Please find available for your review the administrative record for the California Northstate University Medical Center Project (PLNG18-110) as well as the Draft Environmental Impact Report (DEIR). All documents can be found at: http://www.elkgrovecity.org/cnu

The proposed DEIR does not include any type of completion or performance bond which would provide a surety guarantee that this project will not be a blight and environmental wasteland should the proposed developer run out of money. This is a reasonable concern given the project's multiple attempts at financing following the decrease of money coming to the U.S. from China. There is a building in Los Angeles that is experiencing just this type of environmental nightmare and it is located across the street from Staple's Center which is obviously more welcome and desirable than this project. For more information, please follow this link:
https://therealdeal.com/la/2019/01/25/developer-halts-work-on-oceanwide-plaza-megaproject-in-dtla/

I have resided in Elk Grove since 1987, being one of the first 100 homeowners in the Laguna Creek master planned community. For the past 14 years I have been a homeowner in the Lakeside master planned community. I relocated my family to Lakeside because of the quiet, low profile and natural environment and great schools. I am very alarmed and concerned regarding this proposed project being shoehorned into our nearly built out master planned community. Nothing about this project fits with the master plan of our community and the existing infrastructure. This infrastructure was built to address the needs of the community according to the master plan. The proposed project site has businesses that now are low users of infrastructure. The infrastructure was never planned, or built, to be adequate to support the addition of thousands of people in a large medical complex. Reading over the Draft Environmental Impact Report (DEIR) I found many items being listed as having significant and unavoidable impacts on our community that were noted as "no feasible mitigation is available ..." These impact statements are not acceptable and without mitigation the report is incomplete. The following is a short list of the infrastructure listed in the DEIR that either needs to be further addressed or mitigated.

1. The artist renderings of the future project site and of the impact on the surrounding areas, i.e. shadows and proper heights, are inaccurate. These inaccurate renderings display a false effect of the project on the surrounding areas and need to be redrawn with a directional compass to adequately show the Sun's directional path during a day. The other renderings of the finished project buildings are not to scale and will be larger against the surrounding area than they are portrayed.

2. The DEIR has improper and incomplete reports regarding the existing water supply. The current water agency in Sacramento County reports an inadequate supply of water to the existing community over the next ten years. If there is not adequate water supply to meet the needs of the existing businesses and neighborhoods around the project site currently, there needs to be some form of mitigation to allow for the needs of this medical complex.

3. The DEIR addresses the existing floodplain and the location of this project within. This area has flooded several times in recent decades. There have been infrastructure improvements conducted by the city to allow for the build out of the master plan but these are not adequate for the long-term. This report shows the federal government will not institute or allow for any improvements to levees to the north of the Laguna West community because of the construction completed by the City of Elk Grove. Although, the project site is in a floodplain which itself cannot be mitigated, the protection of the existing community needs to be addressed in mitigation measures. It is unreasonable to allow for all of the existing neighborhoods and businesses in the immediate area to flood during a flood event to protect a medical complex that would be inaccessible.

4. The DEIR inadequately addresses the effect of improper mitigation on the existing sewer lines. This report shows the project build out and how it will connect to existing infrastructure. However, this report does not adequately address the impact on a severe increase of waste output on the existing infrastructure. The figures in this report show all of the sewer lines will be redone and retrofitted to meet the increased output into the Stonelake community and meet up with an existing line along E Taron Drive. Then, the waste problem will fall onto the residents of Stonelake because the existing infrastructure only supports the waste of the small businesses, elementary school and Stonelake neighborhood. The infrastructure as it stands today is only adequate for what exists and the entirety would need to be mitigated to allow for a large medical complex to be connected to the existing lines.

