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.
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.
July 28, 2017
The Environmental Council of Sacramento, along with Organize Sacramento, the Sacramento Housing Alliance, the Planning and Conservation League, Mogavero Architects, 350 Sacramento and the California Bicycle Coalition submitted our collective comments on the recent update to SB 375, The Sustainable Communities and Climate Protection Act of 2008. Below are our opening comments, with a link to the letter in full.
Dear Chair Nichols, Air Resources Board Members, and Staff:
In 2004, the Sacramento Area Council of Governments (SACOG) adopted the Blueprint. This plan provided vision for how the region would integrate land use and transportation planning to curb sprawl, reduce vehicle emissions, and cut down on traffic congestion to improve quality of life. This is to be accomplished by encouraging a sufficient variety housing options close to jobs, schools, and other critical community amenities. The adoption of the Blueprint—and subsequent Metropolitan Transportation Plans/Sustainable Communities Strategies (MTPs/SCSs)—has made SACOG a leader in the state and the nation in its efforts to reduce greenhouse gas emissions (GHG) and vehicle miles traveled (VMT), and build more equitable communities.
While we support the recently adopted MTP/SCS, we also believe there is tremendous room to improve the plan. We believe that neither the SB 375 target recommendations made by SACOG staff (-18%) or Air Resources Board (ARB) staff (-19%) represent the full GHG reduction potential from improved land use and transportation behavior in the Sacramento region. Considering the substantial amount of greenfield development anticipated in the current SACOG MTP/SCS and the extremely low densities of the existing urban footprint, we feel that a stronger GHG reduction target is very feasible.
Photo: Smog over LA – is this what we want for the Sacramento region?