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”
Dear James,
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.
Inclusionary Requirement
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.
Anti-Displacement Protection
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.
Our partners at Friends of the Swainson’s Hawk have created a fact sheet to outline the history of Natomas and the Natomas Basin Habitat Conservation Plan.
350 Sacramento, the Environmental Council of Sacramento, and the Sierra Club Mother Lode Chapter are grass-roots groups concerned with minimizing, adapting to, and reversing the effects of climate change. We are concerned that the proposed Elk Grove Climate Action Plan does not meet mandated requirements for a qualified Climate Action Plan, and does not adequately respond to the actual threat climate change poses the City.
Area of “The Boot,” aka the Upper Westside Specific Plan site
February 24, 2019 [UPDATE]
On Tuesday, February 26, 2019 at 2:15 pm, the County of Sacramento Board of Supervisors will consider starting a master plan process to urbanize 2,000 acres of prime agricultural land in Natomas (covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake). If possible, please attend the hearing. Please send a note to the Board (emails below) opposing this expansion on Farmland. Suggested language follows.
I oppose development of farmland in Sacramento County and ask you to deny the request to create an Upper Westside Master Plan for 2000 acres in the Natomas “Boot.” My reasons are:
This proposal violates County General Plan policies, including the Urban Services Boundary and agricultural preservation policies, to preserve agricultural and open space lands in the County.
There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized. There is no economic need to provide for more zoning for urban uses.
There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin and these projects have a Habitat Conservation Plan in place to mitigate for their impacts on wildlife and are included in regional air quality and transportation plans. There is no economic rationale for advancing development in the portion of the basin that lacks infrastructure and mitigation programs.
I support the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan and directly conflict with the preserves located in and adjacent to the plan area.
Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
Landowners in the Boot area of North Natomas have asked the Sacramento County Board of Supervisors to start the legal process needed for approval of a development plan for 2000 acres of urban development in the County covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake.
The proposal directly contradicts and would undermine the Natomas Basin Habitat Conservation Plan (NBHCP) which covers the entire Natomas Basin. This plan — a binding contract between the city of Sacramento and County of Sutter and the state and federal wildlife agencies — relies in part on the Boot continuing to remain in agriculture and open space. It protects the Swainson’s Hawk population which nests along the Sacramento River and forages for rodents in the Basin, including the Boot area. The 2001 Natomas Basin Habitat Plan designates the mile-wide strip of land, in County jurisdiction, next to the Sacramento River levee as the Swainson’s Hawk Zone, which must remain free of urban development for the HCP to succeed.
Most of the proposed Boot development would be within the Swainson’s Hawk Zone. The City’s Incidental Take Permit (issued by USFWS and CDFW) for new development in North Natomas depends on the continued integrity of the NBHCP, including continuation of agriculture and open space in the Swainson’s Hawk Zone, and would be jeopardized by new development in the Boot.
Bob Thomas, who is the project representative, was formerly the City Manager who signed the NBHCP Incidental Take Permit as City Manager, and is very aware of the importance of the Swainson’s Hawk Zone, including the Boot area, to conservation of threatened species and the City’s buildout of North Natomas.
Please help us convince the County Board of Supervisors to deny this request. Letters to the Board members can include these important points:
Urbanization planning in the Natomas Basin is contrary to important County General Plan policies, including the Urban Services Boundary, and policies to preserve agricultural and open space lands in the County.
The Urban Services Boundary (which excludes urbanization in this area) is the basis for our regional air quality and transportation plans which protect our health and prevent the congestion that urban sprawl engenders. This is our region’s core strategy for Climate Action and mitigation for Climate Change.
There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized, and thousands of acres of vacant land already zoned for development. There is no economic need to provide for more zoning for urban uses.
There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin. These projects have planned infrastructure and mitigation programs. There is no economic rationale for considering development in the portion of the basin that lacks infrastructure and mitigation programs.
Express your support for the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan. Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
For residents of Natomas, public safety, emergency evaluation, freeway and airport access and other issues may come to mind in contemplating urbanization west of El Centro and North of I-80.
The hearing is set for 9:30 am, Tuesday, Feb 26, 2019.
Send an email to the Board Clerk requesting hearing notice and notice of availability of documents: BoardClerk[at]saccounty[dot]net.
For more information on the proposal, check the County website at https://planningdocuments.saccounty.net/. Search for “Upper Westside Specific Plan” Control #: PLNP2018-00284
Swainson’s Hawk in flight
Please share this call to action with friends and family who can help.
Tahoe Park residents are asking why housing density has been greatly reduced in the plans for a development to be built near Broadway and Fairgrounds Drive in Sacramento. Why reduce housing density in the midst of a housing shortage, especially in a prime infill location?
Click here to read the letter written in opposition to amending the General Plan to lower the density requirements at 325 Fairgrounds Drive. Signatories include Alex Kelter, MD and Robert Meagher, MD, Co-Chairs of Environmental Council of Sacramento (ECOS) Land Use Committee.
