Jackson Township Specific Plan Project: ECOS Comments

On June 28, 2021, ECOS sent the following comments to CEQA[at]saccounty[dot]net (Cc: Todd Smith smithtodd[at]saccounty[dot]net).

ECOS and other environmental groups have urged developers to start building the project nearest the urban core (the City of Sacramento) and build outward, following the Jackson Highway. This would reduce the project’s GHG emissions, air pollution, and negative impacts on local wildlife. However, the Sacramento County Board of Supervisors has instead elected to let the market decide which part of the project should be built first, and therefore the project is being built contrary to environmental concerns.

Below is an excerpt from our letter.

As stated on p. 20-1, vehicle miles traveled (VMT) has replaced congestion as the metric for determining transportation impacts under CEQA. Nonetheless, in the EIR level of service (relieving traffic congestion related to the development) is said to be “mitigated” by building additional roads and lanes. This will result in more VMT.
The EIR states that “delay-based traffic operations is provided herein for informational purposes. It is assumed for the purpose of this analysis that delay-based effects and the associated measures proposed to reduce these effects to acceptable levels would be included as conditions of approval and/or in the development agreement for the Project.” On pp. 20-41/42, the EIR states that SB 743 requires amendment of CEQA Guidelines to provide an alternative to LOS for evaluating transportation impacts. Particularly within areas served by transit, those alternative criteria must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.”

Measurements of transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.” The EIR continues, “Once the CEQA Guidelines are amended to include those alternative criteria, auto delay will no longer be considered a significant impact under CEQA.” Nonetheless, in the EIR there are plans to construct additional lanes of concrete highway. That is a “business as usual” approach. We can no longer plan for additional roadways that will result in increased VMT and the concomitant increase of GHG and other emissions.

On p. 20-56 the EIR states, “The Project would widen and/or complete many roadways that cross or border the Plan Area and would include new roadways to serve the proposed land uses.” More appropriate mitigation should be funding for Regional Transit to cause even more frequent public transit and additional, Earth-friendly shuttles to get people that live and work in the project area to and from public transit lines, than those suggested in the EIR. On page 20-77 the EIR states, “While most effects could theoretically be reduced to acceptable levels by adding more traffic lanes, grade separations, new roadways, and other similar measures, such LOS improvement measures mitigation may not be consistent with adopted policies and could result in secondary impacts to the environment and other users.”

On p. 21-8 it is stated, “As described in Chapter 20, “Traffic and Circulation,” of this Recirculated Draft EIR, analysis of vehicle miles traveled (VMT) is provided only for Alternative 2. Based on modeling, VMT generated under Alternative 2 would exceed the VMT significance thresholds for residential lands and office land uses (emphasis added). Implementation of Mitigation Measures TR-1, TR-2, and TR-3 would pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, and would identify and fund additional Trip Reduction Services. However, it cannot be guaranteed that the implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce VMT impacts to less-than-significant levels because the specific elements of the VMT-reducing mitigation measures that would be implemented are unknown at this time, and uncertainty exists related to the VMT reductions that would be achieved.” To mitigate for this, the developer should commit funding to Regional Transit for increased public transportation.

On p. 21-17 the EIR states, “Project-generated GHG emissions would exceed applicable Sacramento County thresholds of significance for transportation and result in a cumulatively considerable contribution to climate change. These levels of emissions also indicate that the Project would not be consistent with Sacramento County’s CAP.” Therefore, adequate mitigation is required.

On p. 21-29 the EIR states, “Public transit is not currently provided to, or near the Plan Area. A conceptual transit system to serve the Jackson Corridor Projects (i.e., the Jackson Highway Master Plans, including the Jackson Township Project) has been developed by Sacramento County, SacRT, DKS Associates, and the applicants of the Jackson Corridor Projects as part of a joint transit planning process. This developer and those of adjacent projects should mitigate this by providing additional funds for public transit.”

