Jackson Township Specific Plan Project: ECOS Comments

On June 28, 2021, ECOS sent the following comments to CEQA[at]saccounty[dot]net (Cc: Todd Smith smithtodd[at]saccounty[dot]net).

ECOS and other environmental groups have urged developers to start building the project nearest the urban core (the City of Sacramento) and build outward, following the Jackson Highway. This would reduce the project’s GHG emissions, air pollution, and negative impacts on local wildlife. However, the Sacramento County Board of Supervisors has instead elected to let the market decide which part of the project should be built first, and therefore the project is being built contrary to environmental concerns.

Below is an excerpt from our letter.

As stated on p. 20-1, vehicle miles traveled (VMT) has replaced congestion as the metric for determining transportation impacts under CEQA. Nonetheless, in the EIR level of service (relieving traffic congestion related to the development) is said to be “mitigated” by building additional roads and lanes. This will result in more VMT.
The EIR states that “delay-based traffic operations is provided herein for informational purposes. It is assumed for the purpose of this analysis that delay-based effects and the associated measures proposed to reduce these effects to acceptable levels would be included as conditions of approval and/or in the development agreement for the Project.” On pp. 20-41/42, the EIR states that SB 743 requires amendment of CEQA Guidelines to provide an alternative to LOS for evaluating transportation impacts. Particularly within areas served by transit, those alternative criteria must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.”
Measurements of transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.” The EIR continues, “Once the CEQA Guidelines are amended to include those alternative criteria, auto delay will no longer be considered a significant impact under CEQA.” Nonetheless, in the EIR there are plans to construct additional lanes of concrete highway. That is a “business as usual” approach. We can no longer plan for additional roadways that will result in increased VMT and the concomitant increase of GHG and other emissions.
On p. 20-56 the EIR states, “The Project would widen and/or complete many roadways that cross or border the Plan Area and would include new roadways to serve the proposed land uses.” More appropriate mitigation should be funding for Regional Transit to cause even more frequent public transit and additional, Earth-friendly shuttles to get people that live and work in the project area to and from public transit lines, than those suggested in the EIR. On page 20-77 the EIR states, “While most effects could theoretically be reduced to acceptable levels by adding more traffic lanes, grade separations, new roadways, and other similar measures, such LOS improvement measures mitigation may not be consistent with adopted policies and could result in secondary impacts to the environment and other users.”
On p. 21-8 it is stated, “As described in Chapter 20, “Traffic and Circulation,” of this Recirculated Draft EIR, analysis of vehicle miles traveled (VMT) is provided only for Alternative 2. Based on modeling, VMT generated under Alternative 2 would exceed the VMT significance thresholds for residential lands and office land uses (emphasis added). Implementation of Mitigation Measures TR-1, TR-2, and TR-3 would pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, and would identify and fund additional Trip Reduction Services. However, it cannot be guaranteed that the implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce VMT impacts to less-than-significant levels because the specific elements of the VMT-reducing mitigation measures that would be implemented are unknown at this time, and uncertainty exists related to the VMT reductions that would be achieved.” To mitigate for this, the developer should commit funding to Regional Transit for increased public transportation.
On p. 21-17 the EIR states, “Project-generated GHG emissions would exceed applicable Sacramento County thresholds of significance for transportation and result in a cumulatively considerable contribution to climate change. These levels of emissions also indicate that the Project would not be consistent with Sacramento County’s CAP.” Therefore, adequate mitigation is required.
On p. 21-29 the EIR states, “Public transit is not currently provided to, or near the Plan Area. A conceptual transit system to serve the Jackson Corridor Projects (i.e., the Jackson Highway Master Plans, including the Jackson Township Project) has been developed by Sacramento County, SacRT, DKS Associates, and the applicants of the Jackson Corridor Projects as part of a joint transit planning process. This developer and those of adjacent projects should mitigate this by providing additional funds for public transit.”
The EIR provides “Sacramento County has established draft GHG thresholds for 2030. The Project’s build-out year is 2035, for which the 2030 GHG thresholds were extrapolated in alignment with State GHG reduction targets. Development of the Project or Alternative 2 would result in the production of GHG emissions during construction activities and throughout the operational period of the Project, attributed to vehicle use, energy use, waste generation, water treatment and distribution, and other area sources.” (P. 21-51). It goes on to say, that even with implementation of mitigation suggested, the Project would reduce GHG emissions generated onsite and the remaining GHG emissions exceeding applicable thresholds would be offset through the purchase of carbon credits. Better mitigation than carbon credits is direct funding to RT for mass transit and additional Earth-friendly shuttles as suggested above.
We agree with the statement on p. 21-64 that the Jackson Corridor Projects include substantial amounts of higher density and mixed uses to help support transit use; however, transit service within walking distances of those uses is required to achieve a significant transit ridership. The “LOS Improvement Measures” beginning on p. 21-143 again call for more concrete, and instead should provide funding that will enable public transit to be utilized instead. In the words of teenager Greta Thornburg, “act like our house is on fire.” We cannot develop more roadway and arterials instead of funding additional mass transit, and project mitigation should reflect that.
We agree that implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce Project-generated VMT impacts (p. 21-214). These measures should pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, as well as identify and fund additional Trip Reduction Services (TRS). Such additional trip reduction services should include direct funding to RT for public transit to adequately serve the Project, because the Project “would have a considerable contribution to a significant and unavoidable cumulative VMT impact” (p. 21-214).
/s/
Ralph Propper,
President, Environmental Council of Sacramento

Click here to view the letter as submitted.

