Sacramento City Council
June 21, 2022

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Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory;

Feeling is the property’s expression of the aesthetic or historic sense of a particular period of time; and

Association is the direct link between an important historic event or person and the historic property.

As the subject building does not appear to be individually significant under any of the above listed criteria, an analysis of the property’s historic integrity is not included in this report.

CHARACTER-DEFINING FEATURES
For a property to be eligible for national or state designation under criteria related to type, period, or method of construction, the essential physical features (or character-defining features) that enable the property to convey its historic identity must be evident. These distinctive character- defining features are the physical traits that commonly recur in property types and/or architectural styles. To be eligible, a property must clearly contain enough of those characteristics to be considered a true representative of a particular type, period, or method of construction, and these features must also retain a sufficient degree of integrity. Characteristics can be expressed in terms such as form, proportion, structure, plan, style, or materials.

Though 211-217 North 16th Street was not found individually eligible for listing in the California Register, the building’s character-defining features that allow it to contribute to the North 16th Street Historic District include, include but are not limited to:

Mass & Form
• Square footprint composed of multiple smaller volumes with differing roof forms • One-story height
• Moderately pitched gabled roof along front facade
• North and east facades divided by brick piers into regular bays of window and garage door openings
Exterior Materials
• Brick cladding and piers laid in common bond, dating to the period of significance of the North 16th Street Historic District (1905-1963)
• Red clay tile roofing
• Corrugated metal roofing
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• Concrete lintels
Fenestration
• Storefront at the corner of North 16th Street and North C Street with brick bulkhead walls, large display windows, and transom windows
• Locations and proportions of infilled storefront windows at the center of the front facade • Multi-lite steel windows
• Wire glass skylights
• Garage door openings and outlines of infilled garage door openings

VII. CONCLUSION
The building at 211-217 North 16th Street was primarily constructed during two different periods.

The oldest portion of the building was originally constructed in 1922 as part of the headquarters for A. Meister & Sons Company, an automobile, truck, bus, and railcar body manufacturer. At the time, it was one of the first and only industrial buildings constructed in the North 16th Street area. In 1932, all but the north wing of this building was demolished and replaced with a new building, containing a garage, auto service station, and restaurant. This new building was constructed by Sacramento contractor C.J. Hopkinson as an investment property for owner George L. Baxter, who leased it to various tenants. A restaurant or tavern remained in the building through the 1960s, and a truck and auto repair shop continued through 1975.

Page & Turnbull evaluated the property for individual significance according to the criteria of the California Register. The existing building on the property does not appear to be directly associated with significant historical events or significant individuals in local, state, or national history. It is not a strong example of a particular architectural style or movement, nor is it the work of a master architect or builder. Thus, Page & Turnbull finds that the property does not appear to be individually eligible for listing on the California Register under any criteria. However, the building continues to readily reflect the history of industrial, transportation, and automotive-related development along North 16th Street area and remains a contributor to the locally designated North 16th Street Historic District. Thus, the property qualities as a historic resource for the purposes of review under the California Environmental Quality Act (CEQA).

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VIII. REFERENCES
Published Works & Reports
Avella, Steven. Sacramento: Indomitable City. San Francisco: Arcadia Publishing. 2003.

Boghosian, Paula. “1501 N. C Street.” DPR 523. California Office of Historic Preservation. 2009. --- . “1610-1620 North C Street.” DPR 523. California Office of Historic Preservation. 2009. --- . “Acme Beverage Co.” DPR 523. California Office of Historic Preservation. 2009. --- . “Flying ‘A’ Gas Station Building.” DPR 523. California Office of Historic Preservation. 2009. --- . “Mack Truck International Corp., Crest Carpet Co.” DPR 523. California Office of Historic Preservation. 2009.
--- . “Russell Brothers Company.” DPR 523. California Office of Historic Preservation. 2009. --- . “Sacramento Pipe Works.” DPR 523. California Office of Historic Preservation. 2009. --- . “Sacramento Produce Building.” DPR 523. California Office of Historic Preservation. 1998. --- . “Triangle Produce Building.” DPR 523. California Office of Historic Preservation. 2009. --- . “W.A. Ward Seed Company.” DPR 523. California Office of Historic Preservation. 2009. --- . “Western Body Company.” DPR 523. California Office of Historic Preservation. 2009.

Brechin, Gary and Lee M.A. Simpson. “Unseen Investment: New Deal Sacramento.” In River City and Valley Life: An Environmental History of the Sacramento Region. Ed. Christopher J. Castaneda and Lee M.A. Simpson. Pittsburgh: University of Pittsburgh Press. 2013.

Burg, Willam. Sacramento’s K Street: Where Our City Was Born. Charleston, SC: The History Press. 2012.

California Office of Historic Preservation. Technical Assistance Bulletin No. 7: How to Nominate a Resource to the California Register of Historical Resources. Sacramento: California Office of State Publishing, September 4, 2001.

California Office of Historic Preservation. Technical Assistance Bulletin No. 8: User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory.

Sacramento: California Office of State Publishing. November 2004. Accessed October 22, 2018, http://ohp.parks.ca.gov/pages/1069/files/tab8.pdf.

CEQA Guidelines. Accessed May 10, 2018. http://resources.ca.gov/ceqa/guidelines/.

Dudek. “Cultural Resources Report for the Blue Diamond Growers (BDG) A Street Annex Building Project.” 2018.

Environmental Science Associates. “R Street Corridor Historic District Survey Report.” Report. City of Sacramento Preservation Commission. 2017.

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Historic Environment Consultants. “River District Architectural and Historical Property Survey Update.” 2009.

Orsi, Richard J. “Railroads and the Urban Environment: Sacramento’s Story.” In River City and Valley Life: An Environmental History of the Sacramento Region. Ed. Christopher J. Castaneda and Lee M.A. Simpson. Pittsburgh: University of Pittsburgh Press, 2013. “Sacramento Deep Water Ship Channel Limited Reevaluation Report (LRR) with Project Economic Analysis.” Report. US Army Corps of Engineers. 2011.
https://www.spn.usace.army.mil/portals/68/docs/srdwsc/appendix_e.pdf.

Newspapers & Periodicals
“20,000 Fire Hits North 16th Street Building.” Sacramento Bee. 27 February 1943. “Amy Sprague Married to George Baxter.” Sacramento Bee. 11 June 1932. “Auto Body Plant Has Big Payroll.” Sacramento Bee. 4 August 1923. “Baxter.” Sacramento Bee. 24 January 1977.
“Ben McDonald.” The Press-Tribune (Roseville, CA). 4 April 1985. “Clarence J. Hopkinson.” Sacramento Bee. 14 October 1979. “Clarence Hopkinson is Named Y.M.C.A. Leader.” Sacramento Bee. 10 January 1934. “Development.” Sacramento Bee. 28 October 1922.
“Divorce Is Asked From Truck Service Coowner.” Sacramento Bee. 24 September 1954. “Elks to Conduct Final Rites for Edward Meister.” Sacramento Bee. 17 June 1929. “For Sale.” Sacramento Bee. 1 August 1924.
“Furniture Store Has Steer for All Seasons.” Sacramento Bee. 11 January 1990.

General Motors Trucks & Trailers advertisement. Sacramento Bee. 1 August 1935. “George F. Waugh.” Sacramento Bee. 14 July 1964,
“George L. Baxter Succumbs at Bay.” Sacramento Bee. 6 October 1938. “Henrietta Hopkinson.” Sacramento Bee. 4 September 1962. “Installs Equipment.” Sacramento Bee. 25 August 1937.
“Judgment for $35,000 South By D.F. Appling.” Sacramento Bee. 28 January 1928. “Local Men Are Named to Head New Reo Agency.” Sacramento Bee. 12 August 1936. “Make Trip to Quincy in Seven Hours.” Sacramento Bee. 2 March 1918. “McDonald, Doris Marie.” Sacramento Bee. 13 July 1998.
“Meister Factory Sold to George Baxter at $31,500.” Sacramento Bee. 6 May 1925.

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“Meister Company to Build Plant in Fresno.” Sacramento Bee. 28 January 1922. “New Garage, Stores To be Opened Monday.” Sacramento Bee. 9 September 1932. “Remember When.” Sacramento Bee. 3 July 1983.
“Seeing Red.” Sacramento Bee. 7 February 2007.
“Society Notes.” Sacramento Bee. 22 July 1915.
“Spur Tracks Are Approved In One-Sided Hearing.” Sacramento Bee. 2 October 1923. “Terminal Truck Service Moves to Broderick.” Sacramento Bee. 22 October 1972. “Three Directors Are Honored For Service to YMCA.” Sacramento Bee. 24 May 1948. “Three Firms Begin Business in Industrial Tract North of City.” Sacramento Bee. 19 August 1931. “Three Plans Will Avoid Sixteenth Street Crossings.” Sacramento Bee. 24 February 1924. “Twenty-Four Passenger Auto Bus for Stage Line.” Sacramento Bee. 8 May 1915. “Stock Sale Permit Is Granted Meister and Sons.” Sacramento Bee. 12 July 1921. “Vernard B. Bennett.” Sacramento Bee. 4 April 1979.
“Weeks Building Permits Reach $135,075 Total.” Sacramento Bee. 7 June 1924.

Public Records
California State Office of Historic Preservation. Built Environment Resource Directory (BERD).

Sacramento County. Updated March 2020.

Archival Records
1900 United States Federal Census, Ancestry.com.
1910 United States Federal Census. Ancestry.com.
1920 United States Federal Census, Ancestry.com.
1930 United States Federal Census, Ancestry.com.
1940 United States Federal Census, Ancestry.com.

Building permit records. City of Sacramento.

California, U.S. Death Index, 1940-1997, Ancestry.com.

California, U.S., Marriage Index, 1960-1985, Ancestry.com.

Property records. Sacramento County Clerk-Recorder.

Sacramento city directories, 1922-1982. Ancestry.com.