Lakeside community owner, District 1

The comments of the Stonelake Master Association on the CNU Draft EIR are available at this Dropbox link: https://www.dropbox.com/sh/9tkdf2ucs1sr369/AADfVFe-RdnKRQQSGADzS0yta?dl=0. Please contact [email protected] if you require any assistance to access the letter and exhibits.
The letter describes the DEIR's defects in detail, including but not limited to:
• The DEIR fails to provide an adequate description of the Project, omitting crucial information regarding Project baseline, proposed building design, permitting and licensing processes, and concurrent construction and operations.
• The DEIR fails to include accurate baseline information regarding CNU’s current activities thereby obscuring the Project’s additional impacts.
• The DEIR fails to discuss numerous concurrent review processes and other agencies’ jurisdiction over the Project.
• The DEIR fails to correlate the Project’s significant air emissions to potential human health impacts on Elk Grove residents.
• The DEIR fails to adequately analyze the manner in which the Project take (harm, harass, kill) special-status wildlife species such as the Greater Sandhill Crane, White-Tailed Kite and Swainson’s Hawk.
• The DEIR does not adequately address the inherent risks of relaxing the City’s flood standards to allow siting of essential infrastructure in the 200-year flood plain, including potential stranding of patients and staff in the hospital without safe exit routes in a flood.
• The DEIR fails to disclose what medical and hazardous wastes, and in what amounts, the Project would produce.
• The DEIR’s cumulative impact analysis completely ignores the proposed Delta Conveyance Project, that would also create significant impacts on the Stone Lakes National Wildlife Refuge and migratory birds, just west of Elk Grove.
• The DEIR’s analysis of project alternatives does not adequately consider to the Lent Ranch location, which would avoid many of the Project’s most significant impacts.
Thank you,
Osha Meserve
Counsel for Stonelake Master Association

October 13, 2020

City of Elk Grove Planning Division
Attn: Sarah Kirchgessner

Re: Comments on the DEIR Inadequacy of the Analysis of the Biological Resources Section
regarding the proposed California Northstate University Medical Center Campus Project

The DEIR for the proposed California Northstate University Medical Center Campus Project fails to meet the requirements outlined in the California Environmental Quality Act in the area of Biological Resources analysis.

1. Specifically, the proposed project violates the requirements of the CEQA Guidelines Appendix G in that it failed to evaluate whether the project would “Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.” (Appendix G, IV Biological Resources, paragraph (d)).

2. The DEIR shows no credible analysis of the magnitude of Significant impacts on migratory bird species because of the footprint and height of the proposed project. The Stone Lakes National Wildlife Refuge is on three sides of the proposed project. Yet there have been no Biological Surveys to quantify how many birds would be impacted (i.e., bird strikes of), the 13-story building. CEQA has always required that quantification be determined prior to and during the analysis. The analysis in this instance would require a recent Winter Survey of Southbound Migratory Birds and a Spring Survey of Northbound Migratory Birds. Consequently, the proposed mitigation for the Significant Impacts of bird strikes that relies on a lack of quantified analysis is deficient and would be deemed Inadequate in a court challenge.

The USFWS, Audubon Society and Ducks Unlimited websites all have bird counts that reveal over a billion bird species annually travel the Pacific Flyway with many stopping for rest, residency and breeding during their North to South and South to North travels in the Sacramento Region.

3. The 1918 Migratory Bird Treaty Act is the Federal Nexus for analysis of this proposed project and requires a formal Biological Opinion by the US Fish & Wildlife Service. There are federally listed Endangered Species Act migratory species that transect the proposed site that both winter and breed at the Stone Lakes National Wildlife Refuge and the Cosumnes River Wildlife Preserve. The DEIR alludes to potential bird strikes of the building which would require Take Permits by both USFWS and CDFW, necessitating Formal Biological Opinions by both Responsible Agencies. While the DEIR cites information from USFWS dated 2007, that data is stale due to the passing of 13 years. Stale Data is no substitute for recent Biological Surveys.

Sincerely,

Dr. James W. Reede, Jr.
s/ Dr. James W. Reede, Jr.

As a resident of Elk Grove and a homeowner who would be directly affected by the California Northstate University Medical Campus proposal, I appreciate the opportunity to review and comment on the project DEIR. I have been actively seeking to educate myself about this proposal, which has been a challenging task because of a lack of transparency on behalf of CNU and consistently inconsistent “facts” presented by the organization. I oppose the project and request the following concerns are addressed.