Image by Peter Dargatz from Pixabay

Hidden money, weaponized disinformation and a dark development

By Scott Thomas Anderson

July 19, 2018

Sacramento News and Review

Who’s behind the leading phone survey and sponsored Facebook campaign that are trying to assuage Folsom residents about a massive attack on open space?

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Folsom Ranch, an embattled series of housing developments, is on track to be the largest of its kind in Sacramento County in decades—which means an enormous loss of open space, agricultural land and wildlife habitat.

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I scanned the room for reactions and paused at former Mayor Bob Holderness. After leaving his elected post, Holderness became a consultant for prominent developers and then spearheaded the campaign for Measure W, the 2004 ballot initiative for the city to annex the land on its southern border, which would be taken over by Folsom Ranch. Today, Holderness represents Westland Capital Partners, a major developer of Folsom Ranch, as well as AKT Development, a major seller of its land.

His jump from elected leader to special-interest contractor was mirrored by former City Manager Martha Lofgren, who helped prepare the South of 50 project on the taxpayers’ dime until 2006, and is now serving as legal counsel for the New Home Company, one of the project’s main developers. But wait, there’s a three-peat! Former city planner Mike McDougall is now a top-ranking manager for Folsom Ranch.

Similar to The Folsom Way’s story-weaving in The Bee—and the meditative voice-over work on its sky-soaring Facebook video—Holderness discusses the South of 50 project as if it was approved by locals when they passed Measure W. But that vote for the city to take control of the rolling land’s future, instead of leaving that up to the county, nowhere mentioned 11,000 homes and suburban sprawl. In fact, the measure specifically forbade housing without a new, secured water supply, which remains in doubt.

Did Holderness know who was behind The Folsom Way? Before I could think more about it, he stood up and decided to jump into the kerfuffle unfolding in the chambers. Holderness strolled over to the podium. “I’m frankly disappointed to see that two of our planning commissioners don’t have a good understanding of what their role is in our city government,” he said. “Perhaps they didn’t understand their assignment, and that’s unfortunate.”

Commissioner Mallory, who’d just finished arguing that consultants have too much power in the city, glanced wearily up and replied, “You, sir, are one of the consultants.”

Photo by Devon McMindes

Click here to read the full article.

Environmentalists Sue To Block Possible Elk Grove Expansion

June 18, 2018

By Ezra Romero

Capital Public Radio

“This is classic leapfrog development where you are building on green fields instead of brown fields,” said Alexandra Reagan with ECOS.

Reagan says the city should develop existing land within its boundaries. She also says there are 14 impacts that are unavoidable with the project moving forward. They include altering where migratory birds forage and depletion of groundwater resources.

“We feel like those should be addressed before any next steps for planning growth,” Reagan adds.

Read the full article here.

Disparate Interests Pan Elk Grove’s Expansion Plans at Sacramento LAFCo Meeting

December 18, 2017

Elk Grove News.net

Notwithstanding their 40-plus minute presentation, the City of Elk Grove was criticized at last week’s meeting of the Sacramento Local Agency Formation Commission (LAFCo) for its plans to enlarge the city. The criticisms, which were made by a variety of interests, condemned Elk Grove’s planned expansion through the sphere of influence (SOI) process.

The presentation to the LAFCo commission was made by Elk Grove assistant to city manager and planning specialist Christopher Jordan [sic] at the Wednesday, December 6 meeting. Jordan’s presentation, which was as much part history lesson and part public relations pitch, focused on the city’s state-mandated general plan update and three current SOI applications, which are the initial steps to annex property.

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During public comment, the presentation was criticized by three environmentalist, two agriculture interest, and one Elk Grove resident. There were no public comments in favor of Elk Grove’s expansion plans.

Speaking on behalf of the Mother Lode chapter of the Sierra Club, [and Co-Chair of the Environmental Council of Sacramento’s Habitat Conservation Committee] Sean Wirth noted there was nothing in Jordan’s presentations on the effects on the environment. He also opined what environmental documents included in the application were faulty.

