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.

Share this

How harmful are small, off-road engines?

December 23, 2019

On December 23, 2019 ECOS submitted a comment letter to the California Air Resource Board (CARB) regarding small off-road engines and their impacts on air quality. In our letter, we state:

We support the pursuit of alternatives and incentives to require the transition to zero emission technologies as soon as possible.

CARB research in 2018 found that long-term exposure to certain exhaust compounds emitted by gasoline powered lawn and garden equipment may increase cancer risk by up to 80 excess cases per one million operators exposed.

Click here to view the comment letter.

Click here to learn more about Small Off-Road Engines on the CARB site.

To keep up to date join this facebook group.

Share this

November 2019 was 2nd hottest on record for the planet

December 16, 2019
From the National Oceanic and Atmospheric Administration (NOAA)

Moreover, both the season (September through November) and the year to date (January through November) were each the second hottest in recorded history, according to scientists at NOAA’s National Centers for Environmental Information.

The exceptional heat also was felt at both ends of the world: Sea ice coverage across the Arctic and Antarctic oceans fell to near-record lows in November.

Here’s more from NOAA’s latest monthly global climate report:

Climate by the numbers
November 2019

The average global land and ocean surface temperature for November 2019 was 1.66 degrees F (0.92 of a degree C) above the 20th-century average and the second-highest November temperature on record, just shy of November of 2015.

In fact, the world’s five hottest Novembers have all occurred since 2013.

The average global sea surface temperature in November was 1.39 degrees F (0.77 of a degree C) above average — the second-highest temperature for November on record, behind November 2015.

Click here to keep reading.

Share this