TRAFFIC
o The community surrounding the current Stonelake Landing shopping center does not have a high walkability score. Therefore, this project would negatively affect the community’s access to commercial services within walking distance and would increase the community’s reliance on vehicular transportation to access similar services, which does not follow the vision of the City. How is/will this projection be factored into traffic studies and air quality analyses performed for the DEIR?

o The traffic study was performed during a pandemic, which forced the majority of the population to stay at home. Therefore, the results relating to traffic impacts do not adequately reflect patterns of vehicular traffic during non-pandemic times and the findings are insufficient. How will/does this alter the findings of the current DEIR’s traffic study?

o The impact of construction on Elk Grove Blvd. from I-5 to Franklin Blvd. must be addressed more thoroughly, as this is a main route for countless residents to get to local shopping centers, community services and their homes. This construction would also create an impediment for emergency vehicles and residents driving to the Dignity Health hospital, the first hospital to be approved and completed in Elk Grove at Elk Grove Blvd. and Wymark Drive. Heavy construction would likely create traffic delays that could mean the difference between life and death for those en route to Dignity’s full-service hospital. Where/what are the projections for this significant impact in the current DEIR traffic study?

ENVIRONMENTAL/WILDLIFE REFUGE
According to CNU’s submitted plans, the height of the main hospital would be 12 stories with a mechanical penthouse and a helistop pad. An additional patient tower would be 7 stories in height starting at the fourth floor of the hospital podium. This directly conflicts with Elk Grove’s long standing regulations of having no building exceed 4 stories in height. Combined with Gov. Gavin Newsom’s recently signed mandate to protect 30% of California’s land and coastal waters by 2030, in part through the restoration of wetlands, CNU’s project is contrary to several governmental directives.

o The facility would interfere with the migratory pattern of birds flying to and from the refuge. The DEIR does not sufficiently address this issue so how/when does CNU intend to conduct more research on this subject?

o Helicopter noise output to nesting areas based on flight patterns must be researched extensively, regardless of the frequency of helicopter use. Restrictions for both songbirds and listed species must be exercised. The DEIR does not sufficiently address this issue so how/when does CNU intend to conduct more research on this subject?

o Though there is existing research regarding bird strikes in relation to airplanes, studies need to be conducted extensively to address bird strikes in relation to helicopters. They function very differently from each other and, therefore, such study results should not be interchangeable. Furthermore, relying on outdated data and data procured from sites that differ greatly in comparison to the CNU site should not be included in the study results. The DEIR does not sufficiently address this issue so how/when does CNU intend to conduct more research on this subject?

o Several basement level structures are proposed by CNU. However, with its close proximity to the Stone Lakes National Wildlife Refuge, as well as wetlands that provide the area with additional protection from flooding, an extensive engineering study should preclude any such structure from being built to ensure the safety and sustainability of the natural environment. The DEIR does not sufficiently address this issue so how/when does CNU intend to conduct more research on this subject?

o Currently, the DEIR presents an inaccurate reporting of GHG emissions, as carbon credits, assumed through AB 900 status, are used to offset true quantities. CNU’s AB 900 status is due to expire at the end of 2020 and the project is not estimated to come before the city council until 2021. Please explain how actual emissions will affect both adults and children in the area, and report the actual quantities sans AB 900 certification.

PROXIMITY TO RESIDENTIAL COMMUNITIES OF STONELAKE, LAKESIDE AND LAGUNA WEST
The CNU project would rely solely on immediate entrances and exits located on West Taron Drive near Elk Grove Blvd. Visitors wishing to avoid excessive congestion at the corner of West Taron Drive and Elk Grove Blvd. would have an alternative route on Riparian Drive, exiting through to Elk Grove Blvd. on one of only two other main arteries in the Stonelake community.

o The community of Stonelake has only three main arteries for entrance and exit that are used by the community’s 1400+ residents. Additional traffic would be unsustainable and dangerous. How will the project address the residential community’s needs for access to and from Elk Grove Blvd.?

o There are several homes within 500 feet of the proposed complex. Not only would their privacy be compromised, but they would likely be subjected to an overflow of parking on their residential streets. Only one parking space per two students in the dormitory is allocated. Yet many students will have their own vehicle and parking on the CNU site will be insufficient. How will CNU safeguard the residential community’s established privacy, as well as discourage an overflow of parking due to insufficient dormitory, college and hospital parking?

o If this project were approved, the noise and debris from CNU’s proposed project, both during and after construction, would have a negative impact on local residents. As construction is projected to take place over a period of roughly ten years, this will be a significant detriment to homeowners who work during non-business hours, residents who suffer respiratory illnesses, citizens who are self-employed and work from home, as well as nearby schools and established businesses. How will CNU safeguard the residential community’s health, well-being and livelihoods given these immitigable factors?

