Hearing on Elk Grove’s Latest Attempt to Sprawl – February 7, 2018

January 16, 2017

Below, two updates from our partners at the Sierra Club Mother Lode Chapter, a member organization of ECOS, from their recent newsletter.


Chapter Chair’s Column

By Andy Sawyer

Fighting urban sprawl has long been a priority for the Sierra Club Mother Lode Chapter. Sprawl consumes important wildlife habitat and agricultural land. It increases costs of providing urban services. It undermines efforts to provide the compact, transit- and pedestrian-oriented development needed to serve a population that is becoming increasingly transit dependent. The Chapter has been particularly concerned about effects on air quality. Low density urban sprawl increases automobile dependency, requiring driving for commutes and errands that could otherwise rely on walking, bicycling or transit, and the driving distances are greater, resulting in increased vehicle miles traveled and automobile emissions.

Climate change heightens the urgency of stopping sprawl. The transportation sector accounts for 37% of greenhouse gas emissions in California. Reducing automobile use is essential to reducing those emissions. In 2008, the Legislature enacted Senate Bill 375, providing for the preparation of sustainable communities with plans designed to reduce greenhouse gasses, and providing incentives for development consistent with those plans. A package of bills enacted in 2017 provides incentives for housing in existing urbanized areas. These incentives will not have much effect, however, so long as our local governments make cheap land available for urban sprawl by rezoning agricultural and open space lands, and state and local governments continue to build highway projects designed to open up new areas to development.

A key element of our efforts to combat urban sprawl is involvement in Local Area Formation Commission (LAFCO) decisions. Changes in the boundaries and spheres of influence of cities and special districts, which require approval by county LAFCOs, determine which areas are planned for urban development. By statute, the purposes of the LAFCOs include “discouraging urban sprawl” and “preserving open-space and prime agricultural lands.” Too often, however, county LAFCOs ignore this direction, rubber stamping local applications for sprawl and leapfrog development. Four years ago we won an important victory when the Sacramento County LAFCO turned down the City of Elk Grove’s application to sprawl into important agricultural land and habitat in the Delta. But now Elk Grove is back, hoping that changes in LAFCO membership will yield a different result. The Sierra Club has commented extensively on the proposal, and is gearing up for the February 7 hearing on the project, where we will need a large turnout. Mother Lode Chapter Conservation Chair Sean Wirth provides additional information on this below.

We are also working to shift transportation funding from highway expansion to transit. The Mother Lode Chapter is supporting litigation challenging Caltrans’ failure to consider and provide mitigation for the increase in vehicle miles travelled when it approved additional lanes on Highway 50, and is preparing comments on the proposed expansion of Highway 65. We are also working on proposed local transportation sales taxes, seeking to eliminate funds for sprawl supporting highway expansions and increase funding for transit.

Sprawl hurts us all. Fighting sprawl is critical to our success in protecting our environment, both regionally and globally.


Elk Grove and the ecological health of the north Delta

By Sean Wirth

As Elk Grove aggressively continues to try and realize its growth ambitions to the south of its existing city’s footprint, it is important to take stock of what is at stake for the ecology of the north Delta. Elk Grove has made it clear that it wants to grow right down to the edge of the 100 year floodplain, and then mitigate for the destruction of habitat of listed species, such as the Swainson’s Hawk, that resulted from that development by conserving habitat within the floodplain. The Sierra Club has long been concerned about the loss of upland habitat south of Elk Grove because the Consumnes River floodplain is an active floodplain that is inundated cyclically every seven to ten years, like it did dramatically last winter season.

The land conservation for the majority of north Delta species, especially the Greater Sandhill Crane, has been done within floodplains. When the cyclical flooding of the Consumnes River occurs, many of these species need to seek higher ground for their survival. For the Greater Sandhill Crane, it needs nearby upland areas for foraging and feeding when those floods occur. Though the Greater Sandhill Crane roosts in shallow wetlands at night, and though it will also forage in freshly flooded fields, the vast majority of the calories that this bird relies upon in our region comes from the grains that escaped agricultural harvest, such as corn, rice and wheat.

Sandhill Cranes are unusually loyal to their specific wintering geography and rarely travel more than two miles from their selected roost sites. When the cyclical flooding occurs, these birds look for the closest upland forage opportunities to their roost sites. All of the unincorporated lands south of Elk Grove serve this important purpose and the prospect of all of those lands being developed down to the floodplain would be catastrophic to the Crane and many other species that rely on un-flooded terrestrial habitat for their survival.

