Draft Environmental Impact Report
The City of Elk Grove released the Draft Environmental Impact Report (“DEIR”) for the California Northstate University (“CNU”) Hospital Project (“Project”) on August 14, 2020, finally giving the public the first look at the Project’s potentially significant environmental impacts and an opportunity to provide comments.
On October 13, 2020, the Environmental Council of Sacramento, Habitat 2020 and the Friends of the Stone Lakes Wildlife Refuge, submitted a comment letter on the California Northstate University Medical Center Draft Environmental Impact Report.
Importance: This intrusive Project would have negative consequences for residents and wildlife alike. The City is already conceding that the Project would have significant impacts that cannot be mitigated. With respect to impacts to local residents, the Draft EIR admits that the Project would create light and noise pollution and increase criteria air pollutant emissions. The Project also poses a significant threat to native protected species like Swainson’s hawk, sandhill cranes and burrowing owls that inhabit the Stone Lakes National Wildlife Refuge and surrounding habitat. Noise and light pollution would disturb roosting birds, while helicopter flights and the massive hospital building would pose a danger for bird strikes. Long-term, the Project would contribute to depleting groundwater levels and impaired air quality.
On September 18, 2020, the Environmental Council of Sacramento submitted a letter regarding AB-900 compliance of the CNU Medical Center Project, asking for a 30-day extension for the DEIR review period.
We are requesting an additional 30 days to continue our review of this DEIR and feel that this is more than justified given that the City of Elk Grove needs to be in compliance with the record preparation requirements of AB 900 which requires that all documents that will be part of the public record will be provided by lead agencies within five days of being received and that they will be in an easily accessible electronic format.
A large hospital and medical center has been proposed by California Northstate University (CNU), a new for-profit college, for a location right next to the Stone Lakes National Wildlife Refuge in the southwest corner of the City of Elk Grove.
A 12 story hospital built from reflective glass with a helicopter pad would create a collision risk, particularly for large waterfowl such as sandhill cranes and geese. The helicopter pad would pose both a collision threat and a noise disturbance to birds in the Stone Lakes National Wildlife Refuge. Similarly, 24-hour operations of the hospital would cause light pollution on the western boundary of Elk Grove, also negatively affecting migratory birds.
In addition to the potentially significant environmental impacts on the Refuge and other wildlife habitat south of Sacramento, CNU has misled the public throughout the environmental review process. Email exchanges obtained by the Sacramento Bee revealed that CNU CEO Alvin Chung was seeking to build a “bio wet lab” on or near the existing campus. However, CNU has omitted any reference to a wet lab or biotech component to the Project in Project application materials. CNU successfully applied to have the Project designated an Environmental Leadership Project under AB 900, however, and the AB 900 application states that a “biotechnical laboratory” is a proposed accessory use. (Revised Application, p. 3-1.) The risks associated with the lab, specifically hazardous waste impacts, may not be fully evaluated in the EIR currently under evaluation, as wet labs are not included in CNU’s application to the City. (http://opr.ca.gov/ceqa/california-jobs.html)
The Project’s Leadership designation was approved by the Governor’s office on December 31, 2019, the last day the current statute remained in effect. Notably, the City of Elk Grove failed to provide any notice to the public about the pending application. CNU claimed that the hospital is a “commercial” project in order to be eligible for AB 900 designation because education or medical projects are not eligible. It appears that CNU is manipulating the environmental review process to receive beneficial treatment not intended for private hospitals and wet labs.
CNU is also marketing the Project as a “Trauma II” hospital and banking on receiving that designation to justify the scale of the Project and demonstrate financial feasibility. This ploy further misleads the public. Being designated a Trauma II hospital takes years to achieve and is not guaranteed. By law, only one more hospital can be designated a trauma center in Sacramento County (1 trauma center per 350,000 residents), and a greater need for a trauma center is in the eastern areas of the County. (See Hospital/Trauma Center Map.)
CNU is also greatly overstating the need for a hospital in the area. As shown in the Hospital/Trauma Center Map, the County has numerous hospitals. In addition, a new hospital operated by Dignity Health already has completed the environmental review process and was approved by the City in 2013. The Dignity Health hospital is also in a less sensitive biological location, away from the Refuge and the Delta. Dignity Health representatives conducted a groundbreaking ceremony in January 2020.
