Area of “The Boot,” aka the Upper Westside Specific Plan site
February 24, 2019 [UPDATE]
On Tuesday, February 26, 2019 at 2:15 pm, the County of Sacramento Board of Supervisors will consider starting a master plan process to urbanize 2,000 acres of prime agricultural land in Natomas (covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake). If possible, please attend the hearing. Please send a note to the Board (emails below) opposing this expansion on Farmland. Suggested language follows.
I oppose development of farmland in Sacramento County and ask you to deny the request to create an Upper Westside Master Plan for 2000 acres in the Natomas “Boot.” My reasons are:
This proposal violates County General Plan policies, including the Urban Services Boundary and agricultural preservation policies, to preserve agricultural and open space lands in the County.
There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized. There is no economic need to provide for more zoning for urban uses.
There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin and these projects have a Habitat Conservation Plan in place to mitigate for their impacts on wildlife and are included in regional air quality and transportation plans. There is no economic rationale for advancing development in the portion of the basin that lacks infrastructure and mitigation programs.
I support the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan and directly conflict with the preserves located in and adjacent to the plan area.
Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
Landowners in the Boot area of North Natomas have asked the Sacramento County Board of Supervisors to start the legal process needed for approval of a development plan for 2000 acres of urban development in the County covering most of the existing farmland between the City limit and Sacramento River, south of Fisherman’s Lake.
The proposal directly contradicts and would undermine the Natomas Basin Habitat Conservation Plan (NBHCP) which covers the entire Natomas Basin. This plan — a binding contract between the city of Sacramento and County of Sutter and the state and federal wildlife agencies — relies in part on the Boot continuing to remain in agriculture and open space. It protects the Swainson’s Hawk population which nests along the Sacramento River and forages for rodents in the Basin, including the Boot area. The 2001 Natomas Basin Habitat Plan designates the mile-wide strip of land, in County jurisdiction, next to the Sacramento River levee as the Swainson’s Hawk Zone, which must remain free of urban development for the HCP to succeed.
Most of the proposed Boot development would be within the Swainson’s Hawk Zone. The City’s Incidental Take Permit (issued by USFWS and CDFW) for new development in North Natomas depends on the continued integrity of the NBHCP, including continuation of agriculture and open space in the Swainson’s Hawk Zone, and would be jeopardized by new development in the Boot.
Bob Thomas, who is the project representative, was formerly the City Manager who signed the NBHCP Incidental Take Permit as City Manager, and is very aware of the importance of the Swainson’s Hawk Zone, including the Boot area, to conservation of threatened species and the City’s buildout of North Natomas.
Please help us convince the County Board of Supervisors to deny this request. Letters to the Board members can include these important points:
Urbanization planning in the Natomas Basin is contrary to important County General Plan policies, including the Urban Services Boundary, and policies to preserve agricultural and open space lands in the County.
The Urban Services Boundary (which excludes urbanization in this area) is the basis for our regional air quality and transportation plans which protect our health and prevent the congestion that urban sprawl engenders. This is our region’s core strategy for Climate Action and mitigation for Climate Change.
There are thousands of acres of vacant land inside the Urban Services Boundary in the County where future urban development is already authorized, and thousands of acres of vacant land already zoned for development. There is no economic need to provide for more zoning for urban uses.
There are thousands of vacant acres approved for development in the City and Sutter County portions of the Natomas Basin. These projects have planned infrastructure and mitigation programs. There is no economic rationale for considering development in the portion of the basin that lacks infrastructure and mitigation programs.
Express your support for the Natomas Basin Habitat Conservation Plan. Urbanization of the Boot area would undermine the effectiveness of the Natomas Basin Habitat Conservation Plan. Ask the Supervisors to endorse the Natomas Habitat Conservation Plan as the best plan for the Boot.
For residents of Natomas, public safety, emergency evaluation, freeway and airport access and other issues may come to mind in contemplating urbanization west of El Centro and North of I-80.
