2025-01386 SUPPLEMENTAL MATERIAL County Development Project Upper Westside Specific Plan [Updated 08/11/2025 @ 3:16 PM]

CITY COUNCIL
Kevin McCarty, Mayor
Lisa Kaplan, District 1
Roger Dickinson, District 2
Karina Talamantes, Vice Mayor, District 3
Phil Pluckebaum, District 4
Caity Maple, District 5
Eric Guerra, Mayor Pro Tem, District 6
Rick Jennings, II, District 7
Mai Vang, District 8

CHARTER OFFICERS
Mindy Cuppy, City Clerk
Susana Alcala Wood, City Attorney
Farishta Ahrary, City Auditor
Leyne Milstein, Interim City Manager
John Colville, City Treasurer

City Council
Financing Authority
Housing Authority
Public Financing Authority
Redevelopment Agency Successor Agency
City Hall Complex
915 I Street, Sacramento, CA 95814
Published by the Office of the City Clerk
(916) 808-7200

SUPPLEMENTAL MATERIAL

Description: Attached is supplemental material received after publishing the agenda, attachment 10. The attached staff report replaces the original staff report in its entirety.

For the Meeting of: Tuesday, August 12, 2025 at 2:00 p.m.

Agenda Item: Discussion Item 8

8. County Development Project: Upper Westside Specific Plan

File ID: 2025-01386

Location: Natomas Basin, District 1, District 3

Recommendation: Pass a Motion authorizing the Mayor to execute and deliver a letter addressed to the Sacramento County Board of Supervisors expressing the City Council’s opposition to the Upper Westside Specific Plan.

Contact: Cheryle Hodge, Principal Planner, (916) 808-5971, [email protected]; Matthew Aijala, Assistant Planner, (916) 808-7176, [email protected]; Community Development Department

City of Sacramento
City Council - 2PM Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2025-01386 8/12/2025
County Development Project: Upper Westside Specific Plan File ID: 2025-01386
Location: Natomas Basin, District 1, District 3
Recommendation: Pass a Motion authorizing the Mayor to execute and deliver a letter addressed to the Sacramento County Board of Supervisors expressing the City Council’s opposition to the Upper Westside Specific Plan.

Contact: Cheryle Hodge, Principal Planner, (916) 808-5971, [email protected]; Matthew Aijala, Assistant Planner, (916) 808-7176, [email protected]; Community Development Department
Presenter: Cheryle Hodge, Principal Planner, (916) 808-5971, [email protected], Community Development Department
Attachments:
1-Description/Analysis
2-Background
3-City/County 2002 MOU - Natomas Joint Vision Area
4-Natomas Basin Chronology
5-City Comment Letter to County dated 10.28.24
6-Exhibit A - Natomas Basin Development Projects
7-Upper Westside Land Use Plan
8-NBHCP Swainson’s Hawk Zone One Mile Buffer
9-City NBHCP Letter to County dated 11.28.2000
10-County Responses to City Comments
Description/Analysis
Issue Detail: For over 25 years, the City of Sacramento has led regional efforts to balance urban development with habitat conservation through the implementation of the Natomas Basin Habitat Conservation Plan (NBHCP). This report provides the City Council with a comprehensive understanding of the history that has shaped current conditions and documents the emerging crisis created by Sacramento County's processing of development applications that conflict with established regional agreements and conservation strategies.

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Brief History of the NBHCP
In the 1980s, Congress authorized a federal project for levee improvements in the Natomas Basin, and the U.S. Army Corps of Engineers (USACE) approved Sacramento Area Flood Control Agency’s (SAFCA) construction of proposed levee improvements to provide 100-year flood protection in the Natomas Basin. Through its Section 7 consultation process with the USACE, the U.S. Fish & Wildlife Service (USFWS) required that SAFCA agree that the land-use agencies with jurisdiction in the Natomas Basin would complete a habitat conservation plan to obtain take coverage for the effects of development on the giant garter snake (GGS) and Swainson’s hawk (SWH). 1997 NBHCP
The City of Sacramento ended up preparing the 1997 regional Habitat Conservation Plan designed to authorize take of GGS, SWH and other threatened and endangered species associated with development in the entire basin. (National Wildlife Federation v. Babbitt, 128 F. Supp. 2d at 1277- 1279 (“Natomas I”)). The 1997 NBHCP anticipated that five jurisdictions would participate in the regional plan: the City, Sacramento County, Sutter County, Natomas Mutual Water Company, and Reclamation District No. 10. In the end, only the City agreed to participate.

The Environmental Council of Sacramento (ECOS) and Friends of the Swainson’s hawk (FOSH) successfully sued the USFWS and CDFW regarding the adequacy of the HCP and associated environmental document under CEQA. Judge Levy invalidated the NBHCP on the basis, in part, that the NBHCP was premised on all five jurisdictions participating in the HCP when only the City completed the NBHCP and obtained incidental take coverage. [Natomas II at p.23 (ln 11-23)]. 2003 NBHCP
The City spearheaded the effort to revise the NBHCP to address Judge Levy’s opinion inNatomas I.

The City, Sutter County, Natomas Mutual, and RD 1000 participated in the NBHCP effort, but Sacramento County did not (the Metro Air Park owners association obtained its own HCP for unincorporated land in Sacramento County, but the County was not a permittee; the MAP HCP allows 2,011 acres of development including 28 acres in the City of Sacramento and 1,983 acres in Sacramento County).

The City of Sacramento is a permittee under the NBHCP and is a signatory to the Implementing Agreement (IA). Under the NBHCP, the City obtained incidental take authorization from USFWS for the take of the federally listed GGS among other federally-listed threatened and endangered species for a 50-year permit term. Pursuant to the Section 2081 permit, the City obtained take authorization as a matter of the California Endangered Species Act (CESA) from CDFW for the incidental take of Swainson’s Hawk. The USFWS and CDFW approved the revised NBHCP in 2003. The USFWS and

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CDFW approved the NBHCP, executed the IA and issued incidental take permits to the City, Sutter County, and The Natomas Basin Conservancy (TNBC). Sacramento County is not a plan participant.

The 2002 Memorandum of Understanding
Before the City adopted, and the USFWS and CDFW approved the 2003 NBHCP, on December 10, 2002, the Sacramento City Council and County Board of Supervisors adopted a Memorandum of Understanding regarding principles of land use and revenue sharing for the Natomas area, establishing what became known as the "Natomas Joint Vision." The MOU can be found in Attachment3.

This MOU was adopted through City Resolution 2002-830 and County Resolution 2002-1566. The agreement explicitly recognized that "cooperation between the County and the City is an opportunity to develop a vision for Natomas which reflects areas of collective interest." The MOU established clear jurisdictional roles, stating that "the City, rather than the County, is the appropriate agent for planning new growth in Natomas and can better provide a full range of municipal services. The County is the appropriate agent for preserving open space, agricultural and rural land uses." County Development Proposals
Sacramento County is currently processing development applications for three separate major development proposals in the unincorporated portion of the Natomas Basin (Attachment 6). These development proposals are referred to as the Upper Westside Specific Plan (2,066 acres and 9,356 residential units), GrandPark Southwest Specific Plan (1,871 acres and 8,589 residential units), and Grandpark Trails Specific Plan (3,517 acres and 16,056 residential units). The proposals together consist of approximately 7,454 acres in Natomas Basin and 34,001 residential units.

The Upper Westside Specific Plan (UWSP), encompassing 2,066 acres in what is locally known as "the Boot" area, proposes development of approximately 1,524 acres with 9,356 dwelling units accommodating 25,460 residents and 3,106,700 square feet of commercial uses (Attachment 7). The remaining 542 acres would serve as an agricultural and open space buffer between the development area and Garden Highway and the Sacramento River. The Boot area, bounded by the City of Sacramento on three sides, has remained in agricultural use specifically because of the regional agreements to preserve open space and habitat. The proposal includes three K-8 school sites, one high school site, several parks, and a 10-acre urban farm site on property owned by the Los Rios Community College District.

On October 24, 2024, City staff submitted a comment letter to the County on the UWSP Draft Environmental Impact Report documenting the consolidated feedback from City departments that raise numerous concerns and issues (Attachment 3). The following provides a brief summary of topical issues with the complete detailed October 24, 2024 comment letter provided as Attachment 5:

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· 2002 City/County MOU - Contrary to the MOU, the County has assumed the role of approving urban development in the Natomas Basin instead of the role the County agreed to, which was to preserve open space, agricultural and rural lands.
· Economic Impacts - Concerns about the concentration of commercial development along the westerly extension of El Camino Avenue remain unaddressed. The County has not sufficiently analyzed the potential regional nature of this retail development and its implications for traffic patterns and associated environmental impacts in the Natomas Basin. It fails to address the potential secondary physical and economic impacts within the City that may result from locating retail, hospitality, and other commercial uses adjacent to the City boundary. · Growth Inducement - The Upper Westside Specific Plan (UWSP) project would induce growth by extending the County’s Urban Services Boundary and Urban Policy Area. The County has not sufficiently analyzed the project's consistency with regional long-range plans, particularly its inclusion or absence from the Region's Sustainable Communities Strategy. This omission is significant, as it relates directly to the broader regional planning context and potential cumulative impacts on the City of Sacramento.
· Habitat Conservation Plan - The County failed to adequately evaluate the UWSP’s conflicts with the NBHCP and impacts on the NBHCP conservation:
o Significant portions of the UWSP development would encroach into the Swainson's Hawk Zone - a critical one-mile-wide buffer adjacent to the Sacramento River (Attachment 8). The UWSP’s inadequate agricultural buffer of 542 acres, ranging from merely 700 to 2,700 feet in width, is insufficient compared to the one mile (5,280 feet) protective buffer mandated by the Natomas Basin Habitat Conservation Plan (NBHCP).

This reduction in buffer width would severely compromise a core conservation measure that both wildlife agencies have previously determined to be essential for the protection of Swainson's Hawk habitat.
o The County did not adequately evaluate the UWSP’s effects on the NBHCP due to the development of 1,524 acres of agricultural lands outside of the 17,500 acres authorized for development under the NBHCP. The County has failed to properly analyze and address the concerns raised by the City regarding the County’s approval of development projects outside of the 17,500-acre limit of authorized development under the NBHCP. The County instead focused the analysis on the impacts and mitigation of the UWSP itself but does not address how the UWSP affects the HCP mitigation acreage requirements of 8,750 that must be completed in the Basin for the development authorized in the City of Sacramento, Sutter County, and Metro Air Park.There would be a significant loss of agricultural/open space acreage in the Basin

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directly from the UWSP development itself.
· Agriculture/Open Space - The UWSP falls short in addressing crucial concerns regarding the project's impact on agricultural resources and the habitat conservation plan. UWSP will result in the conversion of approximately 1,372 acres of farmland. How this loss might affect the habitat conservation plan’s requirement to maintain 4,375 acres in rice cultivation for Giant Garter Snake habitat is not addressed.
· Transportation - The UWSP continues to rely on fair share contributions toward roadway widening projects within City limits without adequately addressing concerns raised by City staff about implementation responsibility. For instance, UWSP mitigation still assumes City involvement in implementing improvements at I-5 on-ramps and I-80, despite City staff previously indicating that the City should not be assumed to have matching funds. The UWSP does not propose alternative mitigation approaches that avoid placing implementation responsibility on the City, nor does it explain how these projects would be fully funded and executed given the City's financial constraints. The UWSP VMT analysis remains narrowly focused on project-level impacts and does not address our request to examine how the UWSP may redistribute growth away from the City or impact the City's VMT relative to the regional average. The City continues to be concerned about potential impacts on the City's growth patterns and overall regional VMT efficiency.
· Water - The UWSP assumes that the City of Sacramento would provide the future water supply and potable water service to the project even though the City has not agreed to provide water supply/service to the UWSP. The UWSP Draft EIR states that "The City of Sacramento through an agreement with the SCWA would provide water service to land uses allowed under the proposed UWSP." However, no such agreement exists. This assumption conflicts with General Plan Policy LUP-1.4, which requires annexation prior to the provision of City services unless specific conditions are met, including that "the annexation process has been initiated, and the landowner and City have executed a conditional agreement for services that stipulates minimum standards for the development of roads and urban infrastructure and criteria and conditions for annexation into the City." Water supply/service is essential for any development, yet the UWSP continues to advance through County approvals without this issue being resolved.
· Parks and Recreation - The proposed UWSP is located adjacent to communities of the City of Sacramento; South Natomas and North Natomas. Each community was established and planned to be well-served by neighborhood and community parks that are located within a 10- minute walk of almost all the residential areas. The proposed UWSP falls short of providing parkland. The proposed project’s “parks program” includes 76.5 - 79 acres of parkland which meets the minimum guidelines of 3 acres per 1,000 residents. The 76.5 acres of parkland is considered neighborhood/community serving parks, which will be programmed with active

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recreation uses. However, the DEIR analyzes the project at the minimum dedication requirement under the Quimby Act of 3 acres per 1,000 residents, less than the County’s (and City’s) policy requirement of 5 acres per 1,000. The UWSP “parks program” supplements parkland with an additional 86 acres of parkland but this supplemental acreage is identified as:
permanent drainage facilities, a greenbelt without recreation amenities, urban farms that will likely be leased and operated by community based or non-profit organizations, agricultural buffers, and a median with a trail. These types of facilities do not take the pressure off adjacent neighborhood and community parks that do contain active recreation, which is in high demand in the City of Sacramento. The City of Sacramento Youth, Parks, & Community Enrichment Department (YPCE) recommended that the project reduce the impacts to existing City parks by adding, or converting, 51.5 acres of neighborhood/community serving parkland in order to meet the 5 acres per 1,000 resident standard. The UWSP should incorporate the City’s standards and guidelines for neighborhood and community parks, as adopted by the City’s Parks Plan 2040 and the 2040 General Plan Master EIR. · Municipal Services & Infrastructure (Fire, Police) - The UPW lacks a comprehensive analysis of municipal services as requested. The City continues to request a more detailed evaluation of current service levels, response times, equipment needs, and long-term planning for fire protection and police services. Furthermore, the County has not sufficiently addressed how the project proponent will mitigate service demand impacts and maintain current levels of service throughout the project's implementation. The City has requested more specific information on phasing, funding mechanisms, and interim measures to ensure consistent service levels during development. UWSP is in an area that is bounded on three sides by the City of Sacramento. UWSP is not located in an urbanized unincorporated area of the County currently receiving services and facilities that are necessitated by development of the magnitude of UWSP. The UWSP area in essence creates a County island surrounded on three sides by City urbanization and bordered by protected open space (Fisherman’s Lake), a federally designated levee system with a two-lane rural roadway. Municipal services provided to UWSP by the County or other entities would be a challenge at best, which would likely impact adjacent City services without additional revenue.

On June 23, 2025, despite these unresolved conflicts, the Sacramento County Planning Commission unanimously recommended approval of the Upper Westside project to the Board of Supervisors. This action proceeded without resolving the issues raised by City staff. The Sacramento County Board of Supervisors is scheduled to take final action on the UWSP on August 20, 2025.

The County is concurrently processing two additional specific plans for development proposals in the northern portion of the Natomas Basin. The GrandPark Southwest Specific Plan proposes 1,871.2 acres of development with 8,589 dwelling units, 133.8 acres of Health & Hospitality Mixed Use, 99.7 acres of Office & Entertainment Mixed Use, 26.0 acres of Neighborhood Mixed Use, 22.4 acres of Neighborhood Commercial, and 25.3 acres of Schools. The Grandpark Trails Specific Plan, covering

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approximately 3,400 additional acres, would complete the urbanization of what was originally conceived as a single 5,675.6-acre Natomas North Precinct development area.

If Sacramento County approves the UWSP and the two other pending projects beyond the 17,500 acres authorized by the wildlife agencies, the combined 7,421 acres of proposed County development (1,524 acres from Upper Westside and approximately 5,889 acres from the GrandPark Southwest and Grandpark Trails projects), when added to the already authorized 17,500 acres, would result in nearly 25,000 acres of urban development in a basin where the conservation strategy supports a maximum of 17,500 acres of urban development.

For the reasons stated above, Staff recommends that the Council authorize the Mayor to execute and deliver a letter addressed to the Sacramento County Board of Supervisors expressing the City Council’s opposition to the Upper Westside Specific Plan.

Policy Considerations: The following are relevant 2040 General Plan policies that target conservation objectives citywide.

ERC - 2.11: Natomas Basin Habitat Conservation Plan. The City shall continue to participate in and support the policies of the Natomas Basin Habitat Conservation Plan for the protection of biological resources in the Natomas Basin.

LUP-1.4: City Services Prior to Annexation. Prior to the provision of City services to new development in unincorporated areas, the City shall require that the unincorporated properties be annexed into the City. Alternatively, the City may provide utility service to properties in advance of annexation only if the annexation process has been initiated and the landowner and City have executed a conditional agreement for services that stipulate minimum standards for the development of roads and urban infrastructure and criteria and conditions for annexation into the City. LUP-1 3-4 LUP-1.11: Coordinate to Protect Farmland. The City shall continue to work with Sacramento County and other adjacent jurisdictions to implement conservation plans, preserve farmland and protect critical habitat outside the city.

Environmental Considerations: The UWSP is a County project located in unincorporated Sacramento county, and the City is neither the lead agency nor a responsible agency for the project under CEQA. The item under consideration by the city council is not a project that is subject to CEQA because it is an administrative activity that will not result in direct or indirect physical changes in the environment. (CEQA Guidelines, § 15378(b)(5).)
Rationale for Recommendation: Staff recommends the Council authorize the Mayor to execute and send a letter addressed to the Sacramento County Board of Supervisors communicating the City Council’s position of opposition on the UWSP. As proposed, the UWSP has direct negative

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environmental, economic, and service level impacts to the City of Sacramento that requires a discussion and response by the City Council prior to deliberation by the County Board of Supervisors.

Financial Considerations: Not applicable.

Background Information
The following provides a brief summary of the Natomas Basin Habitat Conservation Plan. A chronology of Natomas Basin is provided in Attachment 4.

Creation of the Natomas Basin Habitat Conservation Plan (1995-2003) Conservation planning in the Natomas Basin began with the recognition that the 53,537-acre area represents critical habitat for numerous species while also facing inevitable development pressure.

The basin's location, bounded by the Sacramento River and various canal systems, creates a distinct ecological area that demanded comprehensive planning rather than piecemeal development decisions.

In 1997, the City of Sacramento adopted the original NBHCP. This effort sought to create a framework that would allow urban development to proceed while ensuring the long-term survival of 22 covered species, including the federally threatened giant garter snake and the state-threatened Swainson's hawk. The U.S. Fish and Wildlife Service and California Department of Fish and Wildlife issued Incidental Take Permits (ITPs) to the City on December 31, 1997, authorizing the "take" of protected species incidental to otherwise lawful development activities.