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Sacramento County Assessor Map Books. Center for Sacramento History.

Sanborn Map Company fire insurance maps. Sacramento, California. Sacramento Public Library.

U.S. Find a Grave Index, 1600s-Current, Ancestry.com.

U.S. Social Security Applications and Claims Index, 1936-2007, Ancestry.com.

U.S., World War I Draft Registration Cards, 1917-1918. Ancestry.com.

U.S., World War II Draft Cards Young Men, 1940-1947, Ancestry.com.

Internet Sources
City of Sacramento Municipal Code, 17.604.210 Criteria and requirements for listing on, and deletion from, the Sacramento register, accessed June 30, 2021,
http://www.qcode.us/codes/sacramento/view.php?topic=17-vi-17_604-ii- 17_604_210&frames=on.

Photo Record for 1983/001/SBPM02259. Center for Sacramento History. Accessed July 12, 2021, https://sacramento.pastperfectonline.com/photo/B9B3F74F-C05F-43FC-AC7D- 014473206224.

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IX. APPENDICES
Appendix A – Building Permit Applications
Front and back pages of building permit applications currently on file with the City of Sacramento.

Cancelled and expired permits are not included.

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Appendix B – Preparer Qualifications
This Historic Resource Evaluation Part 1 was prepared by the Page & Turnbull offices of Sacramento and San Francisco, California. Page & Turnbull staff responsible for this report include: Ruth Todd, FAIA, Principal-in-Charge; Melisa Gaudreau, Project Manager, Christina Dikas, Associate Principal; and Clare Flynn, Cultural Resources Planner, primary author, all of whom meet or exceed the Secretary of the Interior’s Professional Qualification Standards for Historic Architecture, Architectural History, or History.

Preservation Director’s Independent Analysis
Grower’s District – P21-024

The Planning Division of the Community Development Department has received an entitlement application from Growers District, LLC (Applicant), which is being reviewed under Record No. P21-024 and is also referenced as “Grower’s District” (Project). The Project is comprised of three development sites individually identified as Site 200, Site 211, and Site 215. The scope of this evaluation is limited to the individual sites listed on the Sacramento Register of Historic and Cultural Resources (Sacramento Register) , specifically Sites 200 and 211, and is focused on the preservation-related characteristics of physical development of these sites.

Land Use & Entitlements

All three sites are located within the Employment Center Low Rise (ECLR) general plan designation, the Heavy Commercial (C -4-SPD) zone, and the River District Special Planning District (SPD). Two of the sites, Sites 200 and 211, are listed on the Sacramento Register, specifically as contributing resources to the North 16 th Street Historic District (Historic District) . Site 215 is outside of the Historic District and is not listed on the Sacramento Register. None of the sites are listed on the National Reg ister of Historic Places (National Register) or California Register of Historical Resources (California Register).

The Project includes a request for three entitlements:

1. Rezone from the Heavy Commercial (C-4-SPD) zone to the General Commercial (C-2-SPD) zone within the River District Special Planning District (SPD)

2. Site plan and design review for:
a. Demolition (as defined in Sacramento City Code (SCC) section 17.108.090) of Sites 200 and 211
b. Construction of four mixed -use buildings on Sites 200, 211, and 215 with approximately 525 residential units and 71,000 square feet of nonresidential space
c. Deviations to development standards associated with height and multi -unit open space

3. Tree permit for removal of three trees within the public right-of-way

Historical Documentation

An architectural survey within the Project area was conducted by the Redevelopment Agency in 2009 and 2010. The Historic District was listed on the Sacramento Register in 2011 as part of the adoption of the River District Specific Plan. In 2019, the North 16 th Street Historic District Plan (HDP) was adopted as a part of the larger Historic District Plans and Sacramento Register Update initiative. However, an intensive evaluation of the buildings’ architectural and historic context has not been previously conducted by the Planning Division.

The HDP establishes a period of significance for the Historic District between 1905 and 1963 which coincides with the reclamation of the swamp lands of the original American River channel and the opening of the Port of Sacramento. The Historic District reta ins a collection of industrial buildings, unified in their architectural representation of the region’s agricultural industry. Key character-defining features identified in the HDP and applicable to the Project include the following elements:
 Primarily industrial buildings with some commercial buildings concentrated along 16th Street
 Some exterior walls curve along adjacent rail spur alignments  Predominately unpainted brick, corrugated metal, reinforced concrete, concrete block, plaster, or wood siding
 Flat or bowed roofs, often with stepped, arched, or variously shaped parapets  Corrugated metal or clay tile roofs
 Large truck bays, concrete loading docks, truck ramps primarily located along the east-west streets
 Industrial metal sash windows
 Some commercial buildings with large, showroom windows on first stories, generally along North 16th Street
 Decorative cornices
 Blind arches
 Most buildings and structures are built to property lines and oriented to transportation alignments, whether streets or railroad tracks for car-, truck-, or rail- related operations
 Minimal or no property landscaping
 Most east-west streets and rail spur alignments dominated by transportation and loading functions and are not developed with standard curbs, gutters, sidewalks, planter strips, or street trees
 Railroad tracks of the rail spurs

Associated with the Project, two historic resource evaluations (HREs) prepared by Page & Turnbull, consultants on behalf of the Applicant:
 “Sacramento Produce Terminal Building, 200 North 16th Street, Historic Resource Evaluation” dated February 22, 2022, and related to Site 200  “211-217 North 16 th Street, Historic Resource Evaluation ” dated February 22, 2022, and related to Site 211

The HREs included analysis of each building related to eligibility for listing as a historical resource for the purposes of review under the California Environmental Quality Act (CEQA), r etention of integrity sufficient to convey its historic significance , and Identification of character-defining features
Preservation Director’s Determination

The Preservation Director has received and reviewed the HREs and confirms that the HRE authors are qualified for listing under the Secretary of the Interior’s Professional Qualifications Standards and/or California H istorical Resources Information System Historical Resources Consultants List.

The HRE concludes that Site 20 0 s atisfies three of the four criteria for listing on the California Register at the local level : Criterion 1 (Events) for its association with Sacramento’s development as an agricultural hub and the North 16 th Street area’s development as an industrial center; Criterion 2 ( Persons) for its association with two individuals that catalyzed the North 16 th Street as an industrial center; and Criterion 3 (Architecture) as an example of a mid -century produce terminal market building.

Additionally, the HRE concludes that Site 200 satisfies all seven aspects of integrity:
location, setting, design, materials, workmanship, feeling, and association . The Preservation Director concurs with this assessment and notes that the Site’s current listing on the Sacramento Register already qualifies it as historic resources for the purposes of CEQA.

The HRE Site 211 did not satisfy any criteria for listing on the California Register and did not appear to possess significance under any aspect of integrity. The Preservation concurs with the HRE’s conclusion Site’s current listing on the Sacramento Register already qualifies it as historic resources for the purposes of C EQA. While evaluated on its own, the building may not individually possess overall integrity. However, when viewed from the south while travelling on North 16 th Street, its proximity to Site 200 and other buildings such as the 116 North 16 th Street (currently occupied by Sacramento Pipe Works), location abutting the sidewalk, and its exterior (brick, storefront windows) does convey the broader area’s historical significance.

The HRE identifies character-defining features for both Sites 200 and 211. Many of these characteristics are reflected in the previously identified character-defining features of the Historic District. Planning Division staff has analyzed the Project for consistency with the Secretary of the Interior’s Standards for the Treatment of Historic Properties, specifically Standards for Rehabilitation (Secretary of the Interior Standards) and identifies the character-defining features that will be retained. That analysis concluded that sufficient character-defining features wi ll be retained to allow for the expression of the historic identity. The Preservation Director concurs with this assessment.

Planning Division staff concluded that both Sites 200 and 211 are consistent with the Secretary of Interior Standards. The Preservation Director concurs with this assessment.

The Project is being undertaken, in part, to provide additional dwelling units. However, the historic buildings are not easily converted to residential spaces that meet contemporary building and life safety requirements and the relatively small size of existing building square footage limits the income stream that would allow for retention of the buildings without additional leasable area. Furthermore, while the buildings have been partially occupied un til 2021, the buildings have deferred maintenance issues and damage associated with vandalism. These factors are unlikely to change in the near - term and continued vacancy m ay place these buildings at risk for loss as cultural resources.

The Project advances several policies including but not limited to:
 General Plan – Historic and Cultural Resources Policy HCR 2.1.7 Historic Resource Property Maintenance. The City shall encourage maintenance and upkeep of historic resources to avoid the n eed for major rehabilitation and to reduce the risks of demolition, loss through fire or neglect, or impacts from natural disasters.
 General Plan – Historic and Cultural Resources Policy HCR 2.1.11 Compatibility with Historic Context. The City shall review proposed new development, alterations, and rehabilitation/remodels for compatibility with the surrounding historic context. The City shall pay special attention to the scale, massing, and relationship of proposed new development to surrounding historic resources.  General Plan – Historic and Cultural Resources Policy HCR 2.1.14 Adaptive Reuse. The City shall encourage adaptive reuse of historic resources when the original use of the resource is no longer feasible.
 General Plan – Central City Community Plan Policy CC.HCR 1.1 Preservation.

The City shall support programs for the preservation of historically and architecturally significant structures which are important to the unique character of the Central City.
 River District Specific Plan Policy HR1a. Ensure that historic properties help to enhance and provide a valuable special sense of place in the River District.

The Project is also consistent with the purpose of the historic preservation regulations established in SCC section 17.604.100.A that identifies the recognition and preservation of our cultural resources as tools to sustain and revitalize neighborhoods and business districts within the city, enhance the city’s economic, cultural and aesthetic standing, its identity and its livability, marketability and urban character.

