the application for the proposed project on April 11, 20227. Even though the Project Description and environmental setting for several portions of analysis describe the project site as vacant, analysis throughout the MND credits the proposed project with credits to reduce factors such as GHG emissions, energy consumption, and VMT, for operation of the Fry’s Electronics store at full capacity. Applying reduction credits when the former use ceased operations nearly 1.5 years prior is inappropriate and only serves to skew emissions from the proposed project below the applicable thresholds. CEQA Guidelines Section 15063(d) requires that the Initial Study provide "an identification of the environmental setting.” Here, the MND has stated in the Project Description and several areas throughout the MND that the environmental setting is a vacant project site. A Project EIR must be prepared to remove reduction credits from a fully functioning Fry’s Electronics Store because the environmental setting is very clearly a vacant project site, as stated in the MND. This is vital in order to prepare an adequate and accurate informational document with proper environmental analysis for the public and decision makers to review. III Environmental Checklist and Discussion A) Land Use and Planning The MND does not include a consistency analysis with the City’s General Plan. An EIR must be prepared which includes an analysis of the project in conjunction with all General Plan goals and policies, including the following: 1. Policy LU 1.1.1 Regional Leadership. The City shall be the regional leader in sustainable development and encourage compact, higher-density development that conserves land resources, protects habitat, supports transit, reduces vehicle trips, improves air quality, conserves energy and water, and diversifies Sacramento’s housing stock. 2. Policy LU 1.1.2 Building Intensity and Population Density. The City shall regulate the levels of building intensity and population density according to the standards and land use designations set out in the General Plan and the Sacramento City Code. Within these designations, cumulative development shall not exceed 640,400 persons and 390,100 employees by 2035. 3. Goal LU 1.2 Sustainable Sacramento Strategy. Support statewide and regional efforts to reduce greenhouse gas emissions, fund transportation improvements, and meet housing needs. 4. Goal LU 2.6 City Sustained and Renewed. Promote sustainable development and land use practices in both new development, reuse, and reinvestment that provide for the transformation of Sacramento into a sustainable urban city while preserving choices (e.g., where to live, work, and recreate) for future generations. 7 Sacramento Citizen Permit Portal, Project Application P22-017 files uploaded April 11, 2022 https://aca-prod.accela.com/SACRAMENTO/Cap/CapDetail.aspx?Module=Planning&capID1=22CPF&capID2=00000&capID3=00017&agencyCode=SACRAMENTO
5. Policy LU 2.6.1 Sustainable Development Patterns. The City shall promote compact development patterns, mixed use, and higher-development intensities that use land efficiently; reduce pollution and automobile dependence and the expenditure of energy and other resources; and facilitate walking, bicycling, and transit use. 6. Policy LU 2.6.7 Green Building Retrofit. The City shall promote the retrofitting of existing structures with green building technologies/practices and encourage structures being renovated to be built to a higher green building standard such as CalGreen Tier 1 or Tier 2 or Leadership in Energy and Environmental Design (LEED). (RDR) LU 2.6.8 Heat Island Effect . 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. 7. Policy LU 2.7.5 Development along Freeways. The City shall promote high-quality development character of buildings along freeway corridors and protect the public from the adverse effects of vehicle-generated air emissions, noise, and vibration, using such techniques as: 1) Requiring extensive landscaping and trees along the freeway fronting elevation, 2) Establish a consistent building line, articulating and modulating building elevations and heights to create visual interest, 3) Include design elements that reduce noise and provide for proper filtering, ventilation, and exhaust of vehicle air emissions. 8. Policy LU 2.7.6 Walkable Blocks. The City shall require new development and reuse and reinvestment projects to create walkable, pedestrian-scaled blocks, publicly accessible mid-block and alley pedestrian routes where appropriate, and sidewalks appropriately scaled for the anticipated pedestrian use. 9. Policy LU 2.7.7 Buildings that Engage the Street. The City shall require buildings to be oriented to and actively engage and complete the public realm through such features as building orientation, build-to and setback lines, façade articulation, ground-floor transparency, and location of parking. 10. Policy LU 2.7.8 Screening of Off-street Parking. The City shall reduce the visual prominence of parking within the public realm by requiring most off-street parking to be located behind or within structures or otherwise fully or partially screened from public view. 11. Policy LU 2.8.3 High-Impact Uses. The City shall avoid the concentration of high-impact uses and facilities in a manner that disproportionately affects a particular neighborhood, center, or corridor to ensure that such uses do not result in an inequitable environmental burden being placed on low-income or minority neighborhoods. 12. Policy ED 1.1.6 Environmentally Sustainable, Green Technology, and Clean Technology Businesses. The City shall attract and retain environmentally conscious businesses that contribute to the long-term, economic and environmental sustainability of Sacramento.
