Gregory Daggett – March 25, 2025 – SB1000 Environmental Justice in local land planning

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    Note:  What is shown below is a copy of the original letter, made for this website.  It is included here only so that the contents of the original letter can be searchable.  (The PDF received from the City is in the form of an image, and so is not a searchable document.)

    What is below is not the letter sent by the letter-writer. It will contain typographical errors and other departures from the original.  The PDF displayed above is accurate.  The text below is not accurate.  It is printed here for indexing purposes, so that each word can be indexed and included in the search.

     

    Dear Planning Commissioners,
    The California State Attorney General requires local governments such as the City of Arcata to comply with SB1000 in
    Local Land Use Planning.
    SB 1000‐Environmental Justice in Local Land Use Planning. “Environmental justice” is defined in California law as the fair
    treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and
    enforcement of environmental laws, regulations, and policies. (Cal. Gov. Code, § 65040.12, subd. (e).)
    (a) A Land Use Element that designates the proposed general distribution and general location and extent of the uses of
    the land for housing, business, industry, open space, including agriculture, natural resources, recreation, and enjoyment
    of scenic beauty, education, public buildings and grounds, solid and liquid waste disposal facilities, and other categories
    of public and private uses of land. The location and designation of the extent of the uses of the land for public and
    private uses shall consider the identification of land and natural resources pursuant to paragraph (3) of subdivision (d).
    The land use element shall include a statement of the standards of population density and building intensity
    recommended for the various districts and other territory covered by the plan. The land use element shall identify and
    annually review those areas covered by the plan that are subject to flooding identified by flood plain mapping prepared
    by the Federal Emergency Management Agency (FEMA) or the Department of Water Resources.
    A noise element that shall identify and appraise noise problems in the community. The noise element shall analyze and
    quantify, to the extent practicable, as determined by the legislative body, current and projected noise levels for all of the
    following sources:
    (A) Highways and freeways.
    (B) Primary arterials and major local streets.
    Noise contours shall be shown for all of these sources and stated in terms of community noise equivalent level (CNEL) or
    day‐night average sound level (Ldn). The noise contours shall be prepared on the basis of noise monitoring or following
    generally accepted noise modeling techniques for the various sources identified in paragraphs (1) to (6), inclusive.
    The noise contours shall be used as a guide for establishing a pattern of land uses in the land use element that minimizes
    the exposure of community residents to excessive noise.
    California Environmental Quality Act & Environmental Impact Report. The study is based on standard checklists covering
    topics such as air quality, traffic, and noise. The environmental effects of a project will cause substantial adverse effects
    on human beings, either directly or indirectly. The EIR shall also analyze any significant environmental effects the project
    might cause or risk exacerbating by bringing development and people into the area affected. The Noise Element is
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    required by California cities and counties (Government Code Section 65302) It falls under the California General Plan
    Guidelines. Local governments must analyze and quantify noise levels, and the extent of noise exposure, through actual
    measurements. Under Government code section 65302(f) Noise Element Requirement primary arterial and major
    streets such as H and 16th streets, G street, K street, to be monitored and noise research be done such as Average daily
    level of activity (traffic volume per days of the week, and seasonal variations. Distribution of activity over day and night
    time periods, day of the week, and seasonal variations. Average noise level emitted by the source. City of Arcata 3.1.1
    Noise Element. Within the Noise Element of the General Plan, it specifies an exterior noise standard of 60 dB CNEL and
    an interior noise standard of 45 dB CNEL for multi‐family residential. The Secretary of Interior’s Standards for the
    treatment of Historic Properties, Preserving windows, and the relation to noise/environment for Historic Neighborhoods
    and houses, circulation systems, such as roads and streets. The Circulation System of traffic flow using the H street and G
    street for exiting and entering 101 North freeway is a disaster. The quality of life for people living on these busy streets
    in the future will be unbearable with the increase in air pollution and noise. This is a violation of SB1000 Environmental
    Justice in local planning.
    The Gateway Area Plan must do an EIR on the noise exposure from the addition of thousands of more vehicles using the
    major streets H & 16th streets, G street, 8th and 9th Streets, K street and Alliance Road. Government section
    65302(f)Noise Element Requirement primary arterial and major streets that falls under the California Environmental
    Quality Act and the California General Plan Guidelines.
    In the near future Cal Poly Humboldt is building additional housing for 2,400 students with the goal of building additional
    housing in the future.
    Craftsman Student Housing the project will resemble prior planning infill housing at the site. Total project budget 150
    million. Planned opening Dec 2024
    Library Circle Student Housing, Health, and Dining Building & Parking Structure. Total Project budget 175 million.
    Planned opening August 2026
    Campus Apartments Student Housing and Parking Structure. Total project budget 110 million. Planned opening August
    2026.
    All of these projects at Cal Poly and the 3,500 units Gateway Area Project will be putting too much traffic, noise and air
    pollution on the North‐town and Downtown of Arcata. Look at how the California courts ruled in the Berkeley vs
    Berkeley case regarding CEQA requirements and the inadequate environmental impact report addressing polluting
    neighborhoods with traffic and noise. After air pollution, noise is the second biggest environmental factor causing health
    problems, increasing the risk of cardiovascular disorders, high blood pressure, sleep disruption, hearing loss, and heart
    attacks. Noise exposure has also been linked to cognitive impairment and behavioral issues in children. All people have
    the right to a reasonably quiet environment.
    A safety element for the protection of the community from any unreasonable risks associated with the effects of
    seismically induced surface rupture, ground shaking, ground failure, tsunami, seiche, and dam failure; slope instability
    leading to mudslides and landslides; subsidence; liquefaction; and other seismic hazards identified pursuant to Chapter
    7.8 (commencing with Section 2690) of Division 2 of
    the Public Resources Code, and other geologic hazards known to the legislative body; flooding; and wild land and urban
    fires. The safety element shall include mapping of known seismic and other geologic hazards. It shall also address
    evacuation routes, military installations, peak load water supply requirements, and minimum road widths and
    clearances around structures, as those items relate to identified fire and geologic hazards. Tsunami Mapping page 7 for
    Arcata. https://nctr.pmel.noaa.gov/tsu400/documents/Course_1_Day_2/Session_11/NCEE_patton_dengler.pdf Update
    to the NOAA Dengler was published by Lori Dengler on Oct 8th,2022.
    Please comply with California State Law by including SB1000 Environmental Justice in the Land Use Element for the City
    of Arcata.
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    Sincerely,
    Gregory Daggett