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

Save Hinkle Creek

Preserving the Hinkle Creek Nature Area is vital to the success of the Hinkle Creek Center. The Hinkle Creek Center was built with a $740,000.00 public investment and a promise that the Hinkle Creek Center Nature Area would be preserved to interpret the natural, cultural and historical resources, and provide a recreational program space.  Save Hinkle Creek is actively working with Folsom City to finally fulfill the mission and purpose of the Center with upcoming nature, history and cultural programs, as well as guided hikes. Cutting down the oak woodland would greatly diminish the many stories waiting to be brought to life and enjoyed by everyone. The trees are our past, present and future!

HOW YOU CAN HELP!
We need all lovers of trees, creeks, wildlife and history to come and speak up for Alternative #1, the no-dig, increased maintenance and monitoring alternative, which ensures that the existing sewer line is maintained to the highest degree while still preserving the Hinkle Creek Nature Area.

The Folsom City Council meeting is on Tuesday, September 10 at 6:30 p.m.
Located on 50 Natoma Street, Folsom, CA 95630.

If you cannot attend the meeting, please contact the City Council members and simply state:
“I support Alternative #1, the no-dig, increased maintenance and monitoring alternative, to save the oak trees in the Hinkle Creek Nature Area. As far back as 1984 the value of this creek corridor was recognized by the Folsom City Parks and Recreation Commission along with the local neighborhood associations, and it remains just as important, if not more so today.”

For more detailed information on Hinkle Creek, please go to:
https://www.savehinklecreek.com/

Save the Pond at the Old Arena Site!

Sleep Train Arena Pond

August 2019

In August 2019, Christy Berger of Sacramento Heron and Egret Rescue presented to Habitat 2020 on an active wildlife habitat that has been discovered the Sleep Train Arena property in Natomas. At this time, the property is owned by the owners of the Sacramento Kings professional basketball team.

Here’s a summary from Sacramento Heron and Egret Rescue’s website:

We were stunned when we first viewed the huge numbers of herons and egrets nesting at the pond, and overjoyed that they were nesting in a much better site than in a city neighborhood like many other nesting colonies, and are safe from cars and people. But they may not be safe for long if the property owners fail to preserve the pond. Below are some views of the pond and the wildlife that call it home (there are more than just herons and egrets!) You will notice some concrete structures and rebar. We found out that this site is an unfinished baseball stadium built in 1990. Because of the high water table in North Natomas, the excavated area filled in and over the years with trees and other foliage, creating nice wetland habitat.

Learn more

Click here to visit the website of Sacramento Heron and Egret Rescue. There you can learn more about the birds living at the old arena site and why the plans for this property should include preservation of this habitat chosen by the birds themselves, rather than further destruction of their habitat opportunities.

December 2019

On December 9th, ECOS/Habitat 2020 partnered with Sacramento Heron and Egret Rescue to submit comments to the city regarding the Arco Arena Reuse Plan. Click here to view the letter.

Sign up here for email updates on the pond.

Photos by J. Roberson Photography

South American Subbasin Alternative Comments

July 25, 2019

Dear Mr. Eck:

As you are aware, ECOS and Habitat 2020 have been following the Sacramento Central Groundwater Authority’s (Authority) development of the South American Subbasin Alternative (South American Alternative), and the Department of Water Resources (DWR) review and decision regarding its acceptability under the terms and requirements of the Sustainable Groundwater Management Act (SGMA).

The letter you received, dated July 17, 2019, from DWR’s Deputy Director Taryn Ravazzini, and the accompanying staff report, form a well-reasoned determination that the South American Alternative will not satisfy the requirements of SGMA. While the Authority is given thirty days to provide information to refute DWR’s findings, it seems that devoting time to this pursuit is not in the best interest of the Sacramento region and the Authority.

Ralph Propper and Rob Burness

Full letter here.

ECOS comments on Elk Grove Hospital NOP

On June 27, 2019, the Environmental Council of Sacramento, Habitat 2020 and the Friends of Stones Lakes National Wildlife Refuge submitted a letter in response to the Notice of Preparation of an Environmental Impact Report for Northstate University Medical Center, planned for the outer edges of the City of Elk Grove, south of Sacramento.

