AEL Comment Letter on Placer County’s Sustainability Plan

The Alliance for Environmental Leadership is a coalition of community influencers and organizations determined to reframe the way our community grows and is governed through citizen advocacy, environmental leadership and by amplifying the voices for social justice.

Our 14 partner organizations have reviewed the following comment letter on the Placer County’s Sustainability Plan and endorse it, with the exception of California Native Plant Society, Redbud Chapter (CNPS), which supports the letter in concept, but is precluded from signing on because the letter fails to identify consequential connections specific to California plants as required by CNPS organizational policy; therefore CNPS will submit an independent comment letter specific to issues related to native plants, their habitats and as part of a larger ecosystem.


September 5, 2019


Angel Green, Senior Planner
Chairman Moss and Members Placer County Planning Commission
Chairman Uhler and Members Placer County Board of Supervisors
acer County Community Development Resources Agency
Auburn, California 95603


Dear Ms. Green and Members of the Planning Commission and Board of Supervisors:

The world is in a race against climate change. Will we shift away from our fossil fuel economy within 5 -11 years to avert the climate catastrophe predicted by the United Nation’s Intergovernmental Panel on Climate Change? We emphatically urge you to act on our behalf to avert the impending catastrophe.

As with many decisions, the decision regarding adoption of a Placer County Sustainability Plan that is powerful and effective, will likely turn on decision-makers’ understanding of simple economics; even more so than climate change concerns.  The bottom-line questions will be: Will the Placer County Sustainability Plan (PCSP) cost developers or consumers money?  How much will the 2019 standards add to the cost of a new home?

The answer: On average, if made mandatory, the 2019 PCSP standards will increase the cost of constructing a new home by about $9,500 but will save $19,000 in energy and maintenance costs over 30 years. Based on a 30-year mortgage, the Energy Commission estimates that the standards will add about $40 per month for the average home, but save consumers $80 per month on heating, cooling and lighting bills and add value to the home upon resale. The Building Industry Association (BIA) is requesting that of 110 provisions included in the SP, (104 of which are voluntary), the remaining 6 “mandatory” provisions “go away” to allow for more flexibility. There is no justification for this.  In fact, it will harm the health and welfare of our people and set Placer County up for punditry consequences from the State. We urge the Commission and the Board of Supervisors to make all measures “mandatory” for all development, including ministerial permits (i.e., building permit for a single dwelling).

Those in leadership positions cannot bury their heads in the sand and claim that the whole climate crisis is a “hoax” perpetrated by not only the United Nations, but also 97% of the world’s academic and science community. To do so would be immoral.

We still have a chance to act boldly and aggressively against climate change threats that are close-to-home in the next few weeks – because the County is poised to create a climate action strategy; our “Sustainability Plan”.

Sadly, upon reading the “Plan”, we find that the County fails to seize opportunities to lead us to a safe future where global temperature and CO2 level rise is moderated to sustainable levels. The County is not acting boldly or conscientiously.  What is bold action? Bold action is recognizing that the doubling the population of our County while allowing historic low-density sprawl land use practices to persist is inconsistent with sustainability goals. Doubling the number of cars on our roadways, continuing to implement low density sprawl through our zoning ordinance will create an untenable situation for the people that live here and for the climate. We must use the Sustainability Plan as a roadmap for dramatic policy changes that pivot away from the status quo.

At the onset, bold action is undertaking a wholesale review of the zoning ordinance focused on reducing VMT.  Bold action is embarking on massive investment in rapid transit – of a scale comparable to BART or Sac’s light-rail.   We have the capability to do great and monumental things that will avert a climate catastrophe. Our future is at a tipping point and we must set aside politics and business as usual.  Placer County supports, arguably, the most diverse ecosystem anywhere. It is a critical wildlife corridor for avian and terrestrial species upon which our own lives depend. Species and habitat upon which they depend must be protected as a part of Sustainability Plan goals not only for the species’ survival but because habitat sequestration values are essential components to CO2 reduction.

Placer County is the conduit to the treasure that is the Tahoe region; the through-path for interstate commerce, the hub of California’s tourist engine.  Placer County is the keystone County for the State and climate mitigation action today must be commensurate with our stature in the State.

The proposed SP sputters.  It takes a tiny step when bold action is called for. Reduction strategies are non-existent for existing development, voluntary for 89% of all future development (only 11% of County permits are for projects exceeding 1,100 metric tons of CO2 – the threshold that would require projects to comply with CO2 reduction strategies).  In any case, to keep the rise in global temperature to 2 degrees centigrade, the world must average no more than 2.8 tons of CO2 per person for the next 35 years and then; can no longer use fossil fuels thereafter (or until the atmospheric CO2 dissipates in a few hundred years).

It is common knowledge that CO2 generation per capita in the United States is 20 metric tons per year, compared to the world average of 7 metric tons per year. Prior to finalizing a sustainability program, Placer County should do the research to understand what the contributors are to the US being at 20 metric tons and the world being at 7 metric tons. The Sustainability Plan calls for “actions to reduce the average per capita CO2 generation in Placer County to 6 metric tons by the year 2030 and 2 by the year 2050”. These are hollow promises because the PCSP fails to set us on the path to accomplish these CO2 reductions, either by mandatory community actions or individual actions.