Based upon the analysis provided, the Preservation Director concludes that the Project as proposed preserves the essential character-defining building features that convey the historical significance of the buildings. The selective demolition proposed as part of the Project, and the retention and preservation of significant features or characteristics proposed as part of the Project is a practice consistent with the Secretary of the Interior’s Standards and does not, in the j udgement of the Preservation Director, constitute a significant adverse change to each of the property’s historic character, nor removes the justification for its continued listing as an historic resource for the purposes of the CEQA(pursuant to CEQA Guidelines section 15064.5(b)(2).

18576130.1
Hanson Bridgett LLP
500 Capitol Mall, Suite 1500, Sacramento, CA 95814
ROBIN R. BARAL

SENIOR COUNSEL
DIRECT DIAL (916) 491-3052
DIRECT FAX (916) 491-3085
E-MAIL [email protected]
June 7, 2022

VIA E-MAIL

City of Sacramento
Planning and Design Commission
915 I Street
Sacramento, CA 95814-2671

Re: The Grower’s District (Planning Application P21-024)

Dear Chair and Members of the Commission:

Our office represents Blue Diamond Growers in connection with its review of the proposed Grower’s District project. Blue Diamond has raised concerns to the City and applicant, largely with regard to Site 211 (211 N. 16th Street) located adjacent to Blue Diamond’s central campus, as the proposed development of 105 units at Site 211 significantly exceeds the development standards established by the River District Specific Plan. Blue Diamond’s concerns are further compounded by the fact that the City has impermissibly foregone environmental review of the project pursuant to the California Environmental Quality Act (Pub. Res. Code § 21000 et seq., CEQA). Blue Diamond respectfully requests that the City take appropriate steps to discontinue the public hearings for the proposed project, and to review the proposed project in accordance with the City’s obligations as the lead agency for this project under CEQA.

When Blue Diamond first learned of this project and reached out to City planners in January 2022, staff responded that they would recommend that the project be deemed exempt from CEQA pursuant to Public Resources Code section 21155.4. Blue Diamond has disputed the applicability of that and other CEQA exemptions but, rather than formally oppose the project, requested a focused review of noise, lighting and other potential impacts to ensure that impacts of Site 211 could be evaluated prior to the issuance of project entitlements. Unfortunately, neither the City nor applicant meaningfully addressed Blue Diamond’s concerns related to Site 211 and the proposed siting of a multifamily, mixed-use development immediately adjacent to Blue Diamond’s active warehousing operations.
1 Overall, the City implemented a few cosmetic
changes to the project, without directly addressing or evaluating the project’s interface with Blue Diamond’s industrial operations. In addition, the City opted to defer essential acoustic and lighting studies until after entitlements have been approved. Overall, the City’s planning staff has opted to expedite this proposed project rather than engage in the careful planning that should be required in order to effectively site a large, high-density mixed-use residential site

1 Blue Diamond’s central campus contains the world’s largest almond factory, the world’s only almond innovation center, and 20 processing lines. Blue Diamond has invested in major capital improvements, most recently to improve bagging and packaging capacity at its campus. Major policy changes by the City, to allow significantly more residential capacity immediately adjacent to Blue Diamond’s campus, should require careful planning to ensure orderly development and to reduce future land use conflicts.

Planning and Design Commission
June 7, 2022

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adjacent to the City’s largest remaining industrial operation. Over time, this lack of foresight into proper planning will jeopardize Blue Diamond’s viability of remaining in the City of Sacramento.

Given the City and applicant’s inability to meaningfully address Blue Diamond’s concerns, this letter urges the City to comply with its obligations under CEQA so that potential impacts of the project, particularly regarding traffic/transportation, noise, air quality, and land use compatibility, can be addressed and mitigated. CEQA was designed specifically for this purpose, to identify potential impacts, impose mitigation measures to reduce those impacts, and ultimately carry out the City’s obligation for informed decision-making. Any approval of the project without complying with CEQA’s procedural requirements would be invalid as a matter of law, given that no legally defensible CEQA exemptions apply to the Grower’s District project.

The Project Exceeds the Development Standards under the River District Specific Plan and its implementing River District SPD zoning ordinance; therefore the City Cannot Make Legally Defensible Specific Plan Consistency Findings The staff report relies on the CEQA exemption authorized under Public Resources Code section 21155.4, which requires a finding that the proposed project is consistent with a specific plan for which an environmental impact report has been certified. In this case, the City cannot make such a finding because the proposed project significantly exceeds the development standards under the River District Specific Plan and it's implementing River District SPD zoning ordinance.

The River District Specific Plan clearly envisioned that Sites 200, 211 and 215 would be developed pursuant to the City’s Heavy Commercial (C-4) zoning. (RDSP, p. 16) The proposed rezoning of each site from C-4 to General Commercial (C-2) will, as a result of the rezone, allow a significant increase in density at these sites that is inconsistent with the buildout projections for the 16th Street corridor under the Specific Plan. Further, the proposed rezone is not exempt from CEQA review under Government Code 65457 because the zoning action is not being taken to bring the City’s zoning code into compliance with the Specific Plan. Rather, the opposite is occurring here: the City is proposing to rezone these three parcels to allow development at a much greater intensity than what the Specific Plan envisioned.

The City staff report is telling, where it merely concludes, without any substantial evidence or additional findings, that the “proposed project’s land use is consistent with the RDSP.” (Page 10, Findings of Fact, Section 2.A.iv, p. 46.) The Project Background in the staff report, however, describes the proposed rezone and acknowledges that a rezone from Heavy Commercial to General Commercial is needed in order for the City to make the necessary consistency findings for the proposed project:

The applicant is requesting a rezone to the C-2-SPD zone which allows a mixed-use development to be evaluated based on consistency with the General Plan FAR range (rather than density established by the General Plan). Unlike the C-4-SPD zone, the C-2-SPD zone does not establish a density and FAR standard…. Additionally, because the C-2-SPD zone references only FAR and density established by the General Plan, it allows development to exceed the maximum FAR if a significant community benefit is pursuant to General Plan Policy LU 1.1.10.
(Page 16.) The staff report is referring to the City’s C-4 zone density limitations, which limit maximum density under the existing zoning for all three sites to 60 dwelling units per net acre.

Planning and Design Commission
June 7, 2022

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(City Code, § 17.216.930.) By rezoning each site to C-2, the proposed project must instead comply with the “minimum and maximum densities [that] are established in the general plan.” (City Code, § 17.216.720.) Rezoning the property from C-4-SPD to C-2-SPD, is therefore a prerequisite to increase the allowable density at the site from the zoning incorporated by the Specific Plan (C-4-SPD) into the City’s more amorphous density and FAR requirements under the 2035 General Plan for Employment Center Low Rise (C-2-SPD), which has no maximum density, and which allows adjustments to maximum FAR if the City finds that the proposed project will provide significant community benefits. (General Plan p. 2-9, 2-39.) The above excerpts clearly show, from the perspective of the City’s own planning staff, that the purpose of the proposed rezone is to facilitate development of each of the three sites at much greater development intensity than what was envisioned under the River District Specific Plan and its implementing SPD zoning. Specifically, the proposed rezone will allow Site 211 to be developed at an effective density of more than 177 dwelling units per acre, while the existing zoning implemented by the River District SPD allows a maximum of 60 dwelling units per acre.

If the City’s rationale were extended throughout the Specific Plan area, and each parcel could be up-zoned for a 300% increase in development intensity without further environmental analysis, this approach would render the land use standards in the River District Specific Plan, and the associated environmental review that was conducted under CEQA, meaningless. Based on the above, the City cannot rely on Public Resources Code section 21155.4 as a basis for finding the Grower’s District project exempt from CEQA.

The City Cannot Legally Support Its Finding that the Project is Consistent with SACOG’s Sustainable Communities Strategy
Public Resources Code 21155.4 requires the City to make a finding that the project “is consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in either a sustainable communities strategy…” in order for a CEQA exemption based thereon to be legally defensible. The staff report for the proposed project concludes, without any additional support, that “the project’s proposed land uses are consistent with the range of land uses, densities, and building intensities…” for projects located in the Center/Corridor Community under SACOG’s 2020 Sustainable Communities Strategy (SCS). SACOG, in turn, issued a letter concurring with the City’s finding, but providing no further evidence or documentation to support this finding. The only reference by either agency is generally to Appendix D of the SCS.

The City cannot defensibly find that the proposed project is consistent with SACOG’s SCS, as the SCS was based on the proposed buildout under the existing Specific Plan and SPD zoning.

Appendix D of the SCS notes that the “general plan and specific plan development activities occurring in the region by the local jurisdictions are reflected in the population, housing, and employment forecasts for the 2040 MTP/SCS….” The SCS therefore relied on the City’s growth projections under the River District Specific Plan, in part to determine the range of development intensity for the Center/Corridor Community. More specifically, in evaluating the future growth of the Sacramento central city and Center/Corridor Community, the SCS describes all of the planned growth under existing Specific Plans, including the River District area, which includes Township 9 and other areas where the River District Specific Plan proposed significant residential densities and building heights.

Planning and Design Commission
June 7, 2022

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Based on the above, the City relies on circuitous logic to support an alleged CEQA exemption under Public Resources Code section 21155.4. In order to do so, the City must document that the project is consistent with all applicable River District land use standards and SPD zoning.

The City cannot do so, however, as it has noted that the project requires a rezone to allow a 300% increase in residential density for Site 211, and more than a 150% increase in density overall, along with height exceptions and other deviations from the Specific Plan and its SPD zoning.

No Other CEQA Exemptions Apply in this Case
While no other bases for a CEQA exemption are stated in the staff report, we note that this project is not subject to the specific plan exemption under Government Code 65457, for the additional reason that the project proposes both commercial and residential development concurrently with the project buildout. (See, e.g, Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, ruling that a mixed-use project may utilize the residential specific plan exemption for a particular phase that involves only residential development.) Further, the City cannot rely on the Class 32 categorical exemption for urban infill projects (14 Cal. Code Reg. § 15532) because the proposed project exceeds the five-acre maximum, and is inconsistent with the River District Specific Plan and existing zoning of each site.

