ECOS Comments on North Natomas Panhandle Annexation NOP, May 2016

On May 27, 2016 ECOS submitted the comments below on the Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for the Panhandle Annexation and Planned Unit Development (PUD) in North Natomas.

Attn: Dana Mahaffey SENT VIA EMAIL TO dmahaffey[at]cityofsacramento[dot]org
City of Sacramento Community Development Department
Environmental Planning Services
300 Richards Blvd, 3rd Floor
Sacramento, CA 95811

RE: Comments on Notice of Preparation of an Environmental Impact Report for the Panhandle Annexation and Planned Unit Development

Dear Ms. Mahaffey:

This letter provides initial comments from the Environmental Council of Sacramento (ECOS) and Habitat 2020 (H2020) in response to a notice of preparation application for the proposed Panhandle Annexation and Planned Unit Development in North Natomas. ECOS’ membership organizations include: 350 Sacramento, Breathe California of Sacramento-Emigrant Trails, Citizens Climate Lobby Sacramento, Friends of Stone Lakes National Wildlife Refuge, International Dark-Sky Association, Mutual Housing California, Physicians for Social Responsibility Sacramento Chapter, Sacramento Electric Vehicle Association, Sacramento Housing Alliance, Sacramento Natural Foods Co-op, Sacramento Valley Chapter of the California Native Plant Society, Sacramento Vegetarian Society, Save Our Sandhill Cranes, Save the American River Association, SEIU Local 1000 (Environmental Committee), Sierra Club Sacramento Group, and The Green Democratic Club of Sacramento.

Habitat 2020 (H2020) is a coalition of environmental organizations collaborating on common issues in and affecting, the Sacramento region. Members of Habitat 2020 include the Sacramento Audubon Society, California Native Plant Society, Friends of the Swainson’s Hawk, Save the American River Association, Save Our Sandhill Cranes, Sierra Club Sacramento Group, Friends of Stone Lakes National Wildlife Refuge and the Sacramento Area Creeks Council.

Incorporate Prior Letters in Comments

ECOS was signatory to a comment letter (attached as Attachment 1) dated December 18, 2006 in response to the Panhandle Annexation and PUD DEIR of a predecessor project. In addition, James M. Pachl, an attorney representing ECOS and other concerned organizations, submitted a letter on May 34, 2007 (attached as Attachment 2) commenting on the FEIR. Many of the concerns and comments in those letters pertaining to the evaluation of that project’s impacts are still relevant. These comments are incorporated herein by reference and we ask that you address them during the preparation of the new DEIR with the objective of providing a full and complete environmental analysis that addresses deficiencies in the prior documents.

We would also like to provide the following additional comment:

Evaluate Growth Inducing Impact of Enhanced Road Connectivity

The proposed project will provide a new through road between Del Paso Road and West Elkhorn Blvd. Del Paso Blvd represents the north boundary of the Sacramento City Limit, the Sacramento City Sphere of Influence Boundary, and the Sacramento County General Plan Urban Service Boundary. The proposed road will facilitate access to land north of West Elkhorn Blvd that is not included in any adopted plan for urban development. It is essential that the DEIR address the growth inducement potential of the planned road improvements and recommend appropriate mitigation measures.


Brandon Rose, President of the Environmental Council of Sacramento (ECOS)

Attachment 1 – Comment letter dated December 18, 2006 in response to the Panhandle Annexation and PUD DEIR of a predecessor project (PDF)
Attachment 2 – James M. Pachl’s letter dated May 34, 2007 commenting on the FEIR (PDF)

View the comment letter in PDF by clicking here.

ECOS Comments on Yamanee

May 26, 2016

The Environmental Council of Sacramento (ECOS) submitted our comments on the proposed Yamanee Project, P15-047 (“Yamanee”) to the City of Sacramento’s Planning and Design Commission on May 9, 2016. ECOS then provided testimony supporting the letter at the Planning and Design Commission hearing on Thursday, May 12, 2016. On May 26, 2016, ECOS submitted the same comment letter to Mayor Johnson, City Councilmembers, City Staff and City Planner John Shirey, as we believe our concerns should be of vital importance to the Council’s deliberations.

Read our comment letter below.

The Environmental Council of Sacramento (ECOS) has long advocated for less growth at urban Sacramento’s fringe in favor of a greater focus on infill and redevelopment. We support land use plans that are in line with realistic growth expectations, are environmentally sensitive, and while cognizant of neighborhood values, not beholden to them. We also believe that once adopted, local governments need to follow those plans.

The ECOS Land Use Committee has reviewed the Yamanee Project at 25th and J Street, which certainly offers a bold infill project: a 14 story building with a residential density of around 300 units/acre. It is located on a well used bus route and is close to downtown Sacramento jobs.

