Sierra Club Yolano Group comments on Village Farms scope of work
December 15, 2023
The following comments were submitted to the City of Davis by the Sierra Club Yolano Group on December 8. Transmitted via email to <[email protected]>
Biological Resources
1. The Biological Resources should be studied in detail as outlined in the 5 December 2023 letter from Madrone Ecological Consulting, “Subject: Summary of Biological Resources Surveys Planned for the Village Farms Project, Yolo County, California.” but with the following suggestions:
- In the Aquatic Resources Delineation study, we recommend the timing of the determination of the extent of wetlands be expanded to include any times in which the area is water-inundated rather than at specifically identified times because inundation can occur during variable periods.
- We recommend the then current leasehold farmer not perform any cultural activities resulting in soil disturbances, including planting of cover crops, until the all wetland studies are completed.
- In the analysis for rare plants, we recommend all historical records be consulted.
- All surveys performed for determination of Biological Resources should be performed by specialists approved or certified to perform such studies under CEQA guidelines and performed in accordance with CDFW protocols.
- Environmental evaluation should also be performed considering the Yolo Regional Resource Conservation Investment Strategy/Land Conservation Plan (RCIS/LCP) in addition to the Yolo Habitat Conservation Plan & Natural Community Conservation Plan (HCP/NCCP).
Traffic
2. The Traffic impact analysis should be studied for cumulative impacts of all the four proposed properties on Covell and the Mace curve including Village Farms, Palomino Place, Eastside (formerly referred to as Shriners), and On the Curve, as would be done in an East Covell - Mace Curve Specific Plan to assess cumulative impacts.
3. Below is a diagram which illustrates the relationship between the developments by indicating the 1⁄4 mile walking distance of each proposed project. The proposed transportation mitigation should be developed in light of these findings to minimize walking distance to public transit
Alternatives
4. We recommend that the DEIR analyze a co-op model (perhaps similar to Dos Piños or Muir Woods) as a supplement to the proposed starter-home program, and explore the possible environmental benefits that such a model could produce and analyze the impact of Community Gardens on GHG emissions and VMT.
Hazardous Materials
5. We recommend that an additional sample from each of the seven existing monitoring wells that are still accessible on the Village Farms site and the city-owned property to the north of the site be taken and analyzed for toxic contaminants including PFAS (“forever chemicals”) and determine the direction of the aquifer flow. Existing ag wells on the site planned for irrigation use in the project should be tested for the presence of toxics and contaminants including PFAS (“forever chemicals”).
The Scope of Work for Raney Environmental indicates the following, “Raney anticipates the provided Phase I ESA will include soil sampling across the entire project site to test for persistent pesticides and other potential contaminants.” We recommend including analysis for PFAS. (“forever chemicals”) in these soil surveys
Hydrology
6. We recommed the potential impact of peak flows and volumetric capacity on the project and downstream system be studied using a 200-year flood event in the Drainage report in addition to using a 100-year flood event
Cultural Resources -
7. We recommend that the Yoche Dehe Wintun Tribe and other tribal groups be consulted with more than a certified letter to notice them of the upcoming DEIR and consultations opportunities
It's disappointing that the Sierra Club's comments do not include opposition to sprawl.
Posted by: Ron O | December 15, 2023 at 05:31 PM
also am disappointed that the Sierra Club Yolano Club NOP comments state no clear opposition to building on flood plains, particularly the enormous 200-acre flood plan taking up half of the Village Farms site. It makes no sense to build on a huge flood plain that size taking up half of the project land.
It is also disappointing that there is a NOP comment requesting a mere one-time testing of the minimal number of only 7-monitoring wells for roughly 600 acres of total amount of land of the Village Farms land and the Old unlined City Landfill and Sewage Plant. There is no way that only one testing would be adequate given the long history of toxics and other contaminants leakage from the Old unlined City Landfill and Sewage plant into the groundwater that extends into the Village Farms groundwater. More monitoring wells should be added, as well as more frequent testing is needed than only once or twice a year as was done years ago.
However, fortunately the California Water Board raised major concerns regarding the long history of toxics and other contaminants leakage into the ground water from the Old unlined City Landfill and Sewage Plant. As a result of the California Water Board concerns, they recently ordered the City to resume the testing for toxics and other contaminants including PFAS “forever chemicals”.
PFAS “forever chemicals” are very relevant in this situation because they are frequently found in leachates from old landfills. However, oddly, PFAS chemicals have never been tested here. This is especially concerning because many of these PFAS "forever chemicals" are carcinogenic.
Posted by: Eileen Samitz | December 16, 2023 at 02:25 PM
" 4. We recommend that the DEIR analyze a co-op model (perhaps similar to Dos Piños or Muir Woods) as a supplement to the proposed starter-home program, and explore the possible environmental benefits that such a model could produce and analyze the impact of Community Gardens on GHG emissions and VMT."
Glad to see this recomendation for exchange for starter homes. Both will consume less land and increase density. However, of the two, Dos Pinos is the only co-op model and model of permanent affordabilty.
Cohousing is not a co-op model and is usually market rate housing and not permanently affordabie.
They both should be included but it is Important to identify the difference.
David Thompson
PS> Sorry that the Yolo Solano Sierra Club did not speak strongly against the car-centric sub-division as a whole.
Posted by: David J Thompson | December 17, 2023 at 05:50 PM
Thanks, David, that's an important distinction (between Dos Pinos and Muir Woods).
As for speaking against the project, that was beyond the item under discussion, which was just about the scope of work. The SCYG will discuss the project itself at a future time, after the EIR is done, and at that decide whether to take a stand or what that stand should be.
Speaking only for myself, not the Sierra Club.
Posted by: Roberta L. Millstein | December 17, 2023 at 05:55 PM