2025-01126 SUPPLEMENTAL MATERIAL - Airport South Industrial Annexation (P21-017) (Noticed on 11072025; Published 11072025; Passed for Publication 10212025; Published 10242025) [Updated 11/18/2025 @4:41 PM] - Part 4 — Sacramento City Council, December 2, 2025 (part 4 of 4)

Further, the alternative would eliminate the project’s poten tial inconsistency with the Sacramento International Airport Comprehensive Land Use Plan (CLUP) requirement to limit land uses (i.e., parks and light rail stati on) that would result in a substantial concentration of people (i.e., 25 persons per acre on average of 50 persons per acre at any one time) because the off-site alternative would be located outside the airport’s overflight safety zone. Therefore, the off-site alternative would eliminate the project’s significant and unavoidable CLUP consistency impact.

Feasibility/Relationship to Project Objectives

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Depending on the specific location, the off-site alternative may be able to meet the project’s objectives related to creation of a pedestri an-friendly development; development of a project that is consistent with SACOG’s Blueprint plan, development of a residential development near the major employment centers of downtown Sacramento and Metro Air Park; provision of vertically and horizontally mixed neighborhoods; incorporation of parks and open space in a manner that provides connectivity; creating a residential development with a variety of housing types; and providing housing and employment opportunities that meet the City’s long-term housing and employment demand projections. In addition, an off- site alternative could possibly further support and implement the project objective related to developing a project that is consistent with the Sacramento International Airport CLUP because it would eliminate the project’s inconsistency with the safety requirement of maintaining a density of 50 persons per acres for the proposed light rail station, and park areas.

However, the off-site alternative would not m eet the project’s key objective of providing development and land for construction of the DNA light rail ext ension, nor would it meet project objectives related to providing r eadily accessible on-site light rail transit opportunities. (DEIR, p. 8-6.) Failure to meet these objectives makes an off-site alternative infeasible. (See Association of Irritated Residents v. County of Madera (2003) 107 Cal.App.4th 1383 , 1400; Sequoyah Hills Homeowners v. City of Oakland (1993) 23 Cal.App.4th 704, 715 (agency may properly re ject an environmentally superior project alternative for failing to meet “the fundamental objective of the project”).)

CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors.” (Pub. Resources Code, § 21061.1.) The CEQA Guidelines add another factor: “legal” considerations. (CEQA Guidelines, § 15364; see also Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565 (Goleta II).) Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastruc ture, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site. (CEQA Guidelines, § 15126.6, subd. (f)(1).)

As discussed above, this alternative was rejected from further consideration because of its infeasibility. None of the undeveloped resident ial properties within the NNCP area is currently owned by the Greenbriar property owner and, given the timing of the application and the status of development in the North Natomas area, it is not reasonable to consider that the applicant would be successful in obtaining such a property. Further, there is no other site available on the proposed DNA light rail line that could provide a key transit station. Finally, while other property may be available outside the City limits, it would be m
ore distant from the City and would “leapfrog” undeveloped areas, leading to undesirable land use patterns and substantial growth inducement potential.

2. Reduced Traffic Alternative

The reduced traffic alternative would constrain development at the project site to a level that would reduce the project’s significant and unavoidable traffic impa cts at study area Greenbriar (M05-046 / P05-069) January 22, 2008

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intersections below the City’s existing thresholds (e.g., level-of-service or delay) for these intersections. The project would result in significant and unavoidable impacts to the intersections of Elkhorn Boulevard/SR 70/99 northbound ramps, SR 70/99 southbound to I- 5 southbound on-ramp, I-5 northbound to SR 70/99 northbound off-ramp, Meister Way and Metro Air Parkway, Meister Way and Lone Tree Road, and Elkhorn Boulevard and Project Streets 1, 2, and 3. These intersections will operate well over their design capacity with or without the project in most instances. No additional feasible mitigation is available to reduce impacts to these intersections because all feasible roadway improvements to these intersections were assumed or recommended as mitigation in the analysis. Even with these improvements, these intersections woul d continue to operate unacceptably under cumulative plus project conditions. Therefore, the only way to eliminate impacts to these intersections would be to reduce the level of development at the site such that the impact does not occur.

As described in Section 6.1 of the EIR, these intersections would require that Elkhorn Boulevard and Meister Way be widened above and beyond what the City has planned for and intends to do or beyond the existing available right-of-way. Development at the project site would need to be constrained to a level under cumulative conditions that would not trigger the widening of these roadways. It has been determined that development at the project site would need to be constrained to 25% of its current development level (or a 75% reduction). A project constrained to this development size (i.e., 890 residential units and 7.5 acres of commercial development) would not achieve any of the project’s objectives including creating a transit-oriented development (i.e., medium and high-density land uses) centered around a light rail st ation, developing a project consistent with the SACOG Blueprint, providing an elementary school (insufficient demand and funding), and would not meet the City’s goals designed to meet SACOG’s Blueprint growth principles. If development occurs but at a density substantially lower t han the Blueprint considers, especially on larger project sites, such as Greenbriar, greater pressure would be exerted on other sites to accommodate future growth, thereby placing greater potential for conversion of more open space to urban uses. Further, becaus e of infrastructure costs spread over too-few houses, a substantially lower density development would not be an economically feasible development. Because this alternative would not be feasible and would not meet the objectives of the project or the City, this alternativ e was rejected from further consideration. (DEIR, p. 4-7.)

3. Reduced Biological Resources Alternative

The reduced biological resources alternative would re-organize/design on-site land uses to locate the lake/detention basin and other open space features (e.g., parks, linear open space/buffer) along the western edge of the project site adjacent to Lone Tree Canal. The purpose of the proposed changes would be to eliminate potentia l urban encroachment impacts on giant garter snake and its habitat. This alternative would provide a wider buffer between urban land uses and the habitat along Lone Tree Canal. As discussed in Section

6.12 of the EIR, the project’s impacts to giant garter snake and its habitat would be reduced to a less-than-significant le vel through implementation of a recommended conservation strategy that would maintain a linear open space/buffer (i.e., 250-feet from the center of the canal) along Lone Tree Canal to allow snake passage and would preserve and enhance additional off-site lands in accordance with mitigation ratios established by the North Natomas Habitat Conservation Plan.

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Development of this alternative would result in placement of the on-site lake/detention basin closer to the airport runways at the Sacramento International Airport, which could increase the potential hazards associat ed with aircraft bird strikes compared to the hazards associated with the project becaus e the project could create a flyway for birds that is in closer proximity to the airport. Because no significant and unavoidable biological impacts would occur with the project (as this alternative was designed to reduce potential biological impacts) and this alternative could increase potential hazards associated with aircraft bird strikes, this alternative was rejected from further consideration. (DEIR, p. 4-7.)

Alternatives Considered and Incorporated Into the Project

During project initiation, some potentially significant environmental issues were raised during the initial scoping process for the DEIR. Other impacts were identified during preparation of the EIR, and t hey resulted in applicant-initiated changes to the proposed project. These potentially signifi cant environmental issues in volved potential impacts to giant garter snake habitat and wetland areas and noise compatibility impacts associated with aircraft operations at t he Sacramento International Airport, which is located approximately 1 mile west of the project site. In initiating the preparation of the DEIR, two alternatives were considered and were to be evaluated in the DEIR at an equal level of detail as the project.

1. Blueprint Alternative

The Sacramento Area Council of Governments (SACOG) adopted the Sacramento Region Blueprint Transportation and Land Use Study Preferred Blueprint Scenario (Blueprint) in December 2004. The Blueprint is a vision for long-term land uses within the Sacramento region, and promotes compact, mixed use dev elopment, over the ty pe of lower density, sprawling land uses that have been typical of the region in the past. The Blueprint’s preferred land use scenario identifies the Greenbriar site for high density mixed residential and single family small lot land uses.

All of the Blueprint’s principles have been applied in the design of the proposed project. The project incorporates diverse housing types (i.e., low density, medium density, high density residential), development would be compact (i .e., maximized use space by providing medium and high density residential land uses on more than half of the site), the area of public open space is greater than required by city regulations (project provides 48.4 acres versus City requirement of 48.2 acres), and mixed uses (i.e., residential and commercial land uses on one parcel) would be accommodated on the site. In addition, the project would provide a variety of transit opportunities including walking and bicycling, and by planning for a future light rail extension and station at the project site.

The Draft Greenbriar PUD Guidelines fully in corporate the “Smart Growth” Principles.

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bike lanes. Nearly all sidewalks within the PUD’s streets would be detached from the street edge and separated from the str eet by a landscape planter of varying width depending upon the street facility. These pedestrian-friendly streets would provide a safe, walkable route to everywhere in the PUD area under a dense canopy of shade trees.

Because the proposed project incorporates all of the design principles of the Blueprint, a project alternative designed to meet development patterns envisioned in the Blueprint in an alternate pattern is not needed. Based upon the guidance provided by the CEQA Guidelines (Section 15126.6(f)), it was dete rmined that an alternative in addition to the reduced size alternative need not be developed to demonstrate the potential environmental consequences of evaluating an alternative consistent with the Blueprint. For these reasons, it was determined that the analysis of the alternatives described in Section 4.2 of the EIR, provides enough information to permit a reasoned choice between available alternatives and their comparative environmental impacts. (DEIR, pp. 4-5 to 4-6.)

2. Reduced Impacts to Biological Resources Alternative

The intent of this alternativ e was to design the project in such a way as to protect and preserve important giant garter snake habitat lo cated at the project site, primarily along Lone Tree Canal, by developing a 250-foot linear open space/buffer (from the center of Lone Tree Canal) along the western border of the site. In consideration of this design alternative, the project app licant subsequently decided to make this proposed buffer an element of the project, thereby eliminating the need to consider this alternative in the EIR.

Therefore, the project, with the proposed 250-foot buffer, has been considered throughout Chapter 6 of the EIR and t he resulting benefit associat ed with the proposed buffer was compared to baseline environmental conditions.

3. Noise Compatibility Alternative

The intent of this alternative was to develop land uses at the project site that would be less sensitive to aircraft overflight noise asso ciated with private and m ilitary aircraft flights arriving and departing at the Sacramento International Airport. This alternative considered a development pattern at the project site that would concentrate non-residential land uses including employment center, manufactu ring, research, and development, and light industrial land uses in the portion of the project site that falls within the airport safety zone and high-density residential, retail and medium density residential land uses in the eastern portion of the project site that falls outside the airport safety zo ne. Through the scoping process, the Sacramento County Airports System (SCAS) commented that the land uses proposed for the project site are generally compatible with land uses allowed under the Airport Land Use Plan. Further, nuisance-related complaints from single-event noise levels associated with aircraft overflights to pr oposed residents could be offset through the establishment of an overflight easement over the project si te, which requires that new homeowners and tenants/renters be notified through their titl e documents/leases that aircraft operations occur approximately 1 mile west of the site and that occupants could be subjected to noise associated with aircraft overflights.

The project applicant has agreed to implement the navigation easement and title notification to residents as an element of the project. Because the project has been proposed as a predominantly residential developm ent consistent with objectives for the Greenbriar (M05-046 / P05-069) January 22, 2008

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project, and because of the large area that falls within the airport safety zone (i.e., ⅔ of the site), it would be infeasible for the project to re-design the plan in such a way that would continue to provide a predominantly residential community outside the airport safety zone.

All feasible design and policy measures have been incorporated into the project, thereby eliminating the need to consider the alternative in the EIR. (DEIR, pp. 4-2 to 4-4.)

Alternatives Considered in the EIR

1. No Project Alternative – Continuation Of Existing Land Uses

Under the No Project Alternative, development would not occur and the project site would remain designated for agricultural use. Production of agricultural crops would continue at the project site and no new facilities would be constructed. The project site would not be annexed into the City of Sacramento; and it would remain in the unincorporated area of the County of Sacramento. The project site’s current General Pl an land use and zoning designations identified by the County of Sacramento would remain in effect. The Sacramento County General Plan designates the site for Agriculture, and it is zoned by the Sacramento County Zoning Code as Agricultural. The No Project Alternative would be consistent with the designated land uses for the project site but would not meet any of the project objectives. This Alternative would not develop the project site with urban land uses and the project site would continue to operate in an agricultural/farming capacity including rice and row crop cultivation. (DEIR, p. 8-15.)

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Comparative Environmental Effects

With this Alternative, the existing physical conditions of the site would continue. No project- generated traffic would be added to roadways or intersections, and no new air pollutant emissions or noise would be generated from the site. No increased demands for utilities, public services, or parks and open space would occur with this Alternative. There would be no changes to the physical or visual char acter of the site. Further, with no new development, no residents or tenants of the site would be exposed to safety hazards and impacts related to construction erosion and risks from seismic and soil hazards would not occur. This Alternative would reduce the volumes of stormwater discharges from the site because development of urban land uses would not occur. Agricultural operations on the project site would continue under this Alter native and the potential for conflicts between urban land uses and surrounding agricultural operations would not occur. Further, implementation of this Alter native would not result in t he conversion of any Important Farmlands to urban land uses. This Alternative would not develop any urban land uses on the project site and existing biological and wildlife habitats on the project site would remain unchanged.

Although this Alternative would not result in development of the project site, ground- disturbing activities (i.e., disking and plowing) would still occur on the project site. However, these activities would likely not extend to the same depths as the project (i.e., 2-3 feet versus 10-15 feet). Nonetheless, because ground-disturbing activities would continue, this Alternative would result in the same potentially significant impacts associated with the discovery of previously undiscovered cultural resources. Mitigation recommended for the project would reduce these impac ts to a less-than-significant level. Therefore, this Alternative would result in similar cultural resource impacts.

Significant and Unavoidable Impact That Would No Longer Occur

The No Project Alternative would eliminat e the project’s significant and unavoidable transportation impacts to local intersections , roadway segments, freeway ramps, and freeway segments. Further, because the No Project Alternative would not develop any urban land uses on the project site, and no cons truction activities would occur, this Alternative would not generate any construction- or operational-related air emissions (e.g., ROG, NOX, PM10, or TAC’s). The project w ould result in significant and unavoidable impacts related to construction emissions, increases in stationary source TAC’s, and long- term regional emissions. Implementation of the No Project Alternative would eliminate these impacts. However, farming activities would likely occur at the site and these activities would result in the generati on of fugitive dust emissions associated with disking and plowing activities. Quantified dust emissions associated with on-site farming operation are known, but depending the crops that are produced and how crops are rotated at the site, this Alternative could result in the subst antial generation of fugiti ve dust emissions, but because of their intermittent nature would not likely result in significant air quality impacts.

Implementation of this Alternative would also eliminate all of the project’s significant and unavoidable noise impacts. No construction activi ties would occur under this Alternative because no development would occur. As a resu lt, this Alternative would eliminate the project’s construction-related noise impacts; however, these impacts are reduced to a less- than-significant level with implementation of recommended mitigation. Noise impacts Greenbriar (M05-046 / P05-069) January 22, 2008

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associated with aircraft overflights would not occur because no new residential land uses would be developed on-site. Further, mobile-source noise impacts associated with traffic on I-5 and SR 70/99 would not occur because no residences would be located in close proximity to these noise sources.

This Alternative also eliminates the project’s interim significant and unavoidable flooding hazard impacts because no housing would be located on the project site.

Feasibility/Relationship of Alternative to Project Objectives

This Alternative maintains the status quo . The No Project Alternative will avoid the significant and unavoidable impacts associated with the project, provided the existing physical conditions on the site continue to exist. Despite that fact that most, if not all, of the significant impacts associat ed with implementation of the project would be reduced in significance under the No Project Alternative, the implementation of this Alternative would not meet any of the project’s objectives.

The concept of “feasibility” encompasses the question of whether a particular alternative or mitigation measure promotes existing City policies, as well as the underlying goals and objectives of a project. “‘[F]easibility’ under CEQA also encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” ( City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) The No Project Alternat ive would not meet any of the project objectives including those related to development of a light rail station, creation of a pedestrian-friendly development; development of a project that is generally consistent with SACOG’s Blueprint development plan, development of a residential development near the major employment centers of downtown Sacr amento and Metro Air Park; provision of vertically and horizontally mixed neighborhoods; incorporation of parks and open space in a manner that provides connectivity; and creating a residential development with a variety of housing types along the DNA line. This Alternat ive would not further the City’s goal to provide sufficient and additional housing opportuni ties to area residents and would not contribute to meeting long-term housing and employment demand projections. (DEIR, p. 8-

17.)

Importantly, this Alternative would not meet the Project’s key objective of providing development and land for construction of a light rail station along the proposed DNA light rail extension. (See Association of Irritated Residents v. County of Madera (2003) 107 Cal.App.4th 1383, 1400; Sequoyah Hills Homeowners v. City of Oakland (1993) 23 Cal.App.4th 704, 715 (agency may properly re ject an environmentally superior project alternative for failing to meet “the fundamental objective of the pr oject”).) The City recognizes the importance of the DNA line in reducing traffic congestion and improving mobility and air quality by providing alternative transit opportunities. The DNA line would reduce congestion from other non Greenbriar sources on I-5 (primarily), SR 70/99, and I-

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this corridor to access jobs in Downtown demonstrates the need to have a variety of transportation mode choices, including the DNA line, highway improvements and express bus services. Given that the DNA line will parallel I-5, it would likely reduce congestion on I- 5, as well as reducing traffic on SR 70/99. A funding mechanism for a portion of the DNA line construction costs has been established by the City, including the collection of fees from development in the North Natomas Community Plan area and land dedications for the light rail alignment and stations.