o Currently, the DEIR presents an inaccurate reporting of GHG emissions, as carbon credits, assumed through AB 900 status, are used to offset true quantities. CNU’s AB 900 status is due to expire at the end of 2020 and the project is not estimated to come before the city council until 2021. Please explain how actual emissions will affect both adults and children in the area, report the actual quantities sans AB 900 certification and clarify how CNU has arrived at these answers.

o Medical waste (from both the hospital and the “wet labs” that are being envisioned) would be extremely dangerous to residences and nearby schools. Please explain how this will affect both adults and children in the area, explain emergency plans in case of a biohazard incident, and clarify how CNU has arrived at these answers.

o Federal Highways poses stiff restrictions on helicopters flying over state and federal highways. Ingress/egress over residential communities and highways are strictly regulated. Thus, dictated approach patterns are in question. Please address how CNU will abide by these regulations and ensure that they are adhered to.

o CNU has presented the option of hiring off-duty police officers to provide extra security on-site. This is basically an admission that their project will lead to increased crime. However, as extra personal security would protect the CNU site, it would not be obligated to protect the surrounding residential neighborhoods to which such crime would be off-put. Please explain how CNU plans to ensure the safety of nearby residential neighborhoods that may suffer from increased crime due to their project, aside from the private security CNU is proposing for its project site. Additionally, please clarify how this will be paid for.

FLOODPLAIN ISSUES

The area where CNU is proposing to build their medical complex is within a 200-year floodplain and without an Urban Level of Flood Protection. Local levees provide a 100-year level of flood protection for the area, but after Stonelake Landing was developed, California enacted Senate Bill 5 in 2007, requiring new or reconstruction projects to have an “Urban Level of Flood Protection”. Elk Grove complied with those requirements in July 2016. The General Plan SA-14 states, “the City shall locate, and encourage other agencies to locate, new essential government service facilities and essential health care facilities outside of the 100-year and 200-year flood hazard zones, except in cases where such locations would compromise facility functioning.” In addition to requesting that the General Plan is amended to allow such a facility in a 200-year floodplain, CNU’s submission indicates they would raise the first floor of the hospital building by 7 feet to mitigate. This is an irresponsible workaround.

o Should a natural disaster occur in the form of flooding, which is a likely inevitability due to climate change in recent years, entry and exit would be impeded by flood water. Those inside the hospital would be trapped and those seeking emergency service would be turned away, creating even more of a hazardous situation. Please explain how CNU plans to mitigate these potential events.

o This medical complex would directly contradict previous safety amendments that require government services and essential healthcare facilities to be placed outside of a 200-year floodplain. Please explain why CNU believes they have justification for the changing of these safety amendments when the situation would be moot if CNU chose an alternate location for their project.

o According to a recent study, since the Sacramento East Levee was decertified, a breach to the nearby levees must be assumed. In order to take the West Elk Grove areas outside of the 200-year floodplain, extensive and expensive levee work must be performed. This includes raising the levees by 3 feet or, in cases where that is not an option, building a 3 foot floodwall atop the existing levees. Why does CNU believe this type of proper mitigation does not need to take place and be completed prior to CNU’s project being approved? Additionally, please clarify how this will be paid for.

o Clearly, the proposed project is in an area prohibited from this type of development. Also, on July 24, 2019, a City Staff Report on the 200-year flood plain study acknowledged that Stonelake Landing and nearby areas in West Elk Grove were the only parts of the city to have this problem, and that there are no current plans to remediate at any time parallel to the planned construction of this project. Please explain why CNU believes the current proposed site is still the best location for this project, in spite of the above-mentioned findings.

SIGNIFICANT AND UNAVOIDABLE IMPACTS

The DEIR summarizes that implementing the project would result in the following significant and unavoidable impacts:

• Impact 3.1-1: Substantially Degrade the Existing Visual Character
• Impact 3.1-3: Create a New Source of Substantial Light or Glare That Would Adversely Affect Day or Nighttime Views
• Impact 3.2-3: Result in a Net Increase in Long-Term Operational Criteria Air Pollutant and Precursor Emissions That Exceed Sacramento Metropolitan Air Quality Management District (SMAQMD)-Recommended Thresholds
• Impact 3.11-1: Create Construction-Generated Noise
• Impact 3.11-4: Create Ambulance Siren Noise
• Impact 3.15-1: Environmental Impacts from Expansion of Infrastructure
• Impact 4-1: Contribute to Cumulative Visual Character Impacts
• Impact 4-2: Contribute to Cumulative Light and Glare Impacts
• Impact 4-5: Contribute to Cumulative Long-Term Operational Criteria Air Pollutant or Precursor Emissions
• Impact 4-16: Contribute to Cumulative Groundwater Impacts
• Impact 4-18: Contribute to Cumulative Construction Noise Impacts

Please explain why CNU finds these significant and unavoidable impacts to be justified.