The hearing is set for 9:30 am, Tuesday, Feb 26, 2019.
Send an email to the Board Clerk requesting hearing notice and notice of availability of documents: BoardClerk[at]saccounty[dot]net.
For more information on the proposal, check the County website at https://planningdocuments.saccounty.net/. Search for “Upper Westside Specific Plan” Control #: PLNP2018-00284
Swainson’s Hawk in flight
Please share this call to action with friends and family who can help.
Habitat 2020 is ECOS’ Habitat & Conservation committee. Habitat 2020 is a coalition that works to protect the lands, waters, wildlife and native plants in the Sacramento region. The great Central Valley of California has been identified by the World Wildlife Fund as one of North America’s most endangered eco-regions. Preserving its remaining open space and agricultural land is essential for sustaining native plants and wildlife, and ensuring a high quality of life for ourselves and future generations.
In 2017 Habitat 2020 had a continued engagement in a broad range of Sacramento regional environmental protection efforts that no singular organization could address alone.
These crucial activities include:
Continued promotion of the Heartland Project Vision for a regionally coordinated and connected system of parks, preserves and working lands:
Successfully negotiated a new contract in with the UCD Information Center for the Environment and the Capitol Southeast Connector JPA to continue development of the Sacramento regional natural resources data inventory and modeling project, in accordance with the ECOS-Connector JPA Settlement Agreement.
Aided in visioning and oversight of the SMUD carbon sequestration inventory for Sacramento County, the first application of the UCD-Heartland Natural Resource inventory.
Aided in the acquisition of a $600k Federal Environmental Protection Agency grant for UCD to continue a second phase of development for the natural resource inventory to cross analyze public health factors with environmental sustainability factors to better illustrate relationships between human and ecological health in the Sacramento Region.
Continued a decade-long resistance to irresponsible expansion of the City of Elk Grove in an effort to protect critical habitat for myriad species in the Cosumnes River corridor, including Sandhill Crane and Swainson’s hawk. Elk Grove is currently updating its General Plan and has three current Sphere of Influence Expansion Applications. A primary concern is the Kammerrer-99 SOI proposal, outside of the long-standing County Urban Services Boundary and the Regional Sustainable Communities Strategy. Habitat 2020 engagement and commentary has so far led to the decision to recirculate the Draft Environmental impact report to better address important concerns raised with the EIR’s initial analysis. The Final EIR has recently been released and great concerns for the project remain. The Local Agency Formation Commission hearing to consider approval of the project is scheduled for February.
Continued critical representation of the environmental community in development of the final South Sacramento Habitat Conservation Plan and Environmental Impact Report and Statement released this year, after decades of evolution. Habitat 2020 engagement was essential to this process, being the only group to review the entire public draft of the Plan and the environmental documents, over 3300 pages. The extensive commentary Habitat 2020 has provided is aimed at correcting some long standing issues that remain before certification.
Partnered with Friend’s of the Swainson’s Hawk to negotiate an agreement with the City of Sacramento to preserve the integrity of the Natomas Basin Habitat Conservation Plan in mitigation of their approval of the Greenbriar project.
Provided expert testimony to the ongoing CA WaterFix hearings concerning important terrestrial impacts posed by the proposed Delta tunnels project with H2020 partners, including Friends of Stone Lakes National Wildlife Refuge and SOSCranes.
Tracked initial local implementation of the Sustainable Groundwater Management Act, offering in depth commentary on the pros and cons of the Sacramento Central Groundwater Authority’s proposed Groundwater Management Plan Alternative, with the aim to outline a constructive path forward to address current deficiencies with increased public participation and oversight. We continued our active presence at the Environmental Caucus of the Water Forum, and this last year Ted Rauh of our Water Group became an alternate South Central Groundwater Committee Board member representing environmental interests.
H2020 Partner, SOS Cranes, continued participation in the Statewide Sandhill Crane Conservation Strategy Technical Advisory Committee in development of a plan due for release in 2018.