“If this new SOI is approved outside the urban services boundary, there is going to a general belief that other areas nearby will also be able to be part of this sphere,” Wi[r]th said … [“It is going to be impossible to do conservation in that area. The effect will be that it is going to be too expensive to buy any land there.”] … .*

Wirth also noted flooding that occurs every seven to ten years on the southern portions of the city along the Cosumnes River which affect sandhill cranes. When flooding occurs, the cranes flee to higher ground and if the land is developed, they will lose habitat.

Speaking for agriculture interests was Bill Bird from the Sacramento Farm Bureau who in part echoed Wirth. Bird said agricultural uses were not taken into account and once the land is annexed, farms will be abandoned for a variety of reasons.

“When you consider all three sphere of influence amendments, you are talking about taking roughly 1,800-acres out of agricultural production,” he said. “Once these amendments are granted, the writing on the wall for farmers is crystal clear – the message is – GET OUT!”

Addressing Elk Grove’s performance regarding employment development was resident Lynn Wheat. In her comments Wheat noted there was no mention of the quality of the new jobs developed, the 2,000 promised new jobs should the Wilton Rancheria gain approval of their proposed casino will be low wage hospitality jobs, and that the Elk Grove Unified School District remains the largest employer in the city.

Wheat also noted former Mayor Gary Davis’ announcement two years ago that NRC Manufacturing, whom he called a large Silicon Valley concern, was locating to Elk Grove. Since that time NRC has not relocated any of their operations to Elk Grove.

“A firm from the Bay Area NRC was to come a couple of years ago,” Wheat said. “Since it was presented to our city council and spoken about we haven’t heard anything, so the joke in our community is N R C stands for not really coming.”

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Click here to read the full article.

Click here to read the comments the Environmental Council of Sacramento have submitted on these attempts by Elk Grove to enlarge their city.

*This sentence was originally misquoted and the meaning was unclear. It was corrected for the purpose of this post.

Friends of the Swainson’s Hawk Letter re Airport is no place for hawk preserve, May 29, 2017

This is where Sacramento plans to put nearly 3,000 new homes, by Tony Bizjak, May 30, 2017, The Sacramento Bee

Advocates for the Swainson’s hawk, listed as threatened by the state, are unhappy with the habitat mitigation land chosen for the hawks, which is an orchard west of the airport, adjacent to the Teal Bend golf course. Advocate Jude Lamare said the site is too close the airport, where 11 Swainson’s hawks have been counted as hit and killed by jets in the last four years.

The hawks forage in various places around the Natomas basin, but, as development continues, nesting areas will be reduced, forcing more birds into limited sites, including the one next to the airport. “If you are picking a ‘forever’ home for threatened avian species, it would not be next to a runway,” Lamare said. “You are squeezing the species down.”

A Message from Judith Lamare, President of the Friends of the Swainson’s Hawk, a member organization of Habitat 2020/ECOS. May 29, 2017

Here is a text you can copy and email to urge the City to reject the Moody Preserve as part of the Greenbriar project. Use this in the Subject line of your email: Item 19 May 30, 2017: No Hawk Preserve Next to Airport

Dear City Leaders:

Please reject the proposed Moody Preserve as part of the Greenbriar Project at your meeting on Tuesday May 30. (Agenda Item 19)
The property is about 600 feet from the Airport’s west runway.
Eleven Swainson’s Hawks have been listed as fatalities in the FAA bird strike data base for SMF between 2013 and 2016.
Airport operations are expected to grow by 30 percent over the next twenty years.
This is the wrong location to preserve in perpetuity for conservation of a threatened bird species.
Please require the Greenbriar developer to provide another mitigation site that offers more protection to the Swainson’s Hawk, listed as threatened under state law.

The email string to use is:
MayorSteinberg[at]cityofsacramento[dot]org, Angelique Ashby <aashby[at]cityofsacramento[dot]org>, Allen Warren <awarren[at]cityofsacramento[dot]org>, Jeff S. Harris <JSHarris[at]cityofsacramento[dot]org>, Steve Hansen <SHansen[at]cityofsacramento[dot]org>, Jay Schenirer
<jschenirer[at]cityofsacramento[dot]org>, Eguerra[at]cityofsacramento[dot]org,”Lawrence R. Carr” <Lcarr[at]cityofsacramento[dot]org>, Rick Jennings <rjennings[at]cityofsacramento[dot]org>, clerk[at]cityofsacramento[dot]org,swainsonshawk[at]sbcglobal[dot]net

Thank you for your help in averting a bad decision on conservation for our threatened wildlife.

Judith Lamare, President
Friends of the Swainson’s Hawk
www.swainsonshawk.org
swainsonshawk[at]sbcglobal[dot]net

Read the letter from the Environmental Council of Sacramento, Habitat 2020 and Friends of the Swainson’s Hawk here.

Greenbriar: where Sacramento plans to put nearly 3,000 new homes, by Tony Bizjak, May 29, 2017, The Sacramento Bee