ECOS and Partners Letter re Upper Westside of North Natomas, Feb 22, 2019


Area of “The Boot,” aka the Upper Westside Specific Plan site

February 24, 2019 [UPDATE]

On Tuesday, February 26, 2019 at 2:15 pm, the County of Sacramento Board of Supervisors will consider starting a master plan process to urbanize 2,000 acres of prime agricultural land in Natomas (covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake). If possible, please attend the hearing. Please send a note to the Board (emails below) opposing this expansion on Farmland. Suggested language follows.

Click here to view the letter from ECOS, Habitat 2020, Sierra Club and Friends of Swainson’s Hawk, delivered February 22, 2019.

Email string for Supervisors (copy and paste)
SupervisorSerna[at]saccounty[dot]net, nottolid[at]saccounty[dot]net, susanpeters[at]saccounty[dot]net, kennedyp[at]saccounty[dot]net, supervisorfrost[at]saccounty[dot]net, BoardClerk[at]saccounty[dot]net, LundgrenJ[at]saccounty[dot]net.

Suggested text:

I oppose development of farmland in Sacramento County and ask you to deny the request to create an Upper Westside Master Plan for 2000 acres in the Natomas “Boot.” My reasons are:

  1. This proposal violates County General Plan policies, including the Urban Services Boundary and agricultural preservation policies, to preserve agricultural and open space lands in the County.
  2. There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized. There is no economic need to provide for more zoning for urban uses.
  3. There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin and these projects have a Habitat Conservation Plan in place to mitigate for their impacts on wildlife and are included in regional air quality and transportation plans. There is no economic rationale for advancing development in the portion of the basin that lacks infrastructure and mitigation programs.
  4. I support the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan and directly conflict with the preserves located in and adjacent to the plan area.

Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.

Thank you,

Friends of the Swainson’s Hawk
swainsonshawk[at]sbcglobal[dot]net
Judith Lamare
James Pachl
916 769 2857 c


February 11, 2019

Please read the latest call to action below, from Habitat 2020 Member Organization, Friends of the Swainson’s Hawk:

Landowners in the Boot area of North Natomas have asked the Sacramento County Board of Supervisors to start the legal process needed for approval of a development plan for 2000 acres of urban development in the County covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake.

The proposal directly contradicts and would undermine the Natomas Basin Habitat Conservation Plan (NBHCP) which covers the entire Natomas Basin. This plan — a binding contract between the city of Sacramento and County of Sutter and the state and federal wildlife agencies — relies in part on the Boot continuing to remain in agriculture and open space. It protects the Swainson’s Hawk population which nests along the Sacramento River and forages for rodents in the Basin, including the Boot area. The 2001 Natomas Basin Habitat Plan designates the mile-wide strip of land, in County jurisdiction, next to the Sacramento River levee as the Swainson’s Hawk Zone, which must remain free of urban development for the HCP to succeed.

Most of the proposed Boot development would be within the Swainson’s Hawk Zone. The City’s Incidental Take Permit (issued by USFWS and CDFW) for new development in North Natomas depends on the continued integrity of the NBHCP, including continuation of agriculture and open space in the Swainson’s Hawk Zone, and would be jeopardized by new development in the Boot.

Bob Thomas, who is the project representative, was formerly the City Manager who signed the NBHCP Incidental Take Permit as City Manager, and is very aware of the importance of the Swainson’s Hawk Zone, including the Boot area, to conservation of threatened species and the City’s buildout of North Natomas.

Please help us convince the County Board of Supervisors to deny this request. Letters to the Board members can include these important points:

  1. Urbanization planning in the Natomas Basin is contrary to important County General Plan policies, including the Urban Services Boundary, and policies to preserve agricultural and open space lands in the County.
  2. The Urban Services Boundary (which excludes urbanization in this area) is the basis for our regional air quality and transportation plans which protect our health and prevent the congestion that urban sprawl engenders. This is our region’s core strategy for Climate Action and mitigation for Climate Change.
  3. There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized, and thousands of acres of vacant land already zoned for development. There is no economic need to provide for more zoning for urban uses.
  4. There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin. These projects have planned infrastructure and mitigation programs. There is no economic rationale for considering development in the portion of the basin that lacks infrastructure and mitigation programs.
  5. Express your support for the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan. Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
  6. For residents of Natomas, public safety, emergency evaluation, freeway and airport access and other issues may come to mind in contemplating urbanization west of El Centro and North of I-80.

