ECOS Comments on Sacramento Railyards Specific Plan Update, KP Medical Center, MLS Stadium, & Stormwater Outfall SEIR

July 27, 2016

These are comments from the Environmental Council of Sacramento (ECOS), with dozens of individual members and organizational members in the tens of thousands. ECOS has a history of over 4 decades of advocacy to limit sprawl, preserve agriculture, habitat and open space, and improve the quality of life while supporting growth with a vibrant and equitable economy.

Alternatives to the Proposed Projects

The glaring deficiency in this SEIR is the lack of an Increased Density/Intensity Alternative.

Land Use, Transportation, Air Quality, Climate Change

ECOS believes that the requested zoning should include a minimum as well as a maximum number of housing units. Virtually all of the mitigations for Transportation, Air Quality and Climate change involve the enrichment of alternatives to automobile travel to, from and within the project. Other than automobile travel, all the other modes of transportation benefit from higher densities and more residential development, irrespective of the correction of any jobs/housing mismatch. Furthermore, the expensive infrastructure improvements necessitated by the project will not be as efficient at the proposed densities as they would at increased densities.

The addition of the Kaiser Permanente Medical Center (KP) provides ample basis on which to create plans for all-income housing development that would be synchronized with the creation of jobs in the project. Projects of this nature often favor early scheduling of commercial development, followed later, much later or never, by commensurate housing development. This pattern fosters the creation of undesirable patterns of housing, transportation, land speculation and delayed creation of public amenities that collectively depress the success of the integrated and holistic downtown desired by the City and by ECOS. An employer like KP includes one of the widest ranges of salaries imaginable, from low-skilled to some of the highest-skilled in society today. Of all the ways to bring a wide variety of income levels to the project, this has to be one of the most effective. This is an opportunity that should not be squandered by timidity.

At its current capacity for growth, RT is struggling to figure out how to keep up with the proposed growth in the region. Much of this struggle is exacerbated by the relatively timid densities being proposed, including this project. As is often proposed as part of other projects in the region, ECOS would like to see the development of an aggressive Transportation Services District as part of this project. We believe that a fee assessment on a dwelling unit equivalent basis would provide support to RT, or a private shuttle provider, as well as support the functions of the Transportation Management Association.

A further boon to the mode share for RT for trips to, from and within the project would result from a program to make every ticket sold for an event at large venues in the project (e.g., the soccer stadium, major events in public spaces at the Railroad Museum, etc.) also serve as a day pass for unlimited rides on RT. We understand this is being considered by the Golden 1 Center and should also be a part of this project.

To this end the following mitigation steps are presented:

  1. Establish a minimum residential density, say 75% of zoned maximum density, for buildout of the residential and mixed use zones
  2. Require project phasing that requires timely construction of housing units in conjunction with construction of employment producing development
  3. Require establishment of a fee assessment on a dwelling unit equivalent basis to provide enhanced transit support as recommended above
  4. Require that agreements are in place prior to building permit approval that enable all tickets sold at large venues within the project area to be used as transit day passes.

Growth-inducing Effects

For this project, ECOS has no qualms about inducing growth in the vicinity of the project. In fact, the more growth induced near the project, the better. We believe the developers and the City agree with us. All the more reason why there should be a robust Increased Density/Intensity Alternative.

Conclusion

The efficacy of an Increased Density/Intensity Alternative should not be underestimated. A vast array of desirable outcomes accompanies higher densities than are proposed by the project, a location already zoned for the highest densities in the City, but one that could be painfully underutilized by the project as proposed. Smart growth is most successfully enabled when the residential and transportation infrastructure development occur prior to the successive stages of build-out, and thereby structure and guide them. Without this, we will suffer from substantial pressure to put these essential features in parts of the City that are not currently zoned for them, further weakening the excellent General Plan.

Sincerely,

Alex Kelter MD, Co-Chair

Land Use Committee

Environmental Council of Sacramento (ECOS)

Click here to see the letter in PDF.

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Railyards Update & June 30 Public Meeting

June 23, 2016

NOTICE: There will be a public meeting of the City Planning & Design Commission on the proposed Railyards project in Sacramento.

When: Thursday, June 30th
5:30 Commission Training on Principals and Terminology
6:30 Railyards Review and Comment
Where: E.M. Hart Senior Center, 915 27th St, Sacramento, CA 95816.

Background

The Sacramento Railyards project is one of the largest contiguous infill opportunities in the nation. The 2007 Specific Plan for the project estimated the construction of approximately 10,000 to 12,000 new dwelling units of varying types within the Plan Area. The city of Sacramento has stated that we need 10,000 more residential units downtown to correct the jobs-housing imbalance in the urban core. In November 2015, Railyards planners were stating that they had changed the plan to include only about 6,000 housing units. In response, the Environmental Council of Sacramento (ECOS) and Mike McKeever of the Sacramento Area Council of Governments (SACOG) both expressed concerns about this reduction in housing units.

