Sent via email
From: Ralph Propper, Environmental Council of Sacramento
Sent: Apr 3, 2019 5:06 PM
To: James Corless, Sacramento Area Council of Governments
Cc: Christina Lokke, Sacramento Area Council of Governments
Subject: ECOS support letter to legislature for “Green Means Go”
The Environmental Council of Sacramento (ECOS) wants to send a support letter to the Legislature requesting $400M funding for SACOG’s Infill Pilot, “Green Means Go”. We support the intent of your request, but we are concerned about lack of specificity regarding how SACOG would use these funds. We would like clarification included in any budget proposal to reflect the following recommendations; your clarification would enable us to send a support letter.
Infill Siting Criteria
We recommend that sites be surrounded by at least 75% existing urban uses, and the remainder be previous urban uses. This is consistent with SB 375’s infill definition, and our region has sufficient potential to meet these criteria.
VMT Performance Criteria
We recommend using OPR’s SB 743 Technical Advisory of -15% of regional average VMT for land use projects, and no net per capita VMT increase for transportation projects/infrastructure upgrades, as the guiding performance criteria for these projects. These should be the primary goals of the infill pilot, and OPR’s recommendation should be the standard for such incentive projects to meet the identified need in CARB’s GHG Scoping Plan for improved land use to meet climate goals. Accounting for project VMT in the pilot would also serve as a model for SB 743 implementation in our region, and begin to build an inventory of VMT-reducing projects for future VMT mitigation.
We recommend a requirement that 10% of housing in an applicable project should be affordable to “low income”residents, an additional 5% should be affordable to “very low income”, and no in-lieu fee option should be available in low-VMT and Transit Oriented Development areas. This is consistent with requirements in SB 35 and other recent legislation.
Displacement of low-income residents is the greatest risk from the infill investment we need to meet our climate goals, so these investments must be coupled with protections against their displacement. Therefore, we recommend no demolition of existing affordable housing, rental housing, or any housing that was subsidized for affordable or rental housing in the last 10 years, consistent with language in recent legislation, e.g., SB 35, SB 50. Although an MPO cannot require anti-displacement mechanisms (e.g., rent control, just-cause eviction, no-net loss, right of first return), a jurisdiction’s no-demolition policy should be considered in scoring criteria for project selection. Prioritizing existing underutilized commercial zoning (e.g., parking lots) in project selection offers densification potential and avoids the direct displacement of housing.
In conclusion, we believe that VMT-reducing projects should be a priority if funding is provided. Thank you for considering these recommendations, and we look forward to working with you to identify appropriate criteria for projects applicable to this proposal.
Ralph Propper, ECOS President
cc: Christina Lokke