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LETTER 78: BARBARA WALTER
Response to Comment 78-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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LETTER 79: DAWN WHITNEY
Response to Comment 79-1
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR.
Response to Comment 79-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 79-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
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LETTER 80: ACME WONG
Response to Comment 80-1
As discussed under Impact 4.4-15 on page 4.4-79 of the Draft EIR, the Natomas Basin HCP is specifically designed to address potential impacts to biological resources on a cumulative scale within the basin. The Natomas Basin HCP is a multi-species conservation program adopted for the purposes of minimizing and mitigating the loss of habitat values and incidental take of Covered Species resulting from urban development, operation and maintenance of irrigation and drainage systems, and various activities associated with the Natomas Basin Conservancy’s management of reserves established under the Natomas Basin HCP. Through compliance with applicable Take Avoidance, Minimization, and Mitigation Measures, potential impacts to biological resources covered under the Natomas Basin HCP within the permit area are reduced to a less-thansignificant level.
Although only a portion of the industrial park footprint and nonparticipating parcels are within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to special-status plant and wildlife species with potential to occur on-site, including those not covered under the Natomas Basin HCP. Thus, through compliance with the applicable Take Avoidance, Minimization, and Mitigation Measures, the Draft EIR concludes that the proposed project would result in a less-than-significant impact to protected species.
With respect to payment of the Natomas Basin HCP mitigation fees, only site development occurring within the Natomas Basin HCP permit area would be required to pay the fees. However, to ensure the proposed project addresses potential impacts to Swainson’s hawk foraging habitat in on-site areas outside of the Natomas Basin HCP permit area, the Draft EIR includes Mitigation Measure 4.4-5(b), which requires the project applicant to pay the mitigation fees, should a portion of the City’s surplus HCP coverage acreage be made available to the project.
Please see Responses to Comments 66-3 and 66-4.
Response to Comment 80-2
The comment does not specifically address the adequacy of the Draft EIR. Please see Responses to Comments 25-3 and 40-5, as well as the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR.
Response to Comment 80-3
The comment does not specifically address the adequacy of the Draft EIR. Please see Response to Comment 80-1 and the Master Response.
Response to Comment 80-4
The comment does not specifically address the adequacy of the Draft EIR. Please see Responses to Comments 38-2 and 80-1.
Response to Comment 80-5
The comment does not specifically address the adequacy of the Draft EIR. The Alternatives Analysis chapter of the Draft EIR includes consideration of an Off-Site Alternative. As detailed on page 7-5 of the Draft EIR, off-site alternatives that could accomplish the project objectives or Final EIR
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accommodate a similar type and intensity of development as the proposed project are not considered feasible.
Response to Comment 80-6
The comment is a closing statement and does not address the adequacy of the Draft EIR. The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Please see the Master Response.
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AIRPORT SOUTH INDUSTRIAL PARK PROJECT
DRAFT EIR COMMENT HEARING SUMMARY
Date: June 12, 2024
Time: 6:00 PM
Location: Sacramento County Administration Building, 700 H St., Sacramento, CA 95814 Verbal Comments:
Public Comments
Commenter 1 (Harriet Steiner)
My name is Harriet Steiner and I live in north Natomas at Heritage Park. I want to take this opportunity to come down because many of us are very concerned about this project even though it’s not immediately adjacent to Heritage Park that it’s a precursor of what we have to see in the future.
and I think this project having looked at it is inconsistent with LAFCo’s basic policies of not having sprawl, and conserving agricultural uses. I think that the EIR right now does not really adequately address the fact that it is inconsistent with these policies and cannot be made consistent.
I also think it's inconsistent with the Natomas Basin Plan. And all the work that was put into it over these years to maintain the habitat on the fly way to continue to provide a place for our birds and other animals to live and to continue maintaining those the urban area in compatibly with the nonurban area.
I think it's really important before either you or the City take action to change those plans and change those plan lines that it's fully and adequately analyzed which I do not believe the current EIR does. So I think also there’s multiple adverse impacts that have been outlined by some of the comments you’ve got and I won’t go into them again.
But I think this is a really large project. I think it will bring huge amount of truck traffic. Right now as I read the truck traffic analysis there’s no analysis that goes beyond I-5 on Elkhorn. I don’t know how often any of you drive on Elkhorn but I will tell you that every time that I stop to make a left turn on Elkhorn I wait to see the two or three trucks who are going through the red light before I actually turn. I think that at a minimum the traffic needs to be expanded to look at the amount of traffic it will generate and go through to Elkhorn to the east. Thank you very much.
Commenter 2 (Dana Schwartz)
Hi, commissioners. So I appreciate that you’re taking these public comments. I do also see that this report came out, what, 10 days ago, and now you’re taking public comments. It’s pretty soon to be taking public comments. It doesn't really give us enough time to really digest the Draft EIR.
But even when you’ve shown is all the horrible things that this Draft EIR shows. It shouldn't be next door to a school. It shouldn't be next door to Westlake.
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I don't know how Lisa will want to live there with something that's ugly right next door. It's even said so in your report.
When I moved here two and a half years ago from Oakland it was because this area has these lovely open spaces. We're near the Pacific Flyway. We get to hear beautiful snow geese all the time. I do not want more traffic, more pollution. Our neighborhoods. This is not what needs to be happening now. We're already in climate crisis. How is this going to help? This is only going to increase urban sprawl and make it harder for us to have a sustainable environmental quality and people's lives to have quality. So, I'm asking you for these reasons to reject this proposal.
Now I'm also a head of the progressive study group at heritage park. A lot of people who couldn’t make it today asked me to come and talk for them. So I hope that you know that there are over 900 residents at Heritage Park and none of us want to see this project and other projects that are just going to take away all of our open spaces. And I have some letters from one of the residents.
So I would like to leave this here. Who would I give this to? Commenter 3 (Chris Burante)
I'm Chris Burante and I live in Heritage Park, also in North Natomas. I just want to say that we, we butt up against the Elkhorn Boulevard and rice fields that do make up one of the most four important nesting and feeding areas for migratory birds, a.k.a. the critical Pacific Flyway. I know that we are not talking about that parcel of land but it is part of the Natomas Basin Conservatory, and if you haven't had a chance to witness the migration of birds that are coming from Alaska, to and from Alaska, all the way down to Patagonia, South America I really invite you to do it. It's one of the great wonders of the world and we've got to protect it. It’s our responsibility, isn’t it? For ourselves and our future generations.
So I am here, basically, primarily to express my grave concern about the Airport South Industrial Project. This is a lot of acres to take out of open space land. It's definitely going to be a detriment to the quality of life of Natomas and the area. It butts up against a school, two communities, Westlake, Northlake. It takes important land, open land, farmland out of commission to be covered with asphalt to invite semitrucks, exhaust, light, light pollution, and incredible air pollution.
