there is a disruption in housing, such as an eviction, because residents might not be aware of their rights or they might be wary to engage due to immigration status concerns.

In Piedmont, 0.8 percent of residents 5 years and older identify as speaking English not well or not at all, which is below the proportion for Alameda County. Throughout the Region the proportion of residents 5 years and older with limited English proficiency is 8 percent.

Figure A-30: English Proficiency—Population Over Five Years of Age Notes:

Universe: Population 5 years and over
Source: ABAG 2021 Pre-certified Housing Needs Data (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B16005)
3 The provision for bilingual publication of laws, decrees and regulations was removed in the subsequent California Constitution of 1878
8% 8%
99% 92% 92%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Piedmont Alameda County Bay Area
Percent of Population aged 5 and over
Population 5 Years and Over Who Speak English "Well" or "Very well" Population 5 Years and Over Who Speak English "Not well" or "Not at all" Agenda Report Page 255 Attachment 2 Exhibit A
A-42 | City of Piedmont Appendix A: Demographics and Housing Needs Assessment A.3.5 Displacement
Because of increasing housing prices, displacement is a major concern in the Bay Area.

Displacement, also called “gentrification”, has the most severe impacts on low- and moderateincome residents. When individuals or families are forced to leave their homes and communities, they also lose their support network.

The University of California, Berkeley has mapped all neighborhoods in the Bay Area, identifying their risk for displacement. They find that in Piedmont, no households live in neighborhoods that are susceptible to or experiencing displacement and none live in neighborhoods at risk of or undergoing gentrification.

Equally important, some neighborhoods in the Bay Area do not have housing appropriate for a broad section of the workforce. UC Berkeley estimates that 100.0 percent of households in Piedmont live in neighborhoods where low-income households are likely to be excluded due to prohibitive housing costs.

Figure A-31: Households by Displacement Risk and Tenure, City of Piedmont Notes:

Universe: Households
Displacement data is available at the census tract level. Staff aggregated tracts up to jurisdiction level using census 2010 population weights, assigning a tract to jurisdiction in proportion to block level population weights. Total household count may differ slightly from counts in other tables sourced from jurisdiction level sources. Categories are combined as follows for simplicity: At risk of or Experiencing Exclusion: At Risk of Becoming Exclusive; Becoming Exclusive; Stable/Advanced Exclusive At risk of or Experiencing Gentrification: At Risk of Gentrification; Early/Ongoing Gentrification; Advanced Gentrification Stable Moderate/Mixed Income: Stable Moderate/Mixed Income Susceptible to or Experiencing Displacement: Low- Income/Susceptible to Displacement; Ongoing Displacement Other: High Student Population; Unavailable or Unreliable Data.

Source: ABAG 2021 Pre-certified Housing Needs Data (Urban Displacement Project for classification, American Community Survey 5-Year Data (2015-2019), Table B25003 for tenure) 3,377
465
0 500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
Susceptible to or
Experiencing
Displacement
At risk of or
Experiencing
Gentrification
Stable
Moderate/Mixed
Income
At risk of or
Experiencing
Exclusion
Other
Households
Owner Occupied Renter Occupied
Agenda Report Page 256 Attachment 2 Exhibit A
Appendix A: Demographics and Housing Needs Assessment City of Piedmont |A- 43 Section A.4 Housing Stock Characteristics
A.4.1 Housing Type and Vacancy
In recent years, most housing produced in the Region and across the State consisted of singlefamily homes and larger multi-unit buildings. However, some households are increasingly interested in “missing middle housing” – including duplexes, triplexes, townhomes, cottage clusters and accessory dwelling units (ADUs). These housing types may open up more options across incomes and tenure, from young households seeking homeownership options to seniors looking to downsize and age-in-place.

The housing stock of Piedmont in 2020 was made up of 93.3 percent single-family detached homes, 1.7 percent single family attached homes, 2.9 percent multifamily homes with 2 to 4 units,

2.0 percent multifamily homes with 5 or more units, and no mobile homes.

Table A-14: Housing Type Trends, City of Piedmont
2010 2020 Change (in Units) % Change
Single-Family Home:

Piedmont City CouncilMarch 20, 2023

Piedmont City Council
March 20, 2023