Placer County is obligated to identify the sustainability goals and corresponding actions to accomplish those goals. Those goals need to be equal to or better than State goals.  Please explain why, of the Placer County Sustainability Plan’s 110 climate action goals, 95 are voluntary, eight are potentially mandatory, and six only kick-in if development project exceeds CEQA and is approximately 71 or greater dwelling units or is a commercial project producing over 1,100 metric tons of CO2 a year (which is the equivalent of 2,424,400 pounds of CO2 in a year)?  There is no guarantee that the emission goals of the plan will be met.

Unless you are building a project generating more than 1,100 tons of CO2 annually, it is business as usual under the proposed County Plan and this fact defies the County’s commitment to CO2 reductions. Our community’s welfare and the welfare of our children are at stake.  We demand that the County to do more and do it now.

The Plan fails to consider the ecosystem services contributed by habitat.

The Sustainability Plan calls out the use of the mPOWER program as part of Pioneer Community Energy to help strategies work.  Strategies E-1, E-5, E-6, E-12, E-14, E-15, E-20 and WW-7 all reference mPOWER.

 From the Plan:

“Energy Efficiency Financing: mPOWER

To encourage investments in energy efficiency, Placer County initially sponsored the mPOWER (Money for Property Owner Water and Energy Retrofits) Program for residential and commercial properties.  Now a program of Pioneer, the mPOWER Program provides special assessment financing for energy efficiency and renewable energy projects. Financed amounts are repaid as an amount added to the property tax bill.  The GHG reduction strategies in the PCSP expand on these energy efficiency efforts to support more widespread retrofits of existing buildings.”

 The mPOWER Program is terminating as of December 31, 2019.  The Sustainability Plan should replace all references to this program and have the strategies require a new program be implemented that not only matches the mPOWER Program but lowers the cost of obtaining low-interest loans.  (See New Strategy E-22 below.)

Folloing is the AEL Action Plan for CO2 Reduction and Climate Remediation

Placer County Sustainability Plan comments:

The PCSP forecasts emissions for the calendar years 2020, 2030, and 2050 for consistency with short-term and long-term state reduction targets.

GENERAL COMMENTS: The goals based on the State requirements and the strategies for meeting these requirements are well designed and very comprehensive. The main criticism is that, given the seriousness of the impacts of climate change, they are mainly voluntary with little enforcement. Monitoring is only of County actions and not of all of the strategy actions.  Maybe adding an appendix with a table that calls out all areas by type of sustainability, recommendations, The Plan needs an appendix with a table that calls out all area by type of sustainability, recommendations, and whether mandatory.  

Doubling the County’s population without mandating strong CO2 reduction actions for this growth will not get us to zero carbon and a 1.5 degree Celsius (as the UN Panel on Climate Change states we must in order to avert planetary catastrophe).

The Plan should take into consideration the GHG emissions from consumption of materials brought in to the county, not just those produced within the county.  The Plan should net-out CO2 sequestration loss due to development of green fields and account for the loss of the carbon sequestration losses on an annual net (alongside reported CO2 reductions and annually calculate and make available to the public a analysis of CO2 sequestration values lost to development and on a cumulative basis year to year.  The loss of ecosystem service values (which can be quantified) beyond CO2 sequestration should also be accounted for and reported to the Board of Supervisors and public.

The PCSP should also consider embodied energy. Embodied energy is the sum of all the energy required to produce any goods or services, considered as if that energy was incorporated or ’embodied’ in the product itself. The concept can be useful in determining the effectiveness of energy-producing or energy-saving devices, or the “real” replacement cost of a building, and, because energy-inputs usually entail greenhouse gas emissions, in deciding whether a product contributes to or mitigates global warming.

An effort should be made to determine for each strategy how to make it mandatory. Otherwise the County will not be zero carbon by 2045. This includes making strategies mandatory even for projects not exceeding CEQA thresholds.


There is no required GHG emission target that local governments must adopt. The State guidance presented in the 2017 Climate Change Scoping Plan (Scoping Plan) gives local government the option of adopting a per capita target (emissions per resident) rather than an absolute emissions target (sometimes called a “mass emissions target”). The County will pursue the per capita GHG reduction targets as detailed in this section. The State CEQA Guidelines section 15183.5 direct GHG reduction targets be set so that “the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable,” and that these levels be “based on substantial evidence.”

We understand from previous community workshops on the SP that this was originally the County’s goal, to prepare what is referred to in this section as a “qualified” GHG reduction plan. As you know his section of CEQA requires that the level or target, by which a lead agency establishes for the purposes of covering GHG emitting activities under the plan, must be based on substantial evidence. Because the County utilizes the State’s targets and data from its GHG inventory (Scoping Plan), the County’s plan must demonstrate it will achieve the state’s targets (i.e., 2030 goal) in order to meet the criteria for a qualified plan. The plan, however, falls short of meeting the State’s emission reduction targets. County was not successful. For this reason, there is a recommendation to update the plan every 3-5 years to track both County ops and community-wide emissions to see what adjustments can be made to achieve the 2030 target. For this first version, no future development projects will be able to tier from this document and must conduct their own environmental review.  Why, then, is the County now discussing exempting CEQA projects from SP conformance?

