Jackson Township DEIR Comments

On October 31, 2019, Environmental Council of Sacramento (ECOS), Habitat 2020, 350 Sacramento, and Sierra Club provided comments on the Jackson Township Draft Environmental Impact Report (EIR). Below are some excerpts from the letter, followed by a link to the letter in full.

Agricultural Resources

There is insufficient mitigation for farmland lost in the Jackson Township Specific Plan DEIR [Draft Environmental Impact Report]. By converting all this farmland to urban/suburban uses, the GHG emissions will increase due to the increased number of motor vehicle trips (more vehicle miles traveled). Moreover, loss of agricultural resources will reduce the potential for carbon sequestration in the soil by application of compost or regenerative agriculture methods, in addition to the natural processes of plant growth and soil microbial action from farming. There needs to be better mitigation measures to ensure carbon soil sequestration occurs at least as much as it would if the agricultural resources were preserved.

Biological Resources

Use of the South Sacramento Habitat Conservation Plan (SSHCP) was offered as one of the options for dealing with California Endangered Species Act (CESA) and Federal Endangered Species Act (FESA) impacts, and it was clearly stated that the hardline preserves identified in the SSHCP conservation strategy would be provided. Since the SSHCP now has its permits and is in the implementation phase, we are assuming that the Jackson Township will be affected by and compliant with the SSHCP.

Climate Change

We appreciate the opportunity to comment on Chapter 9, “Climate Change”, of the County’s Jackson Township Specific Plan Draft Environmental Impact Report (DEIR). Our greenhouse gas (GHG)-related comments are presented in the following seven sections. We first discuss the County’s past GHG-reduction commitments, because the DEIR:
I. does not accurately describe County climate planning;
II. uses inappropriate baseline data based on past planning;
III. applies inappropriate thresholds of significance; and
IV. is inconsistent with the County’s 2011 General Plan Update, associated Final Environmental Report (GP/FEIR), and Phase 1 CAP.
We also present,
V. other DEIR-related concerns.
We conclude:
VI. the DEIR is legally insufficient
VII. the County’s failure to provide promised mitigation is contrary to the General Plan.

Click here to read the letter in full
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5

SMUD Roseville Water Transfer comments

On September 10, 2019, the Environmental Council of Sacramento and Habitat 2020 sent a letter to Sacramento Metropolitan Utilities District (SMUD) a letter regarding a proposed water transfer between the City of Roseville and SMUD. Below are some excerpts from the letter, followed by a link to the letter in full.

Recently the Environmental Council of Sacramento and Habitat 2020 became aware of the pending temporary water transfer between the City of Roseville and SMUD. Our review of the environmental assessment and decision document prepared by the Bureau of Reclamation found specific deficiencies in the analysis and a casual dismissal of the transfer’s cumulative significance. We believe that the proposed transfer of water does not contain the necessary safeguards to protect Lower American River fisheries. We request that the SMUD Board direct its staff to include provisions in the contract that will address these concerns.

We believe the transfers must be governed by the standards and requirements contained in the Modified Flow Management Standard. These standards and requirements would much better ensure that the transfer would not negatively impact the American River flow and temperature standards.

Click here to read the full letter.

Photo by George Nyberg of the American River

Problems with Galt Climate Action Plan

On September 30, 2019, the Environmental Council of Sacramento, 350 Sacramento and the Sierra Club submitted a letter compiling comments on the Climate Action Plan proposed by the City of Galt.

Below are some excerpts from the letter.

Local climate action is important because the largest sources of greenhouse gas emissions (GHG), in the City of Galt as well as statewide, are building energy [use] and on-road vehicle travel.
Both are best and most directly controlled locally, by adopting energy-efficient building codes and requiring efficient development that reduces the need for auto “vehicle miles traveled” (VMT).

There is no longer any rational doubt that climate change is adversely affecting the livability of our planet now; that physical environmental effects will grow increasingly serious in coming decades; and that without major, timely GHG-reductions, they will cause grave public health impacts and severe economic and social disruptions in the lifetimes of children alive today.
We appreciate the difficulties transitioning from the long-accustomed land use and building models that have contributed to climate change to sustainable ones, and doing it quickly. But the exigencies of climate change, as reflected in State law, require broad and decisive change in how we use and think about energy. The required adjustments will bring many co-benefits, and we no longer have the luxury of delayed or token efforts.
Our organizations are committed to working with Galt in every productive way we can. We look forward to ongoing engagement in the City’s administrative process and may provide specific suggestions in future comments

Click here to read the comment letter in full.

Image credit: https://www.ecolife.zone/

Sacramento Two Rivers Trail Bike Trail

On September 12, 2019, ECOS and Habitat 2020 submitted a comment letter on the Sacramento Two Rivers Trail (Phase II) DEIR.

The Two Rivers Trail Phase II project will provide a 2.4 mile long multi-use path between Sutter’s Landing Park and H Street, by Sacramento State. The trail will provide residents of River Park and East Sacramento a safe, convenient, and protected path into downtown Sacramento. The overall vision is to eventually have the trail connect to the Sacramento River Parkway and create a continuous trail system along both sides of the Sacramento and American Rivers. In addition, the project will environmentally clear the next phase of the trail between Sutter’s Landing Park and the Sacramento Northern Bike Trail.

https://www.cityofsacramento.org/Public-Works/Engineering-Services/Projects/Current-Projects/Two-Rivers-Trail-Phase-II

There are many habitat issues that remain unaddressed in the Draft Environmental Impact Report.

The bottom line is that a bike trail on a levee is not only feasible, but it is the best option for the Two Rivers Trail if we want to protect the American River Parkway and its ecosystems. There are numerous other benefits to putting the trail on top of the levee as well, such as better access during winter floods.

Click here to read the letter in full.

Placer County Sustainability Plan Comments

On September 05, 2019, ECOS and 350 Sacramento wrote a comment letter to the Placer County Community Development Resources Agency in regards to the Placer County Sustainability Plan.

Below are a couple of excerpts from the letter, click the link below to read the full letter.

We encourage all efforts to expedite the transition to a carbon-free economy and are gratified by the County’s aspiration to be a leader in reducing greenhouse gas (GHG) emissions. We offer these comments in the hope they will help the County reach that goal.

It is evident from the draft Plan’s strong monitoring and update commitments that it is meant to be a “living” document, subject to ongoing community dialogue and further refinement. We look forward to working with the County to advance the Plan’s important role in mitigating climate change.

Click here to view the comment letter in full.

South American Subbasin Alternative Comments

July 25, 2019

Dear Mr. Eck:

As you are aware, ECOS and Habitat 2020 have been following the Sacramento Central Groundwater Authority’s (Authority) development of the South American Subbasin Alternative (South American Alternative), and the Department of Water Resources (DWR) review and decision regarding its acceptability under the terms and requirements of the Sustainable Groundwater Management Act (SGMA).

The letter you received, dated July 17, 2019, from DWR’s Deputy Director Taryn Ravazzini, and the accompanying staff report, form a well-reasoned determination that the South American Alternative will not satisfy the requirements of SGMA. While the Authority is given thirty days to provide information to refute DWR’s findings, it seems that devoting time to this pursuit is not in the best interest of the Sacramento region and the Authority.

Ralph Propper and Rob Burness

Full letter here.