The original plan faced immediate legal challenges. Between 1998 and 1999, lawsuits were filed in both state and federal courts by environmental organizations including Friends of Swainson's Hawk, Environmental Council of Sacramento, and the Sierra Club. These legal challenges argued that the conservation strategy was insufficient to protect the covered species and that the environmental analysis was inadequate. The litigation resulted in court judgments in 2000 and 2001 that required substantial revisions to the NBHCP.

During this period, Sacramento County was actively invited to participate in the regional conservation planning effort. A letter dated November 28, 2000 (Attachment 9), from the City, Sutter County, and The Natomas Basin Conservancy (TNBC) documents the formal invitation extended to the County to join as a permittee under the NBHCP. The County's decision to decline this invitation would have lasting ramifications for regional planning coordination that continues today. This decision meant that any future development in the unincorporated County portions of the basin would occur outside the established conservation framework, creating the potential for the conflicts we see today.

The revised NBHCP was adopted by the City Council in 2003, The plan established a framework allowing for exactly 17,500 acres of development within the basin: 8,050 acres allocated to the City of Sacramento, 7,467 acres to Sutter County, and 1,983 acres for the Metro Air Park project in

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Sacramento County (which obtained its own separate habitat conservation plan). This development cap was the result of extensive biological analysis determining the maximum level of development that could occur while still maintaining viable populations of the covered species.

The conservation strategy required mitigation at a ratio of 0.5 acres of habitat preservation for every

1.0 acre of development, resulting in the eventual preservation of 8,750 acres of habitat lands.

NBHCP Implementation (2003-2025)
Following the adoption of the revised NBHCP and the MOU, the City of Sacramento has remained committed to its implementation. The Natomas Basin Conservancy (TNBC), established as the plan operator for the NBHCP, has acquired and managed habitat lands throughout the basin. According to TNBC’s 2024 Implementation Annual Report, as of December 31, 2024, the organization manages 5,389.39 acres of mitigation land.

Through December 31, 2024, developers within the City's permit area have paid $54,971,836.95 in mitigation fees. These fees fund not only land acquisition but also restoration, enhancement, and perpetual management of habitat lands. TNBC endowment fund, designed to ensure permanent funding for habitat management after the 50-year permit term expires, reached $45,624,494 by the end of 2024.

The City's annual reports to the wildlife agencies document development within the authorized limits.

As of December 31, 2024, grading permits have been issued for 6,864.58 acres within the City's permit area, leaving 1,185.42 acres of remaining capacity. However, this remaining capacity includes:
121.68 acres are located outside current City limits in the proposed Airport South Industrial annexation area, 40 acres are reserved for a potential second high school site, and 372.17 acres are unallocated to any specific project or parcel. The actual remaining NBHCP development acreage capacity within existing City limits for identified projects is only 653 acres.

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Natomas Basin - Chronology

General Timeline:

1981, April 22
nd, LAFCo staff report providing response relative to the City’s SOI. Among the topics addressed in the report there is an emphasis on describing the City’s water rights and in relationship to the City’s SOI. The water rights have been described by City officials as extremely unique. The Bureau (the U.S. Water and Power Sources Service) agreed in 1957 to supply the City of Sacramento with as much water as the City nee ds (up to 326,800 acre/fee), at a fixed rate, in perpetuity, provided the City “perfects” those rights at some future point. The justification to divert his amount of water was an ultimate projected population of 1.2 million with a per capita daily consumption of 327 gallons of water.

1981 – October 21
st, City Sphere of Influence (SOI) was adopted by LAFCo in October 1981, after nine public hearings. It has been amended from time to time, in 1984, 1991, 1995, 1996, and in 2006. The SOI is used for planning purposes and represents an area that is a potential service area by the City. The SOI does not necessarily represent a boundary for immediate annexation. It serves the purpose of encouraging more intense cooperation and coordinated between the City, County and affected special districts in those unincorporated areas the bear a direct relationship to the City’s long range planning actions and policies.

1986 – City adopts North Natomas Community Plan (NNCP)

1986 – North Natomas Settlement Agreement for the 1986 NNCP prohibits the City from planning for lands north of Elkhorn Boulevard (note: this has now since expired).

1993 – Board of Supervisors concurred with letter Sacramento City Council members signed stating in the event the Natomas Vision Plan ( NVP) area were to urbanize, it should do so within the City of Sacramento. Based on that information, the Board chose not to extend the Urban Services Boundary (USB) to include the NVP area but recognized the potential urbanization of the NVP area.

1995 – Draft Natomas Basin Habitat Conservation (NBHCP) is released for public review.

1996 – Ose family and Norton family submit applications to move the USB, and County initiates a Special Study for moving the USB and prepares an Environmental Impact Report (EIR). The Special Study Area includes the North Precinct area.

1997 – City of Sacramento adopts the Natomas Basin Habitat Conservation Plan (HCP) on 8/17/97

1997 U.S. Fish & Wildlife Service and California Department of Fish Game issue Incidental Take Permits (ITPs) on 12/31/97 to City of Sacramento

1998/1999 Lawsuits are filed in state and federal courts by Friends of Swainson’s Hawk (FOSH), Environmental Council of Sacramento (ECOS) and Sierra Club challenging the issuance of the ITPs.

1999 – June 3
rd, City Council considers staff recommendation to direct staff to report back within sixty days with a work program for a General Plan Amendment and to revise the City’s SOI.

1999 – June15th, City Council provides direction to staff to prepare a report regarding amending the Sphere of Influence and a General Plan Amendment . City SOI and Annexation Policy (M 99-013)

1999 – June 22 – City releases Notice of Preparation (NOP) for City SOI Amendment and Annexation

1999 – County releases the Draft EIR for the Special Study Area which includes North Precinct.

2000 – February 22
nd – AKT files annexation application P00-027/028, filed on February 22, 2000. The application was placed on hold in October 2005. The Natomas Unified School District purchased 41 acres in the northernmost portion of the West Lakeside property and has issued a Notice of Preparation for an EIR for a middle/high school.

2000/2001 – State & Federal Court judgments issued for pending lawsuits filed by FOSH, ECOS and Sierra Club.

2000 – March 29th, City issues notice for a sphere of Influence Revision Study.

“In recognition of the evolving political landscape of Sacramento County, the City Council has directed staff to revisit existing SOI and Annexation Policies through an amendment to the City’s General Plan.

Goal: Establish a “de- facto” Sphere of Influence” which articulates Areas of Concern surrounding the existing City limits, regarding habitat preservation and future urbanization, and thus provide the City with a leadership role on a regional sacle for growth management”.

2000 – June 7
th – Landowner provides Sacramento County with Notice of Non- Renewal for Williamson Act on property known as West Lakeside property.

2000 – June 22
nd, Planning Commission reviews and provides comments on the Sphere of Influence Revision Study

2000 – June 27 th, City Council reviews the SOI Revision Study and Comprehensive Annexation Policy. Staff report indicates that the City declares its intention to preserve substantial open space lands within the Sphere for the purposes of permanent open space, habitat conservation, airport protection, agricultural preservation, and urban design and aes thetics. Private and governmental grants will supplement development fees in carrying out the policy.

2000 – County withholds action on the Special Study Area in response to City signal that it will move forward with the planning effort in the Special Study Area.2001 – City submits comments for Draft EIR regarding continued County effort to amend the Urban Services Boundary in North Natomas expressing concern for timing with regards to ongoing coordination efforts. Later in 2001, City and County staff continue to meet and discuss a mutually beneficial process for planning the unincorporated Natomas area.

2001 – Report back to City Council (11/13/01) regarding Settlement Agreement for litigation regarding 1997 HCP

2001/2002 – Revisions are made to the 1997 HCP

2002 – City Council and Sacramento County Board of Supervisors enter into an MOU for the NVP area which outlines how urbanization would be considered.

2003 – City of Sacramento and Sutter County adopt updated HCP . The 1997 NBHCP was updated and modified as a result of litigation involving a challenge to issuance of take permits to the City of Sacramento.

2004 – SACOG Board adopts the Blueprint Map that includes urbanization over a portion of the NVP area by 2050.

2004 – July 29
th, Draft Municipal Services Element released for the proposed West Lakeside Property SOIA & Annexation.

2005 – Greenbriar Proposed Project filed with City of Sacramento (5/11/05) proposing annexation into City limits

2005 – Greenbriar Notice of Preparation (NOP) released by LAFCo/City (8/16/05)

2005 – City management initiates potential planning process for NVP area similar to the process for Greenbriar. City Council decides not to move forward with process. Ose family reactivates appeal to move the USB for their property. Gidaro Group appeals to the County Board of Supervisors the staff decision to deny accepting its application to move the USB.

2005/2006 – Greenbriar public meetings and workshops

2005 – Judge Levi (U.S. District Court) issues Memorandum of Opinion and Order on 9/7/05 in National Wildlife Federation (National Wildlife Federation, Friends of Swainson’s Hawk, Planning and Conservation League, and Sierra Club (Plaintiffs) v. Gale Norto n, Secretary of Interior (Defendant). Judgment in favor of Secretary of Interior.

2005, October – AKT annexation application P00 -027/028 which was filed on February 22, 2000 is placed on hold.

2006 – In March, Board of Supervisors considers appeal by Ose Properties regarding development north of Elverta Road. In early April, the City Council reaffirmed the MOU from 2002 and urge the Board of Supervisors to postpone appeal and other development applications in the NVP area while also directing City staff to move forward on an open space strategy ahead of further action. Later in April, the City Council and Board of Supervisors directed their respective staff to initiate open space program contracts for the area with the goal of how to effectively implement open space priorities.

In July, the City Council initiated (Resolution 2006-568) a Sphere of Influence and related Municipal Services Review and EIR for the NVP (now NJVA) and directed staff to report back with all corresponding and future actions and outreach. City Council authorized execution of a professional services agreement for the EIR and Municipal Services Review.

2006 – Sacramento Local Agency Formation Commission (LAFCo)/City release Greenbriar Draft EIR for public review on July 19, 2006.

2007 – In January, the Board of Supervisors and City Council adopted new MOU to share costs for open space programs and General Plan Amendment EIR . The Board of Supervisors received a general update and continued the further consideration of development projects in the NVP area in September, with the City Council hearing a similar status update in October.

2007 – Greenbriar issuance of 2
nd Draft EIR revised and recirculated for public review (April 10, 2007)

2007 – Sacramento LAFCo approves Sphere of Influence Amendment – Greenbriar (July 19, 2007)

2007 – County Board of Supervisors Workshop on Greenbriar Open Space

2007/2008 – Multiple LAFCo/City public workshops and public hearings on annexation of Greenbriar area

2007/2008 – Joint meeting between County Executive and City Manager with key landowner representatives to discuss moving forward with a comprehensive and collaborative planning process. The meeting highlight s the County’s commitment to develop a plan for the NVP area that is inclusive of multiple interests. The Board of Supervisors considers a County led development process and endorses the effort that becomes known as the Broad Visioning process, with funding provided from the Owners group {consists of Angelo K. Tsakopoulos, Brookfield Natomas LLC, Demeter Development, L.P. (Successor to Jeffrey S. Norton Trust), Gibson-Tsakopoulos, LLC, MJ 318, L.P., Natomas Boot II, LLC/ Natomas Boot Investors, LLC, North Natomas/Airport De Matos, LLC, Ose Properties Inc, Saca Development, LLC, and West Lakeside, LLC}.

2008 – City Council approves proposed Greenbriar Project & Annexation (1/29/08).

2008 - City Council approves County/City Property Tax Exchange Agreement and Open Space MOU (3/11/08). County approves TEA and Open Space MOU (3/12/08).

2008 – Sacramento LAFCo approves Greenbriar Annexation 577 acres (4/2/08)

2008 – In April, City Council received comments on the Final Draft Open Space Program Report and a status report on the broad visioning effort. The Open Space Program Report was received and filed to inform subsequent planning efforts. In May, The Board of Supervisors held a similar hearing for the Open Space Program Report and reaffirmed the broad visioning process. The Board directed staff to obtain financial contributions from the Natomas Landowners Group to expand the scope of County staff efforts and involvement.

2008-In September, the Board of Supervisors approved a funding agreement between the County and Natomas Landowners Group to continue joint City and County planning efforts and retention of consultants. The agreement recognized the City of Sacramento as a parti cipating agency in the collaborative planning process and in November, the Board of Supervisors approve and MOU between the County and City regarding the reimbursements of City staff and legal consultant costs.

2008/2009 – City sought landowner financial contribution to prepare Municipal Services Review (MSR) as part of Sphere of Influence activity. City canceled consultant contract given lack of funding being provided and landowners’ determination to proceed to apply to the County to urbanize in the NVP.

2008/2009 – County and City hold public workshops to discuss broad visioning principles for potential urban areas. Three sketches are created. Staff presented results to City Council and County Planning Commission and Board of Supervisors.

2010 – Board of Supervisors initiates consideration of a Special Planning Area for the entire NVP area. Biological studies begin. Multiple meetings occur with County Airports staff.

2011 – In July, Board of Supervisors reaffirms cooperative work between the City, County, and landowners, and in August addressed additional funding details for planning work .

The Owners’ Group conduct s a series of outreach sessions with landowners within the NVP area. Meeting dates were August 29 and 30, and September 13 and 15, 2011.

In November 2011, the Board of Supervisors approved the 2030 General Plan which included an overlay for the NVP area. The overlay reads as follows:

 Natomas Joint Vision Area. On December 10, 2002, the Sacramento City Council and Board adopted a Memorandum of Understanding (MOU) outlining principles of land use and revenue sharing between the City and County of Sacramento for the Natomas area, setting the stage for what has c ome to be known as the “Natomas Joint Vision.” The “Natomas Joint Vision Study Area” overlay on the Land Use Diagram indicates the area addressed by this MOU.

The cooperative effort addresses land use, economic development, and environmental opportunities and challenges in Natomas. The result will be quality development balanced with permanent open space preservation systems. Additionally, SACOG’s Blueprint shows significant development in the Natomas Joint Vision Area. Because of the MOU, the Blueprint and the importance of the Natomas Joint Vision Area to the region, the County anticipates development in portions of the Natomas Basin within the timeframe of the General Plan. Subject to the preparation and certification of the appropriate environmental documentation, this development shall be accomplished either by an expansion of the USB, the City’s Sphere of Influence, or both. See related policy LU -114 and Implementation Measure C in the “Regional and Local Agency Coordination” section of this Element.

2012 – Subsequent to the adoption of the 2030 General Plan, in February 2012 the Board initiates the Natomas Vision Plan and General Plan Amendments for the N JVA area including an expanded USB and Urban Policy Area (UPA), with the boundary locations to be determined through the Master Plan process, in addition to associated rezones, and a Special Planning Area zone.

2014 – December 11
th, City sends comment letter responding to NOP for North Precinct development with questions regarding a range of issues, including City’s NBHCP, habitat mitigation, water service, flood protection, economic impacts and revenue sharing.

2015 – Board of Supervisors adopts new funding agreement. The participating owner’s group of the N VP (consists of Brookfield (representing 11 property owners) , Ose Properties, and Demeter Development} acting as the Applicant, revise the proposed expansion of the USB to be coterminous with the UPA boundary for the North Precinct.

Board approves contract with ESA to prepare the EIR for the Natomas North Precinct.

2016, November 15
th – Former Mayor Heather Fargo urges County Board of Supervisors to postpone funding agreement and EIR consultant for the North Precinct development until the BOS discusses the entire USB at the December 15 th board meeting. Fargo comments that the basic premise of the NJVP was that the City proceed with any additional urban development within the existing or expanded City limits , and for the County to focus on the airport, agriculture and habitat. Additionally, stating that the proposed development should be handled by the City or not all. To do otherwise, undermines the City’s plans for infill , utilizing existing infrastructure and approved plans not only for North Natomas but also throughout the city.

2016 – Board of Supervisors approves acceptance of North Precinct development encompassing ±5,700 acres north of Elkhorn Boulevard and initiates CEQA review.

2017 – County distributes revised NOP for North Precinct (now Grandpark) to update project scope and land use specifications.

2018 – City staff sends comment letter in January to County for revised NOP for Grandpark reiterating issues related to the MOU, the HCP, water provision, fire/police services, transportation, future economic development, and sustainability. Staff receives no formal response initially. Applicants for Upper Westside initiate planning process with County pursuant to County-adopted General Plan criteria. City initiates its own General Plan Update process in October, part of which will evaluate the NJVA Special Study Area.

2019 – February 26th, Board formally initiates the Upper Westside Project (UWP) Specific Plan development encompassing 2,066-acre Plan Area, (±1,532-acre urbanized area and ±534-acre agricultural buffer area). Project includes amending USB. An open house and multiple neighborhood outreach meetings held in latter half of 2019.

2020, October 5
th – County releases NOP for UWP

2020, November 20th – City staff sends comment letter to County for NOP for Upper Westside identifying similar issues to Grandpark related to the MOU, the HCP, water provision, fire/police services, transportation, future economic development, and sustainability. City staff is again actively engaging County staff and applicant teams to have dialogue around City interests and updates on planning efforts for the NJVA.

2021, May – Airport South Industrial (ASI) Project Application is filed with City of Sacramento (May 2021)

2021 – City/LAFCo MOU for Co -Lead Agencies for CEQA EIR for the ASI Sphere of Influence Amendment & Annexation (7/30/21)

2022 – City/LAFCo release Notice of Preparation (NOP) for ASI Project on 3/4/22 for public review.

2022 – City/LAFCo hold NOP Public Scoping Meeting 3/16/22

2022/2023 – ASI Project Applicant hosts community open houses, presentations to North Natomas Community Coalition etc.

2024, August 29
th – County releases Draft EIR for UWP.

2024, October 28
th – City submits DEIR comment letter on UWP to County

2025, January 28
th – Grandpark submits application for Grandpark Brookfield Specific Plan (formerly known as North Precinct and/or Grandpark). Brookfield SP is 3,484.1 acres. The plan provides for 15,944 housing units with a mixture of densities that supports all populatio n segments; 29 active parks; and an extensive plan- wide multi- use trail system.

2025, January 28 th – Grandpark Southwest application filed. Ose & Demeter are applicants for Specific Plan. The area is 1,871.2 acres in size. The Specific Plan provides for 8,589 housing units with a mixture of densities that supports all population segments; 27 active parks; and an extensive multi-trail system throughout the plan area.

2025, February 25
th – County B oard of Supervisors (B OS) approves reimbursement funding agreements for both Grandpark projects and revised contract for CEQA work (ESA consultant).

2025, April 2
nd – LAFCo holds S phere of Influence Amendment (S OIA) hearing for the Airport South Industrial project (ASI) area. Hearing continued to 5/7/25.

2025, May 7
th – LAFCo approves amending City’s SOI for approx. 450-acre Airport South Industrial area.

2025, May 22
nd – City Planning & Design Commission Hearing for consideration of ASI Project & Annexation (approx. 450-acres) – Hearing continued to 6/26/25.