2050 Target 

The Scoping Plan recommends a 2050 per-capita GHG reduction target of 2.0 MTCO2e per person for local governments. Placer County’s unincorporated population is forecasted to be 225,180 people in 2050, which leads to a reduction target of 450,370 MTCO2e. Placer County’s forecasted GHG emissions in 2050 are 2,250,450 MTCO2e, or approximately 10.0 per-capita. Table 3-12 shows the change in GHG emissions between 2005 and 2050, and the reductions needed to achieve the 2050 target. These statements are somewhat misleading.  To call 2.0 MTCO2e per person for a total of 450,370 MTCO2e the reduction target seems to indicate that the amount is how much each person has to reduce their emissions by. But Table 3.12 seems to indicate that the total emissions per person is 2.0 MTCO2e, not the amount of the reduction. The 2.0 MTCO2e goal of total emissions per person does align with the calculations of the amount of fossil fuels for the U.S, that are left to be expended by 2050. Furthermore, there is nothing in the Plan that addresses personal consumption relating to GHG emissions, such less VMT, air travel, diet changes, etc. in order to meet these reduction targets.   Additionally, the State’s goals for getting 51 million electric cars on the road by 2030 and getting to zero net energy are not supported by the SP, because facilitating access to charging stations or retrofitting homes for in-home charging is not supported in the SP.

Reviewing the September 18, 2008 action of the California Public Utilities Commission where they adopted the California Long-Term Energy Efficiency Strategic Plan, with support from the Governor’s Office, the California Energy Commission, the California Air Resource Board, the state’s utilities, local government, and other key stakeholders.

The Long Term Energy Efficiency Strategic Plan is California’s single roadmap to achieving maximum energy savings in the state between 2009 and 2020, and beyond. The Long Term Energy Efficiency Strategic Plan includes four “Big Bold strategies” as cornerstones for significant energy savings with widespread benefit for all Californians:

•        All new residential construction will be zero net energy by 2020.

•        All new commercial construction will be zero net energy by 2030.

Why are we not moving toward compliance?

We propose the following amendments to the Placer County Sustainability Plan

The County of Placer will establish a no-interest loan program for all existing home or business owners wanting to do CO2 reduction retrofits including solar panels, electric adaptations for cars and appliances in garages, charging stations for retail/commercial parking lots, sod and lawn replacement with low-water, drought tolerant native plants among other CO2 reduction measures to be determined by County staff.

The County of Placer will mandate light-colored roofs (which reduce warming and heat island effects) on all new and replacement roofing, requiring installation electric vehicle charging plugs for electric cars and for electric appliances for all new construction, establish that charging stations shall be provided for all new commercial development projects and set a goal for our local energy company, Pioneer Energy, to go 100% renewable electricity by 2030. Pioneer, itself, should be offering programs to incentivize customers.

The County will mandate that every building permit pulled will incorporate every climate mitigation strategy in the Title 24 “Green California” toolbox; (not just for projects of over 71 dwelling units (a project this size generates 1,100 metric tons of CO2 annually)).  The County must list cities and counties in California who have adopted “reach codes”, where going beyond Title 24 is an ordinance requirement. These jurisdictions were required to prepare cost-effectiveness studies as well, which can also be part of the discussion of how to better achieve CO2 reductions.

Putting “Green California” rules in our Building Code now, saves homeowners thousands of dollars each year (annual savings from solar panels alone are over $3100.00 per year per household). To say that Green California toolbox measures add to the “cost” of housing is short-sighted and factually wrong because the measures equate to long-term savings for the end-user – the consumer and protect our common futures something that is unquantifiable. Additionally, the SP fails to identify all the incentives that are made possible for homes built above Title 24 requirements. From the link above: Projects that fall within the scope of an adopted ordinance may be eligible to participate in one or more energy efficiency programs. These programs provide incentives to customers to reduce incremental costs that may be incurred for equipment or measures installed to “reach” beyond the minimum state requirements.

This brings additional cost savings on energy bills to the end user. Cheaper electricity bills also help those who fall in the low to medium income levels, those on SSI. The Building Industry Association Representative who spoke at the Planning Commission on August 22nd, improperly stated that mitigation to reduce GHG is causing homes to “become more expensive and less affordable”. I would expand on this and talk about how these measures, if mandatory, would result in fewer costs as it relates to future energy bills and retrofit costs.

