ECOS/Habitat 2020 Comments on the Two Rivers Trail Phase II project

On November 30, 2018, the Habitat Committee of the Environmental Council of Sacramento submitted a letter to Tom Buford, Principal Planner, and Adam Randolph, Project Manager, with the Community Development Department of the City of Sacramento.

Habitat 2020 is a citizen coalition that works to protect the lands, waters, wildlife and native plants in the Sacramento region. It also serves as the Environmental Council of Sacramento’s Habitat & Conservation committee. The great Central Valley of California has been identified by the World Wildlife Fund as one of North America’s most endangered eco-regions. Preserving its remaining open space and agricultural land is essential for sustaining native plants and wildlife, and ensuring a high quality of life for ourselves and future generations. Members of Habitat 2020 include the Sacramento Audubon Society, California Native Plant Society, Friends of Swainson’s Hawk, Save the American River Association, Save Our Sandhill Cranes, Sierra Club Mother Lode Chapter – Sacramento Group, Friends of Stone Lakes National Wildlife Refuge, the International Dark-Sky Association and the Sacramento Area Creeks Council.

The American River Parkway is a unique and singularly important riparian habitat corridor in the County of Sacramento and is a rare remaining remnant of what was once a much more extensive riparian ecosystem in northern California. Any project to construct facilities within the Parkway and to increase human activities in the Parkway has impacts on the wildlife, habitat and plants of this corridor. This project would create 3.4 miles of new Class 1 bicycle and pedestrian trail primarily along the waterside levee toe west from Sutter’s Landing Regional Park to the Sacramento Northern Bikeway Trail at North 18th Street, and east from the eastern terminus of Sutter’s Landing Regional Park to the H Street Bridge. The trail would be 14-16 feet wide. As stated in the MND/IS, page 5, the project is proposed to be constructed largely in an area designated as “Protected Area” under the American River Parkway Plan, with habitat preservation and recreation-related activities being the primary uses. As stated on page 9, it is one of the objectives of the project to “Complete the project in a manner that minimizes environmental impacts to the Parkway, given the proposed project’s location within the environmentally sensitive Parkway.”

Our comments on the MND/IS focus on the conservation of the Parkway as natural habitat. Moreover, we support the mission of the Save the American River Association (SARA) and endorse (and incorporate by reference into our comments) all comments made by SARA on this MND/IS. Likewise, we endorse and incorporate comments made by the Friends of the River Banks and the Friends of Sutter Landing Park.


We request that the City draft and circulate a full EIR, considering alternatives to the project width and alignment, and significantly improving the mitigation measures for the project
.

View the full letter by clicking here (PDF).

View more information about the project on the City’s website by clicking here.

Share this

Community Perspectives on Local Transportation Needs & Funding

On September 13, 2018, ECOS and other groups submitted a joint letter to the Sacramento Transit Authority regarding transportation needs & funding in the Sacramento region. Below is an excerpt from the letter.

Breathe California Sacramento Region (BCSR), Cien Amigos, Environmental Council of Sacramento (ECOS), Sacramento Area Bicycle Advocates (SABA), Sacramento Housing Alliance (SHA), Sacramento Transit Advocates and Riders (STAR), Sierra Club Mother Lode Chapter and WALKSacramento are pleased to jointly share our perspectives on local transportation needs and funding.

Collectively, our missions stand for the advancement of health, access, equity, justice and environmental stewardship through investments in the built environment. We work closely in partnership with agencies and communities throughout the Sacramento region on issues related to transportation, land use, housing, and the environment, representing a wide-reaching constituency of some of Sacramento’s most engaged voters.

As the Sacramento Transportation Authority (STA) begins to consider how to fund countywide transportation priorities, we’re pleased to know that Measure M approved by Los Angeles County voters in 2016 is a consensus model for a successful funding measure for Sacramento County. Our organizations comprise a working group committed to ensuring that Sacramento County’s next transportation sales tax measure benefits from the lessons learned from Measure M. We commend STA for recognizing the value of Measure M as a model and commit to working with STA to follow the successful approach used by the Los Angeles County Metropolitan Transportation Authority (Metro) in crafting and winning passage of Measure M.

(Continued)

Click here to read the full letter (PDF).

Share this

Approval of the Alternative Plan to the Groundwater Sustainability Plan

On October 23, 2018, ECOS sent a letter to the California Department of Water Resources regarding the Approval of the Alternative Plan to the Groundwater Sustainability Plan. Below is the text of our letter. Click here to view the letter in PDF.