2025, June 24
th – County Planning Commission unanimously approves recommendation to the County Board of Supervisors approval of the Upper Westside Specific Plan.

2025, June 26
th – City Planning & Design Commission recommends to City Council approval of the Airport South Industrial Project & Annexation.

300 Richards Blvd., 3rd Floor
Sacramento, CA 95811

Help Line: 916-264-5011
CityofSacramento.org/cdd

October 28, 2024

Letter submitted via e-mail at: [email protected].

Sacramento County,
Department of Community Development, Planning and Environmental Review Division Attention: Environmental Coordinator
827 7th Street, Room 225
Sacramento, CA 95814

Subject: COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE UPPER WESTSIDE SPECIFIC PLAN (PLNP2018-00284).

Dear Environmental Coordinator,

On August 30, 2024, Sacramento County released the Draft Environmental Impact Report (DEIR) for the Upper Westside Specific Plan (UWSP). The proposed UWSP would include development of approximately 1,532± acres within a 2,066 acres project area located north and west of Interstate 80 and north and east of Garden Highway. The proposal includes the addition of 9,356 dwelling units (25,460 population) and 3,106,700± square feet of commercial uses into the unincorporated Natomas area bounded by the City of Sacramento. The project plan includes development consisting of residential, neighborhood mixed-use, neighborhood commercial, community mixed- use, office mixed-use and health & hospitality mixed-use. The plan includes three K-8 school sites, one high school site, several parks, and a 10.0± acre urban farm site on property owned by the Los Rios Community College District that is envisioned to be part of a 16.0± acre vocational training campus.

The proposed UWSP borders the City of Sacramento on three sides. This area is located within the City’s American River Place of Use (POU) for water rights and the Natomas Basin Habitat Conservation Plan (NBHCP). The Sacramento unincorporated area of Natomas Basin is designated as an Area of Concern and a Study Area per the City’s 2040 General Plan. The UWSP is located in an area that is also known as the “Boot” per the Natomas Joint Vision Plan that was a joint planning effort undertaken years ago with a group of landowners, Sacramento County and the City of Sacramento.

2 The magnitude of the project is significant in that the proposal consists of the development of 1,532 acres of the 2,066 acres of rural agricultural lands. This area along with other open space lands located in Natomas Basin has been mostly undeveloped primarily because the City of Sacramento has been committed to the implementation of the Natomas Basin Habitat Conservation Plan (NBHCP) for over 25 years while prioritizing infill development.

The DEIR comments presented in this letter address multiple topical areas. The following provides a brief listing of significant comment topic points that are later detailed further in this letter along with additional comments:

• Prior NOP Comments Not Addressed – City staﬀ submitted comments in response to the Notice of Preparation (NOP) for the UWSP . These comments provided input on the scope of the EIR as requested by the County. However, the UWSP DEIR analysis does not properly address the issues raised in our NOP comment letter dated November 20, 2020. This letter documents the areas that are deﬁcient in the DEIR.

• NBHCP Conﬂict & Viability – The UWSP is in direct conﬂict with the conservation strategy of the adopted NBHCP and Incidental Take Permits (ITPs) issued by the U.S. Fish and Wildlife Service (FWS) and California Department of Fish and Wildlife (CDFW) to the City of Sacramento. Speciﬁcally, the ITPs limit urban development in the “Basin” to 17,500 acres which is the total combined authorized development of the City of Sacramento, Sutter County and Metro Air Park. The limitation of 17,500 acres pertains to the “Basin” for the approved conservation strategy to be successfully completed. If Sacramento County approves any urbanization beyond the 17,500 acres authorized by the wildlife resources agencies doing so would be in direct violation of the existing ITPs that the wildlife resource agencies enforce. Sacramento County may recall being asked on to join the City of Sacramento and Sutter County to participate in the NBHCP (see Attachment A letter dated 11/28/2000). If Sacramento County is considering allowing further urbanization of the Basin that was not contemplated by the NBHCP how will the County provide assurances to the NBHCP signatory parties that the conservation strategy can still be successfully completed especially without the County’s HCP participation?

The following provides a partial listing of the issues that City staﬀ has determined conﬂict with the NBHCP:
o Proposed UWSP directly impacts the protected one-mile Swainson’s Hawk buﬀer zone approved by the wildlife resource agencies.
o Proposed UWSP would allow development of 1,532 acres of land that currently is rural agricultural lands beneﬁcial to the NHBCP and that could potentially be acquired in the future for habitat lands.

3 o Proposed UWSP would decrease the remaining open space lands in Natomas Basin which directly impacts the viability of the NBHCP by jeopardizing the successful completion of the NBHCP and placing urbanization near protected areas such as Fisherman’s Lake and existing Conservancy owned HCP mitigation lands.
o Future development of 1,532 acres of UWSP would place a greater burden on the existing planned growth authorized by the NBHCP which in turn will most likely cause HCP fee payers increased HCP fee rates and the inability to secure mitigation lands that meet all of the rigorous HCP mitigation land criteria.
o An Amendment to the NBHCP and obligations of the issued ITPs would be needed for any development to occur within the one-mile SWHZ and an in-depth eﬀects analysis in relation to the existing adopted NBHCP conservation strategy including future viability to meet all requirements of the NBHCP considering the loss of 1,532 acres due to UWSP and cumulative impacts associated with the proposed Grandpark Speciﬁc Plan (approximately 5,400 acres) in process with the County. The County is essentially considering allowing roughly 7,000 acres of land located in the unincorporated Sacramento County portion of the Natomas Basin to be removed from beneﬁting and contribution to the completion of the NBHCP conservation strategy.
o Biological – the Draft EIR concludes that with mitigation the UWSP biological impacts can be mitigated to a less than signiﬁcant level. City staﬀ disagrees with this conclusion.

• NBHCP Participation – If the County intends to allow urbanization beyond its Urban Services Boundary (USB) and Urban Policy Boundary (UPB) why would the County not join the NBHCP as the City of Sacramento and Sutter County have done? Sacramento County may recall being asked to participate in the NBHCP (see Attachment A letter dated 11/28/2000). If Sacramento County is considering allowing further urbanization of the Basin that was not contemplated by the NBHCP how will the County provide assurances to the NBHCP signatory parties that the conservation strategy can still be successfully completed especially without the County’s HCP participation? This has been an issue and concern expressed for over 25 years and to date has not been resolved.

• Water – During the County’s preparation of the Draft EIR, the City in compliance with State law provided a water supply assessment as requested by the County.

The water supply assessment is not an agreement nor commitment by the City to provide water for the future development of UWSP . The City has not entered into any agreement to provide water for the UWSP development. The Draft EIR incorrectly assumes and seems to have pre-determined that the City would provide water to UWSP per an agreement to do so with Sacramento County

4 Water Agency (SCWA). Page 2-24 of Section 2 Project Description of the UWSP Draft EIR states the following:

“WATER
The City of Sacramento through an agreement with the SCWA would provide water service to land uses allowed under the proposed UWSP. The City of Sacramento obtains most of its water supply from surface water in the American and Sacramento rivers, while groundwater obtained from the North American and South American subbasins of the Sacramento Valley Groundwater Basin provides the remainder.

As discussed above, the proposed UWSP would require SCWA annexation.

The DEIR conﬂicts with the City’s 2040 General Plan policy that pertains to provisions of City services to new development in unincorporated areas. The speciﬁc policy is presented below:

“LUP-1.4 City Services Prior to Annexation. Prior to the provisions of City services to new development in unincorporated areas, the City shall require that the unincorporated properties be annexed into the City.

Alternatively, the City may provide utility service to properties in advance of annexation only if the annexation process has been initiated and the landowner and City have executed a conditional agreement for services that stipulates minimum standards for the development of roads and urban infrastructure and criteria and conditions for annexation into the City.”

The Draft EIR page 14-29 lists future Service District Annexation requests to the Sacramento Local Agency Formation Commission (LAFCo). City staff opposes any filing of Service District Annexation requests including for example the listed annexation to Sacramento County Water Agency (SCWA) until to the satisfaction of the City of Sacramento pending concerns and issues are resolved such as water supply/service, Natomas Basin Habitat Conservation Plan conflicts, and provision of public services such as police and fire protection.

• Transportation – The UWSP has signiﬁcant implications to the transportation network and facilities located with the City of Sacramento in addition to the nearby freeways and Garden Highway. These concerns are documented in further detail in this letter.

5 • Public Services – The Draft EIR does not adequately address the impacts of the UWSP on existing public services (police, ﬁre, parks) nor details how these services would be provided considering the lack of current County services in the area due to the existing rural nature and that the UWSP is geographically removed from proximity to nearby County services.

ADDITIONAL DETAILED COMMENTS:

The City's comments below respond specifically to the information presented and analysis provided in the DEIR. The Planning Division of the Community Development Department presents the comments below as a single letter representing multiple City departments.

Memorandum of Understanding between City & County

On December 10, 2002, the City & County entered into a Memorandum of Understanding (MOU) (City Resolution 2002-830 and County Resolution 2002-1566) regarding Principles of Land Use and Revenue Sharing for the Natomas Area. The MOU (Attachment B) specifically calls for any future urbanization efforts in the Natomas Joint Vision Area (NJVA) to be processed through the City, with the County remaining a steward of agricultural lands and open spaces.

The DEIR inadequately addresses the implications of this MOU, particularly the agreement that future urbanization efforts in the NJVA would be processed through the City, with the County remaining a steward of agricultural lands and open spaces.

Furthermore, the EIR does not acknowledge or analyze the City's intent to designate the Natomas Basin Study Area, which includes the project area, as an Area of Concern. The City's General Plan policy LUP-A.1 explicitly states the City's near-term goal (2024-2029) to work with LAFCo on this designation, which would give the City "greater influence on land use decisions and other governmental actions" in the area.

City staff does not support the proposed County General Plan Amendment for text amendments to align County policies in various General Plan Elements regarding development in the Natomas Joint Vision Area. There has been no coordination with City staff regarding proposed text amendments to the County’s General Plan that are relative to potential future development in the Natomas Joint Vision Area. Since this specifically pertains to potential development in Natomas Basin which the City has designated as an Area of Concern per the City’s 2040 General Plan and located within our designated Natomas Basin Study Area it would seem that the County would provide some coordination with the City prior to moving forward with changes that pertain to a subject that has been of interest to the City for more than 25 years.

6 Economic Impacts

Our concerns about the concentration of commercial development along the westerly extension of El Camino Avenue remain unaddressed. The DEIR does not sufficiently analyze the potential regional nature of this retail development and its implications for traffic patterns and associated environmental impacts. It fails to address the potential secondary physical and economic impacts within the City that may result from locating retail, hospitality, and other commercial uses adjacent to the City boundary.

The 2002 City/County MOU recognized mutual economic interests in the future of NJVA and outlined a revenue sharing framework. The DEIR does not address how the UWSP aligns with or impacts this framework. There is insufficient discussion of how the County plans to address these economic issues, especially considering the entitlements being sought by project proponents.

Growth Inducement

While the DEIR addresses some concerns raised in our NOP comment, particularly regarding the extension of urban infrastructure and potential growth-inducing effects, certain aspects of our request for analysis have not been adequately addressed, especially as they pertain to impacts on the City of Sacramento.

The DEIR acknowledges that the project would eliminate obstacles to growth by extending the Urban Services Boundary and Urban Policy Area. However, it does not sufficiently analyze the project's consistency with long-range plans, particularly its inclusion or absence from the Region's Sustainable Communities Strategy. This omission is significant, as it relates directly to the broader regional planning context and potential cumulative impacts on the City of Sacramento.

Furthermore, the DEIR lacks a comprehensive analysis of the project's growth-inducing effects on the City of Sacramento. While it mentions consistency with Sacramento County General Plan Policy LU-120, it fails to provide a detailed, quantitative examination of how the project's infrastructure extensions might stimulate additional development within our City limits. This analysis should include estimates of the scale, type, and timing of potential new development, as well as a thorough assessment of the resulting environmental impacts. The DEIR's current list of general impact categories is insufficient without a location-specific analysis of how these effects would manifest within Sacramento.

We request that these areas of analysis be expanded to fully address the growth- inducing impacts of the proposed project on the City of Sacramento, as originally outlined and requested in our NOP comment.

7 Habitat Conservation Plan

Hydrological connectivity

Our NOP comment requested an analysis of hydrological connectivity to existing preserves in Natomas Basin. The DEIR states that the UWSP "is not expected to significantly affect the connectivity of aquatic habitat for giant garter snake" and "would not affect the delivery of water to existing reserves." However, this brief statement lacks the detailed analysis we sought. We request a more thorough examination of potential impacts on existing preserves, particularly the adjacent Cummings Reserve.

Effects on land inventory and mitigation prices

We specifically asked for an analysis of the effects of reducing land available for mitigation while increasing demand, potentially driving up mitigation prices for existing permit holders. The DEIR does not directly address this issue. While it states that mitigation lands "would not unnecessarily directly compete with TNBC for habitat mitigation opportunities," this assertion lacks supporting evidence. We request a detailed analysis of how the UWSP might affect land availability and mitigation costs for existing NBHCP and Metro Air Park (MAP) HCP parties.

Land availability for HCP parties

We asked how and where HCP parties with authorized development would find land for mitigation given the cumulative impacts of proposed developments in the Natomas Basin Area. The DEIR's treatment of this issue is insufficient, stating only that mitigation measures BR-3 & BR-7b are "not expected to interfere with the ability of TNBC to satisfy its mitigation responsibilities." We request a more comprehensive analysis of cumulative impacts on mitigation land availability. Based on our direct experience implementing the NBHCP for over 25 years, we question if there is enough suitable land that would remain available to The Natomas Basin Conservancy to mitigate the already approved authorized development of 17,500 acres granted to the City, Sutter County and Metro Air Park if Sacramento County allows the UWSP and Grandpark Specific Plan projects to be approved. We request that Sacramento County evaluate the HCP mitigation land criteria requirements, total mitigation including size of habitat reserves that are required for completion of the HCP conservation strategy. The UWSP DEIR focuses on the impacts and mitigation of the UWSP project itself but does not address the existing HCP acreage requirements that must be completed in the Basin.

8 detailed accounting and graphics demonstrating of how HCP total acreage requirements could be accomplished with the potential approval and implementation of the UWSP and Grandpark Specific Plan projects. This information and data should also be included as part of the proposed Final EIR when it becomes available.

Consistency with NBHCP Conservation Strategies

We request further clarification on the adequacy of the proposed 250-foot open space buffer between planned development and the Cummings Reserve, compared to the NBHCP's 800-foot setback requirement. The DEIR notes that exceptions to the 800-foot setback have been made in the past. While this explanation is helpful, we request further analysis on whether this 250-foot buffer is sufficient to protect the Cummings Reserve from potential edge effects of urban development.

We urge the County to provide a more robust analysis of these issues in the Final EIR to ensure the UWSP does not compromise the NBHCP's conservation goals or the ability of existing HCP parties to meet their mitigation obligations.

One-Mile Buffer Swainson’s Hawk Zone

The City of Sacramento must express its opposition to the proposed Upper Westside Specific Plan (UWSP) due to its direct conflict with the Natomas Basin Habitat Conservation Plan (NBHCP).

The City of Sacramento, as a signatory to the NBHCP, has a legal obligation to ensure the continued integrity of this regional conservation strategy. Our analysis of the UWSP reveals that significant portions of the proposed development would encroach into the Swainson's Hawk Zone - a critical one-mile-wide buffer adjacent to the Sacramento River that was explicitly established in the NBHCP to protect essential Swainson's Hawk habitat and foraging areas. The NBHCP categorically prohibits development within this zone, with only a strictly limited exception of 252 acres granted to the City of Sacramento.

The project's inadequate agricultural buffer of 534 acres, ranging from merely 700 to 2,700 feet in width, is insufficient compared to the one mile (5,280 feet) protective

9 buffer mandated by the NBHCP. This reduction in buffer width would severely compromise a core conservation measure that both wildlife agencies have previously determined to be essential for the protection of Swainson's Hawk habitat.

The NBHCP is explicit: development beyond the permitted activities necessitates a comprehensive reevaluation of the Plan, a new effects analysis, potential amendments to the Plan and/or permits, and a separate conservation strategy. For the wildlife agencies to issue permits for this project as currently designed would require the completion of all these actions - none of which have been undertaken.

We are particularly alarmed that approval of development within the Swainson's Hawk Zone would directly threaten the biological effectiveness of the NBHCP's conservation strategy, which both the City of Sacramento and Sutter County depend upon for our incidental take permits. The one-mile buffer zone was established through rigorous biological analysis and stands as an indispensable component of the plan's mitigation strategy for impacts to Swainson's Hawk.

The County must either:

• Substantially redesign the project to eliminate all development within the one- mile Swainson's Hawk Zone buﬀer; or

• Undertake the mandatory comprehensive reevaluation of the NBHCP required when proposing development within this zone, including preparation of a new eﬀects analysis and development of a separate conservation strategy that deﬁnitively ensures no net loss of the eﬀectiveness of this critical conservation measure. This reevaluation must be conducted under the strict oversight of USFWS and CDFW to ensure absolute compliance with their obligations as Permitters under the NBHCP .

• For any County approval of development that directly disturbs the one-mile Swainson’s Hawk Zone (SWZ), we request that the County ﬁrst initiate an amendment to the NBHCP with the wildlife resource agencies to modify the requirements and obligations placed on the City of Sacramento and Sutter County that pertain to the one-mile SWZ. Any action by Sacramento County to approve and allow development within the SWZ is in direct conﬂict with the adopted NBHCP and enforceable requirements by the wildlife resource agencies including for example, the Incidental Take Permits issued by U.S. Fish and Wildlife Services (FWS) and the California Department of Fish and Wildlife (CDFW) to the City of Sacramento and Sutter County.

10 Agriculture

The Draft EIR falls short in addressing crucial concerns regarding the project's impact on agricultural resources and the Natomas Basin Habitat Conservation Plan (NBHCP). While the EIR quantifies the conversion of approximately 1,372 acres of farmland within the project area, it fails to provide a comprehensive analysis of how this loss might affect the NBHCP's requirement to maintain 4,375 acres in rice cultivation for Giant Garter Snake habitat. The EIR should evaluate not only the direct loss of farmland but also the potential indirect effect of increased development pressure on remaining agricultural lands in the Natomas Basin, which could make it more challenging to maintain the required acreage of rice cultivation.

Transportation

Roadway Widening and City Responsibility

The DEIR continues to rely on fair share contributions toward roadway widening projects within City limits without adequately addressing our concerns about implementation responsibility. For instance, Mitigation Measure TR-3b still assumes City involvement in implementing improvements at I-5 on-ramps, despite our previous statement that the City should not be assumed to have matching funds. The DEIR does not propose alternative mitigation approaches that avoid placing implementation responsibility on the City, nor does it explain how these projects would be fully funded and executed given the City's financial constraints.

