On September 1, 2020, the Environmental Council of Sacramento (ECOS) submitted comments on the NewBridge Specific Plan and Final Environmental Impact Report (FEIR), dated Aug. 21, 2020.
Below is an excerpt from our comment letter.
CONSISTENCY: The Jackson Corridor projects should be treated consistently in terms of the County’s requirements for project approval. The requirement to meet state mandated greenhouse gas (GHG) emissions reductions targets is a particularly important one. Mather South demonstrated that it met state mandated GHG emissions reductions targets in the Climate Change chapter of its Specific Plan/FEIR. By contrast, the NewBridge FEIR currently calls for a demonstration of adequate emission reductions at the time of tentative map approval.
Close scrutiny of the project by the public and yourselves as County leaders occurs at FEIR approval. We ask that the NewBridge FEIR be modified prior to your approval to ensure GHG thresholds are met and the project’s impact is reduced to a “less than significant level.”
Mather South’s FEIR, CC-2 measures (GHG-reducing measures) are named and quantified: EV Charging and 100 Percent Solar on All Nonresidential Buildings and Residential Buildings. In addition, the CC-3 measure for purchase of carbon offsets is described and quantified. The NewBridge FEIR simply lists the CC-2 measures as a menu to be selected at tentative map approval. No quantification is provided. A demonstration that GHG thresholds are met is not provided.
For reference, please see this excerpt from the Mather South FEIR, page 7-29:
“Implementation of Mitigation Measure CC-1 requires the project to comply with all provisions included in the AQMP. This mitigation would be consistent with provisions of General Plan Policy AQ-4. Implementation of Mitigation Measure CC-2 would further reduce GHG emissions associated with residential and nonresidential building energy and transportation. However, GHG emissions would not be mitigated to a less-than significant level through the provisions of the AQMP and Mitigation Measure CC-2 alone. Thus, the purchase of carbon offsets as discussed in Mitigation Measure CC-3 would reduce the transportation-related GHG emissions to reduce mass emissions by 301 MTCO2e/year for the transportation sector by 2032. With implementation of Mitigation Measure CC-3, all GHG thresholds would be met and this impact would be reduced to a less-than-significant level. [Mather South Final EIR, page 7-29, PLNP2013-00065]
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