The Proposed Project May Reasonably Result in Potentially Significant Impacts that Require Further Analysis in a Mitigated Negative Declaration or EIR For all of the above reasons, Blue Diamond respectfully requests that the City take appropriate steps to discontinue the public hearings for the proposed project, and to review the proposed project in accordance with its obligations under CEQA. A 300% increase in density on Site 211, and a more than 150% increase in baseline density overall for the project, raises a fair argument that the project will have the potential to cause significant impacts to the environment that will require further evaluation, and all feasible mitigation measures imposed. For example, the interface between Site 211 and Blue Diamond’s central campus raises significant concerns regarding the overall impacts to circulation, potential land use conflicts with the City’s adopted plans and policies including the established truck route into Blue Diamond’s central campus, and potential public safety hazards due to the increase of queuing that could occur if Blue Diamond truck deliveries are limited from using the main entrance along North B Street. Noise impacts of the project must be evaluated given the existing baseline includes traffic along 16th Street and Blue Diamond’s industrial operations. The proposed project must also contend with an existing environmental baseline that involve odors and other air quality impacts, particularly given Blue Diamond’s ongoing regulatory requirements for hot spot air monitoring. Project construction would also likely contribute to regional air quality emissions that require implementation of mitigation measures from Sacramento Air Quality Management District.

Most importantly, the decision to rezone the property to facilitate much greater residential density along parcels immediately adjacent to, and in close proximity to Blue Diamond’s central campus constitutes a significant change in City policy under the River District Specific Plan that should only be made through informed decision-making, which CEQA was enacted specifically to provide for the benefit of this Commission, the public, and concerned parties such as Blue Diamond.

Planning and Design Commission
June 7, 2022

18576130.1
Thank you for considering Blue Diamond’s comments regarding this proposed project. As Blue Diamond has asserted throughout the City’s processing, we are willing to work collaboratively with the City and the applicant to ensure that this project is successful, provided that Blue Diamond’s concerns regarding potential land use impacts are meaningfully addressed. At this point, the only viable means for the City to address those potential impacts is to comply with its obligations as the lead agency for this project under CEQA.

Sincerely,

Robin R. Baral

RRB

Angel Anguiano
City of Sacramento
Community Development Department
300 Richards Boulevard, Third Floor
Sacramento, California 95811

May 5, 2022

P21-024 - 200, 211, 215 N 16th Street

Dear Mr. Anguiano,

The River District is very excited to support the proposed development for the properties located at 200, 211 and 215 North 16th Street and we understand the project will come before the Preservation Commission on May 18, 2022.

With this letter the River District wishes to convey our delight to see the project moving forward.

These beautiful old brick buildings are treasured assets of the River District, and we are pleased to see a use being suggested that will elevate and activate North 16th Street towards the mixed uses it deserves and should have. We enthusiastically support this project that will bring much needed housing, retail, and restaurant vitality to the area.

We have been very pleased with the developer’s accessibility, willingness to engage with our board of directors and their thoughtful consideration of community input about the proposed adaptive reuse of an historic building in the River District. It will be a real feather in the City’s cap to have supported such a creative development for a structure designed by the same architect as the Memorial Auditorium and other landmark buildings in the City center.

The River District stands firmly in support of this development and urges the Preservation Commission to move the project forward and into the construction phase. We cannot wait to see the new life fill this old building and experience the vibrancy it will bring to the River District.

Best regards,

Jenna Abbott
Executive Director, The River District and Capitol Station Associates 610 Bercut Drive
Suite B1
Sacramento, CA 95811

cc. Office of District 3 Councilmember Jeff Harris
Office of County Board Supervisor Phil Serna, County District 1 Captain Ethan Hansen, Sacramento Police Department
Matt Eierman, City of Sacramento Parking Services
River District Board of Directors

777 12th Street, Ste. 300 • Sacramento, CA 95814
Tel: 916-874-4800 • Toll Free: 800-880-9025
AirQuality.org

September 24, 2021

Robby Thacker, Associate Planner
City of Sacramento Community Development Department
300 Richards Boulevard, 3rd Floor, Sacramento, CA 95811

Subject: The Grower’s District (P21-024)

Dear Robby Thacker:

Thank you for providing the Sacramento Metropolitan Air Quality Management District (Sac Metro Air District) with the opportunity to review the project routing for The Grower’s District project, a request to construct four mixed-use buildings and associated improvements with a deviation request for height on a 6.29-acre project site located within the River District Special Planning District and North 16th Street Historic District. We offer the comments below on project site improvements and other considerations to benefit air quality and public health and reduce greenhouse gas (GHG) emissions.

CEQA
This project exceeds Sac Metro Air District screening criteria for operational analysis of project GHG impacts under the California Environmental Quality Act (CEQA), so it is particularly important that it maintain consistence with the City of Sacramento’s Climate Action Plan (CAP). Consistence with the City’s CAP would include consistence with its CAP Checklist, including the water and energy efficiency measures therein, in addition to general consistency with the CAP goals and policies. Sac Metro Air District recommends consulting our Guide to Air Quality Assessment in Sacramento County (CEQA Guide), available on our website, for any project CEQA review. Further, because this project is located in in the River District Special Planning District, it is subject to mitigation measures in the Mitigation Monitoring Program in the Environmental Impact Report, pursuant to CEQA, for the River District Specific Plan, which includes measures that mitigate construction-related air quality and climate impacts, as discussed below in the section on “Construction.”

Multi-Modal Transportation
This project is within a ½ mile walk of the planned Sacramento Regional Transit (SacRT) Dos Rios light rail station. Sac Metro Air District commends this project because it is walkable compact infill housing development near a SacRT light rail station. This kind of development is associated with reduced motor vehicle miles traveled (VMT) and resulting polluting emissions. It supports state and regional plans to reduce polluting motor vehicle emissions, including the Sacramento region’s Metropolitan Transportation Plan and Sac Metro Air District’s Sacramento Regional Ozone Attainment Plan and other plans for meeting federal and state air quality standards.

To fully utilize the potential of urban infill to reduce VMT and associated air polluting emissions, the project should provide for the best possible accommodations for sustainable modes of transportation such as walking, bicycling, and transit. High quality pedestrian accommodations are also critical to

The Grower’s District
transit success. Please accept the following Sac Metro Air District recommendations to improve multi- modal transportation for this project:

 Provide continuous tree shading to the public sidewalk frontage, to the full extent feasible, to create healthier pedestrian conditions (see the section below on “Urban Heat Island Effect”) that are also more conducive to walking. Studies have correlated neighborhood tree shade to increased use of pedestrian transportation. Specifically, we recommend that project implementation incorporate the following:

o Tree shading along the North 16th Street sidewalk frontage of Buildings 215 and 211.

This is particularly important due to that area’s western exposure. The hottest temperatures daily occur with afternoon sun from the west. This recommendation would provide for project consistence with the City’s River District Design Guidelines (Design Guidelines) Section 16 specifications for 16th Street. Tree plantings should meet the Design Guidelines tree spacing, canopy coverage, and other specifications (see page 3-84).
o At least one additional tree on North B Street on the south side of Building 211. This recommendation would provide for project consistence with the referenced Design Guidelines tree spacing and canopy coverage specifications. o A trellis to provide vegetative shade along the pedestrian frontage on the south side of Building 200. The “loading dock” area appears to accommodate pedestrian traffic on project plans and could accommodate a trellis.

For all project tree plantings, we recommend using air-quality supportive trees, with approximately 35-foot wide canopies, selected from the Sacramento Tree Foundation’s Shady Eighty guide. The Shady Eighty guide provides a directory of air-quality supportive trees with information for each species on shade canopy, necessary distance between plantings, and more.

 Ensure short-term bike parking within 50 feet of primary entrances, meeting the City’s commendable Bike Rack Design and Placement Design Standards. Long-term bicycle parking appears to be accommodated through bicycle parking rooms on project plans, but it is not clear where short-term bicycle parking is accommodated.

Placement of residential short-term bicycle parking along project street frontage, within 50 feet of primary entrances, would enable easy guest access, and enable residents to make multiple bicycle trips during the day without the added effort of stowing their bicycle in a bicycle storage room.

For optimal security, place parking for retail or other public commercial uses so that it is visible from inside the use.

 Implement an unbundled parking program for residential tenants, which separates the cost of housing from the cost of automobile parking. Unbundled parking allows residents to opt out of paying for parking by excluding parking cost from rental cost for the project housing units.

The Grower’s District

Urban Heat Island Effect
The Sac Metro Air District participated in the 2020 Capital Region Transportation Sector Urban Heat Island Mitigation Project (UHI Project), producing a report on urban heat island effect impacts on the Sacramento region, and mitigation strategies for these impacts. The urban heat island effect already presents a serious challenge for our region, according to the report. Urbanized areas in Sacramento range 3 to 9 degrees Fahrenheit warmer than surrounding areas, which results in decreased air quality and associated public health impacts. The urban heat island results from the conversion of undeveloped land to urbanized land.

The measures below to reduce urban heat island effect impacts are consistent with both the UHI Project and the City of Sacramento Climate Action Plan Policy LU 2.6.8, which stipulates that “The City shall reduce the ‘heat island effect’ by promoting and requiring, where appropriate, such features as reflective roofing, green roofs, light-colored pavement, and urban shade trees and by reducing the unshaded extent of parking lots.” To help reduce temperatures in the immediate vicinity of the project, as well as to contribute regionally to a reduction in the urban heat island effect, Sac Metro Air District recommends the following measures:

 All new structures utilize certified cool roofs. The 2019 California Building Energy Efficiency Standards suggests an aged solar reflectance of at least 0.63 for low-sloped roofs and at least

0.20 for steep-sloped roofs, and minimum thermal emittance of 0.75. The Cool Roof Rating Council provides a product directory of roofs.

