Category Archives: ECOS comment letters

Letter of Support for SacRT Grant Application

SacRT is applying for a grant from the Federal Transit Administration’s Rail Vehicle Replacement Program. The application asks for help replacing our aging fleet of Light Rail Vehicles with modern new low-floor vehicles. As many of us know, many of the light rail cars still in use today were original to the system in 1987 and they are now past their useful life. In addition, the new vehicles are much more accessible for people with mobility issues and those taking bicycles or scooters on light rail for their first-mile/last-mile needs. On December 20, 2022 ECOS submitted a letter of support for SacRT’s application.

Click here to read our letter.

Support for the County of Sacramento’s Early Action for New Construction Electrification Ordinances

On December 20, 2022, the Environmental Council of Sacramento, the Environmental Justice Coalition, 350 Sacramento and Citizens’ Climate Lobby Sacramento submitted a joint letter of support for the County of Sacramento’s early action for new construction electrification ordinances.

You can read our letter below.

Dear County Supervisors,
In advance of the final release of the County’s Climate Action Plan (CAP), we recommend the Board of Supervisors implement the draft CAP’s excellent measures for all-electric new buildings.
County Climate Action Plan measures GHG-05 (commercial) and GHG-07 (residential) call for ordinances to require all-electric construction by 2023 for new low-rise buildings and 2026 for new larger buildings. The measures are included below for your reference.
The City of Sacramento approved a nearly identical ordinance last month, for implementation during the same timeframes as the County CAP measures. The City ordinance is consistent with the California Green Building Standards Code, and was preceded by public workshops, stakeholder meetings and technical reviews – all of which will help to provide guidance for such ancillary issues as technical exemptions and appeal processes.
We note that County staff is already primed for this task. The County has signed onto an MOU on collaborative electrification efforts with both the City and SMUD, and has also created a task force to advise on this subject and other climate actions.
Although a January 2023 start for the measures may no longer be viable, we request you direct staff to prepare the necessary ordinance language and rationale for public review and Board approval shortly thereafter. Taking this decisive action now – without waiting for the CAP – will signal that the County, like the City of Sacramento and many other State municipalities, is ready to move forward with meaningful climate action.

Click here to read our letter in PDF.

Sacramento City Climate Adaptation Plan – ECOS Comments on Preliminary Draft

On December 5, 2022, ECOS submitted a letter to the City of Sacramento regarding their Sacramento City Climate Adaptation Plan Preliminary Draft. Below is the content of the letter.

Thank you for the opportunity to comment on this chapter.

Flooding: The Draft highlights the high flooding risk in Natomas. Proposed developments in the Natomas basin such as South Airport Industrial, Grand Park, and Upper West Side, would increase flooding threat to Natomas because these lands currently are agricultural, and can absorb significant water should flooding occur. In addition to increasing flooding risk in the Natomas Basin, another climate risk associated with these developments is the loss of habitat land and related species (giant garter snake and Swainson’s hawk), which would mean failure of the Natomas Basin Habitat Conservation Plan. Therefore, the City should find a mechanism to influence the County’s process of development approvals in these areas. One possibility might be a “Sphere of Influence” application to LAFCo, which has the charge to preserve agricultural land.

Trees: The City of Sacramento has both the Parking Lot Tree Shading Design and Maintenance Guidelines and a tree ordinance. These should be updated to allow for larger shade trees and larger planting areas. We note that Crocker Village has planted “lollypop trees” that don’t provide much shade, and trees on Crocker Drive have insufficient planting radius to allow for mature growth. In contrast, neighboring Curtis Park has tree plantings that shade the entire streets by foliage meeting in the middle. The City should develop programs to guide urban forestry within communities, with a focus on increasing canopy in underserved communities. Tree planting should be required as part of major roadway or utility projects. The City should establish a resource database to help staff select tree species based on maintenance costs, structural integrity, and the most appropriate planting locations.

Water: The City should actively participate in the Sacramento Regional Water Bank, to store water during high precipitation years, for use during droughts. This is especially important with models showing more extremes of precipitation, and much earlier Sierra snow-melts. Because the City relies on a combined sewer system for the older parts of the city, the City needs to budget for upsizing pipes in that water system.