The No Project Alternative would preclude any development at the pr oject site, thereby eliminating project objectives relating to pr ovision of high density land uses that would support the DNA line and generate ridership. By providing densities of residential development to support the line, the Project will help the City realize its goal of completing the DNA line which, in turn , will promote the use of trans it by residents and employees within the downtown and Natomas areas, as well as allow transit riders using RT’s light rail system to connect from other areas within the City and County of Sacramento to the Natomas area, Sacramento International Airport, the Sacramento Amtrak Depot, and/or the downtown area with a travel option other than a single occupancy vehicle, with a resulting travel time savings by reducing and avoiding traffic congestion. Residents along the future DNA light rail corridor will benefit from a r eduction in traffic congestion and increased transportation connectivity and mobility, and employees working in the downtown, South Natomas and North Natomas communities will be provided with an alternative transportation mode, thereby reducing freeway congestion and air pollution. (FEIR, p. 4-

21.)

The No Project Alternative’s desirability is not on balance with the project in terms of its economic, environmental, social and technologica l elements. The project is the more desirable choice for the community and the region. Therefore, the No Project Alternative is rejected as infeasible.

2. Dispersed Development Alternative

The purpose of this Alternative is to consider whether existing properties within the City’s SOI could support the project’s proposed land uses, while at the same eliminating some of the project’s significant and unavoidable environmental impacts. This Alternative evaluates the comparative impacts of distributing the project’s proposed housing units and commercial land uses in a multiple loca tions on vacant or underdeveloped properties throughout the City’s corporate limits and SOI boundary.

Comparative Environmental Effects

Impacts Reduced Under the Dispersed Development Alternative:

This Alternative would result in temporar y noise generated by construction activities; development of various noise-generating l and uses; increases in traffic noise; and development of sensitive receptors that would be exposed to existing or project noise levels exceeding City standards. Because of the developed nature of the City, it is likely that this alternative would be in close proximity to sensitive receptors. It is unknown whether existing noise levels currently exceed the City’s standards; however, construction of a dispersed development alternative would likely result in an increase in ambient noise levels in the Greenbriar (M05-046 / P05-069) January 22, 2008

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local area and could result in an exceedence of the City’s exterior noise standard (i.e., 60 dBA Ldn/CNEL). If an alternative were dis persed throughout the City, noise levels associated with roadway traffic volumes would likely be comparatively less (i.e., less than 74 to 81.1 dBA unmitigated) because this site would be located at a greater distance from the combined impacts of traffic noise from I-5 and SR 70/99. Thus , significant noise impacts to residential may be eliminated dependi ng on the location of this alternative.

However, final determination of traffic noise reductions can not be made with knowing the specific locations for this alternative. Similarly, although noise impacts at the site from aircraft operations at Sacram ento International Airport are less than significant, this alternative would likely be located a greater distance from regularly used flight paths and would therefore be subject to less frequent overflights by aircraft and would likely have reduced single event (SENL) levels. When compared to the project, because of its likely more distant location from I-5 and SR 70/99 and airport operations, the dispersed development alternative would result in less noise impacts when compared to the project. (DEIR, p. 8-8.)

A Dispersed Development Alternative within the City limits or SOI would generate a similar number of people and create similar public service demands (i.e., police, fire, schools, and libraries) as the proposed project. These demands have already been anticipated by the City’s General Plan and the public facilities f ees that are collected for projects within specific service areas. These fees would provide sufficient facilities and capacity to serve this alternative. For these reasons, a dispersed development alternative, while resulting in the same demands as the project based on a per capita demand factor for each service, would have comparatively less public services effects because demands associated with build out of the city limits or SOI have already been planned for by the City. (DEIR, p. 8-8.)

This Alternative would also have fewer impact related to parks and open space. A Dispersed Development Alternative within the City limits or SOI would generate a similar number of residents as the proposed project and would construct the same facilities (i.e.,

48.4 net acres of parkland) as the project. The City’s standard for parkland dedication (5 acres per 1,000 new residents or a demand fo r 48.2 acres) would remain the same regardless of the location of the alternative. While this alternative would also result in the conversion of open space resources, the loss of these were accounted for in the General Plan and its EIR; therefore, this alternative would not resu lt in the additive loss of open space resources. (DEIR, p. 8-9.)

Under this Alternative, it is likely that development of property within the City limits or SOI could result in the development of open space land or land historically used for farming activities. Therefore, this Alternative would result in the same type of land use alterations as the project because the site would be convert ed to urban land uses. However, it is likely that impacts would be less because some parcels where development could occur would be in urban areas (i.e., infill development). Lighting would be similarly changed under this alternative, but lighting impacts were not identified as significant project impacts. Overall, this alternative would result in the same aesthetic resources impacts, but these impacts would be less than the projec t because the existing urban core of the City would be maintained. (DEIR, p. 8-9.)

While it is unknown whether an off-site location would have contaminated soils, development within the City’s SOI would not be expected to result in public health and Greenbriar (M05-046 / P05-069) January 22, 2008

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hazard impacts that could not be addressed by standard mi tigation and remediation measures (City of Sacramento 1992). It should be noted that because development would be dispersed over multiple properties, the project’s proposed lake/detention basin would likely not be constructed. As a result, this Alternative would eliminate the project’s potential wildlife hazard impacts. However, implementation of the project’s mitigation to reduce bird hazards from the lake would reduce this impact to a less-than-significant level.

Approval of the project would result in the conversion of 518 acres of Important Farmlands and 465 acres of open space areas. While a dispersed development alternative would likely also result in the conversion of Important Farmlands, any such loss was accounted for in the General Plan and its EIR; therefore, this Alternative would not result in the additive loss of farmland. (DEIR, p. 8-10.)

Impacts Similar Under the Dispersed Development Alternative:

Overall, this Alternative could result in reduced transportation impacts because proposed trips would be dispersed over a large area; however, quantification of the traffic reductions can not be determined without specific locations for the Dispersed Development Alternative. In some cases, the exis ting roadway network may currently operate unacceptably and, thus, this Alternative would exacerbate these unacceptable conditions.

Thus, this alternative would result in similar (but may be greater or lesser) transportation and circulation impacts. (DEIR, p. 8-7.)

Overall, this Alternative would result in sim ilar air quality impacts as the project. The air quality impacts identified for the proposed project are related to construction, the land uses proposed (e.g., residential, elementary school and commercial tenants), and the location of these land uses adjacent to I-5 and SR 70/99. Construction of an off-site alternative would result in the same construction and long-term operational emissions as the project (i.e., mitigated to 89.5 lbs/day of ROG and 511.2 lbs/day of NOX) because the same land uses would be developed. Similarly, operational emissions associated with the dispersed development alternative would be the same as the proposed project because the same land uses are proposed. Depending on the multiple locations of the dispersed development alternative, this alternative may not be located in close proximity (i.e., within 500 feet) of a nearby freeway (e.g., I-5 or SR 70/99) and may reduce potential less-than-significant health risk-related air quality impacts associated with toxic air contaminants. However, because the specific locations for this alternative are not known, it cannot be determined with any certainty whether this project would reduce potential TAC impacts. (DEIR, p. 8-7.)

The City’s General Plan and various community plans include measures to reduce soils and geology impacts to a less-t han-significant level. No uni que geologic structures or conditions have been identified in greater Sacramento area and other areas within the City are substantially similar to the project site in terms of site soils and geotechnical issues (i.e., liquefaction, expansive soils, fault hazards). Similar to the proposed project, standard engineering practices can address design and structural requirements for development of a site within the NNCP boundaries. For these reasons there would be no measurable difference in environmental impacts when comparing the proposed project with a dispersed development alternative within the boundaries of the NNCP. (DEIR, p. 8-9.)

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Similar to the requirements for the proposed project, any development within the City would be required to comply with the City’s Grading, Erosion, and Sediment Control Ordinance (Chapter 15.88 of the City Code). A SW PPP would be prepared and BMPs would be required to be implemented to address stormwater quality control during construction and post-construction. With the implementation of these existing requirements, less-than- significant impacts on water quality and hydrology would occur. Further, the Alternative would be required to be designed consistent with the City’s drainage system standards to ensure adequate drainage facilitie s are provided on-site and that adequate capacity is available in off-site drainage facilities to handle proposed flows. Drainage impacts were determined to be less than significant with t he project. This Alternative could be accommodated in areas located outside the Federal Emergency Management Agency’s (FEMA) 100-year floodplain; therefore, less-than-significant flooding impacts would occur.

Therefore, a Dispersed Development Alternative within the City limits or SOI would have similar hydrology, drainage, and water quality effects compared to the project. (DEIR, p. 8-

10.)

Similar to the proposed project, development within the City limits and SOI would result in impacts on Swainson’s hawk, riparian/wetland habitat, and agricultural lands/rice fields.

Without knowing the exact site s within the City limit s or SOI that could be pursued for a dispersed development alternative, it is not possible to perform a detailed comparison of biological impacts. Implementation of a Dispersed Development Alternative in the City limits or SOI would be anticipated to result in similar resource impacts as those affected by the project (e.g., foraging habitat, wetlands) and would result in similar take of species because habitat and species present at the project site is co mmon throughout the City and surrounding areas. Developments north of the American River would be located within the City’s permit area identified in the Natomas Basin Habitat Conservation Plan (NBHCP). The NBHCP, the EIR on the NBHCP, and subsequent monitoring programs have evaluated the impacts to biological resources from development within the NNCP area including impacts to giant garter snake and Swainson’s hawk. Because this alternative would result in similar habitat and species impacts as the project, it would have similar effects on sensitive biological resources. (DEIR, p. 8-10.)

Both the dispersed development site locations and the project site would have the potential for undocumented subsurface cultural resour ces. However, there are no documented resources on either the project site or on Low Density Residential sites within the NNCP.

For this reason, the proposed project and an alternative within the city limits or SOI would have similar effects on cultural resources [Similar]. (DEIR, p. 8-10.)

Significant and Unavoidable Impact That Would No Longer Occur

An off-site alternative dispersed throughout the city limits and SOI would generate a similar number of people and create similar utility and service system demands as the proposed project (i.e., water, wastewater, drainage, el ectricity, and natural gas). These demands have already been anticipated by various public facilities financing programs established by the City. The significant envir onmental impacts that would occur with the provision of wastewater treatment services (i.e., expanded wastewater treatment facilities) to the project would not be expected to occur under this alternative because dispersed locations would be within the city limits or SOI and have been planned for in the SRCSD’s facility master Greenbriar (M05-046 / P05-069) January 22, 2008

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plan. Therefore, this alternative would eliminate the project’s significant and unavoidable impact to wastewater treatment services. (DEIR, p. 8-8.)

A change to the visual character of the projec t site was identified as a significant and unavoidable impact for the project. However, the project would extend the area of the City that would be converted from agricultural to urban land uses. A development within the City limits or SOI would maintain the City’s boundaries and would not extend the urban core of the City.

A Dispersed Development Alternative would eliminate the project’s potential inconsistency with the Sacramento Inter national Airport Comprehensive Land Use Plan (CLUP) requirement to limit land uses (i.e., parks and light rail station) that would result in a substantial concentration of people (i.e., 25 persons per acre on average of 50 persons per acre at any one time) because this Alternat ive would be located outside the airport’s overflight safety zone. Therefore, the dispersed development alternative would eliminate the project’s significant and unavoidable CLUP consistency impact. Further, a site within the NNCP would locate sensit ive receptors including the el ementary school at greater distances from I-5 and SR 70/99, which would reduce their, exposure to mobile source emissions (see Section 8.1.2, “Air Quality,” above). Thus, a dispersed development alternative within the city limits or SOI would have less public health and hazard effects. (DEIR, p. 8-9.)

Feasibility/Relationship of Alternative to Project Objectives

The concept of “feasibility” encompasses the question of whether a particular alternative or mitigation measure promotes existing City policies, as well as the underlying goals and objectives of a project. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.)

80. According to the DNA Dr aft Alternatives Analysis Report (2003), the DNA line is expected to transport as many as 1,200 persons per hour during its peak hour of operation and will reduce weekday peak period auto travel to Downtown Sacramento by 4,700 daily trips. By comparison, traffic volumes on I-5 in 2025 will range upwards to around 19,000 peak hour trips (both directions). The large number of people traveling during peak hour in this corridor to access jobs in Downtown demonstrates the need to have a variety of transportation mode choices, including the DNA line, highway improvements and express bus services. Given that the DNA line will parallel I-5, it would likely reduce congestion on I- 5, as well as reducing traffic on SR 70/99. A funding mechanism for a portion of the DNA line construction costs has been established by the City, including the collection of fees Greenbriar (M05-046 / P05-069) January 22, 2008

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from development in the North Natomas Community Plan area and land dedications for the light rail alignment and stations. (FEIR, p. 4-21.)

The Dispersed Development Alternative woul d preclude any development at the project site, thereby eliminating project objectives relating to provision of high density land uses that would support the DNA line and generate ridership. By providing densities of residential development to support the line, the Project will help the City realize its goal of completing the DNA line which, in turn, will pr omote the use of transit by residents and employees within the downtown and Natomas areas, as well as allow transit riders using RT’s light rail system to connect from other areas within the City and County of Sacramento to the Natomas area, Sacramento Internati onal Airport, the Sacr amento Amtrak Depot, and/or the downtown area with a travel option other than a single occupancy vehicle, with a resulting travel time savings by reducing and avoiding traffic congestion. Residents along the future DNA light rail co rridor will benefit from a reduction in traffic congestion and increased transportation connectivity and mob ility, and employees working in the downtown, South Natomas and North Natomas communities will be provided with an alternative transportation mode, thereby reducing freeway congestion and air pollution.

In addition, this Alternative would be inconsistent with the City’s infill development strategy and would contribute to meeting long-term housing and employment demand projections.

In fact, if development occurred according to this Alternative, the City would not be able to accommodate expected future growth. Accord ing to the City’s General Plan technical background reports, as of September 2005, there were approximately 14,000 acres of low and medium density parcels of vacant land available. However, the actual number is likely less than this total, because a substant ial quantity of land has been developed subsequently in the North Natomas area, where the majority of this land is concentrated.

For example, projects cons idered in a cumulative context include the Westborough, Cambay West, Natomas Crossing, Natomas Town Center, Natomas Creek and Panhandle (595 acres with 3,075 dwelling uni ts) projects; each of which are in the North Natomas area. In the south Sacramento area, M&H Realty and SunCal Companies and Dunmore Homes have submitted an application to develop one of the last remaining large blocks of land in the City, the 925-acre Delta Shores site. Vacant industrial sites at the 240-acre downtown Sacramento railyards (up to 10,000 dwelling units) and 72 acre Curtis Park railyards (540 dwelling units and 188,941 square feet of re tail/commercial) are being actively pursued for development, with applications submitted and the environmental review process begun on both. As this shows, the North Natomas area continues to be actively developed, and other large, vacant, or undeveloped parcels are being actively pursued.

Further, much of the land is tied up by other landowners interested in development. None of the undeveloped low or medium density residential or residential /mixed-use properties within the NNCP area or in other large, undeveloped areas of the City is currently owned by the Greenbriar property owner.

The City believes that, as a result of the lack of available vacant land within its boundaries, the City will need to look to sites outside t he SOI in order to accommodate projected growth. The information provided by the General Plan Update Technical Background Reports and the ongoing City Infill Strategy support this conclusion, as discussed below.

Sufficient holding capacity is available within the City’s SOI to accommodate the project’s proposed residential development. In spite of the fact that the City may currently have Greenbriar (M05-046 / P05-069) January 22, 2008

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holding capacity for the project, this is not expected to be the case in the foreseeable future. According to Sacramento City staff (McDonald, pers. comm., June 19, 2006), the Technical Background report for the City of Sacramento General Plan Update shows the following:

Current (2005) population: 450,000
Proposed General Plan Holding Capacity (2030): 564,000 Anticipated City population (2030): 650,000

Over the next 25 years, the City is expected to grow by 200,000 people. However, the current General Plan, including the current sphere-of-influence, would accommodate an additional estimated 114,000 people. Additional land would be needed if the City intends to accommodate the 86,000 people abov e the General Plan’s holding capacity that are anticipated to live in the City.

In its July 6, 2007 report, economic consultants EPS estimated that, given the General Plan update area’s urban form and land use parameters, the City has vacant and redevelopment capacity for 111,000 additional housing units. The City needs only 42,000 of those units by 2030 to attain agreed-upon growth projections.

While the vacant site potential and reuse potential is theoretically a sizable number, EPS believes that the market and site constraints of these potential development areas will not deliver anywhere near the 100,000 dwelling unit need. In other word s, these sites are generally low potential (rates of absorption by 2030 at less than 30% of theoretical development capacity). Therefore, in order to meet growth targets, the City needs to utilize the new growth sites, including the Greenbriar project site.