The hearing is set for 9:30 am, Tuesday, Feb 26, 2019.

The emails for the Board are: SupervisorSerna[at]saccounty[dot]net, nottolid[at]saccounty[dot]net, susanpeters[at]saccounty[dot]net, kennedyp[at]saccounty[dot]net, supervisorfrost[at]saccounty[dot]net, BoardClerk[at]saccounty[dot]net, LundgrenJ[at]saccounty[dot]net.

Please also cc or forward what you send to swainsonshawk[at]sbcglobal[dot]net.

Send an email to the Board Clerk requesting hearing notice and notice of availability of documents: BoardClerk[at]saccounty[dot]net.

For more information on the proposal, check the County website at https://planningdocuments.saccounty.net/. Search for “Upper Westside Specific Plan” Control #: PLNP2018-00284


Swainson’s Hawk in flight

Please share this call to action with friends and family who can help.

Thank you.

Friends of the Swainson’s Hawk
swainsonshawk[at]sbcglobal[dot]net
Judith Lamare
James Pachl

ECOS and Partners Letter on Natomas North Precinct Master Plan Notice of Preparation, May 31, 2016

On May 31, 2016, the Environmental Council of Sacramento (ECOS), Habitat 2020 and the Sierra Club Sacramento Group submitted a comment letter on the Natomas North Precinct Master Plan Notice of Preparation. You can read the letter in text below, or view the PDF by clicking here or the image of the letter at the bottom of this page.


May 31, 2016

Catherine Hack, Environmental Coordinator

SENT VIA EMAIL TO hackc[at]saccounty[dot]net

Department of Community Development Planning and Environmental Review Division

827 7th Street, Room 225, Sacramento, CA 95814

SUBJECT: NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE NATOMAS NORTH PRECINCT MASTER PLAN (CONTROL NUMBER: PLNP2014-00172)

Dear Ms. Hack:

These are comments from the Environmental Council of Sacramento (ECOS), with dozens of  individual members and organizational members in the tens of thousands. ECOS has a history of over 4 decades of advocacy to limit sprawl, preserve agriculture, habitat and open space, and improve the quality of life while supporting growth with a vibrant and equitable economy. These comments relate to all the requested entitlements, and the Project Objectives found on NOP, pages 3-4, Objectives 1-6, except where noted.

Land Use, Transportation, Air Quality, Climate Change

The proposed Master Plan is obviously inconsistent with the Metropolitan Transportation Plan / Sustainable Communities Strategy (MTP/SCS) and with the Regional Air Quality Attainment Plan. The DEIR must include a full analysis and discussion of the project’s inconsistency with the MTP/SCS and the Regional Air Quality Attainment Plan. How this inconsistency will be mitigated (e.g., with strict project phasing) must also be addressed.

Since the proposed project is inconsistent with the MTP/SCS and the State’s mandates under SB 375 to reduce greenhouse gas emissions, the project must also, by definition, be inconsistent with the County’s Climate Action Plan.  If this plan is to have any value, this inconsistency must also be addressed and mitigated.

The above inconsistencies are critically important since the project, as proposed,  is a totally auto-oriented community.  Regional Transit will not have the ability for many years, if ever, to provide service to this area at the proposed densities.  Therefore it is critically important to establish a Transportation Services District, similar to what exists in North Natomas and portions of the Southeast County, to provide funding for transit service, connectivity and other transportation-related services.

It is important that the EIR, as a tool in assessing impacts, provide information which allows all interested parties and decision-makers to ascertain the level/degree of consistency/inconsistency with critical land use policies. The EIR must fully evaluate consistency with Sacramento County General Plan Policy LU-127. Any finding of inconsistency must be explained and where appropriate quantified, particularly with respect to the crucial finding pertaining to available holding capacity.

