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 leaders are facing a choice: Help or hurt the climate with transportation dollars

December 10, 2019
By Anne Stausboll
Special To The Sacramento Bee

Below is an excerpt from this insightful article on the new sales tax measure.

The sales tax measure will require approval by two-thirds of the voters. This is a steep climb and won’t be achieved by emphasizing enormous new highway projects that lead to more cost and harm to the environment. Support can only be achieved by investing in alternatives while providing for prudent maintenance of our existing roadways.

This isn’t about taking away people’s cars. It is about planning, common sense, and sustainable priorities.

Click here to read the full article.

Photo by Ricardo Esquivel from Pexels

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Homegrown Habitat Comments for Sacramento’s General Plan/Climate Change strategy

On November 11, 2019 the Environmental Council of Sacramento (ECOS) and Habitat 2020 submitted a letter to the City of Sacramento to bring the Homegrown Habitat Program to their attention and to urge them to incorporate some of its native plant guidelines into the City’s General Plan and Climate Change strategy updates.

Below is our letter in full.

November 11, 2019
Scott Johnson, Senior Planner
Community Development Department
300 Richards Boulevard, Third floor
Sacramento, CA 95811
Email: srjohnson [at] cityofsacramento [dot] org
Subject: ECOS/Habitat 2020 Homegrown Habitat program comments for inclusion in the City of Sacramento’s General Plan and Climate Change strategy updates
Dear Mr. Johnson,
The Environmental Council of Sacramento (ECOS) is a 501(c)(3) nonprofit organization working to achieve regional and community sustainability and a healthy environment for existing and future residents. ECOS member organizations include: 350 Sacramento, Breathe California Sacramento Region, Friends of Stone Lakes National Wildlife Refuge, International Dark-Sky Association, Physicians for Social Responsibility Sacramento Chapter, Sacramento Citizens’ Climate Lobby, Sacramento Electric Vehicle Association, Environmental Democrats of Sacramento County, Sacramento Housing Alliance, Sacramento Natural Foods Coop, Sacramento Audubon Society, Sacramento Valley Chapter of the California Native Plant Society, Sacramento Vegetarian Society, Save Our Sandhill Cranes, Save the American River Association, Service Employees International Union (SEIU) Local 1000 and the Sierra Club Sacramento Group.
Members of Habitat 2020, a committee of ECOS, include: Friends of Stone Lakes National Wildlife Refuge, Friends of Swainson’s Hawk, International Dark-Sky Association Sacramento Chapter, Sacramento Area Creeks Council, Sacramento Audubon Society, Sacramento Valley Chapter California Native Plant Society, Save Our Sandhill Cranes, Save the American River Association, Sierra Club Sacramento Group and Sacramento Heron and Egret Rescue.
The Sacramento Chapter of the California Native Plant Society (CNPS), in coordination with State CNPS, ECOS and Habitat 2020, has embarked upon an ambitious regional campaign, called Homegrown Habitat, to promote the preferential use of California Native Plants in home and civic landscaping. Local native plants provide habitat within the build environment that promote regional biodiversity and help create pathways for local insects, pollinators, birds and animals through our built environment. CNPS’s Homegrown Habitat team has prepared a list of appropriate annual and perennial plants, shrubs and trees (HH Plant List) for use in the City of Sacramento’s private and public landscapes. CNPS is currently building the capacity to ensure that these landscaping options are widely available locally.
City wide utilization of these plants will directly contribute to several of the City’s major long-term goals including climate change adaptation and regional biodiversity. Utilization of the local native plants found on the HH Plant List in public spaces, residential areas, and commercial/industrial landscapes within the City will lower water consumption, provide carbon sequestration benefits (even during extended periods of drought when many non-native plants, shrubs, and trees perish), and contribute to regional biodiversity by providing homes and year-round food for pollinators and beneficial insects, local and migratory birds, and animal populations. Nearly all the region’s beneficial insect populations are in decline and many of our bird and animal populations that depend on them are suffering the same fate. We urge the City of Sacramento to adopt the goal of the Homegrown Habitat program and the HH Plant List within the relevant parts of the City’s general plan and climate action plan, and in so doing, take the steps listed in the attached comment document to ensure the planting of these local native plants throughout the City.
Chris Lewis CNPS’s Homegrown Habitat program chair would be pleased to meet with you to more fully describe the program’s goals, objectives, and activities, and to discuss how the program can be implemented within the City. Chris will be following up within the week to set up a meeting with you to further explore implementation of the program within the City of Sacramento.
Sincerely,
Ralph Propper Sean Wirth
President, ECOS Co-Chair, Habitat 2020
Cc: Chris Lewis, Homegrown Habitat Program Chair

Click here to read the letter in PDF.
Attachment 1

Photo from calscape.org, of Western Redbud (Cercis occidentalis)
https://calscape.org/Cercis-occidentalis-(Western-Redbud)?srchcr=sc5dca249f9a5c2

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