So I ask you as I know you are, and I want to thank you for your service, because this is volunteer and it's a gift to all of us. So please be our voices. Be a voice for wildlife, for the Natomas Basin habitat, and for the future generations. And as you can tell, I do oppose this, and I do hope that you will take my comments seriously.
Commenter 4 (Susan Wilson)
Good evening. I'm Susan Olsen. I'm also a resident at Heritage Park and oppose the Airport South Industrial Project.
I chose to move to Heritage Park two years ago because I valued all the open space and habitat area. During the fall, thousands of birds are in this area, which is absolutely amazing. With all of the buildings and homes around the City and County of Sacramento, we need to maintain our existing habitat areas. With the development of this project the birds would probably not feel safe in this area, and we wouldn't see them again.
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With this project, there would be additional traffic on the roads and highways and cause a lot of congestion. It's already a problem to get to and from Sacramento, downtown Sacramento. And if we added all of that other traffic it would be impossible. So I obviously oppose this project. Thank you.
Commenter 5 (Pam Harder)
Good evening. My name is Pam Harder and I do live in Heritage Park. I've been there about four and a half years. And I'm shocked at the amount of development that has already taken place since I moved in. The traffic is so bad I missed a cardiology appointment yesterday morning because I was stuck on the freeway and couldn’t get there in time. So and then if I go to Costco in Woodland, coming back on I-5, which will be right by where this is going, the truck traffic you just sit there, with all of those exhaust fumes going already.
And furthermore, there’s already a huge amount of space dedicated and every structure in place, for an industrial park on the other side of I-5, the metro parkway. And there are warehouses that have been constructed and have been vacant with “for rent” signs for months and months and months. So I don't see the need for more warehouses.
I, too, am concerned about the residential proximity and the grade school and the air pollution.
The noise pollution along with the traffic congestion and the paving over more open space.
We already pay extra flood insurance because we're in a floodplain and the more ground you cover the less opportunity to absorb water. So you are putting this plan, not you excuse me, this plan is just adding to that danger, and we already pay an extra amount for living in that floodplain.
So I ask you, please look at this carefully. There's a reason that boundary is set and there's no need to move it. There's plenty of open space in Sacramento. Thank you.
Commenter 6 (Heather Fargo)
Good evening, Chair Desmond and commissioners, appreciate the opportunity to share a few thoughts with you. My name is Heather Fargo. I’m the former mayor of Sacramento and was involved in establishing the Natomas Basin Conservancy when I was mayor. So it’s very near and dear to my heart, as is the open space and ag land in Natomas. I'm currently on the board of ECOS (Environmental Council of Sacramento) and I'm chairing the Natomas team.
So some of you have heard from me already regarding this project and several other projects in Natomas. I'm here tonight to not only to oppose the Airport South Industrial Project, but to really say that it's kind of shocking to me that we would be in a position of having to consider a project with such incredibly unavoidable significant impacts that cannot be mitigated. So I'm hoping that in a Final EIR you can come up with some mitigation.
If not, I hope the answer is “no” to the Sphere Of Influence change, as well as the annexation and the project. As you can see from my other speakers, this is very personal for a lot of us. Many of us here tonight live in Natomas and we live there because of the open space and because of the farmland and because of items like the strawberries we brought to you tonight so you can have a taste of Natomas.
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And we do feel that this project is growth inducing and it doesn’t seem to me that the EIR has addressed that as much as we see it. If this project is approved, this annexation is approved, it really kind of gives a green light to the other two larger projects. Collectively those three projects are over 8,200 acres. That’s eight thousand, two hundred acres. Lots of farmland. That's an important piece of the County's economy is farmland. And it’s an important piece of all of our quality of life. To be near open space, support the Flyway, support the Natomas Basin Conservancy. And I haven’t really heard any good reasons to give up on all of the collaboration and coordination that was done, for all the plans that you’d be saying “no” to if this goes forward.
So thank you for the time. I'm out of time. And appreciate your attention.
Commenter 7 (Susan Herre)
Good evening Chair Desmond and commissioners, Executive Officer Henriquez and staff. I'm Susan Herre, I’m the president of the Board of Directors of ECOS, Environmental Council of Sacramento. You are now considering approval of the expansion of the Sphere of Influence and potentially the annexation of 450 acres to the City. And the developer of the proposed Airport South has set your commission in motion. But we would ask you to consider upholding two commitments to the sustainability of our region. They are the Sacramento County’s urban service boundary from 1993, and the Natomas Basin Habitat Conservation Plan from 1997.
The Airport South Project and these two regional planning commitments are in conflict. The Airport South would be on land outside of the Urban Services Boundary and on agricultural land that is needed to support the Habitat Conservation Plan. And meanwhile two other projects in the Natomas Basin, the Upper West Side and Grand Park, residential projects that are now in planning at Sacramento County, are also equally in conflict with the sustainability commitments for the USB and the Habitat Conservation Plan.
However, these projects will not come before you. So your decision on Airport South will be precedent setting. And what will it say about us as a region if we toss aside 30-year-old sustainability commitments? And if we do toss them aside, what will that say about our will to achieve the 19 percent greenhouse gas reduction target that the State requires of us? Thank you.
Commenter 8 (Jan Schori)
Good evening. My name is Jan Schori and I'm a native Sacramentan. My husband and I have lived in our home in Natomas for 21 years now and we would be directly across from these warehouses if you allow this project to move forward.
We are original owners and we bought our house and paid a premium for it because it was across from open space ag land and our neighbors on our block did the same.
Your job at LAFCo is, by law, to prevent urban sprawl and preserve open space and prime agricultural land. Your own guidebook and guidelines on your website say that your obligation is to guide development away from open space and prime agricultural land. This project will impact both.
This is not a small project. The pictures you’ve seen tonight are a little misleading. It's about 1.7 miles to drive from the mini-storage business at the edge of our subdivision over to Pole Line Road. This is a big project if you’re driving on Bayou Road. I drove over to Metro Air Park this 81-25
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weekend. That is the north side, the other side of I-5. There is a lot of industrial land for sale and it has been for sale for quite some time. There are also a lot of empty warehouses awaiting lease or sale. Warehouses are not unique and can be put on any industrial property anywhere in the City or in the County.
My ask tonight is that you make an effort to go see this area before you vote on it. Your EIR concedes that this property fits the definition of prime agricultural land. It is being farmed now, and I'm going to give you pictures of the farming that’s going on. You will set the stage to decide whether Sacramento will remain a County with agriculture or will real estate speculators be buying up all of our farmland at prices far below market and turn to you with an easy expectation of rezoning. Thank you.
Commenter 9 (Matthew Alton)
Good evening. My name is Matt Alton. I've lived in the Westlake neighborhood right by the open space for the last 20 years and I'm appalled at this project being proposed.
Sacramento is on swampland and warehouses have no business being near any place of residence, let alone a school. We have a big problem already with light pollution. We have started having that ever since the Sacramento International Airport has started changing their lights back in 2017, multiplied by what's with Paso Verde and what’s with Northlake and all these unsold warehouses that still have yet to be occupied and now we're supposed to build more when we haven't even sold what we've got. Light pollution, especially bright light lights, have a very detrimental impact on human circadian rhythms and animals. And as a result, we have seen less animals over the years, since the changes have started being made.