In addition to analysis of the “No Project” alternative, there should also be an examination of the alternative that 55,000 people will, indeed, move to Sacramento County, but will choose to reside elsewhere, say, in the northern and central portions of the City of Sacramento, choosing infill locations that are already zoned for residential development of the same or higher density as that proposed in this project. It is widely reported that modern  homebuyers are preferentially seeking more compact, urban locations than large-lot, suburban locations. The continuing demand for compact, urban of housing is further bolstered by the history of the recent foreclosure crisis: while homes in Elk Grove and Natomas literally could not be given away, homes in the central city lost very little value, and recovered these losses (and then some) before any other locations did. While such an alternative may not be the preference of these developers, neither is the “No Project” alternative. But the “No Project” alternative ignores the reality that more people are, indeed, choosing to live in this region. In practical terms, if these developers end up with “No Project,” that alone will not halt the population increase. Rather, the new arrivals will live somewhere already zoned for the type of residential development they prefer. That is the comparison that should be made with the project as proposed.

The proposed project includes substantial employment and higher density residential development in order to meet General Plan policy criteria for new development at the urban fringe. The EIR must evaluate the increase in impact, particularly with respect to VMT and CO2 air quality emissions, if the development were to build out at lower, traditional levels of suburban development. The EIR must consider mitigation measures, including but not limited to phasing requirements and development moratoriums, to prevent occurrence of those adverse impacts.

There are already enough flawed assumptions in the feasibility analysis for the regional hospital to conclude that such a facility is extremely unlikely to materialize. The nation has spent the past six decades trying to reduce the ratio of hospital beds per thousand population, not increase it. Therefore, in order to properly assess the range of possible impacts of the proposed project, the EIR must include at least one alternative that does not include a regional hospital.

Water

The EIR must consider the adequacy of water to supply the development. A conclusion that the “project will be supplied by surface water supplemented with groundwater withdrawals” is inadequate. State Water Board approval of Natomas Central Mutual Water Company surface water rights from agricultural to municipal/industrial (M/I) use should not be counted upon as a given outcome. All potential sources of surface water, constraints and obstacles to obtaining them, the timing of water delivery, the potential for delivery curtailment in dry years, and overall feasibility of supplemental surface water supplies must all be thoroughly vetted.

The project is outside of the Urban Services Boundary (USB). M/I development was not assumed as part of the studies and assumptions underlying the Water Forum Agreement. The EIR must include a comprehensive analysis of the North American River Sub-basin, taking into account the buildout of approved and planned projects in Sutter and Placer Counties. The EIR analysis must complement and support sustainable groundwater planning undertaken to implement the California Sustainable Groundwater Management Act.

The EIR must include legally enforceable mitigation measures, including but not limited to phasing requirements and moratoriums, if assumed supplemental surface water supplies are not available sufficiently in advance to forestall groundwater overdraft.

As part of this analysis, the EIR must assess groundwater quality, including the presence of chromium, manganese, iron and arsenic, and its feasibility for domestic consumption. Assessment of infrastructure costs must consider the additional cost of water treatment to remove potentially harmful levels of these and other elements in groundwater supplies.

We are aware of the drainage studies performed under the auspices of the County and others over the past two decades. We believe the drainage problems are even more complex because of additional development that has occurred or been approved since the completion of these drainage studies, including those in Sutter County. The EIR must be extremely detailed as to how adequate drainage will be achieved for this project, as well as how these drainage solutions affect the project’s ability to mitigate for any proposed take of endangered species.

Growth-inducing Effects

The EIR must evaluate growth inducing impact of extending the USB to the County Line. The analysis should include speculative land price increases in the region and the resulting impact on implementing the Natomas Basin HCP, Sacramento County’s relationship to that HCP notwithstanding. The analysis should also include the regional growth-inducing impact of this, the most populous jurisdiction in the region, acting in violation of its own general plan to expand the region’s footprint in a manner inconsistent with regional plans.

Biological Resources

As proposed, this project conflicts with the Natomas Basin Habitat Conservation Plan (NBHCP). While the County declined to become a signatory to the Plan in 2003, nonetheless the proposed development would remove vital agriculture that provides habitat and foraging for at least two endangered species. Without this acreage, mitigation for this project could be rendered inconceivable, especially since other development in the area has already been approved. Those previous approvals have not yet resulted in construction, nor have their approved mitigations been implemented. When they are, the availability of mitigation acreage for this project is nil. The EIR must be explicit about the precise acreage, timing and location of mitigation land, and must demonstrate beyond doubt how compatibility with the NBHCP and already-approved mitigation for already-entitled projects will be achieved.