There are many benefits to meeting/exceeding CALGreen requirements. One of the more focal benefits being the cost-savings to residents, as well as home and business owners. National and state average electricity prices are on the rise. Residents and occupants can save money with energy efficient construction and appliances. Single-family homes built with the 2019 Building Energy Efficiency Standards (Title 24, Part6) will use about 7 percent less energy due to energy efficiency measures versus those built under the 2016 standards. Once rooftop solar electricity generation is factored in, homes built under the 2019 standards will use about 53 percent less energy than those under the 2016 standards. Nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades. There are also cost-savings related to new construction. While the 2019 standards, on average, will increase the cost of constructing a new home by about $9,500, they will save $19,000 in energy and maintenance costs over 30 years. Based on a 30-year mortgage, the Energy Commission estimates that the standards will add about $40 per month for the average home, but save consumers $80 per month on heating, cooling and lighting bills. In addition to saving energy and associated energy costs, homeowners can increase the value of their property.

There are a number of funding options available for energy upgrades or for installing EV infrastructure. One example is Energy Upgrade California, which offers up to $5,500 in rebates to California homeowners when they make energy-saving improvements. This program also helps contractors grow their businesses. There are also financing options like GoGreen Financing. This program has $50k in funding for its residential programs, and between one and five million dollars for small business and other non-residential programs; there’s no limit for multi-residential. This funding helps to finance upgrades to HVAC units, insulation and air sealing, appliances, windows, water heating, LED lighting, pool pumps, as well as installation of cool roofs or radiant barriers. There’s also funding available for cities, counties, special districts, and other public entities that have projects with proven energy and/or demand cost savings; the California Energy Commission (CEC) has 3 million dollars in available funds and provides 1% interest rate loans for those that meet this criteria. For EV infrastructure funding in IOU territory, one source is through PG&E. They have a pilot program for installing EV charging infrastructure at multi-dwelling units, workplaces, and public interest destinations. They will also install chargers for fleet vehicles under certain circumstances. For those that qualify, the program will cover the full cost of L2 make-ready installation and provide a rebate of up to 25-100% on charging equipment. These are just a few examples of potential funding sources.

There is also a considerable amount of legislation aimed at expanding or accelerating the implementation of building energy and EV infrastructure requirements, including SB 700, 1072, 1477, as well as AB 2127 and AB32. Please use these references to refute the statements from the BIA.

Placer County shall cooperate with the Placer County Air Pollution Control District, Placer County Transportation Planning Agency, Sacramento Area Council of Government, the State of California and appropriate Federal agencies, Foundations that have enriched themselves off Placer County sprawl to institute a rapid rail system along the Hwy 65 and I-8O corridors between Sacramento and Reno. This rapid rail system will take precedence over all public investment in projects that contribute to VMT.

The County shall undertake a comprehensive rezoning program designed to eliminate further single family sprawl and concentrate development around the new rapid rail lines and protect the remaining green fields that are critical carbon sinks and methane banks.  AEL estimates that by the year 2026, unless a comprehensive rezoning program is undertaken, land allocated for development in all the Community Plan areas will be exhausted, used-up; setting up a scenario causing remaining greenfields to be lost to development.  This land use pattern is not sustainable for air, water, and life.

Placer County shall undertake a comprehensive CO2 reduction education program incorporating:

1) Educational Billboards on Highways 65 and I-80. The Billboards will educate people locally and also be viewed by the millions of tourists to pass through our Country annually (leaving their CO2 behind)

These Billboards will inform drivers that a) VMT are the largest single contributing factor in CO2 generation and air pollution in Placer County. b) Each gallon of gas we burn adds 20 pound of CO2 to the atmosphere, c) Use public transit to protect our common future d) cost comparison of operating an electric car and gasoline engine car per year d) comparing CO2 generation of an electric car v a gasoline engine car e) etc.

Placer County shall amend the transient occupancy tax provision to include the cost of carbon offsets (i.e, air travelers).

Placer County shall require ski resorts to include a carbon-offset fee (calculated to reflect CO2 generation from point of origin) onto the cost of each ski ticket or pass. Energy provider, Liberty Energy, who provides electricity to the ski resorts, has stated that they are moving towards achieving zero net energy in the future. Pioneer should do the same.

2) Providing to the public, business and development community CO2 reduction educational materials whenever permits are issued, in annual tax bills, in County newsletters, flyers and other digital or hard copy correspondence with the public.


Strategy GHG-1: Establish a carbon offset program that identifies and funds GHG reduction and supports climate adaptation programs or projects, primarily in the unincorporated county and the region. GHG reductions from these programs and projects shall be real, permanent, quantifiable, verifiable, and enforceable. Programs shall primarily serve the residents and businesses of Placer County. The carbon offset program would be available to project applicants to mitigate GHG emissions for projects in the unincorporated county that exceed the County Air Pollution Control District’s project level GHG emissions thresholds after the application of all feasible onsite mitigation strategies are applied to project design and operation. Strategies and projects identified in the PCSP would be eligible for funding from the program. The program should be compatible with and leverage existing County and regional partnerships and programs that reduce GHG emissions. Development of this program should be mandatory instead of voluntary. Otherwise, there is no guarantee any actions will be taken to meet GHG emissions goals.

