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

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Jackson Township DEIR Comments

On October 31, 2019, Environmental Council of Sacramento (ECOS), Habitat 2020, 350 Sacramento, and Sierra Club provided comments on the Jackson Township Draft Environmental Impact Report (EIR). Below are some excerpts from the letter, followed by a link to the letter in full.

Agricultural Resources

There is insufficient mitigation for farmland lost in the Jackson Township Specific Plan DEIR [Draft Environmental Impact Report]. By converting all this farmland to urban/suburban uses, the GHG emissions will increase due to the increased number of motor vehicle trips (more vehicle miles traveled). Moreover, loss of agricultural resources will reduce the potential for carbon sequestration in the soil by application of compost or regenerative agriculture methods, in addition to the natural processes of plant growth and soil microbial action from farming. There needs to be better mitigation measures to ensure carbon soil sequestration occurs at least as much as it would if the agricultural resources were preserved.

Biological Resources

Use of the South Sacramento Habitat Conservation Plan (SSHCP) was offered as one of the options for dealing with California Endangered Species Act (CESA) and Federal Endangered Species Act (FESA) impacts, and it was clearly stated that the hardline preserves identified in the SSHCP conservation strategy would be provided. Since the SSHCP now has its permits and is in the implementation phase, we are assuming that the Jackson Township will be affected by and compliant with the SSHCP.

Climate Change

We appreciate the opportunity to comment on Chapter 9, “Climate Change”, of the County’s Jackson Township Specific Plan Draft Environmental Impact Report (DEIR). Our greenhouse gas (GHG)-related comments are presented in the following seven sections. We first discuss the County’s past GHG-reduction commitments, because the DEIR:
I. does not accurately describe County climate planning;
II. uses inappropriate baseline data based on past planning;
III. applies inappropriate thresholds of significance; and
IV. is inconsistent with the County’s 2011 General Plan Update, associated Final Environmental Report (GP/FEIR), and Phase 1 CAP.
We also present,
V. other DEIR-related concerns.
We conclude:
VI. the DEIR is legally insufficient
VII. the County’s failure to provide promised mitigation is contrary to the General Plan.

Click here to read the letter in full
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5

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SMUD Roseville Water Transfer comments

On September 10, 2019, the Environmental Council of Sacramento and Habitat 2020 sent a letter to Sacramento Metropolitan Utilities District (SMUD) a letter regarding a proposed water transfer between the City of Roseville and SMUD. Below are some excerpts from the letter, followed by a link to the letter in full.

Recently the Environmental Council of Sacramento and Habitat 2020 became aware of the pending temporary water transfer between the City of Roseville and SMUD. Our review of the environmental assessment and decision document prepared by the Bureau of Reclamation found specific deficiencies in the analysis and a casual dismissal of the transfer’s cumulative significance. We believe that the proposed transfer of water does not contain the necessary safeguards to protect Lower American River fisheries. We request that the SMUD Board direct its staff to include provisions in the contract that will address these concerns.

We believe the transfers must be governed by the standards and requirements contained in the Modified Flow Management Standard. These standards and requirements would much better ensure that the transfer would not negatively impact the American River flow and temperature standards.

Click here to read the full letter.

Photo by George Nyberg of the American River

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