The proposed project would also provide for employment through commercial/retail uses, although these uses would primarily serve re sidential uses on and near the project site.

Projections for employment uses in the City are as follows:

Current (2005) employment: 181,000
Proposed General Plan Holding Capacity (2030): 445,000 Anticipated City employment (2030): 321,000

Unlike housing, the City has ample holding capacity for employment uses. As mentioned above, commercial/retail uses on the project site are intended to be local serving, and they would reduce the need for driving trips outside the project site. So, while they could be provided elsewhere within the City, they would frustrate project objectives for a mixed use development.

As stated on page 2-3 of the DEIR, the Sacr amento region is becoming an increasingly attractive place to live through its strong empl oyment market, its relatively affordable housing, and other quality of lif e factors. The discussion in the DEIR demonstrates that, absent additions to developable land through SOI changes, there would not be sufficient land to provide for this population projec tion. If additional land was not provided to accommodate the population growth, it is likely that two outcomes would occur:

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1. If housing was not provided to meet population projection s in the City of Sacramento, demand for available housi ng would be increasingly higher than supply. This would likely dr ive the price for available housing up substantially. In other areas of Califor nia, this has resulted in moderate income families being increasingly priced out of the housing market.

2. In addition to the socioeconomic issues resulting from pric ing moderate income families out of the housing market (socioeconomic effects ar e not environmental impacts and are therefore not consider ed further herein), the common physical environmental impact that consequently results is to push development to outlying communities where greenfield sites are plentiful. The tendency in higher priced communities (e.g., Los Angeles, Orange County, and Bay Area) is that development is pushed further and further from the job centers, increasing commutes, air quality effects, and traffic congestion.

The Blueprint process was developed in large par t as a result of the concern that the Sacramento region needs to accommodate a large future demand for housing, and that if the region was not considered as a whole, the pattern found in the above referenced communities would be repeated in the Sacram ento region. The Greenbriar proposal is consistent with land use recommendations for the site as shown in the Blueprint.

Further, because of its dispersed nature, this Alternative would likely not meet many of the project’s objectives including development of a residential development near the major employment centers of downtown Sacramento and Metro Air Park; provision of vertically and horizontally mixed neighborhoods; incorporation of parks and open space in a manner that provides connectivity; creating a resi dential development with a variety of housing types; and creating a development that could s upport a light rail stati on. However, this Alternative could possibly further support and im plement the project objective related to developing a project that is consistent with the Sacramento International Airport CLUP because it would eliminate the project’s inconsistency with the safety requirement of maintaining a density of 50 persons per acres for the proposed light rail station, and park areas. (DEIR, p. 8-11.)

3. Reduced Size Alternative

The Reduced Size Alternative is designed to reduce the development footprint of the project to avoid one or more of the proj ect’s significant and unavoidable impacts.

Development of this Alternative would be approximately 80% of pr oposed project levels (20% reduction in proposed devel opment at the site) (Exhibit 4-1). Therefore, this Alternative would result in the development of 2,995 residential units and approximately 25 acres of commercial development. The remainder of the site would be undeveloped and would continue in its existing state. To reduce potential impacts to agricultural resources, open space areas, sensitive biological s pecies and habitats, and to minimize the development area that falls wit hin the Sacramento Internati onal Airport’s safety zone, development of this Alternative would need to be concentrated in the eastern portion of the project site. However, mobile source air emissions and noise impac ts from I-5 and SR 70/99 result in the need to locate sensitive receptors including the elementary school at a greater distance from these sources. Therefore, this Alternative would need to be designed in such a way as to provide a buffer on the eastern and southern boundaries of the site in addition to the proposed buffer on the western boundary of the project site. In general, this Greenbriar (M05-046 / P05-069) January 22, 2008

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alternative would result in a development project that pr ovides a 200- to 400-foot open space buffer along the eastern, southern, and western edges of the project site. (DEIR, p. 8-11.)

Comparative Environmental Effects

Impacts Reduced Under the Reduced Size Alternative:

This Alternative would reduce the number of housing units developed at the project site by approximately 20%, resulting in a corresponding 20% reduction in daily traffic volumes on local roadways. Therefore, the Reduced Size Alternative would result in the generation of 32,896 total trips (2,523 a.m. peak hour and 3,574 p.m. peak hour trips). Based on evaluation of the surrounding roadway network, a reduction of approximately 75% of total trip generation (i.e., not to exceed 10,280 total trips) would be required to eliminate the project’s significant and unavoidable transportation system impacts including impacts to local roadway intersections, roadway segments, freeway ramps, and freeway segments.

Therefore, while this Alternative would result in less traffic on area roadways, it nonetheless would continue to result in significant and unavoidable transportation impacts because existing traffic volumes are either closely approaching unacceptable operating conditions or currently exceed acceptable operating thresholds for these facilities. However, it should be noted that mitigation recommended for the project would like result in more efficient and less congested operation of the local roadway network under the Reduced Size Alternative compared to the project. Further, because of its reduced size and the reduced number of traffic trips generated by this alterative, this Alternative would result in less transportation and circulation impacts compared to the project, but these impacts would continue to be significant and unavoidable. (DEIR, p. 8-11.)

This Alternative would result in development of the majority of the project site and the generation of construction- and operations-rela ted air emission. Air emissions would be approximately 20% less under this Alternative because of the reduced number of houses and commercial acreage (and associated vehicle trips). However, because a majority (i.e., 80%) of construction activities and proposed uses would occur, this Alternative would also result in the generation of air emissions that exceed relevant standards of the Sacramento Metropolitan Air Quality Managem ent District (SMAQMD) (i.e., construction-related emissions mitigated to 71.6 lbs/day of ROG and 408.96 lbs/day of NOX ) and operational emissions mitigated to 280.6 lbs/day of ROG, 270.8 lbs/day of NOX, and 165.3 lbs/day of PM10) This Alternative would provide a greater setback between I-5 and SR 70/99 from sensitive receptors through the provision of a 200- to 400-foot buffer along the eastern and southern boundaries of the project site. This setback would further reduce less-than- significant exposure to toxic air contam inants from freeway operations, and could, depending on other design considerations (e.g ., sound walls, tree lines), eliminate any concerns surrounding this impact. Overall, this Alternative would result in less construction- and operation-related air emissions compared to the project, but these impacts would continue to be significant and unavoidable. This Alternative would also likely substantially reduce or avoid the project’s significant toxic air contaminant impacts. (DEIR, p. 8-12.)

Both this Alternative and the proposed project would result in temporary noise generated by construction activities; development of various noise generating land uses; increases in traffic noise; and development of sensitive receptors that would be exposed to existing or Greenbriar (M05-046 / P05-069) January 22, 2008

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project-generated noise levels exceeding Cit y standards. Construction-related noise impacts would be the same as with the pr oposed project because the same types and numbers of construction equipment would be used. However, noise levels at nearby sensitive receptors may be reduced because of the larger buffer areas provided around the development site. Similar to the project, construction activities would be limited to the hours of 7 a.m. to 6 p.m. Monday through Saturday and 9 a.m. to 6 p.m. on Sunday, which would reduce construction-related noise impacts to a less-than-significant level. Given the relative level of traffic (80% of project), compared with the project, traffic noise would be reduced.

This Alternative would also shift the project f ootprint of the site to the center and would provide a greater distance bet ween the development and the major noise source of the Sacramento International Airport. More importantly, this Alternative would provide a greater setback from major transportation noise sources, I-5 and SR 70/99, thereby reducing and perhaps eliminating exterior and interior noise level exceedances at sensitive receptors.

However, because of the constrained nature of the site and the need to locate the elementary school outside the ov erflight safety zone of t he Sacramento International Airport, it may not be feasible to re-locate the elementary school such that the benefit of increased noise reduction could be achieved. Overall, this Alternative would reduce noise impacts to some noise sensitive land uses and impacts would be less than the project. (DEIR, p. 8-12.)

In general, this Alternative would result in the same land uses and same project amenities including the proposed light rail station. This Alternative would reduce the number of houses within the overflight safety zone of the Sacramento International Airport, thereby reducing potential safety risks associated with airport operations. This Alternative would, however, include a proposed light rail station, commercial uses, and parks which would be incompatible with safety standards of the Sacramento International Airport’s CLUP. Further, this Alternative would also locate a lake/ detention basin within the airport safety zone, which could create potential bi rd strike hazards for commercial aircraft. However, implementation of mitigation recommended for the project would reduce this impact to a less-than-significant level. Overall, this Alternative would reduce the development and land uses that would fall within the airport safety zone, thereby reducing the number of residents and tenants that are exposed to potential aircraft hazards. Therefore, this Alternative would result in less public health and hazards impacts. (DEIR, p. 8-13.)

The viability of the buffer areas on the project site (i.e., long, narrow 200- to 400-foot wide strips of land) for agricultural operations would likely be infeasible. In general, large areas dedicated to agricultural operations are needed to have a viable farming operation. Further, potential land use incompatibilities (e.g., air, noise) associated with agricultural operations adjacent to urban development increases the likelihood that a viable agricultural operation surrounding the project site would not occur. Therefore, although the foot print of this would result in less development and direct conver sion of Important Farml and, the net effect because of land use compatibilities and lack of viable farming properties would be similar to the project (i.e., conversion of 518 acres of Important Farmland) and with mitigation would be significant and unavoidable. However, this Alternative would reduce the acreage of open space converted to urban land uses; however, because of the substantial size of this Alternative and the lack of full compensatory mitigation, this impact would remain significant and unavoidable. Nonetheless, this Alternat ive would reduce impacts to Important Farmland and overall impacts would be less [Less]. (DEIR, p. 8-14.)

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Impacts Similar Under the Reduced Size Alternative:

Under this Alternative, ut ility and other public service dem ands would be approximately 20% less; however, these impacts are less than significant or less than significant with mitigation for the project. No significant utilities or public services impacts were identified for the project after mitigation, so this Alternative would not reduce or avoid any such impacts.

Indirect impacts related to regional improv ement projects (i.e., wastewater treatment expansion) would be similar. Overall, this Alternative would result in similar environmental impacts (i.e., based on CEQA thresholds) as the project, although unit demands for utility and other public services would be less because this Alternative would reduce the total population living on-site. (DEIR, p. 8-12, 13.)

Although reduced in size, it is assumed this Alternative would provide comparable park land as the project and would meet the City’s standard for parkland dedication (5 acres per 1,000 new residents). Based on a population of 7,141 residents, approximately 35.71 acres of parkland would be provided under this Alter native. However, because of the need to provide buffers around the perimeters of the project site to reduced noise and air quality impacts associated with traffic on I-5 and SR 70/99 and the constraints associated with the airport safety zone, it may be potentially inf easible for this Alternative to provide a community park (i.e., a park of 23 acres or more). Nonetheless, it is expected that this Alternative would meet its park demand requirements. This Alternative would convert approximately 20% less open spac e areas because of its reduc ed size. Therefore, the proposed project and this Alternative would have similar effects related to parks and open space. (DEIR, p. 8-13.)

Under this Alternative there would be the same alteration of views, but at a reduced scale, of the project site from surrounding lands including I-5, SR 70/99, and local roadways. This impact was identified as significant and unavoidable with the project. With this Alternative, this impact would also be considered significant and unavoidable because the view shed would substantially changed from existing conditions, similar to what would occur with the project. Lighting would be slightly less under this Alternative, but lighting impacts were not identified as significant proj ect impacts. Overall aesthetic resources impacts would be perceived as nearly the same as the project because the site would be substantially converted from any open space to a developed use. (DEIR, p. 8-13.)

Under this Alternative there would be a reduction in project development; therefore impacts related to construction erosion and risks from seismic and soil hazards would be reduced.

Nonetheless, because of its substantial size (i.e., greater than 15 acres), this Alternative would include the same soil erosion (i.e ., preparation of a SW PPP) and soil hazards mitigation measures as the project; therefor e, post mitigation impacts would not change (i.e., impacts would be less than si gnificant). Therefore, this Alternative would result in similar geology and soils impacts. (DEIR, p. 8-13.)

In general, this Alternative would result in the same hydrology and water quality impacts as the project because a substantially simila r, but somewhat r educed development would occur. This Alternative would reduce the volumes of stormwater discharges from the site.

Nevertheless, because both the project and this Alternative would be designed in accordance with City drainage standards, would ensure that sufficient capacity exists in off- site drainage facilities, and would implement BMPs for water quality, this Alternative would Greenbriar (M05-046 / P05-069) January 22, 2008

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result in similar hydrology and water quality impacts. Similar to the project, this Alternative would be located in an area that is located outside the Federal Emergency Management Agency’s (FEMA) 100-year floodplain. Therefore, less-than-significant flooding impacts would occur. Therefore, the proposed project and Reduced Size Alternative would have similar hydrology, drainage, and water quality effects. (DEIR, p. 8-14.)

This Alternative would reduce the development footprint of the pr oject site and would increase the buffer area along the western, eastern, and southern boundaries of the site (i.e., up to 400 feet). Therefore, this Alternative would reduce overall impacts to giant garter snake. Further, similar mitigation to enhance giant garter snake habitat at off-site location would also be provided. There would be increased Swainson’s hawk foraging habitat at the site under this Alternative. Other habitat and species impacts would be comparable under this Alternative, but would occur to a lesser degree (e.g., wetland impacts). Overall, this Alternative would result in less biological resources impacts. However, because less of the site would be developed, less off-site mitigation would need to be purchased and enhanced for the benefit of species affected. The establishment of off-site preserves designed for the benefit of species is intended to fully offset the impacts of project development. Under this Alternative, the need for off-site mitigati on would be less. Because the mitigation is designed to offset the impacts, impacts under th is Alternative would be similar to the proposed project. (DEIR, p. 8-14.)

Because this Alternative would result in development of the majority of the project site and ground-disturbing activities would occur across the site, impacts to unknown archaeological resources would be potentially significant with this Alternative similar to those of the project.

However, with implementation of mitigation recommended for the project, this impact would be reduced to a less-than-significant level. This Alternative would not reduce or avoid and significant cultural resource impact of the project, so overall cultural resource impacts would be similar to the project. (DEIR, p. 8-14.)

Significant and Unavoidable Impact That Would No Longer Occur

While this Alternative would substantially reduce impacts related to transportation and circulation, air quality, noise, conversi on of prime farmland and open space and visual character, all of these impacts would remain significant and unavoidable.

Feasibility/Relationship of Alternative to Project Objectives

As stated above, the concept of “feasibility” encompasses the question of whether a particular alternative or mitigation measure promotes existing City policies, as well as the underlying goals and objectives of a project. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) “‘[F]easibility’ under CEQA also encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.)

This Alternative would constrain development at the project site to a development level that may be financially infeasible to implement. Development of this Alternative would be Greenbriar (M05-046 / P05-069) January 22, 2008

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approximately 80% of proposed project levels (20% reduction in proposed development at the site). Therefore, this Alte rnative would result in the dev elopment of 2,995 residential units and approximately 25 acres of commercial development. The remainder of the site would be undeveloped. This Alternative would shift the same total cost of backbone infrastructure improvements to fewer unity, thereby increasing the cost burden to each individual unit. In addition, under this Alternative, fewer units would be paying the Public Facilities Fee, thereby decreasing the total amount of fee revenue collected by the City of Sacramento. (“Greenbriar Environmental Impact Report Alternatives Analysis”, prepared by EPS, page 2.)

As discussed in the memorandum prepared by EPS, projects with cost burdens above 15 percent are more sensitive to development-cost increases and face the risk of becoming infeasible in the face of cost increases. The Reduced Size Alternative increases the cost burden as compared to the Project: Under the project the cost burdens as a percentage of estimated respective home sales prices are estimated at 15.5% for LDR, 18.5% for MDR, and 13.8% for HDR. The Reduced Size Alternative pushes the limits of feasibility, as its cost-burden ratios approach 20%: the cost burdens as a percentage of estimate respective home sales prices are estimated at 16.4% for LDR, 19.5% for MDR, and 14.6% for HDR. (“Greenbriar Environmental Impact Report Alternatives Analysis”, prepared by EPS, page

3.) Also, as compared to the Project, t he Reduced Size Alternative will contribute less toward funding of public facilities such as parks (including the North Natomas Regional Park), library facilities, fire facilities, police facilities, mainline freeway facilities, community center facilities, and bikeways and shuttles in North Natomas. Specifically, the Project would contribute approximately $10,731,523 for public facilities, while the Reduced Size Alternative would contribute approximately $8,585,218. (“Greenbriar Environmental Impact Report Alternatives Analysis”, prepared by EPS, page 5.)

Further, to reduce potential impacts to agricultural resources, sensitive biological species and habitats, and to minimize the development area that falls within the Sacramento International Airport’s safety zone, development of this Alternative would need to be concentrated in the eastern por tion of the project site. However, mobile source air emissions and noise impacts from I-5 and SR 70/99 result in the need to locate sensitive receptors including the elementary school at a greater distance fr om these sources.

Therefore, this Alternative would need to be designed in such a way as to provide a buffer on the eastern and southern boundar ies of the site. In general, this Alternative would consist of a development projec t that would concentrate land uses in the north central portion of the site. An approximate 200–400 foot-wide buffer/open space/fallowed land area would be provided on the western, eastern, and southern boundaries of the project site.