But the project proposes a 178 foot tall structure in an area zoned for a maximum height of 80 feet (approximately 6 stories)—almost 100 feet greater than the zoning requirement. The only other structure in Midtown of comparable height is Sutter Hospital.

The zoning code does allow for a “deviation” from the zoning code height restriction if the approving body finds that the project is balanced by significant benefits. So far as we aware this is the first height deviation request since adoption of the land use and zoning plans. It is not only a significant deviation in scale, but a precedent setting deviation.

We urge that your Planning Commission carefully consider the justification for the deviation. In an earlier era this would be called a variance—an exception which state law requires findings that there is not a grant of special privilege and that there are unique and special circumstances associated with the property that justify the granting of the variance. Sacramento City’s deviation language was created to avoid those mandated findings, but your Commission would be well advised to reflect on them as you make your decision.

So far the only justification for the project we have heard is that it will be LEED certified and that the architectural design will enhance the J Street corridor. But these are things your Commission should be expecting of all development—they are certainly not of and by themselves a justification for granting a right to more than double the size and density allowed by the zoning. The building would be exempt from the requirement to provide affordable housing, but this upscale project has yet to offer to contribute to affordable housing opportunity in the neighborhood.

And the argument that a building of this height only works at this location, or is not precedent setting, is disingenuous. It is not a basis for granting the exception. The rationale for granting the deviation is the important thing—it will be cited for any project that seeks a deviation whatever its height.

The decision you make will send an important message to landowners and developers in Midtown. It could well impact land values and speculative purchases in a way that changes the character of the neighborhood. If so you will have started a process that undermines implementation of a plan developed with community participation and compromise that would disserve the City and its residents.

ECOS welcomes infill and higher density, but not at the expense of effectively implementing adopted plans. We urge you to set the bar high in weighing the proferred community benefits in exchange for the “special privilege” of a precedent setting height deviation.

To this end, ECOS could support a significant project deviation if the project’s community benefit could justify it. A possible community benefit is the provision of workforce housing units. Yamanee proposes approximately 134 units, and the Sacramento Housing Alliance conservatively estimates that an ownership housing infill project such as Yamanee generates a workforce housing demand of about 15%, or 20 units for Yamanee. ECOS could support a significant project deviation if Yamanee provided mixed income housing sufficient to meet community demand, including approximately 20 units of workforce housing (or 15% of units for any final project). Other desirable community benefits should include facilities to accommodate the expected Sacramento bike sharing program and enhanced transit shelter facilities.

While ECOS commends the City’s efforts to provide housing in the Sacramento grid, to date the significant portion of it has been unaffordable even to moderate income persons. Yamanee’s deviations set a precedent for how and whether development honors existing plans and community agreements. Offsetting the deviations with community benefits that meet actual community need would help ensure the precedent places community need first.


Brandon Rose, President of the Environmental Council of Sacramento (ECOS)

Sacramento Tree Ordinance Update

Summary of Law and Legislation Committee Recommendation on Tree Ordinance Revise

May 10, 2016

City of Sacramento Law and Legislation Committee recommended approval (3-0) of the proposed Tree Ordinance with following changes:

1. Posting of tree removal shall be 15 calendar days (Harris)

2. Expanding the definition of public nuisance to more specifically refer to Dutch elm disease and another specific tree disease (Guerra).

In addition, staff presented three amendments and announced an immediate launching of a new process to replace the 1994 Urban Forest Management Plan creation process (to replace the 1994 plan) which would begin August 2016. Councilmember Guerra asked staff to report back before the Council hearing with on a plan to communicate with neighborhood associations about tree removal. Harris asked staff and to commit to reporting back to Council on implementation of the ordinance after one year (Harris).

Councilmember Harris who has been Council lead on this effort, stated that competing interests are involved and he had worked diligently with staff to seek suitable compromise on issues presented by the all stakeholders, including the public. He believes all public comment has been thoroughly considered. Harris stated that the revised ordinance protects thousands more trees, has tree replacement requirements, a replacement fund and security to back up replacement requirements, prohibits topping and protects root zones of protected trees. He noted that it is not going to get any better. Larger goals such as the Climate Action Plan and canopy can be addressed in the Urban Forest Management Plan update.

Without our efforts, these key improvements noted by Councilmember Harris would not have occurred. We can take pride that the ordinance is now “squared up” with the General Plan policies and common sense CEQA (California Environmental Quality Act) requirements such as guarantees that mitigation for tree removal is actually delivered. Sadly perhaps, it took a full scale community effort to get these corrections made.

