Letter to Elk Grove City Council From Wilton Action Group

The following letter was sent to the Elk Grove City Council regarding the city's Sphere of Influence application from the Wilton Action Group.


Dear Mayor Hume and Council Members:


The July 22, 2009 Elk Grove City Council meeting highlighted the problems associated with the City Council’s continuing effort to include floodplain lands east of State Route 99 in the City’s Sphere of Influence (SOI). Members of the Wilton Action Group (WAG) attended the meeting hopeful that the Council would direct staff to eliminate the floodplain from the SOI application which the City has submitted to the Local Agency Formation Commission (LAFCO). We write now to express our deep disappointment with the Council’s failure to take this sensible, fiscally responsible action, and wish to contrast the Council’s undisciplined SOI discussion with its methodical consideration of how to balance the City’s transit budget during an earlier item on the agenda.



This earlier item required the Council to wrestle with its options for eliminating a projected $1.7 million deficit in the City’s Fiscal Year 2009-2010 (FY 09-10) budget for transit services. The discussion was guided by a thorough and well informed staff presentation on the likely cost savings and user impacts of various modifications in the transit services provided to Elk Grove citizens. In the end, along with other cost saving measures recommended by staff, the Council voted to implement severe reductions in holiday and week-end services that will significantly affect the mobility of the relatively small number of disabled Elk Grove residents who rely on public transportation during these periods. Although clearly troubled by this impact, a majority of the Council concluded that the service reductions were necessary to save approximately $230,000 in the FY 09-10 transit budget and fully eliminate the projected deficit in the transit budget for this year.

In contrast, the Council’s consideration of the City’s SOI expansion was lacking in detail, careless as to cost implications, and devoid of thoughtful discussion as to how the City might tailor its actions to meet its long-term land use planning objectives. More than a year has passed since the concept of expanding the City’s SOI first surfaced; however staff has yet to fully share with the public the assumptions, research, and analysis supporting the LAFCO application.

In its current form, the LAFCO application makes population and job growth projections through 2035, asserting that the City will grow by about 41,000 residents and 31,000 jobs during this period. Using commonly accepted regional metrics for translating these growth projections into land use needs, we estimate that the City needs about 2,300 acres of vacant land for new residential development and about 1,000 acres for commercial, industrial, and office development over the next 25 years. If the above growth projections are doubled to reflect a 50-year period of analysis (out to 2060), then the total amount of vacant land needed to accommodate the City’s population and job growth would be 6,600 acres.

Yet the LAFCO application asserts that by 2035 over 17,000 acres will be needed to support the projected job and population growth rate, including about 14,000 acres currently outside the City’s borders. What accounts for this discrepancy? First, the SOI application’s assumed residential densities (dwelling units/acre) are much lower than what the Sacramento Area Council of Governments (SACOG) recommends and what emerging state law (SB375) may require to limit greenhouse gases. Second, the application’s acreage assumptions for the projected increase in industrial, commercial and office job growth are inconsistent with those commonly used by regional economic planners. As a result, even if the period of analysis is extended to 2060 and the employment and population projections are doubled, the LAFCO application exaggerates the City’s overall need for vacant land by over 250 percent (17,000 acres versus 6,600 acres) and inflates the City’s need for vacant land outside its current borders by almost 400 percent (14,000 acres versus 3,600 acres).

These discrepancies should have been addressed by now and certainly must be addressed before the Council can make any sensible decisions as to how to proceed with the SOI expansion. Again, in contrast to staff’s systematic presentation on transit services at the July 22nd Council meeting, the absence of any discussion regarding the assumptions affecting the SOI was striking, especially because of the cost implications of these assumptions. When asked what it might cost to prepare an environmental impact report in support of an expanded SOI, staff cited “about $200,000.” This estimate might be appropriate for an uncontested environmental review process. In this case, however, it is clear that the SOI application in its present form is likely to generate substantial local, regional, statewide and even national controversy. In addition, the environmental issues raised by the application are likely to be very complex given the sensitivity of the floodplain and habitat areas included in the SOI. This suggests that without going through the same careful “rightsizing” process that characterized the Council’s handling of transit services, the SOI environmental review process is likely to cost substantially more than $200,000.

In the transit discussion, the Council concluded that it could no longer afford to provide the week-end and holiday services that are particularly important to the City’s small number of disabled residents. With respect to the SOI expansion, an equally small number of citizens – owners of large parcels of land that straddle the floodplain - are the principal advocates for including the floodplain in the SOI. This group argues that a traditional SOI focused on land that is actually suitable for urban development would split their parcels and complicate their development plans. However, by attempting to address this perceived complication, the Council is likely to increase the cost of the SOI environmental review process by two or three times the amount that was deemed unavailable to continue transit services for the disabled.

As WAG has pointed out in prior letters to the City, because the SOI is essentially a tool for managing urban development, it is not an appropriate tool for natural resource and floodplain protection. WAG continues to believe that protection of the floodplain which has emerged as the common objective of all of the parties interested in the SOI, should be the subject of an agreement (or memorandum of understanding as staff has suggested) between the City and the County of Sacramento. This agreement could also provide assurances to the eastside landowners that the City and County will fully cooperate in accommodating reasonable land development plans and providing services to the lands affected by such development. Such an agreement would allow the City to “right size” the SOI expansion process so that it focuses only on the land that is actually needed to support future growth. This would minimize opposition to the expansion and avoid what will otherwise be a very costly, time consuming, and potentially unsuccessful environmental review process.

WAG is prepared to cooperate with the City in pursuing this sensible and fiscally responsible approach to the SOI expansion. However, if the floodplain is not eliminated from the LAFCO application we will have no choice but to continue our firm opposition to the application and to maintain our effort to protect the floodplain for as long as it may take to achieve this objective.

CC:

Diane Thorpe, SacLAFCo Commission Clerk
Don Nottoli, Sacramento County Supervisor, 5th District
Terry Schutten, Sacramento County, Executive
Peter Brundage, LAFCo Executive Director
Don Lockhart, SacLAFCo Assistant Executive Director
Taro Eichburu, City of Elk Grove Environmental Planning Manager
Don Hazen, City of Elk Grove Planning Director
Laura Gill, City of Elk Grove Manager
Pat Blacklock, City of Elk Grove Assistant Manager
Matt Baker, Environmental Council of Sacramento
Rob Burness, Habitat 2020
Tina Holt, Herald Area Community Association

Wilton IS a good place to be. Elk Grove thinks so, too.

Bill Kutzer
www.wiltonactiongroup.org
kutzerb@frontiernet.net