Draft MTP/SCS Comments Received - sacog

policies of the SCS. Additional information by jurisdiction and community type is provided in
Appendix E-3.”
The jurisdictional narratives of anticipated growth in Appendix E-3, in conjunction with the
primary map of the plan by community type (Figure 3-2, MTP/SCS, p. 3-11) and the breakdown
of qualifications for the levels of CEQA benefits in Table 2-16 (DEIR, p. 2-60) offer a very broad
net for jurisdictions to make the interpretation of "consistency" with the SCS, or judge the
impacts that have been addressed by the programmatic SCS EIR. We understand that SACOG
does not have the capacity to provide oversight for all regional project-level determinations, but
lacking this oversight or a more specific guide for land-use designations, it is extremely important
that there be a public process before these determinations are made. At the very least, an
opportunity for public input should be established in coordination with the local jurisdictions to
ensure that equity, health, and environmental interests are adequately addressed.
Natural Resources:
We are greatly concerned about the continued trend of greenfield development in the region. We
support the reduced growth footprint of this MTP/SCS, yet there remains a substantial amount of
greenfield development within the footprint (that will now receive CEQA exemptions). And
further, there are currently many thousands of acres of proposed development outside of the plan
that will endanger the plan's future success. Growth outside of the plan in one area will need to be
absorbed by the rest of the region and inhibit the growth of other jurisdictions, in subsequent
MTPs. And it is feared that much more than the CEQA benefits provided by the SCS will be
needed to incentivize smart growth and adherence to the plan.
The centerpiece of the plan's natural resource element is the Rural Urban Connection Strategy.
We cannot understate our praise for the work of the RUCS program since the last MTP in
analyzing the broad range of factors that affect viability of the region's rural communities. And
we commend RUCS's demonstration of the economic imperatives to preserve the regions
agricultural base.
SACOG highlights performance in this area with the projection that, by 2035, 37,000 acres of
agricultural land will be converted to urban development--compared to 200,000 acres converted
since 1988, (despite a greater projected population increase by 2035). This is certainly a great
departure from the past that we support. Clearly, RUCS is an innovative and impressive program,
yet it is essentially an economic viability study for agriculture alone, and the sophisticated
analysis does not extend equally to habitat impacts, or other ecosystem services (i.e. carbon
sequestration, groundwater recharge).
For plant and wildlife habitat viability, the SCS relies mostly on the presumed completion of the
region's Habitat Conservation Plans. But these plans, alone, do not address critical regional
connectivity, and, in some cases, do not at this point show certainty of successful completion.
The total acreage of newly developed land in the SCS is generally represented to be 53,266-
53,914 (EIR 2-25; 19-20). Within the newly developed areas, 36,392 acres of agriculture
(MTP/SCS, 7-6), 5,602 acres of designated forest (EIR,4-44), and 37,681 acres of habitat are
impacted (Table 7-5, MTP/SCS 7-17). Obviously, there are overlaps of these 79,675 acres of
agriculture, forest, and habitat to add up to the ~53,500 figures. Table 6-6 (EIR, 6-35) adds up the
impacts to 53,914 - showing only 16,233 acres of agriculture beyond the 37,000 of habitat. But
how or where the other 24,000 acres overlap is not clearly indicated or shown spatially to be able
to adequately analyze impacts.
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