19j

ECOS Comments on 19J Project

September 5, 2016

ECOS supports the 19J project particularly for its sustainability and “affordable by design” features. We find the urban design features, building scale and location to have an approach consistent with the intent of the City General Plan, despite its modest height increase beyond the Plan’s approved limits. We recommend approval of the project, but strongly recommend that three conditions be applied to its approval.

  1. A deed restriction shall be recorded whereby the rental cost of the 300 to 445 square foot units shall not exceed 30% of Sacramento’s median income.
  2. A deed restriction shall also be recorded stating that no units shall be sold for 15 years from the date of initial occupancy.
  3. Approval of the project shall require that the project owner/operators submit an annual report to the Planning Department verifying compliance with conditions 1 & 2 above.

We believe that in order to maintain the integrity of the project, these conditions must be applied.

View our letter here.

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ECOS endorsement of Alternative F location selection for the Wilton Rancheria project

August 25, 2016

We were pleased that in subsequent months the Wilton Rancheria tribe has selected Elk Grove as the primary choice for location of their project.  On August 4th, the members of the leadership of ECOS met and discussed the project with the Wilton Rancheria tribal chairman Raymond Hitchcock. The discussion included an update on the project as well as the concerns that were substantially avoided by the selection of Alternate F site for the project.

We would like to reiterate our support for the selection of Alternate F as the site for the Wilton Rancheria project and would like to continue to work with the tribe regarding future environmental concerns and impacts. We are hopeful that the Wilton Rancheria, in recognizing that the casino project will still have a role in stimulating expansive Elk Grove urban growth, will join with us in efforts to protect and restore important wildlife habitat in the ancestral lands of the Plains Miwok along the lower Cosumnes River and the Stone Lakes complex.

View our letter here.

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ECOS Comments on Sacramento Railyards Specific Plan Update, KP Medical Center, MLS Stadium, & Stormwater Outfall SEIR

July 27, 2016

These are comments from the Environmental Council of Sacramento (ECOS), with dozens of individual members and organizational members in the tens of thousands. ECOS has a history of over 4 decades of advocacy to limit sprawl, preserve agriculture, habitat and open space, and improve the quality of life while supporting growth with a vibrant and equitable economy.

Alternatives to the Proposed Projects

The glaring deficiency in this SEIR is the lack of an Increased Density/Intensity Alternative.

Land Use, Transportation, Air Quality, Climate Change

ECOS believes that the requested zoning should include a minimum as well as a maximum number of housing units. Virtually all of the mitigations for Transportation, Air Quality and Climate change involve the enrichment of alternatives to automobile travel to, from and within the project. Other than automobile travel, all the other modes of transportation benefit from higher densities and more residential development, irrespective of the correction of any jobs/housing mismatch. Furthermore, the expensive infrastructure improvements necessitated by the project will not be as efficient at the proposed densities as they would at increased densities.

The addition of the Kaiser Permanente Medical Center (KP) provides ample basis on which to create plans for all-income housing development that would be synchronized with the creation of jobs in the project. Projects of this nature often favor early scheduling of commercial development, followed later, much later or never, by commensurate housing development. This pattern fosters the creation of undesirable patterns of housing, transportation, land speculation and delayed creation of public amenities that collectively depress the success of the integrated and holistic downtown desired by the City and by ECOS. An employer like KP includes one of the widest ranges of salaries imaginable, from low-skilled to some of the highest-skilled in society today. Of all the ways to bring a wide variety of income levels to the project, this has to be one of the most effective. This is an opportunity that should not be squandered by timidity.

At its current capacity for growth, RT is struggling to figure out how to keep up with the proposed growth in the region. Much of this struggle is exacerbated by the relatively timid densities being proposed, including this project. As is often proposed as part of other projects in the region, ECOS would like to see the development of an aggressive Transportation Services District as part of this project. We believe that a fee assessment on a dwelling unit equivalent basis would provide support to RT, or a private shuttle provider, as well as support the functions of the Transportation Management Association.

A further boon to the mode share for RT for trips to, from and within the project would result from a program to make every ticket sold for an event at large venues in the project (e.g., the soccer stadium, major events in public spaces at the Railroad Museum, etc.) also serve as a day pass for unlimited rides on RT. We understand this is being considered by the Golden 1 Center and should also be a part of this project.

To this end the following mitigation steps are presented:

  1. Establish a minimum residential density, say 75% of zoned maximum density, for buildout of the residential and mixed use zones
  2. Require project phasing that requires timely construction of housing units in conjunction with construction of employment producing development
  3. Require establishment of a fee assessment on a dwelling unit equivalent basis to provide enhanced transit support as recommended above
  4. Require that agreements are in place prior to building permit approval that enable all tickets sold at large venues within the project area to be used as transit day passes.

Growth-inducing Effects

For this project, ECOS has no qualms about inducing growth in the vicinity of the project. In fact, the more growth induced near the project, the better. We believe the developers and the City agree with us. All the more reason why there should be a robust Increased Density/Intensity Alternative.

Conclusion

The efficacy of an Increased Density/Intensity Alternative should not be underestimated. A vast array of desirable outcomes accompanies higher densities than are proposed by the project, a location already zoned for the highest densities in the City, but one that could be painfully underutilized by the project as proposed. Smart growth is most successfully enabled when the residential and transportation infrastructure development occur prior to the successive stages of build-out, and thereby structure and guide them. Without this, we will suffer from substantial pressure to put these essential features in parts of the City that are not currently zoned for them, further weakening the excellent General Plan.

Sincerely,

Alex Kelter MD, Co-Chair

Land Use Committee

Environmental Council of Sacramento (ECOS)

Click here to see the letter in PDF.