13. Policy M1.2.3 Transportation Evaluation. The City shall evaluate discretionary projects for potential impacts to traffic operations, traffic safety, transit service, bicycle facilities, and pedestrian facilities, consistent with the City’s Traffic Study Guidelines. 14. Policy M 1.2.2 Level of Service (LOS) Standard. The City shall implement a flexible context- sensitive Level of Service (LOS) standard, and will measure traffic operations against the vehicle LOS thresholds established in this policy. The City will measure Vehicle LOS based on the methodology contained in the latest version of the Highway Capacity Manual (HCM) published by the Transportation Research Board. The City’s specific vehicle LOS thresholds have been defined based on community values with respect to modal priorities, land use context, economic development, and environmental resources and constraints. As such, the City has established variable LOS thresholds appropriate for the unique characteristics of the City’s diverse neighborhoods and communities. The City will strive to operate the roadway network at LOS D or better for vehicles during typical weekday conditions, including AM and PM peak hour. 15. Goal ER 6.1 Improved Air Quality. Improve the health and sustainability of the community through improved regional air quality and reduced greenhouse gas emissions that contribute to climate change. 16. Policy ER 6.1.2 New Development. The City shall review proposed development projects to ensure projects incorporate feasible measures that reduce construction and operational emissions for reactive organic gases, nitrogen oxides, and particulate matter (PM10 and PM2.5) through project design. 17. Policy ER 6.1.5 Community Greenhouse Gas Reductions. The City shall reduce community GHG emissions by 15 percent below 2005 baseline levels by 2020, and strive to reduce community emissions by 49% percent and 83% percent by 2035 and 2050, respectively. 18. Policy ER 6.1.7 Greenhouse Gas Reduction in New Development. The City shall reduce greenhouse gas emissions from new development by discouraging auto-dependent sprawl and dependence on the private automobile; promoting water conservation and recycling; promoting development that is compact, mixed use, pedestrian friendly, and transit oriented; promoting energy-efficient building design and site planning; improving the jobs/housing ratio in each community; and other methods of reducing emissions. The MND does not include a consistency analysis with the North Natomas Community Plan. An EIR must be prepared which includes an analysis of the project in conjunction with all North Natomas Community Plan goals and policies, including the following: 1. NN.LU 1.3 Employment Center Development Guidelines. The City shall require any development in an Employment Center area to comply with the North Natomas Development Guidelines.
2. NN.LU 1.16 Employment Center Heights. The City shall ensure that buildings are varied to create an interesting skyline. 3. NN.LU 1.18 Support Retail Required in Each Employment Center. The City shall require every Employment Center to provide some level of support retail goods and services, either ancillary (within a primary use building) or support (within a stand alone building). An Employment Center that is 2 acres or less in size and is located adjacent to a PUD with support retail is exempt from the retail requirement 4. NN.LU1.39 Industrial Development. The City shall provide for comprehensive industrial development that significantly contributes to the city’s employment base while not competing with the types of industrial uses that would likely locate in North Sacramento 5. NN.LU 1.42 Employment Center Light Industrial. The City shall allow a maximum of 20 percent of any employment center to be devoted to light industrial uses such as distribution and warehousing, light manufacturing and assembly, and high tech manufacturing, research, and development with limited office space. 6. NN.LU 1.5 Distinguished Gateways. Heavier landscape treatment and high quality design must be included in specific gateways to the community to provide a suitable entry to the Capitol City. The freeway gateways include: (4) I-80 and Northgate Boulevard. B) Population and Housing The MND does not provide any calculation of the project’s construction or operational employees. The U.S. Energy Information Administration8 provides the following applicable employment generation rate for warehouses: No Refrigeration: 1 employee per 1,224 square feet Applying this ratio results in the following calculation: Non-Refrigerated: 265,686 sf/ 1,224 = 210 Total: 210 employees Sacramento Council of Governments (SACOG) adopted the 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) on November 18, 20199. The 2020 MTP/SCS notes that the Established Communities in the SACOG region will add 146,053 jobs between 2016 - 2040 (Figure 3.5 Community Types and Table 3.2 Summary of Expected Housing and Employment Growth by Community Type). Utilizing the U.S. EIA calculation of 210 employees, 8 US EIA Commercial Buildings Energy Consumption Survey, Table B1: Summary table: total and means of floorspace, number of workers, and hours of operation, 2018 https://www.eia.gov/consumption/commercial/data/2018/bc/html/b1.php 9 SACOG 2020 MTP/SCS https://www.sacog.org/sites/main/files/file-attachments/2020_mtp-scs.pdf?1580330993