 Landscaping incorporates new trees to shade new and existing pavements and structures to the full extent feasible. Our recommendation above on sidewalk shading would also help reduce urban heat island effect impacts. As a reminder, for the outdoor surface parking, the project will need to comply with City of Sacramento parking lot tree shade requirement for 50% parking lot tree shade coverage on “all surfacing on which a vehicle can drive and all parking stalls” (City Code Section 17.612.040 (A)).

Building Electrification
The City’s New Building Electrification Ordinance requires all-electric construction for newly constructed buildings with building permit applications filed starting January 1, 2023 at the earliest.

 To improve public health and reduce GHG emissions, the Sac Metro Air District recommends that all project buildings be all-electric, with no natural gas connections.

Operating buildings without burning natural gas provides substantial public health benefits. Homes in which gas stoves are used have nitrogen dioxide concentrations 50 to 400% higher than homes with electric stoves. Using a gas stove and oven for just an hour often leads to indoor air pollutant levels that exceed California’s ambient air quality standards. This exposure to nitrogen dioxide can cause respiratory effects. For example, in homes with gas stoves, children are at increased risk of having asthma by 42%.

The Grower’s District
Demolition
Due to the health risks posed by public exposure to asbestos, demolition and renovation of existing buildings is subject to Sac Metro Air District Rule 902, to limit asbestos exposure during these activities. Sac Metro Air District staff is available to review notifications and answer asbestos related questions, either by emailing [email protected], or calling 279-207-1122.

Construction
All projects are subject to Sac Metro Air District rules and regulations in effect at the time of construction. Please visit our website to find a list of the most common rules that apply at the construction phase of projects. Because this project is located in in the River District Special Planning District, it is subject to mitigation measures for construction-related air quality and climate impacts in the Mitigation Monitoring Program in the Environmental Impact Report, pursuant to CEQA, for the River District Specific Plan, which includes measures from Sac Metro Air District’s Basic Construction Emission Control Practices, measures to ensure construction equipment efficiency and further control equipment emissions, and possible mitigation fees.

Conclusion
Thank you for your attention to our comments. If you have questions about them, please contact me at [email protected] or 279-207-1157.

Sincerely,

Molly Wright, AICP
Air Quality Planner / Analyst

c: Paul Philley, AICP, Program Supervisor, Sac Metro Air District

September 30, 2021
Robby Thacker
City of Sacramento, Planning Division
300 Richards Boulevard, 3rd floor
Sacramento, CA 95811
NAME OF DEVELOPMENT: The Grower’s District TYPE OF DOCUMENTS: Site Plan and Design Review Sacramento Regional Transit District (SacRT) appreciates the opportunity to review the Grower’s District project, which provides mixed-use housing on three sites, located at 200, 211, & 215 N. 16th Street. The project proposes to construct four mixed-use buildings with 540 housing units in all, and associated improvements in the River District’s North 16th Street area in downtown Sacramento.

The Grower’s District project area is near the future Dos Rios light rail station, with one of the four buildings located within ¼ mile of the station, and the other three buildings within ½ mile of the station. Additionally, all the project sites are approximately one, to one-and-a-half blocks from the nearest fixed-route bus stop, serving SacRT bus route 33.

SacRT is eager to coordinate with the City and the applicant on the Grower’s District project and has the following comments pertaining to the request for re- zoning:

 SacRT fully supports the applicant’s request to rezone the project sites from Heavy Commercial (C-4-SPD) to General Commercial (C-2-SPD). A heavy commercial zone use does not require pedestrian traffic or high visibility, making them not compatible with consumer-oriented retail activities. SacRT believes the land use in this area must support the project goal, which is to transform the area into a walkable urban living district; therefore, general commercial zoning is better suited for this area and ensures that future uses will support the goal.

SacRT values its partnership with the City and looks forward to coordinating on infrastructure improvements within the Grower’s District project area. Staff has the following recommendations pertaining to the Site Plan and Design Review:

 SacRT appreciates the goal of this project, which is to “transform the area into a walkable, energetic, mixed-use, urban living district”, and improving pedestrian connectivity within the project area is a high priority; therefore, SacRT recommends street lighting improvements and restriping crosswalks at C Street, Thornton Avenue, and N. B Street for pedestrian safety.  The site plan indicates a parallel parking space located on N. B Street and Ahern Street directly adjacent to Site 200; however, this conflicts with SacRT’s existing bus stop (ID #5260). SacRT recommends removing the parallel parking space, as well as improving the existing bus stop in order to make it ADA-compliant. Bus stop specifications and design guidelines are available upon request.
 In addition to being served by fixed-route bus service, the project area is also near the future Dos Rios light rail station, which will provide frequent train service seven days a week. Although we do not have plans for bus routes to serve the station, there is still the need to have an accessible bus stop at or near the station if route alignments change, and when train outages occur that require a bus bridge. SacRT requests that the applicant considers constructing a new bus stop on Sproule Avenue to serve the future station.  SacRT fully supports the City’s Transit Oriented Development (TOD) Ordinance which states that properties within ¼ mile of a light rail station do not have a minimum parking requirement; therefore, we recommend a reduction in the proposed parking ratio. SacRT is motivated to help the region reduce VMT’s and GHG emissions and hopes the applicant will take advantage of the transit services offered near the project site to encourage transit use rather than provide a max amount of parking.

Thank you for the opportunity to provide comments pertaining to the Grower’s District project and we look forward to working with the City and team on these recommendations. Please feel free to contact me directly with any questions or concerns. I may be reached at 916.556.0518, or [email protected].

Sincerely,
Sarah Poe
Planner, SacRT

909 12th Street, Suite 125, Sacramento, CA 95814
916-446-9255 • www.civicthread.org

February 8, 2022 VIA EMAIL
Angel Anguiano, Assistant Planner
Department of Community Development
300 Richards Boulevard 3rd Floor
Sacramento, CA 95811
RE: Grower’s District (P21-024)
Dear Angel Anguiano,
Civic Thread has reviewed the Grower’s District project (P21-024) and offers the following comments in support of creating a more walkable and bikeable development.

The Grower’s District proposes to construct a 445,472 square foot mixed-use development on three sites on N. 16th Street between N. C and N. B Streets. The development is located in Sacramento’s River District and offers direct access to high quality transit with the future Dos Rios Light Rail Station; recreational opportunities, such as the Two Rivers Bike Trail and Pipeworks climbing gym; and commercial districts throughout the Midtown grid.

Civic Thread commends the City of Sacramento and the Project Team for incorporating many of the comments submitted during Cycle 1 to advance the proposal’s vision of creating a walkable urban living district. Particularly as the area is currently characterized by light industrial land uses, we have identified the following improvements to ensure the site’s transformation to a mixed-use commercial and residential district is coupled with adequate upgrades to pedestrian and cyclist facilities.

Pedestrian Facilities
We recommend incorporating the following intersection and signage improvements to increase pedestrian visibility and safety throughout and around the site. • Re-stripe the four-way crosswalk at the intersection of 16th St. and N. B St.

909 12th Street, Suite 125, Sacramento, CA 95814
916-446-9255 • www.civicthread.org

• Add push-button activated Rectangular Rapid Flashing Beacons to proposed crosswalks across 16th St. connecting Site 200 with Sites 215 and 211. • Re-stripe north and south crosswalks on Ahern St. where it intersects with N. C St. • Install a three-way stop at the intersection of Ahern St. and N B. St. with associated crosswalk improvements.
• Install a crosswalk on Thornton Ave. where it intersects 16th St.

Lastly, it is unclear if our request to add marked crosswalks between Building 1 and Building 2 on Site 200 was incorporated from Cycle 1. If not, we re-iterate this recommendation to be incorporated during Cycle 2.

Cyclist Facilities
We are pleased to see that each of the three sites proposes short and long-term bicycle parking for residential and commercial spaces that exceed the City’s requirements. To ensure these facilities are as accessible as possible (and, thus, more likely to be used), we recommend the following:
• Ensure all residential entrances have extra wide door frames to accommodate bicycles.
• Ensure all bike rooms feature a variety of rack types to accommodate a range of bicycle types (i.e. cargo bikes, recumbent bikes).

Additionally, to ensure cyclists have safe routes to and from the development, we recommend the following:
• Install Class II bike lanes along Thornton Ave, N. C St., and Ahern St. • Re-stripe the existing Class II bike lane on N. B St. • Upgrade the existing Class II bike lane on 16
th St. to a Class IV protected bike
lane.

To further promote active travel, we recommend the project incorporate consistent, visually appealing, and pedestrian-scale wayfinding (including average walking and cycling trip times) throughout the development to support with navigation. Furthermore, we encourage

909 12th Street, Suite 125, Sacramento, CA 95814
916-446-9255 • www.civicthread.org

wayfinding signage to emphasize access to nearby transit and healthy destinations, such as the Two Rivers Bike Trail and Sutter’s Landing Regional Park.

Continuing to improve upon the project’s designs to support its ultimate goal of creating a walkable urban environment will lead to a range of public health and environmental benefits as people feel safer, and more comfortable opting for active modes.

Thank you for your consideration of these comments and recommendations. Please notify Civic Thread of future routings or notices for this project.

Sincerely,
Jordan Grimaldi
Project Manager, Civic Thread

P.O Box 1768 ● Sacramento, Ca 95812 ● 916-446-0771
www.BlueDiamond.com

VIA E-Mail

April 22, 2022

Karlo Felix
City of Sacramento | Community
Development Department
300 Richards Blvd
Sacramento, CA 95811

Re: The Grower’s District (Planning Application P21-024)

Dear Karlo,

Blue Diamond Growers appreciates the additional time the City has provided for our review of the Grower’s District project. We further appreciate the project revisions that were recently made, and the proposed conditions of approval the City has developed to address some of the project’s land use compatibility issues with our central campus and headquarters. Blue Diamond engaged MIG to review the project, and to provide objective feedback and evaluation of the project and the proposed rezoning that would allow a high-density residential community immediately adjacent to our manufacturing operations. MIG’s initial report is attached to this letter for reference and, based on those findings, we strongly believe that more measures are needed to reduce potential future land use conflicts.

