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Sacramento County’s final draft Climate Action Plan (CAP) is published, and comments are due October 8. The CAP is artfully framed, but, based on preliminary review, the County is doubling down on its decade-old, delay-and-defer climate strategy, and now also intends a CAP adoption process free of a normal environmental review’s legal requirements (for an explanation of this dubious process and our concerns, see our “Heads Up” blog here).

The CAP will “streamline” permitting for future development projects; but its current measures are mostly conceptual, deferred, non-enforceable, and based on un-substantiated data and assumptions. The County’s projections of future greenhouse gas (GHG) emissions, on which its reductions targets are based, is derived from baseline conditions which are both obsolete (2012 data) and incomplete (excludes vehicle miles traveled [VMT] — impacts from 55,000 new homes of planned sprawl development). The CAP’s gestures to VMT reduction and infill development instead of sprawl appear to be window dressing. And the CAP relies heavily on SMUD’s uncertain achievement of carbon-free electricity by 2030.

Without full environmental review, the County need not disclose the cumulative impacts of its sprawl-oriented growth plans; or reconcile the CAP’s inconsistencies with previous promises; the State’s current GHG/VMT reduction targets; and the County’s own Climate Emergency Declaration. It need not meaningfully respond to the climate emergency that’s no longer a distant threat.

350 Sacramento will detail these concerns in official comments, and will call on you to tell the County the CAP’s not good enough. We’ll create a comment portal for you to let the County know we need a strong CAP developed through full public process and review. We’ll be in touch.