2025-01124 [Pass for Publication] Airport South Industrial Annexation (P21-017) — Sacramento City Council, October 21, 2025 (part 4 of 6)

April 2024
According to the Local Transportation Analysis prepared for the proposed project by DKS Associates (see Attachment D of this Plan for Services),5 of the 43 intersections evaluated, the Del Paso Road/East Commerce Way intersection is the only study intersection where operations would deteriorate below the City’s LOS threshold as a result of the proposed project under the Baseline with Project condition. However, the LOS effects associated with the Baseline with Project condition assumes full buildout of the industrial park and nonparticipating parcels, which is applied against the Baseline condition. Given that full buildout of the proposed project is anticipated to occur over multiple years with additional roadway improvements constructed off-site, the Local Transportation Analysis concludes that effects associated with the Baseline with Project condition could be phased, as needed, with subsequent review and analysis. Additionally, the Local Transportation Analysis found that all evaluated roadway segments would operate at acceptable LOS under Baseline and Baseline with Project conditions.

3. Information With Respect to How the Services Will be Financed Funding and financing information for the proposed circulation improvements is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section . All circulation facilities would be constructed by the developer. This includes design and construction where required, or payment of in lieu fees. Roadway construction would be phased as the project develops.

IX. ANIMAL CARE
Animal Care services for the County lands surrounding the project site are currently provided by Sacramento County Animal Care Services, located at 3839 Bradshaw Road, one mile south of U.S. Route 50 (US-50). Within the City limits, the City of Sacramento operates the Front Street Animal Shelter, located at the Front Street/Broadway intersection.

Regulations and standards regarding animal care are set forth in the Sacramento City Code Section 9.44. Enforcement is handled by the Animal Care Services Division of the Public Works Department, with support from police and other County departments regard ing issues of public health and safety related to dangerous or stray animals.

1. Description, Level, and Range of Services to be Extended to the Project Site
The City of Sacramento Animal Care Services include low-cost vaccination clinics, spay and neuter clinics, veterinary care, a pet food pantry, euthanasia services, pet licensing, adoption, boarding, lost and found pet services, and informative resources. The Front Street shelter maintains a full staff of veterinarians, service administrators, field operators, and staff who assist with animal detention, shelter, care, and placement of stray and licensed pets. Animal care also coordinates with other agencies in response to public safety, emergency, and law enforcement needs regarding animals. Animal Care Services are paid for through the City’s General Fund, supplemented by donations and fundraising from animal care groups.

5 DKS Associates. Sacramento Airport South Industrial Development Local Transportation Analysis. February 5, 2024.

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2. An Indication of Any Improvement or Upgrade of Facilities and Other Conditions the City Would Impose or Require Within the Affected Territory if the Reorganization is Completed
The proposed project consists of industrial and commercial development that is not anticipated to affect capacity or demand for animal care services in the City of Sacramento. Improvements to animal care services in the City would not be necessary as a result of the proposed project.

X. CODE ENFORCEMENT
The Sacramento Code Compliance Division provides code enforcement services for the City’s neighborhoods, businesses, entertainment, and housing. The Code Compliance Division’s overarching goal is to preserve and enhance public health, safety, and welfare by addressing issues of blight and enforcing City and State codes. The City of Sacramento 2040 General Plan contains guiding goals and policies related to code enforcement applicable to the proposed project, which are presented below.

Historic and Cultural Resources Element
Goal HCR-2 A comprehensive, citywide preservation program that identifies, protects, and assists in the preservation of Sacramento’s historic and cultural resources.

Policy HCR-2.5 Code Compliance. The City’s Code Enforcement, Building, and Preservation Planning Division staff shall work
collaboratively to identify historic properties under code enforcement actions and facilitate repair work that brings historic properties into compliance, consistent with preservation best practices, including utilizing the State Historical Building Code to support preservation goals.

Environmental Resources and Constraints Element
Goal ERC-7 Protection of life and property from seismic hazards.

Policy ERC-7.2 Seismic Stability. In accordance with the California Building Code, the City shall regulate structures intended for human occupancy to ensure they are designed and constructed to retain their structural integrity when subjected to seismic activity.

Goal ERC-10 A healthy sound environment conducive to living and working.

Policy ERC-10.9 Construction Noise Controls. The City shall limit the potential noise impacts of construction activities on surrounding land uses through noise regulations in the City Code that address permitted days and hours of construction, types of work, construction equipment, and sound attenuation devices.

Mobility Element
Goal M-1 An equitable, sustainable multimodal system that provides a range of viable and healthy travel choices for users of all ages, backgrounds, and abilities.

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Policy M-1.36 Electric Vehicles (EVs) in New Development. The City shall support minimum levels of EV infrastructure readiness and installation in new development and incentivize additional levels of EV charging, and EV car share, beyond City Code minimums.

1. Description, Level, and Range of Services to be Extended to the Project Site
The following services fall under the jurisdiction of the Code Compliance Division:

• Business Compliance: Works with City departments to issue permits and licenses and enforces codes and ordinances, including tobacco retailer licenses, entertainment permits, taxi permits, and mobile food permits. • Housing and Dangerous Buildings : Enforces City and State codes relat ed to residential and commercial structures and addresses pests and mechanical noise. • Anti-Graffiti Program : Works with the Sacramento Police Department (SPD) to carry out efforts to keep neighborhoods clear of graffiti and implements abatement programs, educational outreach, and community involvement programs.

2. An Indication of Any Improvement or Upgrade of Facilities and Other Conditions the City Would Impose or Require Within the Affected Territory if the Reorganization is Completed
Although a need for code enforcement w ould be expanded due to the inclusion of the project site within the City limits, such inclusion would be at a level sustainable to the City.

Currently, the City and the Sacramento Fire Department (SFD) review projects for compliance with State and local code requirements ; however, City code enforcement would vary slightly, depending upon what the City and SFD deem most relevant regarding public safety. Facility upgrades are not anticipated to be required for the Sacramento Code Compliance Division as a result of the proposed project, which would be entirely new development and built to the City’s latest standards in compliance State and local regulations. As the nonparticipating parcels are eventually developed, they would also be constructed in conformance with the State and local regulations in effect at the time of construction.

3. An Indication of When the Services Can Feasibly be Extended to the Affected Territory
Code enforcement services to the project site would be provided consistent with the development and occupation of the proposed structures.

4. Information with Respect to How the Services will be Financed The proposed project would contribute to the City’s funding of the Code Compliance Division through revenues generated from payment of application fees for applicable permits and clearances by new development and local taxes . Additional f unding and financing information related to code enforcement services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XI. POLICE PROTECTION
The project site is currently located within the unincorporated portion of Sacramento County, which is provided law enforcement services by the Sacramento County Sheriff’s Office. Upon annexation into the City of Sacramento, the site would be served by the SPD. The SPD provides Airport South Industrial Project
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police protection services within the City limits and is staffed with approximately 686 sworn personnel, 29 academy recruits, 291 professional staff, and 144 non -career staff.6 The SPD is managed by the Chief of Police , as well as three Deputy Chiefs and a captain who oversee the Offices of Operations, Investigations, and Specialized Services.

The SPD is headquartered at the City’s Public Safety Center at 5770 Freeport Boulevard and is supported by several substations throughout the City. The substations include the William J.

Kinney Police Facility, which serves the SPD’s North Area from 3550 Marysville Boulevard ; the Joseph E. Rooney Police Facility , which serves the SPD’s South Area from 5303 Franklin Boulevard; and the Central Command Richards Police Facility, which is located at 300 Richards Boulevard.

The North Area substation provides police services to the northern portion of the City, from the American River to the south , to the City limits to the west, north, and east. The South Area substation provides police protection services to the southern portion of the City, from US-50 to the north, to the City limits to the west, south, and east. The Central Command Richards Police Facility provides police response to three main beats in the central portion of the City, which are bounded by the American River to the north, US-50 to the south, the Sacramento River to the west, and the City limits to the east. The nearest police substation to the project site is the Central Command Richards Police Facility, which is located approximately 5.4 miles to the southeast of the site.

The SPD does not have an adopted officer -to-resident ratio. The department uses geographic information systems (GIS) data, call and crime frequency information, and available personnel to rebalance its deployment on an annual basis in order to meet the changing demands of the City.

The SPD maintains an unofficial goal of 2.0 to 2.5 sworn police officers per 1,000 residents and one civilian support staff per two sworn officers.

The City of Sacramento 2040 General Plan contains guiding goals and policies related to police protection applicable to the proposed project, which are presented below.

Public Facilities and Safety Element
Goal PFS-1 Responsive police and fire services that ensure a high level of public safety.

Policy PFS-1.1 Crime and Law Enforcement. The City shall continue to work cooperatively with the community, regional law enforcement agencies, local government agencies, and other entities to provide quality police service that protects the long-term health, safety, and well-being of the community.

Policy PFS-1.2 Community-Based Policing. The City shall continue to employ community-based policing strategies and encourage the
establishment of neighborhood watch programs in partnerships with community groups to address neighborhood crime.

Policy PFS-1.5 CPTED Strategies. The City shall continue to promote Crime Prevention through Environmental Design (CPTED) strategies in the design of new developments, including the following:

6 The Targeted MSR’s statistics are based on 2019 staffing levels. Additionally, it should be noted that the SPD was authorized to staff 747 sworn positions and 323.46 professional staff positions during fiscal year 2019/2020.

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• Provision of adequate public lighting;
• Windows overlooking streets and parking lots; and
• The creation of paths to increase pedestrian activity within both private development projects and public
facilities to enhance public safety.

Policy PFS-1.9 Equipment, Facilities, and Staffing. The City shall locate and maintain police and fire equipment, facilities, and staffing at locations and levels that allow for effective service delivery.

Policy PFS-1.12 Cooperative Delivery of Services. The City shall maintain mutual aid relationships with the County of Sacramento and other local, State, and federal agencies that promote regional cooperation in the delivery of services and allow for
supplemental aid from other police and fire personnel i n the event of emergencies.

Policy PFS-1.14 Timing of Services. The City shall monitor the pace of residential and commercial growth in Sacramento and make best efforts to match that growth with commensurate increases in public safety personnel, equipment, and facilities.

Policy PFS-1.15 Development Fees for Facilities and Services. The City shall require development projects to contribute fees to ensure the provision of adequate police and fire services.

Policy PFS-1.16 Development Review. The City shall continue to require new development projects to incorporate safety features and include the Sacramento Police Department (SPD) and the Sacramento Fire Department (SFD) in the development review process to ensure that projects are designed a nd operated in a manner that minimizes the potential for criminal activity and fire hazards and maximizes the potential for responsive police and fire services.

5. Description, Level, and Range of Services to be Extended to the Project Site
The nearest police substation to the project site is the Central Command Richards Police Facility, which is located at 300 Richards Boulevard, approximately 5.4 miles to the southeast of the site. The SPD does not have an adopted officer -to-resident ratio.

Unofficially, the SPD maintains an unofficial goal of 2.0 to 2.5 sworn police officers per 1,000 residents and one civilian support staff per two sworn officers. Additionally, the Sacramento Genera l Plan does not establish a specific response time standard for emergency calls for the SPD.

Development of the proposed project is estimated to result in a total of approximately 4,000 employees. Conservatively estimating that all permanent positions associated with the project would be filled by new residents to the Sacramento region would result in a 0.7 Airport South Industrial Project
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percent increase to the existing City population. 7 While such an increase could incrementally increase demand for police protection services by the SPD, given the relatively short distance of the Central Command Richards Police Facility to the project site, the SPD would be able to capably respond to service calls from the project site. In addition, General Plan Policy PFS 1.15 establishes the City’s commitment to ensuring the SPD has the necessary levels of facilities, equipment, and staffing to adequately provide police protection services to the SPD service area. The City funds the SPD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. In addition, new development within the City is subject to applicable development impact fees to ensure a fair -share contribution is made to finance the purchase of new or expansion of existing S PD facilities, apparatus, and equipment necessary for the purposes of maintaining adequate service levels. The project site is currently contiguous with the City’s North Natomas Finance Plan Area. As part of project approval, the proposed project would be subject to the North Natomas Planning Area Development Fees. Pursuant to Sacramento City Code Section 18.24.050, the North Natomas Planning Area Public Facilities Fee is assessed at a rate of $238,272 per net acre for Convenience Commercial uses; $140,361 per net acre for Community Commercial uses; and between $49,752 and $57,527 per net acre for Light Industrial uses. Thus, through payment of the North Natomas Planning Area Development Fees, buildout of the project site with the proposed uses would include a fair-share contribution to the City for the provision of SPD services to the site.

Finally, the development standards established by Sacramento City Code Section

17.220.250 for the Industrial PUD (M-1-PUD) zoning district require compliance with the City’s wall, fence, and gate regulations, which are set forth in Sacramento City Code Chapter 17.620. The aforementioned regulations allow for enhanced fencing materials capable of providing additional security for nonresidential structures and requirements for gated entrances. Such features would reduce the demand for police protection services associated with the proposed project. Thus, any increase in demand generated by the project, including new residents indirectly attracted to the City by the project, could be accommodated by the SPD.

6. An Indication of When the Services Can Feasibly be Extended to the Affected Territory
SPD services to the project site would be provided consistent with the development timeline of the proposed project, with police staffing and facilities expanding incrementally.

7. Information with Respect to How the Services will be Financed The City funds the S PD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. The proposed project would also be subject to development impact fees, as set forth by Sacramento City Code Section 18.24.050 . Additional funding and financing information related to police protection services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XII. FIRE PROTECTION
The project site is currently provided fire protection services by t he SFD, which provides fire protection services to the City of Sacramento, as well as adjacent areas in unincorporated

7 Based on 2019 population total for the City of Sacramento presented in the Land Use and Planning/Population and Housing chapter of this EIR.

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Sacramento County. The SFD’s service area consists of approximately 99.2 square miles within the City limits and 47.1 square miles in Sacramento County, including two contract areas for the Pacific Fruitridge Fire Protection District and Natomas Fire Protection District. The department is a full-service fire department, with the responsibility for responding to and mitigating incidents involving fires, medical emergencies, hazardous material incidents, and water rescue within its service area.

The SFD also provides a full range of support services, including fire prevention, public education, fire investigation, and domestic preparedness planning and response. The department participates in an automatic aid agreement with neighboring fire jurisdictions, as well as State and federal agencies. The SFD has 678 budgeted personnel positions that respond to approximately 90,000 calls and provide service to approximately 480,000 residents and more than 20,000 businesses in the City. 8 At full staffing levels, the SFD daily operation staff consists of a total of 173 on -duty personnel for fire and emergency medical service (EMS) first responder emergencies, 34 of which are on duty for emergency ambulance transportation. The SFD maintains a goal to have its first responding company, which provides for fire suppression and paramedic services, arrive within four minutes.

The SFD is organized into the following divisions:

• Fire Administrative Services , which is responsible for departmental support of budget, revenues, accounts payable, procurement, contracts, council reports and grants, and various personnel services;
• Fire/Emergency Medical Services, which responds to fires, rescues, hazardous materials incidents, wildland fires, and other emergencies and medical services; • Office of the Chief , which is responsible for developing and providing the department’s overall direction;
• Technical Services, which provides essential support functions to all divisions, including equipment acquisition and repair, information technology, facility maintenance and repair coordination, and fleet maintenance. The division also enforces fire codes and ordinances, conducts plan reviews and construction inspections, and investigates fires; and • Training/Professional Standards, which is responsible for essential fire recruit training including in-service, continuing education, and outreach/recruitment.

The SFD is headquartered at the City’s Public Safety Center, located at 5770 Freeport Boulevard in Sacramento. Th e facility also serves as the SPD’s headquarters. The SFD operates 24 fire stations, which are strategically located throughout the City. The nearest SFD station to the project site is Station 43, which is located at 4201 El Centro Road, approximately 2.5 miles southeast of the site. Although each SFD station operates within a specific response district encompassing the immediate geographical area around the station, all of the fire agencies within Sacramento County (i.e., SFD, Sacramento Metropolitan Fire District, Sac Airport Fire, Cosumnes Community Services District Fire Department, and the Folsom Fire Department) share an automatic aid agreement that allows response from the closest fire unit regardless of jurisdiction.

The nearest existing fire station in Sacramento County to the project site is the Sac Airport Fire station, located at the Sacramento International Airport, approximately 2.1 m iles to the north of the project site.

All but one of the SFD engine companies are staffed with four personnel, consisting of a Company Officer (captain), engineer, and two firefighters. The remaining engine company, located at

8 The Targeted MSR’s statistics are based on 2017 SFD staffing levels.

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Station 3 in the rural portion of the contracted Natomas Fire Protection District, is staffed with three personnel (a captain, an engineer, and a firefighter). In addition, SFD truck companies and the department’s lone rescue company are also staffed with personnel that are identical to the four-person engine companies . Ambulances are staffed with two firefighters/paramedics or a firefighter/paramedic and firefighter/emergency medical technician (EMT) combination.

Metro Air Park, a master planned industrial development, is also scheduled to provide land and facilities for a new fire station near the project site. The 10,000-square-foot (sf) fire station will be located approximately 1.4 miles north of the site and operated by the Sacramento Metropolitan Fire District. Construction of th e facility is planned at such time that Metro Air Park reaches 30 percent buildout.

In addition to the goals and policies listed above related to first-responder services in general, the City of Sacramento 2040 General Plan contains guiding goals and policies related to fire protection applicable to the proposed project, which are presented below.

Public Facilities and Safety Element
Goal PFS-1 Responsive police and fire services that ensure a high level of public safety.

Policy PFS-1.6 Fire Prevention Programs and Suppression. The City shall deliver fire prevention programs that protect the public through education, adequate inspection of existing development, and incorporation of fire safety features in new development.

Policy PFS-1.7 Water Supply for Fire Suppression. The City shall ensure that adequate water supplies are available for fire suppression throughout the city and shall require development to construct all necessary fire suppression infrastructure and equipment.

Policy PFS-1.8 Fire Hazards. The City shall continue to require private property owners to remove excessive/overgrown vegetation (e.g., trees, shrubs, weeds) and rubbish to the satisfaction of the Fire Department to prevent and minimize fire risks to surrounding properties. The City shall continue to remove
excessive/overgrown vegetation from City-owned property.

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1. Description, Level, and Range of Services to be Extended to the Project Site
The nearest SFD fire station to the project site is Station 43, which is located at 4201 El Centro Road, approximately 2.5 miles southeast of the site. Although each of SFD’s 24 fire stations operates within a specific response district encompassing the im mediate geographical area around the station, all fire agencies within Sacramento County (i.e., SFD, Sacramento Metropolitan Fire District, Sac Airport Fire, Cosumnes Community Services District Fire Department, and the Folsom Fire Department) share an aut omatic aid agreement that allows response from the closest fire unit regardless of jurisdiction.

According to the Targeted MSR, the SFD seeks to respond to fire incidents and medical emergencies within four minutes.

As the proposed project primarily consists of industrial uses, with a limited number of commercial uses also proposed, the project would not be anticipated to generate a substantial amount of new population within the SFD service area, as the project does not include new residential units and the majority of jobs created by the project would be filled primarily by those already residing within the Sacramento region. As such, the proposed project would not be expected to substantially increase the need for a dditional SFD fire personnel, equipment, and facilities through population growth.

Nevertheless, due to the industrial nature of the project, the potential exists for work - related injuries that necessitate emergency medical care to occur during project operation.

Based on assumptions in the Local Transportation Analysis, development of the project could generate a total of approximately 4,000 employees. Given the relatively close proximity of Station 43 to the project site, the SFD is anticipated to be capable of responding to emergency medical and fire incidents at the project site withi n the department’s four -minute response time goal. In addition, through the automatic aid agreement between fire agencies within Sacramento County, the most efficient fire protection and emergency medical services would be available to the project site. For example, Metro Air Park is scheduled to provide land and facilities for a new fire station near the project site. The 10,000-sf fire station site will be located approximately 1.4 miles north of the project site and operated by the Sacramento Metropolitan Fire District, which would allow for immediate response to fire and emergency medical incidents at the project site.

All structures included as part of the proposed project would be constructed in accordance with the applicable standards set forth by the California Building Code ( CBC) and California Fire Code (CFC). Consistent with the CBC, the design of the proposed buildings would include the installation and use of automatic fire sprinklers. Fire alarm systems would be incorporated pursuant to CFC requirements. Such features would reduce the potential for fires to occur and spread within the proposed structures, thereby reducing the demand for fire protection services associated with the proposed project.

General Plan Policy PFS 1.9 establishes the City’s commitment to ensuring the SFD has the necessary levels of facilities, apparatus, equipment, and staffing to provide adequate fire protection and emergency medical services within the department’s service area. The City funds the SFD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. In addition, new development within the City is subject to applicable development impact fee s to ensure a fair-share contribution is made to finance the purchase of new or expansion of existing SFD facilities, apparatus, and equipment necessary for the purposes of Airport South Industrial Project
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maintaining adequate service levels. Accordingly, revenues generated through payment of applicable permit application fees by the proposed project , as well as development impact fees established pursuant to Sacramento City Code Section 18.24.050, would ensure the project pays a fair share for fire protection services provided by the SFD.