The Reduced Size Alternative would meet most of the project’s objectives related to creation of a pedestrian-friendly development; development of a project that is generally consistent with SACOG’s Blueprint development plan, development of a residential development near the major employment centers of downtown Sacramento and Metro Air Park; provision vertically and horizontally mixed neighborhoods; incorporation of parks and open space in a manner that provides connectivity; and creating a residential development with a variety of housing types. However, because of its reduced size and reduced population densities, the Reduced Size Alternative may not provide a sufficient population base to support the construction of a light rail station on the project site and it would not Greenbriar (M05-046 / P05-069) January 22, 2008

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provide as great a benefit toward meeting the City’s long-term housing and employment demand projections.

Environmentally Superior Alternative

In addition to the discussion and comparison of impacts of the alternatives to the proposed project, CEQA requires that an “environm entally superior” alternative among the alternatives considered be se lected and the reasons for such selection disclosed. In general, the environmentally superior alternative is the alternative that would generate the fewest or least severe adverse impacts. In the case of the project, the no project alternative is the environmentally superior alternative because it would not create any new site-specific adverse environmental impacts. However, CE QA requires the ident ification of another environmentally superior alternative when the “no project” al ternative is identified as environmentally superior (State CEQA Guidelines Section 15126[e][2]).

The Reduced Size Alternative would be environmentally superior to the project because it would substantially reduce the project’s traffic, air, noise, farmland, and biological resources impacts. Further, it would meet most project objectives including supporting light rail and creating a development consistent with SACOG’s Blueprint.

The Off-Site Alternative within the ex isting boundaries of the NNCP would be environmentally superior to t he project and to the Reduced Size Alternative. This Alternative is the overall superior alternative because it would avoid the project’s significant aircraft safety hazard impact associated wit h compatibility with CL UP standards and it would substantially reduce tra ffic, farmland, biological, air quality, and noise impacts.

Further, it would meet most if not all project objectives. However, a site within the NNCP is not currently owned by the project applicant and all land in the NNCP area is currently proposed for development. Therefore, the Off-Site Alternative considered in this analysis is infeasible. Further, this Alternative would not meet the key project objective of providing a development along the DNA line.

The Dispersed Development Alternative woul d not be environmentally superior to the project. While this Alternative would avoid the project’s significant aircraft safety hazard impacts associated with compatibility with CLUP standard and it would substantially reduce traffic, farmland, biological, air qualit y, and noise impacts, depending on localized conditions could result in greater transportation impacts compared to the project. Further, multiple sites within the City limits or SOI are not owned by the project applicant and most land with the City is currently proposed for development. Therefore, this theoretical Alternative is infeasible. Further, development of an alternative in a dispersed nature would not achieve the key project objectives relat ed to providing resident ial development that would support development of a light rail station along the DNA line. (DEIR, pp. 8-18 to 8-

19.)

F. Statement of Overriding Considerations:

Pursuant to Guidelines section 15092, the City Council finds that in approving the Project it has eliminated or substantially lessened all significant and potentially significant effects of the Project on the environment where feasible. The City Council further finds that it has balanced the economic, legal, social, technol ogical, and other benefit s of the Project Greenbriar (M05-046 / P05-069) January 22, 2008

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against the remaining unavoidable environmental risks in determining whether to approve the Project and has determined that t hose benefits outweigh the unavoidable environmental risks and that t hose risks are acceptable. The City Council makes this statement of overriding considerations in accordance with section 15093 of the Guidelines in support of approval of the Project.

The Project Will Support Development of the Planned DNA Line.

The Project objectives for Greenbriar include creating a transit-oriented development along the planned Downtown-Natomas-Airport (DNA) light rail line. The Project includes densities of residential development that would support the feasibility of this light rail line. (See letters from RT to City in support of Project dated November 1, 2005; September 5, 2006; and July 11, 2007 included in Appendix B of FEIR; see also August 3, 2005 testimony of Beverly Scott before Sacramento LAFCo.)

The Sacramento Regional Transit District (RT) has identified the DNA light rail line on its 20-year project map, and the DNA line is included in SACOG’s Metropolitan Transportation Plan. In a letter submitted to the City on July 11, 2007, RT confirmed its continuing plans to extend light rail from downtown to the Sacramento International Airport.

RT is in the process of preparing a project-level EIR for the first phase of the DNA project that will evaluate the impacts of implementation of this porti on of the DNA light rail line project. Construction of the DNA would occur in 3 segments (minimum operable segments [MOS]): MOS 1 would start at 7th Street and end at Richards Boul evard; MOS 2 would continue from Richards Boulevard to t he Natomas Town Center; and MOS 3 would continue from the Natomas Town Center, cr oss the Greenbriar site and continue to the Sacramento International Airport. RT esti mates that MOS 1 woul d be fully operable by 2014 with the remainder of DNA line operable by 2027. (See FEIR, Appendix B.)

The Alternatives Analysis/Draft EIR/EIS was initiated in 2001 and will be completed within the next month. This will lead to the Preliminary Engineering and Final EIR/EIS, scheduled to begin early next year. RT confirmed that it plans to continue earnestly on this track until the extension is constructed and that it supports the Greenbriar Project, which will focus appropriate transit-oriented development along the proposed DNA alignment. (See FEIR, Appendix B.)

RT is also pursuing a variety of funding sources to fund the construction of the DNA light rail line. RT has been involved in the lengthy Federal Transit Administration (FTA) New Starts funding process, which requires a showing that the light rail line will serve areas with densities that will support tr ansit and generate ridership. The Greenbriar project will support this funding by focusing appropriate transit-oriented development along the DNA line. (See FEIR, Appendix B.)

By providing densities of residential development to support the line, the Project will help the City realize its goal of completing the DNA line which, in turn, will promote the use of transit by residents and employees within t he downtown and Natomas areas, as well as allow transit riders using RT’s light rail system to connect from other areas within the City and County of Sacramento to the Natomas ar ea, Sacramento International Airport, the Greenbriar (M05-046 / P05-069) January 22, 2008

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Sacramento Amtrak Depot, and/or the downtown area with a travel option other than a single occupancy vehicle, with a resulting trav el time savings by reducing and avoiding traffic congestion. Residents along the future DNA light rail corri dor will benefit from a reduction in traffic congestion and increased transportation connectivity and mobility, and employees working in the downtown, South Natomas and North Natomas communities will be provided with an alternative transportation mode, thereby reducing freeway congestion and air pollution.

The DNA line would also reduce congestion from other non-Greenbriar sources on I-5 (primarily), SR 70/99, and I-80. According to the DNA Draft Alternatives Analysis Report (2003), the DNA line is expected to transport as many as 1,200 persons per hour during its peak hour of operation and will r educe weekday peak period auto travel to Downtown Sacramento by 4,700 daily trips. By comparison, traffic volumes on I-5 in 2025 will range upwards to around 19,000 peak hour trips (both directions). The large number of people traveling during peak hour in this corridor to access jobs in Downtown demonstrates the need to have a variety of trans portation mode choices, including the DNA line, highway improvements and express bus services. Given that the DNA line will parallel I-5, it would likely reduce congestion on I-5, as well as reducing traffic on SR 70/99. A funding mechanism for a portion of the DNA line c onstruction costs has been established by the City, including the collection of fees from development in the North Natomas Community Plan area and land dedications for the light rail alignment and stations. (See FEIR, pp. 4- 20 to 4-22.) Please see also Responses to Comments 8-2, 29-47, 29-48, 29-61, S2-13 and Letter 26. (FEIR, pp. 4-208, 4-281, 4-494, 4-496 to 4-497, 6-11.)

The Project Provides High Density Reside ntial Development Within ¼ Mile of a Proposed Light Rail Station.

The Greenbriar project objectives include designing a project that promotes using various modes of transportation by locating high-density residential development within ¼ mile of a proposed light rail station.

The Project site is located along the proposed Downtown-Natomas-Airport (DNA) light rail extension. Medium and high density housing and retail land uses would be located in the center of the Project site along a new arterial, Meister Way. Easements will be provided for a new light rail station to be constructed along this new roadway arterial by Sacramento RT and RT intends to provide a new light rail stop along the proposed Meister Way, which is parallel to the proposed DNA light rail line alignment. (DEIR, pp. 3-11 to 3-12.)

By providing easy access to a light rail station, the Project promotes reduced vehicle miles traveled per household resulting in shortened commute times, reduced traffic congestion, lessened dependence on automobiles and reduced pollution from vehicle emissions.

The Project Will Dedicate Land for Purposes of Constructing a Light Rail Station.

The Greenbriar Project objectives include providing development and land for construction of a light rail stop along the proposed DNA light rail line with densities that will support the feasibility of a light rail line. The Project includes dedicati on of a corridor that could accommodate a future transit stop and light rail alignment located near the center of the Project site along the proposed Meister Way roadway. The light rail station would provide Greenbriar (M05-046 / P05-069) January 22, 2008

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public transportation access to downtown Sacramento, Sacramento International Airport and Metro Air Park. (DEIR, pp. 3-11 to 3-12.)

The Project will allow the City to bring the DNA light rail line to fruition and provide the Project site with an easily accessible light rail station.

The Project is Consistent with and Supportive of Sacramento Area Council of Government’s (SACOG’s) Blueprint Plan.

The Sacramento Area Council of Governments’ (SACOG) Blueprint Preferred Scenario designates that the Project site should be developed as high density, mixed residential and single family small lot land uses. The proposed Project would be consistent with the smart growth principles identified in the Blueprint by providing high density housing and a variety of housing types at varying price ranges; focusing on compact development to maximize use of existing land; offering a range of mixed land uses (residential, retail and office);using existing assets by infilling or intensifying the use of under utilized parcels in urbanized areas; incorporating public-use open space within the Project beyond the regulatory requirements; encouraging a distinctive, attractive community with high quality design; and providing transportation choices to encourage people to walk, ride bicycles, ride the bus, ride light rail, take the train, or car pool.

The Draft Greenbriar PUD Guidelines fully in corporate the “Smart Growth” Principles.

Section 1.3 of the Draft PUD Guidelines addresses the SACOG Blueprint principles in detail. Consistent with Bluepr int principles, the Greenbriar PUD would provide a varied network of both on- and off-st reet pedestrian pathways and tr ails, allowing for safe and convenient nonvehicular travel throughout and within the PUD. The street and trail system within the PUD would allow for varied opportunities for safe and convenient non-vehicular travel throughout the plan area. All arterial and collector streets would have striped Class II bike lanes. Nearly all sidewalks within the PUD’s streets would be detached from the street edge and separated from the str eet by a landscape planter of varying width depending upon the street facility. These pedestrian-friendly streets would provide a safe, walkable route to everywhere in the PUD area under a dense canopy of shade trees.

All of the Blueprint’s principles have been applied in the design of the proposed project. The project incorporates diverse housing types (i.e., low density, medium density, high density residential), development would be compact (i.e ., maximized use of space by providing medium and high density residential land uses on more than half of the site), the area of public open space is greater than required by city regulations (project provides 48.4 acres versus City requirement of 48.2 acres), and mixed uses (i.e., residential and commercial land uses on one parcel) would be accommodated on the site. In addition, the project would provide a variety of transit opportunities including walking and bicycling, and by planning for a future light rail extension and station at the project site. Because the proposed Project would meet the smart growth objectives set forth in the Blueprint Preferred Scenario, the Project would be consistent with the Blueprint.

The Project Will Provide Revenue to the City.

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The Project will provide revenue to the City from sales taxes generated by the commercial portions of the Project, as well as increased property tax revenues to fund public services and facilities. The creation of temporary construction jobs and permanent office and retail jobs will also financially benefit the City, as will the increase in sales taxes from the purchase of goods by Project residents withi n the community. The Project will also generate revenues to the City through payment of building fees and development impact fees.

Public Facilities Fee

The Project will be charged a Public Facilities Fee to fund public facilities required to serve the Project. In addition to constructing all backbone infrastructure facilities and a transit station to serve the proposed DNA Light Rail line, the Project will pay fees at building permit that will help fund parks (including the North Natomas Regional Park), library facilities, fire facilities, police facilities, mainline freeway facilities, community center facilities, and bikeways and shuttles. This provides a measure of public benefit because the fee funding aids the contribution of public facilities in North Natomas, whic h benefits both North Natomas residents and Greenbriar residents. The Project will contribute approximately $10,731,523 for public facilities. (“Greenbriar Environmental Impact Report Alternatives Analysis”, prepared by EPS, page 5.)

Permanent Jobs

Development of the Project would increase economic and employment activity in the Central Business District of Sacramento. The Project would include 27.5 net acres of retail and commercial space, which would directly increase employment opportunities.

Construction Jobs

The Project is also expected to create a number of secondary jobs, as implementation of the Project would require construction jobs for the development of the buildings and associated site improvements. Such jobs will provide income and work experience for City residents and other workers and their families.

The revenue generated as a result of t he Project will benefit the City and other governmental agencies, and their resident s and constituencies by providing needed revenue for provision of required services and amenities.

The Project Will Provide Diverse Housing O pportunities in Close Proximity to an Employment Base.

The Project proposes developm ent of approximately 3,473 re sidential units of various housing types, including high, medium and low density units. The Project also provides an age-restricted facility that pr ovides housing for seniors and retirees to satisfy the requirements of the City’s Inclusionary Housing Ordinance (Section 17.190 of the City of Sacramento Zoning Code.) These diverse housing types make the Project ideal for any type of household including couples, small families, single working professionals, seniors and other family groups. The proposed hous ing will be near the 27.5 net acres of retail/restaurant space, including 155,000 square feet of large-format retail uses (including Greenbriar (M05-046 / P05-069) January 22, 2008

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a 10,000 square foot garden cent er), 67,000 square feet of grocery uses, and 66,000 square feet of retail shops on the village and community commercial designated parcels, for a total of 288,000 square feet of commercial services. These commercial uses will provide residents with employment opportunities close to their homes.

In addition, the proposed Project site is located in relatively close proximity to the downtown urban core, which serves as a major employment center in the Sacramento region. The Project’s location and the proposed DNA light rail extension and station adjacent to the Project site will provide a direct connecti on to the downtown core and will allow the Project’s residents to easily access their work sites.

The Project Will Provide Neighborhood and Community Retail Near Residential Development to Shorten or Reduce the Number of Vehicle Trips.

The Project proposes 27.5 net acres of retail/restaurant space, including 155,000 square feet of large-format retail uses (including a 10,000 square foot gar den center), 67,000 square feet of grocery uses , and 66,000 square feet of reta il shops on the village and community commercial designated parcels, for a total of 288,000 square feet of commercial space to serve the residents of the 3,473 dw elling units, as well as existing and future residents within the Natomas area. The retail and restaurant uses will allow residents to avoid having to drive to access common neighborhood-serving retail uses, such as coffee/sandwich shops, bars, hair salons, dry cleaning, small grocery stores, flower shops and office-type services.

The close proximity of the fu ture light rail stop would enc ourage the use of alternative modes of transportation by Project resident s and employees. Project residents utilizing alternative modes of transportation, such as light rail, will reduce the number of vehicle miles traveled per household even further. In turn, the Project will result in shortened commute times, reduced traffic conges tion, lessened dependence on automobiles and reduced pollution from vehicle emissions. Not driving a vehicle one day a week prevents 55 pounds of pollution each year from being emitted into the air. Overall, residents will save on fuel, vehicle maintenance and parking costs by utilizing the easily accessible light rail line.

The Project Will Provide Parks and Open Spaces.

The Project includes several park and open space features, including greenbelt areas along I-5, SR 70/99, and Elkhorn Boulevard, a 250-foot linear open space/buffer along Lone Tree Canal for the protection of giant garter s nake habitat, bike and pedestrian trails located throughout the proposed community, and 48.4 net acres of parks. A 10-acre neighborhood park would be located adjacent to the proposed elementary school in the southeast portion of the site. A total of six smaller park sites (i.e., park sites ranging from 2 to 6 acres) would be located in the eastern half of the project site north and south of Meister Way. A 23-acre community park site would be located in the northeast quadrant of the project site.

The Project’s park spaces will be designed and implemented to facilitate open space locations and linkages that create a vibrant, enjoyable community.

The Project Realizes an Infill Development Opportunity.

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The Project site is located west of the North Natomas community and will locate 3,473 residential dwelling units and 27.5 net acres of restaurant/retail space in an infill opportunity area close to the downtown urban core. The project site is surrounded by development on three sides. Surrounding land uses include agricultural land uses to the north and south, new residential development in the North Natomas community to the east and south, and the recently approved Metro Air Park development project to the west. The Metro Air Park development consists of proposed commercial, hotel, and recreational (i.e., golf course) land uses. The North Natomas Community Pl an (NNCP) area is located adjacent to the eastern boundary of the project site across SR 70/99. Future development in the North Natomas area includes residential and commercial land uses.