October 23, 2018

Karla Nemeth, Director
Department of Water Resources
1416 Ninth Street
Sacramento, CA 95814
Email: Janiene [dot] Friend [at] water [dot] ca [dot] gov

Re: Approval of the Alternative Plan to the Groundwater Sustainability Plan

The Environmental Council of Sacramento (ECOS) had previously expressed our concerns regarding the request to the Department of Water Resources (DWR) by Sacramento Central Groundwater Authority (SCGA) to approve an Alternative Plan to the Groundwater Sustainability Plan (GSP) required under the Sustainable Groundwater Management Act (SGMA) (See attachments 1 and 2). SCGA’s continued, largely passive, approach to groundwater management over the past several years has strengthened our view that SCGA’s GMP and current governance and finance structure do not constitute a legally adequate “alternative” to preparation of a GSP. The purpose of this letter is to further reinforce our opposition to SCGA’s request, and to urge DWR to quickly find that SCGA is not in compliance with SGMA, and, therefore should immediately begin preparing a GSP.

The County of Sacramento recently approved the South Sacramento Habitat Conservation Plan (HCP) which streamlines Federal and State permitting for covered developments and infrastructure projects while protecting habitat, open space, and agricultural lands. The HCP encompasses 317,655 acres of Sacramento County. Of this amount, 36,282 acres will become part of an interconnected preserve system and include important Groundwater Dependent Ecosystems (GDEs). Twenty eight plant and wildlife species and their natural habitats have been targeted for conservation. The Sacramento Central Subbasin (Subbasin) is largely within the HCP’s boundary. Unfortunately SCGA did not actively participate in the development of the HCP. Nor has SCGA documented the Groundwater Dependent Ecosystems within the Subbasin that are a critical part of SGMA and the GSP planning process. SCGA needs to establish a comprehensive monitoring program that will serve as a foundation for effective groundwater management and recharge programs. This program must be an accounting based water level and water quality framework that supports SCGA taking appropriate action when trigger points are reached. It is our belief that SCGA will only accomplish these important SGMA requirements when DWR directs it to develop and implement a GSP. Absent a GSP, the groundwater dependent ecosystems of the SSHCP preserve system will be at risk, which will place the entire SSHCP conservation strategy at risk.

SCGA’s continuing passive approach to groundwater management results means that it is not only neglecting problems but missing opportunities. ECOS has recently learned of the full import of the Sacramento Central Subbasin’s significance as a potential major storm water recharge area and groundwater resource for the water security of the Region. According to Dr. Graham Fogg of UC Water, the Subbasin is one of only two basins in the entire Sacramento Valley with currently identified geology which can readily accept large amounts of excess storm water as recharge. Dr. Fogg is developing a program of research to determine the optimal locations of the Subbasin’s recharge areas. Unfortunately, SCGA has not exerted any leadership in this critically important area of Subbasin management and is not currently working with Dr. Fogg on the research design. If SCGA were actively developing a GSP, the plan requirements necessitate that SCGA do the foundational work that will assist the Region’s water purveyors and other’s with key stakes in the Region’s water future, to move forward to develop and implement a major program of storm water recharge in the Subbasin.

Specifically, the GSP framework requires SCGA to fully document GDEs. This action will ensure Subbasin management decisions are not in conflict with GDEs and the HCP, including the siting and management of recharge and extraction facilities. The GSP framework requires that SCGA design and implement a Subbasin monitoring network that meets state standards and includes inter/intra basin coordination. The development of this monitoring system coupled with coordination between SCGA and neighboring subbasins is integral to the development of a Subbasin recharge program. Additionally the GSP requires management zones for GDEs. This planning effort will serve as the integration point between recharge and extraction zones, and the HCP and GDEs. SCGA’s development of a GSP will bring about proactive water quality and groundwater level monitoring and management (including GDEs and areas in the basin undergoing remediation). SCGA has not embraced a management role in these important areas but as part of the GSP process it will need to do so if significant recharge is to occur in the Subbasin. Finally, the GSP framework calls for the documentation of important land use considerations. Clearly, if SCGA were following the GSP process it would be actively identifying high priority storm water recharge areas within the Subbasin and working with local land use authorities to assure their preservation.

ECOS is aware of the importance of establishing one or more water banks as part of a comprehensive Subbasin groundwater recharge program. Dr. Robert Gailey of UC Water recently presented a discussion of the Regional groundwater recharge storage opportunities afforded by water banking as well as the issues the Region faces in bringing one or more banks into fruition. SCGA’s completion of a GSP will provide the monitoring and accountability framework and the Subbasin management structure necessary for the establishment of an excess storm water recharge program and water bank(s). Subbasin management, groundwater recharge, and water banking are new concepts and general public awareness of them is low. DWR’s GSP requirements compel SCGA to engage in community and stakeholder outreach and engagement. SCGA has not engaged in outreach and has not implemented an effective communication strategy. Both of these GSP requirements are essential to gaining community support for effective basin management.

We believe the above issues, coupled with earlier concerns we and others have raised, provide compelling reasons why DWR should reject SCGA’s Alternative Plan. We urge you to expeditiously take this action.


Sincerely,

Ralph Proper
President, ECOS

Rob Burness
Co-Chair of Habitat 2020

cc: Don Nottoli, Sacramento Board of Supervisors
Darrell Eck, Staff Engineer, Sacramento Central Groundwater Authority
Forrest Williams Jr., Chairman, Sacramento Central Groundwater Authority

Share this