2. An Indication of When the Services Can Feasibly be Extended to the Affected Territory
SFD services to the project site would be provided consistent with the development timeline of the proposed project, with fire protection staffing and facilities expanding incrementally.

3. Information with Respect to How the Services will be Financed The City funds the S FD budget, in part, through revenues generated from payment of application fees for applicable permits and clearances by new development. The proposed project would also be subject to development impact fees, as set forth by Sacramento City Code Section 18.24.050 . Additional f unding and financing information related to fire protection services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XIII. SOLID WASTE
The project site is not currently provided solid waste collection services. Upon annexation into the City, the site would be provided services by the City of Sacramento’s Recycling and Solid Waste Division, which collects solid waste generated throughout the City, including household waste, recycling, construction and demolition materials, and organic wastes. According to the Targeted MSR, more than 660,000 tons of solid waste are generated annually, with the City collecting approximately 250,000 tons . The remainder is collected by franchised waste haulers and individual residents.

Waste collected by the City is initially transported to two locations , including the Sacramento Recycling and Transfer Station (SRTS), which accepts waste from the southern region of the City, and the Sacramento County North Area Recovery Station (NARS), which accepts waste from the north region of the City. Refuse is hauled from both locations to the Sacramento County Kiefer Landfill for processing. Solid waste generated by commercial uses (including multi -family residences of five units or more) is collec ted by private haulers and transported to the SRTS, NARS, Sacramento County Kiefer Landfill, as well as other facilities, including the Yolo County Central Landfill, L and D Landfill, the Florin Perkins Public Disposal Site , and the Elder Creek Transfer Station. According to the Targeted MSR, the Sacramento County Kiefer Landfill, located at Kiefer Boulevard and Grand Line Road, includes 1,084 acres of total area, with approximately 660 acres of landfill area. The Kiefer Landfill is the primary location for the City of Sacramento’s disposal of solid waste. The waste delivered to the landfill is from municipal and industrial sources, with an average of approximately 2,423 tons per day accepted.

The City of Sacramento 2040 General Plan contains guiding goals and policies related to solid waste applicable to the proposed project, which are presented below.

Public Facilities and Safety Element
Goal PFS-5 Sensible waste management that reduces disposal in landfills and supports cost- effective sustainability efforts.

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Policy PFS-5.1 Solid Waste Reduction. The City shall reduce the amount of solid waste that is disposed in landfills by promoting source reduction and recycling throughout Sacramento and by
expanding the range of programs and information available to local residents and businesses, consistent with State
requirements.

Policy PFS-5.2 Collection and Recycling Services. The City shall provide for continued solid waste collection and recycling services in Sacramento, including contracting with franchise waste haulers, and ensuring adequate transfer station facilities capacity and the availability of adequate landfill capa city to meet future needs.

Policy PFS-5.5 Recycled Materials in New Construction. The City shall encourage the use of recycled materials in new construction.

Methods shall include promoting the availability of materials at Certified Construction and Demolition (C&D) Debris Sorting Facilities and the reuse store at the Sacramento Recycling and Transfer Station.

Policy PFS-5.6 Bulky Item and Appliance Disposal. The City shall continue to provide programs that allow residential households to schedule two appointments per year for the collection of large refuse items.

Policy PFS-5.8 Household Hazardous Waste Disposal. The City shall continue to promote the safe disposal of household hazardous waste, e-waste, and batteries through public education.

1. Description, Level, and Range of Services to be Extended to the Project Site
Solid waste from the City is disposed of at the SRTS, NARS, Sacramento County Kiefer Landfill, as well as other facilities, including the Yolo County Central Landfill, L and D Landfill, the Florin Perkins Public Disposal Site, and the Elder Creek Transfer Station. The Kiefer Landfill is the primary location for the City of Sacramento’s disposal of solid waste.

The waste delivered to the landfill is from municipal and industrial sources, with an average of approximately 6,300 tons per day accepted. According to the California Department of Resources Recycling and Recovery (CalRecycle), the Kiefer Landfill is permitted to accept a maximum of 117,400,000 cubic yards of waste.9 The landfill has a remaining capacity of 112,900,000 cubic yards and is anticipated to cease operations by 2064.

Overall, following development of project site , the proposed project would result in a maximum building square footage of 6,707,500 sf. According to the U.S. Environmental Protection Agency (USEPA) report, Estimating 2003 Building-Related Construction and Demolition Materials Amounts, non-residential construction activities generate an average

9 California Department of Resources Recycling and Recovery. SWIS Facility/Site Activity Details Sacramento County Landfill (Kiefer) (34-AA-0001). Available at:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2070?siteID=2507. Accessed August 2023.

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of 4.34 pounds per square foot (lbs/sf) of waste.10 Therefore, applying such an amount to buildout of the proposed project would produce approximately 29,110,550 lbs (14,555.3 tons) of construction waste (4.34 lbs/sf X 6,707,500 sf).

The construction waste estimate presented above represents a conservative analysis of the maximum potential waste production from construction of the proposed project. The California Green Building Standards Code, otherwise known as the CALGreen Code , requires at least 65 percent diversion of construction waste for projects permitted after January 1, 2017. As such, a minimum of 9,460.9 tons of waste would be diverted away from landfill disposal during construction. Considering the applicable CALGreen Code requirements, buildout of the proposed project would be anticipated to produce up to 5,094.4 tons of waste during construction. In addition, construction waste would be generated as part of installation of the proposed off -site force main. Construction waste generation represents a short -term increase in waste generation. Considering that the Kiefer Landfill has a remaining capacity of 96.1 percent of the total permitted capacity of the landfill, the proposed project’s construction waste would represent only an incremental contribution to the waste received at the landfill.

Operational solid waste generation from the proposed project has been estimated based on an average waste generation rate for employees of industrial uses , as published by CalRecycle.11 The total number of employees would produce approximately 35,720 lbs/day (17.86 tons/day) of operational solid waste. The Kiefer Landfill has a permitted throughput of 10,815 tons/day. Considering that the landfill currently accepts 6,300 tons/day, the landfill would be able to accommodate the operational waste generated by the proposed project. In addition, c onsidering that the Kiefer Landfill has a remaining capacity of 96.1 percent, the proposed project’s operational waste would represent only an incremental contribution to the waste received at the landfill.

Based on the above, the proposed project would not generate solid waste in excess of the capacity of local infrastructure.

3. An Indication of When the Services Can Feasibly be Extended to the Affected Territory
Solid waste service to the proposed project would be provided consistent with buildout of the project site with the proposed uses.

4. Information with Respect to How the Services will be Financed Solid waste services are funded through user fees. Waste collection services w ould be incrementally expanded throughout the course of buildout of the project site. Additional funding and financing information related to solid waste services that would be provided

10 U.S. Environmental Protection Agency. Estimating 2003 Building-Related Construction and Demolition Materials Amounts. 2009.
11 California Department of Resources Recycling and Recovery. Estimated Solid Waste Generation Rates. Available at: https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed June 2023.

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to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XIV. STORM DRAINAGE AND FLOOD CONTROL
The Natomas Basin comprises approximately 50,000 acres spanning northwestern Sacramento County and southwestern Sutter County, and is protected by a levee system under the jurisdiction of the U.S. Army Corps of Engineers (USACE). The levees surrounding the Natomas Basin were decertified by the USACE in December 2008. After that date, the Sacramento Area Flood Control Agency (SAFCA), the USACE, and the State of California have been, and currently are, working together to fund, design and construct levee improvements to provide 200-year protection to the Natomas Basin. Over 50 percent of the levee improvements have been constructed, and 100 percent of the funding has been allocated by local, State, and federal agencies to complete all of the levee improvements.

The City of Sacramento is divided into approximately 120 drainage basins. Drainage from most of the basins flows to local rivers or creeks or drainage channels through pumping. The City owns and operates 105 storm drainage pumping stations throughout the City. The drainage canals and local creeks eventually drain into the Sacramento and American rivers. In the vicinity of the project site, Reclamation District (RD) 1000 owns and operates the existing canals and pumping plants that move storm drainage from the local area to the Sacramento River. RD 1000 collects all runoff within the Natomas Basin through a system of interconnected channels and directs this runoff to pumping plants in order to lift the water into the leveed rivers and channels surrounding Natomas.

The existing regional drainage facilities are shown in Figure 6. Off-site runoff within the project vicinity enters the project site along the RD 1000 L Drain of the Lone Tree Canal that flows south through three eight-foot by five-foot box culverts under I-5 (directly north of the project site). Within the project site, the RD 1000 L Drain of the Lone Tree Canal bisects the easterly third of the site from the remainder of the site. The RD 1000 L Drain flows south to join the West Drainage Canal that is located along the southern boundary of the project site.

At the confluence of the Lone Tree Canal and the West Drainage Canal, drainage runoff either flows east and south toward Pumping Plant 3 on the Sacramento River, or west and northwest toward Pumping Plant 5 on the Sacramento River. It should be noted that the RD 1000 system in the Lone Tree Canal and West Drainage Canal is operated with a permanent backwater condition whereby the canals contain water at all times of the year. Other than the existing RD 1000 ditches and canals discussed above, the project site does not contain internal drainage system facilities.

Peak flows within the West Drainage Canal downstream of the RD 1000 L Drain and West Drainage Canal confluence are currently 465.5 cubic feet per second (cfs). Water surface elevations within the connecting channel just upstream of Pumping Plant 3 are currently 13.789 feet and water surface elevations within the channel upstream of Pumping Plant 5 are currently

14.589 feet.

According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) for the project area, the entirety of the project site is located within Zone A, which is designated as a Special Flood Hazard Area (SFHA) (see Figure 7). However, it should be noted that due to the levee improvements described above, portions of the Natomas Basin are now classified as A-99 flood zones, including the eastern portion of the project site.

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Figure 6
Regional Drainage Facilities

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Figure 7
Project Area Federal Emergency Management Agency Flood Insurance Rate Map

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A-99 is an interim designation that allows new development to proceed without elevation verification while the improvements needed to provide 100-year protection are under construction.

However, the A-99 flood zone is still a SFHA until construction of the levees is complete, and the levees are certified by FEMA.

In addition to the goals and policies listed above related to utilities in general, t he City of Sacramento 2040 General Plan contains guiding goals and policies related to storm drainage applicable to the proposed project, which are presented below.

Public Facilities and Safety Element
Goal PFS-3 Efficient, high -quality utility infrastructure and services to meet the needs of residents and business throughout the city.

Policy PFS-3.15 Adequate Drainage Facilities. The City shall ensure that all new municipal drainage facilities are adequately sized and constructed to accommodate stormwater runoff, including incorporating “green infrastructure” design and Low Impact Development (LID) techniques, where appropriate, stormwater treatment features, and, if applicable, trash capture devices for its stormwater facilities.

Policy PFS-3.16 Stormwater Design in Private Development. The City shall require proponents of new development and redevelopment projects to submit drainage studies that adhere to City stormwater design requirements and incorporate measures, including “green infrastructure”, Low Impact Development (LID) techniques, stormwater treatment, and, if applicable, trash capture devices, to prevent on- or off-site flooding and improve runoff water quality.

Policy PFS-3.17 Regional Stormwater Facilities. The City shall coordinate efforts with Sacramento County and other agencies in the development of regional stormwater facilities.

1. Description, Level, and Range of Services to be Extended to the Project Site
Development of the proposed project would result in the conversion of a rural area to an industrial park , which would include the development of industrial uses, as well as retail/highway commercial uses within the project site. According to the Preliminary Drainage Study prepared for the proposed project by Wood Rodgers (see Attachment E of this Plan for Services) ,12 the proposed project would include an on -site storm drain system composed of post-construction stormwater quality measures such as Low Impact Development (LID) features, dedication of landscaping areas, and six on-site detention basins that would be designed consistent with the Sacramento Region Stormwater Quality Design Manual.

Impervious surfaces proposed as part of the project include building roofs, driveways, and roadways. Runoff from such surfaces would be captured by the on -site stormwater

12 Wood Rodgers. Airport South Industrial Preliminary Drainage Study. October 11, 2023.

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drainage system. The on -site drainage system would consist of a series of detention basins located adjacent to the RD 1000 ditches and canals that border the western and southern boundaries of the project site, and areas adjacent to the RD 1000 L Drain (which bisects the eastern portion of the project site) (see Figure 8). The basins would each be interconnected with 36 -inch diameter culvert(s) or larger in order to provide a single continuous system. The basins would be connected to the RD 1000 system through weirs to meet the pre -project spill conditions and to provide on-site floodplain storage (see Figure 9).

The on-site stormwater drainage system would be controlled by a pump station currently planned to be located near the intersection of the RD 1000 L Drain and the proposed Airport South Industrial Drive. The pump station discharge capacity would be 35 cfs, modeled as two 17.5-cfs pumps.

A low-flow pump may also be incorporated to maintain the flood control depth needed in the basin for the winter months, or as needed to keep the basins drawn down in the summer months. Low flow pumps are typically not operated during flood control operations. The two basin areas on the east side of the RD 1000 L Drain would interconnect from south to north.

The north basin would then connect to the proposed drainage pump station through a pipe crossing under the RD 1000 L Drain, and a box structure and manhole/vault on each side of the RD 1000 L Drain, prior to a connection to the proposed pump station. Trash capture is anticipated to be achievable at the inlet to the pump station through screen mechanisms or mesh bags. The proposed on-site stormwater drainage system is a closed system that would only experience external influences during larger events like th e 100-year event.

Therefore, 10-year system modeling and design is anticipated to be significantly lower than 100-year levels. The approximate volumes for pre-project and post-project detention during the 100-year storm event are presented in Table 5. As shown therein, the proposed LID features would be sufficiently sized to meet the required storage volumes. Thus, project runoff would be properly treated, and would not pollute downstream waterways.

In order to ensure continued operation of the proposed LID control features, a detailed site-specific inspection and maintenance procedures plan would be prepared by the project applicant , as required by Mitigation Measure 4.8 -2 of the EIR . As part of the inspection and maintenance procedures plan, plants and vegetation within the detention basins would be inspected monthly and the basins would be inspected for the presence of standing water 72 hours after rain events. Required maintenance activity would include, but not necessarily be limited to, removal of debris from basins and removal of debris from outlets of basins. In addition, a ny method of trash capture w ould require frequent monitoring and cleaning to keep the pump station fully operational.

In addition, to assess the changes in runoff volumes from the project site that could occur due to the proposed project, Wood Rodgers calculated the pre - and post-construction water surface elevations (WSEs) at key locations within the project site’s drainage shed.

Pre- and post-construction WSEs are presented in Table 6. It should also be noted that peak flows within the West Drainage Canal downstream of the RD 1000 L Drain and West Drainage Canal confluence decrease slightly from pre -project to post-project conditions, from 465.5 cfs to 461.7 cfs.

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Figure 8
Proposed On-Site Drainage Conditions

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Figure 9
Post-Project Drainage Conditions Within the Project Area

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Table 5
Proposed Detention Basin Sizing
Property
Owner Acreage
Pre-Project
Acreage within
100-Year
Floodplain
Pre-Project
Maximum
Water Volume
Stored During
100-Year Event
(acre feet)
Post-Project
Maximum
Water Volume
Stored During
100-Year Event
(acre feet)
North Pointe AKT 353.5 308.8 174.6 362.3
Cayocca* 64.3 37.1 18.4 75.0
Campbell* 6.5 6.5 3.5 1.8
Isgur* 4.6 4.6 2.5 1.3
Patel* 0.7 0.3 0.3 0.2
Caltrans Remnant* 6.9 6.8 3.7 1.9
Total 436.5 364.1 203.0 442.5
Note: Some of the maximum water volumes reported in the table above were obtained by dividing model results by property owner boundaries, rather than watershed and/or development boundaries. An area weighting method was used to aggregate and divide post -project storage volume on a property owner basis for the Campbell, Isgur and Patel properties that share a single detention basin.

* At the time of the Preliminary Drainage Study was prepared, preliminary on -site grading has not been assessed. Detention volumes are preliminary.

Source: Wood Rodgers, 2023.

Water surface elevations within the connecting channel just upstream of Pumping Plant 3 also decrease from 13.789 feet to 13.764 feet, and w ater surface elevations within the channel upstream of Pumping Plant 5 decrease from 14.589 feet to 14.550 feet during post-project conditions . As shown in the table, the proposed project would result in reduced WSEs relative to existing conditions for the design-storm event (i.e., the 100-year storm event).

Based on the above , the proposed project would be consistent with applicable hydromodification requirements and would not increase the rate or amount of runoff leaving the project site during the design storm event. An exhaustive evaluation to determine the exact peak pumping rate that would create an increase in the RD 1000 system was not conducted as part of the Preliminary Drainage Report; however, pumping may be determined to exceed 35 cfs during final design, making the on -site detention system operate even more effectively . Increased pumping could potentially allow for a smaller detention volume after final design features, such as inlet/outlet access ramps and encroachments, are fully accounted for during the improvement plan process.

While the worst case 100 -year flooding in the RD 1000 system occurs during a 10 -day duration storm event, different parts of the system may behave differently under shorter duration rainfall conditions. As such, Wood Rogers also evaluated the drainage system during 100-year, 24-hour rainfall conditions to verify whether the higher intensity rainfall patterns occurring in a 24 -hour duration storm would produce a higher on -site peak condition in the detention basin system. Based on the Wood Rogers analysis, w hile the RD 1000 system would still produce elevated channel levels high enough to spill into the project site during the 100-year 24-hour event, the resulting peak stage in the proposed on-site detention basin would be 11.2 feet, which is more than 2.6 feet lower than the peak Airport South Industrial Project
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stage during the 10 -day storm event. Finally, the outflow that would occur during post - project conditions closely mirrors the existing conditions of the project site. Thus, the proposed drainage system would not result in extensive period of standing water in the basins.

Table 6
Pre- and Post-Project Peak Flow Elevations
Location
Model
Node
Name
COSD NAVD 88
Pre-
Project
Model
WSE
(feet)
Post-
Project
Model
WSE
(feet)
Pre-
Project
Model
WSE
(feet)
Post-
Project
Model
WSE
(feet)
Western Development
Storage Node 1132 12.201 11.86 14.182 13.841
Northern Portion of Eastern
Development Storage Node
Proposed
Development - 11.903 - 13.884
Patel, Isgur, Campbell, and
Caltrans Remnant Node 317 - 11.861 - 13.842
Cayocca Storage Node 11215 12.209 12.052 14.19 14.033
RD 1000 L Drain –
Downstream of I-5 11536 12.579 12.353 14.56 14.334
RD 1000 L Drain – New
Node to Connect New
Pump to the RD 1000 L
Drain
Node 316 - 12.071 - 14.052
RD 1000 L Drain – New
Node to Connect Eastern
Development to the RD
1000 L Drain
Node 314 - 12.066 - 14.047
RD 1000 L Drain and West
Drainage Canal Confluence 167 12.198 11.986 14.179 13.967 West Drainage Canal and
Reach 6 Confluence 1103 12.219 12.018 14.2 14.002
West Drainage Canal –
Node to Connect Western
Development and West
Drainage Canal
166 12.198 11.972 14.179 13.953
West Drainage Canal -
Upstream of Del Paso Road 11013 12.071 11.878 14.052 13.862 Source: Wood Rodgers, 2023.

2. An Indication of Any Improvement or Upgrade of Facilities and Other Conditions the City Would Impose or Require Within the Affected Territory if the Reorganization is Completed
Specific improvements necessary to storm drainage service have been detailed in the Preliminary Drainage Study prepared for the proposed project by Wood Rodgers.

3. An Indication of When the Services Can Feasibly be Extended to the Affected Territory
Storm drainage service to the proposed project would be provided consistent with buildout of the project site with the proposed uses.

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4. Information with Respect to How the Services will be Financed The developer will construct the proposed drainage facilities . In addition, the proposed project would be subject to the RD 1000 development impact fee and stormwater fee to ensure the project contributes a fair share toward improvements to the RD 1000 storm drain system. Additional f unding and financing information related to storm drainage services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XV. PARKS AND RECREATION
The City of Sacramento maintains a network of parks, open spaces, and recreation areas that contribute to the identity and character of the City’s neighborhoods and urban areas. Park and tree maintenance is managed by the City’s Youth, Parks, and Community Enrichment Department, which also directs future park design and planning, administrative services, marketing, recreation and human services, and special events.

Approximately 4,360 acres of parks, parkways, open space, community centers, aquatic facilities, and bike trails are accessible to Sacramento residents at more than 234 sites, which includes 218 parks, recreation, parkway , and open space sites ; 21 lakes, ponds , and beaches; 17 aquatic facilities; 13 community centers ; and approximately 115 miles of shared -use paths , including extensive river parkways along the Sacramento and American rivers. Parks in Sacramento range in size between 0.1-acre and 625 acres and are interwoven with urban areas and neighborhoods.