the project represents 0.14% of the employment growth from 2016 - 2040 within all of SACOG’s Established Communities. A single project accounting for this amount of the projected employment and/or population over 26 years represents a significant amount of growth. A Project EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2016 and projects “in the pipeline” within Established Communities in the SACOG region to determine if the project will exceed SACOG’s employment growth forecast for the Established Communities. Additionally, the Project EIR must also provide demographic and geographic information on the location of qualified workers to fill these positions in order to provide an accurate environmental analysis. III.2 Air Quality, III.5 Energy, and III.7 Greenhouse Gas Emissions The MND does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. This is especially significant as the surrounding community is highly burdened by pollution. According to CalEnviroScreen 4.010, CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project’s census tract (6067007001) ranks worse than 83% of the rest of the state overall. The surrounding community, including residences and Glenwood Elementary School to the east, and residences and Garden Valley Elementary School to the south, bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. For example, the project census tract ranks in the 51st percentile for ozone burden and the 73rd percentile for traffic impacts, which are both typically attributed to heavy truck activity in the area. Traffic impacts represent the vehicles in a specified area, resulting in human exposures to chemicals that are released into the air by vehicle exhaust, as well as other effects related to large concentrations of motor vehicles11. Further, the census tract is a diverse community including 55% Hispanic, 8% African-American and 11% Asian-American residents, which are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 75% of the census tract over age 25 has not attained a high school diploma, which is an indication that they may lack health insurance or access to medical care. Medical care is vital for this census tract as it ranks in the 86th percentile for incidence of asthma and 91st percentile for incidence of cardiovascular disease. 10 CalEnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 11 OEHHA CalEnviroScreen Report https://oehha.ca.gov/media/downloads/calenviroscreen/report/calenviroscreen40reportf2021.pdf
Additionally, the project’s census tract (6067007001) is identified as a SB 535 Disadvantaged Community12, which is not discussed or presented for analysis in the MND. Census tracts adjacent to the project site (6067006701 (east); 6067006702 (east); 6067006800 (east); 6067006900 (southeast); and 6067007007 (west)) are also identified as SB 535 Disadvantaged Communities. This indicates that cumulative impacts of development and environmental impacts in the region are disproportionately impacting these communities. California’s Building Energy Code Compliance Software (CBECC) is the State’s only approved energy compliance modeling software for non-residential buildings in compliance with Title 2413. CalEEMod is not listed as an approved software. The CalEEMod-based modeling in Appendix A does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the MND did not accurately or adequately model the energy impacts in compliance with Title 24, a finding of significance must be made. An EIR with modeling using the approved software (CBECC) must be circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the MND utilizes CalEEMod as a source in its methodology and analysis, which is clearly not the approved software. Further, the MND states that “Because the California Emissions Estimator Model (CalEEMod) program used for that analysis does not specifically quantify diesel and gasoline fuel volumes used for construction and operational sources, additional calculations were completed to calculate diesel and gasoline volumes based on estimated carbon dioxide (CO2) emissions and default factors from The Climate Registry for calculating CO2 emissions from combustion of transport fuels.” However, these additional calculations were not included in the body of the MND or as an attachment for public review, which does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as these calculations contribute directly to analysis of the problem at hand. An EIR must be prepared to include the additional Energy calculations for review, analysis, and comment by the public and decision makers in order to comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). As noted in the Environmental Setting analysis above, the baseline environmental setting/existing conditions at the project site established in the MND are a completely vacant building and property. However, analysis throughout the MND credits the proposed project with emissions and energy consumption credits for operation of the site at full capacity. The arguments and analysis in the 12 OEHHA SB 535 Census Tracts https://oehha.ca.gov/calenviroscreen/sb535 13 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency-1