PROPOSED PROJECT COMPARISON PROVIDED FOR CONTEXT

The proposed CNU Project is aggressively measured by almost any development dimension. CNU is taking an aggressive position on their application for entitlements. The combination of high elevation and high density is 2X Dignity Health’s proposed project and, as a result, has a higher environmental impact. To understand and contrast what CNU is proposing, the table below summarizes the project compared to Dignity Health’s proposed Elk Grove and Folsom Ranch Medical Centers.

Project Site -- Acres-- Height-- Beds-- SQFT (total)-- FAR--

CNU -- 24.4-- 11 Fl/257 ft-- 400-- 1,350,000-- 1.27

Dignity Health Wymark -- 27.9-- 6 FL/120 ft-- 330-- 789,429-- .65

Notable observations when comparing the two projects include:

• Site: The land area for both projects are basically comparable in size.
• Height: CNU is asking for 11 floors and maximum height of 257 ft, compared to Dignity Health’s 6 floor 120 ft height.
o Implication: CNU is asking for a very aggressive entitlement, including more than twice the allowable height that Dignity was able to get for either project. How/why is this justified by CNU?

• Beds: CNU is asking for 400 beds over 10 years compared to 300 and 330 for Dignity’s planed 20-year project build out.
o Implication: CNU is likely overbuilding in comparison to demographic demand. Although not documented in the DEIR, it implies that the project is creating more environmental impact than is justified based on demand for services. How/why is this justified by CNU?

• Total Size: In addition to beds, the CNU project is adding multiple buildings totaling 1.35M SQFT, or 1.7 X Dignity Elk Grove.
o Implication: CNU’s project has basically twice the environmental impact. How/why is this justified by CNU?

• Floor Area Ratio: FAR is the ratio of building area to land area. This is used to determine the overall density of the project. As shown, CNU is basically twice as dense as Dignity Health’s proposed hospital.
o Implication: CNU is asking for 1.27 sq. ft. of building area for each sq. ft. of land area in their project, creating a high-density land use which implies a high environmental impact. How/why is this justified by CNU?

SIMILAR ISSUES WITH PROJECTS THAT PROPOSED A MUCH SMALLER FOOTPRINT AND FEWER SIGNIFICANT AND UNAVOIDABLE IMPACTS

On March 21, 2019, the Elk Grove Planning Commission denied a plan for a Buddhist Monastery in a rural northeast area of Elk Grove. Per the Elk Grove Citizen (http://www.egcitizen.com/news/planning-commission-denies-buddhist-monastery-plan/article_b8090834-519d-11e9-94a0-cb82fb3db432.html):

"The project proposal called for the use of about 700 square feet of assembly space for religious gatherings in an existing building on the five-acre property…. The local Buddhists intended to conduct typical gatherings with 40 to 65 people, as well as five or fewer special events per year, with about 75 to 150 people per event. It was also proposed that an existing 1,440-square-foot residential building maintain its residential designation. As required for assembly use, the project also would have included a new parking area, landscaping and reduced illumination levels; as well as a masonry screening wall, with a minimum height of six feet, to lessen noise levels, the transmission of light and dust and the visual impact of the site. City Planner Matt Dias told the commission the project’s lighting would have been “not as bright or glaring than normal commercial settings.” The screening wall would only have been required to be constructed along the assembly and parking areas, and not along the entire property boundary. The applicant would also have been required to have Campbell Road improved from the project’s proposed main entrance to Elk Grove-Florin Road. A section of road would have needed to be reconstructed and widened to 20 feet to accommodate emergency vehicles and increased traffic from the regular religious gatherings and special events."