Citywide parks are equipped with a variety of amenities, includ ing 127 soccer fields, 138 group picnic areas, seventeen pools, and 213 play structures. Park types within the City of Sacramento include the following:

• Neighborhood Parks: The City’s neighborhood parks range in size between two and 10 acres and each serve a 0.5-mile radius. Some facilities are located adjacent to elementary schools where park programming can be oriented to the recreational needs of children.

Other neighborhood-serving park types include urban plazas and pocket parks, which are strictly less than five acres in size and typically placed in the urban core. • Community Parks: Community parks are generally six to 60 acres in size and provide a broader range of amenities for several neighborhoods within a three -mile radius. In addition to the types of amenities provided at neighborhood parks, community parks are sized to provid e additional amenities such as restrooms, on -site parking, community centers, swimming pools, lighted sports fields or courts, and/or other specialized facilities. • Citywide/Regional Parks: Citywide/regional parks are generally 75 to 200 acres in size and are intended to serve the City. Citywide/regional parks typically incorporate amenities that are not found in smaller neighborhood or community parks and may include facilities such as golf courses, aquatic centers, marinas, amusement areas, nature areas, and/or shared-use trails. Parkways are also included in the classification and typically consist of linear, narrow corridors with limited recreational uses that are p rimarily used for pedestrian/bicycle linkages between residential neighborhoods, schools, parks, and shopping areas.
• Open Space and Shared-Use Paths: The City’s open space and shared-use paths are for natural areas within the City that are used to protect environmental amenities, such as native plant communities or wildlife habitat. Open space areas generally have limited recreational use. While classified separately, parkways are similar to the open space classification, due to their limited recreational use and design.

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The nearest park to the project site is Egret Park, which is located immediately to the east of the site within the Westlake Subdivision community. In accordance with Sacramento City Code Section 18.56.230, new development within the City is required to pay a Park Development Impact Fee prior to issuance of a building permit. Revenues generated through the Park Development Impact Fee pay for any new park facilities deemed necessary by the City, including the design, construction, installation, improvement, and acquisition of park facilities for neighborhood parks within two miles of a project site, community parks within five miles of a site, and regional and citywide park facilities located anywhere in the City.

In addition, the City of Sacramento Parks and Recreation Master Plan 2005 -2010, which establishes policies to guide decision -making by City staff and officials related to park facilities, identifies growth opportunity areas, the closest of which to the pro ject site is the City -approved Northlake (Greenbriar) subdivision, to the north of the site, across I-5. The Parks and Recreation Master Plan does not identify parks and recreation growth opportunity areas within the project site, as the site is currently within the unincorporated portion of Sacramento County. The nearest park facility within the unincorporated County to the project site is the Teal Bend Golf Club, located

2.4 miles to the northwest of the project site.

The City of Sacramento 2040 General Plan contains guiding goals and policies related to park and recreation facilities applicable to the proposed project, which are presented below.

Youth, Parks, Recreation, and Open Space Element
Goal YPRO-1 An integrated system of parks, open space areas, shared -use paths, and recreational facilities that are welcoming, well-maintained, safe, and accessible to all the diverse communities of Sacramento.

Policy YPRO-1.1 Range of Experiences. The City shall provide a range of parks and recreational facilities and strive to ensure an equitable distribution of high-quality facilities throughout Sacramento.

Policy YPRO-1.3 Parkland Service Standard. The City shall evaluate, as needed, the equitable increase of public park acreage to serve the needs of the current and future residents with high -quality facilities. The City shall continue to strive to achieve a parkland service standard of 8.5 acres of parkland per 1,000 residents, which includes neighborhood parks, community parks, regional parks, open space, and parkways.

Policy YPRO-1.4 Parkland Dedication Requirements. The City shall continue to require that new residential development projects contribute toward the provision of adequate parks and recreational facilities to serve the new residents, either through the dedication of parkland, the construction of public and/or private recreation facilities, or the payment of parkland in -lieu fees, consistent with the Quimby Ordinance. To achieve the level of service for all parkland in all areas of the city, the City shall seek other funding resources to prioritize park needs in park deficit areas.

Policy YPRO-1.7 Co-Located Joint -Use Facilities. The City shall continue to facilitate the development of new parks or expansion of existing Airport South Industrial Project
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parks and recreational facilities by co-locating with and joint use of new or existing public and institutional facilities (e.g., schools, libraries, cultural facilities, and stormwater detention basins) in order to efficiently provide for community needs and offset operations and maintenance costs, prioritizing disadvantaged communities with an existing deficit of park or recreation facilities.

Policy YPRO-1.9 Timing of Services. The City shall monitor the pace and location of new development through the development review process and long-range planning efforts to strive to ensure that development of parks, recreation programming, and
community-serving facilities and services keeps pace with growth.

Policy YPRO1.27 Fee Benchmarking. The City shall periodically review Quimby inlieu parkland dedication fees, park development impact fees, application review fees, and user fees and charges to ensure they are adequately providing for community needs and are competitive within the region.

1. Description, Level, and Range of Services to be Extended to the Project Site
The proposed project primarily consists of industrial uses, with a limited number of commercial uses also proposed. Thus, the project would not be anticipated to generate a substantial amount of new population within the City of Sacramento, as the project does not include new residential units and the majority of jobs created by the project would be filled primarily by those already residing within the region. Therefore, the proposed project would not be expected to substantially increase demand for park services provided by the Youth, Parks, and Community Enrichment Department . Similarly, the proposed pro ject would not be anticipated to result in a substantial increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of an existing recreational facility would occur or be accelerated.

2. An Indication of Any Improvement or Upgrade of Facilities and Other Conditions the City Would Impose or Require Within the Affected Territory if the Reorganization is Completed
The proposed project consists of industrial and commercial development that is not anticipated to affect capacity or demand for park and recreation facilities in the City of Sacramento. Improvements to park and recreation facilities in the City w ould not be necessary as a result of the proposed project.

3. Information with Respect to How the Services will be Financed In accordance with Sacramento City Code Section 18.56.230, the proposed project would be subject to payment of the City’s Park Development Impact Fee prior to issuance of a building permit . Revenues generated through the project’s payment of the Park Development Impact Fee would ensure the project contributes a fair share to the construction or expansion of any new park facilities deemed necessary by the City, which would be required to be constructed in accordance with applicable policies, regulations, and standards. Additional funding and financing information related to park and recreation Airport South Industrial Project
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services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

XVI. LIBRARIES
The Sacramento Public Library (SPL) serves the cities of Sacramento, Citrus Heights, Elk Grove, Galt, Iselton, Rancho Cordova, and the County of Sacramento. The SPL authority is governed by a Joint Exercise of Powers Agreement between the cities and County to provide public library services to all citizens in the combined jurisdiction. Currently, SPL operates a total of 27 branches, including 11 branches within the City of Sacramento and 16 branches in other cities and throughout Sacramento County. 13 SPL also operates a bookmobile. Residents of Sacramento County have access to all library branches both inside and outside the City of Sacramento. In addition, 16 new libraries are planned for construction in the City and County of Sacramento by 2025. Based on plans set forth in the SPL Authority Facility Master Plan, the SPL expects to provide 1,007,274 sf of library space throughout the SPL’s service area by 2025. The North Natomas Public Library is the closest SPL branch to the project site and is located approximately

2.5 miles to the east of the site at 4660 Via Ingoglia Street.

The City of Sacramento 2040 General Plan contains guiding goals and policies related to libraries applicable to the proposed project, which are presented below.

Youth, Parks, Recreation, and Open Space Element
Goal YPRO-2 Public facilities located, designed, and programmed to make a vital contribution to neighborhood quality of life.

Policy YPRO-2.4 Library Services. The City shall work with the Sacramento Public Library Authority to ensure adequate library services and facilities are maintained for all residents and promote the siting of facilities in accessible locations with the greatest potential for positive neighborhood impact.

Improvements to library facilities in the City w ould not be necessary as a result of the proposed project.

13 Sacramento Public Library. Locations. Available at: https://www.saclibrary.org/Locations. Accessed February 2024.

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3. Information with Respect to How the Services will be Financed A total of 16 new libraries are planned for construction in the City and County of Sacramento by 2025. Based on plans set forth in the SPL Authority Facility Master Plan, the SPL already expects to provide 1,007,274 sf of library space throughout the SPL’s service area by 2025. Thus, any new residents within the Sacramento region indirec tly induced by the proposed project’s permanent employment positions would reasonably be assumed to not result in the need for new or physically altered SPL facilities to meet performance objectives. Additional f unding and financing information related to library services that would be provided to the proposed project is detailed in the Targeted MSR in the “Financial Ability to Provide Services” section.

Airport South Industrial Project
Final Environmental Impact Report

Errata Sheet
May 2025

Introduction

In the time since the environmental analysis for the Airport South Industrial Project was published, the legal protection status of the burrowing owl was revised, and minor administrative clarifications in the text of the environmental analysis were identified. This Errat a presents the revisions to the Airport South Industrial Project Final Environmental Impact Report (EIR) .

Revisions to the Final EIR text are presented in strike -through and double-underline format, and new revisions to the Draft EIR text are highlighted. The revisions to the Final EIR reflected in this Errata are meant to address minor administrative clarifications in the Final EIR text and the current status of the burrowing owl, and do not affect the adequacy of the previous environmental analysis contained in the Airport South Industrial Project Final EIR . Because the changes presented below would not result in any new significant impacts or increase in impact significance from what was identified in the Final EIR , recirculation of the Airport South Industrial Project Final EIR is not required.

The burrowing owl was designated as a candidate species under the California Endangered Species Act (CESA) on October 24, 2024, subsequent to when the Notice of Preparation (NOP) and Draft EIR for the Airport South Industrial Project were published. While the protected status of any species could change over time, even following the certification of an EIR, compliance with the requirements established by CESA would ensure adequate protection of such species at the time that development would occur. Furthermore, because burrowing owl is currently only a candidate species under CESA, it is unknown if, at the time of initiation of construction activities, the species will be officially protected under CESA or not. With respect to burrowing owl in the context of the Airport South Industrial Project, implementation of Mitigation Measure

4.4-6 would require a preconstruction survey for the presence of the species, and appropriate actions should burrowing owl be found, pursuant to Natomas Basin Habitat Conservation Plan (HCP) Take Avoidance, Minimization, and Mitigation Measures. Furthermore, Mitigation Measure 4.4 -5(b), as amended on page 2-27 of the Final EIR, addresses potential impacts to Swainson’s hawk by requiring, in part, that, prior to the issuance of any grading permit and commencement of project -related ground- disturbing activities outside of the Natomas Basin HCP permit area, the project applicant would consult with CDFW for a Section 2081 Incidental Take Permit, demonstrate to the City that none was required by CDFW, or pay fees (and dedicate land as applicable) under the Natomas Basin HCP if a portion of the City’s surplus HCP coverage is made available to the proposed project. Such mitigation would not only apply to the protection of Swainson’s hawk, but would apply to any species encountered on- site that is protected under CESA. As such, the existing mitigation included in the Final EIR adequately addresses potential impacts to special -status species that could occur on -site, including burrowing owl. No netheless, the Final EIR has been updated to reflect the status of the burrowing owl, and specifically reference Mitigation Measure 4.4 -5(b) as it relates to burrowing owl.

Along with the changed status of the burrowing owl, another change relevant to the Airport South Industrial Project that has occurred since the Draft EIR was published is the completed drafting of the Development Agreement for the project. As defined in Section 18.16.020 of the City’s Municipal Code, the Development Agreement allow s the City and the applicant to enter into an agreement to assure the City that the proposed project would be completed in compliance with the plans submitted by the applicant and assure the applicant of vested rights to develop the project. The Development Agreement was listed as an entitlement of the Airport South Industrial Project and was generally analyzed as part of the Draft EIR with the anticipa tion that the Development Agreement would not include any improvements that could result in physical impacts to the environment beyond what was included in the Draft EIR. Now that the Development Agreement has been finalized and is available for review, the conclusion that additional physical impacts to the environment would not occur beyond what was analyzed in the Draft EIR has been confirmed. As such, approval of the Development Agreement would not warrant further CEQA review beyond what is already included in the Draft EIR.

For clarification and disclosure purposes, the Final EIR has been updated to reflect the status of the burrowing owl, as well as to address other administrative clarifications.

Changes to the Final EIR text

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Mitigation Measure 4.4-4(b) is hereby revised as follows:

Industrial Park and Nonparticipating Parcels

4.4-4(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance,
Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.j:

1. Take of the northwestern pond turtle as a result of
habitat destruction during construction activities,
including the removal of irrigation ditches and drains, and during ditch and drain maintenance, will be
minimized by the dewatering requirement described
above for giant garter snake (see Section 5.a.(3)).

4.4-4(b) Implement Mitigation Measures 4.4-1(a), 4.4-3(a), and 4.4-3(b).

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Mitigation Measure 4.4-4(b), on page 4.4-50 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:

Industrial Park and Nonparticipating Parcels

Natomas Basin HCP Section V.A.5.j:

2. Take of the northwestern pond turtle as a result of
habitat destruction during construction activities,
including the removal of irrigation ditches and drains, and during ditch and drain maintenance, will be
minimized by the dewatering requirement described
above for giant garter snake (see Section 5.a.(3)).

4.4-4(b) Implement Mitigation Measures 4.4-1(a), 4.4-3(a), and 4.4-3(b).

[…]

Mitigation Measure 4.4- 6, beginning on page 4.4 -54 of Chapter 4.4, Biological Resources, of the Draft EIR is hereby revised as follows:

Industrial Park and Nonparticipating Parcels

4.4-6 Prior to the issuance of any grading permit and commencement of ground -disturbing activities , the project applicant shall comply with applicable portions of Measure 4.4- 5(b) regarding consultation with CDFW , demonstration that no incidental take permit was required, or payment of fees (with or without land dedication as applicable) under the Natomas Basin HCP and shall ensure that the following Natomas Basin HCP Take
Avoidance, Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.h:

1. Prior to the initiation of grading or earth disturbing activities, the applicant/developer shall hire a CDFG
approved qualified biologist to perform a pre -
construction survey of the site to determine if any
burrowing owls are using the site for foraging or
nesting. The pre -construction survey shall be submitted to the City prior to the developer’s commencement of
construction activities and a mitigation program shall be developed and agreed to by the City and developer prior to initiation of any physical disturbance on the site.

2. Occupied burrows shall not be disturbed during nesting season (February 1 through August 31) unless a
qualified biologist approved by the CDFG verifies
through non-invasive measures that either: 1) the birds have not begun egg -laying and incubation; or 2) that
juveniles from the occupied burrows are foraging
independently and are capable of independent survival.

3. If nest sites are found, the USFWS and CDFG shall be contacted regarding suitable mitigation measures, which may include a 300 foot buffer from the nest site during the breeding season (February 1 - August 31), or a
relocation effort for the burrowing owls if the birds have not begun egg- laying and incubation or the juveniles
from the occupied burrows are foraging independently
and are capable of independent survival. If on -site
avoidance is required, the location of the buffer zone
will be determined by a qualified biologist. The
developer shall mark the limit of the buffer zone with
yellow caution tape, stakes, or temporary fencing. The
buffer will be maintained throughout the construction
period.

4. If relocation of the owls is approved for the site by USFWS and CDFG, the developer shall hire a qualified
biologist to prepare a plan for relocating the owls to a suitable site. The relocation plan must include: (a) the location of the nest and owls proposed for relocation;
(b) the location of the proposed relocation site; (c) the number of owls involved and the time of year when the
relocation is proposed to take place; (d) the name and
credentials of the biologist who will be retained to
supervise the r elocation; (e) the proposed method of
capture and transport for the owls to the new site; (f) a description of the site preparations at the relocation site (e.g., enhancement of existing burrows, creation of
artificial burrows, one -time or long -term vegetation
control, etc.); and (g) a description of efforts and
funding support proposed to monitor the relocation.

Relocation options may include passive relocation to
another area of the site not subject to disturbance
through one way doors on burrow openings, or
construction of artificial burrows in accordance with the CDFG’s October 17, 1995, Staff Report on Burrowing
Owls Mitigation (see Appendix D).

5. Where on -site avoidance is not possible, disturbance and/or destruction of burrows shall be offset through
development of suitable habitat on TNBC upland
reserves or in other suitable preserved uplands. Such
habitat shall include creation of new burrows with
adequate foraging area (a minimum of 6.5 acres) or 300
feet radii around the newly created burrows. Additional habitat design and mitigation measures are described in CDFW’s March 7, 2012, Staff Report on Burrowing Owl
Mitigation.

The above modification is for clarification purposes only and does not change the analysis or conclusions of the Final EIR.

Airport South Industrial Project
Final Environmental Impact Report

Errata

(October 13, 2025)

Introduction

Since the City of Sacramento published the Final Environmental Impact Report for the Airport South Industrial Project (ASI Project) , the City identified minor revisions and clarifications to the text of the ASI Project Final EIR . This Errata presents the minor clarifications and text revisions to the Airport South Industrial Project Final Environmental Impact Report (EIR).

Revisions to the Draft EIR text that were included in the Final EIR are presented in double- underline format, and new revisions to the Draft EIR text that are the subject of this errata are presented in double-underline format and are highlighted. The revisions to the Final EIR reflected in this Errata are meant to address minor administrative edits and clarifications in the Final EIR text and do not affect the adequacy of the previous environmental analysis contained in the Airport South Industrial Project EIR. Because the changes presented below would not result in any new significant impacts or increase in impact significance from the impacts evaluated in the Draft EIR, recirculation of the Airport South Industrial Project EIR is not required.

Description of Clarifications to Final EIR Text

The following changes are added to the text revisions described in Chapter 3 of the Final EIR.

Chapter 3 Project Description

Page 3 ends

The following section is added before the Development Agreement, consistent with the discussion of the Airport South Industrial Project’s preserve sites set forth on page 2-24 and 3-2 of the Final EIR:

Off-Site Preserves
The ASI project applicant has voluntarily agreed to dedicate 117.59 acres of off-site lands to The Natomas Basin Conservancy (TNBC) for the purpose of preserving and managing open space/agricultural lands in accordance with the NBHCP. b. Off-site Agricultural/Open Space Requirements: The following Off Site Open Space properties:
• 141.51 acres of currently unidentified agricultural/open spaced mitigation property to be located in the unincorporated Sacramento County and/or unincorporated Sutter County.
• 50-acre habitat mitigation property APN 225-0020-014. • 67.59-acre habitat mitigation property APN 225-0020-015.

The two off-site habitat reserve sites consist of the 117.59 acre Rosa properties (APNs 225-020-015 and 225-020-014). The off-site dedication will complete a 400 -acre reserve for The Natomas Basin Conservancy (TNBC). The dedication of the Rosa properties will increase the size of the TNBC adjacent existing reserve.

Chapter 4.2 Agricultural Resources

Mitigation Measure 4.2-1, beginning on page 3-2 of the Final EIR, is hereby revised as follows:

Industrial Park

4.2-1 The City shall ensure that, prior to impacting agricultural/open space resources within the project site by the issuance of a grading permit, any and all project-related subdivision maps satisfy the On- Site Open Space and Off -Site Open Space requirements as defined herein. Open space dedications made pursuant to the Natomas Basin Habitat Conservation Plan (HCP) shall be made to the City and/or the Natomas Basin Conservancy and shall be located in the Natomas Basin. The remaining non-Natomas Basin HCP mitigation acreage may be located in unincorporated Sacramento County, Yolo County, and/or Sutter County, and may be held and managed by a qualified third- party entity with the approval of the City. Preservation shall be ensured in perpetuity via conservation easement, fee, or irrevocable offer of dedication to the satisfaction of the City. All mitigation acreage shall consist of land of comparable agricultural and habitat value as the agricultural/open space resources impacted by the proposed project, as determined by the City.

a. On-Site Agricultural/Open Space Requirements : The following on - site open space properties are consistent with the mitigation requirements:

• 86 acres of detention basins.
• 37.9 acres of freeway buffer.
• 2.3 acres of canal buffers.

b. Off-site Agricultural/Open Space Requirements: The following Off- Site Open Space properties shall be dedicated to The Natomas Basin Conservancy (TNBC):

• 141.51 acres of currently unidentified agricultural/open spaced mitigation property to be located in the
unincorporated Sacramento County and/or unincorporated
Sutter County.
• 50-acre habitat mitigation property APN 225-0020-014. • 67.59-acre habitat mitigation property APN 225-0020-015.

c. Phasing: The Airport South Industrial Project will develop in phases, as such, the amount of On- Site and Off -Site Open Space to be provided hereunder shall be in proportion to the amount of acreage proposed to be impacted by such development by the issuance of a grading permit therefor.

d. With respect to each unidentified open space property listed above, and any proposed substitution of an open space property listed above, the City must determine, in writing, that the proposed agricultural/open space property and/or acreage satisfies the requirements for agricultural/open space to be counted towards the requisite Off-Site Agricultural/Open Space acreage total.

e. Nothing in this Agricultural/Open Space Mitigation is intended to limit or restrict USFWS and CDFW in their consideration of Developer's applications for incidental take and/or other habitat mitigation permits or other entitlements under the federal Endangered Species Act and the California Endangered Species Act.

