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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Unmet Transit Needs – Upcoming Meetings

Posted October 15, 2019

Whether you ride daily, occasionally or haven’t tried transit yet, the Sacramento Area Council of Governments is looking for feedback on our area’s bus, dial-a-ride, paratransit and light rail transit services. SACOG accepts transit needs related comments from any area in the counties of Sacramento, Sutter, Yolo and Yuba.

What are your thoughts on local transit service? Would you like to use it for more trips, but don’t because of issues like where it goes, the schedule or cost? Are there places you really need to go but cannot currently? Please give SACOG your thoughts by attending an Unmet Transit Needs meeting or by relaying your comments to SACOG.

The California State Transportation Development Act (TDA) requires the Unmet Transit Needs Process be conducted annually by Regional Transportation Planning Agencies. SACOG is the Regional Transportation Planning Agency for the counties of Sacramento, Yuba, Sutter and Yolo. SACOG staff conducts the Unmet Transit Needs process annually for these four counties. The TDA requires that SACOG make a determination whether there are “unmet transit needs that are reasonable to meet” in the jurisdictions throughout the four counties.

There are also a number of ways to comment beyond the hearings, so please feel free to also call, text, email, fax or mail your unmet transit needs comments to SACOG!

Upcoming Meetings

OCT 28 2019, MON
2 – 3pm
Sacramento Regional Transit Unmet Transit Needs Hearing
Sacramento RT Auditorium, 1400 29th Street, Sacramento, CA

OCT 30 2019, WED
2 – 3pm
City of Galt Unmet Transit Needs Hearing
Galt Council Chambers, 380 Civic Drive, Galt, CA

NOV 4 2019, MON
2 – 3pm
City of Davis Unmet Transit Needs Hearing
Davis Council Chambers, 23 Russell Blvd., Davis, CA

NOV 5 2019, TUE
2 – 3pm
Sutter and Yuba Counties Unmet Transit Needs Hearing
Yuba County Government Center, 915 8th Street, Marysville, CA

NOV 6 2019, WED
6 – 7pm
City of Elk Grove Unmet Transit Needs Hearing
Elk Grove Council Chambers, 8400 Laguna Palms Way, Elk Grove, CA

JAN 16 2020, THU
9:30 – 10:30am
Sacramento Regional Transit Unmet Transit Needs Hearing
SACOG – Board Room, 1415 L Street, Suite 300, Sacramento, CA

Click here for more details on the SACOG website.

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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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