Blue Diamond instructed MIG to focus its evaluation on the Ruland’s site (Site 211) on North B Street, as it is closest in proximity to our central campus. MIG’s recommendations include considerations – such as repositioning the U-shaped building’s orientation to the north instead of east – that should have been taken into account at the initial conceptualization of the project. While Blue Diamond agrees that the building’s orientation is an important consideration, we are not proposing at this time for the entire site to be revised. Our goal is to work with the applicant and the City given the current stage of processing, to the extent feasible. However, we feel strongly that additional evaluation of the project is needed, as outlined below, given the absence of CEQA review for this project.

Based in large part on the recommendations and rationale provided in MIG’s report, Blue Diamond respectfully requests the following as a supplement to the proposed conditions of approval already developed by the City:

P.O Box 1768 ● Sacramento, Ca 95812 ● 916-446-0771
www.BlueDiamond.com

Noise: An acoustical study should be conducted prior to project entitlements by qualified experts to predict noise levels in the industrial environment that would affect the Ruland’s site (Site 211). The acoustical study should address both ambient and isolated noise events, such as sounds from fixed equipment, back-up beeping from vehicles, noise emitted from truck trips on North B Street, the reverberating effect of the building on the south side, nighttime noise, and daytime noise. This study of existing noise conditions is needed to determine the improvements that the project will need to make for the City’s proposed interior noise standards to be feasible.

Landscaping: The project proposes a five-foot planter and row of trees planted approximately 30 feet on center between the sidewalk and street. This planter provides a buffer for a more desirable pedestrian experience. Denser plantings along North B (on both Sites 211 and 200) would help to increase visual screening, in a manner that is compatible with CPTED principles (see Figure 6-158). The City should also require wrought iron fencing in the planter or other similar measures to provide greater pedestrian safety given the high volume of truck traffic along North B Street, the City’s designated trucking route for the central campus.

Lighting: The applicant should provide assurances, prior to the issuance of any project entitlements, to ensure that impacts of lighting from the central campus are addressed at the 211 Site, by conducting a nighttime lighting site investigation and by providing appropriate architectural elements to reduce nighttime lighting impacts. The applicant has proposed using blackout curtains in all windows along North B Street, however this would not be sufficient to address potential land use conflicts due to the existing lighting at the central campus.

Circulation. The residential project includes a delivery zone and parking along the north side of North B Street. This delivery zone should be relocated to avoid inevitable conflicts that would arise with the high volume of truck traffic that enters North B. During peak deliveries, queuing can occur along North B, therefore the presences of a delivery zone could result in significant disruptions that could ultimately effect circulation through 16th Street, one of the City’s busiest corridors. Again, these are the types of impacts that would ordinarily be resolved through environmental review, as such more evaluation will be needed if the delivery zone is not relocated.

Renter Disclosure/Written Notice. Blue Diamond recognizes that there are existing City requirements for providing landowner disclosures for siting residential uses near major industrial employers. Blue Diamond requests that the language for the required recorded Disclosure/Written Notice be agreed upon prior to project entitlements, to reduce the likelihood of nuisance complaints relating to noise, lighting, odors, and use of fumigants associated with central campus operations.

P.O Box 1768 ● Sacramento, Ca 95812 ● 916-446-0771
www.BlueDiamond.com

While Blue Diamond remains concerned about the proposal to rezone Site 211 to allow high-density residential uses adjacent to our central campus, we have requested reasonable measures and studies to limit noise, lighting, and circulation impacts of the Grower’s District project. In addition to the above, the MIG report includes a set of recommendations for revising the City’s draft design guidelines for siting residential uses near major industrial employers. The draft design guidelines should play an important role to guide residential development in both the Central City and River District Specific Plan areas that are adjacent to the central campus, and we will look forward to working with the City to ensure that the draft guidelines are revised, and ultimately adopted in both specific plan areas. Again, thank you much for considering our comments. We look forward to hearing back from the City, preferably by May 6, 2022, to confirm whether the City will implement and require all of the above proposals prior to and in connection with the project’s entitlement processing.

Sincerely,

Alicia Rockwell
Chief Government Affairs Officer
Blue Diamond Growers

cc: Rachel Royer, Bauen Capital ([email protected])

1 MEMORANDUM To: Blue Diamond Growers to Blue Diamond Growers from Scott Davidson, Tricia Stevens, and Dan Amsden, MIG re Grower’s District Design Review date 04/21/2022 MIG has reviewed the Grower’s District proposals for mixed use housing and the draft Design Guidelines for Industrial Residential interfaces. We offer the following comments and observations. Overall Objective: Blue Diamond Growers seeks to protect their significant investment in Sacramento by ensuring that new residential development close to their facilities is compatible with existing and proposed operations and is built in a manner that greatly reduces the potential for future complaints. Overall Site Recommendations: We recommend that the Grower’s District applicants and the City explore possible modifications to the project on site 211 in order to ensure that the residential uses are sufficiently oriented away from and setback from industrial activities, including the following options:
• Reorienting the project “open space” so that the open end of the horseshoe faces North rather than East

2 Design Guidelines: The draft Design Guidelines provide important guidance on the review of the Grower’s District proposals. Blue Diamond Growers should request that the City amend the Central City Specific Plan Design Guidelines and the River District Design Guidelines to incorporate these Guidelines. MIG offers the following changes to the Design Guidelines: 1. Add photos and/or diagrams to better demonstrate desired interfaces. 2. Add a requirement for residential projects to submit an acoustical study during the project entitlement stage, instead of at the building permit stage, to assess the current noise environment and resulting noise reduction measures specific to the site. 3. Add a requirement for residential projects to submit an existing conditions report at the project entitlement stage that examines other items such as lighting and air quality/odors. • Uses located adjacent to or within 40+ feet of B Street should be passive (e.g., parking) or non-residential. Residential should be setback from B Street. • Residential uses located on the south half of the site shall be designed to that living areas are on the south side of the unit and bedrooms are located on the north side of the unit.

3 4. Add a section on circulation to address potential conflicts between industrial traffic/truck trips and residential traffic flow and parking. 5. Add a section on lighting to offer measures to reduce effects from industrial lighting. Growers’ District Application: Revised Plan and Proposed Conditions of Approval: Blue Diamond Growers acknowledges that the following design changes have either been made or have been agreed to by the applicant: • Elimination of balconies on the south side. • New Landscape Green Screen at East end of podium. • Special Note indicating, Units at south and east facing elevations to provide increase in STC Rating and Visual Screening per code requirements. • Podium parking at street level along North B Street. Blue Diamond Growers also acknowledges that the following items are to be included in the Conditions of Approval to minimize potential existing and on-going noise, odor, and visual impacts, as agreed to by the applicant: a. The application submitted for building permit shall include a noise assessment that quantifies existing ambient noise levels and identifies measures to ensure an interior noise level of 45 dBA Ldn within each dwelling unit, consistent with General Plan Policy EC 3.1.3. b. The plans submitted for building permit shall: - Include sufficient detail and information to allow Planning Division staff to verify consistency with the measures identified in the noise assessment. - Include additional landscaping on the eastern-side of the podium deck open space to reduce light and noise. - Identify curtains, or other similar devices that reduces light and noise, on exterior facing doors and/or windows within each dwelling unit that are operable and under the control of the tenant/occupant. c. Prior to issuance of a certificate of occupancy, the operator of the development shall: - Provide Planning Division staff for review and approval, language that will be included in agreements executed between the operator and tenants/occupants that provides a written notice of the existing industrial use and potential impacts associated with the continued use and operations of the major industrial employer. - Schedule an inspection with Planning Division staff to verify installation of the aforementioned landscaping and curtains and any other measures identified in the noise assessment. d. The operator shall ensure that following items, and any other measures identified in the noise assessment, are maintained in a functional and operable manner: - Exterior facing door and/or window assemblies (e.g. insulation and seals). - Forced-air mechanical ventilation systems. - Aforementioned landscaping. - Aforementioned curtains.

4 Additional Needs. In response to applying these Guidelines to the Grower’s District application, and in response to the design changes and proposed conditions of approval, we recommend the following. In general, proposed noise, odor, lighting, and circulation issues should be resolved by the applicant and City prior to project entitlements. These comments focus on Site 211, but could relate to Site 200. Noise. Noise is the most important factor in ensuring compatibility with existing Blue Diamond operations. Section 2 of the draft Design Guidelines addresses compliance with specific noise standards to ensure interior noise levels of 45 dba. We recognize that the revised plans address noise by eliminating the balconies and orienting the podium parking at street level along North B Street. To be able to assess noise compatibility, we have the following comments: 1. A preliminary peer review conducted by a MIG acoustical expert observes the draft design guidelines for “Noise Reduction” are typical. The guidelines appear to have envisioned exterior noise levels of 70 dBA or higher and require windows and skylights to be STC 29 or better. While the General Plan predicts noise levels of 70 dBA along 16th Street, noise levels along North B Street are not known and may be higher due to the presence of large number of trucks. 2. An acoustical study should be conducted prior to project entitlements by qualified experts to predict noise levels in the industrial environment. The study should address different types of noise, sounds from fixed equipment, back-up beeping from vehicles, noise emitted from truck trips on North B Street and the reverberating effect of the building on the south side, nighttime noise, and daytime noise. We acknowledge that the need for an acoustical study is outside the purview of CEQA as the need for an acoustical study stems from impacts from existing conditions. The need for an acoustical study is supported by General Plan Policy EC 3.1.4: Interior Noise Review for Multiple, Loud Short-term Events: “In cases where new development is proposed in areas subject to frequent, high-noise events (such as aircraft over-flights, or train and truck pass-bys), the City shall evaluate substantiated noise impacts on any sensitive receptors from such events when considering whether to approve the development proposal, taking into account potential for sleep disturbance, undue annoyance, and interruption in conversation, to ensure that the proposed development is compatible within the context of its surroundings.” 3. The noise study should also address Site 200 since Blue Diamond Growers truck transverse North B Street to the west of North 16th Street. Odors. The effect of negative air quality and odors on residential uses is unknown. Assumedly, noise measures would have the effect of reducing odors and negative air quality that might be experienced by residents, but additional study is necessary prior to project entitlements to determine any unanticipated effects.