The above modification s are for clarification purposes only and do not change the analysis or conclusions of the EIR.

THE VOICE OF THE CONSTRUCTION INDUSTRY
THE ASSOCIATED GENERAL CONTRACTORS OF CALIFORNIA | AGC -CA.ORG

June 26th, 2025

City of Sacramento, Design Review Commission
815 I Street
Sacramento, CA 95814

RE: Support for the Airport South Industrial Project

Dear Chair Yeung and Members of the Commission,

On behalf of the Associated General Contractors of California (AGC), I am writing to express our strong support for the Airport South Industrial Project.

AGC represents approximately 1,000 contractor and associated construction members throughout the state. Our members build our state’s critical infrastructure and represents the full spectrum of the construction industry. We recognize the critical role that well-planned industrial development plays in driving economic growth and creating sustainable jobs in our region. The Airport South Industrial Project represents a significant investment in Sacramento County's future —one that will g enerate thousands of construction and permanent jobs, while enhancing the County’s competitiveness in logistics, manufacturing, and goods movement.

With direct access to key transportation corridors and proximity to Sacramento International Airport, this project is ideally located to attract new businesses and support long -term regional economic expansion. It will help address the growing demand for m odern industrial space while providing high -quality employment opportunities across a range of skill levels, including construction trades, operations, and facility management.

We urge the Commission to move this project forward and stand ready to support its timely development. This is the type of infrastructure investment that strengthens the local economy, broadens the tax base, and supports working families throughout the city of Sacramento.

Thank you for your consideration.

Sincerely,
Chris Smith
Senior Director, Government Affairs, Northern California Associated General Contractors of California

2025 EXECUTIVE

COMMITTEE

PRESIDENT
Pat Kelly
Granite Construction
Company

PRESIDENT-ELECT
Ryan Aukerman
Griffith Company

TREASURER
Allison Otto
Otto Construction

VICE PRESIDENT

BUILDING
Matt Seals
Seals Construction Inc.

VICE PRESIDENT

HIGHWAY &

TRANSPORTATION
Mary Teichert
Teichert Construction

VICE PRESIDENT

UTILITY &

INFRASTRUCTURE
Brandon Pensick
Ferreira Construction
Company

VICE PRESIDENT

SPECIALTY CONTRACTORS
Henry Nutt III
Southland Industries

IMMEDIATE PAST

PRESIDENT
Steve Rule
Turner Construction
Company

CEO
Peter Tateishi
AGC of California

HEADQUARTERS OFFICE
3095 Beacon Blvd.

West Sacramento, CA 95691
Ofﬁce: 916.371.2422
Fax: 916.371.2352
[email protected]

June 24, 2025

Planning & Design Commission
City of Sacramento
915 I Street
Sacramento, CA 95814

RE: Letter of Support - Airport South Industrial (ASI) Project

Dear Commissioners,
On behalf of the Sacramento Metro Chamber of Commerce and our member businesses throughout the City of Sacramento, we strongly support the proposed Airport South Industrial (ASI) Project located near the Metro Air Parkway interchange, south of Sacramento International Airport.

The ASI Project represents a transformational opportunity for the Sacramento region—one that directly supports the Metro Chamber’s mission to drive economic growth, attract private investment, and expand job opportunities across the capital region. With over 4.4 million square feet of Class A light industrial space and 100,000 square feet of commercial development, this phased project will serve as a hub for logistics, bioscience, research and development, and clean manufacturing.

The anticipated benefits are substantial:
• Over $700 million in annual economic impact once fully operational • More than 5,200 new jobs and $303 million in annual employee compensation • An estimated $541 million in construction revenue, including wages and benefits for over 3,400 construction jobs
• Critical infrastructure upgrades and traffic safety improvements that will enhance regional connectivity
• Thoughtful open space buffers that support stormwater management and natural habitat preservation

The Sacramento region faces a historically low industrial vacancy rate, currently around 5%. The ASI Project will help meet urgent demand for industrial space while supporting smart growth near existing transportation infrastructure.

We are especially encouraged by NorthPoint Development’s commitment to responsible development, strong community partnerships, and long-term stewardship. This project embodies the type of forward-looking investment that positions Sacramento for sustained prosperity, resilience, and economic leadership.

The Metro Chamber strongly urges your support for the Airport South Industrial Project, and we commend the development team for their thoughtful and impactful proposal.

Thank you for your consideration.

Sincerely,

Robert W. Heidt, Jr.

President & CEO
Sacramento Metropolitan Chamber of Commerce

10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Advocates for the Environment A non-profit public-interest law firm and environmental advocacy organization June 24, 2025 Scott Johnson Senior Planner City of Sacramento Development Department 300 Richards Boulevard, 3rd Floor Sacramento, CA 95811 Via U.S. Mail and email to [email protected] Re: Comments on Draft Environmental Impact Report for Airport South Industrial Project, SCH No. 2022030181 Dear Mr. Johnson: Advocates for the Environment submits the comments in this letter regarding the Draft Environmental Impact Report (DEIR) for Airport South Industrial Project (Project). The Project Site is located near the intersection of Southeast of Powerline Road and Interstate 5 in the City of Sacramento (City). The Project proposes to develop a 5,204,500 square-foot industrial park and 98,200 square feet of commercial uses, on the 353.5-acre Project Site. We have reviewed the DEIR prepared in May 2024 and submit comments regarding the sufficiency of the DEIR’s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA). On October 14, 2024, Advocates for the Environment submitted a comment letter regarding the Environmental Impact Report (EIR) for Airport South Industrial Project (Project). The Project Site is located near the intersection of Southeast of Powerline Road and Interstate 5 in the County of Sacramento. The Project proposes to develop a 5,204,500 square-foot industrial park and 98,200 square feet of commercial uses, on the 353.5-acre Project Site. This letter provides supplementary comments regarding the sufficiency of the EIR’s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA), and violations of CEQA related to the EIR preparation and approval process. These additional comments are intended to supplement, but not replace, the comments in our original comment letter. CEQA Requires a Single Lead Agency CEQA allows only one lead agency for a project. The lead agency is responsible for preparing the EIR and for making determinations on whether the project would have any significant environmental impacts. Proceeding with project approvals under the framework of more than one lead agency contradicts with the express procedures and requirements of CEQA and the CEQA Guidelines. The lead agency is the “public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect upon the environment.” (Public

City of Sacramento Community Development Department Page 2 CEQA Comments on Airport South Industrial Project June 24, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Resources Code Section 21067.) The project scope is relevant to the determination of an appropriate lead agency, because typically the agency with the highest degree of control over the project would be deemed the lead agency. The Project in its entirety includes construction of a large industrial park, which is the express project purpose and the primary focus of the EIR. LAFCo is only involved in the project to approve the Sphere of Influence Amendment and later, after the City’s approvals, annexation of the Project site into the City limits. The development Project as a whole involves many more approvals and agreements which would be carried out by the City. Thus, the City is the appropriate lead agency because it has the principal responsibility for carrying out and approving the Project. The City and LAFCo Entered into an Unlawful Agreement Assigning “Co-Lead Agencies” In the event that the CEQA Guidelines leave questions as to which responsible agency should be the lead agency, disputing agencies may submit a question to the Office of Planning and Research (OPR) for an official designation of the appropriate lead agency. The OPR did not assign an official designation, indicating that neither LAFCo nor the City undertook the procedure of submitting a question to OPR to assign a single lead agency to this Project. Violating CEQA’s requirement for a single lead agency to preside over a project, LAFCo and the City proceeded as co-lead agencies, as indicated by multiple references throughout the EIR and the Memorandum of Understanding (MOU), in which they unlawfully agreed to be co-lead agencies. While multiple agencies may voluntarily enter into an agreement to formally assign one of those two responsible agencies to be the lead agency for the project, there is no basis for entering an agreement to share the responsibility of the CEQA lead agency by acting as co-lead agencies. The MOU expresses the agencies’ joint intent that the City is responsible for addressing “environmental issues associated with applications related to all land use entitlements and reorganization requests, except for the Sphere of Influence Amendment,” which LAFCo is solely responsible for. Dividing the responsibility in this manner is essentially dividing the Project into two separate projects which share the same EIR. Based on the MOU, LAFCo would only need to be involved with the Sphere of Influence Amendment. Yet, during the public hearing at which the EIR was certified, LAFCo made findings that the EIR was adequate as to the entirety of the Project, even though it did not have sufficient involvement in the other aspects of the Project to be qualified to make those findings. Neither agency has taken full responsibility for the Project as a whole due to the agreement to divide responsibility between two aspects of the Project. The EIR Was Reviewed and Certified by an Inappropriate Lead Agency In circumstances where multiple agencies may be involved with a project, as here, CEQA Guidelines Sections 15050 and 15051 provide an outline for determining the appropriate lead agency.

City of Sacramento Community Development Department Page 3 CEQA Comments on Airport South Industrial Project June 24, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] LAFCo and the City did not adhere to these guidelines. LAFCo should not have approval authority as a lead agency because it is not the most appropriate lead agency under the CEQA Guidelines. One important factor of assigning a lead agency is identifying what type of entity will be carrying out the project. “If the project is to be carried out by a nongovernmental person or entity, the lead agency shall be the public agency with the greatest responsibility for supervising or approving the project as a whole.” (CEQA Guidelines Section 15051 (b).) While the approvals to the project involve multiple agencies, including the City and LAFCo, the Project construction and operation is to be carried out or delegated by the Applicant, a private, non-governmental entity. Therefore, Section 15051(b) of the CEQA Guidelines applies and the public agency with the greatest responsibility for the Project as a whole is the most appropriate lead agency. The public agency with the greatest responsibility for supervisor or approving the project as a whole is the City, because it would be responsible for the majority of the land use entitlements and applications related to the Project, whereas LAFCo would govern a single entitlement related to the Project. CEQA Guidelines Section 15051 (b)(1) provides further guidance, clarifying that the lead agency “will normally be the agency with general governmental powers, such as a city or county, rather than an agency with a single or limited purpose such as an air pollution control district or a district which will provide a public service or public utility to the project.” Accordingly, the City, as the involved governmental agency, is most fitting to be the lead agency in this circumstance. In comparison, LAFCo was developed with a limited purpose in mind, and is involved in this Project for the limited purpose to approve the Sphere of Influence Amendment and annexation, and would not oversee the Project as a whole. Additionally, the City has more pressure to approve the Project now that the EIR has already been certified and one of the Project’s entitlements has been approved. There is undue pressure on the City, the second reviewing agency, to continue with the project, because of the time and resources that has already been expended. This concern is particularly severe because LAFCo was primarily focused on the impacts of the Sphere of Influence Amendment rather than the environmental impacts of the entirety of the Project, so the first approval and certification of the EIR should not be valid in these circumstances. Overall, LAFCo was not an appropriate lead agency and should not have been granted the authority to certify the EIR and approve the Project. The City is the appropriate lead agency for the Project, and the failure to assign and proceed with the City as the sole lead agency caused inadequate review of the EIR and the impacts of the Project as a whole. Despite claiming co-lead agency status, LAFCo did not adequately consider the EIR in its entirety and the impacts of the Project as a whole at the Sphere of Influence Amendment hearing, because the unlawful agreement to sever lead agency responsibilities into two defined roles caused LAFCo to hone in on only one aspect of the Project.

City of Sacramento Community Development Department Page 4 CEQA Comments on Airport South Industrial Project June 24, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Preparing the EIR with Co-Lead Agencies Caused Deficiencies in the EIR The EIR should have been prepared by the City as the sole lead agency, with LAFCo serving as a responsible party for a limited preparation role of assisting in the areas related to the Sphere of Influence Amendment or any other entitlements under its supervision. The failure of either agency to take full accountability for the EIR creates the risk for gaps in analysis, evidence, and clarity because there is not a single agency overseeing the veracity of the EIR in its entirety. Thus, the unlawful co-lead agency designation could have resulted in the informational and substantive deficiencies in the EIR, such as the ones that were outlined in the comment letter sent to the City by Advocates for the Environment on October 14, 2024. In addition, the EIR was focused primarily on the development of the Project site, rather than the Sphere of Influence Amendment and the potential environmental effects. The Assignment of Co-Lead Agencies Convoluted the EIR Preparation and Approval Process CEQA’s requirement to assign a single lead agency ensures that a single entity takes full responsibility for an adequate EIR and fully considers the environmental consequences of the entirety of Project before approval and certification of the EIR. Proceeding with two lead agencies created a disorganized EIR preparation process, which caused the EIR to be inadequately prepared and reviewed. Each “co-lead agency” only took partial responsibility with respect to some aspects of the Project, and neither agency took full account for the Project as a whole. Even though the City is the most appropriate lead agency for this Project under the circumstances, appointing either one of the agencies to be the single lead agency would have resulted in a clearer CEQA process because there would be a single entity with full accountability for the contents and form of the EIR and CEQA findings. Information Provided to the State Clearinghouse Did Not Reflect Co-Lead Agencies Both LAFCo and the City assert claims as a lead agency for this Project, made clear by the Memorandum of Understanding in which the two entities agree to proceed with the Project as “co-lead agencies.” Yet, the Notice of Determination (NOD) does not mention the City as a co-lead agency. The NOD does not leave any space for identifying more than one lead agency because this is not warranted under CEQA. The Notice of Determination identifies LAFCo as the lead agency. However, this contradicts the information provided to the State Clearinghouse (SCH), which posts information on CEQA projects for public information and review on CEQAnet.1 On the 1 https://ceqanet.lci.ca.gov City of Sacramento Community Development Department Page 5 CEQA Comments on Airport South Industrial Project June 24, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] CEQAnet page dedicated to this Project, under “Contact Information,” only the City of Sacramento Community Development Department is listed as the agency name, with “Contact Types” designated as “Lead/Public Agency.”2 There is no contact for LAFCo or any other indication that the City would be sharing lead agency designation with LAFCo. Accordingly, Advocates for the Environment submitted a comment letter on the Project to Scott Johnson the listed contact and planner for the City. It is likely that many public commenters also submitted their CEQA comments to the City instead of LAFCo because of the lack of clarity about the lead agency. This likely deprived LAFCo of the opportunity to review all public comments before making the decision on Project approval. There is an Active CEQA Lawsuit over this Project On May 7, LAFCo certified the EIR and approved the Sphere of Influence Amendment—one of the Project’s required entitlements. Acting as the lead agency, and as the approval body, LAFCo filed a notice of determination (NOD) with the Sacramento County Recorder on May 9, effectively triggering the start of CEQA’s short 30-day statute of limitations period. If LAFCo was properly assigned as a responsible agency, rather than sharing approval authority as a “co-lead” agency, the May 7 approval of the Sphere of Influence amendment would not constitute a final approval and the CEQA start of the statute of limitations period would not be triggered until the City’s later certification of the EIR and approval of the Project, which is set for a hearing on June 26, 2025. In the context of CEQA review, the process of approvals by multiple decision-making bodies is manageable and straightforward when there is a single lead agency that is wholly responsible for the contents of the EIR, and how it pertains to the Project as a whole. Despite the unwarranted nature of having multiple lead agencies for the same project, Advocates for the Environment erred on the side of caution by filing a lawsuit on June 3, 2025, within 30 days of LAFCo’s filing of the NOD. The City should consider continuing the approval hearing for a later date after the active litigation has been resolved, in the event that more environmental review is required before carrying out the Project. There is some likelihood that litigation could potentially halt or significantly alter the Project, and delaying approval reduces the risk of unnecessary time and expense on a project which could later be changed. Conclusion LAFCo, acting as a “co-lead” agency, approved the Sphere of Influence Amendment and certified the EIR, triggering the start of the CEQA Statute of Limitations before the appropriate lead agency, the City, has finished considering and approving the Project. This procedure convolutes the process of exhausting administrative remedies and conflicts with CEQA procedural requirements of assigning a single lead agency. This failure to assign a single lead agency amounts to prejudicial 2 https://ceqanet.lci.ca.gov/2022030181/2 City of Sacramento Community Development Department Page 6 CEQA Comments on Airport South Industrial Project June 24, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] procedural error because it caused the agencies to proceed in a manner not allowable by CEQA, rendering the EIR wholly inadequate, warranting the Project entitlements and the EIR to be set invalidated. CEQA prohibits proceeding with project approvals by two lead agencies in the way that the City and LAFCo are attempting to do here. Some of the EIR’s inadequacies and deficiencies may be attributed to dividing the primary authority and responsibility of analyzing the Project’s impacts among multiple agencies, hindering the informative process that CEQA requires. Please notify Advocates for the Environment of any hearings or decisions for this Project. We make this request under Public Resources Code, section 21092.2. Sincerely, Dean Wallraff, Attorney at Law Executive Director, Advocates for the Environment Terms and ConditionsPrivacy PolicySupport powered by SpeakUp© 2025 Granicus

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Carlinn Reyes at May 22, 2025 at 10:02am PDT
As a resident who lives on Del Paso Road east of powerline Road, there has already been an increase in trafﬁc over the past 5 years and numerous accidents and increase of illegal dumping. There are people constantly racing down the street and going way faster than the speed limit. We keep building and building and loosing the natural habitat and beauty of the area. The deer have started moving out of the area which is sad and I get that turning it into warehouses brings jobs but if we don’t stop building there will be no farm land left. Please say No!
Saphire Xiong admin at May 22, 2025 at 9:56am PDT
Additional eComment received by the City Clerk's Ofﬁce.

Attachments: eComment_Item_06_Airport_South_Industrial_Annexation_-_PDC.pdf Oppose
Steve Schweigerdt at May 22, 2025 at 9:53am PDT
Decades of planning point to this land being preserved in agriculture - Natomas Basin Habitat Conservation Plan, SACOG Blueprint, Urban Service Boundary, General Plans, 2002 MOU.... Developers are betting that you'll disregard all of that and allow them to make a bundle by converting it into warehouses. Prove them wrong and follow the plans - deny the project.

Labor groups will speak in favor of the project saying it will give them good jobs to grow our economy. Thing is, they'll get those jobs no matter where the warehouses are built. Wouldn't it be better to invest in existing communities with vacancies and underdeveloped properties and grow the economy where it beneﬁts us instead of paving over more farmland? Landowners will say they can't farm and they have to do this or lose money and land. Thing is, they chose to pursue development instead of conservation. Not one acre in Natomas has been protected that wasn't required mitigation by the HCP, but funding sources like Sustainable Ag Land Conservation Program would pay appraised fair market value for easements or land and the owners could protect the land while making $13 million or more. They made the wrong choice but the conservation option is always available if they are willing.

Don't reward these gamblers. Stick to the plans. Protect farmland and nearby nature. Deny this project! Oppose
Richard Furiosi at May 22, 2025 at 9:24am PDT
I feel this project is not suitable for this area for many reasons but one of the main arguments I agree with is that it is farmland and using this land for industrial use is not the way to go particularly because the land is a habitat for animals , it could pollute our water ways and our air as well as disrupt the way people live in that area and their quality of life since the proximity is so close to a school and established neighborhood. I do think we need growth but positive growth that’s good for the community and its residents not more warehouses and industrial crap
Oppose
Jacquelyn Donahue at May 22, 2025 at 8:36am PDT
Here is the letter I submitted to Governor Newsome that explains my position on this matter as it will impact my quality of life.

Governor Gavin Newsom
California State Capitol
Sacramento, CA 95814
Dear Governor Newsom,
I am writing to you as a concerned resident of the Westlake community in Sacramento. Our neighborhood is currently facing the looming threat of a large warehouse development being constructed immediately adjacent to our homes and an elementary school. This project poses serious risks to the quality of life in our area and raises signiﬁcant concerns regarding environmental justice, public health, and infrastructure burden.

This proposed development sits within a ﬂood plain near the Sacramento River—an already vulnerable area. In addition to the environmental risks, the inﬂux of heavy truck trafﬁc and commuter vehicles from workers—many of whom may not be able to afford to live nearby—will increase congestion on Interstate 5. This will not only worsen commute times but also delay access to and from the Sacramento International Airport.

The residents of Westlake and the greater North Natomas area have consistently and strongly opposed this development. Unfortunately, our concerns have thus far fallen on deaf ears. It seems this project stands to beneﬁt city revenue at the cost of our community’s health, safety, and well-being.

Governor, I am aware that you have signed legislation aimed at addressing the impact of warehouse growth on communities like ours, particularly with regard to environmental and public health protections. I ask that you please consider intervening or supporting our efforts to halt this development. There are alternative locations for such a facility that do not come at the expense of a thriving residential area and an elementary school.

We respectfully request your support in preserving the integrity and safety of our neighborhood.

