Comments re the Regional Water Authority (RWA) Planning Forum

On January 11, 2019, the Environmental Council of Sacramento and Habitat 2020, sent comments regarding the Regional Water Authority (RWA) Planning Forum.

Below is the content of our letter in full.

John Woodling
Executive Director
Regional Water Authority
5620 Birdcage Street, Ste 180
Citrus Heights, CA 95610

Subject: Regional Water Authority (RWA) Planning Forum

Dear Mr. Woodling,

The Environmental Council of Sacramento (ECOS), a 501c3 organization, and Habitat 2020, the Conservation Committee of ECOS, are partner coalitions dedicated to protecting the natural resources of the greater Sacramento region while building healthier, more equitable, economically thriving communities. ECOS-Habitat 2020 member organizations include: 350 Sacramento, AARP, Breathe California-Sacramento Emigrant Trails, Friends of Stone Lakes National Wildlife Refuge, International Dark-Sky Association, Los Rios College Federation of Teachers, Mutual Housing California, Physicians for Social Responsibility Sacramento Chapter, Sacramento Citizens’ Climate Lobby, Sacramento Electric Vehicle Association, Sacramento Green Democrats, Sacramento Housing Alliance, Sacramento Natural Foods Coop, Sacramento Audubon Society, Sacramento Valley Chapter of the California Native Plant Society, Sacramento Vegetarian Society, Save Our Sandhill Cranes, Save the American River Association, Sierra Club Sacramento Group, Friends of the Swainson’s Hawk, and the Sacramento Area Creeks Council.

ECOS/Habitat 2020 are heartened by the extensive work the Regional Water Authority (RWA) and its member organizations are doing to improve the Sacramento Region’s (Region) water reliability and security. The 2018 update of the American River Basin Integrated Regional Water Management Plan (“Plan”) provides a solid framework to guide the Region’s water purveyors and GSAs to improve interconnectivity; engage in water transfers, recharge and banking; plan for and manage the three American River Subbasins sustainably; and, ensure that the Region’s three river systems have sustaining flows, temperatures, and water quality; and, provide the needed habitat for the flora and fauna they support.

We understand that RWA has an established review group called the Planning Forum. ECOS/Habitat 2020 would be pleased to formally join this group. If this meets with RWA needs please include Ted Rauh as our contact point. Ted can be reached at tnrauh[at]att[dot]net or at (916) 261-8011.

We also understand that RWA is preparing to engage in a public awareness campaign to convey to elected officials, agency decision makers, opinion leaders, and the public, the importance of the projects and activities identified in the Plan and how the Plan lays out a prudent path for the region’s water future. We would be pleased to participate with RWA in the development and implementation of this campaign. ECOS/Habitat 2020 represent, or are affiliated with, most of the environmental and community based groups in the Region, and have strong ties with conservation and other public interest groups as well. We believe we can be of significant assistance. However, we believe several key issues need to be addressed to ensure the full success of outreach effort. If these issues are not addressed important aspects of the Plan may be called into question because of its failure to address the Region’s three groundwater subbasins equally and equitably.

Specifically, we strongly believe that each Subbasin needs to have comprehensive Subbasin descriptive modeling systems that assure accurate accounting and impact assessment of both recharge and pumping operations, and accurately describe the flows and elevations of groundwater through the Subbasin so that a Subbasin management approach can be carried out that is capable of responding to delayed changes within the Subbasin due to pumping and recharge operations, and responds to GDE and other triggers. RWA is in the process of establishing this type of modeling system for the North American Subbasin and is actively working with the other two Subbasins to adopt the same system or establish compatible systems. We fully support these efforts.

The Plan includes the potential for substantial water banking resulting from excess storm water runoff. We have received information from UC Water experts that this resource constitutes a real potential for our region. SAFCA is moving forward with a series of actions outlined in the Plan that can make significant quantities of excess storm water available over sufficient time frames to allow for selective regional groundwater recharge and banking under the right conditions. A critical step in satisfying some of these conditions is the completion of a thorough analysis of where within the Region the prime recharge and extraction zones are located. This analysis should include each area’s compatibility with existing land use and water management/conveyance constraints. This information will allow for appropriate modeling to be developed so that the actual storage, flow, and recovery potential of these groundwater resources can be fully understood. We understand that UC Davis is preparing a project plan to carry out this analysis that may be ready for funding in the near future. We think that a project to determine this information should be included within the Plan.

The above observations are not intended to deter RWA’s important planning and project management activities, but rather to point out several gaps that if not addressed, may diminish the extensive work that has already been done. Regardless of RWA’s ability to react to our suggestions, ECOS/Habitat 2020 stand ready to work collaboratively with RWA to communicate the importance of regional water security and the plans and projects that best lead the region toward this goal. We stand ready to meet with you and your staff to further explore these points and how we may assist in your Agency’s efforts to effect comprehensive water security that can benefit the environment. Robert Burness can be reached at rmburness[at]comcast[dot]net or 916-956-0365.

Sincerely,

Robert C. Burness
Co-chair of Habitat 2020

Ralph Propper
Board President of ECOS

Read the letter in PDF by clicking here.

A Note From Our Treasurer: ECOS Needs Your Support

January 11, 2019

Dear Friend,

I hope this letter finds you in good health. I want to highlight some of the Environmental Council of Sacramento’s (ECOS) accomplishments last year, inform you about our plans for the New Year, and ask for your continued financial support—because ECOS would not exist without support from local environmental stewards like you.
We need your support. Please consider becoming a member – better yet with a recurring monthly donation of ten or twenty bucks a month (less than the price of going out to dinner!). You can become a dues-paying member and support our community by clicking here: https://www.ecosacramento.net/membership-account/membership/.

