Galt CAP Requires EIR Analysis

December 4, 2019

The Environmental Council of Sacramento, Habitat 2020, the Sierra Club Sacramento Group and 350 Sacramento submitted a letter containing our follow up to comments on the City of Galt’s draft Climate Action Plan (CAP).

The City of Galt has prepared a draft Climate Action Plan (CAP) describing how it proposes to meet legal obligations to reduce greenhouse gas emissions within the City. Adoption of a CAP requires environmental analysis under the California Environmental Quality Act (CEQA). The City proposes to conduct abbreviated environmental review with a “Negative Declaration” (MND) instead of an “Environmental Impact Report” (EIR). ECOS and partner organizations assert that abbreviated review would not be legally acceptable, and further argue that conducting separate reviews for the CAP and two related road-building studies would be impermissible “piece-mealing” (analyzing environmental impacts of a single project as if it were several separate projects, to minimize apparent impacts).

Below are some of our key points.

  • Preparing an MND for the CAP would be inconsistent with CEQA requirements. Our earlier letter demonstrates with substantial evidence that the City’s draft CAP does not meet the requirements for a qualified GHG reduction plan or for mitigation enforceability, per CEQA Guidelines . . . We cited unsupported use of statewide targets, failure to meet the State’s 2050 target, non-enforceability of virtually all proposed mitigation measures, inadequate monitoring and update protocol, and lack of implementation funding.
  • The above would support a fair argument that adopting the draft CAP as a qualified GHG reduction plan which could streamline (i.e. diminish) CEQA review for future projects will likely have a significant effect on the environment. Pursuant to 14 CCR §15064 such a potential impact requires environmental analysis via an EIR.
  • The City’s grant agreement provides for concurrent development of three planning documents… [which] appear to be one whole project. The second two are clearly directly related. The CAP . . . would have, “a potential . . . reasonably foreseeable indirect physical change in the environment” by reducing or obviating future GHG analysis of the urban development made possible by extending Carillion Boulevard . . . analyzing the . . . potential environmental effects of these three plans together in one document would fall more properly within CEQA’s regulatory requirements.

Click here to read the letter.

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How harmful are small, off-road engines?

December 23, 2019

On December 23, 2019 ECOS submitted a comment letter to the California Air Resource Board (CARB) regarding small off-road engines and their impacts on air quality. In our letter, we state:

We support the pursuit of alternatives and incentives to require the transition to zero emission technologies as soon as possible.

CARB research in 2018 found that long-term exposure to certain exhaust compounds emitted by gasoline powered lawn and garden equipment may increase cancer risk by up to 80 excess cases per one million operators exposed.

Click here to view the comment letter.

Click here to learn more about Small Off-Road Engines on the CARB site.

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SacMoves Coalition Comments to Sacramento Transportation Authority

December 12, 2019

The Sacramento Transportation Authority (STA) is working to put together a new transportation measure for our region. This month, they’re drafting the Transportation Expenditure Plan scheduled for the November 2020 ballot. ECOS has been a part of the SacMoves Coalition, which joined with SMART to develop a framework for the STA. Below is an excerpt from the document:

Sacramento County should have an innovative, seamless and diversified transportation network that offers a wide range of accessible, affordable and efficient mobility choices coupled with supportive land uses. The County’s transportation system should strengthen and diversify our economy, improve our air quality, and reduce carbon emissions and vehicle miles traveled by minimizing single occupancy vehicle trips, expanding and improving public transit and shared mobility services and providing safe access for bicyclists and pedestrians. All community members, particularly from marginalized communities, should have access to sustainable and affordable mobility options that facilitate positive community outcomes for public health and safety, livability and economic vitality. In short, virtually all Sacramento County residents should have the option of living and working within walking distance or a transit stop from everything they need.

Click here to view entire document.

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