Sincerely,
Jacquelyn Donahue
Westlake Resident, Sacramento, CA
Oppose
ralph propper at May 22, 2025 at 8:35am PDT
I'm Ralph Propper, speaking on behalf of Breathe-California, Sacramento Region; formerly American Lung Association. I was an air pollution research specialist at the Air Resources Board, where I worked for 32 years, and chemistry professor at UC Davis; and I have published scientiﬁc papers on toxic air contaminants, including cancer-causing diesel exhaust.

Based on emissions of ﬁne particles from diesel trucks, the EIR calculates a risk of over 9-and-a-half excess cancer cases per million - just under the threshold for mitigation of 10 in a million.

However, this assumes no development in Parcel 8, which is closest to an elementary school.

The EIR states that if Parcel 8 is developed with over a hundred trucks per day, the health risk assessment for cancer would then be analyzed.

Children are especially sensitive to air pollution – young children inhale far more relative to lung volume than we do. Health studies show that inhaling ﬁne particles prevents full lung development - leading to permanent shortness of breath and increased asthma. Ultraﬁne particles are even worse.

A thin buffer is now proposed between Parcel 8 and the school: Breathe Sacramento was involved with research at Arden Middle School that showed that a buffer with tall evergreen trees like redwoods could help capture ﬁne particles; however, the buffer proposed here would not prevent toxic diesel particles from getting deep into kids' lungs.

We’ve seen better air quality here over the past few decades, but this EIR ﬁnds that this project is unable to mitigate signiﬁcant air quality impacts, thereby putting our health at risk.

You are being asked to recommend to the City Council that they approve a resolution that this project “promotes the public health of the city”.

Please let us know what about this proposed project promotes the public health of the city. The EIR clearly demonstrates otherwise.

Oppose
Laurie ten Hope at May 22, 2025 at 8:31am PDT
To: Sacramento Planning and Design Commission
From: Laurie ten Hope, Resident of North Natomas
RE: May 22, 2025, Agenda item #6 - Airport South Industrial Annexation I’m a North Natomas homeowner and have called Natomas home for 24 years. I enjoy the opportunity to experience nature in our community’s backyard. I value visits to local farm stands, bird watching among the wetlands, and cycling throughout Natomas. I believe that future generations should be able to experience this as well. The city cannot continue to expand the city boundaries without compromising these wonderful attributes. Please say no to sprawl, diesel pollution and trafﬁc, and say yes to conserving our quality of life!
This warehouse project is not needed at this time. More importantly, it is inconsistent with the city’s climate goals. The proposed project encourages sprawl and pollution. It also violates the goals of preserving open space and agricultural land.

The developer should not be allowed to hijack the process that established the Urban Services Boundary that was so thoughtfully researched and then adopted in the General Plan, the Natomas Basin Habitat Conservation Plan and others. These plans balance the desire for development with the desire to preserve open space. And, these planning agreements prioritize lands most critical for habitat preservation verses land most suitable for development. As a resident of Sacramento I’m thankful that these agreements exist and I hope they are honored.

I respectfully ask that you vote NO on the Airport South Industrial annexation agenda item.

Oppose
seth howard at May 22, 2025 at 8:06am PDT
There is no commitment to hire local workers or contractors for this project. No commitment to provide health care or a living wage. There will also be terrible pollution from this project Support
Joseph Perez at May 22, 2025 at 7:55am PDT
Suitable health care!
Oppose
Lloyd Reber at May 22, 2025 at 7:46am PDT
My concern with this project is that there is no commitment to using local contractors that employ members of our communities.

There is also no commitment to paying a livable wage or providing health care for the workers. This can add undue burden on our local tax payers.

Oppose
Falme Lampkins at May 22, 2025 at 7:08am PDT
I oppose this project because Sacramento needs housing not warehousing.

Neutral
Marta Smith at May 22, 2025 at 6:55am PDT
I am opposed to this project for two reasons: 1) There are empty buildings all over town that could be re-purposed for business. 2) even if the land isn't being used for agriculture now, it could be in the future. This kind of over-building is , respectfully, short-sighted! Oppose
Raman Dhillon at May 21, 2025 at 11:14pm PDT
I oppose this project for a few reasons. It’s too close to an elementary school so trucks are going to be coming in and out of the facilities at the same as the kids are arriving and leaving school which create worsen trafﬁc in the area. Another reason is the increase in truck trafﬁc will create more pollution and the kids at the school will be breathing in those toxic fumes leading to respiratory illnesses.

After that, there are plenty of other places throughout the Sacramento region that are better suited for an industrial project of this magnitude that are close to
highways. Then, the area is under the Natomas Habitat Conservation Plan which is essential to preserve all living species who claim the land as their home and this proposed industrial project violates the conservation plan.

Oppose
D S at May 21, 2025 at 10:19pm PDT
The current plan does not actually provide an economic beneﬁt to the region and goes against already established plans such as the Natomas Habitat Conservation Plan, City General Plan, and County General Plan, and is counter to the Governor's Climate-Smart Strategy.

Furthermore, there are better, industrial-zoned locations for warehousing projects elsewhere in the area.

Natural AND working lands serve as critical carbon sinks and biodiversity hotspots, and bring signiﬁcant health, wellness, and economic beneﬁt to the region. We should be restoring these areas to serve us better, not eliminating what little is left of them.

PLEASE save our open spaces from development, and focus on areas that have already been developed in our region and stand to make more economic and environmental sense.

Oppose
Daniel Sanchez at May 21, 2025 at 9:56pm PDT
The applicant makes no guarantees to provide a livable wage, health care beneﬁts, or commitments or to use local apprentices on this project. This is going to hurt the Sacramento workforce by allowing lower wages on the project and little to no befeneﬁts to workers. These types of projects are what force workers like myself to have to commute to the bay area for work to afford to live in Sacramento
Oppose
Luz Lim at May 21, 2025 at 9:56pm PDT
Dear Commissioners,
Please read the attached letter, submitted on behalf of the Environmental Council of Sacramento (ECOS).

Thank you,
Luz Lim
Attachments: ECOS_Attachments_on_ASIP.pdf
ECOS_Letter_RE-_Item_6._Airport_South_Industrial_Annexation__P21-017___Noticed_05_02_2025__File_ID-_2025-01031.pdf Oppose
Rosie Yacoub at May 21, 2025 at 9:43pm PDT
Development of warehouses in this location goes against the land use policy that allowed for the development of Natomas; and is not needed as the nearby warehouse zone is replete with vacancies and undeveloped parcels. It will seriously impact the nearby community in terms of reduced road safety and increased pollution exposure This land should be left as agriculture.

Oppose
Morgan Morrissey at May 21, 2025 at 9:31pm PDT
As a resident of Westlake community, I ask that you please don’t destroy this natural habitat for warehouses that in no way beneﬁt our community. Warehouse zones already exist to the north of 5; consider expanding in that existing area. How does it make sense to destroy nature and encroach on the peaceful Westlake community and Del Paso K-8 school with warehouses? Please be a good steward of the land and leave this area untouched. At the very least, use the land for something to beneﬁt the existing neighbors of the land.

Oppose
Colin Tempelis at May 21, 2025 at 9:26pm PDT
I oppose the airport south project as this will over take area being used as ﬂood control in an area that is at high risk for ﬂooding.

Should the area become ﬂooded it would knock out major lifelines to the entire state as it would take out I-5, I-80, and the airport. This area is the epicenter for the state’s commerce and would have devastating ﬁnancial and supply chain effects felt throughout the state.

This area must remain as a ﬂood control area to help alleviate the ﬂood risks.

Oppose
Carmen Pereira at May 21, 2025 at 9:19pm PDT
Hello, I am a long-time Sacramento resident, and I strongly oppose this project. I ask that you do the same. The area in question is vital farmland and essential wildlife habitat. Let's not be shortsighted and destroy farmland, open space, and vulnerable wildlife. The Sacramento City and County General Plans and the North Natomas Community Plan were developed over many years by many constituents who decided to maintain the area in question as agricultural land. Hard work and careful thought went into these plans.

Please give respect to these people and their efforts, and to these plans. The loss of food-productive land, habitat and wildlife, open space and natural beauty, the increase in air and noise pollution, and the decrease in stormwater drainage, are only some of the very important reasons why you should oppose the Airport South Industrial Annexation project. Thank you.

Meeting: Planning & Design Commission (Supplemental Material Updated 5/22/2025 @ 10:15 a.m.)
Meeting Time: May 22, 2025 at 5:30pm PDT
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Rick Dow at May 21, 2025 at 8:55pm PDT
Being good stewards of the land, it is hopeful that members of the Planning & Design Commission will take the following into consideration when making decisions about the Airport South Industrial Annexation:
1) The 2,000 acres of farmland help support migratory birds in the Paciﬁc Flyway, and loss of that farmland to development would potentially harm migratory birds that are part of the ambiance of living in the Natomas area. 2) Loss of farmland would also be a loss of the potential to use farmland as a carbon sink and help ﬁght climate change that is bringing about unusual weather such as severe storms and ﬂooding. 3) Commercial and residential development would eventually clog the area and possibly lead to panic if evacuation from the area were to occur due to disasters such as ﬂooding, earthquake or ﬁre. There are only three roads to be used for evacuation if the need were to occur for whatever reason.

These are reasons my wife and I as residents of Natomas highly oppose the overly ambitious Airport South Industrial Annexation.

Sincerely,
Rick Dow, MS Botany/Zoology
4318 Don River Lane
Sacramento, CA 95834
Rick Dow
[email protected]
Oppose
Kayla Gomez at May 21, 2025 at 8:14pm PDT
Good evening, my name is Kayla Gomez, and I am a ﬁeld representative for the Nor Cal Carpenters Union, Local 46 which covers Sacramento.

I’m here today to highlight the potential beneﬁts projects like this one can bring to our neighborhood. However, my primary concern is whether this project will genuinely serve the interests of our local community. As a carpenter, it’s important to know if the developer plans to hire a responsible general contractor committed to fair wages, healthcare beneﬁts, and accredited apprenticeship programs.

Fair wages are essential to address the high cost of living in our area. Ensuring health care beneﬁts means my family and I, as well as my fellow workers, can access necessary medical services without ﬁnancial strain. Local hiring practices are crucial not only to avoid long commutes but also to create jobs and strengthen our community.

I urge the developer to prioritize these values—fair wages, comprehensive health care, and local hiring. Also general contractors that hire from a state certiﬁed apprenticeship programs—so that this project can truly beneﬁt our community. Thank you.

Oppose
Karen Olson at May 21, 2025 at 7:47pm PDT
Dear Sacramento Planning Commissioners;
I urge you to NOT approve the proposed Airport South Industrial Annexation.

The proponents of this project claim new jobs are an important potential beneﬁt. Currently, the unemployment rate in Sacramento County is historically low at 4.70%. This is lower than the long-term average of 6.46%. Source: YCHARTS.com (May 2025) So will the labor that is needed come from outside the Sacramento area? Second, what type of jobs will be available once the better paying construction jobs are no longer needed? I imagine they will be low-paying warehouse/fulﬁllment jobs.

On the other hand, it would be a terrible shame to pave over more farmland, open space and natural habitat to build more warehouses and “light industrial development”. We should respect and preserve our environment, quality of life, and health. Already, and increasingly, the continued expansion of development and freeway centric projects are decreasing our quality of life as we spend more time commuting and ﬁghting trafﬁc. Our health is suffering from increased air pollution. The priority should be inﬁll projects rather than more sprawl.

Please don’t give-in to developers and speculators. Do not approve the Airport South Industrial Project. Stand for smart growth and maintaining a high quality of life in Sacramento.

Oppose
Omar Hernandez at May 21, 2025 at 7:06pm PDT
I strongly oppose this project. We are in need of more homes, not warehouses. We don’t need facilities that are going to create more trafﬁc and pollution in our environment. To give an example. A single Semi produces an average of 207 tons of Annual CO2 Emissions per year. A passenger car produces 4.7tons of CO2. These warehouses will be having an average of 2,000 semi-trucks per day! We in Sacramento need to focus on other, more important, pressing matters. Things like our roads, more homes, schools, etc. I trust that the Board will do the right thing, and do a “No” vote on this item. Thank you.

Oppose
Matt Williams at May 21, 2025 at 6:40pm PDT
Dear Commissioners,
As both a local resident and Air Pollution Specialist with ten years experience working on heavy-duty emissions sources, I urge you to vote no on the proposed Airport South Industrial Project (ASIP). The ASIP will pave over natural and working lands, introduce new truck trafﬁc, increase emissions of toxic air contaminants from vehicles and off-road equipment, and greatly diminish the rural feel of northern Natomas that many residents prioritized when moving to the area. The ASIP will result in substantial environmental damage, contrary to the City’s goals and to the detriment of the community. ASIP will destroy a large portion of a dwindling supply of wildlife habitat, expose residents to diesel particulate, and increase local trafﬁc. To protect the environment, community health, and Natomas vibes, I urge the Commission to vote against and cancel the ASIP.

Oppose
Alexandra Reagan ECOS Dir Ops at May 21, 2025 at 6:23pm PDT The Environmental Council of Sacramento (ECOS) opposes this annexation of farmland to build warehouses and asks you to recommend denial of the developers' request to the City Council. Please read the attached letter and its accompanying documents as part of our comments.

Attachments:

ECOS_Letter_RE-_Item_6._Airport_South_Industrial_Annexation__P21-017___Noticed_05_02_2025__File_ID-_2025-01031.pdf ECOS_Attachments_Re_Airport_South_Industrial_Project.pdf Oppose
Hind Baki at May 21, 2025 at 5:55pm PDT
Dear Commissioners,
On behalf of the Carpenters Local Union #46 (“Local 46”), my Ofﬁce is submitting these comments for the Sacramento Planning and Design Commission’s (“City”) hearing regarding the Sacramento Airport South Industrial Project (“Project”). (please see attached letter for more details)
Attachments: 20250522_Local46_Sacramento_PDC_AirportSouthIndustrialProject_CL_Signed_Combined.pdf Oppose
Corinne Gartner at May 21, 2025 at 5:44pm PDT
As a District 1 constituent, concerned citizen, mother, and resident of the Westlake neighborhood whose home looks directly out on the open space upon which this appalling development project proposes to build millions of square feet of warehouses, I urge you to VOTE NO, for all the reasons articulated by my North Natomas neighbors in other comments.

Please consider that nearly every comment made on this agenda item opposes this project. Moving this project forward in the face of such overwhelming opposition will only serve to conﬁrm that City staff made a dirty backroom deal with the developer years ago, without public input or proper authorization.

This Commission has the power to stop this ill-advised project in its tracks. Please do the right thing and do so. If you make the misguided decision to move the project forward, though, please require a larger setback from the Westlake neighborhood, at minimum 1/4 mile. Knowing that this project is guaranteed to result in adverse health outcomes for the children and families that live and go to school in the immediate area, requiring anything less would be unconscionable.

Oppose
James Pachl at May 21, 2025 at 5:24pm PDT
Please read the attached letter which explains that the project's detention basin will invite aircraft waterfowl collision in the path of aircraft using SMF. This impact cannot be mitigated to less than signiﬁcant despite the EIR claim.

Attachments: SACCITYPLANINGASIP52225.pdf FAA_150-5200-33C.pdf FAA.Airport_Sponsors_Assurances.pdf Oppose
Melanie Herman at May 21, 2025 at 5:05pm PDT
The way the county is blowing past every law, ordinance and regulation makes me wonder why I shouldn’t do the same. I would like to actually send you a photo of a bobcat and a different one of a fox that I and my neighbor took over this winter. It was tragic to see two different foxes smashed by cars out on the Garden Highway.

I’m surprised now that you haven’t sold off the banks of the American river to cronies who will help you with money during the next election. I guess we’ll just have to wait and see how low you’re willing to go.

Oppose
Kyle Swarens at May 21, 2025 at 4:46pm PDT
Good evening Planning commission
As a longtime Sacramento resident and current homeowner in Natomas. I strongly oppose this development.

We need smart growth for our community in Natomas. Often I will be stuck in trafﬁc 45mins to an hour trying to get from Woodland to Natomas area. This development will only cause more of a trafﬁc jam that's already an issue and creating more pollution for our region with little to no gain.

We also need to take in consideration the workforce building these projects. We are a blue-collar community. Often we forget this. It's time we stand up for the blue-collar workforce in our community and demand better. Developments like this one tend to be a race to the bottom for the workers. Little to no beneﬁts and low wages. Making workers who want to make a livable wage having to commute hours to the bay area. Please stand up for our community and stand up for the workforce when making decisions for the city of Sacramento.

Oppose
David Grandstaff at May 21, 2025 at 4:32pm PDT
We are a 23-year Westlake resident and living within 150 feet of the proposed Airport South Industrial Project. We wish to go on record as agreeing with the numerous comments opposed to this project and do personally and strenuously oppose it ourselves.

David and Bunny Grandstaff
3867 Gresham Ln.

Sacramento, CA 95835
Oppose
Sean Reese at May 21, 2025 at 4:32pm PDT
Strong opposition to this project due to its harmful impacts on the environment and potential to worsen local infrastructure issues.

The project would signiﬁcantly increase air pollution, water pollution, and noise pollution, posing serious risk to our health. Especially those already at-risk. It would intensify trafﬁc congestion along the already crowded I5 corridor, making my daily commute more difﬁcult and just polluting everything around us. I urge the decision makers and applicant to consider these consequences and prioritize a more sustainable and community friendly alternative.

Oppose
Chester Haley at May 21, 2025 at 4:30pm PDT
The applicant has made no guarantees that the vast majority of the construction jobs associated with this project would provide workers with health care or livable wages. There have been no commitments from the applicant to use local apprentices, which would help strengthen our workforce community. This project would have terrible effects on the environment - air pollution, water pollution, and noise pollution.

Oppose
Chris Martinez at May 21, 2025 at 4:24pm PDT
I’m here to oppose this project.

Far too often, projects like this end up being crime scenes—plagued by wage theft, worker exploitation, and labor abuses. We’ve seen it here in Sacramento. Our own District Attorney recently held a press conference calling out the injustice faced by workers in these types of developments and the lasting harm it causes our communities.

The applicant has made no commitment to labor compliance, no guarantees for worker protections, and no access to a private right of action. Without clear, enforceable commitments, this project opens the door to more harm.

Sacramento doesn’t need another crime scene. We need responsible development that respects workers and protects our community. I urge you to reject this project as it stands.

Oppose
Lynn Lenzi at May 21, 2025 at 4:17pm PDT
Dear Chair Yeung and Planning and Design Commissioners
As a 24-year resident of North Natomas, Westlake Community, I am registering my strong OPPOSITION to the proposed Airport South Industrial Project (ASIP).

As a former City Planning Commissioner, I am alarmed to see a proposal that is so incompatible with housing, schools, and other mixed uses has received support from staff. Annexation and extension of services to this land ignores existing land use plans, the City's General Plan, the North Natomas Community Plan, and multi-jurisdictional habitat plans.

Annexing 447 acres is NOT inﬁll development, it is creating city sprawl. Can you tell me where the City of Sacramento has or is currently planning to zone 447 acres of industrial park with six (6) million square feet of warehouse adjacent to housing and schools? GOOD PLANNING MUST PREVAIL. There is no compelling reason to create urban sprawl, remove agricultural land and habitat when there is an abundance of land available in North Natomas and the City for development that includes uses for industrial parks. Think about where you live - would you want six (6) million square feet of warehouse, freight trailer truck trafﬁc, noise and pollution next door? Please reject this proposal and vote no to annexation.

Lynn Lenzi
Lynne Randolph at May 21, 2025 at 4:13pm PDT
Dear City of Sacramento Planning Commission:

My name is Lynne Randolph and I live about a mile and a half from the Airport South site down El Centro Road.

I oppose putting thousands of square feet of warehousing in this residential neighborhood, next to an elementary school and across the road from another school. Del Paso Road is already congested, and this would only make it worse with hundreds of semi-trucks added into the mix.

The air quality would also be severely affected, leaving residents at the mercy of noise and constant exhaust fumes. One of the paid union members here cited legislation that would require truck exhaust pipes to point away from residences. But with all respect, that so-called solution would be like claiming secondhand smoke won't cause cancer if you don’t blow cigarette smoke directly into the face.

Simply put, developing the Airport South land with warehouses that could be placed elsewhere, would cause blight and have a permanent detrimental effect on the neighborhoods, quality of life, and land values in West Natomas forever.

As a Planning Commission, I expect that you not simply decide where developments should take place but also protect those who are already there.

Thank you.

Lynne Randolph
470 Forastera Circle
Sacramento, CA 95834
Oppose
Thomas Roehrick at May 21, 2025 at 4:09pm PDT
Far too often these types of projects are crime scenes. Rampant with wage theft and other worker abuses. The Sacramento DA had a press conference in regards to this very worker injustice and how it affects us all. Avdis & Cucchi have made no commitment to compliance or access for private right of action. Without commitment and action you cannot support the project. We don’t need another Crime Scene project in Sacramento.