Our concerns include: an increase in bird collisions, helicopter flight impacts on migratory birds in surrounding roosting and foraging habitat, lighting impacts, building a hospital in a floodplain, surface water runoff, cumulative impacts, compliance with our region’s Metropolitan Transportation Plan/Sustainable Communities Strategy, growth inducement and more.

Click here to read the letter in full.

Letter from ECOS Requesting that LAFCo Reconsider Approval of “Kammerer 99 SOIA” Amendment

May 1, 2018

Patrick Hume, Chair
Sacramento Local Agency Formation Commission
1112 I Street, Sacramento, CA, 95814
Via email to commissionclerk[at]saclafco[dot]org

RE: Request to Reconsider LAFCo approval of Kammerer/99 SOIA amendment

Dear Mr. Hume and fellow Commissioners:

I would like to focus on two concerns that ECOS and Habitat 2020 believe were not adequately addressed by LAFCo Commissioners in their deliberations on the Kammerer/99 SOIA Amendment: 1) Cumulative Traffic impacts and 2) County policy regarding changes to the urban service boundary established in the 1993 Sacramento County General Plan and included in the 2011 update of that plan.

1. Traffic Impacts on the SE Connector. On or about February 29, 2018 the Southeast Connector JPA released a Mitigated Negative Declaration for review and comment. The information contained in this document was not available prior to the LAFCo hearing on February 7, 2018. Among other things the document contained a comprehensive analysis of cumulative traffic impacts both with and without the proposed improvements to Kammerer Road.

Most instructive is Table 45, which shows cumulative and cumulative plus project (the road improvement project) Level of Service (LOS) on a segment by segment basis between Interstate 5 and Highway 99 (See Attachment 1). The cumulative conditions for the analysis are based on full buildout within Elk Grove City (although not taking into account casino development) and MTP/SCS traffic forecasts based on projected 2036 development outside of Elk Grove City. This table reveals a number of important points:

• The cumulative conditions for the various segments are based on a minimum of 4 lanes of traffic, rather than the 2 lanes in the LAFCo RDEIR. Our understanding is that the JPA’s intent is to build the 4 lanes with the proposed project, but if funding is short, the project may be phased with just two lanes at first. If so, the expansion to 4 lanes would occur with funding from impact fees on new development collected by the city of Elk Grove (communication from Matt Satow, project engineer)/

• The daily traffic volume for the segments between Bruceville and Promenade Parkway range between 13,740 and 38,300. This compares to an estimated 29,719 vt/d in the RDEIR for Kammerer/99 SOIA.

• The Cumulative Plus Project conditions in Table 45 yield considerably higher daily volumes along the same stretch of roadway. This is largely the induced traffic demand that connecting Kammerer Road to Interstate 5 will generate.

• The segments west of Bruceville are projected to accommodate 28,000 to 32,000 vt/d. Some of these vehicle trips will originate and end from the north on Bruceville; others will continue eastward toward Highway 99.

• Traffic volume in the Cumulative Plus Project scenario for the segments east of Bruceville are projected to increase between 6,300 and 18,240 vt/d, with the amount of increase decreasing from west to east.

• The level of service with the Cumulative Plus Project actually declines along all segments except one. For one segment, the decline is to LOS E.

This analysis does not include either the Bilby or Kammerer/99 requests. It is logical to assume that taken together, these projects would cause traffic levels on Kammerer/99 to increase LOS along much of the SE Connector between Highway 99 and Interstate 5 to unacceptable levels.

It is clear from the comments of LAFCo Commissioners that the presence of the proposed Southeast Connector was a significant justification for approving the project. This new information, not available at the time of decision, raises the important question that the Kammerer/99 SOIA, particularly when taken into consideration of the soon to be heard Bilby Ridge SOIA, will create significant congestion and challenge the ability of the Connector Project to meet its primary goal: to provide an alternative means for travelers to circumvent the congestion of the Sacramento Urban Area by travelling around the southeast periphery of the developed urban area.

We recognize that Mitigation Measure 3.24-1a requires traffic studies and plans for improvements to mitigate traffic to acceptable levels prior to approval of annexation. Yet there has been no discussion in the record as to what the scope of those improvements might be and how they relate to the purpose of the Southeast Connector as a regional road designed to move traffic between Interstate 5 and Highway 50. For a threshold decision regarding urban growth, this is a glaring omission.

