New “Green Means Go” Program in Sacramento

Sent via email
From: Ralph Propper, Environmental Council of Sacramento
Sent: Apr 3, 2019 5:06 PM
To: James Corless, Sacramento Area Council of Governments
Cc: Christina Lokke, Sacramento Area Council of Governments
Subject: ECOS support letter to legislature for “Green Means Go”

Dear James,

The Environmental Council of Sacramento (ECOS) wants to send a support letter to the Legislature requesting $400M funding for SACOG’s Infill Pilot, “Green Means Go”. We support the intent of your request, but we are concerned about lack of specificity regarding how SACOG would use these funds. We would like clarification included in any budget proposal to reflect the following recommendations; your clarification would enable us to send a support letter.

Infill Siting Criteria

We recommend that sites be surrounded by at least 75% existing urban uses, and the remainder be previous urban uses. This is consistent with SB 375’s infill definition, and our region has sufficient potential to meet these criteria.

VMT Performance Criteria

We recommend using OPR’s SB 743 Technical Advisory of -15% of regional average VMT for land use projects, and no net per capita VMT increase for transportation projects/infrastructure upgrades, as the guiding performance criteria for these projects. These should be the primary goals of the infill pilot, and OPR’s recommendation should be the standard for such incentive projects to meet the identified need in CARB’s GHG Scoping Plan for improved land use to meet climate goals. Accounting for project VMT in the pilot would also serve as a model for SB 743 implementation in our region, and begin to build an inventory of VMT-reducing projects for future VMT mitigation.

Inclusionary Requirement

We recommend a requirement that 10% of housing in an applicable project should be affordable to “low income”residents, an additional 5% should be affordable to “very low income”, and no in-lieu fee option should be available in low-VMT and Transit Oriented Development areas. This is consistent with requirements in SB 35 and other recent legislation.

Anti-Displacement Protection

Displacement of low-income residents is the greatest risk from the infill investment we need to meet our climate goals, so these investments must be coupled with protections against their displacement. Therefore, we recommend no demolition of existing affordable housing, rental housing, or any housing that was subsidized for affordable or rental housing in the last 10 years, consistent with language in recent legislation, e.g., SB 35, SB 50. Although an MPO cannot require anti-displacement mechanisms (e.g., rent control, just-cause eviction, no-net loss, right of first return), a jurisdiction’s no-demolition policy should be considered in scoring criteria for project selection. Prioritizing existing underutilized commercial zoning (e.g., parking lots) in project selection offers densification potential and avoids the direct displacement of housing.

In conclusion, we believe that VMT-reducing projects should be a priority if funding is provided. Thank you for considering these recommendations, and we look forward to working with you to identify appropriate criteria for projects applicable to this proposal.

Ralph Propper, ECOS President

cc: Christina Lokke

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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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