TR-3a and TR-3b Impacts & Mitigations on Page ES-119 & ES-120: The City of Sacramento looks forward to working collaboratively with the County on the required I- 80 West El Camino Avenue interchange improvements being triggered by the project’s development. As specified in the Upper Westside Specific Plan Public Facilities Financing Plan on page 23, the traffic analysis estimated that approximately 90 percent of trips caused by new development in the County using this interchange would be caused by development in the UWSP. The City looks forward to seeing the UWSP project fulfills the required improvements and phasing to ensure the ultimate improvements are constructed when triggered by the UWSP project.

Conflict with City Transportation Policies

Our NOP comments highlighted the City's current focus on reducing lanes on City roadways to align with our Climate Change goals. However, the DEIR does not acknowledge or analyze how the proposed roadway widenings, such as those in Mitigation Measure TR-3a, align with or conflict with this policy direction. We request that the Final EIR include an analysis of how the proposed transportation improvements align with the City's current transportation policies and goals.

11 Regional Growth and VMT Impacts

The DEIR's VMT analysis remains narrowly focused on project-level impacts and does not address our request to examine how the UWSP may redistribute growth away from the City or impact the City's VMT relative to the regional average. We continue to be concerned about potential impacts on the City's growth patterns and overall regional VMT efficiency. We request that the Final EIR include modeling scenarios that evaluate these broader impacts as originally suggested in our NOP comments.

Ongoing Technical Coordination

While the DEIR mentions some collaboration with the City, it does not outline a specific process for ongoing coordination throughout project development and implementation as we had requested. Given the project's potential impacts on City infrastructure and services, we believe a more detailed plan for continued technical coordination is necessary.

Water

In our NOP comments, we identified three potential alternatives for providing domestic water to serve the proposed UWSP area. While the DEIR focuses on Alternative 3 - utilizing City of Sacramento water rights and infrastructure - it does not provide a comprehensive analysis or clear dismissal of Alternatives 1 and 2 involving Natomas Central Mutual Water Company (NCMWC) water rights. We request that the Final EIR include a thorough evaluation of all three alternatives to ensure a complete understanding of the project's water supply and water retailer options.

Furthermore, our NOP comments requested specific details regarding the water delivery system engineering, including the size of mains, distribution, volume, future capacity, system pressurization, storage capacity, and measures to protect the water supply and prevent contamination of the City's existing system. While the DEIR provides some information about the proposed water delivery system, including a water storage tank and transmission mains, it lacks the level of detail we requested. We urge the County to include more comprehensive information on these aspects in the Final EIR to fully assess the potential environmental impacts and ensure the adequacy of the proposed water infrastructure.

Sewer System

The City of Sacramento notes the EIR's discussion of new wastewater infrastructure needed to serve the Upper Westside Specific Plan area, including the proposed sewer pump station and force main. However, we note that our previous comment requesting

12 analysis of impacts to the Sacramento Regional County Sewer Interceptor has not been adequately addressed. Specifically, the EIR lacks a comprehensive evaluation of the interceptor system's capacity downstream of the New Natomas Pump Station to accommodate additional flows from this project in combination with buildout of the existing Natomas area and other proposed development in the Natomas Joint Vision area. We remain concerned about the potential cumulative impacts on this critical piece of regional infrastructure and whether it has sufficient capacity to serve all these areas without requiring significant upgrades. The City requests that the EIR be revised to include a thorough analysis of existing and projected flows in the interceptor system, an assessment of its available capacity at key points along its alignment, and an evaluation of whether system upgrades may be necessary to handle the increased wastewater volumes. If upgrades to the interceptor are required, the potential environmental impacts of such improvements should also be discussed.

Fire Protection

The City of Sacramento notes the acknowledgment in the DEIR that the City's Fire Department currently provides and will continue to provide fire protection and emergency medical services to the Upper Westside Specific Plan (UWSP) area under contract with the Natomas Fire Protection District. We also note the inclusion of a site for a new fire station within the proposed plan. However, we find that the DEIR does not adequately address several key concerns raised in our NOP comments.

The DEIR lacks a comprehensive analysis of fire protection services and facilities as requested. While it provides a basic assessment of increased demand and the need for a new station, it falls short of the in-depth analysis needed for a project of this scale. We request a more detailed evaluation of current service levels, response times, equipment needs, and long-term planning for fire protection services. Furthermore, the DEIR does not sufficiently address how the project proponent will mitigate service demand impacts and maintain current levels of service throughout the project's implementation. We request more specific information on phasing, funding mechanisms, and interim measures to ensure consistent service levels during development.

Given the City's extensive experience in providing municipal services, including over 100 years of fire protection services, we reiterate our position that the City is best equipped to provide a full range of municipal services to the UWSP area. We request that the EIR include a more robust discussion of the City's role in long-term service provision and planning for the area.

Law Enforcement

The DEIR fails to adequately address the concerns raised in our NOP comment regarding potential impacts to City of Sacramento police protection services. The DEIR focuses

13 exclusively on Sacramento County Sheriff's Office services without acknowledging or evaluating potential impacts to the City of Sacramento Police Department (SPD). This oversight is particularly concerning given the project's unique geographical context - adjacent to the City but isolated from developed County areas - which could potentially strain City services.

Furthermore, the DEIR does not provide the requested evaluation of how and when law enforcement services and facilities will be provided to ensure no impacts to the City of Sacramento. While plans for a new County sheriff's substation are discussed, this does not address the potential cross-jurisdictional impacts or need for coordinated services with the City.

The California Highway Patrol's role is only briefly mentioned, without fully addressing its responsibilities for state highways, state-owned buildings, and state property within the City, as noted in our NOP comment.

Given the project's location and potential to affect multiple jurisdictions, we reiterate our request for a more comprehensive analysis that considers impacts to both County and City services, as well as inter-agency coordination strategies. This analysis should evaluate how the proposed development's law enforcement needs will be met without adversely impacting existing City services or response times.

Schools

We appreciate that the DEIR identifies the existing schools that would serve different portions of the UWSP area, including Witter Ranch Elementary School, Two Rivers Elementary School, Natomas Middle School, Inderkum High School, and Natomas High School. This information adequately addresses which schools would serve residents both inside and outside the specific development plan areas within the UWSP.

However, the DEIR does not fully address our question regarding which schools would serve the area while the proposed schools are being built. While Table PS-2 provides helpful enrollment and capacity data for existing schools, the DEIR lacks a clear explanation of how school services will be provided during the interim period before new schools are operational. We request that the Final EIR include a phasing plan showing when the proposed schools would be constructed relative to residential development, an explicit discussion of which existing schools would absorb students during the construction phases, and an analysis of whether those existing schools have sufficient capacity to handle temporary increases in enrollment. This information is crucial for understanding the full impacts of the project on school services throughout its implementation.

14 Parks & Recreation Facilities

The Draft EIR for the UWSP analyzed the project’s impact on the existing setting for Parks and Recreation Facilities by considering whether an increase in use of public parks and recreation facilities resulting from the UWSP would cause the substantial physical deterioration of those facilities (e.g., damage to vegetation, accelerated wear on sports facilities and fields, or erosion along trails) or in the need for new or expanded facilities, the construction or operation of which would result in substantial adverse physical effects. This analysis further considers whether implementation of the proposed UWSP would diminish or otherwise adversely affect recreational opportunities and existing facilities within the UWSP area based on facility capacity.

Within a 1-mile radius of the UWSP area, there are approximately 20 parks, most of which are within the City of Sacramento and comprising a total of 160 acres of parklands. The closest parks to the UWSP area include River Otter Park, located directly adjacent to the southeastern edge of the UWSP area across Interstate 80, Peregrine Park, located directly adjacent to the eastern edge of the area, and San Juan Reservoir Park, located directly adjacent to the northwestern edge of the area. The North Natomas Regional Park, at 212 acres, located 1.6 miles northwest of the UWSP serves the entire region.

As stated in the DEIR, the proposed UWSP would facilitate development of up to 9,356 housing units and yield 25,460 residents. The Sacramento County 2030 General Plan, Policy PF-123 requires 5.0 acres of parkland per 1,000 residents. As a result, approximately 127.9 acres of parkland is required to serve the needs of the proposed UWSP. As there are no parks currently located directly within the UWSP area, the 160 acres of nearby parks previously described could be adversely affected by the increase of residents generated by the proposed UWSP. The areas surrounding the UWSP area, in which the existing parks are located, are developed, and contain existing residents that utilize these facilities. Therefore, there is a need for new parks to serve the UWSP area and to alleviate pressure which would occur to nearby parks from increased residential uses in this area.

To accommodate the increase in residents resulting from the proposed UWSP, the plan includes a “parks program,” which outlines the proposed parks and recreational facilities to be implemented in the UWSP area. The proposed UWSP parks program proposes a diverse mix of recreational amenities and public gathering spaces which are sized and distributed to serve the anticipated needs of the residents within the UWSP. A total of 146.6 acres of parks and amenities would be provided in the UWSP area, which accounts for 11 percent of the Development Area. Parks and amenities would include

76.5 of active parks and the 2.6-acre Town Center median park as well as the 15-acre Westside Canal, 34.1 acres of greenbelt space, a 10-acre urban farm, a 12.1-acre West Edge Buffer, and a 14.7-acre Basin Edge Parkways trail.

15 The UWSP concludes that these facilities would be sufficient to accommodate the 25,460 proposed residents and would meet the requirements for parkland under the Sacramento County 2030 General Plan. Therefore, no additional means would need to be utilized to meet any demands in the UWSP area for parks and recreation services.

Objectives for parks and recreation in the UWSP area would be met under the proposed plan, and the impact would be less than significant.

The proposed project’s “parks program” includes 76.5 – 79 acres of parkland which meets the minimum guidelines of 3 acres per 1,000 residents. The 76.5 acres of parkland are considered neighborhood/community serving parks, which will be programmed with active recreation uses. However, the DEIR analyzes the project at the minimum dedication requirement under the Quimby Act of 3 acres per 1,000 residents, less than the County’s (and City’s) policy requirement of 5 acres per 1,000. If the project were to dedicate neighborhood/community parkland at the County standard of 5 acres per 1,000 resident, the proposed project’s parkland dedication requirement would total approximately 128 acres of neighborhood/community serving parks.

The proposed project’s “parks program” supplements the 79 acres of parkland with an additional 86 acres of parkland. The 86 acres of parks and recreation facilities are identified has having permanent drainage facilities, a greenbelt without recreation amenities, urban farms that will likely be leased and operated by community based or non-profit organizations, agricultural buffers, and a median with a trail. These types of facilities do not take the pressure off adjacent neighborhood and community parks that do contain active recreation, which is in high demand in the City of Sacramento.

The proposed UWSP is located adjacent to communities of the City of Sacramento; South Natomas and North Natomas. Each community was established and planned to be well-served by neighborhood and community parks that are located within a 10- minute walk of almost all the residential areas. The proposed project’s gap of 51.5 acres that are not identified as neighborhood/community parkland will likely result in an adverse physical effect on the nearby parks within the two adjacent communities.

Additionally, the proposed 79 acres of parkland will likely be diminished or adversely affected at a quicker rate than industry standards. This would be a significant impact.

The City of Sacramento Youth, Parks, & Community Enrichment Department (YPCE) recommends the project reduce the impacts to existing City parks by adding, or converting, 51.5 acres of neighborhood/community serving parkland in order to meet the 5 acres per 1,000 resident standard. The proposed project should incorporate the City’s standards and guidelines for neighborhood and community parks, as adopted by the Parks Plan 2040, a subsequent project of the 2040 General Plan Master EIR. The existing parks within the adjacent communities are well-used, and it can be expected that the UWSP parks will be as well. Additional recommendations for the UWSP’s park program are to consider community input from residents within the adjacent communities. They want to see regular enhancements and to the parks, such as lighting,

16 restrooms, outdoor exercise equipment, an all-weather field, and an integrated bicycle network. Residents are also advocating for accessible parks for all ages, drought- tolerant landscaping, and the preservation of wildlife habitat.

The UWSP’s investment of over $143 million into the acquisition and development of parks, trails, and open space converts to approximately $1 million per acre with an annual estimated cost of $3.5 million to maintain each park facility. These costs exceed the City of Sacramento’s Park development impact fee credit limits set for turnkey parks, and the estimated annual maintenance costs currently funded by Community Facilities Districts and Landscape and Lighting Districts within North Natomas. The full development of the UWSP park program will likely result in amenities that are attractive to use, and likely a financial impact on Parks annual workplans to repair and replace in 20 years from development. The proposed project’s Public Facilities Finance Plan includes a fee for the provision of repair and replacement of facilities (e.g. parks, pump stations) as well as infrastructure after their useful life. The County may consider funding the long-term repair and replacement costs through a combination of the proposed infrastructure CFDs and through the new services CFD that will fund the share of urban services not paid for by property taxes. The City encourages the County to include an infrastructure CFD to fund long term repair and replacement costs of park facilities. Additionally, the utilities costs to maintain the 146.6 acres of parkland should also be included in the infrastructure CFD.

The conversion of 51.5 acres to neighborhood/community parkland, incorporation of the parks Plan 2040 standards and guidelines for park and facility development, incorporation of the 2040 General Plan park access policies for South and North Natomas, and funding for long term repair and replacement of facilities will reduce impacts to the existing parks within the adjacent communities and proposed parks within the UWSP.

Land Use Planning (City’s 2040 General Plan)

On February 27, 2024, the City of Sacramento adopted the new 2040 General Plan. The new General Plan identifies five Special Study Areas that are adjacent to existing City limits and are of interest to the City of Sacramento. Planning for the future of these unincorporated areas requires collaboration between the City and the County.

The proposed Upper Westside Specific Plan (UW SP) is located within the Natomas Basin Special Study Area which bears relation to the planning of the City of Sacramento. The City of Sacramento is projected to see significant growth by 2040 (69,000 new homes, and 76,000 new jobs), and with careful land use planning, new development can help make Sacramento a model of sustainable, equitable growth and community development.

17 Updating the 2040 General Plan was a major undertaking and a multi-year process in effort to develop a land use framework and policies which provide for strategic growth and change that seek to concentrate new growth within the existing City limits.

The City is concerned about how the UW SP could induce sprawl and redistribute growth away from the City especially if the proposed development does not comport with the City’s new land use standards and innovative policies.

The intent of the City’s General Plan land use vision is to promote greater integration of uses along the corridors and in centers to broaden the range of housing types in the City, support the vitality of local businesses, lay the foundation for high-frequency transit, and make it easier to provide electric vehicle charging infrastructure and also to get around without a car.

The building intensity standards are intended to provide more flexibility and innovation in building design. Minimum density standards apply in all areas where residential development is permitted and a primarily FAR-based system could incentivize the design and construction of smaller units, potentially resulting in units that are more affordable by design.

For your reference below is a link to the City of Sacramento’s new 2040 General Plan.

Building intensity standards are shown on Maps LUP-6, LUP-7, LUP-8, and Figure LUP-

5. https://www.Cityofsacramento.gov/content/dam/portal/cdd/Planning/General- Plan/2040-General-Plan/Adopted%202040%20General%20Plan_20240227.pdf

Additionally, below two key innovative policies that support our emission reduction and sustainability goals in the 2040 General Plan. Policy LUP-4.13 requires new or expanded gas stations provide EV charging infrastructure. Policy LUP-4.14 eliminates vehicle parking minimums Citywide.

• LUP-4.13 Future-Ready Gas Stations.

The City shall prohibit the establishment of new gas stations or the expansion of new fossil fuel infrastructure at existing gas stations unless the project proponent provides 50kW or greater Direct Current Fast Charger (DCFC) electric vehicle charging stations on site at a ratio of at least 1 new charging station per 1 new gas fuel nozzle.

• LUP-4.14 Elimination of Vehicle Parking Minimums.

The City shall not require new or existing development to provide oﬀ-street vehicle parking spaces.

18 Conclusion

As this project progresses through planning, environmental review, and engineering, we request the County’s continued coordination and that we receive all project public notifications including those for any future public meetings and hearings. If you have follow-up questions or seek clarifications on any of the above issues, please contact Cheryle Hodge at [email protected] o
r 808- 5971.

Sincerely,

Cheryle Hodge
New Growth Manager, Community Development Department

cc: Michael Jasso, Assistant City Manager, City of Sacramento Tom Pace, Director, Community Development Dept., City of Sacramento Greg Sandlund, Planning Director, Community Development Dept.

Matt Eierman, Director, Department of Public Works
Lucinda Willcox, Assistant Director, Dept. of Public Works, Jennifer Donlon Wyant, Transportation Planning Manager, Dept. of Public Works Pravani Vandeyar, Director, Department of Utilities
Brett Ewart, Supervising Engineer, Department of Utilities Pelle Clarke, Senior Engineer, Department of Public Works Jackie Beecham, Director, Youth, Parks & Community Enrichment Dept.

Shannon Brown, Assistant Director, Youth, Parks & Community Enrichment Dept.