The Sacramento Area Council of Governments (SACOG) adopted the Sacramento Region Blueprint Transportation and Land Use Study Preferred Blueprint Scenario (Blueprint) in December 2004. The Blueprint’s preferred land use scenario identifies the Greenbriar site for high density mixed residentia l and single family small lot land uses. Existing North Natomas development to the east across SR 70/99 is designated for single-family large lot and single-family small lot, and the area south of I-5 for single-family large lot, single-family small lot, public, and medium-density mixed-use center or corridor land uses. Undeveloped areas to the north are designated for medium-density and high-density mixed residential land uses with the area to the west designated for industrial land uses.

The City of Sacramento has discretion to determine how it would implement the Blueprint’s smart growth principles in its long-term planning. For areas considered as Urban Reserve (i.e., areas designated for future urban growth beyond a 20-year planning horizon), the City determined that future growth within t he Natomas Area in accordance with SACOG’s Blueprint smart growth principals could result in the development of up to approximately 44,400 housing units, approximately 4 million square feet of commercial space, and 14,600 jobs.

All of the Blueprint’s principles have been applied in the design of the proposed Greenbriar project. The project incorporates diverse housing types (i.e., low density, medium density, high density residential), development would be compact (i.e., maximize used space by providing medium and high density residential land uses on more than half of the site), the area of public open space is greater than required by city regulations (project provides 48.4 acres versus City requirement of 48.2 ac res), and mixed uses (i.e., residential and commercial land uses on one parcel) would be accommodated on the site. In addition, the project would provide a variety of transit opportunities including walking and bicycling, and by planning for a future Downtown-Natomas-Airport light rail extension and station at the project site. Following smart growth principles, the Project shortens future commute times, reduces traffic congestion, lessens dependence on automobiles and provides for housing choices that more closely align with the needs of an aging population. (Letter dated August 27, 2007, from City of Sacramento to Sacramento LAFCo.)

The Project will Provide All Necessary On-s ite Infrastructure and Contribute Fair Share Funding to Upgrade the City’s Infrastructure System.

Installation of necessary on-site infrastructure would be constructed by the Project applicant and/or the applicant w ould contribute its fair shar e of the funding for this Greenbriar (M05-046 / P05-069) January 22, 2008

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infrastructure, resulting in the necessary revenue for the City to fund such improvements.

In addition, the Project applicant will have to pay building and development impact fees that will help fund the costs for off-site infrastructure needed to serve the Project.

The North Natomas Financing Plan under funds identified infrastructure needs by about $70 million. This deficiency is the result of construction costs and standards escalating faster than the adjustment of fees. These def iciencies include library, fire, police, transit and roadway facilities.

The North Natomas Financing Plan funded the land acquisition for the North Natomas Regional Park; however, identified deficiencies are the payment of Habitat Conservation Plan Fees and capital improvements for the Regional Park Greenbriar will contribute approximately $3.35 million to help fund this amount.

The Greenbriar project would include phased expansion and extension of public utility infrastructure from adjacent areas (e.g., NNCP area) to the project site. Infrastructure plans would specify the size and locations of pipe lines necessary to convey potable water, wastewater (including pump and lift stations if necessary), and storm water drainage to and from the project site. In addition, locations for placing electrical infrastructure and natural gas lines would also be identified on the plans.

The main water supply for the project site would be a 30-inch transmission line that would be extended from South Bayou Road (south of the project site) under I-5 (via a jack and bore construction method) to Elkhorn Boulevard. Additional reliability and redundancy in the water distribution system would be provided through a 24-inch transmission line that would be constructed from Natomas Boulevard and Elkhorn Boulevard (east of the project site) to the intersection of Lone Tree Road and Elkhorn Boulevard where it would connect to on- site distribution facilities. The proposed water distribution system would consist of a grid of 8-inch and 12-inch distribution mains throughout areas designated for residential land uses.

An 18-inch transmission main would run under Meister Way from the western edge of the project site to the east; it would then run north between two parcels designated for high density residential land uses (near the eastern boundary), east along the boundary of the site, and would terminate at a 24-inch transmi ssion main located in Elkhorn Boulevard.

Three groundwater wells would be constructed on-site; one to periodically maintain flow in Lone Tree Canal; and two to maintain (if needed) flows within the on-site lake detention basin.

The project also includes the construction of a gravity flow and force main wastewater collection system. Approximately one-quarter of the site would be served by a gravity flow system that would connect to the existing 33-inch North Natomas interceptor located at the terminus of Greg Thatch Circle (immediately east of the project site). The remaining portions of the project site would be served by gravity flow to a centrally located lift station.

Flows from the lift station would be conveyed by a 16-inch sewer force main that would ultimately connect to the 33-inch North Na tomas Interceptor along the northwestern boundary of the property.

Greenbriar will contribute to the North Nato mas Financing Plan to help fund several categories of infrastructure and public facilities. The project will provide $3.35 million for Greenbriar (M05-046 / P05-069) January 22, 2008

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the planned Regional Park. In addition, the project will provide $1.78 million for library facilities, a $1.52 million contribution for the construction of fire facilities, and $2.4 million for police facilities, which includes a $1.5 million 880-MegaHerz radio transmission tower.

The Project also includes dedication of a corridor that could accommodate a future transit stop and light rail alignment for the Downtown-Natomas-Airport (DNA) light rail extension located near the center of the Project site along the proposed Meister Way roadway. The light rail station would provide public tr ansportation access to downtown Sacramento, Sacramento International Airport and Metro Air Park. The transit st ation is currently estimated at $2.4 million. RT will also be provided with the right-of-way over the Project site at no cost.

Finally, the Greenbriar project will provide $1.65 million for the improvements to the Elkhorn interchange. (Letter dated August 27, 2007, from City of Sacram ento to Sacramento LAFCo.)

The Project is Consistent with and Promotes the City’s Adopted Planning and Land Use Goals.

The City is currently updating the General Plan and the City Council has adopted a vision for the future of the City, as well as several guiding principles to help guide the update and achieve this vision. The Project meets the City’s guiding principles and existing General Plan goals, policies and objectives, which include the following:

General Plan Update Vision

Promote the reuse and revitalization of existing developed areas, with special emphasis on commercial and industrial district.

Promote economic vitality and diversification of the local economy.

General Plan Goals and Policies

. . . provide continued support of private and public efforts that promote the Central City’s role as the region’s commercial office, employment, and cultural center. . .. (Sec. 1-33)

Promote the re-use and revitalization of existing developed areas, with special emphasis on commercial and industrial districts. (Sec. 4-1)

Encourage mixed use developments to generate greater pedestrian activity. (Sec 5-22) Greenbriar (M05-046 / P05-069) January 22, 2008

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EXHIBIT B – MITIGATION MONITORING PLAN

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ATTACHMENT 3 - RESOLUTION AMENDING RESOLUTION 2001-518

RESOLUTION NO.

Adopted by the Sacramento City Council

A RESOLUTION AUTHORIZING THE SEPARATE PROCESSING AND APPROVAL

OF ENTITLEMENTS FOR THE GREENBRIAR PROJECT, NOTWITHSTANDING CITY RESOLUTION NO. 2001-518

BACKGROUND

A. On July 24, 2001, the City Counc il approved Resolution No. 2001-518 to temporarily establish restrictions on the approval of entitlements on three properties outside of the City of Sacramento (Camino Norte, West Lakeside, and Greenbriar Farms).

B. Resolution No. 2001-518 was enacted pur suant to the “Agreement to Settle Litigation By and Between National Wildlife Federation, Environmental Council of Sacramento, Friends of the Swainson’s Hawk, Mountain Lion Foundation, Planning and Conservation League and the Sierra Club, the City of Sacramento, Natomas Estates LLC and Kern Schumacher. This Settlement Agreement arose out a lawsuit filed in the U.S. District Court for the Eastern District of California under the federal Endangered Species Act (FESA) as well as National Environmental Policy Act (NEPA) and Section 706 of the Federal Administrative Procedure Act, 5 U.S.C. Sec. 706. The primary challenge of the lawsuit was to the adequacy of the Natomas Basin Habitat Conservation Plan (HBHCP) and the adequacy of the environmental review undertaken for that plan.

C. The Settlement Agreement followed a decis ion by the district court granting the Plaintiff’s motion for summary judgment on four counts under the FESA and one count under NEPA. Thereafter, the U.S. Fish and Wildlife Service and the City, along with other public entities, initiated efforts to revise the NBHCP and to undertake further environmental review. Pursuant to the Settlement Agreement, a limited amount of development was allowed to occur in the Permit Area covered by the NBHCP, pending completion of the Revised NBHCP and issuance of a new Incidental Take Permit (ITP). The right to engage in the limited amount of development was conditioned upon compliance with certain measures, including the City’s adoption of Resolution No. 2001-518.

D. Following adoption of Re solution No. 2001-518, the City, Sutter County and The Natomas Basin Conservancy (TNBC) prepared a revised NBHCP (“2003 NBHCP”) that was reviewed and approved by the U.S. Fish & Wildlife Service Greenbriar (M05-046 / P05-069) January 22, 2008

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and California Department of Fish & Game (the “Wildlife Agencies”), Subsequent to the adoption of Resolution No. 2001-518, a revised NBHCP was reviewed and approved, following additional environmental review under CEQA and NEPA, and a new ITP was issued. The Wildlife Agencies and Permittees entered into an Implementation Agreement and issued new ITPs to the City, Sutter County and TNBC. These decisions were challenged in federal and state courts, and these decisions were upheld, and the challenges rejected.

E. With respect to future development in the Natomas Basin outside of the City and Sutter’s respective Permit Areas as defined in the 2003 NBHCP (“Future Urban Development”), Section 3.1.1 of the 2003 NBHCP Implementation Agreement (“IA”) provides, in part, that “CITY and SUTTER further agree that in the event this 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 CITY’s or SUTTER’s Permits in the event the CITY or SUTTER violate such limitations. ”By
its terms, the Settlement Agreement expired on October 1, 2002, provided that certain obligations (the City’s obligation to Acquire Mitigation Lands and its obligation to establish the Mitigation Cushion) survived the expiration of the Settlement Agreement and the issuance of the Revised NBHCP and the related HCP.

F. By its terms, the Settlement Agreem ent expired on October 1, 2002, provided that certain obligations (the City’s obligation to Acquire Mitigation Lands and its obligation to establish the Mitigation Cushion) survived the expiration of the Settlement Agreement and the approval of the Revised NBHCP and the issuance of the related ITP to the City.

BASED ON THE FACTS SET FORTH IN THE BACKGROUND, THE CITY COUNCIL RESOLVES AS FOLLOWS:

Section 1. The City Council of the City of Sacramento rescinds Resolution No. 2001- 518 to the extent that it restricts or prohibits the City from approving separately the first stage entitlements for the Greenbriar project. The provisions of Resolution No. 2001-518 shall remain in effect as to other properties within the Joint Vision area.

Section 2. The City acknowledges and agrees that prior to approval of any related rezoning or prezoning by the City for Future Urban Development, the City will conduct a reevaluation of the Natomas Basin HCP and incidental take permits, and prepare a new effects analysis pursuant to the 2003 Revised

Susana Alcala Wood, City Attorney Jorge Oseguera, City Auditor Mindy Cuppy, City Clerk Howard Chan, City Manager John Colville, City Treasurer City Council Report
915 I Street, 1st Floor
Sacramento, CA 95814
www.cityofsacramento.org

File ID: 2021-00731 June 29, 2021 Consent Item 09

Title: City-Sacramento LAFCo Memorandum of Understanding (MOU) for the Processing of the Airport South Industrial Project

Location: Unincorporated Natomas area south of I-5, extending from Powerline Road on the west to the City of Sacramento city limits on the east, and south to the West Drainage Canal.

Recommendation: Adopt a Resolution authorizing the City Manager or City Manager’s designee to sign a Memorandum of Understanding (MOU) between the City of Sacramento and Sacramento Local Agency Formation Commission (LAFCo) for the coordinated environmental review and preparation of a single environmental document for processing the Sphere of Influence (SOI) amendment and annexation.

Contact: Cheryle Hodge, Principal Planner, (916) 808-5971, Community Development Department

Presenter: None.

Attachments:
1-Description/Analysis
2-City of Sacramento Sphere of Influence Map
3-Resolution
4-Exhibit A – Project Location Map
5-Memorandum of Understanding
6-LAFCo Staff Report May 5, 2021

Page 1 of 50 ends

File ID: 2021-00731 Consent Item 09
June 29, 2021
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City of Sacramento

Description/Analysis

Issue Detail: This report requests authorization of a City–LAFCo Memorandum of Understanding (MOU) for the preparation of an Environmental Impact Report for the sequential processing of an Sphere of Influence (SOI) amendment and annexation of the Airport South Industrial project. Cities are able to establish planning areas for property located outside its jurisdictional boundaries and outside its SOI. However, any entitlements granted have no land use authority until such area is annexed. Annexation of an area may not occur until it is within the City’s SOI. Concurrent processing of a Sphere of Influence change and an annexation is generally not allowed under Sacramento LAFCo policies unless certain factors are present. This is not a concurrent process, in that each step of the LAFCo and City consideration will be conducted sequentially. The LAFCo has the discretion to amend or deny any SOI proposal and any subsequent annexation proposal. The City-LAFCo MOU is intended to set forth the process and steps for preparation of a single environmental review consistent with the California Environmental Quality Act (CEQA). LAFCo and the City would serve as co-Lead Agencies for CEQA purposes with LAFCo as lead agency for the SOI amendment and the City of Sacramento as lead agency for related pre-zoning/annexation for the Airport south Industrial Project.

Policy Considerations: Staff feels the collaborative relationship with LAFCo staff defined by the City-LAFCo MOU (Attachment 4 – MOU) will result in an efficient processing of the Airport South Industrial project environmental review. The City’s existing 2035 General Plan adopted by the City Council on March 3, 2015, contains numerous policies that are relative to the City’s SOI and annexations. The following are key policies:

LU 1.1.8 Annexation Prior to City Services. Prior to the provision of City services to unincorporated areas, the City shall require those unincorporated properties be annexed into the City, or that a conditional service agreement be executed agreeing to annex when deemed appropriate by the City.

LU 1.1.9 New Growth. The City shall continue to plan for future expansion and new growth in Special Study Areas to ensure that regional growth is adequately accommodated and served by the City, particularly when it cannot be absorbed in infill areas.

LU 10.1.2 Comprehensive Planning for Special Study Areas. The City shall require that Special Study Areas be planned comprehensively prior to annexation and development, and subject to the following processes:

■ Amendment of the General Plan, including completion
of a new Community Plan chapter where applicable.

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File ID: 2021-00731 Consent Item 09
June 29, 2021
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City of Sacramento

■ Approval of a Sphere of Influence amendment by the
LAFCo prior to annexation request where applicable.
(Sacramento LAFCo local policies discourage
concurrent Sphere of Influence Amendment and
Annexation).

■ Completion and adoption of Master Plans, Specific
Plans, pre-zoning, and Development Agreements,
as appropriate, in order to establish the timing,
phasing, costs, and responsible parties associated with development in the area to be annexed.

LU 10.1.3 Regional and Community Benefits. The City shall require that regional and community benefits are achieved as the result of annexations and development approvals in any Special Study Area or Planned Development Area, consistent with the goals and policies outlined in this Plan. Examples include, but are not limited to, the following:

■ A mix of land uses that results in a full range of jobs, housing, amenities, services, and open space, resulting in complete neighborhoods and dynamic centers that
have strong linkages with the city and region.

■ Transportation systems, including transit and roadways that are substantially improved and expanded, in a
manner that provides enhanced mobility for all sectors
of the community and benefits regional air quality.

■ Sustainable infrastructure and community facilities,
where adequate land is provided for such facilities, and construction and ongoing maintenance are funded by
proposed development.

■ Conservation of open space, including important
agricultural lands, sensitive habitat areas and wildlife corridors, and other non-urbanized areas that serve as
buffers or “greenbelts” for public use.

Economic Impacts: Not applicable.

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File ID: 2021-00731 Consent Item 09
June 29, 2021
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City of Sacramento

Environmental Considerations: This is a governmental coordination and administrative and fiscal activity that will not result in direct or indirect change in the environment, and it does not commit the City to any project approvals, and it is therefore exempt from the California Environmental Quality Act (CEQA). (CEQA Guidelines, §§ 15378 (b)(4) and (5); 15352; 15004.)The potential environmental issues related to the processing of the Airport South Industrial project will be evaluated in the environmental document, such as an Environmental Impact Report (EIR). The EIR process will include a full opportunity for review and comment by the public and would be completed in compliance with the requirements ofCEQA .

Sustainability: Not Applicable. Sustainability will be evaluated during the environmental analysis and review process.

Commission/Committee Action: On May 5, 2021, the Local Agency Formation Commission authorized the LAFCo Executive Officer to work with City staff in preparing a Memorandum of Understanding with the City of Sacramento setting forth the roles, responsibilities, terms and conditions for a collaborative co-lead agency status in the preparation of an Environmental Impact Report for the Airport South Industrial project.

Rationale for Recommendation: The recommended action will allow for the City of Sacramento and LAFCo to serve as co-lead agencies for the preparation of a single environmental document that will fully address the proposed Sphere of Influence Amendment, all City land use entitlements (i.e. prezoning and related requests) and the proposed Reorganization (annexations and related detachments). Serving as co-lead agencies for preparation of a coordinated environmental review process will provide for efficient use of staff resources and could avoid redundancy in the environmental review process by two agencies (City and LAFCo).