Oppose
Mitchell Vinciguerra at May 21, 2025 at 4:06pm PDT
The applicant has made no guarantees that the vast majority of the construction jobs associated with this project would provide workers with health care or livable wages, nor is there any commitments to hire from our local community. The project will also make trafﬁc even worse than it already is on the Interstate 5 corridor. I would also like to caution against any project that does not make commitment to use local apprentices.

Oppose
Lynn Duarte at May 21, 2025 at 3:45pm PDT
Stop further development in the open areas on the residential side of Hwy. 5. It is impacting the quality of life for the wildlife and people living here. It will only increase the noise and congestion and reduce our quality of life. Stay on the airport side.

Meeting: Planning & Design Commission (Supplemental Material Updated 5/22/2025 @ 10:15 a.m.)
Meeting Time: May 22, 2025 at 5:30pm PDT
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John Burke at May 21, 2025 at 3:44pm PDT
Truck trafﬁc on I5 is already suffocating from Metro Airpark and Amazon. Airport South will only increase that trafﬁc in an area that is already heavily congested.

The Airport South project will create warehouses and truck trafﬁc within 100 yards of an elementary school. Most trucks are still diesel- powered and will be spewing pollutants over the school. Do you really want young kids breathing in these fumes? Are they going to have to be kept inside all day?
In addition to the warehouses north of I5 by the airport, there are already several large warehouses along I5 just south of the I5/99 connection. Why do we need more warehouses?
The primary argument in favor of the project is that it will bring jobs to the area. If there really is a need for more warehouse space, the warehouses can be built north of I5. Does not solve the trafﬁc problem but it does protect our kids and provide the same jobs. Or, how about further north on the other side of the Sacramento River which would at least mitigate the trafﬁc issue.

Lastly, local residents feel we are not going to be represented on city council since our councilperson feels she must recuse herself because she lives near the proposed project and fears the city could be sued if she votes against it. How about leveling the playing ﬁeld? Any councilperson who has accepted campaign money from the proposed developers should also recuse themselves. Seems to me that represents a signiﬁcant conﬂict of interest. Perhaps it could also lead to law suits.

Oppose
Florencio Rivera at May 21, 2025 at 3:35pm PDT
Dear Sacramento Planning Commissioners,
I want to express my strong opposition regarding the proposed Airport South Industrial Project. My opinions and reasons for this have been covered by others multiple times so I simply want to add my voice of opposition to this as I live right next to this area. -F. Rivera
Oppose
Dan Branton at May 21, 2025 at 3:15pm PDT
Strongly oppose and hope you do too!!
Is this just another Developer Money grab?
The applicant has made no guarantees that the vast majority of the construction jobs associated with this project would provide workers with health care or livable wages. There is no commitment that they will hire construction companies and workers within our community to build the or maintain the project and further more you have no commitments from the applicant to use local apprentices, which would help strengthen our workforce community. Far too often these type of projects end up being crime scenes where wage theft, tax fraud and gross crimes against workers happen and affect us all. We have no indication the applicant will do anything to strengthen local workforce development. For these reasons and many more, I ask you to oppose this project as it stands.

Oppose
James Pryor at May 21, 2025 at 2:36pm PDT
We write to you as the homeowner-elected Board of Directors of Westlake Master Association and seek your support in opposing the proposed Airport South Industrial Project, and hope you are committed to preserving the quality of life for residents of the Westlake community, which is part of North Natomas. Westlake is a residential community of over 3,000 residents living in over 925 homes and if approved the proposed Airport South Industrial Project would be immediately adjacent to and would negatively and signiﬁcantly impact our community. ....continued.

Please read our entire letter and issues, attached. Thank you.

Board of Directors
Westlake Master Homeowners' Association
Attachments: 2025-05-21_Opposition_to_Airport_South_Industrial_Project.pdf Oppose
Mary Ingram at May 21, 2025 at 2:12pm PDT
I do not want this project approved. To close to schools and housing. The land is for farming and wildlife. There is plenty of land on the other side of 5 that already is zone for storage warehouse etc. The only people who would beneﬁt from this project are the land speculators. Please do not approve of this plan
Oppose
Ed Jahan at May 21, 2025 at 2:02pm PDT
Dear Sacramento Planning Commissioners,
I am writing to express my strong opposition and deep concern regarding the proposed Airport South Industrial Project.

This development poses signiﬁcant and unacceptable environmental and community impacts. First and foremost, it threatens to destroy critical wildlife habitat in the area—natural spaces that are rapidly disappearing and irreplaceable once lost. These ecosystems support biodiversity and serve as vital green buffers in an increasingly urbanized landscape.

Furthermore, the project jeopardizes water quality in the region. Construction and increased industrial activity will contribute to runoff and pollution, impairing local waterways and affecting both human and ecological health.

The increase in noise and air pollution from heightened truck and industrial trafﬁc is also alarming. These impacts will degrade the quality of life for nearby residents and pose health risks, especially to vulnerable populations such as children and the elderly.

Trafﬁc congestion is another pressing issue. This project will lead to more vehicles on already strained roadways, increasing commute times and making local streets less safe for pedestrians and cyclists.

Perhaps most concerning is the impact on the neighborhood's peace and its proximity to a school. Our children deserve a safe, quiet, and clean environment to learn and grow. The industrialization of this area threatens their well-being and undermines the stability of the surrounding community.

I urge you to reconsider the long-term consequences of this project. Sacramento must prioritize sustainable, community-friendly development that respects environmental limits and protects public health.

With kind regards,
Ed Jahan
Oppose
PA Davis at May 21, 2025 at 1:29pm PDT
The Airport South Industrial Project (ASIP) – would replace farmland and wildlife habitat with warehouses and place trafﬁc- inducing diesel trucks next to a neighborhood and school. The Planning and Design Review Commission should recommend that the City Council reject or require signiﬁcant changes to the project.

Louise Gray at May 21, 2025 at 1:12pm PDT
“America’s farmland is irreplaceable.

It grows our food.

It supports wildlife and biodiversity.

It cleans our water, increases resilience to natural disasters like ﬂoods and ﬁres, and helps combat climate change.

Our food, our water, our environment, our survival—it all depends on American farmland and ranchland.” https://farmlandinfo.org/why-save-farmland/
You obviously don’t care we get cancer, climate change gets worse, etc—- right? Cancer, increasing pollution, freeway deaths, etc. doesn’t matter? Oppose
Judith Poxon at May 21, 2025 at 12:54pm PDT
Please oppose this project and preserve the existing farmland and wildlife habitat! Oppose
Eric Webb at May 21, 2025 at 12:41pm PDT
As a long time Natomas resident I am deeply concerned about this precedent-setting decision.

There are innumerable reasons for opposition:

Firstly, this is a clear violation of the Natomas Basin Conservation Plan. It will gobble up important open space and habitat that includes the Swainson’ Hawk. Not only does it impact a vital ecological corridor, it also deletes important barrier land we need for ﬂood control.

We have hardened enough of the Natomas Basin’s landscape; we need to preserve its balance.

This project also requires an exemption to the Urban Services Boundary. This boundary is based on a lot of wisdom.

Given that we have plenty of inﬁll alternatives, including north of I-5, our default should be to respect our carefully crafted Natomas Conservation Plan and established boundaries.

Any economic beneﬁt will be mitigated by increased pollution and trafﬁc and the loss of buffer lands in the event of an inevitable ﬂood disaster.

I collect acorns for the Sacramento Tree Foundation in this proposed area.

Finding valley oaks that have not been hybridized by our non-native urban forest is much harder to come by. I say this to emphasize our need to protect our open spaces in the urban setting. Our endemic ﬂora and fauna is what makes us unique in California and beyond.

Certainly these landscapes distinguish us from other major cities in the United States. We need to orient ourselves to preserving our open lands.

Please reject this proposal.

Oppose
Kate Lenox at May 21, 2025 at 12:19pm PDT
This proposed project is too near neighborhoods and schools. Noise and pollution will increase and affect nearby homes.

Moreover, it will destroy some of the ﬁnest farmland and habitat in the area.

I question the need for a trucking facility when tariffs and an unpredictable economy could make it redundant.

Oppose
Pamela Schneider at May 21, 2025 at 12:12pm PDT
Please preserve and protect the open space we currently share with farmers, wildlife, and birds along the paciﬁc ﬂyway in the Natomas basin. The habitat is as developed as it should ever have been allowed to be— more will continue to erode the natural habitat and bio-diversity that makes California unique and beautiful. Please say “No.” Oppose
Adele Logsdon at May 21, 2025 at 11:55am PDT
Please reject this proposal. It only beneﬁts those who want to make money, and they can do so elsewhere. Don't wildlife, school children, and nearby residents count for anything? Please put yourselves in our places. Thank you for your attention.

Adele Logsdon
4536 Villa Del Paso Lane
Sacramento 95834
Byron Tucker at May 21, 2025 at 11:07am PDT
WOW! This is SUPER important! The land is very low and is a percolation area for rain. Cement will only make ﬂooding here in MY community exacerbated! There are other large areas to the north and east within the County that have very good access for product access to the freeways and airport. Every projection and plan in the Sacramento history is absolutely opposed to this ASIA (P21-017).

This is just a big money slight of our efforts to protect our open land and wildlife (bird ﬂyway and many other species) AND to protect our quality of family life. We moved to this area BECAUSE of the open space and ease of access to downtown and to the airport! The roads and Interstate 5 are already sadly extremely congested. The air quality would be severely compromised for our children in school and at home.

I urge you to reject all parts of this proposal hurting US, your constituency. My family and friends are watching and hoping this destruction of our quality of life won't be sacriﬁced for a few measly dollars.

Thank You for considering this plea.

Byron Tucker
4902 Brookdale Drive
Sacramento, CA 95834
Oppose
Gee Weckerle at May 21, 2025 at 10:53am PDT
I recently moved into this area. I am already appalled by the diesel trucks parked overnight with their generators running one the streets practically in someone's home, often within 10 feet. I oppose the Airport South Industrial Project (ASIP). This project would replace farmland and wildlife habitat with warehouses and place trafﬁc-inducing diesel trucks next to my neighborhood and school.

Please consider the long term ramiﬁcations of this and think what it would be like if this were to happen to your established neighborhood.

Oppose
Karen OHaire at May 21, 2025 at 10:00am PDT
As a former SACOG land use planner, neighbor to the proposed project and environmental attorney I urge you to reject this proposal.

The proposed project ﬂies in the face of good land use planning. It would site huge industrial warehouses next to an existing school and residential neighborhood. How would you feel if this project were located next to your, your children’s, or grandchildren’s school or home? It is a project that conﬂicts with existing land use plans and eliminates agricultural land and open space. In addition, the proposed project is located outside the Urban Services Boundary and proposes up to 6,609,300 square feet of industrial uses for which there has not even been a demonstrated need. In fact, there are existing vacant industrial sites located to north of I-5 as well as zoned industrial areas within the city to accommodate any need and provide inﬁll.

To ignore existing land use plans, multi- jurisdictional habitat plans and the urban services boundary, as well as losing prime agricultural land and habitat for this development proposal would be a detriment to the neighboring community, the city, the airport, the county and the region.

Please reject this proposal- it is a travesty!
Thank you,
Karen O’Haire
Oppose
Ona Saras at May 21, 2025 at 9:59am PDT
We do not want this near our neighborhood. There is so much other space away from neighborhoods that the project can go to.

This will cause extreme pollution to the surrounding neighborhoods and school that are very close proximity. This is a greedy, greedy, polluting project that is unnecessary, anti-health, anti-nature, anti-climate, and all around anti-ethical. Why not move this elsewhere or better yet, use existing infrastructure? I highly, highly oppose this project.

Wayne Watts at May 21, 2025 at 9:16am PDT
We do not need this, we already have space available at Mather and at McClellan Park. Better to use these existing facilities rather than destroy the open spaces that will never be recovered once they are covered in concrete and asphalt.

Oppose
Judith Lamare at May 21, 2025 at 9:10am PDT
This proposal and its EIR do not comply with the Natomas Basin Habitat Conservation Plan requirements applying to prezoning outside the City's permit area, includes other conﬂicts with the NBHCP such as counting detention basins as habitat, using out of Basin mitigation land, failure to mitigate 1:1 for loss of foraging habitat, and no assessment of impacts on adjacent NBC preserves.

City’s development in the Basin is subject to the 2003 NBHCP, and its Implementation Agreement, an agreement signed by the City, Sutter County and the Federal and State Wildlife Agencies. The 2003 NBHCP Implementation Agreement ("IA") §3.1.1 provides that "CITY agrees not to approve more than 8,050 acres of Authorized Development and to ensure that all Authorized Development is conﬁned to CITY's Permit Area as depicted on Exhibit B. . . ." (see ATTACHED Exhibit B). See also 2003 Natomas Habitat Conservation Plan, ATTACHED Figure 2, "Land Use Agencies Permit Areas." The City also agreed in the NBHCP that "in the event that future urban development should occur, prior to approval of any related rezoning or prezoning, such future urban development shall trigger a reevaluation of the Plan and Permits, a new effects analysis, potential amendments and/or revisions to the Plan and Permits, a separate conservation strategy and issuance of Incidental Take Permits to the permittee for that additional development and/or possible suspension or revocation of [Permit] in the event that the City or Sutter violates such limitations. " ((IA 3.1 (a)). (Emphasis added) NBHCP IA, p. 3 and Exhibit B attached.

The City Staff and the EIR have consistently and deceptively ignored this contractual obligation and are now arguing that the proposed project can be included within the NBHCP without amendment, thereby falsely claiming the effects on the NBHCP are fully mitigated by the EIR mitigation program.

Also attached is a letter from Natomas Basin Conservancy explaining why building on agricultural land in the Basin hurts the NBHCP.

We urge you to deny the project until it has fully complied with the NBHCP Implementation Agreement.

Attachments: NBHCPIA3_ExhB.pdf Natomas_Rules.pdf 25.04.17_Ltr_to_LAFCO.NB.pdf Oppose
DoLee Spurgeon at May 21, 2025 at 9:07am PDT
Please do not pass the Airport So. Industrial Annexation (P21-017). It would be ridiculously irresponsible of you to put this complex so close to schools and so many homes. Not to mention destroying wild life habitats and farm land. Our communities suffer enough from air and noise pollution from the airplanes and large trucks on I-5. In addition you are already asking us to reduce our water and electrical usage. Families health and well being are more important than big business. Reduce government waste and you won't need the increase in tax dollars. Life in California is challenging enough without greedy government continuing to put more pressure on citizens.

Meeting: Planning & Design Commission (Supplemental Material Updated 5/22/2025 @ 10:15 a.m.)
Meeting Time: May 22, 2025 at 5:30pm PDT
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John Gerken at May 21, 2025 at 8:54am PDT
May 20, 2025
Chair Enoch Yeung and City of Sacramento Planning and Design Commissioners 300 Richards Boulevard, 3rd Floor
Sacramento, CA 95811
Re: Airport South Industrial Annexation (P21-017)
Dear Chair Yeung and Planning and Design Commissioners:

Thank you for the opportunity to provide comments on the Airport South Industrial Annexation project (P21-017). The Natomas Uniﬁed School District greatly appreciates the revisions to the project and mitigation measures that have been made prior to this item coming before your body. We do have some additional minor requests, which are similar to those we shared with the City in letters dated December 5th, 2024 and March 14th, 2025.

The Paso Verde School is located adjacent to, and south of the project site and the closest school building is approximately 250 from the project site, as measured at the closest point. An outdoor play area is in the northwestern portion of the school site, approximately 240 feet from the project site, as measured at the closest point. We understand that the project before you is focused on the project applicant sponsored lands. However, we have some requests that pertain to one of the “non-participating” parcels – Parcel 8 (as mapped on page 3-6, Figure 3-3 in the Draft EIR).

We understand that the proposed prezoning would be Industrial (M-1) for the “nonparticipating” parcels, including the property adjacent to Paso Verde School. The Natomas Uniﬁed School District requests conditions to be applied at this stage since by-right uses under the proposed M-1 zoning include manufacturing, trucking terminal yard, and warehouse and distribution center (City of Sacramento Code of Ordinances, 17.220.110). While page 17 of 602 of the Planning and Design Commission Report for Item 6 notes that future development of nonparticipating parcels “will require additional planning entitlements and will be subject to the California Environmental Quality Act,” it seems the City’s discretionary authority could be limited for uses that are allowed by right under the proposed zoning. Our requests are focused on two mitigation measures – Mitigation Measure 4.3-3 on air quality and Mitigation Measure 4.7-5(a) on hazards.

Air Quality - Mitigation Measure 4.3-3. Mitigation Measure 4.3-3 requires a Health Risk Assessment prior to issuance of a building permit for development of Parcel 8 under certain conditions. This mitigation language has been revised to make it clear that the Health Risk Assessment shall include not only emissions sources proposed on Parcel 8 but also emissions sources for the entire project site. From page 40 of 602 of the Planning and Design Commission Report for Item 6:
"(Mitigation Measure 4.3-3) The HRA shall be prepared in accordance with SMAQMD guidelines, as well as the guidelines identiﬁed in the California Ofﬁce of Environmental Health Hazard Assessment (OEHHA) Guidance Manual for Preparation of Health Risk Assessments. If health risks associated with Parcel 8, **combined with the health risks calculated for the Industrial Park portion of the proposed project**, (see Table 4.3-11 of this EIR are determined to exceed the applicable SMAQMD thresholds, a qualiﬁed air quality consultant shall identify measures sufﬁcient to reduce the project’s health risks to below the SMAQMD’s thresholds of signiﬁcance." The Natomas Uniﬁed School District greatly appreciates this revision to Mitigation Measure 4.3.3. Please revise the Mitigation Monitoring Reporting Program to include the same text between the above, added asterisks. This added language is currently missing from the version of Mitigation Measure 4.3-3 on page 4-11 of the Mitigation Monitoring and Reporting Program, which is page 138 of 602 of the Planning and Design Commission Report for Item 6.

Hazards and Hazardous Materials - Mitigation Measure 4.7-5(a). This mitigation measure includes actions to prevent the establishment of resident populations of Canada geese on the project site. Among the preventative measures listed in Mitigation Measure 4.7-5(a) is the use of noise generators (e.g., pyrotechnic devices, blank cartridges) and the use of chemical repellents. City of Sacramento Municipal Code Section 8.68.060 prohibits exterior noise that is more than 20 decibels above the existing ambient noise level as measured on agricultural or residential property and prohibits noise generation of 15 decibels above ambient levels for impulsive noises.

It does not appear that the pyrotechnic devices or blank cartridges identiﬁed by Mitigation Measure 4.7-5(a) were analyzed for potential impact or consistency with the City’s noise ordinance.

If noise generators are to be used within the southern or southeastern portions of the project site when school is in session, please condition the project to notify the Paso Verde School in advance. Also, please have the applicant team characterize the approach for chemical repellents to clarify that this would not include any airborne chemicals that would leave the project site and condition future development of Parcel 8 appropriately.

Again, NUSD is very appreciative of the opportunity to provide comments on this item. Please do not hesitate to contact me if you have any questions about our requests.

Sincerely,
Lalanya Rothenberger
Executive Director, Facilities and Strategic Planning
Natomas Uniﬁed School District
Oppose
Scott Smith at May 21, 2025 at 8:51am PDT
Paciﬁc ﬂyway during winter months when thousands of waterfowl rest & feed. Food production among the acres- rice, hay. Clean air, enjoyable open space. Vs diesel pollution, congested freeways.

Oppose
Diane Hovey at May 21, 2025 at 8:42am PDT
Please rethink what you are trying to do. When I built my house on the Garden Highway we had to schedule construction so as to not disturb the nesting Swenson Hawks. The area you are looking to "develop" is the small remaining feeding ground for these birds.

The original plan to keep this area open as habitat was well thought out. The present "rethinking" is not taking in the bigger picture. The freeway has already turned into a virtual parking lot because of this short term thinking. Please choose to refrain from adding to it.

Oppose
Pat Schink at May 21, 2025 at 8:33am PDT
As a Natomas resident I wish to record my opposition to this project. It is ill considered and will not enhance the community. I agree with all the earlier posted objections.

Oppose
Airrion Copeland at May 21, 2025 at 8:32am PDT
Dear Planning Commissioners,
As a resident of Sacramento in the North Natomas/Westlake area who lives near the proposed Airport South Industrial Project (ASIP), I am writing to express my strong opposition to this development.

This project threatens to destroy invaluable farmland and vital wildlife habitat, open spaces that not only deﬁne the character of our region but serve as crucial buffers against climate change and ecological loss. As someone who runs in this area regularly, I witness ﬁrsthand the beauty and biodiversity that would be lost if this project moves forward.

In addition to the environmental damage, ASIP would place a high volume of diesel truck trafﬁc directly next to neighborhoods and a local school, risking serious health consequences for families and children. This is not just an environmental issue, it’s a public health and environmental justice issue.