Continued participation in the Sacramento Area Council of Governments “Sounding Board” advisory committee for development of the 2020 Metropolitan transportation Plan Sustainable Communities Strategy (MTP/SCS), emphasizing the need for smart, more compact regional growth that simultaneously provides greater, more equitable access to non-auto modes of travel, and preserves natural and agricultural resources. Habitat 2020 has also offered important representation in the SB 375 target revision process currently underway at the CA Air Resources Board, with an aim to determine the most ambitious GHG reduction targets feasible for the Sacramento Region’s MTP/SCS.
Supported Audubon Society efforts to preserve essential Purple Martin nesting habitat in the City of Sacramento’s I St bridge replacement project.
Supported International Dark Sky Association recommendations to the Cities of Sacramento and West Sacramento for reducing light impacts to aquatic and terrestrial habitat on the Sacramento Riverfront.
Supported Folsom community residents in a campaign to develop an alternative plan for storm/waste water infrastructure improvements to minimize impacts to Hinkle Creek and its surrounding forest.
Coordinated broad regional stakeholder input into a robust set of recommendations for the City of Sacramento for the consideration of investment in a regional educational facility focused on the region’s unique natural resources.
We want to take a moment to highlight some the Environmental Council of Sacramento’s (ECOS) accomplishments this year and inform you about current activities and challenges moving into the New Year. We know these are challenging times but we hope you can find some encouragement in how our local advocacy makes a difference throughout the Sacramento Region.
For the countless number of Californians affected the horrendous wildfires or threatened by too little or too much water, this year has not been a happy one. ECOS usually focuses on guarding against environmental assaults unique to Sacramento County, but climate change is increasingly impacting everyone, whether local residents or not. Over the past year, ECOS has been increasingly proactive in building our relationships with, and holding accountable, our local elected officials, while educating them about environmental problems and effective solutions.
2017 began with ECOS’s participation and advocacy in support of a package of ethics reform ordinances that the City Council adopted on March 21. The reforms include the creation of an independent Ethics Commission, adoption of an Ethics Code and Sunshine Ordinance to increase the accountability of elected and appointed City officials.
In response to the national debate on the role of science in federal actions, ECOS joined a coalition to organize the April 22 Sacramento March for Science that had over 15,000 participants advocating for the value of the scientific method and the need to act upon the science of climate change to accelerate the pace of greenhouse gas emission reductions.
On the implementation side, ECOS advanced our climate protection commitment by:
Successfully advocating as part of a local government, business, and nonprofit coalition for the award of $44 million from the Volkswagen settlement agreement to the City of Sacramento for the construction of electric vehicle charging stations and acquisition of EV fleets to be stationed in disadvantaged neighborhoods and managed by local nonprofits in car sharing programs;
Participated in the planning and production, led by 350 Sacramento, of the “Leading the Way to Carbon Zero Community Forum” on May 13; and
Tracked and provided testimony on the development and updating of climate action plans by the County of Sacramento and local cities.
With the economy continuing to improve, land use projects of increasing size and adverse environmental impact were proposed within the county in 2017. Some are new – such as the Natomas North Precinct community proposal (5,700 acres, 55,000 proposed new residents) – and some are novel configurations of previously defeated proposals, such as the latest Elk Grove Sphere of Influence application. With the increasing need to accommodate new residents in ways that will limit increases in greenhouse gas emissions, these business-as-usual land use designs undercut the gains made by a growing number of residents who are investing in climate change solutions through the retrofitting of residences with solar panels and the replacement of fossil fueled vehicles with electric cars.
In addition to highlighting the adverse environmental impacts of these proposals, ECOS is working hard to protect high value lands before they become targets for development. We have played a major role in pushing adoption of the South Sacramento County Habitat Conservation Plan to the finish line after more than a decade in development. Furthermore, in conjunction with our member partners, we protected the Greenbriar settlement agreement through tough negotiations to ensure that the integrity of the Natomas Basin Habitat Conservation Plan was preserved.