Financial Considerations: The project applicant will pay all costs associated with the Airport South Industrial project applications filed with the City of Sacramento and LAFCo.

Local Business Enterprise (LBE): Not applicable.

Background: On December 10, 2002, the City Council and the Board of Supervisors approved a MOU regarding principles of land use and revenue sharing for the Natomas area.

This has come to be known as the Joint Vision for Natomas. The City-County MOU identifies the City of Sacramento as the appropriate agency for development within the Natomas Joint Vision Area.

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File ID: 2021-00731 Consent Item 09
June 29, 2021
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City of Sacramento

In May 2021, the City of Sacramento received a landowner application to process an annexation and land use entitlements for approximately 450 acres referred to as the Airport South Industrial project (Attachment 4 – Location Map). The Airport South Industrial project area is located west of the City limits and south of I-5.

The Airport South Industrial’s proposed development, subject to environmental analyses and entitlement approvals, includes a mix of employment activities and industrial uses. No residential uses are proposed.

The project applicant desires to have a single EIR prepared for the Airport South Industrial project. The applicant, City staff and LAFCo staff feel that this is a cost-effective approach and may result in time savings. The single environmental document would fully address the proposed Sphere of Influence Amendment, all City land use entitlements (i.e. prezoning and related requests) and the proposed Reorganization (annexations and related detachments) and could avoid redundancy in the environmental review process by two agencies (City and LAFCo). The MOU would memorialize the understanding between the City and LAFCo regarding roles and responsibilities in preparing a single environmental document.

On May 5, 2021, the Local Agency Formation Commission authorized the LAFCo Executive Officer to sign a Memorandum of Understanding with the City of Sacramento setting forth the roles, responsibilities, terms and conditions for a collaborative co-lead agency status in the preparation of an Environmental Impact Report for the Airport South Industrial project. On May 24, 2021 the project applicant submitted an application to LAFCo for the proposed Sphere of Influence Amendment. submitted an application to LAFCo for the proposed Sphere of Influence Amendment. City staff and LAFCo staff have been closely working together to prepare a Draft MOU (Attachment 3-Draft City-Sacramento LAFCo MOU) which staff feels is mutually acceptable and is new ready to be considered by the City Council and LAFCo.

Sphere of Influence Amendment and Annexation:

A "Sphere of Influence" is a plan for the probable ultimate physical boundaries and service area of a local governmental agency, as determined by LAFCo. The Airport South Industrial project site is located outside of the City’s existing Sphere of Influence and adjacent to City limits.

LAFCo policies require that unincorporated lands be in the City’s sphere prior to an annexation.

The project application has been made on behalf of Angelo K Tasakopoulos Holdings (AKT), with the consent of additional landowners, i.e., JTS Engineering Consultants Inc. and Cayocca family. The project applicant has requested the annexation of the Airport South Industrial project area to the City of Sacramento. The annexation will require LAFCo approval of the SOI amendment prior to any actions taken on the annexation.

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File ID: 2021-00731 Consent Item 09
June 29, 2021
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City of Sacramento

Natomas Basin Habitat Conservation Plan
On May 13, 2003, the City Council by Resolution 2003-290, adopted the Final Natomas Basin Habitat Conservation Plan (NBHCP) and NBHCP Implementation Agreement. The City of Sacramento, Sutter County, U.S. Fish and Wildlife Service, California Department of Fish and Wildlife and The Natomas Basin Conservancy (“Conservancy”) are all signatory parties to the NBHCP. Sacramento County is not a signatory party to the NBHCP. To date, the Conservancy has acquired approximately 4,600 acres of land in compliance with the NBHCP.

The Airport South Industrial Project area is located within Natomas Basin. A portion of the Airport South Industrial area consisting of approximately 121 acres is located in City’s NBHCP area and would have coverage under the NBHCP upon annexation into the City limits. The project will be evaluated relative to the NBHCP as part of the environmental review process.

North Natomas Community Plan
The Airport South Industrial project area is approximately 450 acres in size. A portion of the project site consisting of approximately 121 acres is located within the boundaries of the North Natomas Community Plan. The project will be evaluated relative the North Natomas Community Plan as part of the environmental review process.

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RESOLUTION NO. 2021-

Adopted by the Sacramento City Council

June 29, 2021

Resolution Authorizing the City Manager or City Manager’s Designee to Sign a Memorandum of Understanding (MOU) between the City of Sacramento and Sacramento Local Agency Formation Commission (LAFCo) for Preparation of an Environmental Impact Report for a Sequential Sphere of Influence (SOI) Amendment and Annexation of the Airport South Industrial Project

BACKGROUND

A. On December 10, 2002, the Sacramento City Council and the Sacramento County Board of Supervisors approved the Memorandum of Understanding (MOU) regarding principles of land use and revenue sharing for the Natomas area. This has come to be known as the “Joint Vision for Natomas”.

B. The City-County MOU identifies the City of Sacramento as the lead agency for development within the Natomas Joint Vision Area.

C. In June 2021, the City of Sacramento received a landowner application to process the Airport South Industrial Project entitlements for approximately 450 acres. The project site is located immediately south of I-5, extending from Powerline Road on the west to the City of Sacramento city limits on the east and south to the West Drainage Canal.

The project site is south of Metro Air Park (and the new Metro Air Parkway/I-5 interchange) and southwest of the City of Sacramento Greenbriar development project (now known as Northlake), which is currently under construction and east of the existing Westlake community.

D. The applicant desires to have a single EIR prepared for the Airport South Industrial project. The applicant, City staff and LAFCo staff feel that this is a cost-effective approach and may result in time savings.

E. On May 5, 2021, the Local Agency Formation Commission (LAFCo) authorized the LAFCo Executive Officer to work with City staff in the preparation of a Memorandum of Understanding (MOU) with the City of Sacramento setting forth terms and conditions for a collaborative co-lead agency status in the preparation of an Environmental Impact Report for the Airport South Industrial project.

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F. The terms and conditions are defined in the attached City-LAFCo MOU based upon the following proposed principles adopted by LAFCo at the May 5, 2021 commission meeting:

1. The MOU will address only the proposed “Airport South Industrial Area” proposal (Exhibit A).

2. An application, with deposit, will be submitted to LAFCo by AKT Investments, Inc. (AKT.) The application material will be consistent with LAFCo requirements and the submittal will be provided prior to any Commission staff resources being expended, consistent with this MOU.

3. Applicant (AKT) will submit a signed Agreement to Pay form for all project processing costs, (https://saclafco.saccounty.net/Pages/forms.aspx ).

4. City of Sacramento City Council will execute the MOU prior to or concurrently with the final consideration of the MOU by Sacramento LAFCo.

5. The Commission will be kept apprised of all areas of special consideration or conflict identified during the preparation of the MOU and EIR.

6. LAFCo and City are responsible for the scoping and drafting of the EIR.

7. LAFCo will retain the authority to certify the Draft EIR as to the SOI Amendment issues.

8. LAFCo will retain the authority to adopt independent mitigation measures independently review all LAFCo related issues of the proposed SOI Amendment and Reorganization (Annexation and Detachments) environmental impacts.

9. LAFCo and the City are not waiving any rights with respect to their lead agency status, nor statutorily discretionary authority.

10. LAFCo will act first in time to consider the SOI amendment and the EIR prior to action by the City of Sacramento.

BASED ON THE FACTS SET FORTH IN THE BACKGROUND, THE CITY COUNCIL RESOLVES AS FOLLOWS:

Section 1. The City Council of the City of Sacramento hereby authorizes the City Manager to enter into a Memorandum of Understanding with Sacramento LAFCo for preparation of an Environmental Impact Report for a sequential Sphere of

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Influence amendment and annexation of the project known as Airport South Industrial project consistent with the principles stated in paragraph F, above.

Table of Contents:

Exhibit A: Airport South Industrial Project Location Map

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Attachment 4
Exhibit A
Project Location Map

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Airport South Industrial Project June ___, 2021
1 Memorandum of Understanding between the
Sacramento Local Agency Formation Commission and the City of Sacramento Relating to the Preparation of a Coordinated Environmental Review Process for the Airport South Industrial Project and Establishment of Co-Lead Agencies for the purpose thereto

A. Recitals

1. The CITY OF SACRAMENTO is a California municipal corporation and charter city (the “City”), and the SACRAMENTO LOCAL AGENCY FORMATION COMMISSION (“LAFCo”), is an independent, county-wide agency, pursuant to the Cortese-Knox-Hertzberg Act of 2000, which can be found at California Government Code § 56000, et. seq.

2. The City and LAFCo desire a Memorandum of Understanding that outlines the steps for preparation of a coordinated environmental review process, which may include preparation of an Environmental Impact Report regarding a Sphere of Influence Amendment, and related subsequent reorganization Annexation and detachments) for the Airport South Industrial Project and related actions.

3. The affected territory is comprised of approximately 450 acres located immediately south of I-5, extending from Powerline Road on the west to the City of Sacramento city limits on the east and south to the West Drainage Canal. The project site is south of Metro Air Park (and the new Metro Air Parkway/I-5 interchange) and southwest of the City of Sacramento Greenbriar development project (now known as Northlake), which is currently under construction and east of the existing Westlake community. City roads, water, sewer, and drainage are all located immediately adjacent to the Airport South Industrial area.

4. The development proposal is comprised of a General Plan Amendment, Prezoning, Master Tentative Parcel Map, Planned Unit Development, Development Agreement and Public Facilities Financing Plan. In addition, the proposed development would require the City to apply to LAFCo for a Sphere of Influence Boundary Amendment (including a related Municipal Services Review) and Reorganization (annexation and related detachments).

5. Taken together these applications would comprise a “project” within the meaning of and subject to the California Environmental Quality Act (Pub. Res. Code, § 21000 et seq.) (CEQA) for which an environmental review will be conducted, to

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Airport South Industrial Project June ___, 2021
2 determine the appropriate level of environmental review. This is referred to collectively in this Memorandum of Understanding as the Airport South Industrial Project.

6. LAFCo is the appropriate Lead Agency for the proposed Sphere of Influence Boundary Amendment(s). (Gov. Code, § 56425 subd. (a); Pub. Res. Code, § 21067; LAFCo Policies, IV.F.1, p. IV-7.) LAFCo will require that the EIR adequately address all environmental issues associated with LAFCo proceedings related to this application. The City is the appropriate Lead Agency for the remaining elements of the proposed Airport South Industrial Project and will require that the environmental document adequately address the environmental issues associated with applications related to all land use entitlements and reorganization requests, except the Sphere of Influence Amendment. (14 Cal. Code Regs., § 15051 subd. (b)(2); LAFCo Policies, § IV F.1.d... p. IV-7.)

7. The City and LAFCO desire to have a single EIR prepared for the Airport South Industrial Project. LAFCo will consider the adequacy of the necessary LAFCo related CEQA analysis in a single EIR. The City and LAFCo will cooperate in the CEQA review process. It is the intent of this MOU to support the completion of the most efficient CEQA review process, in a mutually acceptable manner.

8. A Lead Agency may comply with CEQA by adopting EIR materials provided by an applicant or an applicant’s consultant so long as the Lead Agency independently reviews, evaluates, and exercises its independent judgment over the documents and the issues they raise and address. (14 Cal. Code Regs., § 15084 subd. (d) and (e); Friends of La Vina v. County of Los Angeles (1991) 232 Cal App 3rd 1446 (disapproved on other grounds in Western States Petroleum v Superior Court (1991) 9 Cal.4th 559, 570 fn. 2, 576 fn. 6); San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal App4th 656); Eureka Citizens for Responsible Government v.

City of Eureka (2007) 147 Cal.App.4th 357, 369

9. City and LAFCo enter into this Memorandum of Understanding to establish themselves as Co-Lead Agencies for the Airport South Industrial Project and to establish their respective roles and responsibilities relating to the oversight and management of the preparation of the necessary CEQA analysis, findings, and mitigation measures. The purpose of this Memorandum of Understanding is to ensure that the resulting Airport South Industrial Project EIR adequately addresses the environmental issues of the Airport South Industrial Project as a whole and provides both LAFCo and the City with the information each needs to review, consider, and act on the Airport South Industrial Project applications in full compliance with the law.

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Airport South Industrial Project June ___, 2021
3 B. Determinations

LAFCo and the City agree to the following:

1. LAFCo and the City may allow the Airport South Industrial Project applicant to select and contract directly with a consultant chosen from a list of qualified consultants, as contained in the “Consultant List” mutually agreed to by LAFCo and City; to prepare the necessary CEQA analysis, findings, and mitigation measures on the Project. The environmental document must include the environmental review of all of the following: the Sphere of Influence Amendment, General Plan amendment, Prezoning, Master Tentative Parcel Map, Development Agreement, Reorganization (annexation and detachments), Planned Unit Development approval and any related issues identified by LAFCo relating to the requirements of the Cortese-Knox-Hertzberg Act. Prior to any commencement of work by such a consultant, the scope of work must be reviewed and approved by responsible staff of each agency. The scope of work must include description of responsibility for preparation of the CEQA Findings of Fact, Statement of Overriding Considerations, if required, and for preparation and circulation of the various documents required by the CEQA process (e.g., Notice of Determination).

2. The City and LAFCo shall cooperate and work collaboratively to ensure that the necessary CEQA analysis, findings, and mitigation measures fully satisfies LAFCo’s requirements for conducting a legally adequate environmental review of the Sphere of Influence Amendment in accordance with CEQA, the CEQA Guidelines, the Cortese-Knox-Hertzberg Local Governmental Reorganization Act of 2000 (Gov. Code §56000 et seq.), and LAFCo’s locally adopted Policies, Standards and Procedures. The following protocols for preparation of the EIR apply:

2.1. The City, through its staff, shall be the primary contact point for the applicant’s CEQA consultant for purposes of generally directing the work of preparing the necessary CEQA analysis, findings, and mitigation measures; transmitting, receiving, and disseminating reports, studies, drafts, and other documents related to the EIR; transmitting, receiving, and responding to questions, comments, requests for clarification or additional information; scheduling meetings; and the like.

2.2. LAFCo, through its Commission staff, and independent consultants, shall have final oversight, review, and approval authority over the content of the environmental document (i.e., administrative draft EIR (ADEIR), the draft EIR (DEIR), and the final EIR (FEIR)) as they each relate to the Sphere of Influence Amendment and shall have Responsible Agency review over the Reorganization (annexation and related detachments). The City, through its staff, shall coordinate and work cooperatively and collaboratively with LAFCo to ensure that LAFCo has sufficient

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Airport South Industrial Project June ___, 2021
4 and meaningful opportunity to review, evaluate, and exercise its independent judgment over the content of the EIR as it relates to the Sphere of Influence Boundary Amendment and as a responsible agency over the Reorganization (annexation and related detachments). To this end, LAFCo shall retain the right to approve all studies, reports, drafts, and other documents prepared for or in connection with the environmental document before public release, to edit or request changes to the environmental document (i.e., ADEIR, DEIR, and FEIR), to review and recommend responses to comments submitted on the DEIR, and to request additional work as LAFCo, in the exercise of reasonable judgment and discretion, determines to be necessary to ensure the adequacy and objectivity of the environmental document as needed for LAFCo’s action as lead agency for the Sphere of Influence Amendment and as responsible agency for the Reorganization (annexation and related detachments).

The City and LAFCo shall mutually copy (“cc”) one another with their CEQA related correspondence (if any) to the CEQA consultant, except those related to solely to contract and billing issues. LAFCo shall receive fair and adequate notice, (not less than 72 hours) and reserve the opportunity to attend all meetings with the environmental consultant.

2.3. City and LAFCo shall each identify and notify the other of their respective staff contacts responsible for implementing this MOU. Staff contacts are as follows:

LAFCo
Executive Officer
(Address/Phone/email)

City of Sacramento
Cheryle Hodge, New Growth Manager
(Address/Phone/email)

2.4 City and LAFCo staffs shall hold regular status meetings, at a mutually agreed to time and location, to discuss the progress of the work in conformance with the agreed upon schedule.

2.5. LAFCo shall schedule and hold at least one public hearing during the DEIR public review and comment period to receive comments on and proposed revisions to the DEIR.

3. City and LAFCo agree that the Project Applicant shall be fully and solely responsible for the costs of the environmental consultant and for the costs incurred by LAFCo for retaining its independent environmental consultant as well as its normal processing fees, including, but not limited to, consultant fees, staff time, and legal review.

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Airport South Industrial Project June ___, 2021
5 4. City and LAFCo shall use all reasonable effort and due diligence to process the Project through to the final hearings in a timely fashion to meet City’s objective of having LAFCo set for public hearing the SOIA prior to City Council consideration of related entitlements. City and LAFCo agree to work cooperatively with each other, and the project applicant and/or environmental consultants as necessary to develop a project schedule listing key steps and dates to aid in achieving City’s objectives, which schedule shall be attached to and become a part of this Memorandum of Understanding.

