The following comments are the Sierra Club Yolano Group's response to the call for comments on the proposed scope of environmental review of the proposed Eastside (misleadingly called "Shriners") project. See earlier article for details: https://www.davisite.org/2024/07/notice-of-preparation-nop-for-so-called-shriners-property-project.html .

Apologies for the weird numbering on the list -- the SCYG Management Committee's intent should be clear.

From: Sierra Club Yolano Group
To: Dara Dungworth, Principal Planner
Re: Eastside NOP Comments
Date: August 7, 2024 

Transmitted via email: <[email protected]>

Ms Dungworth - Regarding the Notice of Preparation (NOP) and the upcoming preparation of a Draft Environmental Impact Report (DEIR) for the “Eastside” housing project (formerly referred to as “Shriners”), the Sierra Club Yolano Group offers the following comments and recommendations.

1. Alternatives
   
   
   1. City staff has recommended that one the Alternatives to be analyzed in the EIR should have “Higher Number of Units – Same Footprint,” but it does not specify the number of units to be analyzed. We recommend that a minimum of 1500 units be analyzed and that the design of this Alternative incorporate a substantial co-op model (perhaps similar to Dos Pinos or Muir Woods) that prioritizes alternative modes of transportation, especially bicycling.  This Alternative would better achieve the following goals: more traffic/transit efficiency, better for minimizing negative impacts to air quality and climate change, more equitable and affordable, better able to serve underserved populations.

2. Biological Resources
   

1. 1. We recommend the then current leasehold farmer not perform any cultural activities resulting in soil disturbances in environmentally sensitive areas, including planting of cover crops, until all of the biological studies are completed.
      
      
   2. In the analysis for rare plants, we recommend all historical records be consulted.
      
      
   3. We recommend all surveys performed for determination of Biological Resources be performed by specialists approved or certified to perform such studies under CEQA guidelines and performed in accordance with CDFW protocols.
      
      
   4. We recommend environmental evaluation 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).

3. Traffic

1. 1. We recommend the traffic impact analysis be studied for cumulative impacts of all the four proposed properties on Covell and the Mace curve including this project, Village Farms, Palomino Place, and On the Curve, as would be done in an East Covell - Mace Curve Specific Plan to assess cumulative impacts.
   2. Below is a diagram which illustrates the relationship between the developments by indicating the ¼ mile walking distance of each proposed project. We recommend the proposed transportation mitigation be developed in light of these findings to minimize walking distance to public transit.
   3. We recommend a study to determine long it would take to evacuate the residents of the 1800 units from the two exits in case of fire, flood, etc., and whether that could provide for a safe evacuation.

4. Air Quality

1. 1. Given that development is almost adjacent to the Open Space for Public Health and Safety housing exclusion zone around the landfill and sewage treatment plant, we recommend that an EPA-approved air dispersion modeling tool be employed to investigate potential harmful or nuisance odorous or particulate matter or other vectors be performed to determine the extent of possible exposure of residents of Eastside to emissions emitted from the Yolo County Landfill or the Davis Wastewater Treatment Plant.

Excerpts from Davis General Plan re Exposure to Odors and Vectors from Landfill

Section V: Community Facilities and Services Davis General Plan

Chapter 9: Parks and Open Space May 2001/ Amended Through January 2007 (p. 228)

“The land within one mile of the landfill and sewage treatment facilities is designated “Open Space for Public Health and Safety.” The intent is that residential development is prohibited within this area due to public health concerns including vectors and odors. In addition, this area poses a hazard to aircraft because of the large number of birds that congregate in the vicinity of the landfill.”

5. Hazards and Hazardous Materials-

1. 1. We recommend a Public Health Vector Control analysis be performed as a result of the proximity of the development project to the Open Space for Public Health and Safety housing exclusion zone. Concerns could include vectors such as mosquitoes (from the wetlands by the wastewater plant) as well as rats and seagulls potentially carrying dangerous impacts (feces, West Nile virus, etc.) toward the new development.

6. Hydrology

1. 1. Given the 100-year floodplain extends into the property, we recommend 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.

Map of 100-year Floodplain Extending into Property

7. Noise

1. 1. We recommend noise analyses be performed to evaluate potentially loud noises from adjacent uses which have occurred in the past, e.g., sound guns to scare off birds from the landfill to the north of the property and from agricultural land to the north-east of the property.

8. Cultural Resources

1. 1. 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.