5 Landscaping. It is acknowledged that “green screens” are to be provided at the east end of the podium. The residential project provides a five-foot planter and row of trees planted approximately 30 on center between the sidewalk and street. This planter provides a buffer for a more desirable pedestrian experience. Consider denser plantings along this side to increase visual screening and in a manner that is compatible with CPTED principles (see Figure 6-158). Also consider an open wrought iron fence in the planter to provide greater pedestrian safety. Lighting. It is not known if the residential units would be affected by industrial lighting from the Blue Diamond Growers facilities. . The applicant should provide assurances prior to project entitlements that lighting is addressed by conducting a nighttime lighting site investigation and by providing architectural elements are appropriately provided. Circulation. The residential project includes a delivery zone and parking along the north side of North B Street. The delivery zone should be relocated in order to avoid conflicts with truck traffic. Disclosure/Written Notice. Ensure that the language for the required recorded Disclosure/Written Notice be agreed upon prior to project entitlements, to reduce the likelihood of nuisance complaints relating to noise, lighting, odors, and use of fumigants associated with the major industrial employer. CPTED. The residential applicant indicated agreement with all the Police Department recommendations. No further comments are provided.

P.O Box 1768 ● Sacramento, Ca 95812 ● 916-446-0771
www.BlueDiamond.com

VIA E-Mail

April 27, 2022

Karlo Felix
City of Sacramento | Community
Development Department
300 Richards Blvd
Sacramento, CA 95811

Re: The Grower’s District (Planning Application P21-024)

Dear Karlo,

In follow up to our letter last Friday, Blue Diamond would like to supplement our request for the City to include an additional condition that was referenced in MIG’s report:

Residential uses located on the south half of the site shall be designed so that living areas are on the south side of the unit and bedrooms are located on the north side of the unit

To our knowledge, no interior room layouts have been submitted to the City for review. Even if they have, Blue Diamond believes that a condition of approval prohibiting bedrooms on the southern end of the building could significantly reduce the potential for future noise or other complaints by potential future tenants at the Site 211 building.

Again, thank you much for considering our comments and Blue Diamond looks forward to hearing back from the City, ideally before May 6, 2022 to confirm whether the City will implement our proposed measures for promoting greater site compatibility of the Grower’s District project.

Sincerely,

Alicia Rockwell
Chief Government Affairs Officer
Blue Diamond Growers

cc: Rachel Royer, Bauen Capital ([email protected])

Public Comments and Proposal Modifications

On August 11, 2021, the application was submitted for entitlements. As previously noted in this report, staff received comments from several agencies and organizations, and some resulted in modifications to the initial proposal. These comments and any modifications made by the applicant are summarized below.

Sacramento Area Council of Governments (SACOG)

On September 16, 2021, staff received a letter from SACOG confirming that the proposed project is consistent with the 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) and is located within a Transit Priority Area (TPA).

The project site is within one -half mile from multiple light rail stations on Sacramento Regional Transit’s Blue Line, which qualify as major transit stops. The vicinity of the project to these stations demonstrates that the project site is within a TPA. Moreover, the proposed project is located within the Center/Corridor Community designation of the MTP/SCS for t he City of Sacramento. Within the Center/Corridor Community, the MTP/SCS forecasts a range of low and high density residential, commercial, office, and industrial uses, and the project’s proposed land uses are consistent with the range of land uses, densities, and building intensities.

Sacramento Regional Transit (SacRT)

On September 30, 2021, staff received a letter from SacRT which stated support for the rezone request as it will enable the development of a walkable urban living district. SacRT provided the following recommendations:

 “SacRT appreciates the goal of this project, which is to “transform the area into a walkable, energetic, mixed -use, urban living district ”, and improving pedestrian connectivity within the project area is a high priority; therefore, SacRT recommends street lighting improvements and restriping crosswalks at C Street, Thornton Avenue, and N. B Street for pedestrian safety.”

A condition of approval has been imposed that requires the developer to construct traffic signals and other required improvements consistent with the prepared Traffic Analysis and to the satisfaction of Public Works Department.

 “The site plan indicates a parallel parking space located on N. B Street and Ahern Street directly adjacent to Site 200; how ever, this conflicts with SacRT ’s existing bus stop (ID #5260). SacRT recommends removing the parallel parking space, as well as improving the existing bus stop in order to make it ADA-compliant. Bus stop specifications and design guidelines are available upon request.”

The applicant team modified the site plan to remove the proposed street parking space; including agreeing to the improvement of the existing bus stop consistent with bus stop specifications and design guidelines.

 “In addition to being served by fixed-route bus service, the project area is also near the future Dos Rios light rail station, which will provide frequent train service seven days a week. Although we do not have plans for bus routes to serve the station, there is still the need to have an accessible bus stop at or near the station if route alignments change, and when train outages occur that require a bus bridge. SacRT requests that the applicant considers constructing a new bus stop on Sproule Avenue to serve the future station.”

The applicant team received these comments; however, Sproule Avenue is located two blocks north of the project site, outside the scope of work and not owned or controlled by the applicant.

 The site plan indicates a parallel parking space located on N . B Street and Ahern Street directly adjacent to Site 200; however, this conflicts with SacRT ’s existing bus stop (ID #5260). SacRT recommends removing the parallel parking space, as well as improving the existing bus stop in order to make it ADA-compliant. Bus stop specifications and design guidelines are available upon request.

The applicant modified the site plan to remove the proposed street parking space; including agreeing to the improvement of the existing bus stop consistent with bus stop specifications and design guidelines.

 “SacRT fully supports the City ’s Transit Oriented Development (TOD) Ordinance which states that properties within ¼ mile of a light rail station do not have a minimum parking requirement; therefore, we recommend a reduction i n the proposed parking ratio. SacRT is motivated to help the region reduce VMT ’s and GHG emissions and hopes the applicant will take advantage of the transit services offered near the project site to encourage transit use rather than provide a max amount of parking.”

The applicant team received these comments; however, the number of vehicle parking spaces were not reduced.

Sacramento Metropolitan Air Quality Management District (SMAQMD)

On September 24, 2021, staff received a letter from SMAQMD and provided the following recommendations:

 “This project exceeds Sac Metro Air District screening criteria for operational analysis of project GHG impacts under the California Environmental Quality Act (CEQA), so it is particularly important that it maintain consistence with the City of Sacramento’s Climate Action Plan (CAP). Consistence with the City’s CAP would include consistence with its CAP Checklist, including the water and energy efficiency measures therein, in addition to general consistency with the CAP goals and policies. Sac Metro Air District recommends consulting our Guide to Air Quality Assessment in Sacramento County (CEQA Guide), available on our website, for any project CEQA review. Further, because this project is located in in the River District Special Planning District, it is subject to mitigation measures in the Mitigation Monitoring Program in the Environmental Impact Report, pursuant to CEQA, for the River District Specific Plan, which includes measures that mitigate construction-related air quality and climate impacts, as discussed below in the section on “Construction.””

The project will satisfy the mitigation measures in the Mitigation Monitoring Program in the Environmental Impact Report for the River District Specific Plan.

 “Provide continuous tree shading to the public sidewalk frontage, to the full extent feasible, to create healthier pedestrian conditions (see the section below on “Urban Heat Island Effect ”) that are also more conducive to walking. Studies have correlated neighborhood tree shade to increased use of pedestrian transportation.

Specifically, we recommend that project implementation incorporate the following:
o Tree shading along the North 16th Street sidewalk frontage of Buildings 215 and 211. This is particularly important due to that area’s western exposure.

The hottest temperatures daily occur with afternoon sun from the west. This recommendation would provide for project consistence with the City’s River District Design Guidelines (Design Guidelines) Section 16 specifications for 16th Street. Tree plantings should meet the Design Guidelines tree spacing, canopy coverage, and other specifications (see page 3-84). o At least one additional tree on North B Street on the south side of Building 211. This recommendation wou ld provide for project consistence with the referenced Design Guidelines tree spacing and canopy coverage specifications.
o A trellis to provide vegetative shade along the pedestrian frontage on the south side of Building 200. The “loading dock ” area appears to accommodate pedestrian traffic on project plans and could accommodate a trellis.”

As part of the City ’s project review process, the project was routed to the Urban Forest Division and the Public Works Department, and to address SMAQMD ’s above recommendations, trees have been added, per the landscape plan, along 16th Street and within the site, in coordination with City staff to confirm there are not potential conflicts with sidewalks, driveways, and other City facilities.

 Ensure short-term bike parki ng within 50 feet of primary entrances, meeting the City’s commendable Bike Rack Design and Placement Design Standards.

Placement of residential short -term bicycle parking along project street frontage, within 50 feet of primary entrances, would enable eas y guest access, and enable residents to make multiple bicycle trips during the day without the added effort of stowing their bicycle in a bicycle storage room.

The applicant will comply with the long -term and short-term bicycle requirements consistent with commercial and multi-unit dwelling standards.

 “Implement an unbundled parking program for residential tenants, which separates the cost of housing from the cost of automobile parking. Unbundled parking allows residents to opt out of paying for parking by excluding parking cost from rental cost for the project housing units.”

The applicant received these comments, but ultimately, did not reduce the number of vehicle parking spaces.

 “All new structures utilize certified cool roofs. The 2019 California Building Energy Efficiency Standards suggests an aged solar reflectance of at least 0.63 for low - sloped roofs and at least 0.20 for steep -sloped roofs, and minimum thermal emittance of 0.75. The Cool Roof Rating Council provides a product directory of roofs.”

