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

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?

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.

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.

Suit filed to block step toward annexation of land by Elk Grove

June 5, 2018

By Ben van der Meer

The Sacramento Business Journal

A coalition of environmental groups has filed suit to block a step that the city of Elk Grove must take before it can annex more than 1,100 acres to the south.

The plaintiffs, led by the Environmental Council of Sacramento, filed suit in Sacramento County Superior Court alleging that an environmental impact report for the move doesn’t adequately address impacts on water, loss of farmland and at-risk species such as the sandhill crane and Swainson’s hawk.

The suit also claims that the Sacramento Local Agency Formation Commission went against its stated policies to discourage sprawl when it approved a sphere-of-influence amendment for Elk Grove earlier this year.

. . .

Click here to read the full article.

Lawsuit filed on Elk Grove Sphere of Influence

June 1, 2018

Sierra Club, ECOS, et al. File Legal Action to Reverse Sacramento Local Agency Formation Commission (LAFCo) Approval of Expansion of Elk Grove Sphere of Influence

On June 1, 2018, the Environmental Council of Sacramento, Sierra Club, Friends of Swainson’s Hawk, Friends of Stone Lakes Wildlife Refuge and Habitat 2020 filed an action to block Sacramento LAFCo’s approval of an expanded Sphere of Influence for the City of Elk Grove.  “Numerous legal errors occurred in the Commission’s consideration and approval on a 4-3 vote of this landowner*-initiated amendment to Elk Grove’s potential boundary. The decision permits previously protected farmland to now be considered for annexation into the City,” said Don Mooney, attorney for the environmental groups.  “My clients represent the public interest in curbing sprawl and preserving farmland in this region.”

The Sierra Club, Environmental Council of Sacramento (ECOS) and associates have long maintained that the health and sustainability of the Sacramento region depends upon the preservation of farmland and avoidance of further urban sprawl.  “LAFCo has pivoted away from long established regional goals with this approval,” said Sierra Club Mother Lode Chapter Conservation Chair Sean Wirth,” and we aim to hold them accountable.  All of our region’s planning for infrastructure, the Regional Transportation Plan, the South Sacramento Habitat Conservation Plan, water supply, sanitation, and the Air Quality Plan are based on an Urban Services Boundary that LAFCo pushed aside in its February 7 decision.  This blatant disregard for decades of careful planning must be challenged.”

Ralph Propper, President of ECOS, noted that “Although the Sphere of Influence Amendment is just the first step in urbanization  ­—no dirt will be turned soon—, the Environmental Impact Report identified 22 significant and unavoidable impacts from this decision that cannot be mitigated.  This is a damaging land use decision that threatens the health of our community.”

Jim Pachl, Sierra Club Mother Lode Chapter Legal Chair, pointed out that “there are over 4000 vacant acres zoned for new development within the City of Elk Grove, including 1800 acres with residential project approvals that remain unbuilt.  Some projects were approved over ten years ago and remain unbuilt.  Lent Ranch Mall remains a half-built shell.  LAFCo lacks a legitimate reason to allow a conversion of farmland for expansion of Elk Grove’s footprint.”

LAFCo denied a request to reconsider its decision on May 2, setting the stage for the filing of litigation. 

*The Sphere of Influence Amendment was sought by landowners of 1,156 acres south of Kammerer Road and west of Highway 99.  The applicants are Gerry Kamilos and Martin Feletto.

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Pitch In!

Lawsuits are pricey! If you would like to provide monetary support for this, you can donate online HERE OR send a check to the Environmental Council of Sacramento, P.O. Box 1526, Sacramento, CA 95812. Please include a notation “for Elk Grove lawsuit” in the memo field of Paypal or your check to ensure that your donation goes to the lawsuit.

In The News

Suit filed to block step toward annexation of land by Elk Grove
June 5, 2018
The Sacramento Business Journal
https://www.bizjournals.com/sacramento/news/2018/06/05/suit-filed-to-block-step-toward-annexation-of-land.html

Environmental Groups File Lawsuit Against Sacramento LAFCO, Seek to Halt Elk Grove Expansion
June 5, 2018
ElkGroveNews.net
http://www.elkgrovenews.net/2018/06/environmental-group-files-lawsuit-against-elk-grove-expansion.html

Environmentalists sue to block city’s southern expansion
Elk Grove Citizen
June 8, 2018
http://www.egcitizen.com/news/environmentalists-sue-to-block-city-s-southern-expansion/article_e06d57f0-6b55-11e8-a42c-274a961568ea.html

More Information

Click here for the project application.

Click here for more background information on this issue.

Click here for a PDF of the media advisory.