South Sac Habitat Conservation Plan – Final Comments from ECOS

What is the South Sac Habitat Conservation Plan?

Comments from ECOS

September 5, 2017

Attention: Rich Radmacher, Senior Planner
Sacramento County Planning Department
827 7th Street, Sacramento, CA 95814

Delivered via email to: radmacherr [at] saccounty [dot] net

These comments on the public draft of the South Sacramento Habitat Conservation Plan are presented on behalf of the Environmental Council of Sacramento (ECOS), Habitat 2020, the Sierra Club, the Institute for Ecological Health, and Save Our Sandhill Cranes.

Issues addressed by these comments include:

  • long-term sustainability of vernal pool resources in our region
  • agricultural-residential development
  • effects of pesticide use on agricultural preserve lands
  • effects of artifical lighting on species covered by the plan, as well as the insect prey of those species
  • effects of rodenticides on various species
  • better monitoring of how species are doing
  • avoidance and minimization measures
  • available inventory (in acres) remaining for each cover type/habitat type in the Plan Area
  • the regular review of relevant new scientific studies and reports for applicability in Preserve management

Animals of special concern include:

  • various local species of raptors (birds of prey) including the Burrowing Owl, the White Tailed Kite and the Swainson’s Hawk
  • the American Badger
  • the Loggerhead Shrike (a “songbird with a raptor’s habits”)
  • the Greater Sandhill Crane (which has one of the longest fossil histories of any bird still in existence)
  • the Tricolored Blackbird
  • the Western Red Bat

Read Our Comments

Click here to read the full comment letter.

Corresponding Addendum to our letter:

Addendum 1- 3

Addendum 4

Addendum 5, Part 1

Addendum 5, Part 2

Addendum 5, Part 3

More Resources

Click here to learn more about the South Sacramento Habitat Conservation Plan

Click here for a glossary of terms used in and in relation to the South Sacramento Habitat Conservation Plan

Click here to learn more about the Sandhill Crane

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Kammerer/Highway 99
 Sphere Of Influence Amendment DREIR

On September 11, 2017, ECOS submitted our comments on the Draft Recirculated Environmental Impact Report (DREIR) for the Proposed Kammerer/Highway 99
 Sphere Of Influence Amendment (SOIA) Application for the City of Elk Grove.

Click here or on the image above to read the comment letter.

Summary

We appreciate the added attention to detail offered in the recirculated draft EIR, but rather than alleviate our concerns expressed in our original letter, the DREIR only further confirms those concerns. ECOS remains strongly opposed to the proposed Kammerer-99 Elk Grove SOI expansion and stands by our initial observation summarizing the project: Elk Grove’s anticipated growth can be accommodated within the existing City limits, and we find no justification for expansion beyond the Sacramento County Urban Services Boundary (USB) established in1993 to be the ultimate growth boundary within the County. The proposal is inconsistent with the Sacramento Area Council of Governments’ (SACOG) Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) for meeting State mandated greenhouse gas (GHG) reductions, Federal mandates for Air Quality Attainment under the State Improvement Plan (SIP), as well as myriad regional goals for social equity, public health and natural resource conservation. There is an extreme lack of certainty that municipal water can be provided to this area without severe regional impacts, and the impacts to invaluable agricultural and biological resources by the proposal are potentially impossible to mitigate. The RDEIR confirms significant and unavoidable impacts in all these above-mentioned areas, with the exception of less than significant biological impact after mitigation which is a finding we disagree with. The question is, what justification is there for these impacts? We, again, find that there is not, and we strongly recommend that LAFCo decline the proposed Kammerer/99 SOIA.

Click here to read our comment letter to the Draft Environmental Impact Report, submitted March 31, 2017, which is referenced in our letter.

Click here for the Friends of Swainson’s Hawk’s comment letter on the Draft Recirculated Environmental Impact Report, submitted September 11, 2017, which is also referenced in our letter.

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