Jackson Township Specific Plan Project: ECOS Comments

On June 28, 2021, ECOS sent the following comments to CEQA [at] saccounty [dot] net (Cc: Todd Smith smithtodd [at] saccounty [dot] net).

ECOS and other environmental groups have urged developers to start building the project nearest the urban core (the City of Sacramento) and build outward, following the Jackson Highway. This would reduce the project’s GHG emissions, air pollution, and negative impacts on local wildlife. However, the Sacramento County Board of Supervisors has instead elected to let the market decide which part of the project should be built first, and therefore the project is being built contrary to environmental concerns.

Below is an excerpt from our letter.

As stated on p. 20-1, vehicle miles traveled (VMT) has replaced congestion as the metric for determining transportation impacts under CEQA. Nonetheless, in the EIR level of service (relieving traffic congestion related to the development) is said to be “mitigated” by building additional roads and lanes. This will result in more VMT.
The EIR states that “delay-based traffic operations is provided herein for informational purposes. It is assumed for the purpose of this analysis that delay-based effects and the associated measures proposed to reduce these effects to acceptable levels would be included as conditions of approval and/or in the development agreement for the Project.” On pp. 20-41/42, the EIR states that SB 743 requires amendment of CEQA Guidelines to provide an alternative to LOS for evaluating transportation impacts. Particularly within areas served by transit, those alternative criteria must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.”

Measurements of transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.” The EIR continues, “Once the CEQA Guidelines are amended to include those alternative criteria, auto delay will no longer be considered a significant impact under CEQA.” Nonetheless, in the EIR there are plans to construct additional lanes of concrete highway. That is a “business as usual” approach. We can no longer plan for additional roadways that will result in increased VMT and the concomitant increase of GHG and other emissions.

On p. 20-56 the EIR states, “The Project would widen and/or complete many roadways that cross or border the Plan Area and would include new roadways to serve the proposed land uses.” More appropriate mitigation should be funding for Regional Transit to cause even more frequent public transit and additional, Earth-friendly shuttles to get people that live and work in the project area to and from public transit lines, than those suggested in the EIR. On page 20-77 the EIR states, “While most effects could theoretically be reduced to acceptable levels by adding more traffic lanes, grade separations, new roadways, and other similar measures, such LOS improvement measures mitigation may not be consistent with adopted policies and could result in secondary impacts to the environment and other users.”

On p. 21-8 it is stated, “As described in Chapter 20, “Traffic and Circulation,” of this Recirculated Draft EIR, analysis of vehicle miles traveled (VMT) is provided only for Alternative 2. Based on modeling, VMT generated under Alternative 2 would exceed the VMT significance thresholds for residential lands and office land uses (emphasis added). Implementation of Mitigation Measures TR-1, TR-2, and TR-3 would pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, and would identify and fund additional Trip Reduction Services. However, it cannot be guaranteed that the implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce VMT impacts to less-than-significant levels because the specific elements of the VMT-reducing mitigation measures that would be implemented are unknown at this time, and uncertainty exists related to the VMT reductions that would be achieved.” To mitigate for this, the developer should commit funding to Regional Transit for increased public transportation.

On p. 21-17 the EIR states, “Project-generated GHG emissions would exceed applicable Sacramento County thresholds of significance for transportation and result in a cumulatively considerable contribution to climate change. These levels of emissions also indicate that the Project would not be consistent with Sacramento County’s CAP.” Therefore, adequate mitigation is required.

On p. 21-29 the EIR states, “Public transit is not currently provided to, or near the Plan Area. A conceptual transit system to serve the Jackson Corridor Projects (i.e., the Jackson Highway Master Plans, including the Jackson Township Project) has been developed by Sacramento County, SacRT, DKS Associates, and the applicants of the Jackson Corridor Projects as part of a joint transit planning process. This developer and those of adjacent projects should mitigate this by providing additional funds for public transit.”

The EIR provides “Sacramento County has established draft GHG thresholds for 2030. The Project’s build-out year is 2035, for which the 2030 GHG thresholds were extrapolated in alignment with State GHG reduction targets. Development of the Project or Alternative 2 would result in the production of GHG emissions during construction activities and throughout the operational period of the Project, attributed to vehicle use, energy use, waste generation, water treatment and distribution, and other area sources.” (P. 21-51). It goes on to say, that even with implementation of mitigation suggested, the Project would reduce GHG emissions generated onsite and the remaining GHG emissions exceeding applicable thresholds would be offset through the purchase of carbon credits. Better mitigation than carbon credits is direct funding to RT for mass transit and additional Earth-friendly shuttles as suggested above.

We agree with the statement on p. 21-64 that the Jackson Corridor Projects include substantial amounts of higher density and mixed uses to help support transit use; however, transit service within walking distances of those uses is required to achieve a significant transit ridership. The “LOS Improvement Measures” beginning on p. 21-143 again call for more concrete, and instead should provide funding that will enable public transit to be utilized instead. In the words of teenager Greta Thornburg, “act like our house is on fire.” We cannot develop more roadway and arterials instead of funding additional mass transit, and project mitigation should reflect that.