Chris Costamagna, Fire Chief, Sacramento Fire Department King Tunson, Program Specialist, Sacramento Fire Department Kathy Lester, Police Chief, Sacramento Police Department Eddie Macaulay, Lieutenant, Sacramento Police Department Tom Bufford, Principal Planner, Environmental Planning Services Scott Johnson, Senior Planner, Environmental Planning Services Remi Mendoza, Senior Planner, Long Range Planning

EXHIBIT A

SACRAMENTO RIVER
INTERSTATE - 80
INTERSTATE - 5

FISHERMAN'S
LAKE/
SLOUGH

ARENABOUL

WEST EL CAMINO AVENUE
EVARD

NATOMASCROSSINGDRIVE(FUTURE)

GARDEN HIGHWAY

HIGHWAYGARDEN

DUCKHORNBOULEVARDSAN JUAN ROAD

SACRAMENTO COUNTYYOLO COUNTY

NATOMAS WESTSIDE PATH

WITTERCANAL

RADIO ROAD

SAN JUAN ROAD

EL CENTRO ROAD
BRYTE BEND ROADSTREET 7

FARM ROAD
STREET 1

STREET F
STREET 8STREET 10
CMU
VLDRVLDR33.6 ± AC62.7 ± AC

6.4 ± AC
VLDR70.4 ± AC
OS-AG24.5 ± AC
AG117.2 ± ACLDR10.9 ± ACLMDR7.8 ± ACMDR4.6 ± AC
HS64.2 ± AC
LDR41.7 ± ACUF10.0 ± AC
K-816.0 ± AC
P4.5 ± AC
LDR25.7 ± ACLDR15.1 ± ACK-816.0 ± ACLDR13.8 ± AC
EHC41.8 ± AC
EHC11.1 ± AC
LDR31.2 ± ACLMDR21.5 ± AC
P18.4 ± AC
LDR17.0 ± ACLMDR22.2 ± AC
P4.8 ± AC
LDR3.5 ±
LDR11.9 ± ACLDR11.1 ± ACP4.4 ± AC
LMDR10.8 ± ACLMDR11.2 ± AC
LDR12.8 ± ACLDR11.8 ± ACLMDR12.8 ± ACLMDR12.5 ± AC
MDR4.2 ± ACHDR4.1 ± ACMDR4.1 ± ACHDR4.3 ± ACVHDR3.9 ± ACVHDR3.8 ± ACCMU4.2 ± ACCMU4.4 ± ACVHDR3.8 ± AC CMU4.1 ± ACCMU4.2 ± ACVHDR3.7 ± ACVHDR3.7 ± ACMDR3.9 ± ACHDR3.8 ± AC LDR24.3 ± ACLDR16.4 ± AC
CMU4.1 ± ACVHDR3.7 ± ACHDR3.9 ± ACMDR4.0 ± ACHDR3.3 ± ACCMU3.7 ± ACCMU4.2 ± ACCMU3.8 ± ACHDR3.4 ± AC MDR4.8 ± AC
MDR6.1 ± ACHDR6.9 ± AC
HDR6.7 ± ACK-817.0 ± AC
P17.4 ± AC
P7.4 ± AC
LDR10.1 ± AC
LDR29.9 ± AC
LDR26.8 ± AC
LDR18.8 ± ACOS35.1 ± ACOS35.6 ± AC

EL CENTRO ROAD
G3.0 ± AC

4.2± ACOS-AG

11.5 ± ACOS

4.5 ± ACG1.3± ACG1.3± ACG1.7 ± ACG

2.9 ± ACG 2.3 ± ACOS4.1 ± ACG

EL CENTRO ROAD

BRYTE BEND ROAD

0.5 ± ACP 0.6 ± ACP0.5 ± ACP0.5 ± ACP3.5 ± ACOS-C4.1 ± ACOS-C3.7 ± ACOS-C3.7 ± ACOS-CSTREET I

ORCHARD LANE
LDR7.7 ± AC
CC11.0 ± AC

0.4 ± ACP
STREET 2
AG130.1 ± AC

4.0 ± ACMDR4.0 ± ACMDR

2.0 ± ACMDR2.0 ± ACMDR2.0 ± ACMDR2.0 ± ACMDR

4.4 ± AC4.4 ± AC0.9 ± ACG

4.3 ± AC4.3 ± ACCMU

STREET G

1.4 ± ACG 6.0 ± ACG
STREET ASTREET BSTREET CSTREET 3STREET 4
STREET 5STREET 6
1890' ±
1500' ± 950' ±
700' ±
CMU25.5 ± AC

1.6 ± ACCMU
AG113.2 ± AC
2800' ±
250' ±
250' ±
250' ±
LDR18.3 ± AC
STREET 70.2 ± ACGLDR12.5 ± AC1.3 ± ACG 0.2 ± ACG2.0 ± AC1.4 ± ACG5.0 MILESGOLDEN1CENTERTO AR63.9 ± AC
OS20.0 ± AC
LMDR19.4 ± ACLMDR9.0 ± AC
1 2
3 LMDR7.7 ± ACLDR10.8 ± ACP7.5 ± AC
OS27.6 ± AC

1.1 ± ACOS4.4 ± ACOS

3.1 ± ACOS-AG
MDR4.6 ± ACSTREET 12

STREET H

WEST EL CAMINOAVENUE
LDR
OS

OSSTREET DSTREET E

ELECTRICAL
ELECTRIC SUBSTATION #2

STATION SITESEWER PUMP
*PROPOSEDSUBSTATION #1

1.7 ± AC

1.3 ± AC
P4.0 ± AC

7.4 ± ACOS

3.2 ± AC
LDR5.5 ± AC0.6 ± ACAR22.2 ± AC
P5.1 ± AC
GMDR9.6 ± ACCMU

STREET F
FARM ROAD*POTENTIAL SHERIFFSUBSTATION
CMUCMU

FIRE STATION

2.9 ± ACP

WATER TANK STORAGE

2.0 ± ACOS

0.2 ± ACP

4.8± ACOS-AG
AG53.8 ± ACSTREET 9
STREET12
OS13.7 ± AC
ACG

SOUTH BASIN

WEST BASINEAST BASIN

NORTH BASINBASINNORTH

1.3 ± ACG

3.1 ± ACOS

1.1 ± ACOS

VLDRLDRLMDRMDRHDRVHDREHCS
AR
G/UFP
OS-CLC
CMU

OS-AGAG
OS

PRELIMINARY LAND USE PLAN - MISSING MIDDLE HOUSING INCENTIVEUPPER WESTSIDE PRELIMINARY LAND USE PLAN - UPPER WESTSIDE INFILLBUILDING RELATIONSHIPS ONE PROJECT AT A TIME3301 C St, Bldg. 100-BTel 916.341.7760Fax 916.341.7767Sacramento, CA 958160NORTH60012002400

LAND USE DESIGNATION
NET ACREAGE BASED ON PRELIMINARY LAND USE PLAN GENERATED IN GIS/AUTOCAD BY WOOD RODGERS. THIS PLAN IS SUBJECT TO CHANGE. ARTERIALS, COLLECTORS AND PRIMARYRESIDENTIAL STREETS, AND LANDSCAPE CORRIDORS AS SHOWN ON MAP ARE NETTED OUT.ESTIMATED POPULATION CALCULATION UTILIZING 3.0 PERSONS PER HOUSEHOLD (pph) FOR SINGLE-FAMILY AND 2.5 pph FOR MULTI-FAMILY (HDR AND HIGHER), RESULTING IN 25,578± PEOPLE [(4,981 DU x 2.5 pph)+(4,375 DU x 3.0 pph)]=25,578 POPULATION]. THIS IS A PRELIMINARY ESTIMATE AND SUBJECT TO CHANGE.THE ALLOCATED SQUARE FOOTAGE (SF) IS IN ADDITION TO EXISTING COMMERCIAL LAND USES.AGRICULTURAL RESIDENTIAL (AR), AGRICULTURAL CROPLAND (AG), OPEN SPACE (OS) BUFFER TO THE NORTH AND WEST, AND MAJOR ROADS B AREAS ARE NOT INCLUDED INPROPOSED 1,524-ACRE DEVELOPMENT AREA OR THE UPA/USB EXPANSION REQUEST. THE 542-ACRE "AG-BUFFER" AREA WILL REMAIN AS IS AND NO UNITS ARE ALLOCATED.THE 1.6-ACRE CMU SITE LOCATED SOUTHWEST OF THE TOWN CENTER IS DESIGNATED FOR A FIRE STATION AND THEREFORE WAS NOT ALLOCATED RESIDENTIAL UNITS OR COMMERCIAL SF.THIS VERSION OF THE PRELIMINARY LAND USE PLAN ACCOUNTS FOR THE MISSING MIDDLE DENSITY BONUS. UP TO 300 M.M.D.B. UNITS MAY BE ADDED TO LDR, LMDR, AND MDR PARCELSAS DUPLEX, TRIPLEX OR FOURPLEX UNITS TO BRING THE TOTAL BACK TO 9,356 UNITS.BLUE CROSS-HATCH IN OPEN SPACE INDICATES THE LOCATION OF BASINS WHERE WATER SURFACE INCREASES DURING STORMWATER EVENTS.

COUNTY OF SACRAMENTO, CALIFORNIAJANUARY 15, 2024
(1)(2)NOTES

VICINITY MAP

3.4 MILESTO DOWNTOWN

5.0-MILEBIKE RIDETO DOWNTOWN

TO SMF AIRPORT
DOWNTOWNI-5I-5
I-80
NORTHN.T.S.

UPPER WESTSIDE TO DOWNTOWN TRAIL
SOURCE: AFAR
I-5

5.0 MILES TO DOWNTOWN
(3)(4)(5)
(3)(3) (5)
(4)(4)
(4)
(6)
(6)(6)(6)
(6)
(7)
(7)

26 - Responses
Upper Westside Specific Plan 26-108 PLNP2018-00284
LETTER 12
City of Sacramento Department of Community Development, local government entity, written correspondence; dated October 28, 2024.

COMMENT 12-1
• Prior NOP Comments Not Addressed – City staff submitted comments in response to the Notice of Preparation (NOP) for the UWSP. These comments provided input on the scope of the EIR as requested by the County. However, the UWSP DEIR analysis does not properly address the issues raised in our NOP comment letter dated November 20, 2020. This letter documents the areas that are deficient in the DEIR.

RESPONSE 12-1
Please see Responses 12-2 to 12-36 below.

COMMENT 12-2
• NBHCP Conflict & Viability – The UWSP is in direct conﬂict with the conservation strategy of the adopted NBHCP and Incidental Take Permits (ITPs) issued by the U.S. Fish and Wildlife Service (FWS) and California Department of Fish and Wildlife (CDFW) to the City of Sacramento. Speciﬁcally, the ITPs limit urban development in the “Basin” to 17,500 acres which is the total combined authorized development of the City of Sacramento, Sutter County and Metro Air Park. The limitation of 17,500 acres pertains to the “Basin” for the approved conservation strategy to be successfully completed. If Sacramento County approves any urbanization beyond the 17,500 acres authorized by the wildlife resources agencies doing so would be in direct violation of the existing ITPs that the wildlife resource agencies enforce.

Sacramento County may recall being asked on to join the City of Sacramento and Sutter County to participate in the NBHCP (see Attachment A letter dated 11/28/2000). If Sacramento County is considering allowing further urbanization of the Basin that was not contemplated by the NBHCP how will the County provide assurances to the NBHCP signatory parties that the conservation strategy can still be successfully completed especially without the County’s HCP participation? RESPONSE 12-2
The approval of the proposed UWSP in unincorporated Sacramento County would not directly conflict with the NBHCP and related ITPs because the County is not a Permittee under the NBHCP and those ITPs do not cover development activities proposed in unincorporated Sacramento County. This is clearly articulated in the Draft EIR, Chapter 7, Biological Resources, pages 7-36 and 7-37, which state, in part:

While the UWSP area is in the Natomas Basin, the County is not a participant in either the NBHCP or the MAP HCP. Therefore, the applicant (and any future applicants for buildout of the UWSP area) is not eligible for the take coverage

COUNTY RESPONSES TO CITY COMMENTS
26 - Responses
Upper Westside Specific Plan 26-109 PLNP2018-00284
granted by USFWS and CDFW under the NBHCP or MAP HCP. The proposed UWSP is also outside of the planned development areas of the NBHCP and MAP HCP and potential impacts resulting from development allowed under the proposed UWSP were not considered in the NBHCP.

Draft EIR Impact BR-14 provides a thorough analysis of the relationship of the proposed UWSP to the NBHCP. Please see Master Response BR-1: Conflict with Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan.

COMMENT 12-3
The following provides a partial listing of the issues that City staﬀ has determined conﬂict with the NBHCP:
o Proposed UWSP directly impacts the protected one-mile Swainson’s Hawk buﬀer zone approved by the wildlife resource agencies.

RESPONSE 12-3
Please see Master Response BR-4: Impacts on Swainson’s Hawk Zone.

COMMENT 12-4
o Proposed UWSP would allow development of 1,532 acres of land that currently is rural agricultural lands beneﬁcial to the NHBCP and that could potentially be acquired in the future for habitat lands.

RESPONSE 12-4
Please see Master Response BR-1: Conflict with Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan and Master Response BR-2:

Reductions in Agricultural Land Available to NBHCP Covered Species COMMENT 12-5
o Proposed UWSP would decrease the remaining open space lands in Natomas Basin which directly impacts the viability of the NBHCP by jeopardizing the successful completion of the NBHCP and placing urbanization near protected areas such as Fisherman’s Lake and existing Conservancy owned HCP mitigation lands.

RESPONSE 12-5
Please see Master Response BR-1: Conflicts with the Conservation Strategy for the Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan which summarizes the Draft EIR’s assessment of the effects of UWSP development on TNBC’s reserve lands.
26 - Responses
Upper Westside Specific Plan 26-110 PLNP2018-00284
COMMENT 12-6
o Future development of 1,532 acres of UWSP would place a greater burden on the existing planned growth authorized by the NBHCP which in turn will most likely cause HCP fee payers increased HCP fee rates and the inability to secure mitigation lands that meet all of the rigorous HCP mitigation land criteria.

RESPONSE 12-6
For a discussion of the effects of the proposed project on the availability of future reserve lands please see Master Response BR-1: Conflict with Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan.

COMMENT 12-7
o An Amendment to the NBHCP and obligations of the issued ITPs would be needed for any development to occur within the one-mile SWHZ and an in-depth eﬀects analysis in relation to the existing adopted NBHCP conservation strategy including future viability to meet all requirements of the NBHCP considering the loss of 1,532 acres due to UWSP and cumulative impacts associated with the proposed Grandpark Speciﬁc Plan (approximately 5,400 acres) in process with the County. The County is essentially considering allowing roughly 7,000 acres of land located in the unincorporated Sacramento County portion of the Natomas Basin to be removed from beneﬁting and contribution to the completion of the NBHCP conservation strategy.

RESPONSE 12-7
An amendment to the NBHCP and any further obligations from the existing ITPs is not proposed as part of the UWSP. Mitigation measures in the Draft EIR appropriately include regulatory permitting with the California Department of Fish and Wildlife and the U.S. Fish and Wildlife Service where applicable. In particular, see Mitigation Measures BR-2c (Special Status Plants), and BR-3 (Giant garter snake). Please see Master Response BR-1: Conflict with Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan.

COMMENT 12-8
o Biological – the Draft EIR concludes that with mitigation the UWSP biological impacts can be mitigated to a less than signiﬁcant level. City staﬀ disagrees with this conclusion.

RESPONSE 12-8
The comment expresses an opinion regarding the conclusions of the Draft EIR, but does not raise specific issues pertaining to the adequacy, accuracy, or completeness of the Draft EIR’s analysis of the proposed UWSP. The comment is acknowledged for the record and will be forwarded to the decision makers for consideration. 26 - Responses
Upper Westside Specific Plan 26-111 PLNP2018-00284
COMMENT 12-9
• NBHCP Participation – If the County intends to allow urbanization beyond its Urban Services Boundary (USB) and Urban Policy Boundary (UPB) why would the County not join the NBHCP as the City of Sacramento and Sutter County have done? Sacramento County may recall being asked to participate in the NBHCP (see Attachment A letter dated 11/28/2000). If Sacramento County is considering allowing further urbanization of the Basin that was not contemplated by the NBHCP how will the County provide assurances to the NBHCP signatory parties that the conservation strategy can still be successfully completed especially without the County’s HCP participation? This has been an issue and concern expressed for over 25 years and to date has not been resolved.

RESPONSE 12-9
Please see Response 12-7 above. The comment will be included as a part of the record and made available to the decision makers prior to making a final decision on the proposed project.

COMMENT 12-10
• Water – During the County’s preparation of the Draft EIR, the City in compliance with State law provided a water supply assessment as requested by the County. The water supply assessment is not an agreement nor commitment by the City to provide water for the future development of UWSP. The City has not entered into any agreement to provide water for the UWSP development. The Draft EIR incorrectly assumes and seems to have pre-determined that the City would provide water to UWSP per an agreement to do so with Sacramento County Water Agency (SCWA).

Page 2 ends

following:
“WATER
The City of Sacramento through an agreement with the SCWA would provide water service to land uses allowed under the proposed UWSP. The City of Sacramento obtains most of its water supply from surface water in the American and Sacramento rivers, while groundwater obtained from the North American and South American subbasins of the Sacramento Valley Groundwater Basin provides the remainder.

As discussed above, the proposed UWSP would require SCWA annexation.

Water supply would be delivered to the UWSP area through the City’s water treatment and distribution system, which consists of two water treatment plants, eight pump stations, many storage reservoirs, 28 municipal wells, thousands of hydrants, and nearly 1,800 miles of pipeline.” The DEIR conflicts with the City’s 2040 General Plan policy that pertains to provisions of City services to new development in unincorporated areas. The specific policy is presented below:
26 - Responses
Upper Westside Specific Plan 26-112 PLNP2018-00284
“LUP-1.4 City Services Prior to Annexation. Prior to the provisions of City services to new development in unincorporated areas, the City shall require that the unincorporated properties be annexed into the City. Alternatively, the City may provide utility service to properties in advance of annexation only if the annexation process has been initiated and the landowner and City have executed a conditional agreement for services that stipulates minimum standards for the development of roads and urban infrastructure and criteria and conditions for annexation into the City.” The Draft EIR page 14-29 lists future Service District Annexation requests to the Sacramento Local Agency Formation Commission (LAFCo). City staff opposes any filing of Service District Annexation requests including for example the listed annexation to Sacramento County Water Agency (SCWA) until to the satisfaction of the City of Sacramento pending concerns and issues are resolved such as water supply/service, Natomas Basin Habitat Conservation Plan conflicts, and provision of public services such as police and fire protection.

RESPONSE 12-10

Page 2 ends

the water system that would deliver potable water to the proposed UWSP. The Draft EIR states that “[t]he City of Sacramento through an agreement with the SCWA would provide water service to land uses allowed under the proposed UWSP.” As described in the August 2024 Draft UWSP, the City of Sacramento would serve as the water wholesaler, and the Sacramento County Water Agency (SCWA) would serve as the water retailer, and would own, operate, and maintain on-site storage, transmission, and distribution facilities.
13 Thus, as proposed the City would wholesale treated water through its existing water infrastructure, specifically an existing 24-inch transmission line within El Centro Road and San Juan Road east of the UWSP. SCWA, as the retailer, would connect the new UWSP water infrastructure to the City’s existing transmission line, and therefore provide water service (transmission and distribution) to the UWSP area. Since the County, and not the City, would be the water service provider to the UWSP, the UWSP would not be inconsistent with City 2040 General Plan Policy LUP-1.4.

In order to provide additional clarity, Draft EIR, Chapter 2, Project Description, page 2-44, the first two paragraphs are revised to read:

The City of Sacramento’s through an agreement with the SCWA would Department of Utilities would serve as the water supply wholesaler to the UWSP. SCWA, as the water retailer, would provide water service to land uses allowed under the proposed UWSP. The City of Sacramento obtains most of its water supply from surface water in the American and Sacramento rivers, while groundwater obtained from the North American and South American subbasins

13 Sacramento County, Upper Westside Specific Plan, Public Review Draft, August 2024, page 5-8. 26 - Responses
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of the Sacramento Valley Groundwater Basin provides the remainder. As discussed above, the proposed UWSP would require SCWA annexation.

Water supply would be delivered to the UWSP area through the Wholesale treated water would be conveyed to the UWSP area through the City’s existing infrastructure east of the UWSP. The City’s water treatment and distribution system, which consists of two water treatment plants, eight pump stations, many storage reservoirs, 28 municipal wells, thousands of hydrants, and nearly 1,800 miles of pipeline. To deliver the treated water within the UWSP, SCWA, as the water retailer would own, operate and maintain the infrastructure within the UWSP including on-site storage, transmission, and distribution facilities as summarized below.

