Elk Grove General Plan

On September 26, 2018, the Environmental Council of Sacramento submitted a comment letter on the Elk Grove General Plan.

Summary

Following ECOS and Habitat 2020s’ opposition to the recently adopted Kamerrer-99 Sphere of Influence Expansion, ECOS and Habitat 2020 are primarily concerned with the “study areas” for further expansion proposed in this General Plan Update. Elk Grove’s anticipated growth can be accommodated within the existing City limits, and we find no justification for expansion beyond the Sacramento County Urban Services Boundary (USB) established in 1993 to be the ultimate growth boundary within the County. The proposal is inconsistent with the Sacramento Area Council of Governments’ (SACOG) Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) for meeting State mandated greenhouse gas (GHG) reductions, Federal mandates for Air Quality Attainment under the State Improvement Plan (SIP), as well as myriad regional goals for social equity, public health and natural resource conservation. There is an extreme lack of certainty that municipal water can be provided to this area without severe regional impacts, and the impacts to invaluable agricultural and biological resources by the proposal are potentially impossible to mitigate.

The justification given for study of further expansion is the need for Elk Grove to correct its job’s housing balance. This is a goal that ECOS agrees with, but, again, the housing and employment that Elk Grove anticipates to achieve from existing planning areas within the current City boundaries already far exceed that of SACOG’S projections for Elk Grove by 2040. If Elk Grove were to achieve these housing and employment projections in the SOIA as well, it would certainly have impacts on housing and employment in neighboring jurisdictions in the region.

While these proposed expansion areas are only “study areas,” it is irresponsible of the City to signal intent for growth that is so divergent from the regional plan, and where the cumulative impacts to the region would be so great.

Click here to read the full letter in PDF.

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Gas stations and pot businesses not welcome, Sacramento says. Here’s where and why

By Tony Bizjak

May 13, 2018

The Sacramento Bee

The city of Sacramento is laying plans to ban new gas stations, drive-through restaurants and marijuana cultivation businesses within a quarter-mile of light-rail stations, saying those areas should be reserved for transit-oriented and pedestrian-friendly uses.

The goal, officials say, is to boost rail ridership at 23 light-rail stations around the city and give more residents the chance of living a car-free lifestyle by paving the way for higher-density housing, job-rich offices and pedestrian-oriented retail in those areas.

Click here to read the full article.

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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.

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