5. The following is a sequence of actions to be taken to complete processing of the Airport South Industrial Project subject to all LAFCo and City criteria:

5.1. Project scoping, environmental document preparation and circulation (i.e., NOP, ADEIR and DEIR) thru Completion of the final environmental document and submittal to LAFCo.

5.2. LAFCo public hearing(s) and exercise of discretionary action on certification of the final environmental document and Sphere of Influence Amendment.

5.3. If the Sphere of Influence Amendment(s) are approved, a City public hearing and action on the General Plan Amendment, Prezone, Master Tentative Parcel Map, Planned Unit
Development, Development Agreement and LAFCo filing of a Reorganization (detachments and related annexation) will follow.

5.4. If the City approves the items in subsection 5.3 above, a LAFCo hearing and action on the Reorganization (annexation and related detachments) will follow.

Nothing contained in this Memorandum of Understanding is intended, nor shall it be construed, to commit, control, or influence in any manner whatsoever the authority, judgment, or discretion of the LAFCo Commission or the City Council of the City of Sacramento in their respective future hearings on all or any aspect of the Airport South Industrial Project and the ultimate decision of each to approve, modify and approve, approve with conditions, or disapprove the Airport South Industrial Project, in whole or in part, or to require or impose mitigation measures as a result of the environmental review of the Airport South Industrial Project.

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Airport South Industrial Project June ___, 2021
6 This Memorandum of Understanding is entered into as of ________, 2021.

By________________ By________________
Howard Chan, City Manager Don Lockhart, Executive Officer City of Sacramento Sacramento Local Agency
Formation Commission

Approved as to form: Approved as to form:

By________________ By________________
City Attorney Sacramento LAFCo Counsel

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Airport South Industrial Project June ___, 2021
7 Airport South Industrial Project Preliminary Schedule

May 16, 2021 Airport South Industrial Project Applicant submits application to Sacramento LAFCo and the City of
Sacramento

June 29, 2021 City Council action on MOU for CEQA co-Lead Agencies

________, 2021 LAFCo action on MOU for City & County to serve as co- Lead Agencies for CEQA purposes for the Airport South
Industrial Project

September 27, 2021 Notice of Preparation (NOP) is made available for a 30-day public review period

October 4, 2021 NOP Public Scoping Meeting is held

October 26, 2021 NOP 30-Day Public Review Period Concluded

December 13, 2021 Administrative Draft Environmental Impact Report is released

January 13, 2022 City, LAFCo and applicant comments are delivered to Environmental Impact Report preparer

March 1, 2022 Draft Environmental Impact Report is released and distributed for a 45-day public review period

April 15, 2022 Draft Environmental Impact Report public comment period closes

May 16, 2022 Administrative Final Environmental Impact Report and Mitigation Monitoring Plan is released

May 31, 2022 City, LAFCo and applicant comments are delivered to Environmental Impact Report preparer

June 30, 2022 Final Environmental Impact Report and Mitigation Monitoring Plan is released and distributed

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Airport South Industrial Project June ___, 2021
8 August 3, 2022 Sacramento LAFCo hearing on Sphere of Influence amendment, certification of the Final Environmental
Impact Report and acceptance of the Municipal Services
Review

August 4, 2022 City of Sacramento Planning and Design Commission hearing on the Final Environmental Impact Report,
General Plan Amendment, Pre-zone, Planned Unit
Development Establishment, Tentative Master Parcel Map, Development Agreement, Annexation, and any other
necessary items as determined by City staff

August 16, 2022 Sacramento City Council hearing on the Final Environmental Impact Report, General Plan Amendment,
Pre-zone, Planned Unit Development Establishment,
Development Agreement, Annexation, and any other
necessary items as determined by City staff

September 7, 2022 Sacramento LAFCo hearing on the Reorganization (Detachments & Annexation)

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From: Sacramento Citizens
To: Clerk of the Board Public Email
Subject: Comment Letter: L AFCo No. M03-21 Airport South Industrial Project Date: Tuesday, May 4, 2021 5:34:06 PM
Attachments: LAFCo SCED Comment Letter - Copy.pdf
EXTERNAL EMAIL: If unknown sender, do not click links/attachments.

Hello,
A comment letter is attached for Item
No. 6 on LAFCo's agenda for its May 5, 2021 meeting
(LAFCo No. M03-21 Airport South Industrial Project). We kindly request the letter be distributed to the Commissioners in advance of the meeting.

Sincerely,
Sacramento Citizens for Equitable Development
ITEM LAFCo PUBLIC COMMENT 001

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Aeroecology: probing and modelling the aerosphere
Thomas H. Kunz, 1,* Sidney A. Gauthreaux Jr, † Nickolay I. Hristov,* ,# Jason W . Horn,* Gareth Jones, ‡ Elisabeth K. V . Kalko,§ Ronald P . Larkin,/C244Gary F . McCracken,k Sharon M. Swartz, # Robert B. Srygley,** Robert Dudley, †† John K. Westbrook ‡‡ and Martin Wikelski §§ /C3 Center for Ecology and Conservation Biology, Department of Biology, Boston University, Boston, MA 02215, USA; †Department of Biological Sciences, Clemson University, Clemson, SC 29634, USA; ‡School of Biological Sciences, University of Bristol, Woodland Road, Bristol BS8 1UG, UK; §Department of Experimental Ecology, University of Ulm, Albert-Einstein-Allee 11, 89069, Ulm, Germany; /C244Illinois Natural History Survey, 607 East Peabody Drive, Champaign, IL 61820, USA; kDepartment of Ecology and Evolutionary Biology, University of Tennessee, Knoxville, TN 37996-1610, USA; #Department of Ecology and Evolutionary Biology, Brown University, Providence, RI 02912, USA; /C3/C3 USDA-ARS, 1500 N.

Central Avenue, Sidney, MT 59270, USA; ††Department of Integrative Biology, University of California, Berkeley, CA 94720, USA; ‡‡USDA-ARS, 2771 F&B Road, College Station, TX 77845, USA and §§Department of Ecology and Evolutionary Biology, Princeton University, Princeton NJ 08544, USA Synopsis Aeroecology is a discipline that embraces and integrates the domains of atmospheric science, ecology, earth science, geography, computer science, computational biology, and engineering. The unifying concept that underlies this emerging discipline is its focus on the planetary boundary layer, or aerosphere, and the myriad of organisms that, in large part, depend upon this environment for their existence. The aerosphere influences both daily and seasonal movements of organisms, and its effects have both short- and long-term consequences for species that use this environment. The biotic interactions and physical conditions in the aerosphere represent important selection pressures that influence traits such as size and shape of organisms, which in turn facilitate both passive and active displacements. The aerosphere also influences the evolution of behavioral, sensory, metabolic, and respiratory functions of organisms in a myriad of ways.

In contrast to organisms that depend strictly on terrestrial or aquatic existence, those that routinely use the aerosphere are almost immediately influenced by changing atmospheric conditions (e.g., winds, air density, precipitation, air temperature), sunlight, polarized light, moon light, and geomagnetic and gravitational forces. The aerosphere has direct and indirect effects on organisms, which often are more strongly influenced than those that spend significant amounts of time on land or in water. Future advances in aeroecology will be made when research conducted by biologists is more fully integrated across temporal and spatial scales in concert with advances made by atmospheric scientists and mathematical modelers. Ultimately, understanding how organisms such as arthropods, birds, and bats aloft are influenced by a dynamic aerosphere will be of importance for assessing, and maintaining ecosystem health, human health, and biodiversity.

Introduction
The biosphere has been traditionally viewed as being
composed of the lithosphere, hydrosphere and atmo-
sphere, each of which interact dynamically with the
other. In an ecological context, the Earth’s lower
atmosphere or troposphere has long been considered
an important functional component of the biosphere
through the exchange of nutrients, water, and gases
in the form of local, regional, and global climate
variation and biogeochemical cycles. However, to our
knowledge, the aerosphere—the relatively thin sub-
stratum of the troposphere closest to the Earth’s surface that supports life–has rarely been considered beyond
studies of meteorological conditions and functional
ecosystem relationships, such as nutrient cycling
and gas exchanges in the atmosphere (Oke 1987,
Sorbjan 1989, National Research Council 1997). Until
quite recently, ecologists with interests in organisms
that depend on the aerosphere as a fluid medium for
movement (e.g., dispersal, foraging, and migration),
a source of food and nutrients, and ever-changing
physical conditions (e.g., weather and air pollution),
have worked more or less independently of atmo-
spheric scientists. Research goals of organismal biolo- gists who study airborne organisms have mostly
focused on the behavior, ecology, and evolution of
specific taxonomic groups (e.g., microbes, arthropods,
From the symposium ‘‘Aeroecology: Probing and Modeling the Aerosphere—The Next Frontier’’ presented at the annual meeting of the Society for Integrative and Comparative Biology, January 2–6, 2008, at San Antonio, Texas. 1E-mail: [email protected]
1 Integrative and Comparative Biology , pp. 1–11
doi:10.1093/icb/icn037
/C223The Author 2008. Published by Oxford University Press on behalf of the Society for Integrative and Comparative Biology. All rights reserved.

For permissions please email: [email protected].

Integrative and Comparative Biology Advance Access published May 21, 2008 birds, and bats), or specific physiological or behavioral functions such as thermoregulation, water balance,
respiration, or flight. In contrast, research goals of
atmospheric scientists and engineers have largely
emphasized how severe weather and climate can
affect human well-being, and thus have focused on
the efficacy and efficiency of human developments,
including building construction (e.g., skyscrapers),
modes of transportation (e.g., sail boats, aircraft,
spacecraft), design and installation of communication
infrastructure (e.g., tall towers and transmission lines), and power generation (e.g., utility and residential scale wind energy facilities). Achieving these two sets of goals in large measure depends upon understanding the
dynamic properties of wind and associated meteor-
ological conditions at local, regional, or global scales, and understanding how these conditions affect move-
ments of organisms.

To our knowledge, no organism spends its entire
life in the aerosphere, yet many species spend a
significant portion of their lives in this environment
(Wilcove 2008). Species that spend significant
amounts of time in terrestrial and aquatic ecosystems
also may depend on the aerosphere for daily and
seasonal locomotion, and sometimes for courtship
and mating. Important selection pressures accord-
ingly influence the biology of flight, including the
size and shape of structures that comprise the flight
apparatus, and sensory modalities that provide infor-
mation about the aerosphere, and the active and
passive systems that control locomotor movements.

On both temporal and spatial scales, the aero-
sphere is more variable and dynamic than the litho-
sphere or hydrosphere. Relative to strictly terrestrial and aquatic organisms, species that regularly occupy
the aerosphere are almost immediately influenced
by changing atmospheric conditions (e.g., pressure,
wind, air density, precipitation, temperature), and
other physical factors (e.g., solar radiation, polarized light, moon light, and geomagnetic and gravitational
forces). Organisms that use the aerosphere for
foraging, dispersal, and seasonal movements have
evolved unique body forms and shapes, but also
specific physiological traits (e.g., increased produc-
tion of hemoglobin at high altitudes), thermoregu-
latory and respiratory responses, and the like, in
response to different selection pressures. The aero-
sphere and the organisms that compose it not only
are strongly influenced by predictable atmospheric
conditions, but also by a myriad of anthropogenic
conditions (e.g., lighted towns and cities, skyscrapers, air pollution, aircraft, radio and television towers, and more recently from the proliferation of wind turbines
and communication towers) that increasingly have
adverse effects on such essential activities such as
feeding, dispersal, migration, and courtship (Kunz
et al. 2007a, 2007b; National Research Council 2007;
Arnett et al. 2008; Horn et al. 2008; Fig. 1). Similarly, human-altered landscapes (e.g., forest fragmentation,
agriculture, and urbanization) are rapidly and irre-
versibly transforming the quantity and quality of
available habitats for organisms that use the aero-
sphere, conditions that also can affect the struc-
ture and function of terrestrial and aquatic ecosystems and the assemblages of organisms therein. Prevailing
climate change and its expected effects on global
circulation of the atmosphere and resultant changes
on local, regional, and weather conditions may have
profound effects on the historic migratory patterns
of animals that use the aerosphere (Wilcove 2008).

Challenges of probing and modeling the
aerosphere
Ecologists who study species that use the aerosphere
face three important challenges: (1) to discover how
best to detect the presence, taxonomic identity,
diversity, and activity of organisms that use this
space, (2) to identify ways to quantify relevant envi-
ronmental variables at different temporal and spatial
scales, and (3) to determine how best to understand
and interpret responses of organisms in the context
of complex meteorological events and patterns
within both natural and anthropogenically altered
environments. Efforts to address these challenges
require the collaboration of scientists from diverse
disciplines who have expertise and instruments
needed to probe the aerosphere whether by day or
night, in arid and humid conditions, at low and high
altitudes, in strong and weak magnetic fields, in cold
and warm climates, and during calm and windy
conditions. Increasingly available tools, some origin-
ally designed for military purposes, space explora-
tion, climate modelling, and security applications,
include remote sensing and imaging devices such as
radar, lidar, aircraft surveillance, weather satellites, night vision, and thermal infrared imaging cameras.

Other instruments designed specifically for the study
of animal movements, include radio-telemetry net-
works of ground-based stations and satellites, devices
that detect audible and ultrasounds of birds and bats,
stable isotope and DNA markers for assessing migra-
tion, which can be particularly valuable when used in
combination with remotely sensed atmospheric, ocean-
ic, and landscape conditions. Availability of these tools and methods provides rich opportunities for address-
ing emerging questions in ecology and environmental
sciences with an emphasis on the aerosphere.
2 T . H. Kunzet al.

Fig. 1 The aerosphere is influenced by both natural phenomena and anthropogenic factors. ( A) Aerospheric view of a volcanic eruption on the island of Montserrat (news.nationalgeographic.com); ( B) Counter-clockwise swirl of clouds as a cyclone passed over Iraq, and dust being transported within the warm sector of the system (ucsu.colorado.edu/ /C24 drewsc/sandstorm/); ( C) Aerial view of the North American landscape at night, showing lighted cites and towns (www.usgcrp.gov/usgcrp/images/ocp2003/8.1b-HCR); ( D) Aerospheric view of skyscrapers New Y ork City (www.justinlagace.com); ( E) Aerial view of an agricultural landscape, showing the influence of center pivot irrigation in an arid region of Colorado (www.discoverlife.org/IM/EL_DP/0010/mx); ( F) Aerospheric view of land-based communication towers (hawkins.pair.com/voadelano/voa_delano03.jpg); ( G) Aerospheric view of a modern U.S. Air Force F-16 Fighting Falcon aircraft (galleries.fototagger.com/image/f-16_fighting_); ( H) Aerospheric view of a modern, utility-scale wind energy facility in Palm Springs, California (www.planetscience.org/revisiontime/wind2.jpg).

Aeroecology 3
The appropriate integration of diverse tools,
technologies, and multiple databases promises to
inform important ecological concerns and concepts,
ranging from spread of invasive species, changes in
biodiversity, and local- and global-scale animal
movements in response to altered terrestrial, aquatic,
and aerial environments. To date, ecologists have
been hampered by a lack of technological awareness,
inconsistent vocabularies, and challenges of working
across different disciplinary platforms, including the
complexities of establishing meaningful collabora-
tions with atmospheric and computer scientists.

Similarly, ecologists interested in proximate and
evolutionary responses of airborne fauna to climate
change and other anthropogenic perturbations have
yet to optimally use the rich databases on landscapes
assembled by earth scientists and geographers using
remote sensing tools [e.g., American MODIS
(Moderate Resolution Imaging Spectroradiometer),
the European MERIS (Medium Resolution Imaging
Spectrometer), and the Indian IRS-P6 (Indian
Remote Sensing Satellite)].

Goals of the aeroecology symposium
The papers presented in this symposium address
some of the limitations and challenges highlighted
above, and highlight opportunities for gaining new
insights that could arise from overcoming these
challenges. To accomplish these goals, each of the
authors considered several ecological questions that
require analyses that embrace ecological and envir-
onmental sciences relevant to the aerosphere.

Specifically, questions relate to animal displacements, and atmospheric and biological factors that may
affect daily and seasonal patterns of prey density,
foraging behavior, and migration. In addition to
developing and promoting new tools and technolog-
ies to support research in aeroecology, it is
important to integrate knowledge from different
disciplines by encouraging the participation of
scientists from varied backgrounds to develop a
broader understanding of complex processes and the
responses of organisms to a dynamic aerosphere. To
achieve these goals, the authors share ideas with
respect to novel tools, emphasize tangible and
specific scientific questions, and adopt novel research paradigms. To this end, we have identified instru-
mentation and software tools, and discuss their
applications to improve our collective understanding
of the aerosphere and the interactions of airborne
organisms with the hydrosphere and lithosphere.

Several research areas were not included in this sym-
posium because time was limited. Notwithstanding,
we include brief comment on these and other
emerging disciplines relevant to understanding the
ecology of organisms that use the aerosphere.