Comment 9-2 from LAFCo explicitly indicates SCWA is not a service district under the jurisdiction of LAFCo. When SCWA needs to extend the infrastructure and provide retail water service to the UWSP area, it will not be accomplished through LAFCo’s annexation process, in this instance, LUP-1.4 does not apply. As described in Response 9-2, …the description of proposed LAFCo actions presented in the Draft EIR, Chapter 2, Project Description, page 2-20 is revised to read:
• Annexation to SacSewer Expansion of the Sphere of Influence of, and subsequent annexation to, the Sacramento Area Sewer District (SacSewer).

Furthermore, this comment expresses an opinion in opposition to future service area annexations that would be required for the proposed UWSP, however it raises neither new significant environmental issues nor specific questions about the analyses or information in the Draft EIR that would require response pursuant to CEQA Guideline section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed project.

COMMENT 12-11
• Transportation – The UWSP has significant implications to the transportation network and facilities located with the City of Sacramento in addition to the nearby freeways and Garden Highway. These concerns are documented in further detail in this letter.

RESPONSE 12-11
The County has responded to the City’s specific transportation comments in Responses 12-24 through 12-28.

COMMENT 12-12
• Public Services – The Draft EIR does not adequately address the impacts of the UWSP on existing public services (police, fire, parks) nor details how these services 26 - Responses
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would be provided considering the lack of current County services in the area due to the existing rural nature and that the UWSP is geographically removed from proximity to nearby County services.

RESPONSE 12-12
The provision of public services, including law enforcement, fire and emergency services, libraries, schools, and parks and recreation facilities is described in the Draft EIR, Chapter 2, Project Description, pages 2-48 through 2-54. Because under CEQA the purpose of the EIR is to disclose the physical adverse environmental effects of the proposed project, it does not address the financing of these services. The Draft UWSP, Chapter 8, Implementation, addresses the financing of construction and operation of a variety of services. It indicates that ongoing governmental services, such as those listed in the City’s comment, may be implemented and financed through a variety of methods, including the creation of a Community Facilities District, developer financing, the creation of a County Service Area, one or more Community Service Districts, Landscape and Lighting Districts, and/or Home Owners Associations.

An Upper Westside Public Facilities Financing Plan (PFFP) is being prepared for the proposed project which is intended to outline the funding and financing mechanisms for construction of public facilities, including backbone roadways and infrastructure. It also will summarize the envisioned phasing of facilities needed to support the development plan, as well as the programs to be employed for on-going public services and maintenance. More specifically, the PFFP will include an Urban Services Plan (USP) which will address the costs of and funding programs for ongoing provision of public services required to serve uses in the Plan Area, including costs for ongoing maintenance of public facilities. The PFFP will be part of the package of proposals included in the UWSP and made available for public review prior to being presented to the Board of Supervisors for its consideration and potential approval.

COMMENT 12-13
Memorandum of Understanding between City & County
On December 10, 2002, the City & County entered into a Memorandum of Understanding (MOU) (City Resolution 2002-830 and County Resolution 2002-1566) regarding Principles of Land Use and Revenue Sharing for the Natomas Area. The MOU (Attachment B) specifically calls for any future urbanization efforts in the Natomas Joint Vision Area (NJVA) to be processed through the City, with the County remaining a steward of agricultural lands and open spaces.

Furthermore, the EIR does not acknowledge or analyze the City's intent to designate the Natomas Basin Study Area, which includes the project area, as an Area of Concern.

The City's General Plan policy LUP-A.1 explicitly states the City's near-term goal (2024- 26 - Responses
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2029) to work with LAFCo on this designation, which would give the City "greater influence on land use decisions and other governmental actions" in the area.

RESPONSE 12-13
As discussed above, under CEQA the purpose of the EIR is to evaluate and disclose the significant environmental impacts of the proposed project. The issues raised by the City relating to governmental responsibilities associated with planning for future urbanization in the Natomas Basin are potential points of future discussion between the County and the City. The comment is noted and will be made available to the decision makers prior to making a final decision on the proposed project.

COMMENT 12-14
City staff does not support the proposed County General Plan Amendment for text amendments to align County policies in various General Plan Elements regarding development in the Natomas Joint Vision Area. There has been no coordination with City staff regarding proposed text amendments to the County’s General Plan that are relative to potential future development in the Natomas Joint Vision Area. Since this specifically pertains to potential development in Natomas Basin which the City has designated as an Area of Concern per the City’s 2040 General Plan and located within our designated Natomas Basin Study Area it would seem that the County would provide some coordination with the City prior to moving forward with changes that pertain to a subject that has been of interest to the City for more than 25 years.

RESPONSE 12-14
This comment expresses the City’s preferences concerning the proposed project but does not address the information contained within the Draft EIR or a specific environmental effect. The comment is noted and will be made available to the decision makers prior to making a final decision on the proposed project.

COMMENT 12-15
Economic Impacts
Our concerns about the concentration of commercial development along the westerly extension of El Camino Avenue remain unaddressed. The DEIR does not sufficiently analyze the potential regional nature of this retail development and its implications for traffic patterns and associated environmental impacts. It fails to address the potential secondary physical and economic impacts within the City that may result from locating retail, hospitality, and other commercial uses adjacent to the City boundary.

RESPONSE 12-15
In addition to the CEQA-required analysis of VMT and traffic safety included in Chapter 18, Transportation, of the Draft EIR, the Draft EIR also contained a Local Transportation Analysis (LTA) in Appendix TR-2. The LTA was based on travel demand modeling using SACOG’s SACSIM model. In addition to providing an analysis of traffic 26 - Responses
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operations for the purposes of mobility planning, the LTA provided technical data about traffic flows that formed the basis of several environmental analyses in the Draft EIR, including effects related to traffic noise, and air emissions of both criteria pollutants and toxic air contaminants. The traffic modeling included travel between all planned origins and destinations, including retail development.

The effects of the proposed retail uses in the UWSP were also studied for their indirect effects on other retail uses in the vicinity, including the potential to create urban decay as a result of the competitive real estate process. An overview of the project’s potential impacts related to urban decay was presented in Chapter 23, Growth Inducement and Urban Decay, of the Draft EIR, with additional detail included in the Upper Westside Specific Plan Urban Decay Analysis in Appendix UD-1.

While raising a general question about the adequacy of the analysis of proposed retail uses, the City’s comment provides no specific information as to how the analysis contained in the Draft EIR is deficient. The comment will be included as a part of the record and made available to the decision makers prior to making a final decision on the proposed project.

COMMENT 12-16
The 2002 City/County MOU recognized mutual economic interests in the future of NJVA and outlined a revenue sharing framework. The DEIR does not address how the UWSP aligns with or impacts this framework. There is insufficient discussion of how the County plans to address these economic issues, especially considering the entitlements being sought by project proponents.

RESPONSE 12-16
The issues raised by the City are potential points of future discussion between the County and the City. As part of its consideration of the proposed project, the County will assess the economic and fiscal effects of the proposed project. However, while economic and fiscal impacts are important considerations for the County in determining whether to approve the proposed project, under CEQA they are not issues that require analysis within an EIR. In fact, CEQA Guidelines section 15131 provides guidance on how economic and social effects are to be addressed in EIRs, stating that “[e]conomic or social effects of a project shall not be treated as significant effects on the environment.” Under CEQA economic and social effects are limited to (1) being addressed as a link in a chain of effects that ties the implementation of the project to a physical environmental effect, or (2) being one of a number of factors considered in addressing the feasibility of an alternative, mitigation measure, or change to the project (see CEQA Guidelines sections 15131(b, c).The comment is noted and will be made available to the decision makers prior to making a final decision on the proposed project. 26 - Responses
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COMMENT 12-17
Growth Inducement
While the DEIR addresses some concerns raised in our NOP comment, particularly regarding the extension of urban infrastructure and potential growth-inducing effects, certain aspects of our request for analysis have not been adequately addressed, especially as they pertain to impacts on the City of Sacramento.

RESPONSE 12-17
The project’s impacts related to growth inducement were evaluated in Chapter 23, Growth Inducement and Urban Decay, of the Draft EIR. The Draft EIR on page 23-1 states that the proposed project “would result in the elimination of an obstacle to growth by extending the Urban Services Boundary [USB] and Urban Policy Area [UPA] to serve the 1,524-acre Development Area.”
With respect to the project’s potential growth inducement in the City of Sacramento, the project site is surrounded on three sides (north, east, and south) by existing urban development within incorporated areas of the City of Sacramento, and urban services are already available in these areas. Expansion of development to the west of the project site is constrained by Garden Highway and the Sacramento River, and the project would also include a 542-acre Ag Buffer to reduce development pressures on unincorporated lands to the west of the project site.

There is no disputing that the proposed UWSP is not anticipated for development in the current versions of the Blueprint and MTP/SCS. In fact, in describing how the land use 26 - Responses
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forecast that is included in the MTP/SCS was developed, SACOG stated that it was based on “an inventory of unbuilt capacity for housing and employment uses, based on existing, adopted plans.”14 The proposed UWSP is not accounted for in the 2020 MTP/SCS or the Blueprint because it currently lies outside of the USB and UPA, and did not meet SACOG’s criteria for inclusion in those documents. The 2020 MTP/SCS Appendix D: Land Use Forecast Documentation specifically stated “[o]utside of the current UPA and USB, in the northwestern portion of the county, the county is also currently processing an application for two projects identified as the North Natomas Precinct and the Upper Westside Specific Plan. While many of these areas are consistent with the region’s long term growth strategy, the Blueprint, and are in varying stages of the local entitlement process, they are not yet approved by the county.” 15 If
the County approves the proposed project, and in doing so extends the USB and UPA, these factors would be considered in future land use forecasts undertaken by SACOG in preparation of future versions of the MTP/SCS.

That the proposed UWSP is not reflected in the current versions of the Blueprint and/or MTP/SCS does not automatically lead to a determination that the project, if approved, would be inconsistent with the Blueprint. In fact, the MTP/SCS states that “[i]ncluding growth within the MTP/SCS is not a guarantee that it will happen. Likewise, growth in areas outside the MTP/SCS may occur during the planning period. Growth outside the MTP/SCS may or may not be consistent with the smart growth, long-term, Blueprint vision for the region.”
16 COMMENT 12-18
Habitat Conservation Plan
Hydrological connectivity
Our NOP comment requested an analysis of hydrological connectivity to existing preserves in Natomas Basin. The DEIR states that the UWSP "is not expected to significantly affect the connectivity of aquatic habitat for giant garter snake" and "would not affect the delivery of water to existing reserves." However, this brief statement lacks the detailed analysis we sought. We request a more thorough examination of potential impacts on existing preserves, particularly the adjacent Cummings Reserve.

RESPONSE 12-18
Under Impact BR-14, the Draft EIR states: “The UWSP area is hydrologically connected to the Cummings Reserve but given that the existing canals and ditches in the UWSP

14 Sacramento Area Council of Governments, 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy, Appendix D: Land Use Forecast Documentation, November 18, 2019, page 4. 15 Sacramento Area Council of Governments, 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy, Appendix D: Land Use Forecast Documentation, November 18, 2019, page 47 16 Sacramento Area Council of Governments, 2020 Metropolitan Transportation Plan/Sustainable Communities Strategy, Appendix D: Land Use Forecast Documentation, November 18, 2019, page 3. 26 - Responses
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area are terminal habitat for giant garter snake, the proposed UWSP would not reduce connectivity between reserve land or other giant garter snake habitat… COMMENT 12-19
Effects on land inventory and mitigation prices
We specifically asked for an analysis of the effects of reducing land available for mitigation while increasing demand, potentially driving up mitigation prices for existing permit holders. The DEIR does not directly address this issue. While it states that mitigation lands "would not unnecessarily directly compete with TNBC for habitat mitigation opportunities," this assertion lacks supporting evidence. We request a detailed analysis of how the UWSP might affect land availability and mitigation costs for existing NBHCP and Metro Air Park (MAP) HCP parties.

RESPONSE 12-19
The Draft EIR evaluated the potential for the UWSP to interfere with the ability of TNBC to meet its reserve acquisition requirements. As explained on page 7-83 of the Draft EIR, the UWSP will not directly compete with TNBC for habitat mitigation opportunities because Mitigation Measures BR-3 and BR-7b require compensatory mitigation lands to be located outside the Natomas Basin.. Please see Master Response BR-1: Conflict with the Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan.

COMMENT 12-20
Land availability for HCP parties
We asked how and where HCP parties with authorized development would find land for mitigation given the cumulative impacts of proposed developments in the Natomas Basin Area. The DEIR's treatment of this issue is insufficient, stating only that mitigation measures BR-3 & BR-7b are "not expected to interfere with the ability of TNBC to satisfy its mitigation responsibilities." We request a more comprehensive analysis of cumulative impacts on mitigation land availability. Based on our direct experience implementing the NBHCP for over 25 years, we question if there is enough suitable land that would remain available to The Natomas Basin Conservancy to mitigate the already approved authorized development of 17,500 acres granted to the City, Sutter County and Metro Air Park if Sacramento County allows the UWSP and Grandpark Specific Plan projects to be approved. We request that Sacramento County evaluate the HCP mitigation land criteria requirements, total mitigation including size of habitat reserves that are required for completion of the HCP conservation strategy. The UWSP DEIR focuses on the impacts and mitigation of the UWSP project itself but does not address the existing HCP acreage requirements that must be completed in the Basin.

Prior to conducting any public hearings for potential action on the UWSP by the County Planning Commission and Board of Supervisors, we request Sacramento County provide the NBHCP signatory parties (City of Sacramento, Sutter County, FWS and 26 - Responses
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CDFW) a detailed accounting and graphics demonstrating of how HCP total acreage requirements could be accomplished with the potential approval and implementation of the UWSP and Grandpark Specific Plan projects. This information and data should also be included as part of the proposed Final EIR when it becomes available.

RESPONSE 12-20
As noted in the Draft EIR, all compensatory mitigation would be secured outside of the Natomas Basin. It also demonstrates that approximately 84% of the available mitigation lands within the Natomas Basin would still be available should the project be approved.

Please see Master Response BR- 1: Conflict with the Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan.

COMMENT 12-21
Consistency with NBHCP Conservation Strategies
We request further clarification on the adequacy of the proposed 250-foot open space buffer between planned development and the Cummings Reserve, compared to the NBHCP's 800-foot setback requirement. The DEIR notes that exceptions to the 800-foot setback have been made in the past. While this explanation is helpful, we request further analysis on whether this 250-foot buffer is sufficient to protect the Cummings Reserve from potential edge effects of urban development.

RESPONSE 12-21
Please see Master Response BR-1: Conflict with the Natomas Basin Habitat Conservation Plan and Metro Air Park Habitat Conservation Plan. In addition, the NBHCP only requires that reserves be initially sited more than 800 feet from existing or planned urban lands at the time of acquisition (see discussion of Buffers within the Reserve Lands under Impact BR-14: Conflict with Natomas Basin Habitat Conservation Plan in the Draft EIR, ) and does not specify that this spacing be maintained in perpetuity. Here, the Draft EIR explained that very low density residential development is the closest planned urban development to the Cummings Reserve, which further supports the Draft EIR’s conclusion that development in the UWSP area would not alter the effectiveness of buffers within TNBC reserve lands.

COMMENT 12-22
One-Mile Buffer Swainson’s Hawk Zone
The City of Sacramento must express its opposition to the proposed Upper Westside Specific Plan (UWSP) due to its direct conflict with the Natomas Basin Habitat Conservation Plan (NBHCP).
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The City of Sacramento, as a signatory to the NBHCP, has a legal obligation to ensure the continued integrity of this regional conservation strategy. Our analysis of the UWSP reveals that significant portions of the proposed development would encroach into the Swainson's Hawk Zone - a critical one-mile-wide buffer adjacent to the Sacramento River that was explicitly established in the NBHCP to protect essential Swainson's Hawk habitat and foraging areas. The NBHCP categorically prohibits development within this zone, with only a strictly limited exception of 252 acres granted to the City of Sacramento.

While Sacramento County is not a direct signatory to the NBHCP, both the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) are bound to the NBHCP as "Permitters" with mandatory obligations to enforce its provisions. These wildlife agencies would be required to issue permits for the UWSP, yet doing so would fundamentally conflict with their legal obligations under the NBHCP, which states that any additional urban development within the Swainson's Hawk Zone "would constitute a significant departure from the Plan's Operating Conservation Program."
The project's inadequate agricultural buffer of 534 acres, ranging from merely 700 to 2,700 feet in width, is insufficient compared to the one mile (5,280 feet) protective buffer mandated by the NBHCP. This reduction in buffer width would severely compromise a core conservation measure that both wildlife agencies have previously determined to be essential for the protection of Swainson's Hawk habitat.

The County must either:
• Substantially redesign the project to eliminate all development within the one- mile Swainson's Hawk Zone buﬀer; or
• Undertake the mandatory comprehensive reevaluation of the NBHCP required when proposing development within this zone, including preparation of a new eﬀects analysis and development of a separate conservation strategy that deﬁnitively ensures no net loss of the eﬀectiveness of this critical conservation measure. This reevaluation must be conducted under the strict oversight of 26 - Responses
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USFWS and CDFW to ensure absolute compliance with their obligations as Permitters under the NBHCP.
• For any County approval of development that directly disturbs the one-mile Swainson’s Hawk Zone (SWZ), we request that the County ﬁrst initiate an amendment to the NBHCP with the wildlife resource agencies to modify the requirements and obligations placed on the City of Sacramento and Sutter County that pertain to the one-mile SWZ. Any action by Sacramento County to approve and allow development within the SWZ is in direct conﬂict with the adopted NBHCP and enforceable requirements by the wildlife resource agencies including for example, the Incidental Take Permits issued by U.S. Fish and Wildlife Services (FWS) and the California Department of Fish and Wildlife (CDFW) to the City of Sacramento and Sutter County.

RESPONSE 12-22
The comment expresses opposition to the proposed project based on concerns about the UWSP potential to encroach into the NBHCP Swainson’s Hawk Zone. As stated in the Draft EIR, the development of the UWSP area would result in permanent loss of 975 acres of Swainson’s hawk foraging habitat within the NBHCP Swainson’s Hawk Zone, which represents approximately 8.2 percent of the habitat in the entire NBHCP Swainson’s Hawk Zone. The Swainson’s Hawk Zone foraging habitat within the UWSP area includes no alfalfa production, which is the highest quality foraging habitat for Swainson’s hawk; whereas the balance of the Swainson’s Hawk Zone outside of the UWSP area includes 644.0 acres of alfalfa production. In recognition of the ecological value of the NBHCP Swainson’s Hawk Zone, Mitigation Measure BR-7b has been modified to preferentially site off-site Swainson’s hawk foraging habitat mitigation to locations within 1 mile of the Sacramento River or Feather River (see Master Response BR-4: Impacts on Swainson’s Hawk Zone). The proposed UWSP would provide mitigation for impacts on Swainson’s hawk foraging habitat at a ratio of at least

0.75:1 (mitigation habitat to permanently lost habitat) for mitigation sites within 1 mile of the Sacramento River or Feather River. Compensatory mitigation for mitigation sites greater than 1 mile from the Sacramento River and Feather River would be at a ratio of at least 1:1, or of equal or greater ecological value as established in separate authorizations or permits by the USFWS and/or CDFW. This includes lands near the Sacramento River and Feather River. Furthermore, the minimum 0.75:1 mitigation ratio identified in Mitigation Measure BR-7b is 50 percent greater than the 0.5:1 mitigation ratio identified in the NBHCP Conservation Plan considered to be an effective mitigation ratio for development of Swainson’s hawk foraging habitat within the Natomas Basin.