And the waterways and uses for farming are also taken away. As a result, we’re seeing animals getting -- being wandering on to places where they don't belong. They’re wandering in the roads, they’re wandering on to houses. We have nice natural lights that we put on our house that are not going anywhere. We are going to keep those up as long as we can. And as a result, we've actually started seeing animals that we've never seen before wander to our yard.
Noise pollution is also a big thing because with all of those trucks backing up at night, how are you going to master that? So not only do we have noise pollution but we also have air pollution right by the schools and kids are supposed to breathe that stuff.
In conclusion we do not believe that this is an appropriate project. We believe that this should be considered elsewhere. There are open spaces up in the north right near Elkhorn. We should not be putting something that's not as thought out this close to a neighborhood and a school and on swampland.
Commenter 10 (Judith Lamare)
Good evening. I'm going to lecture you. I'm a lecturer. So look, a purpose of an EIR is to disclose to the decision-makers what are the impacts of the project. We expect you to read this 600 pages.
We expect you to read it in light of the things that we have been bringing up tonight, our concerns.
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of the written comments. We will be in the process from beginning to end but we’re asking you:
do your homework. This is a really important decision laid on you.
Why? Why was this laid on you? Because a landowner petitioned to change an SOI is going to be given to LAFCo and LAFCo will be the lead agency for the SOI. So why would the landowner come to you and ask you to make this decision? Instead of working through the City that it is expecting to join? What's wrong with going to the City and the General Plan process? We just went through the General Plan in the City. These folks had nothing to say in public. They were not present at the hearings.
This City General Plan does not include industrial land to the west. And not thinking about annexing anything. So why are you the target here? I think you need to do a lot of studying and talking to people and I appreciate your time tonight. Thank you.
Commenter 11 (Jim Paschl)
Good evening. My…I'm Jim Paschl representing the Friends of the Swainson's Hawk; however, tonight I am going to talk a little bit about ducks. The Sacramento Airport and the project site are located beneath the Pacific Flyway, which is the avian equivalent of I-5. During the fall and winter, millions of waterfowl pass overhead and some stick around. Aircraft using the airport sometimes collide with geese and ducks, which can cause a crash. So far, it’s not happened yet, but the airport is justifiably very concerned about it. Waterfowl are attracted to areas of open water, such as the project's detention basins located about a mile or two from the southern end of the runway.
The great majority of airport departures, by the way, are southward facing. The County airport correctly regards the proposed detention basins as a hazard by attracting waterfowl into the path of airplanes approaching or departing on the runways.
Migrating geese and duck often fly at night. Waterfowl sucked into a jet engine can destroy the engine and cause a crash. The detention basins will by necessity be quite large. The project site is the bottom of former American Lake. Water flows on to the site from all directions during the rainy season, which is when the ducks and geese are migrating in the area. This project with the detention basins so close to the end of the runways will increase the likelihood of a tragedy caused by waterfowl collision.
The airport is very concerned about this. The possible consequence of a waterfowl-caused crash might be strict FAA limitations on future airport operations. This project need not be at this risky location and can be located elsewhere, such as, maybe, across the street at Metro Airpark. Thank you very much.
Commenter 12 (Giovanni Adalini)
Good evening Chair, commissioners. My name is Giovanni Adalini. I'm a field for Carpenters Local 46, here in Sacramento. I represent over 3,000 hardworking men and women in the Sacramento area. I appreciate all of the testimony from the residents of the area. I shared the same concerns with them.
Unfortunately, development is inevitable and to preserve that is unrealistic. The jobs that this project could potentially create will help reduce greenhouse gases by allowing the members of 81-40
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the community that are going to be living here because of RHNA obligations. The housing is coming. Where are the jobs going to be for those people that the housing is being built for? We can have them drive further out of the community and increase the greenhouse emissions. Or we can have them working closer to home in Sacramento.
That's what Carpenter's Local 46 supports. Working closer to home. Again, the other added benefit is reduced greenhouse emissions. So I’m anxious to see how this project moves forward and the opportunities for members of the community and my brothers and sisters to be able to work closer to home and reducing the carbon emissions footprint. Thank you. 81-47
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LETTER 81: PUBLIC COMMENT HEARING SUMMARY
Response to Comment 81-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 81-2
The Draft EIR evaluates the proposed project’s potential to cause a significant environmental impact due to a conflict with any Sacramento LAFCo plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect under Impact 4.9-2, which begins on page 4.9-16. Table 4.9-6 within the analysis lists the proposed project’s consistency with applicable Sacramento LAFCo policies related to land use and planning, including those policies and standards associated with annexation, reorganization, and SOI Amendments, which are found in Chapter V of the Sacramento LAFCo Policy, Standards and Procedures Manual, and pertain, in part, to preventing sprawl. As discussed therein, the SOI Amendment and Annexation of the project site appear to be generally consistent with the Sacramento LAFCo policies regarding land use and planning. However, policy compliance is often a matter of interpretation.
Thus, the Draft EIR notes that the LAFCo commissioners are the ultimate arbiters of LAFCo policy for the proposed project, and their judgment regarding the project and a specific policy may be different from that set forth in the Draft EIR. Furthermore, Sacramento LAFCo has the ability to impose additional requirements or conditions of approval on a project, at the time of its approval, to bring a project into more complete conformance with existing policies. Thus, the analyses and conclusions in the Draft EIR are adequate.
With the respect to the proposed project’s potential to result in the conversion of Farmland to nonagricultural uses, please see Response to Comment 38-2.
Response to Comment 81-3
Please see Responses to Comments 66-3, 66-4, and 80-1.
Response to Comment 81-4
The commenter expresses a general opinion that the Draft EIR did not adequately analyze the potential impacts associated with the proposed project, but does not identify specific defects in the Draft EIR that would allow for a detailed response.
Pursuant to the requirements set forth by CEQA Guidelines Section 15121, the Draft EIR assesses all potential project impacts that could occur with respect to all environmental issue areas required for analysis under CEQA. As part of such assessment, the Draft EIR evaluates the proposed project’s consistency with applicable policies, regulations, and standards established at the federal, State, and local levels. Where potential impacts are identified, the Draft EIR sets forth mitigation measures to reduce the severity level of the identified impacts to the extent feasible and discloses the level of impact that would occur subsequent to incorporation of mitigation. As such, the analysis within the Draft EIR is adequate and meets the requirements set forth by the CEQA Guidelines.
