350 Sacramento

Sacramento County released its final draft CAP on Friday for a 30-day public review, and in our latest review, we continued to focus on four factors, which together will make the CAP worse than none if not improved.

1. Vague, unenforceable, and/or unfunded measures;
2. Support for massive high-GHG sprawl development, rather than feasible infill;
3. Lack of environmental analysis, instead claiming a 2011 analysis done before the CAP existed is adequate;
4. CEQA-streamlining function, meaning future development will avoid further GHG-impact analysis and only need to comply with the CAP’s measures, no matter how weak.

Join us now in demanding action, check out our Action Network page here, and reach out to your supervisors!

UNRELIABLE MEASURES
The CAP’s measures suggest much but lack actionable detail. Instead they again “kick the can down the road”, relying on unfunded and uncertain future planning to detail actions that would actually reduce GHG emissions.  GHG-30 is Gone. In addition to the general deficiencies, this draft no longer includes Measure GHG-30 which previously required projects outside the County’s growth boundary to be carbon-neutral.  Although hedged with uncertainties about how that would be achieved, GHG-30 was the strongest measure in the previous draft.  Its deletion is very disappointing.

THE COUNTY’S SPRAWL BIAS
The CAP continues to assume a continuation of high VMT/GHG (Vehicle Miles Traveled/Greenhouse Gas) sprawl development, with vague assurances that the impacts will be dealt with through onsite measures (which cannot reduce VMT induced by leapfrog development);  and by carbon offsets (provided through a program which is described only conceptually, which is of uncertain effectiveness).

• • The County’s “Response to Public Comments” document does not effectively reflect or address 350’s concerns about the proposed mitigation, or about the County approving far more dwellings than the market can absorb, meaning that more sprawl approvals will not help the housing crises, and that future build-out will occur in a fragmented pattern, increasing VMT, and making proposed transit mitigation impossible.
  • Instead of providing solid measures to increase infill development, the County cites existing policies and past planning, both of which have been ineffective because of the County’s reliable approval of sprawl proposals. The CAP’s proposed future planning to encourage infill is good but comes too late for the CAP, and its results are uncertain.

LACK OF FULL CEQA ANALYSIS
Failure to conduct a CAP-specific environmental review under CEQA means the CAP is not subject to two key regulatory requirements: that the CAP conclusions (e.g., re-measure effectiveness) are supported by substantive evidence; and that measures are enforceable.

• • The County claims a new CEQA analysis is unnecessary based on five assertions, all of which we believe are incorrect:
    • The County’s program-level 2011 General Plan EIR provided adequate analysis for project-specific GHG mitigation.
    • No environmental or regulatory changes since 2011 require updating the 2011 analysis
    • It’s within the scope of an EIR addendum to conduct substantive analyses of potential environmental impacts and draw conclusions (an Addendum justifies the use of an old EIR when a proposed project has had only minor changes).
    • Environmental review of a CAP is limited to the potential direct impacts of implementing CAP mitigation measures.
    • Environmental review of a CAP need not consider indirect GHG impacts, including the CAP’s ”streamlining” of project-specific analysis and mitigation of GHG impacts.
  • The County reneges on its mitigation commitment by excluding large planned projects outside growth boundaries. Apparently responding to our legal objections regarding the “GPA projects” (so-called because they are beyond adopted growth boundaries and approving them will require General Plan Amendments), the CAP will no longer apply to them.
    • This has the ostensibly positive effect of excluding them from CAP streamlining.  More profoundly, however, it reneges on the County’s 2011 mitigation promise to adopt a CAP addressing all of the GP’s GHG impacts.
    • The reason for CAPs under CEQA is that because GHG emissions are by nature ubiquitous and interlocking, they need to be addressed at the programmatic level, where fundamental policy options can be considered during the EIR alternatives analysis.  Such policy strategies can’t be assessed at the individual project level.  Consideration of policy-level strategies, instead of business-as-usual, individual project review, is why the County’s 2011 promise of a CAP (“within one year”) could be credibly counted as mitigation for future GHG impacts.
    • Now, the County intends that GPA projects proceed under individual, project-level GHG analysis – exactly as if the County had never promised a CAP!  The County is excluding the largest, furthest distant, most GHG-impacting projects from its promised (now ten years overdue) mitigation.
    • The four very large GPA projects plan 57,000 new homes.  For comparison, per SACOG only 37,000 new homes will be needed through 2040; and the County has estimated that 33,000 of these could be accommodated through infill.

GHG STREAMLINING
Future development projects can rely on the CAP’s environmental assessment and need only comply with the CAP’s mitigation measures, no matter how weak.  The CAP’s deficiencies are thus baked into future County climate action indefinitely.  This is why a bad CAP is worse than none – improvement at the project level is extremely unlikely.

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• Youtube link: https://youtu.be/jfJrzZYrccY
• Action Network: tinyurl.com/Sacramento-CAP
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