Historical and current research on
aeroecology
Weather radar historically has been used for detect-
ing groups of migrating birds (Able 1970; Bruderer
and Steidinger 1972). Since the early 1990s, weather
surveillance, NEXRAD (NEXt Generation RADar)
Doppler radar has been used at various temporal
scales to quantify movements of birds (Diehl et al.
2003; Diehl and Larkin 2005; Larkin 2005;
Gauthreaux and Belser 2003, 2005; Gauthreaux
et al. 2003, 2006; Kunz 2004), although it has
become increasingly clear that many targets also
include bats and insects (Westbrook et al. 1998;
Kunz 2004; Cleveland et al. 2006; Cryan and Diehl in
press). Similarly, tracking radar is being used to
investigate foraging, dispersal, and migratory move-
ments of flying arthropods, birds, and bats (Bruderer
and Boldt 2001; Bruderer and Popa-Lisseanu 2005;
Larkin 2005). Additionally, use of vertical profiler
radar promises to provide new insight into the
distribution and movement of air masses, and of
arthropods, birds, and bats in the aerosphere (Smith
et al. 1993; Eaton et al. 1995; McLaughlin 2003; Kunz
et al. 2007b; T.A. Kelly, personal communication).

Advances in radio-telemetry (e.g., miniature radio
transmitters for insects, small birds and bats, and
satellite tracking with GPS for larger species), have
advanced our knowledge of movements at smaller
spatial and temporal scales than can be provided by
radar. Recent developments of integrated arrays of
receiving antennae and satellite tracking of small
birds and bats (Cochran and Wikelski 2005; Smith
et al. 2005; Wikelski et al. 2007), in addition to
advanced canopy-netting techniques (Hodgkison
et al. 2002), are beginning to yield new insights on
animal movements, pollination of flowers by nectar-
ivores, and dispersal of seeds by frugivores
(Hodgksion et al. 2003; Thies and Kalko 2004;
Croxall et al. 2005; Nathan et al. 2005; Thies et al.
2006)—research that also is relevant to the conserva-
tion of biodiversity (Trakhtenbrot et al. 2005) and for understanding the transmission and mitigation of
emerging diseases (Chivian 2003; Epstein et al. 2003).

Radio transmitters, together with other visualiza-
tion methods, also are enabling researchers to
quantify energy expenditure, wingbeat patterns,
respiration, and flight altitudes of small, free-ranging animals (e.g., Lord et al. 1962; Dudley 2000; Altshuler et al. 2004; Bowlin et al. 2005). Use of wind tunnels
4 T . H. Kunzet al.
and computer-aided visualization techniques (Srygley
and Thomas 2002; Altshuler and Dudley 2003;
Pivkin et al. 2005; Swartz et al. 2006; Hedenstro ¨m
et al. 2007; Henningsson et al. 2008; Muijres et al.
2008) also are helping to inform field ecologists in
how flow dynamics and atmospheric conditions
influence flight behavior of bats, birds, and insects
(e.g., Dillon et al. 2006).

Measuring physiological traits of foraging and
migrating animals, under different atmospheric
conditions (Greenstone 1990, 1991), also has begun
to advance our knowledge of how animals respond
to different aerospheric conditions. Moreover, novel
efforts are being made to understand how insects,
birds, and bats navigate during migration (Holland
et al. 2006a, 2006b). Experimental manipulations
have included alteration of magnetic fields to
understand how animals navigate over long distances
(e.g., Cochran et al. 2004; Srygley et al. 2006;
Holland et al. 2006b; Wang et al. 2007). A recent
initiative to employ radio technology on a near-earth
satellite to track small animals around the globe
holds considerable promise for understanding migra-
tory movements of free-ranging animals (Wikelski
et al. 2007). A recent global initiative, known as the
International Cooperation for Animal Research
Using Space (ICARUS; www.icarusinitiative.org),
also has been formed to help achieve this goal.

Other initiatives, including NEON (National Ecologi-
cal Observatory Network [http://www.neoninc.org/]),
and related Research Coordination Networks, such as
MIGRATE (Migration Interest Group: Research
Applied toward Education [www.migrate.ou.edu]),
both funded by the National Science Foundation,
have been formed to help answer important questions
such as the influence behavioral plasticity of migrants, drivers of population dynamics of migratory animals,
determinants of individual fitness, and impacts of
environmental change on migratory life-histories
(JF Kelly, personal communication).

Recent developments in audible and ultrasonic
acoustic detection and analysis, coupled to high-
speed infrared and thermal images now make it
possible to quantify three-dimensional flight trajec-
tories of bats as they pursue airborne arthropods
(Schnitzler and Kalko 2001; Holderied et al. 2005;
Holderied and Jones in press; Hristov et al. 2008),
and to unambiguously identify the mix of free-
ranging bat species in both temperate and tropical
assemblages (Parsons and Jones 2000; Brigham et al.
2004; Szewczak 2004; Parsons and Szewczak in press).

This technology now makes it possible to characterize
species richness and activity patterns that previously
been difficult to quantify or record species have gone
completely undetected, such as many aerial insectivor-
ous bats, especially in tropical regions (Jung et al.
2007). Night vision devices and thermal infrared
cameras have become increasingly used to observe
birds, bats, and insects aloft, not only for assessing
foraging behaviors (Simmons 2005; Betke et al. 2007;
Horn et al. 2008; Hristov et al. 2008), but also for
censusing animals during nightly emergence flights
(Sabol and Hudson 1995; Frank et al. 2003; Betke
et al. 2007, 2008; Hristov et al. 2008). When used
simultaneously with tracking radar, night vision
devices and thermal infrared cameras also make it
possible to distinguish between birds and bats as they
respond to anthropogenic structures such as wind
turbines (Gauthreaux and Livingston 2006; Kunz et al.
2007a; 2007b).

Many important aspects of the behavior of flying
organisms in the aerosphere occur in groups, some-
times of immense sizes. Many collective behaviors
are influenced by the three-dimensional geometry of
the environment, and by the cognitive abilities
of animals that interact with prevailing atmospheric
conditions. Understanding the behavior of indivi-
duals in isolation does not necessarily provide
information about the properties of individuals
within groups (Couzin and Krause 2003). Increased
focus on empirical studies, self-organization theory,
and mathematical modelling of group and collective
behavior of insects, birds, and other organisms
promises to help advance knowledge about daily
flocking behavior at the population level and group
dynamics during migration (Couzin 2006a, 2006b).

Use of stable isotopes of carbon and nitrogen as
dietary tracers also can provide valuable insights into trophic relationships of airborne predators and their
prey (Iba´n˜ez et al. 2001; Sullivan et al. 2006: Popa- Lisseanu et al. 2007), and isotopes of hydrogen can
additionally be used for discerning geographic
origins of nocturnal migrants (Hobson and
Wassenaar 2001; Cryan et al. 2004; Kelly et al.
2002; 2005, Hobson et al. 2006).

Collaborations of biologists with atmospheric scien-
tists and aerospace engineers are needed to help
advance understanding of animal behavior in the aero-
sphere. In turn, these collaborations can help advance
the technical design and function of small, unmanned
aerial vehicles, as inspired by the ecology, behavior,
physiology, and biomechanics of real organisms (Watts
et al. 2001; Pivkin et al. 2005; Swartz et al. 2006).

The symposium
To the extent possible, each contribution from this
symposium has posed several important questions
Aeroecology 5
and has reviewed existing and upcoming applica-
tions that inform new answers. Interdisciplinary
approaches are emphasized, particularly those
designed to optimally exploit the expertise of
domain scientists in behavior, ecology, biomechanics,
meteorology, computer science, and geography—
approaches that are central to developing meaningful
cross-disciplinary collaborations.

Using Doppler weather surveillance radar,
Gauthreaux et al. (2008) discuss major challenges
in understanding daily and seasonal movements of
airborne fauna. Reflectivity data contain information
on the quantity of organisms aloft, and data on
velocity and winds aloft are needed to determine the
different types of organisms that use the aerosphere.

The latter is accomplished by examination of
statistical distributions of the maximum ground
speeds of airborne fauna in the aerosphere. Because
migrating birds and bats have mean velocities greater
than most insects and randomly foraging birds and
bats in a sample volume of the aerosphere, these data
can often be used to detect and discriminate specific
targets aloft.

Horn and Kunz (2008) used NEXRAD databases
to explore how Brazilian free-tailed bats disperse
nightly into the aerosphere, and how this informa-
tion can provide insight into local population
dynamics. NEXRAD radar images are georeferenced
and compiled in a GIS along with colony locations
and landscape features. In temporal sequences of
NEXRAD images, identification of individual bat
colonies is accomplished by assessing reflectivity
from bats aloft using computer vision algorithms.

These measurements are used to compute relative
colony size and mean direction of travel and to
compare variation in emergence behavior both
within and among colonies. Analyses using circular
statistics suggest that multiple factors play a role in the nightly flight and dispersal behavior of bats, and
demonstrate that NEXRAD data can be a valuable
resource for monitoring the nightly behavior of large
bat colonies, and larger-scale seasonal and inter-
annual changes in abundance of local populations.

Larkin and Szafoni (2008) discuss how tracking
radar data can be used to investigate nocturnal
aggregations of birds. Statistical analyses of detailed flight paths support the hypothesis that individual
birds that fly together (closer than 200–300 m) move in the same direction and at the same speed more often
than those that are widely dispersed. Evidence from
tracking radar suggests that birds flying together also may have similar wing beat frequencies than can be
expected by chance.

Hristov et al. (2008) provide an overview of recent
applications of thermal infrared imaging in eco-
logical research and discuss how this technology has
revolutionized our ability to observe and document
the behavior of free-ranging organisms in the dark.

Unlike traditional imaging that requires visible light, thermal infrared imaging relies on the emission of
heat energy from objects in the environment.

Temperature-sensitive cameras and computer vision
algorithms are used to detect differences in thermal
values in their fields of view and to depict
information visually as different brightness (tem-
perature) values. As noted in this article, successful
applications of thermal infrared imaging from
ongoing studies of bat ecology and behavior also
are relevant for the study other organisms.

Kalko et al. (2008) present results based on
recordings and analysis of echolocation calls of
Neotropical bats that, for the first time, permit
explicit species identification as well as assessment of foraging activity in these species-rich tropical assem- blages. Use of miniature radio transmitters also
makes it possible to assess foraging strategies, range
size, and differential habitat use of species that
previously have been otherwise difficult to study.

Given the high impact of bats as seed dispersers,
pollinators, and predators on arthropods, the fine
resolution of movements afforded by radio-telemetry
provides a better understanding of the links between
spatial use and resource distribution and abundance.

In turn, this provides novel information needed to
understand temporal dynamics, to help quantify the
ecosystem services provided by bats, and to predict
how anthropogenic changes may affect the abun-
dance and distribution of their prey.

Jones and Holderied (2008) discuss how echoloca-
tion is used by bats to detect, localize, and classify
airborne targets at night. As obstacles or prey species are approached, it has become increasingly clear that
the call structure of echolocating bats changes in
predictable ways: calls become shorter to reduce
overlap between pulse and echo, and calls change in
shape so that localization errors in the detection of
insect prey can be minimized. Echolocation behavior
and flight performance of bats are closely synchro-
nized by monitoring both features simultaneously
using stereo photo- and videogrammetry, and by
acoustic tracking of their flight paths. These
approaches make it possible to quantify the intensity
of signals used by free-ranging bats, and thus
demonstrate systematic changes in signal design in
relation to the proximity of obstacles (e.g., moving
insect prey and stationary objects) in the aerosphere.
6 T . H. Kunzet al.

Westbrook (2008) discusses long-distance migra-
tion of important agricultural pests, such as adult
corn earworm moths ( Helicoverpa zea ), also called
cotton bollworm moths, and several other noctuid
moth species upon which bats and birds sometimes
feed. These seasonal geographic expansions of pest
populations and the consequent increased infestations
of agricultural crops are documented on a conti-
nental scale in North America. Observed patterns
of migratory flight by these insect pests are largely
associated with vertical profiles of temperature and
wind direction and are concentrated in the atmo-
spheric boundary layer. Collective patterns of moth
migrations generally are related to wind direction, but often at significant angular deviations. Preliminary
analyses suggest that moth distributions in the aero-
sphere can be estimated from discrete moth counts
using X-band radar and bulk reflectivity data from
NEXRAD Doppler radar.

McCracken et al. (2008) discuss bat echolocation
calls recorded using radio microphones suspended
in the aerosphere from kites and tethered helium
balloons. These data mostly include calls of Brazilian
free-tailed bats from ground-level up to 1118 m
above ground level (AGL). Altitudinal profiles show
significantly different levels of bat echolocation call activity at different levels AGL in the aerosphere.

Bat activity was greatest at ground level and
400–600 m AGL, coincident with the atmospheric
boundary layer and the highest densities of moths
as described in the paper by Westbrook (2008).

Feeding buzzes, indicating attacks on aerial prey,
were most abundant near ground level and at
400–600 m AGL, although some were detected at
altitudes up to 1 km AGL.

Srygley and Dudley (2008) review data on insects in
the atmospheric boundary layer by tracking indivi-
duals as they migrate across the Caribbean Sea and the
Panama Canal. Data presented on dragonflies of the
genus Pantala show that migration occurs in October
and is associated with frontal systems. Butterflies
and dragonflies are capable of directed movement
towards a preferred compass direction in variable
winds, whereas moths of the genus Urania migrate
from Central to South America and drift with winds
over water. Butterflies navigating in the aerosphere
appear to use both global and local cues. In support
of optimal migration theory, butterflies and dragon-
flies appear to adjust their flight speeds to maximize
migratory distance per unit energy, whereas moths
do not.

Swartz et al. (2008) examine the biomechanics and
physiology of flight of bats in the laboratory, and
explore how this knowledge can help advance
understanding of foraging, dispersal, and migration
of free-ranging animals. Laboratory studies of animal
flight in wind tunnels provide valuable information
for improving and understanding of airflow dyna-
mics. Emphasis is placed on flow characteristics of
distinct aerial environments as a critical first step
toward understanding the ecology of free-ranging
animals aloft. The dynamics of natural airflow, char-
acterized by air speeds, variability, intensity, and
turbulence, will likely influence many aspects of an
animal’s behavior in the aerosphere. A combination
of field- and laboratory-based research also is needed
to delineate conditions under which flight mechanics
and energetics are influenced by turbulence created
by other animals.

Cochran et al. (2008) discuss the advanced use of
miniaturized radio-transmitters that allow for the
continuous monitoring of behavioral and physiolo-
gical variables of small, free-ranging animals that use the aerosphere. Monitoring of nocturnal migratory
flights of three species of neotropical thrushes in the mid-western US has revealed variations in wing beat
frequencies, flight speeds and body accelerations that
may reflect ascending and descending movements of
individuals during flights. Individual thrushes also
pause (in wingbeat) more often than expected during
their migratory flights, likely to save energy. The high variation in wingbeat frequencies also cautions
against categorizing radar echoes as particular types
of birds.

Future directions
To further advance the emerging discipline of
aeroecology, studies are needed that integrate the
research discoveries of atmospheric scientists, engi-
neers, and computer scientists with those of ecol-
ogists, physiologists, and functional morphologists,
to more fully understand the activity and move-
ments of organisms in the aerosphere. Research that
incorporates laboratory and field studies on biome-
chanics, physiology, behavior, and ecology also
promises to provide new insights into how, where,
when, and why organisms interact with anthropo-
genic features in the aerosphere. To this end, studies
are needed to assess: (1) physiological and behavioral
responses of airborne organisms to climate change,
(2) behavioral and ecological responses of organ-
isms to structures that extend into the aerosphere
(e.g., communication towers, tall buildings, and wind
turbines), (3) how landscape fragmentation and land
use change affects movements, and (4) how the
altered structure of aeroecological communities,
through the invasion of exotics, may affect species
Aeroecology 7
distributions and abundance (Lindenmayer and
Fischer 2006; National Research Council 2007;
Kunz et al. 2007a; Lian 2007; Wilcove 2008). Use
of stable isotopes to investigate trophic relationships between insects, birds, bats, and their prey also
promises to yield valuable insight into how the
myriad of organisms interact in the aerosphere.

Ultimately, understanding the ecosystem services
provided by arthropods, birds, and bats that use
the aerosphere is important for maintaining ecosys-
tem health, human health, and biodiversity on
the planet (Daily et al. 1997; Cleveland et al. 2006;
Chivian and Burnstein 2008).

Acknowledgments
We wish to thank the Society for Integrative and
Comparative Biology (SICB) Program Committee, its
program director, Linda Walters, the chairs of the
divisions of Vertebrate Zoology, Comparative Bio-
mechanics, and Ecology and Evolution for support-
ing the ‘Symposium on Aeroecology.’ We also thank
Sue Burk, SICB meeting director for making the
logistical arrangements to convene our symposium.

We are grateful to Paul Cryan, Mark Friedl, Jeff
Kelly, and Ana Popa-Lisseanu for their valuable
suggestions on an earlier draft of this manuscript.

We are especially grateful to Johnny Evers and
Willard Larkin for their encouragement and support
in convening this symposium. We wish to thank the
Air Force Office of Scientific Research, through a
grant to Boston University (FA9550-7-1-0449 to
THK), for providing partial travel support for each
of the speakers to present their papers as part of
the ‘Symposium on Aeroecology,’ and the SICB for
waiving registration fees for symposium speakers.

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Sacramento City CouncilDecember 2, 2025

Sacramento City Council
December 2, 2025