Response to Comment 81-5
The effects of the proposed project on traffic volumes are evaluated in the Traffic Impact Analysis (attached as Appendix N to the Draft EIR), starting on page 36, which includes evaluation of Final EIR
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project-generated traffic volumes on Elkhorn Boulevard. However, as discussed in the Transportation chapter of the Draft EIR on page 4.12-13, impact significance in the Draft EIR is based upon VMT, whereas the results of the Traffic Impact Analysis related to LOS (i.e., effects of project-generated traffic volumes on roadway segment and intersection operations) will be used by the City, separate from the analysis in the Draft EIR, to address consistency with Sacramento 2040 General Plan goals and policies related to transportation, including adopted LOS policies.
Response to Comment 81-6
While the Draft EIR comment hearing was conducted on June 12, 2024, the Draft EIR was made available for public review for a 45-day period, from May 31, 2024 to July 17, 2024. Members of the public and other interested parties were able to submit comments on the Draft EIR during the aforementioned time period. Thus, the opportunity to review the Draft EIR was not limited to 10 days, as suggested by the comment.
Response to Comment 81-7
The commenter expresses a general opinion that the Draft EIR describes “horrible things” associated with the proposed project, but does not provide specific examples that would allow for a detailed response.
The Draft EIR assesses all potential project impacts that could occur with respect to all environmental issue areas required for analysis under CEQA, as required by CEQA Guidelines Section 15121. Where potential impacts are identified, the Draft EIR sets forth mitigation measures to reduce the severity level of the identified impacts to the extent feasible and discloses the level of impact that would occur subsequent to incorporation of mitigation. As such, the analysis within the Draft EIR is adequate and meets the requirements set forth by the CEQA Guidelines.
Response to Comment 81-8
The Draft EIR does not characterize the project components as “ugly.” Specifically, the Draft EIR evaluates the potential for the proposed project to substantially degrade the existing visual character or quality of public views of the project site and its surroundings under Impact 4.1-3, which begins on page 4.1-16. As detailed therein, due to the introduction of industrial uses to a site currently used for agricultural purposes, the Draft EIR concludes that the quality of a portion of public views currently afforded of the site would be substantially degraded by the project, with feasible mitigation unavailable to mitigate the impact to a less-than-significant level. Thus, the Draft EIR concludes that the impact would remain significant and unavoidable.
Response to Comment 81-9
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-10
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
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Response to Comment 81-11
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-12
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Aesthetics; Agricultural Resources; Air Quality, Greenhouse Gas Emissions, and Energy; and Transportation chapters of the Draft EIR.
Response to Comment 81-13
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-14
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-15
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Biological Resources chapter of the Draft EIR.
Response to Comment 81-16
Please see Response to Comment 81-5.
Response to Comment 81-17
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-18
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-19
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy; Noise; and Transportation chapters of the Draft EIR.
Response to Comment 81-20
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions related to flooding in the Hydrology and Water Quality chapter of the Draft EIR.
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Response to Comment 81-21
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-22
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-23
As alluded to by the comment, the Draft EIR identified significant and unavoidable impacts associated with the proposed project related to aesthetics, agricultural resources, and air quality, which are summarized on pages 6-7 through 6-9 of the Draft EIR and individually analyzed in the Aesthetics; Agricultural Resources; and Air Quality, Greenhouse Gas Emissions, and Energy chapters.
Due to the project’s significant and unavoidable impacts, a statement of overriding considerations has been prepared separately by Sacramento LAFCo and the City and will need to be adopted by the Sacramento LAFCo Commissioners and the Sacramento City Council should they vote to approve the project.
In addition, the Draft EIR sets forth mitigation measures to reduce all identified potentially significant impacts to the extent feasible. Please see Table 2-1 of the Executive Summary chapter of the Draft EIR, which starts on page 2-6, for a summary of the mitigation measures established by the Draft EIR.
Response to Comment 81-24
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-25
Project approval would allow for development of only those components detailed and evaluated in the Draft EIR. Other pending development proposals in the project vicinity would require their own separate reviews and approvals by the applicable decision-makers.
The Draft EIR evaluates potential growth-inducing impacts under Section 6.2, Growth-Inducing Impacts, which starts on page 6-1. As discussed therein, the proposed project has the potential to foster economic growth due to the commercial nature and employment opportunities of the proposed project. However, the magnitude of economic growth is reasonably assumed to not be substantial such that new business growth would result elsewhere in the region that could necessitate additional housing to support increases in local employees. Additionally, all utility infrastructure improvements installed as part of the proposed project would exclusively serve the proposed project. The proposed entitlements would also only apply to the project site and would not allow for further expansion of the City boundaries or additional development beyond what is proposed. Therefore, the project is not anticipated to eliminate any obstacles to population growth.
The proposed project would not increase population such that service levels, facility capacity, or infrastructure demand would require construction of new facilities that could cause significant environmental impacts. Finally, the Draft EIR provides a comprehensive assessment of the potential for environmental impacts associated with development of the proposed project. Please refer to the technical chapters of the Draft EIR for further information.
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Response to Comment 81-26
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-27
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration. With respect to the Natomas Basin HCP, please see Responses to Comments 66- 3, 66-4, and 80-1.
Response to Comment 81-28
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-29
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-30
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-31
Please see Response to Comment 81-2.
Response to Comment 81-32
While the comment alludes to photos presented at the comment hearing, it should be noted that the Draft EIR’s presentation of the project components is adequate, as the Project Description chapter of the Draft EIR makes clear the components that would be constructed as result of project approval.
Please see the Master Response.
Response to Comment 81-33
Please see Response to Comment 38-2 and the Master Response. The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-34
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-35
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analysis and conclusion under Impact 4.1-4 of the Draft EIR, which starts on page
4.1-24 and includes evaluation of potential impacts related to light and glare.
Response to Comment 81-36
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Biological Resources chapter of the Draft EIR.
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Response to Comment 81-37
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Noise and Air Quality, Greenhouse Gas Emissions, and Energy chapters of the Draft EIR.
Response to Comment 81-38
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
Response to Comment 81-39
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-40
Contrary to the comment’s assertion, the project applicant has not avoided attaining necessary project approvals through the City. Sacramento LAFCo and the City of Sacramento are both Lead Agencies for the environmental review of the proposed project. As discussed on page 1-1 of the Draft EIR, because Sacramento LAFCo would have to first act on a SOI Amendment request by the City in the event of project approval, under CEQA Guidelines Section 15051(c), Sacramento LAFCo is the Lead Agency for that action. Under CEQA Guidelines Section 15051(b)(2), the City is the Lead Agency for the General Plan Amendment, Prezoning, and other related development entitlements for the proposed project. Should LAFCo approve that request, the City could then annex the project site into the City limits and apply City General Plan land use designations and Prezoning to the site, as well as proceed forward with the other requested development entitlements for the project. Pursuant to CEQA Guidelines Section 15051(d), Sacramento LAFCo and the City entered into an agreement that provides for “cooperative efforts” and “a joint exercise of powers,” in order to comply with the requirements of CEQA for lead agencies to consider the “whole of the action” (CEQA Guidelines Section 15003[h]), avoid duplicative efforts, and provide a clear point of contact for the public and interested public agencies to ask questions and provide comments on the Draft and Final EIRs.
