Sac County Needs A Good CAP

Hello friend. We've been trying for a long time to get Sacramento County to get its act together and come up with a Climate Action Plan (CAP) to get us on a path to reducing carbon emissions, and building a sustainable, livable future for all of us.

Unfortunately, if passed by our County Supervisors this October, the CAP they've come up with will set us on a path to missing those climate goals - and actually make things WORSE.

You can keep reading this and the next page for more context, but here's our ask for you:

We need your voice. Use this tool to send in a public comment to prevent Sacramento County from committing to a bad climate plan.

We need a good, visionary CAP to set the direction for a livable future!

The public review period ends on October 8th, 2021!

We've set up this tool with some tips to help you write your comment on the next page, and it'll automatically submit for you! Whether you want to dive in and share your story, or even if your comment is just a sentence, every comment that we send in matters - our goal is to show how many people think this is a problem and that Sacramento County needs to do better.

What's wrong with the CAP?

There are a few key things wrong with the proposed Climate Action Plan (CAP) for Sacramento County that is currently in its public review process. The following context will also be available for you to review on the next page as you draft your public comment.

At its core, this CAP misses the direction set by the Climate Emergency Declaration passed by the Sacramento County Board of Supervisors in December 2020

  • Sacramento County already affirmed the need to reduce emissions as much as possible by 2030 and, stating last year that we are in a climate emergency. Drafted half a decade ago, the legal limit for California of 2045 is far too late of a target to reduce our carbon emissions.
  • The top scientists at the United Nation's Intergovernmental Panel on Climate Change released a global climate report this year, cited as a "code red for humanity" that we need to act on climate now, not later.
  • The CAP recites the Climate Emergency Declaration’s (CED) direction without
    substantively responding to it, and acknowledges, ”this version of the CAP does not
    meet the [CED’s] carbon neutrality goal”. Not one of the CED’s eight elements is
    credibly addressed, let alone implemented.
  • The CAP assertion that, “The County is on track … toward the 2030 carbon neutrality
    goal” is not credible, because the CAP’s measures are almost all vague,
    weak, unenforceable, unfunded, and lack evidence for effectiveness as State law
    (CEQA) requires.
  • The CAP “commits” to several actions that “that will meet the goals of the Climate
    Emergency Resolution”., but none are credible, e.g.:
    • “Reviewing updates to the State … Scoping Plan” does not commit to doing
      anything substantive.
    • A proposed “update to the General Plan … to further promote infill development
      and VMT reduction” is currently unscheduled and unfunded; the GP is valid
      through 2030; there is no penalty for going past that date; and the contents of any
      future update is entirely speculative.
    • “Update[ing] the CAP’s GHG inventory” on a triennial basis is a 2011 promise the
      County has already failed to keep; and how GP and Scoping Plan updates would
      inform that technical exercise is unexplained.
    • The targets [sic] for carbon neutrality (which is already explicit in the CED) and for
      “options contained in CAP Appendix F” would be updated at a time unstated to
      unspecified reason or effect.
    • The CAP would be updated with “… new GHG reduction strategies to incorporate
      local actions recommended by the State in the 2022 Scoping Plan and Natural and
      Working Lands Climate Smart Strategy”. But if the County wants to incorporate
      Scoping Plan recommendations, there is no need to wait - current and past
      versions all emphasize the critical importance of local action, particularly in
      reducing VMT. And the County has little or no authority over management of
      natural and working Lands, but the need to wait for this document’ is unexplained.