There are also red flags regarding CNU’s ability to administer a full teaching hospital. CNU is for-profit, a dubious distinction for a medical school. Now it is being cited by the California Department of Student Affairs for offering unaccredited programs. (https://www.kcra.com/article/elk-grove-california-issues-citations-against-school/30708429)
The Project’s environmental impacts to the Stone Lakes National Wildlife Refuge and wildlife in the region are significant and warrant environmental opposition to the Project. CNU’s issues with transparency and misleading the public only compound the concerns regarding the environmental impacts.
Previous Comments from Habitat 2020 and ECOS
The ECOS Habitat committee (Habitat 2020) is tracking the hospital proposal and has been sharing our concerns with the City of Elk Grove.
On May 13, 2019, the Friends of Stone Lakes National Wildlife Refuge, a member of Habitat 2020 and submitted a letter outlining their concerns prior to the release of the Notice of Preparation. Click here to read the letter.
On June 27, 2019, the Environmental Council of Sacramento, Habitat 2020 and the Friends of Stones Lakes National Wildlife Refuge submitted a letter in response to the Notice of Preparation of an Environmental Impact Report for Northstate University Medical Center. Our concerns include: an increase in bird collisions, helicopter flight impacts on migratory birds in surrounding roosting and foraging habitat, lighting impacts, building a hospital in a floodplain, surface water runoff, cumulative impacts, compliance with our region’s Metropolitan Transportation Plan/Sustainable Communities Strategy, growth inducement and more. Click here to read the letter.
Stone Lake Community
The Stone Lake Community Association released a statement in January of 2020. Below is an excerpt.
We should not accept anything less than a corporate neighbor who supports our priorities, engages in an open, transparent, and respectful manner, and is willing to work collaboratively towards a mutually shared vision that improves life for everyone, for generations to come.
“Neighbors Ensuring Stonelake Transparency” (NEST)
The greatest concerns expressed by the community so far include:
- Lack of transparency on behalf of CNU and city officials/unwillingness to correct false data and “misquotes” via the media
- A facility even more expansive than originally disclosed elevates residents’ concerns
- Financial failure, similar to the Elk Grove “Ghost Mall”, would leave behind an eyesore/empty shell of a hospital that would ultimately need to be demolished
- Displacement and/or destruction of local small-businesses
- Unreliable jobs projections, based on the original 24,000 being revised to only 1,400 over the next 10 years
- A hospital more than 6x higher than the tallest homes in the West Elk Grove/destruction of the aesthetics of the surrounding area
- Unsustainable traffic increases along Elk Grove Blvd., at the on-ramp and off-ramp of I-5 and on one of three main arteries into the Stonelake residential community
- Parking overflowing onto community streets
- Major safety concerns for nearby schools
- Negative impacts on the natural environment
- Lack of security available to accommodate the heightened safety risks
- Impacts to local wildlife, such as the many birds who depend on the Stone Lakes National Wildlife Refuge to survive
- Growth Inducement
Click here to view the environmental documents and other information on the proposed hospital. (You can also sign up for email updates on the hospital here.)
In the News
A series of town hall meetings on CNU hospital begins
February 19, 2020
The Elk Grove Citizen
CA issues citations against school planning to open hospital in Elk Grove
January 30, 2020
Dignity Health estimates Elk Grove hospital will cost at least $327 million to build
January 9, 2020
The Sacramento Bee
Dignity Health unveils plans for new, 30-acre Elk Grove hospital
January 8, 2020
Complicated diagnosis: State officials ordered California Northstate University to stop offering unapproved medical courses in the middle of school’s push to build a new teaching hospital
Sacramento News and Review
January 2, 2020
Environmental meeting for controversial proposed Elk Grove hospital draws dozens of questions, concerns
June 24, 2019
Elk Grove News.net
Former Elk Grove Mayor Davis slammed for calling Stonelake residents childish, dishonest
April 25, 2019
Elk Grove News.net
Emails reveal details of hospital project
Protest group says city staff’s correspondence with university lacks transparency
Apr 12, 2019
Elk Grove Citizen
Residents speak out against proposed Elk Grove hospital site
Protestors address City Council for an hour
Mar 8, 2019
Elk Grove Citizen
Last updated April 15, 2020