Sacramento Region Highway CapCity Projects

On October 3, 2018, the Environmental Council of Sacramento (ECOS) sent the following letter to the California Department of Transportation regarding the Sacramento Region Highway CapCity Projects.

Dear Director Benipal:

The Environmental Council of Sacramento (ECOS) is concerned that planned freeway expansions in the Sacramento region will induce major increases in vehicle volumes, contravening the spirit and intent of state legislation such as SB 375. We are most concerned about the CapCity (SR 51) expansion (including possible widening of the American River bridge), and also concerned about the planned I-5 HOV lanes between Sacramento and Elk Grove, and the proposed widening of I-80 between Sacramento and Davis.

We appreciate the CapCity project team’s continued engagement with ECOS and its willingness to discuss the project’s progression. However, ECOS would like to expand this conversation into a broader discussion about regional transportation challenges and priorities. We are willing to work with Caltrans staff to coordinate discussions with other regional agencies and stakeholders with the aim of considering potential alternatives to address these challenges.

Following are some reasons why this conversation is timely: CARB’s greenhouse gas scoping plan shows that we must reduce VMT by 15% to meet 2050 goals for GHG emissions. Guidelines for SB 743 specify that the principal criterion in evaluating transportation projects is now VMT reduction, as opposed to congestion relief. Based on these Guidelines, Caltrans will need to consider induced travel demand from future expansion projects, such as caused by land use impacts. The Sacramento Transportation Authority is planning a tax measure for the 2020 ballot. SACOG is developing its draft preferred scenario the 2020 MTP/SCS. Finally, the fate of SB 1 hinges on the outcome of Proposition 6 in November.

The proposed CapCity expansion is emblematic of multiple other prospective projects in the region, and raises questions about historic approaches to longstanding problems as well as approaches to future challenges the region faces. We acknowledge that the challenges involved are significant, and that a rethinking of potential solutions also has great hurdles. We believe that the convergence of challenges and opportunities we face warrants an exploration of additional tools to increase travel-mode options, support infill housing and economic needs, and reduce VMT with increased transit operations and emerging strategies such as congestion pricing and shared mobility.

We would all benefit from a broadly based conversation regarding alternative solutions for regional mobility before major public funds are committed to significant increases in highway capacity. We hope that you will consider cooperating in such a discussion with ECOS, and we are sharing this letter with other organizations and government bodies that we hope to include in this conversation as well. We look forward to discussing possible meeting times and locations.

Sincerely,

Ralph Propper
ECOS President

Click here to read the full letter in PDF.

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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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ECOS Comments on the Folsom General Plan

On June 25, 2018, ECOS submitted our comments/testimony on the latest changes to the City of Folsom’s General Plan.

Here is an excerpt:


ECOS and Habitat 2020 are greatly relieved to see that the Study Area for new City growth south of White Rock road has been removed from the General plan.

Further growth in this area would pose potentially un-mitigatable impacts to invaluable agricultural and biological resources and severely inhibit successful implementation of the South Sacramento Habitat Conservation Plan (SSHCP), currently in its final phase of adoption after decades of development.

Further growth in this area would be critically 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.

Finally, ECOS is extremely concerned about the ability of the City to supply adequate water supplies to this potential growth area, or any new expansion area. With the decision to supply the City’s current expansion south of US 50 solely with conservation efforts of existing supplies, it is apparent that the City has fully allocated those supplies. We remain concerned that the City will not be able to supply the current expansion area without severe burdens on existing residents with the mandatory cut-backs in supply that the City is subject to in Dry and Extremely Dry years. We have not seen evidence that the City has yet acquired back up supplies to prevent these burdens, and given this, it is extremely difficult to see how the City could speculate on further expansion of their footprint.


Click here to read the full comment letter.

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