Thus, while the UWSP would result in conversion of habitat within the Swainson’s Hawk Zone, such development would be adequately mitigated.

ADEQUACY OF AGRICULTURAL BUFFER
The commenter also opines that that the proposed agricultural buffer is inadequate. As described in the Draft EIR, Chapter 2, Project Description, the Agricultural Buffer would range in width from 700 feet in the south to over 2,700 feet in the north, providing a 26 - Responses
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substantial buffer to the riparian habitat along the Sacramento River that support Swainson’s hawk nesting.

The NBHCP’s Swainson’s Hawk Zone is intended to help maintain blocks of suitable Swainson’s hawk foraging habitat proximal to their nesting and breeding habitat within the riparian corridor along the Sacramento River. Under existing conditions, not all land within the NBHCP Swainson’s Hawk Zone provides suitable foraging habitat for the species, and the quality of suitable foraging habitat within the Swainson’s Hawk Zone is also variable. The foraging habitat within the UWSP area includes no alfalfa production, which is the highest quality foraging habitat for Swainson’s hawk; the balance of the Swainson’s Hawk Zone outside of the UWSP area includes 644.0 acres of alfalfa production.

Additionally, as described in Master Response BR-4: Impacts in Swainson’s Hawk Zone, Mitigation Measure BR-7b has been modified to prioritize compensatory mitigation of Swainson’s hawk foraging habitat conversion under UWSP to areas within 1 mile of the Sacramento River or Feather River, prioritizing sites that effectively provide the similar ecological value as the NBHCP Swainson’s Hawk Zone. The opportunities for compensatory mitigation under Mitigation Measure BR-7b include more than 8,000 acres of highest quality foraging habitat (i.e., alfalfa, pasture, field crops, wheat, grain and hay, truck crops, young perennial, and annual grassland), including lands near the Sacramento River in close vicinity of the proposed UWSP.

NEED FOR NEW EFFECTS ANALYSIS FOR NBHCP
The commenter states that approval of development within the UWSP would trigger a need to prepare a new effects analysis for the NBHCP that definitively ensures the effectiveness of the Swainson’s Hawk Zone measure, unless the footprint of the UWSP were modified to eliminate all development within the Swainson’s Hawk Zone.

Alternatively, the commenter suggests Sacramento County prepare an amendment to the NBHCP regarding the Swainson’s Hawk Zone.

The NBHCP recognizes that within the 50-year permit term of the NBHCP and ITPs, the possibility remains that existing land use outside the Permit Areas and within the Natomas Basin could change over time in a manner that would affect Swainson’s hawk foraging habitat. The NBHCP’s adaptive management program is thus designed to respond to changes in baseline habitat that could occur if undeveloped lands in the Natomas Basin were converted to urban uses. Impacts to SWHA nests and GGS habitat would be subject to conditions of approval in any take authorizations for those species that would relate to each phase of UWSP development. While the take authorization would proceed under a completely separate process from the prior authorizations under the NBHCP, since Sacramento County is not a signatory to that conservation plan, the take authorization for each phase of UWSP development would nonetheless consider development already authorized under the NBHCP as part of the evaluation of cumulative effects. Approval from USFWS would ensure that adequate measures are implemented to ensure no jeopardy of the species; any ITP issued from the CDFW would ensure that any impacts to SWHA nests or GGS habitat are fully mitigated.
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The Draft EIR impact analysis under BR-7 explains how the effects of UWSP on Swainson’s hawk nesting and foraging habitat would be less than significant with implementation of applicable mitigation, and the impact analysis under BR-14 provides a detailed discussion for why the proposed UWSP would not conflict with implementation of the NBHCP or MAP HCP.

COMMENT 12-23
Agriculture
The Draft EIR falls short in addressing crucial concerns regarding the project's impact on agricultural resources and the Natomas Basin Habitat Conservation Plan (NBHCP).

While the EIR quantifies the conversion of approximately 1,372 acres of farmland within the project area, it fails to provide a comprehensive analysis of how this loss might affect the NBHCP's requirement to maintain 4,375 acres in rice cultivation for Giant Garter Snake habitat. The EIR should evaluate not only the direct loss of farmland but also the potential indirect effect of increased development pressure on remaining agricultural lands in the Natomas Basin, which could make it more challenging to maintain the required acreage of rice cultivation.

RESPONSE 12-23
The NBHCP is a habitat conservation plan and not an agriculture preservation plan.

Effects of the proposed UWSP related to biological resources, including effects related to giant garter snake and associated habitat and effects related to the NBHCP, are addressed in Chapter 7, Biological Resources, of the Draft EIR. Effects of the proposed UWSP related to direct and indirect effects to agricultural resources are evaluated in accordance with regulations, policies, and standards applicable to agricultural resources in Chapter 5, Agricultural Resources, of the Draft EIR.

Impacts of the proposed UWSP related to direct conversion of farmland to nonagricultural uses are fully addressed in Impact AG-1 on pages 5-20 through 5-22 in Chapter 5. As discussed in the analysis, the proposed UWSP would result in the direct loss of approximately 1,372 acres of farmland subject to mitigation pursuant to General Plan Policy AG-5. Implementation of Mitigation Measure AG-1 would require preservation of farmland at a 1:1 ratio. However, the Draft EIR concludes that, even with this mitigation, there would be a substantial net loss of farmland within Sacramento County as a result of the proposed UWSP, and this impact would be significant and unavoidable. Therefore, the Draft EIR appropriately identifies that a significant and unavoidable impact related to the conversion of farmland to nonagricultural uses would occur with implementation of the proposed UWSP. In addition, as shown in Table BR-1 of the Draft EIR (page 7-5), the UWSP area does not currently contain any rice crop land cover types. Thus, the proposed UWSP would not have any effect on the NBHCP’s ability to secure rice production acreage.

With regard to indirect effects, including potential indirect effects to agricultural lands (including lands under rice cultivation) in the Natomas Basin, as discussed in Impact AG-3 on pages 5-24 through 5-25 of the Draft EIR, the proposed UWSP would not 26 - Responses
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indirectly result in the conversion of agricultural land outside of the UWSP area. As discussed in the analysis, while implementation of the proposed UWSP would place new residents near existing farmlands and agricultural uses, the proposed plan would include an West Edge Buffer Corridor to enable continued agricultural operations within the 542-acre agricultural buffer to the west of the Development Area. In addition, the proposed UWSP includes a request to amend the UPA and USB. The amended UPA and USB would specifically exclude the aforementioned adjacent agricultural lands. In addition, for any new development north or south of the UWSP area that would propose to convert farmland to nonagricultural use, the land would need to be rezoned and entitled under a separate process requiring substantial effort. As further discussed in Impact AG-3, the proposed UWSP emphasizes policies that support the long-term preservation of agriculture and ensure that development pressures are avoided to the maximum extent feasible. For example, UWSP Policy 3-EE specifies the implementation and maintenance of the aforementioned agricultural buffer to the west of the Development Area to preserve existing agricultural uses and farming operations, to allow visual separation between the Development Area and the Garden Highway/Sacramento River, and to create a transition to habitat mitigation areas located to the northwest. As further discussed in Impact AG-3, proposed high density residential uses would be concentrated near the center of the UWSP area, and development allowed under the proposed UWSP would gradually transition to low density residential uses towards the agricultural buffer zone. This gradual dispersal of residential density would reduce pressure to urbanize areas adjacent to, as well as to the north and south of, the agricultural buffer. As discussed in the analysis, development consistent with the proposed UWSP would concentrate development within the Development Area and would not extend infrastructure to areas beyond the identified growth boundary, Furthermore, infrastructure would not be sized to serve development offsite.

Consequently, the Draft EIR determined that the proposed UWSP would not indirectly result in the conversion of agricultural land outside of the UWSP area, and this impact would be less than significant (See Master Response AR-1:Conversion of Farmland to Nonagricultural Uses, Master Response AR-2: Interface Between Agricultural and Urban Uses, and Master Response BR-2: Reductions in Agricultural Land Available to NBHCP Covered Species).

COMMENT 12-24
Transportation
Roadway Widening and City Responsibility
The DEIR continues to rely on fair share contributions toward roadway widening projects within City limits without adequately addressing our concerns about implementation responsibility. For instance, Mitigation Measure TR-3b still assumes City involvement in implementing improvements at I-5 on-ramps, despite our previous statement that the City should not be assumed to have matching funds. The DEIR does not propose alternative mitigation approaches that avoid placing implementation responsibility on the City, nor does it explain how these projects would be fully funded and executed given the City's financial constraints.
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RESPONSE 12-24
Mitigation Measure TR-3b requires the project applicant to pay their proportionate fair share toward improvements at the I-5 southbound on-ramp at West El Camino Avenue and I-5 southbound and northbound on-ramps at Garden Highway, which would satisfy the applicant’s obligation related to traffic impacts on these facilities. Each of these ramps is owned/operated by Caltrans. The mitigation further describes how either the City of Sacramento or Caltrans could serve as the lead agency to pursue the improvements (note that both interchanges are outside the County of Sacramento, thus precluding the County from serving as lead agency). The mitigation measure does not assume any matching funds to be provided by the City of Sacramento. It is possible that new land development proposals in the vicinity of the interchanges could trigger the need for these improvements, thus creating an additional fair share contributor.

Additionally, new funding sources could come from future state or federal sources, or could be generated by including these projects in a future update to the voluntary I-5 Subregional Corridor Transportation Improvements Fee Program. However, the impact is considered significant and unavoidable because both interchanges are outside the County of Sacramento, thus precluding the County from serving as lead agency, and Sacramento County cannot compel those agencies to approve and allow construction of the specified improvements.

COMMENT 12-25
TR-3a and TR-3b Impacts & Mitigations on Page ES-119 & ES-120 The City of Sacramento looks forward to working collaboratively with the County on the required I-80 West El Camino Avenue interchange improvements being triggered by the project’s development. As specified in the Upper Westside Specific Plan Public Facilities Financing Plan on page 23, the traffic analysis estimated that approximately 90 percent of trips caused by new development in the County using this interchange would be caused by development in the UWSP. The City looks forward to seeing the UWSP project fulfills the required improvements and phasing to ensure the ultimate improvements are constructed when triggered by the UWSP project.

RESPONSE 12-25
The Upper Westside Specific Plan Public Facilities Financing Plan17 states on page 23 that the proposed UWSP is 90 percent of total growth in County traffic at the I-80/West El Camino Avenue Interchange. It then concludes that the proposed UWSP is therefore responsible for 90 percent of the $38 million cost for the interchange improvements. The comment requests that the proposed UWSP fulfill its required improvements and phasing to ensure the ultimate improvements are constructed when triggered by the UWSP project.

17 Source: ATT 4 Draft Public Facilities Financing Plan.pdf 26 - Responses
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The project applicant will be financially contributing through payment of roadway fees, which include the interchange. Sacramento County, serving as lead agency, will pursue construction of the required improvements when triggered based on phasing analysis and the dynamic implementation tool.

COMMENT 12-26
Conflict with City Transportation Policies
Our NOP comments highlighted the City's current focus on reducing lanes on City roadways to align with our Climate Change goals. However, the DEIR does not acknowledge or analyze how the proposed roadway widenings, such as those in Mitigation Measure TR-3a, align with or conflict with this policy direction. We request that the Final EIR include an analysis of how the proposed transportation improvements align with the City's current transportation policies and goals.

RESPONSE 12-26
The Sacramento 2040 General Plan18 was adopted by the Sacramento City Council in February 2024. Chapter 8 (Mobility Element) includes Map M-1 (Roadway Reallocations) which identifies 10 specific road segments outside of downtown that have been identified as ‘a future roadway reallocation segment’. In this context, these streets have been identified as places where excessive roadway capacity exists (i.e., too many vehicle travel lanes) and can be repurposed as spaces to prioritize walking, bicycling, and transit use. None of the reallocation segments are within the vicinity of the proposed project.

The comment requests an analysis of how the proposed transportation improvements (identified in Mitigation Measure TR-3a) align with the City's current transportation policies and goals. This mitigation measure identifies the need for improvements at the I-80/West El Camino Avenue interchange and West El Camino Avenue/El Centro Road intersection. Map M-2 shows the Circulation Diagram for the City of Sacramento including several streets outside the City limits and within the UWSP area. The map shows El Centro Road and San Juan Road as each being two lanes. According to the Upper Westside Specific Plan (August 2024), El Centro Road is planned to be six lanes from West El Camino Avenue northerly to Farm Road, and four lanes north of Farm Road to Arena Boulevard. San Juan Road would remain two lanes from west of I-5 to Garden Highway. Widening of some of these streets, which are within unincorporated Sacramento County, are necessary to comply with the County’s General Plan level of service (LOS) policies. It is acknowledged that the widening of those streets would create an inconsistency with 2040 General Plan Map M-2, which is showing some streets outside the City of Sacramento limits.

The City of Sacramento 2040 General Plan includes goals pertaining to transportation (an equitable, sustainable multimodal system, reduced reliance on single-occupant

18 Source: 2040 General Plan | City of Sacramento
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vehicles, streets designed and maintained as places that contribute to quality of life, a safer transportation system, and connections to the regional transportation network that facilitates the movement of people and goods). These goals are supported by 98 policies. As the proposed project’s transportation improvements would primarily be in unincorporated Sacramento County, they would not affect these goals and policies.

However, several improvements were identified within the City of Sacramento (e.g., improvements at El Centro Road/Arena Boulevard intersection). As such, the City of Sacramento has final authority over whether to approve those projects.

COMMENT 12-27
Regional Growth and VMT Impacts
The DEIR's VMT analysis remains narrowly focused on project-level impacts and does not address our request to examine how the UWSP may redistribute growth away from the City or impact the City's VMT relative to the regional average. We continue to be concerned about potential impacts on the City's growth patterns and overall regional VMT efficiency. We request that the Final EIR include modeling scenarios that evaluate these broader impacts as originally suggested in our NOP comments.

RESPONSE 12-27
This comment requests that the Final EIR include modeling scenarios that examine how the proposed project may redistribute growth away from the City or impact the City's VMT relative to the regional average. Table 2-1 of the Sacramento 2040 General Plan indicates a baseline (2016) of 7,991 miles per person per year. According to this table, a 20 percent reduction in this metric is targeted by 2030 and a 30 percent reduction is targeted by 2040. Thus, the City’s VMT reduction targets are not based on a comparison to a regional average.

Page 3 ends

69,000 new units by 2040, the majority of which would be located in the Opportunity Areas shown on Map LUP-3. These Opportunities Areas are situated in various parts of the city including Downtown, Railyards Specific Plan, and many other parts of the city (both north, south, and east of downtown). Any effort to estimate how future land development patterns would change within the City of Sacramento or regionally with the proposed project developed would be speculative. Since CEQA does not require speculative analyses, no such analysis is presented here. However, it is acknowledged that development of the proposed project could affect (i.e., reduce) the amount of new residential absorption in the City of Sacramento. Depending on the location of that lost absorption, the City’s VMT targets could be easier or more difficult to achieve. This comment does not alter the DEIR’s conclusion that proposed project impacts on VMT (which were analyzed in a manner consistent with Sacramento County Transportation Analysis Guidelines) would be less than significant.
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COMMENT 12-28
Ongoing Technical Coordination
While the DEIR mentions some collaboration with the City, it does not outline a specific process for ongoing coordination throughout project development and implementation as we had requested. Given the project's potential impacts on City infrastructure and services, we believe a more detailed plan for continued technical coordination is necessary.

RESPONSE 12-28
This comment requests that a more detailed plan for continued technical coordination be developed given the project's potential impacts on City infrastructure and services.

To quickly quantify when specific improvements are needed, Sacramento County required that a “dynamic implementation tool” be developed. This tool will be utilized during collaborations between the City of Sacramento and Sacramento County to identify when and what types of specific improvements are needed as UWSP development occurs, following a process similar to Sacramento County’s collaborative efforts related to land development with other cities like Rancho Cordova, for example

19. That program
includes certain improvements within the City of Sacramento, demonstrating how this inter-agency coordination is already occurring.

COMMENT 12-29
Water
In our NOP comments, we identified three potential alternatives for providing domestic water to serve the proposed UWSP area. While the DEIR focuses on Alternative 3 - utilizing City of Sacramento water rights and infrastructure - it does not provide a comprehensive analysis or clear dismissal of Alternatives 1 and 2 involving Natomas Central Mutual Water Company (NCMWC) water rights. We request that the Final EIR include a thorough evaluation of all three alternatives to ensure a complete understanding of the project's water supply and water retailer options.

RESPONSE 12-29
The Draft EIR evaluated the applicant’s proposed project, as described in the Draft EIR, Chapter 2, Project Description, which proposed provision of water to the UWSP area by the Sacramento County Water Agency (SCWA), via an agreement with the City of Sacramento (see Draft EIR page 2-25). The County recognizes that provision of water from SCWA would require annexation of the project area into SCWA’s service area (please see response 12-10, above). The County also acknowledges that such an annexation would be subject to future discussion between the County and the City if the project proceeds. The Draft EIR analyzed the environmental effects of this scenario

19 https://planning.saccounty.gov/PlansandProjectsIn-Progress/Documents/Appendix%20TR- 2%20Transportation%20Mitigation%20Strategy.pdf
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(see page 20-36 of the Draft EIR) and determined that sufficient water would be available through SWCA to serve the proposed project.

The City’s comment requests analysis of a range of alternatives for how water supply may be delivered to the proposed project. Such an analysis is not required in this EIR.

As required under CEQA pursuant to California Water Code section 10910, a Water Supply Assessment (WSA) was prepared by the City of Sacramento in 2022 and was included in the Draft EIR as Appendix UT-1. The conclusions of the WSA were (1) that the water demand for the proposed project was included in the City’s 2020 Urban Water Management Plan, adopted June 29, 2021; (2) that all the infrastructure necessary to deliver a water supply to the project is in place (excepting distribution facilities required to be constructed and financed by the project applicant); and (3) that there are sufficient water supplies for the proposed project during normal, single-dry and multiple dry years over a 20 year period. Accordingly, there was no requirement that the Draft EIR would need to address alternative water supply sources within its consideration of alternatives.