The EIR provides “Sacramento County has established draft GHG thresholds for 2030. The Project’s build-out year is 2035, for which the 2030 GHG thresholds were extrapolated in alignment with State GHG reduction targets. Development of the Project or Alternative 2 would result in the production of GHG emissions during construction activities and throughout the operational period of the Project, attributed to vehicle use, energy use, waste generation, water treatment and distribution, and other area sources.” (P. 21-51). It goes on to say, that even with implementation of mitigation suggested, the Project would reduce GHG emissions generated onsite and the remaining GHG emissions exceeding applicable thresholds would be offset through the purchase of carbon credits. Better mitigation than carbon credits is direct funding to RT for mass transit and additional Earth-friendly shuttles as suggested above.

We agree with the statement on p. 21-64 that the Jackson Corridor Projects include substantial amounts of higher density and mixed uses to help support transit use; however, transit service within walking distances of those uses is required to achieve a significant transit ridership. The “LOS Improvement Measures” beginning on p. 21-143 again call for more concrete, and instead should provide funding that will enable public transit to be utilized instead. In the words of teenager Greta Thornburg, “act like our house is on fire.” We cannot develop more roadway and arterials instead of funding additional mass transit, and project mitigation should reflect that.

We agree that implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce Project-generated VMT impacts (p. 21-214). These measures should pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, as well as identify and fund additional Trip Reduction Services (TRS). Such additional trip reduction services should include direct funding to RT for public transit to adequately serve the Project, because the Project “would have a considerable contribution to a significant and unavoidable cumulative VMT impact” (p. 21-214).

/s/
Ralph Propper,
President, Environmental Council of Sacramento

Click here to view the letter as submitted.


Image by Peter Dargatz from Pixabay

Airport South Industrial Project: ECOS Comments

On June 28, 2021, the Environmental Council of Sacramento, Habitat 2020, Sierra Club Sacramento Group, Friends of the Swainson’s Hawk and Former Sacramento City Mayor Heather Fargo submitted a joint letter on the Airport South Industrial Project.

Below is an excerpt from our letter.

We urge you to remove Item 9 from the Consent Calendar and vote to deny the staff’s recommendation. The Resolution before you conflicts with and interferes with the success of the 2003 Natomas Basin Habitat Conservation Plan (“NBHCP”) the City’s efforts to reach carbon zero status, and General Plan policies. The City’s approval of the proposed annexation and development would constitute a breach of the City’s obligation under the 2003 Natomas Basin Habitat Conservation Plan to not annex or develop outside of the NBHCP permit area, and could lead to revocation of the City’s Incidental Take Permit under the Natomas Basin Habitat Conservation Plan.

Click here to read the letter in full.

City of Sac’s New Building Electrification Ordinance

On May 31, 2021, ECOS submitted our letter of support for the proposed Sacramento City Council New Construction Electrification Ordinance.

The Environmental Council of Sacramento (ECOS) urges the Sacramento City Council to support the New Construction Electrification Ordinance. This ordinance is an important first step in reducing greenhouse gas (GHG) emissions, and its passage would show we are serious in adopting the unanimous recommendations of the Mayors’ Commission on Climate Change.

Click here to read the letter in full.


City Council Votes June 1

The New Building Electrification Ordinance will be presented at an upcoming City Council meeting.

Date: Tuesday, June 1, 2021 (see the agenda and staff report here*)
Time: 5:00 p.m.
Location: Video Conference (see the meetings page for the link to eComment once the agenda is posted)
Hearing Title: An Ordinance Adding to and Amending Various Provisions of Title 15 of the Sacramento City Code and Adopting Local Amendments to the California Building Standards Code, Relating to Green Building Standards Including Electrification

Comments can be provided via eComment before or during the meeting. You may also call directly into the meeting to provide comments.


What is the New Building Electrification Ordinance?

The City of Sacramento is considering a reach code known as the “New Building Electrification Ordinance” that would establish phased requirements for new construction to be all-electric. A “reach code” is a local code that “reaches” beyond the state minimum requirements for energy use in building design and construction. The Ordinance would make changes to Title 15 (Buildings and Construction Code) of City Code to require all-electric new construction for new buildings that are 1-3 stories when building permits are filed on or after January 1, 2023, and for buildings that are four stories or more when building permits are filed after on or after January 1, 2026. With a few exceptions, new buildings would not include natural gas or propane plumbing and would use only electricity as the sole source of energy.

