Sacramento County Climate Action Plan (CAP) – HEADS UP!

Will Sacramento County continue to avoid meaningful climate action?

Sacramento County has delayed its promised draft Climate Action Plan (CAP) until September. We hope for the best, but from what County staff has indicated, it looks like Sacramento County will continue to avoid meaningful climate action. The County’s intended process for adopting a CAP will avoid environmental review and requirements that the County prove that the CAP works. This approach neutralizes our ability to hold the County accountable as they follow a baffling and self-contradictory public process that has no legal basis. In the end, Sacramento County will be able to ignore any mitigation alternatives.

What is the County doing?

It’s complicated! Sacramento County has three tactics that, intentionally or not, muddy the CAP’s environmental process and undermine the public’s ability to influence the result: avoid environmental review, conduct a confusing and contradictory public process, and present alternatives the County can ignore. Here’s the strategy:

Avoid environmental review

Under the California Environmental Quality Act (CEQA), an environmental review of Sacramento County’s CAP must include “substantial evidence” that the proposed mitigation will work.

This is the important backstory: In 2011, the County didn’t include the required greenhouse gas (GHG) mitigation in the Environmental Impact Report (EIR) for its 2011 general plan (GP) update. The County instead promised to adopt the CAP within a year. Now, after 10 years of weak proposals and wasted time, the County claims that the 2011 EIR provided the environmental review for the CAP. As unbelievable as this seems, this allows the County to avoid presenting an alternative analysis and evidence that the CAP will work. For the proposed EIR addendum, CEQA requires only a brief explanation (soon to be released) justifying its use, based on substantial evidence.

Conduct a confusing, contradictory public process

Sacramento County claims that the 2011 EIR is adequate so a new environmental review is unnecessary. Curiously, the County still plans to carry out such a review. The problem is that the new review will have no legal basis or requirements because the 2011 EIR supposedly took care of that. As a result, the County will conduct a superficially CEQA-like process contrary to CEQA’s purpose. The County can legally ignore public input and show no evidence that the CAP is effective. And any commitments the County makes will be unenforceable under CEQA because they weren’t adopted through a prescribed CEQA process.

Present alternatives the County can ignore

Under CEQA, a full environmental review must present mitigation alternatives and select the best alternative based on substantial evidence. Instead, Sacramento County plans to present “alternatives” as attachments but not as part of the recommended CAP. Critically, they will present these alternatives after the CAP is drafted not before. The alternatives may make the recommended CAP seem like a reasonable compromise. Free of legal requirements and with alternatives that aren’t part of the CAP, the County can simply ignore the alternatives without evidence.

The 2011 EIR review is insufficient

The lynchpin of Sacramento County’s CAP adoption strategy is its claim that the 2011 EIR provides adequate CAP analysis. We await the County’s explanation but remain skeptical. The 2011 EIR didn’t include enough GHG mitigation or analysis for the GP’s adoption. That’s why the County had to promise a CAP.

How can the 2011 EIR possibly now provide adequate review of the current CAP and its proposed mitigation? Ten years have passed. Environmental conditions have changed. The climate is dramatically worse and changing far faster than was expected in 2011. We are closer to disastrous climate thresholds and the science is more clear that urgent, decisive action is essential to prevent climate catastrophe. Although new laws and GHG reduction targets are in place, GHG emissions continue to increase.


Moreover, the CAP is a pivotal policy-level plan that will propose new mitigation measures, streamline approval of new developments, and present fundamental new program-level decisions about County action (and inaction) to address climate change. These all need review.

The County’s strategy has risks

When San Diego County tried the same approach, the Sierra Club sued and the court ordered a full environmental review. San Diego County persisted and spent millions of taxpayer dollars to evade their GHG responsibilities but lost six times in trial and appeal courts. San Diego’s CAP consultant, Ascent Environmental, is now helping CAPs for Sacramento County and Rancho Cordova, which has indicated it will follow the same strategy.

Why would Sacramento County go through this convoluted, self-contradictory, and legally suspect process? Likely because passenger vehicle miles traveled (VMT) are the biggest source of countywide GHG emissions. And…

The County has plans pending for 55,000 units of new sprawl development and its climate-busting tailpipe emissions. These projects are all outside the County’s regular GP growth boundary and depend on amendments to the GP, but their VMT blows through the State’s threshold for reducing VMT from new construction by 15 percent below the per capita average. These sprawl projects would generate VMT well above average. Adopting a CAP based on the 2011 EIR and free from normal regulatory obligations would allow the County to circumvent the VMT requirements for the future projects—baking in high VMT and GHG emissions for decades to come.

350 Sacramento responds

Legal tricks won’t make the climate crisis go away. To deal with this crisis, Sacramento County needs to:

  • Provide a full environmental analysis for the CAP
  • Give the public a full range of alternatives before they publish a final draft of the CAP
  • Take Sacramento County’s 2020 Climate Emergency Declaration seriously

This will be 350 Sacramento’s perspective as we review the CAP draft. If we conclude that it streamlines sprawl without credible mitigation, presents ineffective measures, or disregards feasible alternatives, we’ll use all our advocacy tools and again ask you to support us with the Board of Supervisors. It’s up to us to insist that the County treats climate change as the crisis it is—not a bureaucratic drill to get around requirements and facilitate sprawl. Really, it’s up to all of us, and 350 is only as strong as your support. We’ll be in touch.

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