The footprint of this proposed project, as well as its effects on traffic, noise level and nearby residential neighborhoods, were miniscule in comparison to the proposed CNU project. However, the following comments were offered by the various planning commissioners when justifying the denial of the Buddhist Monastery project.

o The project would “add too much to that road, too much to that quarter.” - Commissioner George Murphey

o (Similar to traffic exiting I-5N to Elk Grove Blvd. near the CNU site,) regarding making a right-hand turn after driving over railroad tracks, “There are a few places around Elk Grove that drive me nuts, because it is difficult to make a right-hand turn (without) nearly getting rear-ended, and it is extremely frustrating to me.” - Commissioner Kevin Spease

o Saying that the monastery project would be “shoehorning” a particular use into the residential area, “The thing about conditional-use permits, it is always a paramount thing for me is the character of the area. Conditional use has to comport with the character of the area, and I am afraid this one does not.” - Commissioner Frank Maita

With an even larger footprint, a much more drastic difference from the existing character of the area, more severe significant and unavoidable impacts, and a much closer proximity to residential neighborhoods, how can CNU determine that the above statements by the Elk Grove Planning Commission do not or should not apply to the CNU project?

The California Northstate University Medical Campus proposal and DEIR are full of red flags, glaring inconsistencies and complete disregard for the wellbeing of the communities in West Elk Grove and Elk Grove as a whole. This project would be shoehorning a particular use into a residential area for which it was never intended and for which it is not safe. It will needlessly cause the destruction of several cherished small business. It will upset the delicate balance of nature and humanity. It will pose extreme financial risk to the City. It will destroy the character of the area. The DEIR is woefully inadequate and if considering a project of this magnitude, further detailed studies must be completed. For all of the reasons stated in this letter, and as an Elk Grove/Stonelake resident who would be greatly and detrimentally affected if this project came to fruition, it is my hope and my strenuous urging that this project be denied, and that the City Council’s goal of serving as wise and responsive stewards of fiscal, physical and natural resources remains intact.

Sincerely,
S. Anderson

There are several issues with the EIR that have been addressed as SU- significant and unavoidable. However, many of these issues are unavoidable by either moving the project or changing the scale of the project. The SU measures will affect the quality of life of the residents in West Elk Grove and this is a significant impact.
Impact 3.1-1: Substantially Degrade the Existing Visual Character and Impact 3.1-2 Consistency with Regulations Governing Site Design and
Architecture and - there is no other building in EG that has this size and character. The building out scales anything in West Elk Grove especially the housing developments that surround it. What other options are there with respect to the scale of this building and how it will impede the visual character of the Stonelake and Lakeside neighborhoods. This is mitigable- the EIR is treating it as it is not. There should be many options that can address this and why is not being addressed.

Impact 3.1-3 Create a New Source of Substantial Light or Glare That Would Adversely Affect Day or Nighttime Views- gain why are other options not being addressed. The scale of the building is out of proportion to the home surrounding. there will be a shadow casted for several hours a day during the winter months on the West Lakeside homes. many of which have solar. How ill this be addressed. Why is the scale of the project not offered as a solution to this issue.

Impact 3.2-2: Cause Construction-Generated Criteria Air Pollutant or Precursor Emissions to Exceed SMAQMD Thresholds - large excavation site such as this will create a lot of dust. watering two times day will not be enough to prevent the amount of dust that will be produced during the excavation. The noise with pile drivers is not addressed. Why? also not addressed is the impact of 1500 trucks on the corner of Wet Taron and EG Blvd. Is this intersection capable and rated to handle construction traffic safely and without significant disruption to the existing neighborhoods. Can trucks maneuver the right hand turn from EG to West Taron? Will Riparion, a residential street, be used as an alternative rout during the construction phase? What plans are in place to address that this street be maintained for residential travel. How will traffic be impeded during the construction and replacement of sewer lines that have to be tied in from East Taron to West Taron down Riparion. No traffic study was done on this street to address the use of this as a thoroughfare alternative to those who do not want to wait in the traffic existing on EG Blvd. The city traffic engineer has stated that EG Blvd and Laguna Blvd are not able to handle any increase in traffic due to no space to increase lanes. How will adding a turn lane onto EG Blvd from Franklin reduce this traffic? Will there be lanes added into the green space on EG Blvd from Franklin to West Taron?

