On September 11, 2017, ECOS submitted our comments on the Draft Recirculated Environmental Impact Report (DREIR) for the Proposed Kammerer/Highway 99 Sphere Of Influence Amendment (SOIA) Application for the City of Elk Grove.
We appreciate the added attention to detail offered in the recirculated draft EIR, but rather than alleviate our concerns expressed in our original letter, the DREIR only further confirms those concerns. ECOS remains strongly opposed to the proposed Kammerer-99 Elk Grove SOI expansion and stands by our initial observation summarizing the project: Elk Grove’s anticipated growth can be accommodated within the existing City limits, and we find no justification for expansion beyond the Sacramento County Urban Services Boundary (USB) established in 1993 to be the ultimate growth boundary within the County. The proposal is inconsistent with the Sacramento Area Council of Governments’ (SACOG) Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) for meeting State mandated greenhouse gas (GHG) reductions, Federal mandates for Air Quality Attainment under the State Improvement Plan (SIP), as well as myriad regional goals for social equity, public health and natural resource conservation. There is an extreme lack of certainty that municipal water can be provided to this area without severe regional impacts, and the impacts to invaluable agricultural and biological resources by the proposal are potentially impossible to mitigate. The RDEIR confirms significant and unavoidable impacts in all these above-mentioned areas, with the exception of less than significant biological impact after mitigation which is a finding we disagree with. The question is, what justification is there for these impacts? We, again, find that there is not, and we strongly recommend that LAFCo decline the proposed Kammerer/99 SOIA.