Response to Comment 81-41
The project site, due to its location outside of the City’s SOI, is not identified in the City’s 2040 General Plan as being anticipated for industrial uses. However, as shown in Map LUP-I of the 2040 General Plan, the project site is within the Natomas Basin Study Area. The Special Study Area (SSA) designation is applied to five areas that could become part of the City in the future after additional studies have identified the fiscal and service delivery implications on City functions.
Consistent with the project site’s SSA designation in the City’s 2040 General Plan, the City, as well as Sacramento LAFCo, are evaluating the fiscal and service delivery ramifications of approving the proposed project entitlements as part of the overall project approval process. Thus, Sacramento LAFCo and City of Sacramento are studying the effects of the proposed project, as the comment recommends.
Response to Comment 81-42
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analysis and conclusion under Impact 4.7-5 of the Draft EIR, which begins on page Final EIR
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4.7-20. As discussed therein, the proposed project would be subject to Mitigation Measure 4.7- 5(a), which requires the project applicant to prepare a Design and Management Plan that incorporates specific design measures to prevent bird strikes and other wildlife-related airspace safety hazards in the project vicinity through inclusion of a Wildlife Hazards Management Plan.
The Design and Management Plan would be subject to review and approval by the Sacramento Airport Land Use Commission and the Sacramento County Airport System.
Response to Comment 81-43
As discussed under Impact 4.7-5 of the Draft EIR, which begins on page 4.7-20, the project site is located within the Sacramento International Airport’s Airport Influence Area. According to the Sacramento International Airport’s Airport Land Use Compatibility Plan (ALUCP), the western portion of the project site is located within Safety Zone 3, which is designated “Inner Turning Zone,” the south-central portion of the site is located within Safety Zone 4, which is designated “Outer Approach/Departure Zone,” and the eastern portion of the project site is located within Safety Zone 6, which is designated “Traffic Pattern Zone.” All of the uses proposed to be developed on the project site and off-site force main alignment as part of the project, including short-term lodging (i.e., hotels, motels, other transient lodging); commercial, office, and service uses; and industrial, manufacturing, and storage uses (with the exception of hazardous materials production uses, such as oil refineries and chemical plants, which are not anticipated to be developed on-site) are normally compatible, or conditionally compatible uses within Zones 3, 4, and 6. Table 2 of the ALUCP provides criteria for conditionally compatible uses within each Safety Zone to ensure the uses are compatible with the Sacramento International Airport.
To reduce strike hazards, the Draft EIR notes that the ALUCP has placed restrictions on the land uses in the influence area of Sacramento International Airport. The ALUCP states that any uses that attract large flocks of birds shall not be permitted within the Airport Influence Area. The project site was historically used as hay fields, with possible intermittent use as rice fields from 1937 until at least 2020. As such, the project site, in its historical context, has occasionally been an attractant to birds and other waterfowl, which has increased the hazard potential to aircraft compared with other, non-rice farmed/urban areas located within the Sacramento International Airport’s safety overflight zone. The proposed project would result in the development of the site with industrial and commercial uses, which are not typically uses that would attract birds and other wildlife. While the proposed project would include the development of stormwater retention features, which could periodically result in standing water being present within the project site, permanent water features would not be included in the project design.
In addition, because the final design of the stormwater retention features has not yet been determined, the Draft EIR requires Mitigation Measure 4.7-5(a) to ensure potential bird-strike hazards do not occur. Please also see Response to Comment 81-42.
Response to Comment 81-44
Please see Responses to Comments 81-42 and 81-43.
Response to Comment 81-45
The comment expresses a general opinion that the Sacramento International Airport is concerned about the proposed project and that the proposed project could result in limitations imposed on the airport in the future by the Federal Aviation Administration (FAA), but does not provide specific evidence to substantiate such claims.
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Please see the Master Response and Responses to Comments 81-42 and 81-43.
Response to Comment 81-46
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 81-47
The comment does not address the adequacy of the Draft EIR. Please see the Master Response, as well as the analyses and conclusions in the Air Quality, Greenhouse Gas Emissions, and Energy chapter of the Draft EIR. The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
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82-1
Letter 82
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82-2
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82-5
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Letter 82
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Letter 82
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82-8
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82-9
Letter 82
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82-10
Letter 82
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82-12
Letter 82
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82-12
Cont.
82-13
82-14
Letter 82
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82-14
Cont.
82-15
82-16
Letter 82
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82-16
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82-17
Letter 82
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82-18
82-19
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82-20
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82-21
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82-22
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82-23
82-24
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82-24
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Letter 82
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82-27
Letter 82
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82-28
Letter 82
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82-29
Letter 82
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82-30
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82-32
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82-33
Letter 82
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82-33
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82-34
Letter 82
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82-35
Letter 82
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82-36
Letter 82
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82-36
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82-37
Letter 82
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Letter 82
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LETTER 82: KEVIN CARMICHAEL, SACRAMENTO RESIDENTS FOR
RESPONSIBLE DEVELOPMENT (ADAMS BROADWAY
JOSEPH AND CARDOZO)
Response to Comment 82-1
The comment is an introductory statement and is an expression of dissatisfaction with the analysis of the Draft EIR, the specific criticisms of which are addressed in more detail below.
Response to Comment 82-2
The comment describes the interests of Sacramento Residents for Responsible Development.
The comment does not address the adequacy of the Draft EIR.
Response to Comment 82-3
The comment does not adequately describe a specific defect in the Project Description to allow for a response. Please see the Master Response.
Response to Comment 82-4
The comment does not adequately describe a specific defect in the Project Description for the proposed project to allow for a response. Please see the Master Response.
Response to Comment 82-5
See Response to Comment 23-10. As discussed therein, the increase in DPM emissions associated with use of five emergency generators on-site for 100 hours per year, in combination with DPM emissions associated with heavy-duty diesel trucks travelling to and from the project site would not result in a cancer or non-cancer hazard risks above the SMAQMD thresholds. Fire pumps would only be used in an emergency, and, thus, would be in use even more infrequently than the emergency generators. Just as the use of emergency generators would not alter the conclusions of the Draft EIR, the contribution of fire pumps would be so incremental such that the conclusions would be the same.
Response to Comment 82-6
The comment is incomplete and is addressed in full under Response to Comment 82-8, below.
Response to Comment 82-7
The comment does not provide specifics regarding the adequacy of the Draft EIR. See the Master Response.
Response to Comment 82-8
The commenter excludes relevant language that supports the conclusion cited in the comment and mischaracterizes the analysis of the Draft EIR. The full discussion of construction-related TAC emissions presented on pages 4.3-49 and 4.3-50 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, consists of the following:
Short-term, construction-related activities could result in the generation of TACs, specifically DPM, from on-road haul trucks and off-road equipment exhaust emissions.