Impact 3.2-3: Result in a Net Increase in Long-Term Operational Criteria Air Pollutant and Precursor Emissions That Exceed SMAQMD-Recommended Thresholds- since the project will increase this and even with the mitigation efforts in place. it is stilled deemed SU. How will this impact persons in sensitive groups such as COPD and and other respiratory illness, what mitigation is possible that will reduce the impacts on the quality of life of the residents surrounding the project that live in the adjacent homes and how does this affect the wild life preserve that surrounds the home and the projects.

there are many issues with the Wildlife Preserve that have not been addressed including species that use the Pacific Flyway for migration purposes. The mitigation efforts to reduce the impact on these species in not adequately addressed. Including the height of the building that will lead to collision of the birds with the building. Why is this not an issue with the height of the hospital when it determined the height of the hotel across the street. Why was height not considered as a mitigation factor?

Impact 3.11-1: Create Construction-Generated Noise- construction is slated to be completed over 10 years. Although there are mitigation efforts described, none address the quality of life of residents who will see increased traffic, increased issues related to street parking, increased dust and noise, All seem to be accepted by the EIR to be part of the project. What other options are available to mitigate the disruption to the residents surrounding the options? Ten year projected time line is long time to live through a significant project that borders the community and will affect traffic and safety of the residents. Yet, there are many gaps with respect to the residents. I believe, although inadequate, the birds received more considerations than the residents.
Impact 3.11-1: Create Construction-Generated Noise- how will the vibration from the pile driving affect the homes that border the project. Will it produce structural damage to the homes? How will the noise/vibration from the pile drivers be reduced so the residents who work non traditional work hours such as health care workers will not be disturbed?

This residential community was not designed to handle such a large project on a small site. There needs to be reconsideration that this project needs to be moved.

Amrit Sandhu

Hello! Thank you for allowing residents, such as myself, the ability to comment on the draft EIR for the CNU Medical Center Project.

I have lived in Stonelake for nearly 19 years now and it has become the family-oriented community that I had hoped it would become. We bought our home here to raise our two children and because of the community surrounding it. Not only were the clubhouse, numerous parks, walking trails, and access to the Stonelake Wildlife Preserve enticing elements of this "Master Planned" community, but also the planned retail around it. As we are all well aware, the recession in the early 2000's significantly impacted retail growth in all of Elk Grove. The primary shopping center in question was completed just before the recession hit and yes, it did sit fairly empty for quite some time - but not unlike many other shopping centers in the city. In recent years, it saw a steady increase of new businesses - and good ones! Unfortunately, just a year or two later, CNU bought the shopping center and decided it was going to tear it down to build this hospital. It has essentially forced out the majority of the business tenants to date and then they get to claim that it is a dying, empty shopping center. Well, it is dying because CNU is killing it. But all of that is neither here or there, for this statement on the EIR.

I vehemently oppose this project for the many reasons that have already been stated:
1. It is proposed to be built in a 200-year flood plain. Should a disaster happen, the fuel tanks and other chemical waste will just flood the area, including the wildlife preserve. The emergency evacuation of the hospital will cause massive backups for the residents of Stonelake to get out of their neighborhood, as there are only 4 primary ways to get out of the development. Two of these would be immediately used by the thousands of employees, patients and emergency vehicles, leaving just 2 entrances for the Stonelake residents. Plainly, this puts lives at risk.

2. The draft EIR inadequately addresses the impact on the wildlife preserve. Please note that CNU is a hospital without an affiliation, meaning they will cater primarily to Medicare/Medi-Cal patients as well as patients without insurance. Typically, this encompasses a large homeless population. As unfortunate as it is, one can easily conclude that homeless patrons of the hospital will camp nearby....yes, that means in the wildlife preserve. The draft EIR fails to take this into account.

3. The helicopter issue is a major issue, beyond noise. Bird strikes will be common. If not, that means that the migratory birds flight paths will be unnaturally altered. As far as I am concerned, I don't need to see a helicopter crash within 500 yards of my home.

4. The risk of wetlabs next to a wildlife preserve should be easily seen as an extreme concern. While many mitigations could be made in an attempt to minimize any issues, the fact is that, as a human population, we have been grossly inept at ensuring underground pipes/storage are free of failure. In addition, there are numerous reports about the inability of these types of facilities being able to manage their chemical waste. Again, all next to a wildlife preserve and Elk Grove residents that rely on groundwater?