Specifically, the EIR needs to analyze the impact of this proposed project on the implemented Natomas Basin Habitat Conservation Plan, including, but not limited to the following:

  • Analysis of impact on conservation strategy implementation in the NBHCP.
  • Analysis of impact on effectiveness of mitigations in the NBHCP. As an example, the NBHCP stipulates a 1:1/2 acre mitigation for terrestrial non wetland habitat loss, but this was predicated on no additional development beyond that covered in the NBHCP within the basin.
  • Analysis of the impact on “feasibility for acquisition” for the lands needed within the available inventory for the NBHCP within the basin given that over 5600 additional acres are proposed to be removed from the inventory, and at least that amount, if not substantially more, will be needed to mitigate for the proposed development.
  • Analysis of the impact of potentially increased acquisition costs for acquiring mitigation lands for the NBHCP because of the increased demand resulting from trying to mitigate for this project in the same geography as the NBHCP.
  • EIR needs to provide substantive evidence that the loss of so much more habitat than was contemplated and covered in the NBHCP in the basin will not result in jeopardy for the Swainson’s hawk and the giant garter snake.
  • Analysis of the impact of removing more than 5600 acres of important habitat for the giant garter snake needs to be included. Cumulative effects need to be analyzed for the giant garter snake in this context as well.
  • Analysis of the impact of removing more than 5600 acres of important habitat for the Swainson’s hawk needs to be included. Cumulative effects to the Swainson’s hawk need to be analyzed in this context as well.
  • The EIR needs to provide all appropriate and feasible mitigations for impacts to species so that their efficacy can be analyzed, and not kick the can down the road with the deferred mitigation of indicating that such details will be worked out later with the regulatory agencies after entitlements are granted.
Financing

The environmental challenges of this project represent astounding obstacles, of a scale rarely seen in this region. The EIR must be very sound in its demonstration of how the provision of public infrastructure and services to this project can be achieved while maintaining a “neutral-to-positive fiscal impact” to the County (see NOP, page 4, Objective #8).

Infrastructure costs for internal drainage, SAFCA flood control assessments, roads and other essential services will be extensive. Parallel evaluation of these costs is essential to the EIR process. The EIR must show that mitigation measures attached to the project, particularly those that rely on developer funded implementation—and in particular those that are related to habitat mitigation requirements—will, when combined with the burden of infrastructure costs, be financially feasible.

Bonding of mitigation measures must be evaluated as part of the mitigation and monitoring program. This evaluation must be part of the draft EIR process and available for public review well before final project approvals.

Conclusion

ECOS agrees with the assumption that the population of the region and the county will grow. The purpose of the General Plan is to control future development such that it meets the stated needs of the county. Applicant must demonstrate how the proposal will help the county meet these needs, consistent with the existing General Plan, MTP/SCS, Regional Air Quality Attainment Plan, Climate Action Plan, Sustainable Groundwater Management Act, the NBHCP, and, of course, CEQA. Any requested departure from these requirements must demonstrate unequivocal and unique circumstances that outweigh the considerable constraints of those existing requirements. To the extent that one considers the provision of public infrastructure and services, themselves, as mitigation for the environmental impacts of the project, their feasibility, adequacy and their own inherent impacts must be explicated fully and compared to alternatives that do not require amendments to the General Plan, various specific plans ( listed in the NOP as “Requested Entitlements”), or new annexations to the Sanitation District and Sewer District.

The region, and the county, specifically, already have countless alternatives to meet future growth within the above requirements (well beyond the 55,000 people subsumed by this proposal). In fact, the existing General Plan subsumes much more growth than is projected by SACOG. It is incumbent on the applicant, therefore, to demonstrate how the proposal comports with the alternatives already available under the General Plan, MTP/SCS, etc. A simple “No Project” alternative that also assumes no growth anywhere else in the region, or one that fails to relate the project to at least one of these alternatives, is simply not good enough to support rational decision-making.