The Latest

On June 13, 2016, Alan Hersh LDK Ventures, the project’s developer, presented to ECOS at our Land Use Committee meeting. You can view the full minutes from the meeting, including his presentation, here. Hersh said they are “getting an entitlement for 10,000 units.” The zoning entitlement allows for a maximum of 10,000 housing units, but there won’t be a minimum requirement of units to actually get built, although this requirement could be created in the zoning. Hersh says only 6,000-8,000 units are probably realistic and that the density that works in the current market is 4-6 stories wrapped around central parking. This allows for wood frame buildings and will result in significant cost-savings per square foot.

What’s Next?

ECOS is disappointed that the number of units has been so drastically slashed and we hope that number will rise again. This is major infill proposal that could potentially do a lot to improve the jobs-housing balance in Sacramento and potentially set an example for a successful smart growth, infill, brownfield development for the rest of the country to consider.

Take Action

Make sure your voice is heard as the plans for this major development are being formed.

  • Contact the Planning and Design Commission and City Council via email, letters, phone calls and social media.
  • Attend the June 30th meeting if you are able and interested in flexing your civic power.
  • View early design concepts of the Railyards and provide feedback directly to the Railyards planning team here.
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ECOS Comments on Yamanee

May 26, 2016

The Environmental Council of Sacramento (ECOS) submitted our comments on the proposed Yamanee Project, P15-047 (“Yamanee”) to the City of Sacramento’s Planning and Design Commission on May 9, 2016. ECOS then provided testimony supporting the letter at the Planning and Design Commission hearing on Thursday, May 12, 2016. On May 26, 2016, ECOS submitted the same comment letter to Mayor Johnson, City Councilmembers, City Staff and City Planner John Shirey, as we believe our concerns should be of vital importance to the Council’s deliberations.

Read our comment letter below.


The Environmental Council of Sacramento (ECOS) has long advocated for less growth at urban Sacramento’s fringe in favor of a greater focus on infill and redevelopment. We support land use plans that are in line with realistic growth expectations, are environmentally sensitive, and while cognizant of neighborhood values, not beholden to them. We also believe that once adopted, local governments need to follow those plans.

The ECOS Land Use Committee has reviewed the Yamanee Project at 25th and J Street, which certainly offers a bold infill project: a 14 story building with a residential density of around 300 units/acre. It is located on a well used bus route and is close to downtown Sacramento jobs.

But the project proposes a 178 foot tall structure in an area zoned for a maximum height of 80 feet (approximately 6 stories)—almost 100 feet greater than the zoning requirement. The only other structure in Midtown of comparable height is Sutter Hospital.

The zoning code does allow for a “deviation” from the zoning code height restriction if the approving body finds that the project is balanced by significant benefits. So far as we aware this is the first height deviation request since adoption of the land use and zoning plans. It is not only a significant deviation in scale, but a precedent setting deviation.

We urge that your Planning Commission carefully consider the justification for the deviation. In an earlier era this would be called a variance—an exception which state law requires findings that there is not a grant of special privilege and that there are unique and special circumstances associated with the property that justify the granting of the variance. Sacramento City’s deviation language was created to avoid those mandated findings, but your Commission would be well advised to reflect on them as you make your decision.

So far the only justification for the project we have heard is that it will be LEED certified and that the architectural design will enhance the J Street corridor. But these are things your Commission should be expecting of all development—they are certainly not of and by themselves a justification for granting a right to more than double the size and density allowed by the zoning. The building would be exempt from the requirement to provide affordable housing, but this upscale project has yet to offer to contribute to affordable housing opportunity in the neighborhood.

And the argument that a building of this height only works at this location, or is not precedent setting, is disingenuous. It is not a basis for granting the exception. The rationale for granting the deviation is the important thing—it will be cited for any project that seeks a deviation whatever its height.

The decision you make will send an important message to landowners and developers in Midtown. It could well impact land values and speculative purchases in a way that changes the character of the neighborhood. If so you will have started a process that undermines implementation of a plan developed with community participation and compromise that would disserve the City and its residents.

ECOS welcomes infill and higher density, but not at the expense of effectively implementing adopted plans. We urge you to set the bar high in weighing the proferred community benefits in exchange for the “special privilege” of a precedent setting height deviation.

To this end, ECOS could support a significant project deviation if the project’s community benefit could justify it. A possible community benefit is the provision of workforce housing units. Yamanee proposes approximately 134 units, and the Sacramento Housing Alliance conservatively estimates that an ownership housing infill project such as Yamanee generates a workforce housing demand of about 15%, or 20 units for Yamanee. ECOS could support a significant project deviation if Yamanee provided mixed income housing sufficient to meet community demand, including approximately 20 units of workforce housing (or 15% of units for any final project). Other desirable community benefits should include facilities to accommodate the expected Sacramento bike sharing program and enhanced transit shelter facilities.

While ECOS commends the City’s efforts to provide housing in the Sacramento grid, to date the significant portion of it has been unaffordable even to moderate income persons. Yamanee’s deviations set a precedent for how and whether development honors existing plans and community agreements. Offsetting the deviations with community benefits that meet actual community need would help ensure the precedent places community need first.

Sincerely,

Brandon Rose, President of the Environmental Council of Sacramento (ECOS)

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