We do have concerns that the recommended language makes it easier for staff to remove protected trees because broad authority is given to the Director of Public Works, criteria to be used are subjective, and existing language prohibiting harmful actions is not included in the recommended ordinance. Specifically, there is nothing in the ordinance which would require Urban Forestry to deny removal of a structurally-sound, protected tree. And we are seeing a lot of this. Last week it was 30 protected trees on R Street and several on West El Camino approved to be removed for public improvement projects.

We will keep you advised of the upcoming Council hearing on this issue.

For more information, please visit

ECOS May Board Meeting

Join the Environmental Council of Sacramento (ECOS) for our Board of Directors meeting!

In May, we are hosting a presentation with Rich Radmacher and Bill Ziebron on the long-awaited and much-needed South Sacramento Habitat Conservation Plan. We will also have a chance to discuss the plan with some of its long-time collaborators. Read more about the South Sac Habitat Conservation Plan here:

Monday, May 23rd, 2016
5:30 pm Reception with wine & refreshments
6:00 pm Meeting begins

As always:
– ECOS Committees will report on their activities.
– Announcements are welcome at the end
– Everyone who is interested is welcome! Bring a friend!

Please note the SEIU parking lot now requires the purchase of a permit. Street parking should be free starting at 6pm.

2016 5 May 23 ECOS Board Meeting Agenda

Del Paso Regional Park/Renfree Field Update, May 2016

May 3, 2016
To those concerned about Renfree Baseball Field and adjacent parkland beside it in Del Paso Regional Park:

There will be a public meeting Wednesday, May 11 at 5 pm, with city park personnel and SIBA representatives that will affect the future of this area.  The meeting will be held at the Sacramento Horsemen’s Association, 3200 Longview Dr, Sacramento, CA 95821.  Please share this with those who are interested in baseball, and with those who are interested in the natural area within the City of Sacramento’s largest regional park.

On December 16, 2014 the city council made an agreement with SIBA (Sacramento International Baseball Assoc) to renovate Renfree Field which opened the door to sell a portion of Del Paso Regional Park adjacent to the nature area.  There have been many delays, but we hope to hear more about the agreement and the project at this May 11 meeting.  The meeting will present the proposed rehabilitation of the Renfree baseball field, which everyone supports, but there is concern that a clause in the agreement allows the city to sell not only the baseball field, but considerable acreage of currently undeveloped natural area adjacent to it.  There is also concern that the renovation will allow for a ten fold increase in the viewers from the former 300 to a proposed 3000 viewers.

The flyer below from the city was sent to be shared with all.  It has information about the meeting.  We look forward to learning more about this project.  This may also be a time to express opposition to language in the agreement allowing this city park land to be sold.  This has been shared by one of many concerned residents.

renfree flyer

North Natomas Precinct Update, May 2016

May 3, 2016

Natomas North Precinct – Notice of Preparation of Draft Environmental Impact Report

Sacramento County is processing an application for the Natomas North Precinct Master Plan located in the Natomas community of unincorporated Sacramento County. The Project site is located north of the City of Sacramento, west of Steelhead Creek, south of the Sutter County Line, and east of Highway 99. The County Project Control Number is PLNP2014-00172 and the State Clearinghouse Number is 2016042079.

As the lead agency for the Natomas North Precinct Master Plan Project (Project), Sacramento County has determined that an Environmental Impact Report (EIR) is the appropriate California Environmental Quality Act (CEQA) document to evaluate the environmental consequences of the Project. Sacramento County published a Notice of Preparation on April 28, 2016.

Scoping Meeting on May 16, 2016

In order to provide additional opportunities for agencies and members of the public to comment on the scope and content of the environmental information to be included in the EIR, a public scoping meeting will be held. The meeting time, date, and location are as follows:

Time: 6:00 to 7:30 PM
Date: May 16, 2016
Location: South Natomas Community Center, 2921 Truxel Road, Sacramento, CA 95833

At the scoping meeting, staff will explain the environmental review process at the beginning of the meeting and the applicant will follow with a short project review. Staff will then be available to receive comments on the scope of the EIR in break-out stations.

Public Comments due May 31, 2016

It is not necessary to attend the EIR Scoping Meeting in order to provide comments on what is addressed in the EIR. Written comments can be submitted to the Sacramento County Planning and Environmental Review Division (Attn: Catherine Hack, Environmental Coordinator) via email at CEQA[at]saccounty[dot]net, or via mail at 827 7th Street, Room 225, Sacramento, CA 95814. Please contact Sheryl Lenzie, Project Manager, at 916-874-7722 or lenzies[at]saccounty[dot]net with requests or questions.

Here’s the link to the Notice of Preparation:

Here’s a link to the ECOS comment letter submitted in December 2015:

Image featured in this post was painted by Granville Redmond