Galt CAP Requires EIR Analysis

December 4, 2019

The Environmental Council of Sacramento, Habitat 2020, the Sierra Club Sacramento Group and 350 Sacramento submitted a letter containing our follow up to comments on the City of Galt’s draft Climate Action Plan (CAP).

The City of Galt has prepared a draft Climate Action Plan (CAP) describing how it proposes to meet legal obligations to reduce greenhouse gas emissions within the City. Adoption of a CAP requires environmental analysis under the California Environmental Quality Act (CEQA). The City proposes to conduct abbreviated environmental review with a “Negative Declaration” (MND) instead of an “Environmental Impact Report” (EIR). ECOS and partner organizations assert that abbreviated review would not be legally acceptable, and further argue that conducting separate reviews for the CAP and two related road-building studies would be impermissible “piece-mealing” (analyzing environmental impacts of a single project as if it were several separate projects, to minimize apparent impacts).

Below are some of our key points.

  • Preparing an MND for the CAP would be inconsistent with CEQA requirements. Our earlier letter demonstrates with substantial evidence that the City’s draft CAP does not meet the requirements for a qualified GHG reduction plan or for mitigation enforceability, per CEQA Guidelines . . . We cited unsupported use of statewide targets, failure to meet the State’s 2050 target, non-enforceability of virtually all proposed mitigation measures, inadequate monitoring and update protocol, and lack of implementation funding.
  • The above would support a fair argument that adopting the draft CAP as a qualified GHG reduction plan which could streamline (i.e. diminish) CEQA review for future projects will likely have a significant effect on the environment. Pursuant to 14 CCR §15064 such a potential impact requires environmental analysis via an EIR.
  • The City’s grant agreement provides for concurrent development of three planning documents… [which] appear to be one whole project. The second two are clearly directly related. The CAP . . . would have, “a potential . . . reasonably foreseeable indirect physical change in the environment” by reducing or obviating future GHG analysis of the urban development made possible by extending Carillion Boulevard . . . analyzing the . . . potential environmental effects of these three plans together in one document would fall more properly within CEQA’s regulatory requirements.

Click here to read the letter.

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Sacramento City General Plan Update and Climate Action Plan – Comments due Nov 4, 2019

The City of Sacramento has issued a Revised Notice of Preparation (NOP) of a Master Environmental Impact Report (MEIR) for the City of Sacramento 2040 General Plan Update and Climate Action Plan.

The City is initiating the 2040 General Plan Update and Climate Action Plan, consistent with the City’s requirement to revise and update the General Plan every five years, as necessary, to address significant emerging trends, recent state statutes, new issues, and to update the status of implementation measures.

As lead agency, the City of Sacramento has issued a Revised NOP to inform trustee and responsible agencies, and the public, of the decision to undertake preparation of a MEIR and to provide information and clarification for the General Plan Update and MEIR as to the existing designated Special Study Areas that are in physical proximity to the city limits. These study areas on the edge of the city were previously defined by the City over a decade ago as unincorporated areas that are of interest to the City, as the planning of the areas necessitates interjurisdictional cooperation with Sacramento County and other entities.

The Revised NOP is available on the City’s Community Development Department webpage.

The Revised NOP circulation period is from October 3, 2019 to November 4, 2019. Written comments on the scope of the MEIR will be accepted until 4 p.m. on Monday, November 4, 2019.

Please submit comments to:

Scott Johnson, Senior Planner
Community Development Department
300 Richards Boulevard, Third Floor
Sacramento, CA 95811
Email: srjohnson [at] cityofsacramento [dot] org

Additional information on the 2040 General Plan Update and Climate Action Plan is available here.

Image found at https://commons.wikimedia.org/wiki/File:Sacramento_from_Riverwalk.jpg

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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.

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