Via our settlement agreement that protects against leap-frog development along the proposed Elk Grove – Folsom Connector, we acquired funding for the mapping of important habitat and open space lands in Sacramento County. To further this effort, we have partnered with UC Davis through a U.S. EPA grant in the development of a habitat inventory and health benefit assessment project. When the regional natural resources data inventory and modeling project is complete, and as funds become available, it will facilitate the identification of critically important lands to protect through future acquisition or conservation easements.
In the transportation arena, ECOS is similarly working proactively to increase mobility while reducing environmental impacts. When Caltrans failed to correct deficiencies in its review of impacts from the construction and operation of additional lanes on Highway 50 between I-5 and Watt Avenue (despite our repeated comments), we challenged the project’s environmental impact report in court.
The above matters represent only a portion of our 2017 activities. We remain engaged on many fronts including issues such as future transportation funding options, Phase 2 hearings on the California WaterFix, and engagement on local implementation of the Sustainable Groundwater Management Act and many more.
Our annual events like Sacramento Earth Day, Environmentalist of the Year and the Wild and Scenic Film Festival represent the core of our annual funding but we need your help to bridge the final budget gap. Although dedicated volunteers complete much of our work, we are significantly enhanced by the logistical support provided by two part-time paid staff. Our work is made possible by your generous commitment to our region and a desire to make it a healthier and more sustainable.
This is where Sacramento plans to put nearly 3,000 new homes, by Tony Bizjak, May 30, 2017, The Sacramento Bee
Advocates for the Swainson’s hawk, listed as threatened by the state, are unhappy with the habitat mitigation land chosen for the hawks, which is an orchard west of the airport, adjacent to the Teal Bend golf course. Advocate Jude Lamare said the site is too close the airport, where 11 Swainson’s hawks have been counted as hit and killed by jets in the last four years.
The hawks forage in various places around the Natomas basin, but, as development continues, nesting areas will be reduced, forcing more birds into limited sites, including the one next to the airport. “If you are picking a ‘forever’ home for threatened avian species, it would not be next to a runway,” Lamare said. “You are squeezing the species down.”
A Message from Judith Lamare, President of the Friends of the Swainson’s Hawk, a member organization of Habitat 2020/ECOS. May 29, 2017
Here is a text you can copy and email to urge the City to reject the Moody Preserve as part of the Greenbriar project. Use this in the Subject line of your email: Item 19 May 30, 2017: No Hawk Preserve Next to Airport
Dear City Leaders:
Please reject the proposed Moody Preserve as part of the Greenbriar Project at your meeting on Tuesday May 30. (Agenda Item 19)
The property is about 600 feet from the Airport’s west runway.
Eleven Swainson’s Hawks have been listed as fatalities in the FAA bird strike data base for SMF between 2013 and 2016.
Airport operations are expected to grow by 30 percent over the next twenty years.
This is the wrong location to preserve in perpetuity for conservation of a threatened bird species.
Please require the Greenbriar developer to provide another mitigation site that offers more protection to the Swainson’s Hawk, listed as threatened under state law.
The email string to use is: MayorSteinberg[at]cityofsacramento[dot]org, Angelique Ashby <aashby[at]cityofsacramento[dot]org>, Allen Warren <awarren[at]cityofsacramento[dot]org>, Jeff S. Harris <JSHarris[at]cityofsacramento[dot]org>, Steve Hansen <SHansen[at]cityofsacramento[dot]org>, Jay Schenirer
<jschenirer[at]cityofsacramento[dot]org>, Eguerra[at]cityofsacramento[dot]org,”Lawrence R. Carr” <Lcarr[at]cityofsacramento[dot]org>, Rick Jennings <rjennings[at]cityofsacramento[dot]org>, clerk[at]cityofsacramento[dot]org,swainsonshawk[at]sbcglobal[dot]net
Thank you for your help in averting a bad decision on conservation for our threatened wildlife.