Carbon offset programs allow communities to “cancel out” some of their GHG emissions by paying to fund other efforts that reduce GHG emissions. Using offset programs, communities can reduce emissions by supporting a wide number of one-time and ongoing GHG reduction actions under the umbrella of a single effort. These actions and their associated reductions must be tracked and managed in detail and located in Placer County so that the reductions can be well verified. Carbon offsets still allow CO2 to be produced.

Strategy E-1: Facilitate a transition to electricity as the primary energy source for residential, mixed-use, commercial, and office buildings. Do not require installation of new natural gas infrastructure or connection to existing natural gas infrastructure to serve new development. Change building codes to enforce this.  Explore requiring greenfield residential construction to be all-electric, except as may be needed for public health and safety. Mandate.  

There are many benefits to meeting/exceeding CALGreen requirements. One of the more focal benefits being the cost-savings to residents, as well as home and business owners. National and state average electricity prices are on the rise. Residents and occupants can save money with energy efficient construction and appliances. Single-family homes built with the 2019 Building Energy Efficiency Standards (Title 24, Part 6) will use about 7 percent less energy due to energy efficiency measures versus those built under the 2016 standards. Once rooftop solar electricity generation is factored in, homes built under the 2019 standards will use about 53 percent less energy than those under the 2016 standards. Nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades. There are also cost-savings related to new construction. While the 2019 standards, on average, will increase the cost of constructing a new home by about $9,500, they will save $19,000 in energy and maintenance costs over 30 years. Based on a 30-year mortgage, the Energy Commission estimates that the standards will add about $40 per month for the average home, but save consumers $80 per month on heating, cooling and lighting bills. In addition to saving energy and associated energy costs, homeowners can increase the value of their property.

Strategy E-4: Require new residential, office, and commercial development, as mitigation for discretionary projects exceeding applicable GHG thresholds, to comply with CALGreen Tier 1 standards and accelerate ZNE in new construction. Explore density bonuses and permit streamlining for discretionary projects that implement CALGreen Tier 1 and Tier 2 measures, located within an urbanized area, consisting of no more than 71 residential units and is not more than four acres in total area. Change limits. Require retrofitting of buildings that are not in compliance with zne standards.

Strategy E-7: Create incentives to construct new nonresidential buildings to ZNE energy efficiency standards in advance of the 2030 mandate, and a second class of incentives to support new nonresidential construction that does not achieve ZNE but exceeds minimum standards. These standards only offset electricity use and should be met beyond minimum standards. All-electric non-residential buildings should be required where feasible.

Strategy E-8: Encourage businesses, nonprofits, and other nonresidential property owners and tenants to replace old equipment with more energy-efficient models. Only energy efficient equipment should be allowed for replacement.

Strategy E-10: Work with landlord groups and property management groups to increase adoption of modern appliances in residential rental properties. Legal support should be given to tenants who demonstrate need for new appliances. 

Strategy E-11: Partner with APCD to develop and implement programs to replace old wood- and propane-burning space heaters with modern, efficient, and low-carbon appliances where feasible, while ensuring that access to alternative heating is maintained. Efficient wood burning stoves to be changed to pellet stoves.

Strategy E-12: Support increases in renewable energy generation and storage systems for existing nonresidential structures. Community solar for non-residential buildings.

Strategy E-15: Incentivize new homes to install renewable energy generation and energy storage systems that can fully supply the home’s energy needs, in cases where the required size of the renewable energy system is insufficient to fully meet on-site demand.  Starting in 2020, California law will require many new homes to install on-site solar energy systems. However, these mandatory systems may not be large enough to meet the home’s electrical demand, leaving some households with a still-sizeable energy bill. Placer County can encourage homes to install larger on-site renewable energy systems, capable of meeting most or all of a home’s demand, especially if they are bundled with a battery storage system. Force compliance with 2019 standards. Note: Annually, embodied carbon in housing is responsible for 11% of global GHG emissions and 28% of global building sector emissions.

Require onsite solar PV systems and/or energy storage as mitigation for discretionary projects exceeding applicable GHG thresholds, for new nonresidential buildings exceeding 20,000 square feet. Apply 2030 standards now for all buildings.

Support efforts by the Pioneer Governing Board to decrease the carbon intensity of Pioneer’s CCA program’s electrical supplies as financial conditions allow. Vote to increase renewable energy portfolio to exceed RPS standards.

Encourage the Pioneer Governing Board to purchase electricity from local renewable and carbon free sources as financial conditions allow. Factor in costs to the environment by not doing this. Pass gas tax to cover transportation impacts.

New Strategy:

Strategy E-22: Request that the Pioneer Governing Board consider increasing the proportion of renewable and carbon-free energy supplied by Pioneer’s CCA program and expanding Pioneer’s service territory to cover all parts of Placer County currently served by private utilities.

 Earlier in the document it is stated: “The PCSP assumes no additional increase in the amount of renewable and carbon-free electricity that Pioneer’s CCA program supplies to it customers, beyond the increases mandated by state law, and so there is no increase in GHG reduction beyond those included in the state reductions section.  Additionally, the PCSP assumes that Pioneer does not expand into the Tahoe Basin area.”