However, construction is temporary and occurs over a relatively short duration in comparison to the operational lifetime of the proposed project. Health risks are typically associated with exposure to high concentrations of TACs over extended periods of time Final EIR
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(e.g., 30 years or greater). As discussed above, construction of the proposed project is anticipated to occur over an approximately six-year period.
All construction equipment and operation thereof would be regulated per the CARB’s InUse Off-Road Diesel Vehicle Regulation, which is intended to help reduce emissions associated with off-road diesel vehicles and equipment, including DPM. Project construction would also be required to comply with all applicable SMAQMD rules and regulations, particularly associated with permitting of air pollutant sources. In addition, construction equipment would operate intermittently throughout the day and only on portions of the sites at a time.
Because construction equipment on-site would not operate for long periods of time and would be used at varying locations within the sites, associated emissions of DPM would not occur at the same location (or be evenly spread throughout the entire project site) for long periods of time. Due to the temporary nature of construction and the relatively short duration of potential exposure to associated emissions, the potential for any one sensitive receptor in the area to be exposed to concentrations of pollutants for a substantially extended period of time would be low. Therefore, construction associated with the proposed project would not be expected to expose any sensitive receptors to substantial pollutant concentrations. In addition, it should be noted that due to the temporary nature of construction activities, construction of the proposed project would not result in any worse impacts than what would occur during operations associated with DPM emissions generated by heavy duty truck traffic, as discussed in further detail below. In addition, as discussed above, Mitigation Measure 4.3-1(b) would require the use of cleaner engine construction equipment, such as Tier 4 final equipment, during project construction, which would further help to reduce DPM emissions during construction.
As such, contrary to the characterization of the commenter, the analysis of the Draft EIR does not solely rely on the fact that construction would be temporary in nature, but also relies on implementation of mitigation and compliance with applicable regulations.
Response to Comment 82-9
See Response to Comment 16-38.
Response to Comment 82-10
See Response to Comment 16-38.
Response to Comment 82-11
Contrary to the claim of the commenter, potential impacts related to hazardous materials are addressed under Impact 4.7-2 in Chapter 4.7, Hazards and Hazardous Materials, of the Draft EIR.
In addition, the source of each recognized environmental condition (REC) is described beginning on page 4.7-3.
Response to Comment 82-12
Contrary to the claim of the commenter, enforcement of Mitigation Measures 4.7-2(a) and 4.7- 2(b) is contingent upon approval by the City of Sacramento Community Development Department.
In addition, both of the foregoing mitigation measures specify that on-site concentrations of hazardous materials must be reduced to below the applicable regulatory screening levels. The methods of the analysis of on-site soils is not required to be specified by the mitigation; any allowable methods are permissible, given contaminated soils are remediated, as required by the mitigation measures and State regulations. In this case, the provided mitigation has clear, Final EIR
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enforceable performance standards and is not deferred mitigation. Compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact to the specified performance standards (CEQA Guidelines Section 15126.4.) In the case Center for Biological Diversity v. California Department of Conservation, etc. (2019), the court explains that “[g]enerally, it is improper to defer the formulation of mitigation measures…However, an exception to this general rule applies when the agency has committed itself to specific performance criteria for evaluating the efficacy of the measures to be implemented in the future, and the future mitigation measures are formulated and operational before the project activity that they regulate begins.” (36 Cal.App.5th 210, 239.) The court determined both conditions were met and upheld the deferred mitigation measures.
Similarly, the mitigation measures presented in the Draft EIR require compliance with specific performance standards and regulatory requirements, and also require implementation prior to project activities begin. Therefore, the proposed mitigation would not be considered deferral.
The movement of on-site soils, including stockpiled soils, is accounted for in the modeling for emissions associated with construction equipment. In addition, soil hauling was assumed to occur during the grading phase.
Response to Comment 82-13
See Response to Comment 82-12.
Response to Comment 82-14
See Response to Comment 9-3.
Response to Comment 82-15
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 82-16
As cited by the commenter, Mitigation Measure 4.3-1(b) states requires vehicles included in construction of the proposed project to “be a combination of engine Tier 3 or Tier 4 off-road construction equipment, or hybrid, electric, or alternatively fueled equipment (or any combination of the above), sufficient to achieve a fleet-wide average reduction in construction-related NOX emissions to below the applicable SMAQMD thresholds of significance (85 lbs/day).” As such, so long as construction-related NOX emissions are reduced to below the applicable SMQAMD thresholds of significance, the engine types of construction equipment used is irrelevant. The presentation of construction-related emissions in Table 3-8, Maximum Mitigated ConstructionRelated Emissions, of the Draft EIR serves to prove it is possible to reduce construction-related emissions to below the thresholds of significance, and does not imply that the sole use of Tier 4 equipment is the only possible method to do so.
Response to Comment 82-17
See Responses to Comments 13-79 and 13-81. As discussed therein, construction of the proposed project is not predicted to substantially increase existing noise levels; proposed construction activities are expected to be 10 dBA less than existing ambient noise levels, assuming the use of the loudest piece of construction equipment. Pursuant to Section 8.86.060 of the City Code, for locations where the existing ambient noise level exceeds 75 dBA Lmax during daytime hours, such as at the existing residences in the project vicinity, the standard of significance for a significant noise impact is any increase in the ambient noise environment.
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Because the proposed construction activities would be 10 dBA below existing ambient noise levels at the nearest residence, a significant impact would not occur. Furthermore, it is noted that the proposed project would be required by law to comply with the City Code, including Section
8.60.080 related to the allowable hours for project construction.
Response to Comment 82-18
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 82-19
Please see Responses to Comments 13-79 and 13-81.
Response to Comment 82-20
As stated on page 4.10-14 in Chapter 4.10, Noise, of the Draft EIR, the Environmental Noise Assessment prepared for the proposed project by Saxelby Acoustics, LLC (see Appendix J of the Draft EIR) “used the SoundPLAN noise prediction model to calculate noise levels at the nearest sensitive receptors. Inputs to the model included loading dock noise and on-site vehicle circulation noise associated with the warehouses and the commercial uses. To determine typical noise levels associated with the proposed loading docks, noise level measurement data from a United Natural Foods, Inc. (UNFI) warehouse was used.” Although not explicitly stated, the noise level measurement data from a UNFI warehouse used in the analysis included noise generated by rooftop mechanical equipment. Therefore, contrary to the claim of the commenter, noise levels associated with such were addressed in the analysis, and additional mitigation is not required.
Further, even if the baseline noise data did not include rooftop mechanical equipment, the commentor performed a simplified calculation that does not include potentially shielding from the rooftop edges or building parapets. Saxelby Acoustics added rooftop HVAC units with a sound power level of 96 dBA at each of the easternmost building corners, as suggested by the commentor. The resulting HVAC noise contribution ranged between 28 to 36 dBA per unit, with a total noise increase of 1 dBA, resulting in a maximum noise level of 49 dBA L50 when combined with other project noise sources. This still meets the 50 dBA L50 nighttime noise standard and, thus, additional mitigation is not required.