Advocates for the Swainson’s hawk, listed as threatened by the state, are unhappy with the habitat mitigation land chosen for the hawks, which is an orchard west of the airport, adjacent to the Teal Bend golf course. Advocate Jude Lamare said the site is too close the airport, where 11 Swainson’s hawks have been counted as hit and killed by jets in the last four years.
The hawks forage in various places around the Natomas basin, but, as development continues, nesting areas will be reduced, forcing more birds into limited sites, including the one next to the airport. “If you are picking a ‘forever’ home for threatened avian species, it would not be next to a runway,” Lamare said. “You are squeezing the species down.”
On May 31, 2016, the Environmental Council of Sacramento (ECOS), Habitat 2020 and the Sierra Club Sacramento Group submitted a comment letter on the Natomas North Precinct Master Plan Notice of Preparation. You can read the letter in text below, or view the PDF by clicking here or the image of the letter at the bottom of this page.
Department of Community Development Planning and Environmental Review Division
827 7th Street, Room 225, Sacramento, CA 95814
SUBJECT: NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE NATOMAS NORTH PRECINCT MASTER PLAN (CONTROL NUMBER: PLNP2014-00172)
Dear Ms. Hack:
These are comments from the Environmental Council of Sacramento (ECOS), with dozens of individual members and organizational members in the tens of thousands. ECOS has a history of over 4 decades of advocacy to limit sprawl, preserve agriculture, habitat and open space, and improve the quality of life while supporting growth with a vibrant and equitable economy. These comments relate to all the requested entitlements, and the Project Objectives found on NOP, pages 3-4, Objectives 1-6, except where noted.
Land Use, Transportation, Air Quality, Climate Change
The proposed Master Plan is obviously inconsistent with the Metropolitan Transportation Plan / Sustainable Communities Strategy (MTP/SCS) and with the Regional Air Quality Attainment Plan. The DEIR must include a full analysis and discussion of the project’s inconsistency with the MTP/SCS and the Regional Air Quality Attainment Plan. How this inconsistency will be mitigated (e.g., with strict project phasing) must also be addressed.
Since the proposed project is inconsistent with the MTP/SCS and the State’s mandates under SB 375 to reduce greenhouse gas emissions, the project must also, by definition, be inconsistent with the County’s Climate Action Plan. If this plan is to have any value, this inconsistency must also be addressed and mitigated.
The above inconsistencies are critically important since the project, as proposed, is a totally auto-oriented community. Regional Transit will not have the ability for many years, if ever, to provide service to this area at the proposed densities. Therefore it is critically important to establish a Transportation Services District, similar to what exists in North Natomas and portions of the Southeast County, to provide funding for transit service, connectivity and other transportation-related services.
It is important that the EIR, as a tool in assessing impacts, provide information which allows all interested parties and decision-makers to ascertain the level/degree of consistency/inconsistency with critical land use policies. The EIR must fully evaluate consistency with Sacramento County General Plan Policy LU-127. Any finding of inconsistency must be explained and where appropriate quantified, particularly with respect to the crucial finding pertaining to available holding capacity.
In addition to analysis of the “No Project” alternative, there should also be an examination of the alternative that 55,000 people will, indeed, move to Sacramento County, but will choose to reside elsewhere, say, in the northern and central portions of the City of Sacramento, choosing infill locations that are already zoned for residential development of the same or higher density as that proposed in this project. It is widely reported that modern homebuyers are preferentially seeking more compact, urban locations than large-lot, suburban locations. The continuing demand for compact, urban of housing is further bolstered by the history of the recent foreclosure crisis: while homes in Elk Grove and Natomas literally could not be given away, homes in the central city lost very little value, and recovered these losses (and then some) before any other locations did. While such an alternative may not be the preference of these developers, neither is the “No Project” alternative. But the “No Project” alternative ignores the reality that more people are, indeed, choosing to live in this region. In practical terms, if these developers end up with “No Project,” that alone will not halt the population increase. Rather, the new arrivals will live somewhere already zoned for the type of residential development they prefer. That is the comparison that should be made with the project as proposed.