What complicates this problem even further is that the most conservative modeling for the impacts of global sea level rise in the north Delta indicate that basically all of the current lands set aside for the Greater Sandhill Cranes, and hundreds of other terrestrial species, are going to be threatened with permanent inundation as the symptoms of climate change accrue. This reality elevates the importance of the lands south of Elk Grove as a critical pathway to get our North Delta species over to the higher ground in the east. And clearly, this pathway is not going to be effective if it is paved over for low density sprawl neighborhoods and their associated malls.

Voicing these concerns is going to be an important part of convincing LAFCO that allowing Elk Grove to pave over this critically important geography is not in the interest of our region. Please join us on February 7th to demonstrate your concern at the hearing. The hearing starts at 5:30 p.m. and will be held at the Board of Supervisor’s chamber at 700 H Street in downtown Sacramento.

Kammerer Road-Highway 99 Sphere Of Influence Amendment DREIR

On September 11, 2017, ECOS submitted our comments on the Draft Recirculated Environmental Impact Report (DREIR) for the Proposed Kammerer/Highway 99 Sphere Of Influence Amendment (SOIA) Application for the City of Elk Grove.

Click here or on the image above to read the comment letter.

Summary

We appreciate the added attention to detail offered in the recirculated draft EIR, but rather than alleviate our concerns expressed in our original letter, the DREIR only further confirms those concerns. ECOS remains strongly opposed to the proposed Kammerer-99 Elk Grove SOI expansion and stands by our initial observation summarizing the project: 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 RDEIR confirms significant and unavoidable impacts in all these above-mentioned areas, with the exception of less than significant biological impact after mitigation which is a finding we disagree with. The question is, what justification is there for these impacts? We, again, find that there is not, and we strongly recommend that LAFCo decline the proposed Kammerer/99 SOIA.

Click here to read our comment letter to the Draft Environmental Impact Report, submitted March 31, 2017, which is referenced in our letter.

Click here for the Friends of Swainson’s Hawk’s comment letter on the Draft Recirculated Environmental Impact Report, submitted September 11, 2017, which is also referenced in our letter.

ECOS comments on US-50 HOV Phase 2 Project Draft IS/EA

November 4, 2016

RE: Sac 50 Phase 2 High Occupancy Vehicle (HOV) Lanes* Project Draft Initial Study [with Proposed Mitigated Negative Declaration]/Environmental Assessment

In general, ECOS is greatly concerned that this Initial Study does not adequately analyze the potential impacts of the project, and strongly recommends that a full EIR be conducted.

hov-ltr

Read our full comment letter here.

What’s an HOV lane? 
From Caltrans: The central concept for HOV lanes is to move more people rather than more cars. Some HOV lanes carry almost half of the people carried on the entire freeway.

But how will we get there? ECOS on the draft Sustainable Communities Strategy

Thanks to ClimatePlan for featuring the Environmental Council of Sacramento’s response to the Sacramento region’s draft Sustainable Communities Strategy!

ClimatePlan Blog
November 19, 2015

Guest post by: Matt Baker, Land Use and Conservation Policy Director, Environmental Council of Sacramento (ECOS)

Sacramento has released a draft of its 2016 Sustainable Communities Strategy (SCS)—its second plan, after its first in 2012 led the state toward better planning. The plans should coordinate land use and transportation, to help make communities healthier and reduce greenhouse gases.

Comments on the new draft plan were due Monday, November 16th, 2015

Below is a quick summary of our comment letter on Sacramento’s draft 2016 plan. Read the full letter here.

(For more background, see Baker’s previous post on the plan here.)

Quick take

Sacramento’s draft SCS shows leadership and innovation. It offers a path to healthy, socially equitable, economically thriving, and environmentally sustainable communities.

But we are concerned: there are big disparities between the regional plan and the plans adopted by the region’s cities and counties.

The region’s jurisdictions must overhaul their growth plans to align with the regional plan. Otherwise, its many benefits—including more housing and transportation choices for residents, biodiversity and farming resource protections, and reducing greenhouse gases—may never come to life.

Overall, much to applaud

We applaud the Sacramento Area Council of Governments’ (SACOG’s) innovations: its excellent travel forecasting, performance assessment of projects (and cutting those that don’t perform well), rural-urban connections, and the region’s first climate adaptation analysis.

We’re pleased to see these steps forward in the draft plan:
 – Substantial projected increases in transit service, ridership, and access 
- Improved access to transit in disadvantaged communities 
- Funding to rebuild streets to allow safe and pleasant walking and biking
-A “fix-it-first” initiative to favor road maintenance before new road construction

Perhaps the most impressive thing about the plan is that its growth scenario reduces vehicle miles traveled, or VMT, through true land use and transportation behavior change—putting destinations closer together and reducing the need to drive.