Response to Comment 82-21
See Responses to Comments 19-12 and 23-8.
Response to Comment 82-22
See Responses to Comments 19-12 and 23-8.
Response to Comment 82-23
As stated on page 4.12-21 in Chapter 4.12, Transportation, of the Draft EIR, Mitigation Measure
4.12-3 notes that the Draft EIR included as Appendix Q a VMT Mitigation Memorandum prepared by Avdis & Cucci. The VMT Mitigation Memorandum provides evidence of the feasibility and effectiveness of achieving the reductions required by the mitigation measure. The preparers of the VMT Mitigation Memorandum are certified experts in the field, and the conclusions of their analysis are considered accurate and reliable. Nonetheless, the concerns of the commenter shall be forwarded to the decisionmakers for their consideration.
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Response to Comment 82-24
The comment is a conclusion statement and does not specifically address the adequacy of the Draft EIR. See the Master Response.
Response to Comment 82-25
The comment provides a summary of criticisms of the analysis of the Draft EIR, all of which are addressed in further detail below.
Response to Comment 82-26
See Response to Comment 23-7.
Response to Comment 82-27
See Responses to Comments 19-32 and 23-7.
Response to Comment 82-28
See Response to Comment 19-12.
Response to Comment 82-29
See Response to Comment 11-12.
Response to Comment 82-30
See Response to Comment 11-12.
Response to Comment 82-31
The comment consists of an introductory statement and does not address the adequacy of the Draft EIR.
Response to Comment 82-32
The comment consists of a summary of the proposed project and does not address the adequacy of the Draft EIR.
Response to Comment 82-33
See Response to Comment 82-5.
Response to Comment 82-34
See Response to Comment 16-38.
Response to Comment 82-35
See Responses to Comment 82-11 and 82-12.
Response to Comment 82-36
See Response to Comment 82-16.
Response to Comment 82-37
See Response to Comment 9-3.
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Response to Comment 82-38
The comment is a conclusion statement and does not specifically address the adequacy of the Draft EIR.
Response to Comment 82-39
The comment consists of an introductory statement and does not specifically address the adequacy of the Draft EIR.
Response to Comment 82-40
The comment does not address the adequacy of the Draft EIR. See the Master Response.
Response to Comment 82-41
See Responses to Comments 13-79 and 13-81.
Response to Comment 82-42
See Response to Comment 82-20.
Response to Comment 82-43
The comment is a summary of the criticisms of the analysis of the Draft EIR, which are addressed in detail above.
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Letter 83
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LETTER 83: DEAN WALLRAFF, ADVOCATES FOR THE ENVIRONMENT Response to Comment 83-1
The comment is an introductory statement and does not address the adequacy of the Draft EIR.
Please see the Master Response.
Response to Comment 83-2
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 83-3
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 83-4
Contrary to the claim of the commenter, the information discussion presented within Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, is clearly delineated between the three nominal topics through the use of headers and introductory text. In addition, the environmental impact analysis is organized by individual impact headers which clearly refer to which environmental topic is being discussed. Impacts pertaining to air quality, GHG emissions, and energy are addressed individually and the conclusions regarding the potential significance of each impact are clearly distinguished from one another through repetition of the significance statement in the introduction and conclusion of each portion of the analysis. As such, although impacts related to air quality, GHG emissions, and energy are addressed in one chapter of the Draft EIR, the analysis clearly distinguishes between the background, standards of significance, and conclusions for each topic.
Response to Comment 83-5
As stated on page 4.3-33 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, the standards of significance listed and referenced throughout the chapter are based on the recommendations of SMAQMD and consistent with Appendix G of the CEQA Guidelines. As such, the standards of significance presented in the chapter are consistent with the requirements of CEQA and, thus, are appropriate for the analysis of the Draft EIR.
Response to Comment 83-6
See Responses to Comments 83-4 and 83-5. The use of the word “or” on page 4.3-34 of Chapter
4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR is used to signify that the project could result in a significant impact if any of the listed standards of significance is met, and does not imply that all of the significance thresholds are interrelated or dependent upon one another. The commenter is drawing a conclusion that is not only not implied by the text of the Draft EIR, but is explicitly contradicted.
Response to Comment 83-7
See Response to Comment 83-6. Contrary to the claim of the commenter, by grouping the analysis of air quality, GHG emissions, and energy into one chapter, it is implied that the environmental topics are interrelated. As the commenter states, Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR provides extensive information regarding the environmental setting, regulatory context, and methods of analysis for each of the environmental topics addressed in the chapter. As such, sufficient information is provided for the reader to understand the analysis. As discussed under Response to Comment 83-4, the Final EIR
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environmental analysis is organized using the questions provided in Appendix G of the CEQA Guidelines, which clearly delineate which environmental topic is being addressed.
Response to Comment 83-8
See Response to Comment 83-4. With respect to impacts related to odors, consistent with the comment, such impacts are not necessarily restricted to being related to only air quality or GHG emissions. As such, the analysis does not address just one or the other, but applies to any odorous emissions that could impact a substantial number of people. The restrictiveness that the commenter implies is necessary is not required under CEQA.
Response to Comment 83-9
See Responses to Comments 83-4 through 83-8.
Response to Comment 83-10
With regard to construction GHG emissions, Mitigation Measure 4.3-7(a) of the Draft EIR requires that the project applicant demonstrate that construction-related GHG emissions would be reduced to 935 MTCO2e/yr prior to construction of the industrial park and that the future applicant demonstrate that construction-related GHG emissions would be reduced to 165 MTCO2e/yr prior to construction of the nonparticipating parcels. Further, the measure identifies a number of examples of reasonable means to achieve compliance with the stated performance standard, and includes the option for offsite carbon credits to be purchased to make up the difference if the quantified reduction measures do not reduce construction-related GHG emissions to below 935 MTCO2e/yr for the industrial park and 165 MTCO2e/yr for the nonparticipating parcels. Mitigation Measure 4.3-7(a) would ensure that the appropriate reduction measures are implemented and/or offsite carbon credits are purchased, as necessary, prior to construction of the industrial park and at the time future development is proposed within the nonparticipating parcels. Thus, a quantification of the reduction measures included in Mitigation Measure 4.3-7(a) is not required at this time.
For evaluating operational GHG emissions, SMAQMD has prepared a two-tiered framework of analysis for new projects. All development projects are required to implement Tier 1 measures (BMP 1 and 2). If operations of the proposed project would exceed 1,100 MTCO2e/yr after implementation of the Tier 1 measures, then the project is required to implement Tier 2 measures (BMP 3). Both the Tier 1 and Tier 2 measures are qualitative in nature. As such, if a project implements the required design elements of BMPs 1 through 3, GHG emissions are assumed to be less than significant. Mitigation Measures 4.3-7(b) through 4.3-7(d) would ensure that the proposed project is consistent with the SMAQMD BMPs. Given that the SMAQMD operational GHG emission thresholds are qualitative in nature, a quantification of the GHG emissions reductions associated with such measures is not required.