The proposed project includes substantial employment and higher density residential development in order to meet General Plan policy criteria for new development at the urban fringe. The EIR must evaluate the increase in impact, particularly with respect to VMT and CO2 air quality emissions, if the development were to build out at lower, traditional levels of suburban development. The EIR must consider mitigation measures, including but not limited to phasing requirements and development moratoriums, to prevent occurrence of those adverse impacts.
There are already enough flawed assumptions in the feasibility analysis for the regional hospital to conclude that such a facility is extremely unlikely to materialize. The nation has spent the past six decades trying to reduce the ratio of hospital beds per thousand population, not increase it. Therefore, in order to properly assess the range of possible impacts of the proposed project, the EIR must include at least one alternative that does not include a regional hospital.
Water
The EIR must consider the adequacy of water to supply the development. A conclusion that the “project will be supplied by surface water supplemented with groundwater withdrawals” is inadequate. State Water Board approval of Natomas Central Mutual Water Company surface water rights from agricultural to municipal/industrial (M/I) use should not be counted upon as a given outcome. All potential sources of surface water, constraints and obstacles to obtaining them, the timing of water delivery, the potential for delivery curtailment in dry years, and overall feasibility of supplemental surface water supplies must all be thoroughly vetted.
The project is outside of the Urban Services Boundary (USB). M/I development was not assumed as part of the studies and assumptions underlying the Water Forum Agreement. The EIR must include a comprehensive analysis of the North American River Sub-basin, taking into account the buildout of approved and planned projects in Sutter and Placer Counties. The EIR analysis must complement and support sustainable groundwater planning undertaken to implement the California Sustainable Groundwater Management Act.
The EIR must include legally enforceable mitigation measures, including but not limited to phasing requirements and moratoriums, if assumed supplemental surface water supplies are not available sufficiently in advance to forestall groundwater overdraft.
As part of this analysis, the EIR must assess groundwater quality, including the presence of chromium, manganese, iron and arsenic, and its feasibility for domestic consumption. Assessment of infrastructure costs must consider the additional cost of water treatment to remove potentially harmful levels of these and other elements in groundwater supplies.
We are aware of the drainage studies performed under the auspices of the County and others over the past two decades. We believe the drainage problems are even more complex because of additional development that has occurred or been approved since the completion of these drainage studies, including those in Sutter County. The EIR must be extremely detailed as to how adequate drainage will be achieved for this project, as well as how these drainage solutions affect the project’s ability to mitigate for any proposed take of endangered species.
Growth-inducing Effects
The EIR must evaluate growth inducing impact of extending the USB to the County Line. The analysis should include speculative land price increases in the region and the resulting impact on implementing the Natomas Basin HCP, Sacramento County’s relationship to that HCP notwithstanding. The analysis should also include the regional growth-inducing impact of this, the most populous jurisdiction in the region, acting in violation of its own general plan to expand the region’s footprint in a manner inconsistent with regional plans.
Biological Resources
As proposed, this project conflicts with the Natomas Basin Habitat Conservation Plan (NBHCP). While the County declined to become a signatory to the Plan in 2003, nonetheless the proposed development would remove vital agriculture that provides habitat and foraging for at least two endangered species. Without this acreage, mitigation for this project could be rendered inconceivable, especially since other development in the area has already been approved. Those previous approvals have not yet resulted in construction, nor have their approved mitigations been implemented. When they are, the availability of mitigation acreage for this project is nil. The EIR must be explicit about the precise acreage, timing and location of mitigation land, and must demonstrate beyond doubt how compatibility with the NBHCP and already-approved mitigation for already-entitled projects will be achieved.