Sacramento is known for its commitment to sustainability and “farm-to-fork” values. ASIP contradicts these principles by prioritizing short-term industrial gain over long-term community wellbeing, climate resilience, and responsible land use.

I urge you to recommend that the City Council reject this project or, at the very least, require major revisions that safeguard open space, public health, and the integrity of our local ecosystems.

Please help protect what makes Sacramento truly livable.

Sincerely,
Airrion Copeland
Sacramento Resident
Oppose
Joyce Wolfe at May 20, 2025 at 9:44pm PDT
I’m writing as a resident of Westlake to urge you to oppose the Airport South Industrial Project.

Our neighborhood is made up of families who have made a home here because it’s peaceful, safe, and close to nature. The proposed industrial project puts all of that at risk. We’re not against development. We’re against development that puts warehouses before people.

This project would ﬂood El Centro, Del Paso, and surrounding streets with semi-trucks. We’re talking about hundreds of diesel trucks passing near homes, parks, and schools every day. The Environmental Impact Report admits there will be health impacts — yet does little to protect us. That’s not acceptable.

This isn’t just about our streets and lungs. It’s also about our land. This area includes farmland and open space that supports wildlife and helps prevent ﬂooding. Once it’s gone, it’s gone forever. Sacramento claims to care about sustainability — this project ﬂies in the face of that.

Reports show that Sacramento already has high industrial vacancy rates — some over 80% in newly built warehouses. Why rush to pave over more land when we can’t even ﬁll what we’ve already built? If the project is approved despite the community’s overwhelming concerns, the city must commit to creating a substantial, enforceable buffer between Westlake and the industrial site. This is not just a landscaping issue — it’s about protecting the health, safety, and dignity of a residential community that didn’t sign up to live next to a logistics hub.

We are calling for a minimum 1,500-foot setback between any warehouse structure and the nearest residential property line. Our community deserves that much at the very least.

We chose to live in Westlake because it’s a safe, livable place to raise families. This project threatens everything that makes it special.

Please listen to the people who live here — the people who walk these streets, breathe this air, and call this place home.

Oppose
Kathleen Ave at May 20, 2025 at 7:03pm PDT
The fact that this proposal has come as far as it has suggests that its supporters have succumbed to Shifting Baseline Syndrome in which a degraded and unhealthy environment is considered "normal" or "acceptable" because memories and knowledge of past conditions have faded. That can make it difﬁcult to imagine a world in which these conditions could improve, but they certainly can if we push back on the continued proliferation of warehouses and the over-consumption of resources that they enable.

This Airport South project is proposed for land outside of Sacramento County’s 1993 Urban Services Boundary (USB) and on land not permitted for development in the 1996 Natomas Basin Habitat Conservation Plan (NBHCP). For all the reasons that the USB was established - to mitigate ﬂood and wildﬁre risk and support permanent preservation of agriculture, range lands, critical habitat and natural resources - it must be maintained. This is especially important now because the physical impacts of climate change are exacerbating many of these existing risks.

It is especially disturbing to see the City staff supporting a developer's proposal to build single family housing on a parcel currently zoned for multi-family that is directly adjacent to a light rail station (Item #5) and ON THE SAME AGENDA supporting this ill-advised attempt to build more warehouses on open space. These moves are the opposite of smart growth. I strongly oppose this proposal.

Neutral
Matt A at May 20, 2025 at 4:00pm PDT
Does this development pencil out ﬁscally for the city long-term? No real opinion on the development itself (logistics/shipping are a necessary part of our world) but if the initial infrastructure needs to be debt-ﬁnanced by the city ($92 million of new infrastructure liabilities!) - Is a large enough return expected from this development to fund repair and replacement of the infrastructure? (e.g. roads) As a taxpayer without any ﬁnancial expertise it would be super helpful if staff could just high-level how the project is anticipated to offset the onging infrastructure liabilities we are taking on from annexing/building out the backbone infrastructure. Do the project revenues justify our new costs on an ongoing basis?
Oppose
Jan Schori at May 20, 2025 at 1:08pm PDT
Dear Commissioners:

The Airport South Industrial Project is too polluting, too big and too close to current City Westlake residents and the Paso Verde schoolchildren.

The EIR describes and documents the expected increased cancer risk to neighboring residents and children as a result of the operation of the project’s heavy-duty diesel trucks. The map of the plume of diesel carcinogens extends well into multiple homes within Westlake.

The EIR in its alternatives analysis concedes that there is a need for a signiﬁcant buffer between residential and industrial uses to avoid signiﬁcant adverse impacts (such as exposure to toxic and cancer causing air contaminants and noise conﬂicts). It is unconscionable to be imposing this cancer increase risk on existing city residents; city government has a responsibility to protect the health and welfare of its citizens and must not approve this project as currently conﬁgured which will put people’s lives and health at risk.

Please reject Airport South as currently recommended. If it is your intent to let it proceed, then it should include a signiﬁcant setback of at least one quarter mile from the existing Westlake neighborhood residences and the Paso Verde elementary school. This setback buffer requirement must apply to the project and the non-participating parcels.

The latest project proposal as recommended by your staff includes a new 125 foot setback (see page 4, not in EIR?) to add to the City’s existing 200 foot dirt buffer between the residential neighborhood and the project, which is a step in the right direction but which is insufﬁcient and inadequate to address the toxic air quality and noise impacts on Westlake and the Paso Verde school. Please see the EIR’s “reduced footprint alternative” analysis, which is the preferred environmental alternative, for a description of the signiﬁcant environmental beneﬁts of moving the project further away from residents and the school.

We ask you to require a much bigger setback of at least one quarter mile from residences and the school to lessen and mitigate the egregious multiple adverse impacts of this industrial development on its existing neighbors.

Additionally, the staff recommendation proposes to go forward with annexation and “pre-zoning” of the non-participating Cayucca parcel without doing a toxic air contaminant study, allowing the study to be avoided completely if certain representations regarding intended use of the property are made, or to be done at some point in the future after the property has been approved for industrial zoning. This parcel directly abuts the Paso Verde school and Westlake residents. The risk which must be studied by the City and this property owner is about daily cancer-causing toxic air contaminant exposure to school children from kindergarten through grade 8 and neighboring residents (all considered “sensitive receptors” in air quality analysis regulations). This study must be done now if the Cayucca parcel is to be considered for industrial pre-zoning. We are shocked that this attempt to bypass such an important issue has been included in the staff’s recommendation. The study must be a mandatory requirement on the developer and done before any action is taken relating to approval of industrial development on this property. The owner(s) should not be rewarded for his non participant status by allowing him to grandfather his project under this applicant’s studies, especially when development of this owner’s property will potentially have the greatest adverse air quality impacts on the neighborhood and the school.

Respectfully submitted,
Jan Schori & Case Butterman, 191 Lanfranco Circle, Sacramento Oppose
Susan Herre AIA AICP, Immediate Past President, ECOS at May 20, 2025 at 12:29pm PDT Dear City of Sacramento Planning & Design Commissioners, Please see our letter re the Airport South Industrial project, and the PowerPoint on the Urban Services Boundary that is included.

Susan Herre AIA AICP
Attachments: 250520_LETTER_to_City_PDC_re_Airport_South_Industrial.pdf Jacob Bredberg admin at May 20, 2025 at 9:11am PDT
Additional eComments received by the Ofﬁce of City Clerk. Norman PT 2 Attachments: 05222025_Item_06_2025-01031_Additional_eComments_received_by_the_Ofﬁce_of_City_Clerk_--_PT_2.5.pdf 05222025_Item_06_2025-01031_Additional_eComments_received_by_the_Ofﬁce_of_City_Clerk_--_PT_2.0.pdf Heather Brantley admin at May 20, 2025 at 9:09am PDT
Additional eComments received by the Ofﬁce of City Clerk. Norman PT 1 Attachments: 05222025_Item_06_2025-01031_Additional_eComments_received_by_the_Ofﬁce_of_City_Clerk_--_PT_1.0.pdf 05222025_Item_06_2025-01031_Additional_eComments_received_by_the_Ofﬁce_of_City_Clerk_--_PT_1.5.pdf Cecelia Ventress admin at May 19, 2025 at 9:39am PDT
eComment received by the City Clerk's Ofﬁce
Attachments: 05222025_PDC_eComment_Item_06.pdf
Oppose
Odet Ford at May 19, 2025 at 9:05am PDT
Dear Commissioners,
My name is Odet Ford, and I am the parent of a student at Paso Verde Elementary School. I’m writing to express deep concern about the proposed Airport South Industrial Project adjacent to the school. This development poses serious risks to air quality, environmental health, and noise levels, directly impacting our students' well-being and ability to learn.

What’s especially troubling is that, so far, the School Board and school leadership have not publicly addressed the project or informed school families about its potential consequences. As a concerned parent, I strongly urge you to oppose this development and formally communicate that position to the City Council and Planning Commission.

If the project does move forward, I request that the Commission advocate for a minimum 1,500-foot buffer zone to help mitigate the harmful effects of air and noise pollution near the school.

Thank you for your attention to this critical matter. I hope we can count on your leadership to help protect Paso Verde students' health and learning environment.

Sincerely,
Odet Ford
Mark Rodriguez, activist at May 17, 2025 at 10:36am PDT Please do not go to Sun Spa, located at 6804 Fruitridge Rd #A Sacramento, CA, 95820, They will claim that they are too busy for you.

Meeting: Planning & Design Commission (Supplemental Material Updated 5/22/2025 @ 10:15 a.m.)
Meeting Time: May 22, 2025 at 5:30pm PDT
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6. Airport South Industrial Annexation (P21-017) [Noticed 05/02/2025] File ID: 2025-01031 SUPPLEMENTAL MATERIAL Item 06 2025-01031Airport South Industrial Annexation (P21-017) [Noticed 05/02/2025] Item 06 2025-01031 Airport South Industrial Annexation (P21-017) [Noticed 05/02/2025]  75 Public Comments
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From: John Roberts <[email protected]>
Date: Wednesday, May 21, 2025 at 11:57 AM
To: [email protected] <[email protected]>
Cc: Heather Fargo <[email protected]>, Kimberli Burns <[email protected]>, Jennifer Skupic <[email protected]>, Eric Dubovik <[email protected]>
Subject: Re: Outside the 17,5000-acre Permit Area
Susan: thanks for the phone calls and conversations Friday.

I promised to recap my answers to the question you posed in that conversation. Your question regarded the logic behind the Conservancy’s views on the Airport South Industrial Project.

I hope this recap is helpful. My guess, based on your follow-up questions during that conversation, was that perhaps I wasn’t communicating very well. And I could tell you were taking notes as I spoke, so maybe some of what I said didn’t get heard. By responding in writing, perhaps the conversation could be made more clear so that you get the answers you deserve and requested.

Before doing this, I want to again state that your statement that the Conservancy supports Airport South Industrial Park (ASIP) is not accurate.

Founding Conservancy Board Chair Anne Rudin put us on this course many years ago: avoid taking positions for or against urban developments. The Conservancy serves at the pleasure of the “Parties” to the HCP, and as I said in our phone conversation, at any time, for cause or even without cause, the Conservancy could be replaced with a different Plan Operator.

The Conservancy has never advocated for or against urban developments. We will provide information relevant to the implementation of the HCPs to decision makers and interested parties if asked, but otherwise do not play a role in the land use decision making process.

So, here is what I tried to say in response to your question Friday:

1. ECOS says approval of the proposed ASIP would set a precedent. This is getting said a lot these days with regard to any approval of the proposed ASIP. As I noted, I believe the proverbial horse is out of the barn. As the Conservancy made clear to the City Council many years ago, in open session and elsewhere, the Greenbriar project did that. And did it in a major way. The Conservancy has been deeply confounded with this precedent.

So, we clearly understand the negatives that come with precedent.

2. Project setting and biological viability. We have to be realistic about the proposed ASIP.

Estimates by CalTrans for 2025 show traffic counts to the adjacent north of the proposed ASIP project site (on Interstate 5) at between 120,000 and 180,000 per day.

It’s hard to even conceive of that many vehicles in one day, let alone next to land that might serve as productive habitat land.

To the northwest, we have SMF with 1.2 million passengers expected to board aircraft in 2025. We have roughly 300 flight operations a day there, nearly all (depending on time of year) going overhead or in the vicinity of ASIP’s proposed development area.

To the adjacent west, the County of Sacramento has publicly noticed its intent to install a 122-acre “WattEV” industrial operation, with approximately 92 acres of reflective glass (solar panels), many in the NBHCP-established Swainson’s Hawk Zone.

To the east, we have industrial (warehouse and storage).

I am hoping we can all agree this location is not exactly top-rate wildlife habitat. I say all this to make this point: the Conservancy’s Fisherman’s Lake Reserve Area (FLRA) has been expensive and the results of all that investment and care for the benefit of the HCPs’ Covered Species has been disappointing. At some point, all the money in the world (proverbially speaking) and diligence cannot overcome the challenging effects of urbanization on the HCPs’ Covered Species. (We HAVE NOT stopped trying to make the FLRA biologically productive.) The Conservancy tries to be mindful of these factors in deciding where to focus its efforts to secure lands that will best support the HCPs’ Covered Species.

3. “
High hill to climb.” The point is made that those developing outside the 17,500-acre Permit Area will have “an uphill battle” or, otherwise, a “high hill to climb” to evidence and acknowledge needs of the HCPs in mitigation (loosely stated by me and not intended to be legal interpretation). This was part of a theme that was stated in the NWF v. Norton case (2005).

ECOS and others may conclude that the Conservancy, as you say, supports the proposed ASIP project because we like to say the following:

In nearly all other cases of ground disturbance (urbanization) outside the 17,500-acre Permit Area, the Conservancy’s ability to implement the HCPs has been made more difficult and expensive. Some projects, however, make it easier and less expensive. (Loosely stated: they have climbed the proverbial high hill; they made peace with the proverbial uphill battle; in both analogies, that is, to some large degree).

Let’s take for example the case of the Natomas Levee Improvement Project (NLIP). This was and is a massive ground disturbance project. However, SAFCA conducted mitigation for the NLIP that has benefitted the Conservancy’s ability to implement the HCPs. Granted, it’s not all been without adversity, but overall, SAFCA and the other parties working with it, especially the USACE, have made improvements which further the implementation effort. Similarly, PG&E has done a project outside the Permit Area, cooperating fully with the Conservancy and the State and federal Wildlife Agencies. It actually added to the HCPs’ implementation advancement. These are the exceptions:
in most other cases, the results have been seriously challenging and detrimental to HCP implementation.

And so today we look at the proposed ASIP, keeping in mind the discussion in number one above, and we see ASIP’s proponents have taken numerous steps to reduce the proposed project’s impact on the Conservancy’s mitigation land work in the area. And also to enhance its HCP implementation effort.

We understand that the ECOS and others believe Conservancy acknowledgement of these steps to be an indication of support for the project. It is not. It is a realistic assessment of the situation. The public (and presumably ECOS) has come to trust information the Conservancy issues. We’ve strived to be transparent, and to ensure that we answer and respond in ways that are well grounded in fact. This is one such case.

But in no case can this be construed as support for the project. You are aware of our recent letter to the Sacramento County Board of Supervisors on development outside the 17,500-acre Permit Area. We stand by that letter. But we are not going to prevaricate as to the harmful or helpful effects we anticipate as to a proposed development if asked. We’re going to state the facts as we see them. Indeed, we believe authorities WANT the Conservancy to have a good and fair assessment of these proposals.

4. What happens if the City declines ASIP. We have no hard information to support what we’re about to say here, but we believe that if the City were to decline to annex and approve the ASIP, the next most likely next step would be for the landowners to submit the same or similar project to the County of Sacramento for consideration. With the City, the Conservancy will know that with its (that is, the City’s) commitment to the State and federal Wildlife Agencies (see the relevant “Implementation Agreements”), the City would most likely be cognizant of Plan Operator issues on this particular proposal. We do not know if that would be the same if this project were considered by the County. So, in the interest of doing what’s best for the HCP implementation effort and based on nothing more than our anticipation and expectation, the Conservancy wonders what happens next if it is rejected by the City.

Finally, and separate from the points I tried to make in our phone conversation, we emphasize there are many urban development proposals in the Sacramento County portion of the Natomas Basin that are out for public review or are publicly declared. In all cases except the proposed ASIP, not one of those currently being considered have worked productively with the Conservancy on advancing or even minimizing impacts on the HCP implementation effort.

I have shared the information that I have on many of these projects with ECOS. For example, the County’s WattEV project, again, immediately adjacent to the proposed footprint of the proposed ASIP, will place approximately 92 acres of reflective glass in part in the Swainson’s Hawk Zone. Can you imagine what impact this will have on HCP implementation efforts? Despite our questioning, the County has evidenced zero interest in sharing details on what, if any, steps it would take to lessen the impact on HCP implementation efforts.

Indeed, Judge Levy wrote in his 2005 decision in federal court (NWF v. Norton ) the following
regarding urbanization outside the 17,500-acre Permit Area and inside the Sacramento County portion of the Natomas Basin:

Thus, while plaintiffs contend that future development will vitiate the NBHCP, it is more likely that, if future development in the County will have this effect, the Secretary will decline to issue ITPs for development in the County or will insist on mitigation that may be considerably greater than that required by the NBHCP.” p. 22, NWF v Norton So we ask of these project proposals, what exactly will be the “mitigation that may be considerably greater than that required by the NBHCP?” We see “considerably greater” proposed on ASIP, we saw “considerably greater” with NLIP, we saw “considerably greater” with PG&E. We see stonewalling on nearly all others. These projects have not negotiated the “uphill battle” or the “high hill to climb” in terms of mitigation consistent with the court’s statement about the NBHCP.

So, that’s a better recounting of my answer to you. I hope this is adequately responsive to your inquiry.

John
March 14, 2025
To: LAFCo Commissioners, Commission Clerks and Planners; Sacramento County Board of Supervisors, Planning Commission and Planners; City of Sacramento City Council, Mayor, Planning Commission and Planners
Subject: Airport South Industrial Project (P21-017) proposed annexation into the City of Sacramento
The North Natomas Community Coalition (NNCC) is open to residents of all North Natomas neighborhoods. NNCC’s vision is to assure North Natomas maintains its desirability and quality of life.

NNCC has reviewed the Airport South Industrial project since August 2022 as the project worked to develop the Draft Environmental Impact Report (EIR). We have reviewed the Draft EIR and have some serious concerns about the use of the designated land, which is currently zoned for agricultural use, being changed to Industrial – Planned Unit Development and Commercial – Planned Unit Development. We provided these comments previously in July 2024 (see below).

Key points:
• The Airport South Industrial Project is located outside the Urban Services Boundary for Sacramento County and is located inside the Natomas Basin Conservation boundaries. • There are many other available Industrial – Planned Unit Development and Commercial - Planned Unit Development locations throughout Sacramento County. • The Airport South Industrial Project is adjacent to a long-time housing development and an elementary school, with negative environmental effects which cannot be mitigated.

One of the purposes of the Local Area Formation Commission according to its website is to “to exercise its authority to guide development away from open space and prime agricultural land uses unless such actions would not promote planned, orderly and efficient development.” Since this project seeks to repurpose agricultural land to industrial uses, it needs to provide evidence that this is the only location that can accommodate this purpose in Sacramento County.

The proposed Project is outside the Urban Services Boundary for Sacramento County. It is located on land which is currently zoned Agricultural – 80 acres. This area is the habitat for numerous protected species, which can coexist with agricultural land but will be displaced with the urbanization of the land.

Allowing projects of this nature outside the Urban Services Boundary will set a precedent for even more urban sprawl, which is the direct opposite of the purpose of both LAFCo and setting boundaries for urbanization.

There are many spaces available throughout Sacramento County within the Urban Services Boundary which are suitable for this development. Directly across the Interstate 5 freeway is Metro Air Park, with a large area of open space which has been designated for industrial/commercial use.

This area has already been partially developed with structures of similar sizes and uses as those proposed in the Airport South Industrial Project, and additional space is still available for this development.

Additionally, there are several other industrial/commercial properties which have adequate vacancy rates to accommodate the buildings proposed for this project. These include McClellan Park, the Northgate Industrial Zone and Mather Field.

All of these alternatives are located far enough away from residential developments that they do not affect the quality of life for the residents, nor would they affect the value of the homes adjacent to the development.

The area selected for this project does not have access to public transportation, nor is it part of any active transportation network which would provide non-vehicular access. This means that in addition to the large truck traffic in support of the facilities, there will be increased commuter traffic to the site. This increases the environmental impact of the project.

The location immediately adjacent to a highly populated neighborhood and elementary school also is problematic. Vehicular and industrial noise, traffic and possible accessibility to the nearby developed area will create the need for additional public safety services and code enforcement, at expense to the City of Sacramento, which already faces a budget shortfall. Additionally, in order to secure the facilities, additional lighting will be required which will create light pollution for the adjacent neighborhood and school.