The Placer County representative to the Pioneer Board should introduce regulations to the Board that require PCE to exceed the renewable percentage requirements of the state RPS.  All other CCAs in California are exceeding the RPS whereas Pioneer is only committed to just matching the standard.

 Strategy E-24: Provide incentives and opportunities to have residential property owners conduct an energy audit when conducting energy efficiency improvements. Develop an incentive program to reduce the cost of professional home energy audits, especially for lower-income households. Establish fund for this purpose.

Strategy WW-2: Require new development projects, as mitigation for discretionary projects exceeding applicable GHG thresholds, to exceed minimum state water efficiency requirements for new water fixtures. As part of the County’s discretionary and environmental review of projects, Placer County can require project applicants to comply with more stringent water conservation and efficiency standards to further reduce GHG emissions and ensure sufficient long-term water availability. Make mandatory for all projects – not just discretionary ones.

Strategy WW3: Consider offering expedited or reduced-fee permits to major renovation projects that include grey water systems. Make mandatory.

Strategy WW-5: Consider requiring grey water systems as a condition of approval for new developments when appropriate. Make mandatory where feasible.

Strategy WW-6: Placer County can supplement this action by encouraging existing landscapes to reduce their water use through the use of water-efficient landscaping technologies and plants that require little or no additional water to thrive. Bonus for dry landscaping of new and existing lots.

Strategy WW-8: Implement a Purple Pipe Network in new development projects for use of recycled water for irrigation and outdoor purposes. Make mandatory.

Strategy WWW-9: Identify and pursue grant funding to support energy efficiency retrofits at water and wastewater treatment facilities. Require solar panels to offset energy.

Strategy WWW-10: Seek grant opportunities to support the exploration of methane capture technology at the Regional Wastewater Facilities. Require technology.

Strategy T-1-1: Encourage the installation of EV charging stations in high-volume parking lots such as major shopping destinations and employment centers. Electricity must come from a renewable source.

Strategy T1-2: Placer County can help encourage EV adoption by going beyond the minimum state standards, requiring new homes to install the actual wiring needed for an EV charger for new development projects. Make mandatory.

Strategy T-1.3: Require new multifamily residential and residential mixed-use development, as mitigation for discretionary projects exceeding applicable GHG thresholds, to design and install EV-Capable and EVSE Installed Level 2 charging stations as shown in Figure 4-2 and Table 4-6. Require it for all projects.

Strategy T-1.4: Require new office and commercial development with 10 or more parking spaces (including hotels, motels, and restaurants), as mitigation for discretionary projects exceeding applicable GHG thresholds, to design and install EV-Capable infrastructure and EVSE-Installed Level 2 charging stations as shown in Figure 4-2 and Table 4-6. 10 is too high. 1 is right number. Increase required number of charging stations. Need to cover different kinds of vehicles.

Strategy T-2: Support the installation of alternative fueling stations to encourage residents and visitors to transition from high-carbon vehicle fuels, such as diesel or gasoline, to less-carbon-intensive vehicle fuels, such as natural gas, propane, biofuel, or hydrogen. Only allow renewable fuels and no limit on the size of development -71.

Strategy T-3: Encourage new development to provide a mix of land uses and to be located contiguous to existing developed areas and infrastructure to support connectivity and to reduce trip lengths. Electric buses and transit to be required.

Strategy T-5: Partner with incorporated communities and regional agencies to develop bikeways and trails between communities. Include e-bikes.

Strategy T-6: Increase the frequency of Capitol Corridor trips east of Sacramento and explore opportunities to increase the frequency of long-distance Amtrak trains between the San Francisco Bay Area and Truckee. Must be required for new developments to have proper job-housing mix.

Strategy T-7: Support and implement additional trip reduction programs in the Tahoe Basin region. Oppose Squaw valley development.

Strategy T-10: Promote infill development that combines multiple land use types. Density levels in Placer County are not expected to reach the levels where infill development will have a distinct GHG reduction benefit independent of other efforts. Population is expected to double. Infill is what is needed – not new towns.

Strategy SW-1: Explore opportunities to work collaboratively with the Western Placer Waste Management Authority to increase the methane capture rate at the Western Regional Sanitary Landfill to 90 percent by 2030, and work toward an aspirational goal of 100 percent methane capture as economically feasible and as available outside funding allows. Speed up timing of capture.

Strategy SW-4: Explore the feasibility of converting all facility and hauling vehicles to low-carbon fuel types such as electric and compressed natural gas (CNG, preferably derived from landfill gas) if outside funding is available. Compressed natural gas is still non-renewable. Don’t use natural gas.

Strategy SW-5: Explore grant funding to research new methane capture technology and apply for grant opportunities to implement, as it becomes practical and economically feasible, in order to sustain a maximum feasible methane capture rate at the Western Regional Sanitary Landfill. Make mandatory.

Strategy SW-8: Support the development of alternative technologies to derive fuel or energy from waste.  Still add to CO2 if used in vehicles. Use it for heat or electricity.

