MTP/SCS EIR Scoping Comments from ECOS

On May 25, 2019, ECOS submitted a letter outlining our comments and concerns about the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) 2020 update, managed by the Sacramento Area Council of Governments (SACOG).

The Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) for the Sacramento region pro-actively links land use, air quality, and transportation needs. The current 2016 MTP/SCS was adopted in February 2016. The MTP/SCS is federally required to be updated every four years. The next MTP/SCS is required to be adopted by February 2020.

Click here to view the letter.

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New “Green Means Go” Program in Sacramento

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.

Ralph Propper, ECOS President

cc: Christina Lokke

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Light Pollution Effects on Wildlife and Ecosystems

Source: International Dark-Sky Association

For billions of years, all life has relied on Earth’s predictable rhythm of day and night. It’s encoded in the DNA of all plants and animals. Humans have radically disrupted this cycle by lighting up the night.

Plants and animals depend on Earth’s daily cycle of light and dark rhythm to govern life-sustaining behaviors such as reproduction, nourishment, sleep and protection from predators.

Scientific evidence suggests that artificial light at night has negative and deadly effects on many creatures including amphibians, birds, mammals, insects and plants.

Artificial Lights Disrupt the World’s Ecosystems

Nocturnal animals sleep during the day and are active at night. Light pollution radically alters their nighttime environment by turning night into day.

According to research scientist Christopher Kyba, for nocturnal animals, “the introduction of artificial light probably represents the most drastic change human beings have made to their environment.”

“Predators use light to hunt, and prey species use darkness as cover,” Kyba explains “Near cities, cloudy skies are now hundreds, or even thousands of times brighter than they were 200 years ago. We are only beginning to learn what a drastic effect this has had on nocturnal ecology.”

Glare from artificial lights can also impact wetland habitats that are home to amphibians such as frogs and toads, whose nighttime croaking is part of the breeding ritual. Artificial lights disrupt this nocturnal activity, interfering with reproduction and reducing populations.

Click here to continue reading this on the International Dark-Sky Association’s website.


Outdoor Lighting Basics

Modern society requires outdoor lighting for a variety of needs, including safety and commerce. IDA recognizes this but advocates that any required lighting be used wisely. To minimize the harmful effects of light pollution, lighting should

  • Only be on when needed
  • Only light the area that needs it
  • Be no brighter than necessary
  • Minimize blue light emissions
  • Be fully shielded (pointing downward)

Learn more at www.darksky.org.

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