Since tenants have not been identified, there is no way of knowing if the development will be providing warehousing, with increased big truck traffic, or industrial businesses, which may create hazardous waste, noxious odors and noise pollution. Either situation has environmental issues which cannot be mitigated.

Because of these issues, the North Natomas Community Coalition opposes the proposed project and asks LAFCo to deny the request, the City of Sacramento not to annex the property and the Planning Department of the City of Sacramento to deny the rezoning from Agricultural land to Industrial/Commercial.

Respectfully submitted,
Lisa Pray, President
North Natomas Community Coalition

Previous letter on the Draft Environmental Impact Report July 16, 2024
To: LAFCo Commissioners, Commission Clerks and Planners; City of Sacramento City Council, Mayor, Planning Commission and Planners
Subject: Airport South Industrial Project (P21-017) Draft Environmental Impact Report and proposed annexation into the City of Sacramento
The North Natomas Community Coalition (NNCC) is open to residents of all North Natomas neighborhoods. NNCC’s vision is to assure North Natomas maintains its desirability and quality of life.

NNCC has been reviewing the Airport South Industrial project since August, 2022 as the project worked to develop the Draft Environmental Impact Report (EIR). We have reviewed the Draft EIR and have some serious concerns about the use of the designated land, which is currently zoned for agricultural use, being changed to Industrial – Planned Unit Development and Commercial – Planned Unit Development.

The Draft EIR lists in Table 2-1 the Summary of Impacts and Mitigation Measures. Of the numerous impacts, 39 are rated as Significant. Three of those cannot be mitigated, particularly regarding the impact on the aesthetics of the properties adjoining the project site. People who bought homes on the west side of the Westlake subdivision will have their view to the west degraded, possibly impacting the value of their properties. Additionally, light pollution from the site could degrade the value of the properties adjacent to the development, along with noise and noxious odors which might be emitted from the occupants of the structures. Furthermore, the added large vehicular traffic brings noise and pollution to neighbors to the east of the project, based on prevailing winds.

Since no tenants have been identified, it is impossible to determine how significant these impacts might be.

Numerous others have commented on the environmental impact of changing agricultural land to industrial/commercial land due to loss of habitat and the necessity of creating drainage canals and the sewer and water infrastructure required.

Draft EIR Section 7.3 Selection of Alternatives analyzes other ways the project could be mitigated by reducing scale, feasible alternatives, or avoiding significant environmental impacts. Mixed-Use Residential Alternative explores the addition of adding a mixed-use housing component. This analysis rejects the residential alternative, finding that "development of portions of the project site with residential uses would prevent the proposed project from developing employment uses…and could result in conflicts related to the incompatibility between residential and industrial uses. Overall, a Mixed-Use Residential Alternative that could accomplish the project objectives is not considered feasible. As a result, the Mixed-Use Residential Alternative is dismissed from detailed evaluation.” Since this proposed industrial development is adjacent, adjoins and borders the Westlake Residential Subdivision and Paso Verde School, the conflict of incompatibility is inherent. The project has inappropriately been sited next to a residential community which is incompatible with the industrial uses. The EIR fails to analyze impacts to community sustainability and home values caused by putting what the analysis acknowledges is an incompatible industrial use within residential.

Finally, appropriate land is abundantly available just north of Interstate 5. This area is already being developed for industrial and commercial uses and provides the same access to connecting freeways, the airport and other services without impacting adjacent homes. There is no need to adversely affect the residences, parks and schools which will be near this proposed project.

North Natomas Community Coalition strongly opposes the annexation of this land to the City of Sacramento for the purposes analyzed in the Draft Environmental Impact Report. We urge LAFCo and the City of Sacramento to reject this request to modify the land use, rezone the parcels and expand the Sphere of Influence.

Respectfully submitted,
Lisa Pray, President
North Natomas Community Coalition

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

December 18, 2024 VIA EMAIL
Matthew Aijala
Assistant Planner, New Growth Section
300 Richards Blvd., 3rd Floor
Sacramento, CA 95811
RE: Airport South Industrial Annexation (P21-017)

Dear Matthew:

Thank you for routing the following development to Civic Thread. The Airport South Industrial PUD Site Plan and proposed annexation plans to bring the proposed development and land under authority of the City of Sacramento while developing predominantly light industrial uses and highway commercial uses. The following review centers on the cyclist and pedestrian perspective within the circulation plan provided.

We want to commend the developer's inclusion of planter separated sidewalks wherever sidewalks are present. This allows for the planting of trees to provide shade, reduce Urban Heat Island effects, and support improved air quality, particularly where industrial traffic will likely be concentrated. In review of the proposed development’s circulation plan and roadway cross-sections, Civic Thread has several concerns regarding the provision or lack thereof of appropriate cycling facilities.

Recognizing the predominantly industrial uses and accommodating travel lane configuration, it is our opinion that except for Airport South Industrial Drive which possesses a 12’ sidewalk and can accommodate both pedestrians and cyclists, all other roadways provide either significantly inadequate cycling facilities or do not provide them at all. Additionally, the plans incorrectly label “A” Drive as possessing a Class II bike lane in the General Plan Bikeway Diagram yet the cross section for “A” Drive indicates no bike lanes planned. Instead, curb to center lane on each side indicates 3’ of curb and gutter, 17’ travel lane, and 6’ (doubled to 12’ when including both sides) as proposed landscape median or two way turn lane. Please see the details of our overall recommendations below.

Bikeway and Cycling Facility Recommendations:
• Where plans indicate the provision of “Landscape median or two way run lane” we recommend providing the landscape median.
o This will allow additional shade, permeable surface, and overall traffic calming opportunities within the development.

Page 2 of 2 ends

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

• Provide, at minimum, a 3’ buffer to the 5’ bike lane on the southbound travel lane of Metro Air Parkway.
o The current configuration, at its widest, has a 5’ bike lane between a 14’ right turn lane and two 11’ travel lanes and one 11’ left turn lane. This is a very high stress configuration for cyclists.
• Increase all 5’ minimum bike lanes to Sacramento Street Design Standards (pg. 12) minimum designated 6’ bike lane width .
• Building from Airport South Industrial Drives 12’ walkway, implement a complete low-stress bike network allowing maximum protection for cyclists traveling between SMF, South Airport Industrial, and existing development to the east.

In addition to the recommended travel lane modifications described above, we strongly recommend the following connectivity considerations to support reduced demand for single occupancy vehicle trips and overall congestion along I-5 and within the nearby neighborhoods that may result from intensified land use development via the Upper Westside Specific Plan and other developments taking place in and around North Natomas.

Consideration and retention of access to the proposed site via the multi-use path traversing Egret Park to the southeast would allow for a low-stress, convenient means for active modes to access employment, the proposed restaurants, Sacramento International Airport (SMF) directly, or as discussed in the next section, access an intermediate transit stop for people traveling to or from the airport. The current proposed access to or from the site regardless of mode relies on Bayou Way at El Centro Road which proposes no bike lanes and 15’ travel lanes which will likely induce speeding and add significant stress to those who must bike to or from the location and dissuade would be travelers who may otherwise be interested in biking to or from the location.

As mentioned, circulation planning for this development should consider future transit connection opportunities. Currently, SacRT Bus Route 13 terminates in a loop near Del Paso Road and Hovnanian Drive with a stop at Del Paso Road and El Centro Road. A transit stop within the Airport South Industrial development should be incorporated in coordination with SacRT and to the extent feasible, a continuous, low-stress, route should be developed connecting these stops to incentivize alternatives to SOV trips.

Please notify Civic Thread of future routings or notices for this project.

Sincerely,

David Moore, AICP
Community Planning Specialist

December 5, 2024Matthew Aijala Assistant Planner, New Growth Section 300 Richards Blvd. 3rd Floor Sacramento, CA 95811 cc: Cheryle Hodge [email protected] Garrett Norman [email protected] Re: Draft EIR for the Airport South Industrial Annexation (P21-017) Dear Mr. Aijala: Thank you for the opportunity to provide comments on updated plans for the Airport South Industrial Annexation project (P21-017). As you know, the Paso Verde School is located adjacent to, and south of the project site and the closest school building is approximately 250 from the project site as measured at the closest point. An outdoor play area is in the northwestern portion of the school site, approximately 240 feet from the project site, as measured at the closest point. We understand that the Tentative Master Parcel Map currently before the City is focused on the project applicant sponsored lands. However, we have some requests that pertain to the environmental impact report (EIR) prepared for the whole of the requested actions that, in particular, focus on conditioning the future development of Parcel 8. Air Quality - Mitigation Measure 4.3-1(b) – We appreciate the requirement for less polluting construction equipment, and believe that Tier 4 equipment should be available and used when electric equipment cannot be used on-site. Air Quality – Mitigation Measure 4.3-2 – We appreciate the requirement for zero-emission forklifts for future development. We believe that this mitigation measure was likely intended to apply to all uses on-site that require forklifts, though the mitigation language currently limits this to industrial uses. It would help clarity to require zero-emission forklifts for all tenants, period. Air Quality – Impact 4.3-3. We understand that the toxic air contaminants impact is reported for only the maximally exposed individual, and that the resulting cancer risk was 9.53 relative to a threshold of 10 excess cancer cases in a million and therefore less than significant. We also understand that no assumption for heavy duty trucks was included as a part of the EIR analysis. We would recommend developing a reasonable assumption for this non-participating parcel based on participating parcels

and revising the HRA. This would be appropriate since the set of approvals would convey prezoning and ultimately zoning to the non-participating Parcel 8 and since an expectation of some heavy-duty truck activities on this property is not speculative. While not for the purposes of the HRA, for the purposes of the hazards analysis under Impact 4.7-3, the EIR did assume that Parcel 8 would be developed with warehousing to act as fulfilment centers for large regional retailers (EIR, page 4.7- 19). It appears that assumptions for the development of Parcel 8 were also used in the trip generation and transportation analysis (EIR, page 4.12-13 through 4.12-14).

In addition, please provide a buffer for the school site for Parcel 8 similar to the detention basin locations for other participating properties that effectively provide a buffer at the southern edge of the project site (Draft EIR, page 4.3-51). Figure 3-4 – Schematic Basin Drainage Plan, on page 3-11 of the Draft EIR shows a detention basin for Parcel 8 that is instead in the southwestern corner of Parcel 8, which would not provide a buffer for the school. Please condition the project to require the detention basin to provide a buffer along the southern portion of Parcel 8 or require some other type of buffer in this area. Please also include a condition that prohibits the use of airborne chemical applications on the southern portion of Parcel 8.

Air Quality - Mitigation Measure 4.3-3. Mitigation Measure 4.3-3 requires a Health Risk Assessment (HRA) prior to issuance of a building permit for development of Parcel 8 under certain conditions.

Please revise the mitigation language to make it clear that the HRA shall include not only emissions sources proposed on Parcel 8 but also for the entire project site.

Hazards and Hazardous Materials - Mitigation Measure 4.7-5(a). This mitigation measure includes options to prevent the establishment of resident populations of Canada geese on the project site that include the use of noise generators (e.g., pyrotechnic devices, blank cartridges) and the use of chemical repellents. If noise generators are to be used within the southern or southeastern portions of the project site when school is in session, please notify the Paso Verde School in advance. Please characterize the approach for chemical repellents to clarify that this would not include any airborne chemicals that would leave the project site.

Again, NUSD is very appreciative of the opportunity to provide comments on updated plans for the project. Please do not hesitate to contact me if you have any questions about our requests.

Sincerely,

Lalanya Rothenberger
Executive Director, Facilities and Strategic Planning
Natomas Unified School District

Westlake Master Association
4701 Westlake Parkway, Sacramento, California 95835
916.621.3722
{5668.01/00651771.3}

August 24, 2023

Councilmember Lisa Kaplan District 1 Supervisor, Phil Serna Council District 1, 915 I Street, 5th Floor 700 H Street, Suite 2450 Sacramento, CA 95814 Sacramento, CA 95814
Email: [email protected] Email: [email protected]

Re: Opposition to Proposed Airport South Industrial Project in North Natomas We write to you, as the member elected Board of Directors of Westlake Master Association and seek your support in opposing the proposed Airport South Industrial Project, and hope you are committed to preserving the quality of life for residents of the Westlake community , whic h is part of North Natomas . Westlake is a residential community of over 3,000 residents living in over 900 homes and if approved the proposed Airport South Industrial Project would be immediately adjacent to and would negatively and significantly impact our community.

The proposed 419-acre Airport South Industrial Project is currently undergoing environmental and LAFCO review in connection with the developer NorthPoint's request to annex the project into the City of Sacramento . The Airport South Industrial Project would directly abut the Westlake residential community (current City boundary) and the recently opened Natomas Unified Paso Verde elementary and middle school. The development's location is also near sensitive and protected wetlands and wildlife habitat, including the nesting and f oraging habitat for the Swainson's Hawk, which is listed as a threatened species by the State of California.

Westlake's B oard and members have attended presentations on the project by representatives of NorthPoint and ECOS, the Environmental Council of Sac ramento. We are advised this annexation would constitute one of the largest industrial projects in the City of Sacramento's history, and we cannot understand why the City would consider such a development directly next to a large residential community, a s ensitive protected wetland and threatened species habitat, and a school with young children.

Westlake Master Association
4701 Westlake Parkway, Sacramento, California 95835
916.621.3722
{5668.01/00651771.3}

The proposed project consists of five warehouses of over 6.6 million square feet. The current Amazon warehouse, which is one of the largest industrial warehouses in the Sacramento region, is approximately 855,000 square feet , located on the north side of Interstate 5 at the Metro Air Park exi t. This proposal constitutes a request to build more than the equivalent square footage of six new Amazon warehouses immediately next to the Westlake community, opening up industrial uses on the south side of Interstate 5. We encourage you to visit Metro Air Park to get a sense for what you are being asked to approve and ask yourselves whether you would deem such a project appropriate for your own neighborhood. Moreover, this development is not compliant with the North Natomas Community Plan.

It is clear the proposed project will produce significant negative impacts which cannot be mitigated, including excessive traffic, noise, air pollution, loss of open space and threatened species habitat, visual impact, and diminution of residential property values directly and negatively impacting the lives of the residents of the Westlake community .

As we await the release of the draft EIR with its analyses of these and other issues and will pay particular attention to the "no project" and "project alternatives" analyses which should be thorough. Given the numerous serious concerns listed above, and the negative impact this proposal will have on the Westlake community, our Board has unanimously voted to oppose the Ai rport South Industrial Project. Please add the Westlake Master Association to your project notification list.

On behalf of the Westlake community, we ask for your careful consideration and seek your support in opposing this proposal. Thank you for your consideration of our concerns and please contact us with any questions.

Sincerely,
Westlake Master Association
Monica Sanchez, President
Gabriela Alvarado, Vice President
Rajan Merchant, Treasurer
Jay Shukla, Secretary
Jonathan Burke, Director
Outlook
FW: Airport South Industrial Annexation - comments
FromGarrett Norman <[email protected]>
Date Fri 2/28/2025 2:05 PM
To Matthew Aijala <[email protected]>
Cc Cheryle Hodge <[email protected]>
FYI. Please save to our public comment folder and include their email address for public hearing notices.

Garrett Norman
Senior Planner, North Area
Community Development Department
City of Sacramento
Phone: 916-808-7934
Email: [email protected]
300 Richards Blvd, Sacramento, CA 95811
https://www.cityofsacramento.gov/community-development

From: Y Campbell <[email protected]>
Sent: Friday, February 28, 2025 12:46 PM
To: Garrett Norman <[email protected]>
Subject: Airport South Industrial Annexation - comments

Hello,

I may have more comments later but here are some initial thoughts:

We need a strong buffer between the school, park, and
residential areas and this new proposal.

If there is covered parking for heat, then at least make them have solar panels above them so that cuts down on electricity usage (you can use them to power the lights or other needed city services).

Make sure there is plenty of lighting to deter crime and keep the area safer. Make sure the roadways are improved to handle the larger footprint.
2/28/25, 2:07 PM Mail - Matthew Aijala - Outlook
https://outlook.office.com/mail/inbox/id/AAMkAGIzYzFkNTQ0LWY1NzItNDQ3Mi1hOWEwLTYyM2M2YzJiNzQ0MwBGAAAAAADMc7JFpHEZRKUHrwf… 1/2

I'm not excited about losing more open space to yet more "industry". It would be nice if we keep some of our spaces wild and open.

Yating Campbell
Westshore resident
2/28/25, 2:07 PM Mail - Matthew Aijala - Outlook
https://outlook.office.com/mail/inbox/id/AAMkAGIzYzFkNTQ0LWY1NzItNDQ3Mi1hOWEwLTYyM2M2YzJiNzQ0MwBGAAAAAADMc7JFpHEZRKUHrwf… 2/2 www.ecosacramento.net

April 11, 2024

Maya Wallace, Chair, and Members of the City of Sacramento Planning and Design Commission Cheryl Hodge and Garrett Norman, Planners in Community Development Department Via email

Re: Planning and Design Commission Hearing April 11, 2024 Discussion Calendar Item 5: Airport South Industrial Project File ID: 2024-00766

Dear Chair Wallace, Commissioners, and Staff,

We understand your review of the Airport South Industrial Project at this point is for general background, given that the Sacramento Local Area Formation Commission (LAFCo) has been asked to consider approval of a Sphere of Influence change to the City for the project.

Since the Draft EIR for the project is not yet out for review, that document’s analysis of the environmental impacts is not available to you.

We appreciate this opportunity to share our concerns
with you.

LAFCo should not, in our view, approve a Sphere of
Influence change to the City for this development, for
the reasons below and because of LAFCo’s own goals
shown in the image at right.

ECOS opposes the Airport South Industrial Project for
the following reasons:

• It is located outside both Sacramento County’s Urban Services Boundary and the City limits.

• The project location and use are inconsistent with the City and County general plans, the SACOG Blueprint, the Natomas Basin HCP, and LAFCo goals.

• It will have harmful direct impacts on the Paso Verde school, the Westlake neighborhood, and the nearby preserve land, including Fisherman’s Lake – impacts to air quality, traffic, property values, etc.

2 of 2

• There are other available sites within the City and County, including Metro Air Park on the Northside of I-5, that are already zoned for industrial uses. City of Sacramento development investments should occur in infill areas, not in greenfield areas that worsen sprawl. There are many areas in the City where this development and these jobs would be welcome and have a great positive impact.

• This project is proceeding at the request of the applicant, not the City. The Airport South Industrial Project has never been to City Council for them to authorize proceeding with either a Sphere of Influence request or annexation. In 2022, when ECOS asked for the project to be removed from the consent calendar and given a full hearing, City staff instead sent it to LAFCo without Council or public input.

Two additional points:

The suggestion of a hotel should be checked against allowable uses in the airport flight path.

Farmland should not be referred to as “vacant land.”

Thank you for your consideration of our comments.

Sincerely,

Susan Herre AIA AICP Heather Fargo
President of the Board of Directors Former Mayor, Lead ECOS Natomas Team

April 10, 2024

Kelly Boyle
Associate Planner
Community Development Planner
Community Development Department
[email protected]

Re: Airport South Industrial Project (P21-017)

Kelly Boyle:

This leƩer is in response to the NoƟce of Public Hearing for the Airport South Industrial Project (P21-017) (the “Project”) by the Community Development Department dated March 29, 2024.

The Project applicant is requesƟng a Sphere of Inﬂuence Amendment, ReorganizaƟon (AnnexaƟon and Detachment), Property Tax Exchange Agreement, Development Agreement, Public FaciliƟes Finance Plan, General Plan Map Amendment, Prezone, Planned Unit Development (PUD) Establishment (including a PUD SchemaƟc Plan and Guidelines), Project Municipal Services Review, and a Plan for Services.

As agendized, there is no acƟon to be taken on the Project or any of the Project’s components. Rather the item is listed as only an “informaƟonal item.” Thus, no acƟon or commitment may be taken, and notwithstanding the erroneous informaƟon on your noƟce, there is no requirement to raise any or all project defects now in order to subsequently bring legal challenge.

Seƫng aside that fact, certain issues should be appreciated regarding the Project.

First, the Project would be in violaƟon of the City’s Incidental Take Permit stemming from the June 24, 2003 biological/conference opinion of the U.S. Fish and Wildlife Service, thereby puƫng the City’s 50- year permit at risk.

Second, the Project would destroy approximately 12 acres of federally recognized wetlands including freshwater forested wetlands, freshwater emergent wetlands, and riverine habitat.

Third, the Project would re-route an exisƟng public road from a locaƟon adjacent to Interstate 5 to a locaƟon 200 feet from Sacramento City residents’ front doors. This same road would connect to fast food restaurants, a gas staƟon, and millions of square feet of industrial warehouse uƟlized by heavy trucks.

Thank you,

Sacramento CiƟzens for Equitable Development

BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW
10250 CONSTELLATION BOULEVARD
SUITE 2300
LOS ANGELES, CALIFORNIA 90067
(213) 572-0400

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Sacramento City CouncilOctober 21, 2025

Sacramento City Council
October 21, 2025