We agree that implementation of Mitigation Measures TR-1, TR-2, and TR-3 would reduce Project-generated VMT impacts (p. 21-214). These measures should pay for bus and/or shuttle operations between the Project and the Manlove Light Rail Station, as well as identify and fund additional Trip Reduction Services (TRS). Such additional trip reduction services should include direct funding to RT for public transit to adequately serve the Project, because the Project “would have a considerable contribution to a significant and unavoidable cumulative VMT impact” (p. 21-214).

/s/
Ralph Propper,
President, Environmental Council of Sacramento

Click here to view the letter as submitted.


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ECOS Comments on NewBridge Specific Plan, FEIR

On September 1, 2020, the Environmental Council of Sacramento (ECOS) submitted comments on the NewBridge Specific Plan and Final Environmental Impact Report (FEIR), dated Aug. 21, 2020.

Below is an excerpt from our comment letter.

CONSISTENCY: The Jackson Corridor projects should be treated consistently in terms of the County’s requirements for project approval. The requirement to meet state mandated greenhouse gas (GHG) emissions reductions targets is a particularly important one. Mather South demonstrated that it met state mandated GHG emissions reductions targets in the Climate Change chapter of its Specific Plan/FEIR. By contrast, the NewBridge FEIR currently calls for a demonstration of adequate emission reductions at the time of tentative map approval.

Close scrutiny of the project by the public and yourselves as County leaders occurs at FEIR approval. We ask that the NewBridge FEIR be modified prior to your approval to ensure GHG thresholds are met and the project’s impact is reduced to a “less than significant level.”

Mather South’s FEIR, CC-2 measures (GHG-reducing measures) are named and quantified: EV Charging and 100 Percent Solar on All Nonresidential Buildings and Residential Buildings. In addition, the CC-3 measure for purchase of carbon offsets is described and quantified. The NewBridge FEIR simply lists the CC-2 measures as a menu to be selected at tentative map approval. No quantification is provided. A demonstration that GHG thresholds are met is not provided.

For reference, please see this excerpt from the Mather South FEIR, page 7-29:

“Implementation of Mitigation Measure CC-1 requires the project to comply with all provisions included in the AQMP. This mitigation would be consistent with provisions of General Plan Policy AQ-4. Implementation of Mitigation Measure CC-2 would further reduce GHG emissions associated with residential and nonresidential building energy and transportation. However, GHG emissions would not be mitigated to a less-than significant level through the provisions of the AQMP and Mitigation Measure CC-2 alone. Thus, the purchase of carbon offsets as discussed in Mitigation Measure CC-3 would reduce the transportation-related GHG emissions to reduce mass emissions by 301 MTCO2e/year for the transportation sector by 2032. With implementation of Mitigation Measure CC-3, all GHG thresholds would be met and this impact would be reduced to a less-than-significant level. [Mather South Final EIR, page 7-29, PLNP2013-00065]

Click here to read the letter in full (PDF).

Click here to view the environmental and planning documents.

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Proposed Elk Grove Hospital Draft Environmental Impact Report Released

August 14, 2020

The City of Elk Grove released the draft environmental impact report (“DEIR”) for the California Northstate University (“CNU”) Hospital Project (“Project”) on August 14, 2020, finally giving the public the first look at the Project’s potentially significant environmental impacts and an opportunity to provide comments.

Who: The City is the lead agency for the Project, meaning it is responsible for preparing the DEIR and complying with the California Environmental Quality Act (“CEQA”).

What: The Project is the total redevelopment of the shopping center located directly east of Stone Lakes National Wildlife Refuge and north-west of impact mitigation land for Swainson’s hawk. The Cosumnes River Preserve is only 12 miles from the Project site. CNU, a for-profit medical school already operating on site, intends to construct a 12-story hospital topped with a helipad, a dormitory, and numerous parking and auxiliary structures. The Project would be developed in three phases over a period of 10 years.

When: The 45-day public comment period began on August 14, 2020 with the release of the DEIR.

The deadline to submit written comments and receive a response in the Final EIR is 5:00 pm on September 28, 2020.

Oral comments may be provided at the September 16, 2020 City Council meeting and the City will provide responses to those comments in the Final EIR as well.

Where: The DEIR and supporting documents is available at: http://www.elkgrovecity.org/city_hall/departments_divisions/planning/current_development_projects/california_northstate_university_hospital/documents__visuals. Physical copies of the DEIR are available at the City Planning Division counter at 8401 Laguna Palms Way, Elk Grove, CA 95758.

Why: Concerned members of the public should submit comments on the Project to demonstrate opposition to this intrusive Project that would have negative consequences for residents and wildlife alike. The City is already conceding that the Project would have significant impacts that cannot be mitigated. With respect to impacts to local residents, the Draft EIR admits that the Project would create light and noise pollution and increase criteria air pollutant emissions. The Project also poses a significant threat to native protected species like Swainson’s hawk, sandhill cranes and burrowing owls that inhabit the Stone Lakes National Wildlife Refuge and surrounding habitat. Noise and light pollution would disturb roosting birds, while helicopter flights and the massive hospital building would pose a danger for bird strikes. Long-term, the Project would contribute to depleting groundwater levels and impaired air quality. Now is the time for the public to voice their concerns and let the City know that Project is not right for Elk Grove.

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