Although there was no requirement to include an evaluation of water supply and retailer options in the Draft EIR, an exploration of such options could be part of a future discussion of issues between the County and the City. The comment will be included as a part of the record and made available to the decision makers prior to making a final decision on the proposed project.

COMMENT 12-30
Furthermore, our NOP comments requested specific details regarding the water delivery system engineering, including the size of mains, distribution, volume, future capacity, system pressurization, storage capacity, and measures to protect the water supply and prevent contamination of the City's existing system. While the DEIR provides some information about the proposed water delivery system, including a water storage tank and transmission mains, it lacks the level of detail we requested. We urge the County to include more comprehensive information on these aspects in the Final EIR to fully assess the potential environmental impacts and ensure the adequacy of the proposed water infrastructure.

RESPONSE 12-30
The engineering details requested by the City are not required under CEQA (see CEQA Guidelines section 15124 where it is stated that a project description “should not supply extensive detail beyond that needed for review and evaluation of the environmental impact”). Identification of details such as pipe sizes, pressurization requirements, and other system characteristics are not required at this time, and would occur during final design of the project. Any water system developed for the proposed project would be required to abide by existing and long-established County and City design standards and engineering protocols, and compliance with those standards and protocols would avoid potential adverse effects.
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COMMENT 12-31
Sewer System
The City of Sacramento notes the EIR's discussion of new wastewater infrastructure needed to serve the Upper Westside Specific Plan area, including the proposed sewer pump station and force main. However, we note that our previous comment requesting analysis of impacts to the Sacramento Regional County Sewer Interceptor has not been adequately addressed. Specifically, the EIR lacks a comprehensive evaluation of the interceptor system's capacity downstream of the New Natomas Pump Station to accommodate additional flows from this project in combination with buildout of the existing Natomas area and other proposed development in the Natomas Joint Vision area. We remain concerned about the potential cumulative impacts on this critical piece of regional infrastructure and whether it has sufficient capacity to serve all these areas without requiring significant upgrades. The City requests that the EIR be revised to include a thorough analysis of existing and projected flows in the interceptor system, an assessment of its available capacity at key points along its alignment, and an evaluation of whether system upgrades may be necessary to handle the increased wastewater volumes. If upgrades to the interceptor are required, the potential environmental impacts of such improvements should also be discussed.

RESPONSE 12-31
Please see Response 5-4 with respect to capacity in the region interceptor system COMMENT 12-32
Fire Protection
The City of Sacramento notes the acknowledgment in the DEIR that the City's Fire Department currently provides and will continue to provide fire protection and emergency medical services to the Upper Westside Specific Plan (UWSP) area under contract with the Natomas Fire Protection District. We also note the inclusion of a site for a new fire station within the proposed plan. However, we find that the DEIR does not adequately address several key concerns raised in our NOP comments.

Given the City's extensive experience in providing municipal services, including over 100 years of fire protection services, we reiterate our position that the City is best 26 - Responses
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equipped to provide a full range of municipal services to the UWSP area. We request that the EIR include a more robust discussion of the City's role in long-term service provision and planning for the area.

RESPONSE 12-32
The County recognizes the City’s interest and concerns with respect to the provision of fire protection services for the project, but the level of detail requested by the City is not germane to the requirements of CEQA and the analysis of public service impacts in general. CEQA’s treatment of public services impacts is narrowly defined to include only those impacts that would arise from the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental effects. The precise significance criteria used in Chapter 17, Public Services and Recreation, of the Draft EIR, and also in CEQA Guidelines Appendix G (XV)(a) states:

Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
1) Fire protection; 2) Police protection; 3) Schools; 4) Parks; and 5) Other public facilities?
CEQA regulations and applicable case law on this issue demonstrate the threshold concerns only the environmental effects associated with the provision of new or altered physical public service facilities. Response times, service ratios, and other performance objectives are relevant to the analysis only within the context of whether or not new or expanded facilities would be required to meet defined criteria related to those service objectives, and what the environmental effects would be of providing those facilities.

As noted in the City’s comment, and also on pages 2-38 and 17-15 of the Draft EIR, the project would create an additional demand for fire protection within the project area that would not be met by existing fire protection facilities and resources. Accordingly, and as stated on page 17-15 of the Draft EIR, a site for a new fire station has been identified in the land use plan for the project, and the station would be constructed as part of Phase 1 of the development plan. The environmental effects of constructing this facility are included as part of the analysis of physical impacts on the environment resulting from development of the proposed project. As discussed in the relevant chapters of the Draft EIR, compliance with mitigation measures and other construction-related regulatory requirements would reduce construction-related effects to the extent feasible. Therefore, the physical impacts of the proposed fire station have been accounted for in the analysis, and the impact was found to be less than significant.

Please see Response 12-12 above regarding the Upper Westside Public Facilities Financing Plan (PFFP) which would address the financing of construction and ongoing operation of public facilities and services, including fire protection. 26 - Responses
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The analysis in the Draft EIR meets the requirements of CEQA. The issues raised by the City are potential points of future discussion between the County and the City, but they are not required by CEQA, or the information contained in the Draft EIR.

COMMENT 12-33
Law Enforcement
The DEIR fails to adequately address the concerns raised in our NOP comment regarding potential impacts to City of Sacramento police protection services. The DEIR focuses exclusively on Sacramento County Sheriff's Office services without acknowledging or evaluating potential impacts to the City of Sacramento Police Department (SPD). This oversight is particularly concerning given the project's unique geographical context - adjacent to the City but isolated from developed County areas - which could potentially strain City services.

RESPONSE 12-33
Please see Response 12-32, above. The Draft EIR evaluated the environmental effects that would arise from providing additional police protection facilities that would be required to serve the project. The analysis in the Draft EIR meets the requirements of CEQA.

The issues raised by the City are potential points of future discussion between the County and the City, but they are not relevant to CEQA, or the information contained in the Draft EIR.
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COMMENT 12-34
Schools
We appreciate that the DEIR identifies the existing schools that would serve different portions of the UWSP area, including Witter Ranch Elementary School, Two Rivers Elementary School, Natomas Middle School, Inderkum High School, and Natomas High School. This information adequately addresses which schools would serve residents both inside and outside the specific development plan areas within the UWSP.

RESPONSE 12-34
Please see Response 12-32, above. The Draft EIR evaluated the environmental effects that would arise from providing additional school facilities that would be required to serve the project. The analysis in the Draft EIR meets the requirements of CEQA.

The issues raised by the City are potential points of future discussion between the County and the City, but they are not relevant to CEQA, or the information contained in the Draft EIR.

COMMENT 12-35
Parks & Recreation Facilities
The Draft EIR for the UWSP analyzed the project’s impact on the existing setting for Parks and Recreation Facilities by considering whether an increase in use of public parks and recreation facilities resulting from the UWSP would cause the substantial physical deterioration of those facilities (e.g., damage to vegetation, accelerated wear on sports facilities and fields, or erosion along trails) or in the need for new or expanded facilities, the construction or operation of which would result in substantial adverse physical effects. This analysis further considers whether implementation of the proposed UWSP would diminish or otherwise adversely affect recreational opportunities and existing facilities within the UWSP area based on facility capacity. 26 - Responses
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Within a 1-mile radius of the UWSP area, there are approximately 20 parks, most of which are within the City of Sacramento and comprising a total of 160 acres of parklands. The closest parks to the UWSP area include River Otter Park, located directly adjacent to the southeastern edge of the UWSP area across Interstate 80, Peregrine Park, located directly adjacent to the eastern edge of the area, and San Juan Reservoir Park, located directly adjacent to the northwestern edge of the area. The North Natomas Regional Park, at 212 acres, located 1.6 miles northwest of the UWSP serves the entire region.

The UWSP concludes that these facilities would be sufficient to accommodate the 25,460 proposed residents and would meet the requirements for parkland under the Sacramento County 2030 General Plan. Therefore, no additional means would need to be utilized to meet any demands in the UWSP area for parks and recreation services.

Objectives for parks and recreation in the UWSP area would be met under the proposed plan, and the impact would be less than significant.

The proposed project’s “parks program” includes 76.5 – 79 acres of parkland which meets the minimum guidelines of 3 acres per 1,000 residents. The 76.5 acres of parkland are considered neighborhood/community serving parks, which will be programmed with active recreation uses. However, the DEIR analyzes the project at the minimum dedication requirement under the Quimby Act of 3 acres per 1,000 residents, less than the County’s (and City’s) policy requirement of 5 acres per 1,000. If the project were to dedicate neighborhood/community parkland at the County standard of 5 acres 26 - Responses
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per 1,000 resident, the proposed project’s parkland dedication requirement would total approximately 128 acres of neighborhood/community serving parks.

51.5 acres that are not identified as neighborhood/community parkland will likely result in an adverse physical effect on the nearby parks within the two adjacent communities.

Additionally, the proposed 79 acres of parkland will likely be diminished or adversely affected at a quicker rate than industry standards. This would be a significant impact.

They want to see regular enhancements and to the parks, such as lighting, restrooms, outdoor exercise equipment, an all-weather field, and an integrated bicycle network.

Residents are also advocating for accessible parks for all ages, drought tolerant landscaping, and the preservation of wildlife habitat.

The UWSP’s investment of over $143 million into the acquisition and development of parks, trails, and open space converts to approximately $1 million per acre with an annual estimated cost of $3.5 million to maintain each park facility. These costs exceed the City of Sacramento’s Park development impact fee credit limits set for turnkey parks, and the estimated annual maintenance costs currently funded by Community Facilities Districts and Landscape and Lighting Districts within North Natomas. The full development of the UWSP park program will likely result in amenities that are attractive to use, and likely a financial impact on Parks annual workplans to repair and replace in 20 years from development. The proposed project’s Public Facilities Finance Plan includes a fee for the provision of repair and replacement of facilities (e.g. parks, pump stations) as well as infrastructure after their useful life. The County may consider funding the long-term repair and replacement costs through a combination of the proposed infrastructure CFDs and through the new services CFD that will fund the 26 - Responses
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share of urban services not paid for by property taxes. The City encourages the County to include an infrastructure CFD to fund long term repair and replacement costs of park facilities. Additionally, the utilities costs to maintain the 146.6 acres of parkland should also be included in the infrastructure CFD.

RESPONSE 12-35
The comment asserts that the proposed UWSP provides insufficient parks and that this would result in residents in the UWSP utilizing existing City parks located off-site and to the east. The comment further asserts that this would in turn result in undue wear on the City parks which could result in a significant impact on City parks. The comment’s calculations and interpretation of park credit under the Parks & Open Space Plan presented in Figure 6-1, page 6-7 of the Draft UWSP are not correct.

The proposed UWSP Parks Program has been updated since publication of the Draft EIR to account for changes in population estimates and Quimby factors., and Tables 6-3 and 6-4, page 6-6 of the Draft UWSP.

The UWSP Parks Program (e.g., park locations, park sizes, the amount of active parkland and other parks, and what should receive credit) was reviewed and accepted by County Parks. The program meets the County’s Quimby requirement of 3.0 acres/1,000 population, and it meets the County’s General Plan goal of providing 5.0 acres per 1,000 population which allows for a mix of park sizes and types (see Sacramento County Code (SCC) section 22.40).

SCC section 22.40 discusses the Quimby requirement and provides factors by housing type to be utilized in determining the required acreage. This results in a 3.0 acre per 1,000 population requirement of 70.5 acres, and the General Plan goal of 5.0 acres per 1,000 population results in a need for 117.4 acres. The proposed UWSP Parks program would provide 79.1 acres of active parkland, and an additional 85.9 acres that would include different types of facilities that would allow for active recreation, for a total of 165.0 acres. Of this total, County Parks allowed a credit of 146.6 acres, which is a surplus of 29.2 acres.

Park facilities, such as the Westside Canal, the Greenbelts with bike trails and distributed Urban Farm nodes, the Urban Farm, the landscaped West Edge hiking trail, and the Parkways around proposed lake basins would provide opportunities for active outdoor recreation and are fair to consider meeting the needs of future residents. These are given full or partial credit to arrive at 146.6 acres, as shown in Table 6-4, page 6-6 of the proposed UWSP.
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For reference, the UWSP Parks Program would also meet and exceed the City’s Quimby requirement of 3.5 acres per 1,000 population, and the resultant need for

78.2 acres of active parkland. Similarly, the program would exceed the City’s 5.0 acres per 1,000 population goal which results in a need for 111.7 acres (see City Municipal Code section 17.512).

COMMENT 12-36
Land Use Planning (City’s 2040 General Plan)
On February 27, 2024, the City of Sacramento adopted the new 2040 General Plan.

The new General Plan identifies five Special Study Areas that are adjacent to existing City limits and are of interest to the City of Sacramento. Planning for the future of these unincorporated areas requires collaboration between the City and the County.

The proposed Upper Westside Specific Plan (UWSP) is located within the Natomas Basin Special Study Area which bears relation to the planning of the City of Sacramento.

The City of Sacramento is projected to see significant growth by 2040 (69,000 new homes, and 76,000 new jobs), and with careful land use planning, new development can help make Sacramento a model of sustainable, equitable growth and community development.

Updating the 2040 General Plan was a major undertaking and a multi-year process in effort to develop a land use framework and policies which provide for strategic growth and change that seek to concentrate new growth within the existing City limits.

The City is concerned about how the UWSP could induce sprawl and redistribute growth away from the City especially if the proposed development does not comport with the City’s new land use standards and innovative policies.

For your reference below is a link to the City of Sacramento’s new 2040 General Plan.

Building intensity standards are shown on Maps LUP-6, LUP-7, LUP-8, and Figure LUP-5. https://www.Cityofsacramento.gov/content/dam/portal/cdd/Planning/General-Plan/2040- General-Plan/Adopted%202040%20General%20Plan_20240227.pdf 26 - Responses
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Additionally, below two key innovative policies that support our emission reduction and sustainability goals in the 2040 General Plan. Policy LUP-4.13 requires new or expanded gas stations provide EV charging infrastructure. Policy LUP-4.14 eliminates vehicle parking minimums Citywide.
• LUP-4.13 Future-Ready Gas Stations.

The City shall not require new or existing development to provide off-street vehicle parking spaces.

RESPONSE 12-36
As discussed in Draft EIR Chapter 14, Land Use, the proposed UWSP would meet regional and County visions and plans intended to promote smart growth principles, including compact development, mixed-use development, housing choice and diversity, transportation choice, reduction of vehicle miles travelled (VMT), reduction of greenhouse gas (GHG) emissions, natural resource conservation, and quality design.

More specifically, Draft EIR Impact LU-3 in Chapter 14, Land Use, discusses County General Plan Policy LU-120 which is intended to reduce impacts of many different types – such as growth inducement, unacceptable operating conditions on roadways, poor air quality, and lack of appropriate infrastructure – by establishing design criteria for all amendments to the Urban Policy Area (UPA). Policy LU-120 represents a performance- based approach, emphasizing high quality, smart growth criteria rather than business- as-usual approach that repeated historical land use patterns. Policy LU-120 was developed with the primary objective of reducing VMT by identifying sufficiently high densities to support transit; requiring infrastructure, including transit, is put in place at the same time the project is developed; maintaining a jobs-housing balance that reduces the need for long commutes and ensures lower VMT; ensuring a project design that will enable residents to walk, ride bicycles, or take transit to their jobs and schools; and requiring a reasonable amount of mixed-use development. As shown in Table LU-3:
on pages 14-29 through 14-31 of the Draft EIR, the proposed UWSP would be consistent with LU-120’s performance criteria, scoring 24 out of 24 possible points.

With regard to the concern that the proposed UWSP could induce sprawl and redistribute growth away from the City, the proposed UWSP is immediately adjacent to existing and planned development, including residential uses within the City of Sacramento’s North Natomas and South Natomas community that are located to the north and east of the UWSP area. The proposed UWSP project area is closer to the regional core in downtown Sacramento than recently annexed areas of the City such as Northlake and the Panhandle. Impact LU-2 in Draft EIR Chapter 14, Land Use, presents 26 - Responses
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the extensive planning framework for the County lands located near the North Natomas community have established guiding principles for future master planning efforts within the Natomas Joint Vision Area. The impact discusses the ways in which the proposed UWSP’s community form responds to this important groundwork and cites Section 1.4 of the draft UWSP that demonstrates how the proposed UWSP would be consistent with County General Plan Policy LU-114, which specifies that development and open space preservation in the Natomas Joint Vision Overlay Area occur in a comprehensive, responsible, and cohesive manner that best addresses land use, economic development, and environmental opportunities and challenges in Natomas.

Finally, the design of the proposed UWSP has been informed by extensive and ongoing coordination between County and City staff, including the following:
• December 19, 2018: County Planning and Environmental Review (PER) staff (Leighann Moffitt, Todd Smith, John Lundgren, Todd Taylor) met with City of Sacramento staff (Tom Pace, Cheryle Hodge, Remi Mendoza) to discuss the proposed project and potential issues to be addressed.
• June 11, 2019: PER staff conducted an open house on the project and the master plan process. City of Sacramento staff (Cheryle Hodge) attended. • October 13, 2020: PER staff and Department of Transportation (DOT) staff conducted a kickoff meeting regarding the project’s transportation analysis. City of Sacramento staff invited to the kickoff and subsequent meetings included Cheryle Hodge, Pelle Clark, Aelita Milatzo, Anis Ghobril, and Michael Hanebutt.

The City of Sacramento was requested to provide a list of facilities and development projects to be included in the scope of the transportation analysis.

Further technical discussions occurred throughout the completion of the transportation analysis and development of mitigation approaches. • Other ongoing coordination occurred between Cheryle Hodge and Todd Smith on December 6, 2021, January 3, 2022, January 20, 2022, and July 6, 2022.

The County recognizes that the City of Sacramento in its recently adopted 2040 General Plan identified a number of “special study areas” that are outside of its legally established Sphere of Influence, including all of the unincorporated land in the Natomas Basin other than Sacramento International Airport and Metro Airpark, the fully developed Arden- Arcade community, and the East Study Area. There are no current proposals to add these areas to the City’s Sphere of Influence, and the planning for these areas remains the responsibility and within the jurisdiction of the County. The County shares the City’s interest in promoting “responsible land and resource-efficient planning” in these areas.

While the proposed UWSP is not subject to City of Sacramento plans and policies, the Draft EIR addresses the consistency of the proposed project with regional and County visions and plans intended to promote smart and orderly growth.

The references to the City of Sacramento General Plan land use densities and policies to promote EV charging stations and eliminate parking minimums are noted. The County’s recently adopted Climate Action Plan includes provisions to promote EV charging stations as part of new developments and when current gas stations are 26 - Responses
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improved (see CAP Action GHG-07-f). CAP Measure GHG-10, including associated Actions GHG-10-a through GHG-10-e, requires revision of County parking standards, including the lowering of parking minimums, unbundling parking from associated land uses, and requiring shared parking in some infill development areas.

Sacramento City CouncilAugust 12, 2025

Sacramento City Council
August 12, 2025