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.

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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)

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ECOS statement on Measure B

Date: April 28, 2016

To: Governing Board, Sacramento Transportation Authority

From: John Deeter, co-chair, ECOS Transportation, Air Quality & Climate Change Committee

Re: Comments on proposed Measure B

The proposal for allocating Measure B revenues up for discussion today contains improvements over Options 1 and 2 presented at the April 14th Board meeting, but the Environmental Council of Sacramento believes that it still allocates far too much for new road construction and far too little for transit. Moreover, we are troubled about the lack of public involvement in drafting this measure, without a full public discussion regarding the division of revenue, the tax rate, alternative sources of funding, and the appropriateness of using sales tax revenue to build roads.

A fundamental question implicit in the current discussion of an additional county-wide transportation tax is whether Sacramento County is committed to a robust transit system or is content with continuing to accept a much smaller system persistently hobbled by inadequate public financial support. Measure B if passed would immediately provide Regional Transit with an additional $25 million per year, which would be barely sufficient to restore services that were cut eight years ago provided this allocation were used solely for this purpose. But RT has other needs as well, such as replacement or overhaul of worn-out vehicles, conversion of light rail to low floor vehicles, and slow, steady expansion of the existing skeletal bus and rail network. To achieve these goals, RT needs at least $50 million per year or a quarter-cent sales tax dedicated exclusively to its programs.

ECOS might be able to support Measure B even if it included some funding for roads, provided this money was limited to less than 40% of the total and was used primarily for road maintenance (“fix-it-first”), additional sidewalks, and more bike lanes. But the proposal currently under consideration is weighted in the opposite direction: expanding road capacity instead of promoting alternative modes of transportation, and carrying with it all the well-known negative externalities such as air pollution, global warming, and unnecessarily expensive supporting infrastructure.

We urge the STA Board to reformulate Measure B to provide better funding for transit and other non-automobile modes of transportation.

STA ltr capture

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