A few more things to fix

Here’s more detail on where we’d like to see improvement:

Compare scenario performance

We support the recommended scenario. But the region could do even better, and we were disappointed to see Scenario 3, the most sustainable, dismissed. Now we’d like to see:

– The real picture: Compare performance (on VMT/GHG) between the preferred scenario and a “business-as-usual” scenario that reflects cities’, towns’ and counties’ existing plans. “Business as usual” will put the region far beyond its required greenhouse gas targets; let’s confront that reality.

– Focus in existing communities: Look at the performance of an “all-infill” land use scenario in which twenty- year growth is constrained solely to existing “Established Communities.” There’s plenty of room; the region’s current density is extremely low.

Shift from sprawl to infill

Despite the growing demand for walkable neighborhoods near good public transit, current and planned development continues to churn out car-oriented suburbs far from services. Sixty percent of jurisdictions’ planned growth is greenfield development.

The regional and local plans are hugely out of joint: for example, current general plans estimate eight times more growth in “Rural Residential” areas than in the SCS.

At the same time, major infill proposals are not capitalizing on their potential. For example, the Sacramento Railyards–one of the largest contiguous infill opportunities in the nation–is currently amending its proposal to reduce its residential capacity by half.

Peripheral low-density greenfield growth imposes a triple negative on the regional plan:

1) There’s a direct increase of VMT and GHG emissions from the development itself.
2) The regional government must allocate funding to more roads to service those communities, further limiting funding that could be used for transit.
3) Finally, that peripheral growth prevents the density needed to provide the ridership and fare recovery to maintain the transit system.

Build for transit and fund it earlier

The 2036 transportation plan offers many benefits, but it relies on more compact development. The jurisdictions must commit to more compact development or the much-improved transportation system envisioned for 2036 will never be built.

Much more funding is needed for transit operations earlier in the plan. Early investment will help guide development around transit—with the walkable neighborhoods that more people want.

SACOG can help incentivize better development, by funding only projects that comply with the regional SCS, following the model of the “One Bay Area” grant program. Jurisdictions should have to show performance on VMT/GHG and air quality, as well as equity, public and ecological health.

Rounding is an error: Hit the greenhouse gas target

The SCS nearly meets the greenhouse gas emissions (GHG) reductions targets imposed by the CA Air Resources Board. However, 15.58% does not equal 16%. Saying so sets a bad precedent.

It may sound like a small amount but it means many tons of air pollution.

We strongly urge the Board to adopt a scenario that achieves that extra .42% reduction, or better, goes beyond the 16% target.

We appreciate the GHG analysis that SACOG provides, but would like to it go further: a 2050 scenario would help show whether the current trajectory will keep the region on track.

Track implementation

SACOG is dedicated to public participation, but its travel modeling and investment strategies are hard to understand. We need better tools to understand where investments are going from cap & trade and for disadvantaged communities.

Address gentrification and displacement with more affordable homes near transit

SACOG is making continued improvements in its public health and social equity inputs and analyses, but more is needed.

Right now, lower-income communities are poorly served by transit. That needs to change for many reasons, including meeting the region’s required GHG reductions targets, because the data show that lower-income residents will use transit more—if it is available.

More homes in transit-rich areas must be affordable. All jurisdictions must adopt strict mixed-housing ordinances and anti- displacement measures that preserve existing affordable and work-force housing, and build new affordable homes. Meeting the Regional Housing Needs Allocation (RHNA) housing goals should be required for transportation funding.

Map and protect rural lands, biodiversity, ecosystem services, and water

SACOG’s Rural-Urban Connections (RUCS) program is helping support the agricultural sector. We’re also glad to see the plan and environmental analysis consider ecosystem services, such as flood control, groundwater recharge, and carbon sequestration.

The biological impact analysis in the 2016 update is much improved. We’d still like to see maps that show how growth would affect regional connectivity and ecosystem viability, as well as local species needs.

The plan estimates development of 47,563 acres of wild or agricultural lands in the next 24 years—that’s a lot less than the 214,000 acres consumed in the previous 24 years. While we think the region could do better, given the current growth behavior of the region, we fear the impact will be much worse.

Looking ahead

We applaud SACOG’s progress in development of the 2016 MTP/SCS update. We call on all of the region’s jurisdictions to support it, with serious changes to their growth patterns and policies.

We thank our partners and SACOG and look forward to continuing to work together to improve the region’s plan—and its future.