Environmental Setting review above are herein reincorporated. The CalEEMod analysis (used for Air Quality, Energy, and GHG modeling) credits the proposed project with 156,013 square feet of Electronics Superstore, but the MND does not provide any meaningful information to support that 156,013 square feet of Electronics Superstore existed and was operational on May 24, 2022 when the modeling was prepared. The environmental setting of the project site described throughout the MND states that the site is vacant. This further demonstrates that it is not appropriate to provide reduction credits to the proposed project. The credits given for the “existing use” only serves to skew environmental impacts downward in an effort to reduce impacts. The emission and energy consumption credits given are based on a fully operational Fry’s Electronics store that was permanently closed nearly 1.5 years prior to the date of applicational submittal for the proposed project. Notably, the proposed project will exceed SMAQMD’s significance threshold of 1,100 MTCO2e (GHG emissions) annually prior to the reduction credits applied from the former Fry’s Electronics store. A Project EIR must be prepared to remove reduction credits from operations of the former Fry’s building, in order to be an adequate an accurate informational document. III.13 Transportation The MND has not adequately analyzed the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or result in inadequate emergency access. Figure 6: Proposed Site Plan depicts in multiple onsite areas that there is not adequate space to accommodate heavy truck maneuvering. The available onsite turning radius does not provide sufficient space to execute turning maneuvers. As shown on Figure 6, the white lines (outlines of the truck body and its maneuvering areas) overlap in several areas. The overlapping lines mean that if two trucks were to maneuver at the same time, they would collide because there is not adequate maneuvering space. For example, a truck attempting to exit the site from the south side of Building A is shown to collide with a truck maneuvering to a dock at Building B. Trucks maneuvering to utilize the dock doors on the east side of Building B are shown to collide at all eight of the modeled areas. Additionally, the MND has not provided any analysis of the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) at the project driveways. Only one driveway is proposed to serve all trucks/trailers and passenger cars entering and existing the project site. The MND has not included a turning radius exhibit to demonstrate that the project driveway intersection or Northgate Blvd. is adequate to accommodate truck/trailer turning maneuvers. A finding of significance must be made as part of a Project EIR due to both of these described issues.
Table 16: Project Trip Generation provides trip generation reduction credits for the former Fry’s Electronics building the VMT analysis also provides credits for existing uses. It is not appropriate to model the previous uses at full operational capacity and provide trip generation reduction credits based on existing uses. As noted above in the Environmental Setting analysis, the baseline environmental setting/existing conditions at the project site established in the MND are a completely vacant building and property. However, analysis throughout the MND credits the proposed project with emissions and energy consumption credits for operation of the site at full capacity. The arguments and analysis in the Environmental Setting review above are herein reincorporated. Appendix D: VMT Analysis credits the proposed project based on modeling the former Fry’s Electronics as ITE Land Use Code 863 even though the same document dated describes the building as "currently vacant.” If the MND wishes to credit the proposed project with trips from the existing building, it should have conducted traffic counts at the project site. Those traffic counts would demonstrate that 0 cars and/or trucks visit the site, and 0 reduction credits would be applied based on the environmental setting. Utilizing ITE standard modeling to model a vacant site as fully operational serves to artificially reduce the project’s significant environmental impacts. The existing conditions of the site generates 0 VMT and 0 vehicle trips. The project VMT analysis and project trip generation must be revised to remove any credit given for the existing building in order to accurately and adequately analyze the project’s significant VMT impacts in accordance with CEQA Section 15064.3 and the City’s General Plan LOS requirements. Additionally, a Project EIR must be prepared to include all truck/trailer activity for quantified VMT analysis. The operational nature of industrial/warehouse uses involves high rates of truck/trailer VMT due to traveling from large regional distribution centers to smaller industrial parks and then to their final delivery destinations. The project’s truck/trailer activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. A Project EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer activity to adequately and accurately analyze the potentially significant project transportation impacts. Conclusion For the foregoing reasons, GSEJA believes the MND is flawed and an EIR must be prepared for the proposed project and circulated for public review.