Specifically, the EIR needs to analyze the impact of this proposed project on the implemented Natomas Basin Habitat Conservation Plan, including, but not limited to the following:
Analysis of impact on conservation strategy implementation in the NBHCP.
Analysis of impact on effectiveness of mitigations in the NBHCP. As an example, the NBHCP stipulates a 1:1/2 acre mitigation for terrestrial non wetland habitat loss, but this was predicated on no additional development beyond that covered in the NBHCP within the basin.
Analysis of the impact on “feasibility for acquisition” for the lands needed within the available inventory for the NBHCP within the basin given that over 5600 additional acres are proposed to be removed from the inventory, and at least that amount, if not substantially more, will be needed to mitigate for the proposed development.
Analysis of the impact of potentially increased acquisition costs for acquiring mitigation lands for the NBHCP because of the increased demand resulting from trying to mitigate for this project in the same geography as the NBHCP.
EIR needs to provide substantive evidence that the loss of so much more habitat than was contemplated and covered in the NBHCP in the basin will not result in jeopardy for the Swainson’s hawk and the giant garter snake.
Analysis of the impact of removing more than 5600 acres of important habitat for the giant garter snake needs to be included. Cumulative effects need to be analyzed for the giant garter snake in this context as well.
Analysis of the impact of removing more than 5600 acres of important habitat for the Swainson’s hawk needs to be included. Cumulative effects to the Swainson’s hawk need to be analyzed in this context as well.
The EIR needs to provide all appropriate and feasible mitigations for impacts to species so that their efficacy can be analyzed, and not kick the can down the road with the deferred mitigation of indicating that such details will be worked out later with the regulatory agencies after entitlements are granted.
Financing
The environmental challenges of this project represent astounding obstacles, of a scale rarely seen in this region. The EIR must be very sound in its demonstration of how the provision of public infrastructure and services to this project can be achieved while maintaining a “neutral-to-positive fiscal impact” to the County (see NOP, page 4, Objective #8).
Infrastructure costs for internal drainage, SAFCA flood control assessments, roads and other essential services will be extensive. Parallel evaluation of these costs is essential to the EIR process. The EIR must show that mitigation measures attached to the project, particularly those that rely on developer funded implementation—and in particular those that are related to habitat mitigation requirements—will, when combined with the burden of infrastructure costs, be financially feasible.
Bonding of mitigation measures must be evaluated as part of the mitigation and monitoring program. This evaluation must be part of the draft EIR process and available for public review well before final project approvals.
Conclusion
ECOS agrees with the assumption that the population of the region and the county will grow. The purpose of the General Plan is to control future development such that it meets the stated needs of the county. Applicant must demonstrate how the proposal will help the county meet these needs, consistent with the existing General Plan, MTP/SCS, Regional Air Quality Attainment Plan, Climate Action Plan, Sustainable Groundwater Management Act, the NBHCP, and, of course, CEQA. Any requested departure from these requirements must demonstrate unequivocal and unique circumstances that outweigh the considerable constraints of those existing requirements. To the extent that one considers the provision of public infrastructure and services, themselves, as mitigation for the environmental impacts of the project, their feasibility, adequacy and their own inherent impacts must be explicated fully and compared to alternatives that do not require amendments to the General Plan, various specific plans ( listed in the NOP as “Requested Entitlements”), or new annexations to the Sanitation District and Sewer District.
The region, and the county, specifically, already have countless alternatives to meet future growth within the above requirements (well beyond the 55,000 people subsumed by this proposal). In fact, the existing General Plan subsumes much more growth than is projected by SACOG. It is incumbent on the applicant, therefore, to demonstrate how the proposal comports with the alternatives already available under the General Plan, MTP/SCS, etc. A simple “No Project” alternative that also assumes no growth anywhere else in the region, or one that fails to relate the project to at least one of these alternatives, is simply not good enough to support rational decision-making.
Sincerely,
Brandon Rose, President, Environmental Council of Sacramento (ECOS)