5. Size. Oh, the size. While the draft EIR clearly states the dimensions of the building, I cannot begin to imagine having a structure that is LARGER than the California State Capitol building on that site. It will not be viewed as a beacon of progress, rather it will be seen as an eyesore....and that's if it even gets to be completed (but that's an entirely other issue). How many single family homes are directly across the street from the state capitol? Just a thought.

6. CNU continues to state (both in person and in print) that this hospital will decrease wait times for those in need. However, excluding the neighborhoods West of Franklin Boulevard, where are all of these people that will experience faster and more convenient service? There are little to no residents south of Elk Grove Boulevard on the I-5 corridor until you hit Lodi. Even then, there are not many. Most are still near Highway 99. To the north, most residential homes don't appear until Greenhaven (but soon to be Calvine/Delta Shores). Still, the amount of residents that would benefit? Minimal. With Dignity's hospital located more centrally, the majority of Elk Grove residents will experience much faster emergency service there. The majority of Elk Grove's population is closer to Highway 99. It would actually take LONGER for an Elk Grovian living near the center of the city to get to the proposed hospital.

7. I vehemently object to CNU's political tactics and lack of transparency. Even in the draft EIR, there are several numbers that seem to be inflated or are quoted from unreliable or inexperienced resources. The number of jobs, the number of ambulance incidents, the number of helicopter incidents....all from sources that have little to no experience projecting for a project of this magnitude. The rudeness of their spokespeople, their refusal to have a real conversation with the residents of the area, their "donations" to the mayor, their "care" for their business tenants.....all shady.

Lastly, I just want to say that I am not anti-hospital. I would love for Elk Grove to have multiple hospitals. Heck, I may not even oppose a hospital being build on the proposed site. BUT I don't understand why such a large hospital that is proposed by a group that has ZERO experience running a hospital is being so strongly supported. Just having ANY hospital isn't necessarily a good thing. Having the RIGHT hospital placed in the RIGHT location for all of Elk Grove with EXPERIENCED administrators and staff running it is what our city should be pursuing for its residents. Anything else is just political desperation without the true care for what our city's residents deserve.

Thank you.

As a resident of Elk Grove, I strongly oppose the building of the teaching hospital at their proposed location off of Elk Grove Blvd near I-5. Not only will it create light and sound pollution permanently for residents in surrounding neighborhoods, but it will have an adverse impact on the surrounding wet lands and wildlife reserves. In addition, the proposed location is on a 200 year flood plain. While there seem to be plans to ensure the hospital is secure and protected, this puts the nearby residents at risk by exposing them to potential hazardous waste.

To whom it may concern:

I strongly oppose the project as described within the Draft Environmental Impact Report. With many significant and unavoidable impacts, and it’s proximity to Stone Lakes National Wildlife Refuge (SLNWR); this project will negatively affect the surrounding area. I urge you to oppose this project at its current location and to support a new project at the proposed alternative site at the Lent Ranch Marketplace.

Noise pollution caused by construction, as well as siren and helicopter noise during hospital operation, will negatively impact wildlife at the neighboring SLNWR, as well as the residents living in neighboring communities. Light pollution will permanently degrade the quality of habitat at SLNWR. The mitigation measures proposed are inadequate to truly minimize the tremendous impact this project will have on the surrounding wildlife habitat.

Again, I urge the city to oppose this project at it’s current location. Please consider the alternative site at Lent Ranch Marketplace.

Thank You,

Brad K. Compton

Hello to whom may concern.
I've spent many years studying and working with my peers at the Stone Lakes Wildlife Refuge. This is a wonderfully diverse place that has been established to help preserve wildlife of many species. The bird population is massive and I've spent time studying birds with my school doing bird banding. This area is hugely important habitat and also provides great data on the birds of North America. The fact that a huge medical center is being planned to be established is very disheartening. The wildlife that lives very close to where this facility is planning on being built is very sensitive to the loud noise pollution, people and other human impacts that will come along with it. It does not seem reasonable to to impair such an important community that people have spent countless hours establishing and so much money working to build/upkeep. As a member of the community who has a deep connection and understanding of the ecology present at Stone Lakes Wildlife Refuge, I just cannot stand and let it be ruined by a project that can be relocated to a less impactful location. There has already been a huge shopping center built near where Stone Lakes is and I cannot imagine that adding more human impacts to this area will help the local ecology at all. Thank you for taking time to hear me out as a community member and I hope that these points will be considered in the planning process of the medical facility.