From: Peter Sheehan
To: Commission Submit; Jose Quintanilla
Subject: Fw: City of Sacramento Planning Commission Meeting 10-27-22 Public Hearing Item #3 Northgate Industrial Park Date: Tuesday, October 25, 2022 3:32:43 PM
Attachments: GSEJA NorthGate Industrial Park Project MND PC Comments 10-27-22.pdf Subject: City of Sacramento Planning Commission Meeting 10-27-22 Public Hearing Item #3 Northgate Industrial Park MND
To whom it may concern,
Attached to this email and below are public comments on behalf of Golden State Environmental Justice Alliance. The attachment contains further comments than below and is not duplicative of the below comments. These comments are submitted to the Planning Commission to be included in the record for the Planning Commission's consideration regarding the
Northgate Industrial Park Project MND, at the Planning Commission meeting October 27, 2022 at 530PM Public Hearing Agenda Item 3.
For clarification purposes, only the highlighted yellow portion of the body of this email is the public comment to be read aloud during the meeting as stated in the agenda packet.
Please confirm receipt of this email.
Good evening, my name is Peter Sheehan and I’m with the Golden State Environmental Justice Alliance. We submitted a comment letter to the Mitigated Negative Declaration. Our letter identified several deficiencies with the MND. The deficiencies include but are not limited to, project description, environmental setting, environmental checklist and discussion, air quality, energy, greenhouse gas emissions, and transportation.
During these turbulent times, we as citizens expect and deserve our local government’s elected and appointed officials to protect us from environmental and social injustice, to aid in the preservation and rehabilitation of the environment in which we all share, and to ensure accountability and responsibility in regard to the environmental decisions they may make.
We stand by our comment letter and believe the MND is flawed, and a full Environmental Impact Report must be drafted and circulated for public review. In closing we call on this commission to be a leader on the aforementioned issues and be the first line of defense for our citizenry and environment. Only by working together can we continue to be excellent stewards of our environment, outstanding stewards to our citizens and each other. Thank You.
Please confirm receipt of this email.
Thank You,
Peter Sheehan
To: City of Sacramento Planning Commission
From: Golden State Environmental Justice Alliance
Subject: NorthGate Industrial Park MND
This letter is to serve as further comment in addition to all previously submitted comments and documents by Golden State Environmental Justice Alliance.
CalEnviroScreen Information
CalEnviroScreen is a mapping tool that helps identify California communities that are most affected by many sources of pollution, and where people are often especially vulnerable to pollution’s effects. CalEnviroScreen uses environmental, health, and socioeconomic information to produce scores for every census tract in the state. The scores are mapped so that different communities can be compared. An area with a high score is one that experiences a much higher pollution burden than areas with low scores. CalEnviroScreen ranks communities based on data that are available from state and federal government sources. CalEnviroScreen is updated and maintained by The Office of Environmental Health Hazard Assessment, on behalf of the California Environmental Protection Agency.
CalEnviroScreen Data on NorthGate Industrial Park Project Location/Area
The above listed project is in census tract 6067007001 . Overall, when compared to other census tracts, the project site census tract is in the 83rd percentile regarding pollution. As far as pollution burden is concerned, this census tract is in the 65th percentile. In terms of Ozone, this census tract is in the 51st percentile, Particulate Matter 2.5 36th percentile, Diesel Particulate Matter 34th percentile, Toxic Releases 26th percentile and Traffic73rd percentile to name a few.
Conclusion
Consider the above referenced information when making this important decision. Realize that you and the citizens of this area face some of the WORST POLLUTION in the entire state of California.
It is the responsibility of the City’s elected and appointed officials to make environmentally responsible development decisions. Based on the CalEnviroScreen data, this is more than sufficient evidence of the further air quality impacts that the citizenry of Sacramento will continue to encounter with further development of a n industrial park. We are not against development, as we believe it is necessary for further economic growth in our current society. Development needs to be conducted with the highest of expectations to ensure the local population does not suffer further air quality burdens.
We stand by our comments and believe the MND is flawed, and a full Environmental Impact report needs to be drafted and circulated for public revi ew.
Respectfully Submitted,
Peter Sheehan
Peter Sheehan
GSEJA
Source - https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40
Glossary of Terms
Ozone - Amount of daily maximum 8-hour Ozone concentration
Particulate Matter 2.5 - Annual mean PM 2.5 concentrations
Diesel Particulate Matter - Diesel PM emissions from on-road and non-road sources
Toxic Releases - Toxicity-weighted concentrations of modeled chemical releases to air from
facility emissions and off-site incineration.
Traffic -Traffic density, in vehicle-kilometers per hour per road length, within 150 meters of the census tract boundary.