Electrification: The City should move forward rapidly on an ordinance requiring existing building electrification, rather than burning natural gas that accentuates the heat island effect.

Land Use: The City should consider land use as an adaptation; e.g., rezoning around transit for higher density, creating community public spaces and parks.

Structures: The City should consider incentivizing green walls and green roofs that cool buildings and provide food in urban settings, as well as shaded bus shelters, including passive-cooled shelters, such as developed by JCDecaux. The City should develop green building programs that require institutional and commercial buildings to have cool roofs. These strategies can be phased in based on square footage and allow for flexible compliance between cool roofs, green roofs, and rooftop solar PV to help alleviate cost concerns.

Roadways: The City should have code requirements for both new roadways and maintenance activities to ensure that roadways are designed and built at the outset to support heat-resilient paving materials. The City should also require high albedo and permeable pavements for transit stations, centers, and corridors.

Click here to view the letter in PDF.

Why ECOS is opposed to Measure A

October 18, 2022

ECOS’ Executive Committee has voted to oppose Measure A, the Sacramento County sales tax initiative on next month’s ballot. Here are some reasons to vote NO on Measure A:

Measure A is designed to circumvent the Sacramento BLUEPRINT, California’s climate targets, and federal transportation planning law. Its highway projects are not included in our region’s long-range plan, the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS). They have not gone through any public process or analysis against accepted smart growth planning principles, goals, and laws. Why? Because these projects would not pass the test. So, the measure’s proponents have skirted the process, and spent over a million dollars for a “citizens’ initiative” to make us pay for projects that enable their sprawl developments.

Measure A is full of roadway capacity expansion projects and a new rural expressway. These projects will induce more car travel and sprawling housing development. This will pull resources from infill development, with its attendant economic revitalization, better transit access, affordable and energy efficient housing, and community enhancements.

Being anti-planning has another serious dollars and cents impact for our region. SACOG, our metropolitan planning organization, has shown that the measure’s projects would cause our region to exceed federal air quality standards and greenhouse gas targets, making us unable to receive State and federal transportation and housing funds.

Measure A will mean a dismal and economically disastrous step backward; a forty-year prospect of regional decline and a worsening climate. So, can we consider and pursue other options?

We admire cities in Europe because they have many layers of development, making the character of the streets inviting, alive, and culturally valuable. In Sacramento, we have just an initial layer of built form, and in many places the buildings are dilapidated and no longer work economically. We are ripe for another layer of development to fill in. Sacramento should take this moment in its history to flex forward, to turn away from the automobile as the primary means of getting around. This is what the climate challenge demands and what future generations will need.

Let’s work together to write an initiative for 2024 that puts local transportation funding where it needs to go: locate higher capacity transit where more people live and where bus ridership is high; create new accessible public plazas and parks, connected by boulevards and promenades; and provide housing for people of all income levels within walking distance to transit, food, and schools. And, let’s show the federal and State government that Sacramento can be a reliable partner for funding by uniting around a vision.

On Thursday, the SACOG Board meeting will feature an example of coalescing behind a vision with a workshop/case study of the Salt Lake City region, Envision Utah. October 20, Agenda Item 18: https://sacog.primegov.com/Portal/Meeting?meetingTemplateId=3358

Below is SACOG’s map of the Measure A proposed projects and their estimated effect on vehicle miles traveled (VMT.)

Please vote NO on Measure A.

Click here to read our full statement, including footnotes.

ECOS Comment Letter re CARB Draft 2022 Progress Report, California’s Sustainable Communities and Climate Protection Act, Jun 2022

On July 14, 2022, ECOS submitted a comment letter regarding the CARB Draft 2022 Progress Report, California’s Sustainable Communities and Climate Protection Act, dated June 2022.

Below is an excerpt from our letter.

…we ask that CARB collect and analyze information that is more current, and report on
SB 375 progress more frequently, so the public has a better sense of our climate status and jurisdictions can more timely make course corrections.

Based on the current report, we are not on a trajectory to prevent climate change. We urge CARB to
work with the state legislature to implement the recommendations and suggestions [we have out forth in this letter].

Click here to read the letter in full.