Sincerely,

Brandon Rose, President, Environmental Council of Sacramento (ECOS)

Robert C. Burness, Co-Chair, Habitat 2020

Barbara Leary, Executive Committee Chair, Sierra Club Sacramento Group


natomas letter image

ECOS Letter 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.

Sincerely,

Brandon Rose, President of the Environmental Council of Sacramento (ECOS)

Attachments:
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.

ECOS and Habitat 2020 Letter re Natomas North Precinct Plan, Dec 16, 2015 and Call to Action for hearing on Mar 23, 2016

CALL TO ACTION: On Wednesday, March 23rd, 2016 at 2:00 PM, Sacramento County will look at a new proposal to expand the Urban Services Boundary. The boundary was created in the early 1990’s to try to limit the sprawl of urbanization in the Sacramento region.

Please voice your opposition to this proposal at this critical time. Tweet, Call, Email, Write or Post on Facebook and tag County Supervisors if you can!

Attend the 2PM workshop in the Board of Supervisors chambers on Wednesday if you are able — all bodies and testimonies are appreciated!

We need to halt urban sprawl in our beautiful valley, not add to it. The proposal is not consistent with the Sacramento Area Council of Governments’ recently adopted transportation plan, or the Sacramento Air Quality Management District’s plan.

Read the article by Rob Burness of ECOS and published March 22, 2016 in the Sacramento Bee, summarizing the latest:
http://www.sacbee.com/opinion/op-ed/soapbox/article67576377.html

Some Background

The Sacramento County Board of Supervisors is considering the entitlement request of North Natomas landowners to expand the Urban Service Boundary, amend the General Plan, prepare a specific plan, and rezone 5600 acres to allow for the development of a new suburban community of 55,000 people.

Why Expanding the Urban Service Boundary is Significant and Precedent Setting

Sacramento’s adoption of an Urban Service Boundary in 1993 represented one of the first California General Plans to define a long term boundary for urban growth in a metropolitan setting. It provided sufficient land within the USB for many decades worth of growth. The USB provided the potential, with carefully considered phased growth, to at least triple the unincorporated urban population in the County.

By and large the Urban Service Boundary has been an effective planning policy. Folsom did expand beyond the boundary south of US Highway 50—as a city it is not bound by the same policies—and the County approved one minor expansion for a truck stop along Interstate 80. When Elk Grove City tried to expand its sphere way beyond the USB, the boundary’s importance weighed in the issues brought before LAFCo and their ultimate decision to deny the expansion. The boundary was an important benchmark for the analysis that led to the Water Forum Agreement, and has been, as intended, a valuable tool for planning sewer interceptors and other urban infrastructure over the last 22 plus years.

The Natomas Project would expand the Urban Service Boundary to allow a new “city” of 55,000 people. It would send the message to other cities that the USB is just a line on a map and not a significant delimiter for urban development. For all of us who want to see responsible, efficient, phased growth that gives infill a chance, moving forward with the Natomas project at this time sends exactly the wrong message. So, for us and many Sacramento residents, moving the boundary IS a big deal.

ECOS submitted a comment letter on December 16, 2015 that can be viewed here.

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ECOS and Habitat 2020 Letter on Expanding the Urban Services Boundary in Natomas, Dec 16, 2015

The Sacramento County Board of Supervisors announced today that they have moved their workshop on the plan to expand the Urban Services Boundary north of Natomas from tomorrow, December 16th, 2015 to March 8, 2016. ECOS’ comments on how expanding the boundary would allow for a whole new area of urban sprawl when we should instead be focusing on infill development and reaping the co-benefits were submitted on December 15th, 2015.

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We hope that your Board understands the significance of your actions regarding expanding the USB north to the Sutter County line. We understand that this is only a step in a long process of considering entitlement approval. But you have authorized entering into contracts for over $7 million worth of studies and work to figure out the details of creating a new town of 55,000 people, and you have authorized preparation of a $1 million Environmental Impact Report to consider the impacts. You are proceeding as if this is a done deal only requiring the planning details to be worked out. And you are doing so without having fully and publicly addressed the significant issues associated with the threshold decision of whether this development should proceed at all, in this time frame, or under the auspices of the County rather than the City. Please consider our request to put the project on hold while you undertake a serious and unbiased review and hold a public discussion on the important concerns we are raising.

See our comments by clicking on the letter above or here.