Compliance with Title 24 energy standards will be required and reviewed and administered through the building permitting process with the Building Division.

 “Landscaping incorporates new trees to shade new and existing pavements and structures to th e full extent feasible. Our recommendation above on sidewalk shading would also help reduce urban heat island effect impacts. As a reminder, for the outdoor surface parking, the project will need to comply with City of Sacramento parking lot tree shade req uirement for 50% parking lot tree shade coverage on “all surfacing on which a vehicle can drive and all parking stalls” (City Code Section 17.612.040 (A)).”

Ahern Street and Site 200 parking lot meet 50% shade requirements, in addition, new trees will be planted on the along the right-of-way, where currently none exists.

Civic Thread

On February 8, 2022, staff received a letter from Civic Thread and provided the following recommendations:

 “We recommend incorporating the following intersection and signage improvements to increase pedestrian visibility and safety throughout and around the site.
o Re-stripe the four-way crosswalk at the intersection of 16th St. and N. B St. o Add push -button activated Rectangular Rapid Flashing Beacons to proposed crosswalks across 16th St. connecting Site 200 with Sites 215 and 211.
o Re-stripe north and south crosswalks on Ahern St. where it intersects with N. C St.
o Install a thre e-way stop at the intersection of Ahern St. and N B. St. with associated crosswalk improvements.
o Install a crosswalk on Thornton Ave. where it intersects 16th St. o Provide a marked crosswalk between Building 1 and Building 2 (Site 200).”

The applicant team has agreed to implement most of the comments, however, several of them conflict with the Traffic Study. There are operational concerns with large volumes in both westbound and northbound directions along with the consideration of a truck route. The traffic study recommends not installing a cross walk at the intersection of 16th Street and North B Street as it would impact signals and dual westbound lefts. The traffic analysis also evaluated appropriate crosswalk treatments consistent with the City’s ped crossing guidelines. A Pedestrian Hybrid Beacon (PHB) is the appropriate treatment for crossing, which will be located to the north of Site 200. A South crosswalk exists today at the intersection of Ahern Street and North C Street. However, the northeast corner has no receiving curb ramp and not part of development. Crosswalks will be added as development occurs. Currently Ahern Street and N orth B Street is a four-leg intersection with two-way stop but the volumes and speed may not warrant a three -way stop and may present conflicts as a four-leg intersection. Lastly, incorporating a crosswalk on Thornton Avenue and North 16th Street would be too close to the existing signal at North B Street and North 16 th Street. In addition, the crosswalk cannot be unprotected and would require a PH B, which is too close to an existing traffic signal.

 “To ensure these facilities are as accessible as possible (and, thus, more likely to be used), we recommend the following:
o Ensure all residential entrances have extra wide door frames to accommodate bicycles.
o Ensure all bike rooms feature a variety of rack types to accommodate a range of bicycle types (i.e. cargo bikes, recumbent bikes). o Install Class II bike lanes along Thornton Ave, N. C St., and Ahern St. o Re-stripe the existing Class II bike lane on N. B St. o Upgrade the existing Class II bike lane on 16th St. to a Class IV protected bike lane.
o Provide pedestrian scale wayfinding, such as signage to Two Rivers Bike Trail and Sutter’s Landing Regional Park”

The applicant has agree d to provide extra wide door frame to accommodate bicycles and ensure that all bike rooms feature a variety of rack types to accommodate a range of bicycle types. Thornton Ave and North C Street (East) are designed and exist as a local street, where it’s typical for on-street biking as a bike route. Right-of-way is limited in these local streets and the applicant only has control over a short segment of these streets. The Project is conditioned for frontage improvements and construction, which may include re -striping due to deterioration and will be determined at plan check. North 16th Street Streetscape project analyzed the corridor and concluded due to large vehicular volumes not to install a bike lane on 16 th Street. Instead, 12th Street will hav e a cycle track to facilities bicycle travel (North 16th Street Streetscape Project).

Blue Diamond Growers

In February 2022, staff was contacted by Blu e Diamond Growers and requested an opportunity to review the proposal and to meet with staff to note their concerns with housing adjacent to their facility related to noise, truck traffic, and lighting. Blue Diamond also requested that public hearings that were tentatively scheduled to begin in March 2022 be rescheduled to allow additional 30 days for coordination. The applicant was amenable to rescheduling hearings to begin in April 2022 and made modifications to their plans and additional conditions of approval to address the comments received during their discussions. After further discussions, an additional 30 days for review was requested and hearings were rescheduled to begin in May 2022. Additionally, Blue Diamond provided two comment letters on April 22, 2022 and April 27, 2022 that include the following recommendations based on a study prepared by their consultant, MIG. Only those recommendations that have not already been incorporated into the proposal based on previous collaborative discussions between the two parties are identified below.

 “Reorienting the project “open space” so that the open end of the horseshoe faces North rather than East.”

The applicant received these comments, but ultimately, did not reorient the building as a new design would be required to ensure that the historic structure is appropriately incorporated into the building.

 “Uses located adjacent to or within 40+ feet of B Street should be passive (e.g., parking) or non-residential. Residential should be setback from B Street.”

The applicant received these comments, but ultimately, did not modify the configuration of the building as it would reduce the number of residential units proposed.

 “Residential uses located on the south half of the site shall be designed to tha t living areas are on the south side of the unit and bedrooms are located on the north side of the unit.”

The applicant received these comments and will modify their plans on Site 211 studios units on the south side of the building overlooking North B Str eet. The modification is limited to studios as dwelling units with an enclosed bedroom must have an egress window to comply with Building and Fire Codes. Staff has imposed a condition of approval reflecting this change.

 Noise: An acoustical study should b e conducted prior to project entitlements by qualified experts to predict noise levels in the industrial environment that would affect the Ruland ’s site (Site 211). The acoustical study should address both ambient and isolated noise events, such as sounds from fixed equipment, back-up beeping from vehicles, noise emitted from truck trips on North B Street, the reverberating effect of the building on the south side, nighttime noise, and daytime noise. This study of existing noise conditions is needed to dete rmine the improvements that the project will need to make for the City ’s proposed interior noise standards to be feasible.

The applicant is amenable to a condition of approval that requires an acoustical analysis to inform the development of plans submitted for building permit. Staff has imposed this requirement as a condition of approval.

 Landscaping: The project proposes a five -foot planter and row of trees planted approximately 30 feet on center between the sidewalk and street. This planter provides a buffer for a more desirable pedestrian experience. Denser plantings along North B (on both Sites 211 and 200) would help to increase visual screening, in a manner that is compatible with CPTED principles (see Figure 6-158). The City should also require wro ught iron fencing in the planter or other similar measures to provide greater pedestrian safety given the high volume of truck traffic along North B Street, the City’s designated trucking route for the central campus.

City staff has imposed conditions of approval that requires frontage improvements consistent with adopted street standards and has not imposed the requested landscaping.

 Lighting: The applicant should provide assurances, prior to the issuance of any project entitlements, to ensure that impacts of lighting from the central campus are addressed at the 211 Site, by conducting a nighttime lighting site investigation and by providing appropriate architectural elements to reduce nighttime lighting impacts. The applicant has proposed using blackout curtains in all windows along North B Street, however this would not be sufficient to address potential land use conflicts due to the existing lighting at the central campus.

The applicant is amenable to a condition of approval that requires a lighting analysis to inform the development of plans submitted for building permit. Staff has imposed this requirement as a condition of approval.

 Circulation. The residential project includes a delivery zone and parking along the north side of North B Street. This delivery zone should be relocated to avoid inevitable conflicts that would arise with the high volume of truck traffic that enters North B. During peak deliveries, queuing can occur along North B, therefore the presences of a delivery zone could result in significant disruptions that could ultimately effect circulation through 16th Street, one of the City’s busiest corridors.

Again, these a re the types of impacts that would ordinarily be resolved through environmental review, as such more evaluation will be needed if the delivery zone is not relocated.

In consultation with the Public Works Department, the applicant has relocated a loading zone from North B Street to North 16th Street.

 Renter Disclosure/Written Notice. Blue Diamond recognizes that there are existing City requirements for providing landowner disclosures for siting residential uses near major industrial employers. Blue Diamond requests that the language for the required recorded Disclosure/Written Notice be agreed upon prior to project entitlements, to reduce the likelihood of nuisance complaints relating to noise, lighting, odors, and use of fumigants associated with central campus operations.

City staff has imposed a condition of approval consistent related to notification of industrial uses within the area consistent with SCC section 17.444.130.D. As proposed the timing of the language is required to be reviewed prior to is suance of a building permit.

On June 7, 2022, Blue Diamond Growers submitted another letter to the City about the project wherein it asserts that the project “significantly exceeds the development standards established by the River District Specific Plan” and “the City has impermissibly foregone environmental review of the project pursuant to the California Environmental Quality Act…”

 Staff disagrees with these assertions. The project is consistent with the Specific Plan’s vision for the transformation o f the River District into a vibrant, mixed -use community of higher -density residential and job -generating uses. While the Specific Plan contains assumptions pertaining to the distribution of land uses and proposed densities, the Plan explicitly states tho se assumptions were not meant to be prescriptive, but rather act as a tool to envision an overall level of development within the Plan area. The Grower’s District project is consistent with the Plan’s directives for the area ’s overall level of development and is within the parameters analyzed by the Specific Plan’s Environmental Impact Report.

 In addition, the project meets the requirements of the CEQA exemption set forth in CEQA Guidelines section 21155.4: the project is in a transit priority area, is consistent with the River District Specific Plan for which an EIR was certified and is consistent with the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) adopted by the Sacramento Area Council of Governments (SACOG). In addition, none of the circumstances set forth in Public Resources Code section 21166 and CEQA Guidelines section 15162 have occurred, so no further environmental review is needed.