Strategy AG-1: Work with local growers and farming groups to encourage the reuse of rice straw for other purposes as market conditions allow, such as animal bedding or erosion control, rather than burning the straw or reintegrating it into the soil in advance of cultivation. This item is contradictory. If there is a proposal for preferred action put that as the recommendation. The non-preferred actions of burning and putting into the ground should both be called out as non-preferred. Either stop growing rice, or incorporate residue into the soil.

Strategy AG-2: Encourage farmers to replace old diesel equipment and vehicles with more fuel-efficient models in advance of their engine emission compliance date.  Convert to electric vehicles that are charged with solar panels.

Strategy AG-4: Explore reuse opportunities for cleared forest residue.  Stop open pile burning. Require chipping for biomass. Reduce logging and increase prescribed burns.

Strategy AG-5: In partnership with farming groups, academic institutions, and the Placer County Resource Conservation District, promote ways to conserve fertilizer and other soil amendments while maintaining good soil health and economic viability. No-till farming, and elimination of pesticides.

Strategy AG-8: Explore volunteer opportunities to capture manure and other waste products from livestock operations for energy. Reduce livestock and have frequent movable grazing.

Strategy OR-1: Promote the use of hybrid and alternative fuel construction equipment for new developments and significant retrofits.  Ban sales of diesel equipment. Require electric.

Strategy OR-2: Encourage property owners and landscaping companies to adopt the use of hybrid and alternative-fuel landscaping equipment and promote the availability of incentive programs for new efficient landscaping equipment. Ban non-electric.

Strategy OR-3: Explore opportunities to increase adoption of alternative fuel and more fuel-efficient recreational vehicles, including boats and snowmobiles. Require electric off-road vehicles.

Strategy GO E-1: Incorporate advanced energy-efficiency designs, renewable energy systems, and energy storage in new County construction projects at the County owned facilities. Make mandatory.

Strategy GO E-2: Evaluate the potential to develop large renewable energy projects to meet the remaining energy needs at key buildings that cannot install on-site energy systems. Not all buildings are suitable for on-site renewable energy generation. They may have an unsuitable roof shapes or surfaces, structural issues, or shaded areas that prevent on-site renewable energy systems from being feasible. However, the County can still help move these buildings closer to ZNE status by taking advantage of a tool called “virtual net metering,” which allows the energy use from a larger, off-site renewable energy system to be credited to the energy use of these existing facilities. The County currently strives to achieve LEED Silver design standards when retrofitting County facility buildings. Make mandatory.

Strategy GO E-3: Following energy conservation and efficiency strategies, evaluate the potential for onsite renewable energy projects to meet the remaining electricity use at existing buildings. Make mandatory where feasible to save the County money.

Strategy GO E-4: Encourage facilities to improve the energy performance of other existing buildings to support ZNE efforts, including electrification of existing buildings.  Require it for all projects.


Straegy GO E-5: Upgrade streetlights and traffic signals to advanced energy efficient bulbs.  Make mandatory.

Strategy GO E-6: Implement energy conservation and demand-response programs to reduce enery use and costs. Do it now to help the Grid.


Strategy GO E-7: Improve the energy performance of existing County owned buildings to support ZNE efforts. Make mandatory. 

Strategy GO E-9: Explore the feasibility of installing a micro-grid at the Placer County Government Center for backup power and evaluate the feasibility of micro-grids in Tahoe or Foresthill to provide emergency response and economic resiliency. Get the state to finance this.

Strategy GO E-10: Incorporate advanced energy-efficiency features, renewable energy systems, and energy storage in new County construction projects at additional sites outside of the Placer County Government Center, as feasible. Do it for all county buildings.

Strategy GO WW-1: Improve the energy performance of wastewater facilities. Do this to become ZNE.

Strategy GO WW-3: Conserve water through continued water-efficient landscaping on County properties. Remove all turf from county properties.

Strategy GO WW-6: Revise development standards to ensure the use of grey water, recycled water, and rainwater catchment systems are allowed in all zones. Use same standards as set for residential properties.

Strategy GO T-1: Expand the existing light-duty fleet conversion policy with the goal of converting the entire County fleet to vehicles, trucks, and equipment powered by alternative low-carbon fuels, electricity, fuel cells, and/or other technologies as they become financially feasible. Set target to replace vehicles with electric.

Strategy GO T-2: Implement a commute trip reduction program for County employees with a monitoring program and vehicle miles traveled (VMT) reduction goal, as feasible for individual departments. Expand charging. Provide ride-sharing incentive.

Strategy GO T-3: Track options for alternative fuel vehicles and equipment and continue to review options through the Department of Public Works. Require new vehicles to be electric and wireless recharging.

Strategy GO T-4: Replace current transit buses with more fuel-efficient vehicles. Make mandatory.

Strategy GO T-5: Prohibit the idling of on- and off-road fleet vehicles when the vehicle is not moving or when the off-road equipment is not performing any work for more than five minutes in any one-hour period. No problem if all-electric vehicles.

Strategy GO T-6: Implement a bike share at County buildings and campuses for employees to use to go to lunch or a nearby meeting. Do it.

trategy GO T-7: Provide end-of-trip facilities at County buildings. Do it.