In this light, reconsideration of the project is warranted. At a minimum, LAFCo commissioners should ask for an analysis and report back from the Southeast Connector JPA on the impacts of the projects before the Commission, with additional traffic analysis as necessary to be funded by the applicants. Moreover, we would recommend that reconsideration should be considered at the same time and with the available analysis of the Bilby Ridge project, so as to better evaluate the full scope of traffic impacts on the Southeast Connector.

2. Consistency with Sacramento County Land Use Policy LU-127. Our second point is not so much a matter of new information as it is a glaring oversight on the part of LAFCo commissioners not only in framing their decision, but in making the overriding considerations for approving the project in light of 22 significant and unavoidable adverse impacts.

The RDEIR for Kammerer/99 SOIA does identify policy LU127, which reads as follows:

Policy LU-127: The County shall not expand the Urban Service Boundary unless:
• There is inadequate vacant land within the USB to accommodate the projected 25 year demand for urban uses; and
• The proposal calling for such expansion can satisfy the requirements of a master water plan as contained in the Conservation Element; and
• The proposal calling for such expansion can satisfy the requirements of the Sacramento County Air Quality Attainment Plan; and
• The area of expansion does not incorporate open space areas for which previously secured open space easements would need to be relinquished; and
• The area of expansion does not include the development of important natural resource areas, aquifer recharge lands or prime agricultural lands;
• The area of expansion does not preclude implementation of a Sacramento County-adopted Habitat Conservation Plan;

OR

• The Board approves such expansion by a 4/5ths vote based upon on finding that the expansion would provide extraordinary environmental, social or economic benefits and opportunities to the County.

If this expansion request was before the County this is the policy that would guide decision-making regarding SOIA. We recognize that the policy does not bind the decisions of the City of Elk Grove, nor does it strictly bind Sacramento LAFCo decisions. Yet in many ways the policy gets to the heart of LAFCo’s mandates to consider the need for expanding jurisdictional spheres, to protect prime agricultural demand and to ensure adequate services.

Yet, surprisingly, the RDEIR finds that the proposed SOIA is consistent with the policy under the self-limiting logic that no land use changes are proposed that would require expanding the USB:

Consistent: The SOIA Area is currently within the jurisdiction of the County of Sacramento and is entirely outside of the County’s General Plan USB. However, no land uses changes are proposed that would require expanding the USB.

That is entirely beside the point. The simple fact is that approval of the SOIA would lead to the inevitable urban development that the USB is designed to limit. The question at hand is whether the proposed SOIA, if implemented, would be consistent with the county’s policy. We believe that we have provided ample evidence that it would not be. Both the RDEIR and the Commissioners’ approval of the project are deficient in not adequately taking this into account.

Note that Policy LU-127 does give guidance on when it would be appropriate, despite the required findings, to approve USB expansion. They can, by a supermajority vote, find that the expansion would provide extraordinary environmental, social or economic benefits and opportunities to the County.

So it would stand to reason, that LAFCo commissioners might want to consider the same context in their decision regarding the Kammerer/99 SOIA’s approval. Yet what we heard at the meeting were the same “business as usual” types of justifications for approving the project: Elk Grove needs to grow, the project will provide jobs, new development will help Elk Grove improve its job’s housing balance and the like. These are reflected in the Findings of Fact and Overriding Concern, which were not made available to the public until just prior to the hearing, without adequate opportunity for public review and consideration. Nowhere can we find, in either the written or the spoken comments at the hearing, that there were any extraordinary benefits for approving the project despite its inconsistency with County Policy, LAFCo mandates and common sense.

Moreover, your Commission’s decision, in starting the process to allow Elk Grove’s expansion beyond the USB, provides justification to not only Folsom in the area south of its current limits, but the County itself, in the huge North Precinct Development, to justify expansion of the Urban Service Boundary, entirely in the absence of any extraordinary justification, thus continuing the cycle of sprawl many citizens in this County are dedicated to ending.

In view of this, and if for no other reason, we ask that you reconsider your justification and your findings in approving the project.

Sincerely,

Robert Burness, Habitat 2020 Co Chair
Attachments


Click here for a PDF of this letter.

Click here for more background on this issue.