Response to Comment 83-11
See Response to Comment 19-26.
Response to Comment 83-12
The commenter states that, “the EIR included a discussion of the 2022 Scoping Plan and the City of Sacramento Climate Action and Adaptation Plan (CAAP) as part of its determination that the Project would have a significant impact…” This statement is false. Rather, the significant impact included in the Draft EIR is specifically related to the project’s exceedance of the SMAQMD construction GHG threshold and project compliance with the SMAQMD BMPs. As discussed on Final EIR
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pages 4.3-67 and 4.3-68 of the Draft EIR, the proposed project would generally comply with all applicable measures of the City’s CAAP. In addition, as shown in Table 4.3-17 of the Draft EIR and as concluded on page 4.3-71 of the Draft EIR, the proposed project would generally comply with the applicable suggested project attributes included in the 2022 Scoping Plan. Given the project’s compliance with the City’s CAAP and the 2022 Scoping Plan, mitigation related to such is not warranted, and the analysis included within the Draft EIR regarding the proposed project’s consistency with the CAAP and the 2022 Scoping Plan remains adequate.
Furthermore, Mitigation Measures 4.3-7(a) and 4.3-7(b) provide extensive direction regarding compliance with applicable SMAQMD requirements during construction and operation of the project, respectively. For example, Mitigation Measure 4.3-7(a) requires proof of compliance with SMAQMD recommendations that would reduce construction-related GHG emissions prior to initiation of construction, contingent on approval from the City of Sacramento Community Development Department. In addition, Mitigation Measure 4.3-7(b) explicitly requires implementation of GHG emission reduction measures during project operations in order to comply with applicable plans and regulations, proof of which is required prior to approval of building permits. Alternatively, both of the foregoing mitigation measures allow the project applicant to purchase offsite carbon credits, consistent with City and SMAQMD guidelines. As such, the Draft EIR provides adequate analysis to support the findings presented therein related to the proposed projects consistency with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.
Response to Comment 83-13
The Key Project Attributes listed and analyzed in Table 4.3-17, Project Consistency with the 2022 Scoping Plan, in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, are taken from Appendix D, Local Actions, of the 2022 CARB Scoping Plan. The Key Project Attributes listed therein are meant to apply to local development projects, whereas the language cited by the commenter is a general discussion of statewide implementation of emissionsreducing actions, but do not specifically apply of local development. Furthermore, the requirements adopted by SMAQMD and the newly adopted CAAP are in place to help provide consistency with the 2022 Scoping Plan. As discussed under Impact 4.3-7, with implementation of mitigation, the proposed project would be consistent with the foregoing requirements.
Response to Comment 83-14
As acknowledged under Impact 4.3-7 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, the proposed project could conflict with SMAQMD’s BMP-1 and CAAP Measure E-2. However, as stated on page 4.3-65, pursuant to SMAQMD’s Guidance, BMP1 may be replaced with an alternative mitigation strategy that would reduce GHG to the same extent. Mitigation Measure 4.3-7(b) requires the project applicant to offset GHG emissions associated with project operation. Furthermore, as stated on page 4.3-67, “as required by Mitigation Measure 4.3-7(c), the project would provide 1,652 EV Ready spaces, and 545 spaces with EVSE. As such, the proposed project would comply with Section 4.106.4 of the CALGreen Code, thus generally complying with Measure TR-3 of the CAAP.” Many CAAP measures are related to requirements that are not applicable to the proposed project and, thus, are not addressed in the Draft EIR. For example, the carbon sequestration measure cited by the commenter states, “CS-1: Increase urban tree canopy cover to 25% by 2030 and 35% by 2045.” Unlike the other CAAP measures addressed under Impact 4.3-7 in Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, Measure CS-1 is not a Final EIR
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requirement or recommendation with which individual development projects are required to demonstrate compliance.
Response to Comment 83-15
The 2022 Scoping Plan supersedes the 2017 Scoping Plan, which is now out of date. Thus, the Draft EIR is not required to demonstrate compliance with the 2017 Scoping Plan. As stated on page 4.3-23 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, “CARB intends to work with relevant State agencies to ensure that future scoping plan updates identify and recommend measures to achieve the carbon neutrality goal [established by Executive Order B-55-18].” The “relevant State agency,” in this case, is SMAQMD. Given that the SMAQMD Guidelines were established following the adoption of Executive Order B-55-18, by demonstrating compliance with SMAQMD regulations, the Draft EIR is demonstrating compliance with Executive Order B-55-18.
Response to Comment 83-16
The comment consists of a summary and does not specifically address the adequacy of the Draft EIR. See the Master Response.
Response to Comment 83-17
See Response to Comment 83-10. In addition, neither the City, nor SMAQMD, or any other regulatory agency with approval authority over the proposed project has a specific requirement that the project’s GHG emissions be reduced to zero. Thus, a nexus for the City to require the proposed project to reduce GHG emissions to zero does not exist. Any obligation for the proposed project to reduce GHG emissions to zero would be voluntary by the applicant, and the project applicant has not indicated such voluntary measures would be implemented.
Response to Comment 83-18
Mitigation Measure 4.3-7(a), beginning on page 4.3-72 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, states, “Prior to the initiation of construction of the industrial park, the project applicant shall demonstrate that construction-related GHG emissions would be reduced to 935 MTCO2e/yr and shall submit proof to the City of Sacramento Community Development Department. In addition, prior to the initiation of construction of the nonparticipating parcels, the future applicant of all future development proposals on such parcels shall demonstrate that construction-related GHG emissions would be reduced to 165 MTCO2e/yr and shall submit proof to the City of Sacramento Community Development Department.” As such, while options are provided regarding the methods of mitigation, enforcement of compliance is clearly established in the language cited above.
Response to Comment 83-19
Mitigation Measure 4.3-7(b), beginning on page 4.3-73 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, addresses operational GHG emissions associated with the proposed project, and would be adequate to reduce impacts related to such to a lessthan-significant level.
Response to Comment 83-20
See Responses to Comments 19-26 and 83-10. As stated on page 4.3-75 of Chapter 4.3, Air Quality, Greenhouse Gas Emissions, and Energy, of the Draft EIR, compliance with the provisions of Mitigation Measure 4.3-7(b) shall be ensured by the City of Sacramento Community Development Department. As such, enforcement of the mitigation is the responsibility of the City.
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Response to Comment 83-21
See Responses to Comments 83-10, 83-12, 83-18, 83-19, and 83-20.
Response to Comment 83-22
The comment does not address the adequacy of the Draft EIR. Please see the Master Response.
Response to Comment 83-23
The comment consists of a conclusion statement and does not address the adequacy of the Draft EIR beyond the criticisms addressed above. Please see the Master Response.
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Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments
Final EIR
Airport South Industrial Project
March 2025
Chapter 2 – Responses to Comments