The measures proposed in the CAP are vague, weak, and unenforceable

  • The CAP is not a plan, it’s a listing of things that could happen but probably won’t, because there’s no commitment.
  • Most CAP measures are conceptual, vague, voluntary, deferred, unfunded, and/or non-enforceable; and their feasibility and effectiveness are not substantiated as State law requires.
  • Instead of presenting a credible, thought-out program, the CAP defers "consideration of actions that allow the CAP measures to be achieved ... and funded" to future unspecified, unscheduled '"internal coordination". The County needs to complete its plan before adopting the CAP, not push it off another ten years!
  • The CAP’s best-developed measure - GHG-05, for new building electrification - is much
    weaker than the Air Quality Management District’s recommendation based on its finding
    that that we can’t meet State goals with any new gas hookups.
  • The County promised all the following in 2011; but none are included in the CAP:
    • a fee on development to fund CAP work
    • economic analysis of measures
    • detailed programs
    • timelines

The CAP will increase climate-busting suburban sprawl

  • The County is obligated to adopt a CAP because they promised in 2011 they would. However, once a CAP is adopted, future projects won’t need to show how they will reduce greenhouse gasses (GHG) - they only need to comply with CAP measures, no matter how weak. So a weak CAP is worse than none.
  • The County’s biggest source of GHG emissions is auto vehicle-miles-traveled (VMT) and sprawl development is a major cause of high VMT.
  • The County now has in planning four sprawl projects totaling 55,000 new dwellings. All four are beyond the County’s normal growth boundary, so will need general plan amendments .
  • These four projects have a VMT problem. The State’s VMT reduction target for new development is 15 percent below current average per capita VMT, but these four projects will all increase average per capita VMT.
  • We don't need more sprawl approvals. Most foreseeable housing needs can be met with infill and the rest with already-approved projects. Per SACOG, the County will need 37,000 new dwelling units through 2040. The County’s infill capacity is 33,000 units, and the County has already approved 49,000 additional new homes
  • With infill, already approved projects, and the four new proposed developments, the County is on-track to have approved 140,000 new homes – almost four times the foreseeable need. This over-supply of land approved for development far beyond need is not rationale planning - it's land speculation
  • The County’s open-door to new, unneeded development pulls investment away from our existing communities and neighborhoods, where affordable housing near to jobs, shopping, and services, and served by transit is desperately needed.

The CAP tries to dodge much-needed, and legally required, full environmental review

  • The County’s process is legally dubious. California courts have ruled that adopting a
    CAP requires a new environmental review.
  • The County’s proposed adoption process for the CAP avoids providing an
    environmental review under State law (CEQA) - this is a huge concern! As a result the County:
    • Doesn’t need to show “substantial evidence” that it’s measures are feasible,
      effective, or enforceable – in other words, that the CAP will actual reduce GHG
    • Doesn’t need to consider alternative strategies to reduce GHG, like not approving
      more sprawl development.
    • Doesn’t need to consider the cumulative GHG emissions of the County’s planned
    • Is free of normal public participation requirements.
    • Can’t be held accountable under State law for the CAP’s quality, no matter how
  • The County claims no environmental review is needed because it was provided when
    the General Plan (GP) was updated back in 2011. But at that time, instead of
    identifying GHG mitigation as was required, the County explicitly deferred GHG
    mitigation to the CAP, which it promised to adopt within one year. Now ten years
    later, in circular fashion, the County says the earlier analysis was adequate. If so, why
    was a separate CAP needed?
  • We are not living in the same world as when the last review was conducted a DECADE AGO in 2011, we need to act on current science. The CAP needs legitimate environmental review now! The 2011 review is inadequate because:
    • The CAPs measure weren’t even known when the GP was updated, so there is no
      way they could have been adequately analyzed.
    • This isn’t 2011 and environmental conditions have changed. Climate change is no
      longer a distant threat. The climate is dramatically worse and is changing much
      faster than was expected in 2011. We are closer to disastrous climate thresholds.
      Climate science has greatly advanced and is now more certain that urgent, decisive
      action is essential to prevent climate catastrophe. And many important new laws
      and policies are in place.
    • The CAP itself is a program-level plan that will allow new development without
      further GHG analysis or mitigation, it needs robust environmental review,
      particularly because its measures are weak and unsubstantiated.
  • We need a full Environmental Impact Report, not just an "EIR Addendum" leaning on old documents from a decade ago to try to dodge the California Environmental Quality Act

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