Strategy GO SW-1: Encourage Western Placer Waste Management Authority (WPWMA) to research new methane capture technology and apply for grant opportunities to implement, as it becomes practical and economically feasible, in order to sustain a maximum feasible methane capture rate at the Western Regional Sanitary Landfill. Mandate it.

Strategy GO SW-4: Strive to reduce waste production at County facilities. Only offer food that does not use plaster containers or non-compostable utensils.

Strategy GO SW-6: Encourage WPWMA to implement renewable biogas projects, as feasible and economically practical (e.g. outside funding available), including those that use methane captured at landfills in the County. Must produce less methane. Must capture it all if used to create electricity.

Strategy GO SW-8: Encourage facility operators to improve the energy performance of solid waste facilities as economically feasible and as outside funding becomes available. Require solar panels to offset electricity as well as better LED lighting.

Strategy GO AG-1: Transition landscaping equipment to hybrid and alternative-fuel technology as feasible and encourage businesses in Placer County to do the same. Do it.

Strategy GO AG-2: Identify and plant trees for County landscaping projects that have a naturally high carbon-sequestration rate, taking into consideration the suitability of the tree species for the area. This strategy is supportive. Emissions associated with biomass are not included in the inventory, so reductions in these emissions cannot be counted. Forest carbon sequestration should be included.

Strategy GO AG-3: In strategic locations that can support additional trees without detriment to forest health or public safety/structures, establish a goal of annual net tree planting, considering removals or losses. Emissions associated with biomass are not included in the inventory, so reductions in these emissions cannot be counted. Forest carbon sequestration should be included.

Strategy GO ED-1: Use local and sustainable building materials for all new County buildings as feasible. Use forest certification standards for wood products.

Strategy GO ED-3: Establish budgeting and administration practices to support the Placer County Sustainability Plan. Budget should include funds to support all of the sustainability strategies.

Strategy GO ED-4: Give preference to contractors using reduced-emission equipment for County construction projects and give preference for contracts for services to businesses that practice sustainable operations. Require contractor information to decide on contract awards.


Monitor and enforce all existing policies that impact sustainability.

Forest Biomass Energy 

Electric generation from biomass in forested areas burns cleaner than other disposal methods (like prescribed burns or pile burning). Prescribed burns will reduce CO2 emissions from large fires that more than offset the biomass option.


Strategy DR-2: In coordination with the Placer County Water Agency and Nevada Irrigation District, explore ways to improve the storage capacity and generation efficiency at PCWA/County hydroelectric power plants and to increase installation of small-scale hydroelectric facilities. Actions: 1. Identify areas that are appropriate for small-scale hydroelectric facilities. Use of in-steam turbines that do not impact fish passages. Create uphill power storage facilities.

Strategy DR-7: Coordinate with ski resort operators to support additional recreational activities that are less dependent on snowpack levels. Encourage local recreation unless electric transportation is available for longer travel.

Strategy DR-12: Explore amending land use standards as needed to extend grazing in Placer County’s foothill regions as ecosystem shifts permit this, while maximizing environmental protections and avoiding land use compatibility issues from any new grazing areas. Only if livestock is used to make the land more sustainable and is managed for maximum native grass recovery.

Strategy PD-2: Explore opportunities to locate facilities in Placer County that can store and process bark beetle–infested wood and debris from forest fuel-clearing activities into useful products, including those that can support other Placer County industries and bioenergy. Prioritize siting of an appropriate-scale biomass facility in eastern Placer County. These facilities should be less than 3mg in size and use non-merchantable wood or slash only to eliminate open-pile burning.

Strategy PD-3: Work with stakeholders during the permitting stages for processing woody material from tree mortalities to expedite approval. Hazard trees only from national forests.

Strategy PD-6: Increase funding for pest detection and noxious weed abatement. Use natural weed abatement items only.

Strategy WF-1: Identify funding opportunities to support new or expanded fuel reduction projects, including those that provide assistance for biomass facilities. These facilities should be less than 3mg in size and use non-merchantable wood or slash only to eliminate open-pile burning.

Strategy WF-11: Explore prohibiting or limiting increases in residential density within the WUI. Actions: 1. Amend Community Plans and the County General Plan to prohibit or limit increases in residential density within the WUI. Agreed.

This is by no means an exhaustive list of revisions and modifications that AEL urges the County Board of Supervisors to make to the proposed Placer County Sustainability Plan.  Through the public hearing process, more innovative and constructive proposals will likely come forward. Like you, members of the AEL partnership and the citizens you will hear from during the public review process feel the urgency of the climate crisis.  Our goal is to support and encourage your pro-activity to protect and defend the welfare of the people of Placer County today and ensure their safe and secure future that is sadly at risk.

Thank you for your demonstrating climate action leadership by incorporating the improved goals, policy initiatives, revisions and amendments to the Placer County Sustainability Plan as described herein.

We pledge to work with the County to achieve significant CO2 reductions upon which our common future depends.


Leslie Warren, Chair

Alliance for Environmental Leadership

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