Consistent with the recommendations of the Mayors’ Commission on Climate Change and in response to stakeholder feedback on the feasibility of certain project types, the New Building Electrification Ordinance includes provisions for an infeasibility waiver for the portions of the project where all electric is demonstrated by the project applicant to be infeasible. In addition, the Ordinance includes limited exemptions for cooking equipment in commercial food establishments, for process loads in manufacturing and industrial facilities, and for water heating systems in regulated affordable housing (when virtual net energy metering is not available). The staff report and presentation will also address related key issues, including next steps to develop a strategy for decarbonizing existing buildings.

You are invited to participate in the upcoming public hearing.

Any Questions?

Please visit http://www.cityofsacramento.org/SacElectrificationOrdinance to review a summary of the project, community and stakeholder engagement (including videos of eight informational webinars), the Final New Building Electrification Ordinance for City Council’s consideration on June 1, and answers to questions that city staff have heard from the community and stakeholders over the course of the project.

If you have any questions please contact Helen Selph at (916) 808-7852 or HSelph[at]cityofsacramento[dot]org

Development of the 2020 Urban Water Management Plan

On May 5, 2021, the Environmental Council of Sacramento (ECOS), the Sierra Club Sacramento Group and the League of Women Voters of Sacramento County submitted a joint letter to a number of local water agencies summarizing our comments on the current development of the 2020 Urban Water Management Plan. Below is the opening of our letter.

The development of the 2020 Urban Water Management Plan (UWMP) including the Water Shortage Contingency Plan (WSCP) lacks a full, open, and meaningful public participation process. State law provides a minimum 14-day public notice prior to the adoption hearing. but in view of the fact that the U.S. Drought Monitor, a weekly hydrological analysis by the federal government, shows 93% of California in either “severe,” “extreme” or exceptional” drought, this suggests a public voice is more important now than ever.

Communities throughout the region are concerned about the availability of water for drinking, the environment and affordability issues. Climate change magnifies these concerns. The assumptions and projections documented in the Urban Water Management Plans, and the specific conservation and efficiency programs planned are of great interest to the community.

Click here to read the letter in full.

Sac City Building Electrification Ordinance

On May 4, 2021, the Environmental Council of Sacramento (ECOS) sent the following in an email to the City of Sacramento’s Law and Legislation Committee regarding a Building Electrification Ordinance.

Dear City Council members Eric, Katie, Jeff, and Jay,

The Environmental Council of Sacramento (ECOS) supports the proposed New Building Electrification Ordinance, to be considered today by the Sacramento Law and Legislation Committee. ECOS believes that the proposed ordinance is necessary for the City to take appropriate action to be a leader in the development of technology that all cities will need before long, as the threat of climate change becomes increasingly obvious to all. It will benefit the City to be a leader, as we strive to develop a world-class economy.

We note that the proposed ordinance is generally consistent with the recommendation from the Mayors’ Climate Commission. It would require new buildings, with permit applications filed on or after January 1, 2023, to be all electric. Buildings that are four stories or more, with building permit applications filed on or after January 1, 2026, would be all electric. We note that staff has added time limited exemptions for food establishments for cooking equipment only, and for manufacturing process loads within a manufacturing or industrial facility. The revised ordinance also includes more detail on the process for obtaining an infeasibility waiver. We hope that the Committee agrees that, with these changes, it can support the proposed ordinance.

Ralph Propper, ECOS President


Update: Good News!

After we sent our letter, at their meeting later the same day, the Sac City Law and Legislation Committee voted to recommend that the proposed New Building Electrification ordinance move forward to the full Council. The vote was 3:1 (with Schenirer, Harris, and Guerra voting for, and Valenzuela voting against). The Committee also directed the staff to do further outreach between now and the council meeting.

We want to express a huge thank you to those of you who took the time to write support letters on behalf of yourself and your organizations. It made a big difference as the opposition is strong, especially from restaurants.

The item is tentatively scheduled for the May 25 council meeting. It’s important that we continue to express our support between now and then.


Photo by Pixabay https://www.pexels.com/photo/time-lapse-photography-of-blue-lights-373543/