We accomplished a lot in 2018:
· ECOS wins lawsuit securing light rail funding. ECOS secured $40.5 million for the Sacramento Regional Transit Light Rail system by settling our lawsuit challenging the Caltrans Environmental Impact Report for the Capital City Freeway Improvement Project. This money will be used to complete double tracking to Folsom, purchase low floor train cars, and resume evening service on the Gold Line.
· ECOS organizes 29th annual Earth Day. On April 22, 2018, ECOS hosted Sacramento’s annual Earth Day celebration in Southside Park—the largest annual environmental event in Sacramento County. This event now draws over 3,000 visitors to live music, 150 nonprofit and crafts vendor booths, and the largest electric vehicle display and test-drive event in the Sacramento region. Thanks to our partners the Sacramento Electric Vehicle Association and Charge Across Town, some 40 different electric vehicle models were displayed by owners and several hundred test-drives were conducted by regional EV dealers.
· ECOS advocates for underserved communities. In 2018, ECOS advocated for environmental protection in green spaces occupied by Sacramento’s growing homeless population and for expanded homeless services and transitional housing. In addition, ECOS established an Environmental Justice Committee within our organization to identify the priorities of underserved communities and help build networks in support of our mutual environmental interests, including the expansion of public transit, affordable infill housing, and living wages.
· Housing, housing, housing. With the economy continuing to improve, land use projects of increasing size and adverse environmental impact were proposed in Sacramento County last year. If the region does not accommodate the new urban housing market, sprawl will continue, threatening whatever habitat, agriculture and open space is left. So we have also paid a great deal of attention to the intensification of urban development in the region’s cities (Elk Grove, Roseville, Sacramento, Galt, Citrus Heights, West Sacramento, etc.) where the new urban housing market could be focused.

In 2019, ECOS will focus on future transportation funding options, Phase 2 hearings on the California WaterFix, local electric vehicle roll-out, environmental justice group empowerment, and local implementation of the Sustainable Groundwater Management Act next year. You can support our work by becoming a member: https://www.ecosacramento.net/membership-account/membership/.

As you know, we are a small, local organization that operates on a shoestring budget and depends on the financial support of community members like you. ECOS does a lot with a little: we have an annual budget of just thousands of dollars; with more members and an expanded budget, we can serve the community better. We know you receive requests from many organizations and hope our decades of dedicated community service and proven success earn us a spot on your list. As always, we would be extremely grateful for your support.

Happy New Year!

Best Regards,

Earl Withycombe, ECOS Treasurer

P.S. There are many ways to support ECOS. Beyond your annual donation we encourage you to become a monthly sustainer, which give us the financial stability to do more. You can do this by visiting our website (https://www.ecosacramento.net/), and then clicking on “Donate” under “Support ECOS”. We also welcome volunteers for every aspect of our work – you’ll have fun and learn skills as you help our environment. Contact us at office[at]ecosacramento[dot]net.

Use the Surplus Land Act to Build More Affordable Housing

By Scott Thomas Anderson

November 1, 2018

Sacramento News and Review

Housing advocates tell mayor his administration is skirting the California Surplus Land Act

One thing is certain: Sacramento’s wheeling and dealing of public land to market-rate developers happened during a crisis that hurts low-income renters more than anyone.
The controversial land sales were brought to Steinberg’s attention in July when the Sacramento Housing Alliance and the Environmental Council of Sacramento sent him a joint letter* expressing concern. Specifically, the two organizations questioned whether the city is in compliance with the Surplus Land Act, a law that requires prioritizing surplus government land for affordable housing. One case that the nonprofits found particularly “alarming” was the city’s sale of 4722 Ninth Avenue and 4601-4625 10th Avenue, near Stockton Boulevard.

This week, Steinberg said his office is looking into the issue Sacramento Housing Alliance and ECOS raised.

“The Surplus Land Act is an important law and the city should absolutely comply with it,” the mayor told SN&R.

Click here to read the full article.

*The letter to the Mayor Steinberg from the Sacramento Housing Alliance and the Environmental Council of Sacramento that is referenced in this article was sent on July 9, 2018.

Click here to read the letter.

Monitoring Groundwater in Sacramento County

October 12, 2018

The South American Subbasin is located in the central portion of Sacramento County. It is primarily managed by the Sacramento Central Groundwater Authority (SCGA).

ECOS believes that Sacramento Central Groundwater Authority’s understanding of the hydrology of the Subbasin should be measurably improved, and we have written a letter suggesting some ways to achieve that. Below is an excerpt of our letter.

The Environmental Council of Sacramento (ECOS) notes with interest the Sacramento Central Groundwater Authority (SCGA) Board’s September 12, 2018 direction to Staff to evaluate the State of California’s C2VSimFG model input data for the South American Subbasin (Subbasin) and update the State’s model data as necessary. We believe that SCGA’s understanding of the hydrology of the Subbasin should be measurably improved. SCGA should look to the modeling and monitory efforts underway by the Regional Water Authority and the Sacramento Groundwater Authority (SGA), and adopt and put in place a comprehensive and compatible monitoring program for the Subbasin.
We also believe the Board acted with imprudence when it recently adopted its operating budget for the upcoming year, in that, among other issues, the Board did not provide enough funding for groundwater monitoring and modeling. SCGA’s existing set of monitoring wells is insufficient to provide a full understanding of the flows of groundwater into, through and out of the Subbasin. Semiannual data points are not sufficient to understand and effectively manage the Subbasin. While we commend SCGA’s recent effort to provide real time monitoring in a small, select group of wells, we believe you should do far more in this important area.

Click here to read the full letter (PDF).

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.

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.