Draft EIR for Village Farms released for public comment
February 02, 2025
By Roberta Millstein
On January 7, the City of Davis released the Draft Environmental Impact Report (DEIR) for the Village Farms Davis Project for public review. The approximately 497.6-acre project site is located north of East Covell Boulevard, east of F Street, and west of Pole Line Road in a currently unincorporated portion of Yolo County, California. The City has invited public comment on this document for a 45-day period extending from January 7, 2025 through February 25, 2025. (Sorry for the late notice, but there is still time to submit comments). EIRs are part of the California Environmental Quality Act (CEQA) process.
The DEIR materials can be found within the ‘CEQA Documents and Information’ tab at: https://www.cityofdavis.org/city-hall/community-development/development-projects/village-farms-davis
It's a very long document, but citizens can start with:
And then, you can peruse particular areas of interest or concern:
- 4.1 _Aesthetics
- 4.10_Noise
- 4.11_Population and Housing
- 4.12_Public Services and Recreation
- 4.13_Transportation
- 4.14_Utilities and Service Systems
- 4.15_Wildfire
- 4.2_Agricultural Resources
- 4.3_Air Quality, GHG Emissions, and Energy
- 4.4_Biological Resources
- 4.5_Cultural and Tribal Cultural Resources
- 4.6_Geology and Soils
- 4.7_Hazards and Hazardous Materials
- 4.8_Hydrology and Water Quality
- 4.9_Land Use and Planning
If you are unfamiliar with the CEQA process, the City offers some guidance here: https://www.cityofdavis.org/home/showpublisheddocument/19752/638646686914530000
The Project Description chapter states that the EIR provides a comprehensive description of the Village Farms Davis Project (Proposed Project) and the equal-weight Biological Resources Preservation Alternative (BRPA). However, in my conversations with the developers at a public meeting, I was told that only the BRPA is under consideration, so citizens should probably focus their comments there.
The Introduction states:
"The BRPA would consist of a mixed-use development community on the same 497.6-acre project site. Similar to the Proposed Project, the BRPA would include a total of 1,800 dwelling units, comprised of both affordable and market-rate single- and multi-family residences across various residential neighborhoods. However, the BRPA would preserve a 47.1-acre Natural Habitat Area comprised of the Alkali Prairie Yolo Habitat Conservation Plan/Natural Community Conservation Plan (HCP/NCCP) land cover that occurs south of Channel A. In addition, the BRPA would include the development of neighborhood services; public, semi-public, and educational uses; associated on-site roadway improvements; utility improvements; parks, open space, and greenbelts; and off-site improvements."
Comments may be emailed to Dara Dungworth, principal planner for the city of Davis Department, at [email protected] or mailed to Dara Dungworth at Community Development, 23 Russell Blvd., Suite 2 Davis, CA 95616.
In the interests of dialogue, I encourage Davisites to share their thoughts on the Village Farms DEIR here, although of course commenting here does not count as an official comment.
Great summary of a long and complex document. I urge anyone who is interested in commenting on the Draft EIR to start reading it now. I've spent the weekend plowing through it and have submitted 7 pages of comments on 2 chapters and an appendix, and I still have a long way to go. Because the DEIR is so long, focus on the subjects of most interest to you, whether it is transportation, air quality, open space, etc. Writing your comments in a focused manner is also time consuming. It is helpful to cite the issue (impact, mitigation measure, etc.) in your comments, rather than simply making a general or blanket comment such as "I'm unhappy with the transportation impact analaysis."
Keep in mind that under new CEQA rules, traffic congestion (roadway Level of Service or LOS) is not considered an impact. The focus is now how a proposed project will reduce per capita Vehicle Miles Traveled (VMT) below specified threshholds. A particular project may result in drivers being stuck in traffic longer than previously, but that is not an impact within the realm of CEQA.
Also keep in mind that because of recent court decisions, the potential impact of the environment upon the project is not a subject germane to CEQA. For example, if a source of noise or potentially hazardous substances are near a proposed project, that is is not an "impact" relative to a CEQA analysis.
The City of Davis Planning Commission (of which I am a member) will conduct a public hearing on the DEIR on Wednesday evening, February 12 @ 7:00 PM. This will be a great opportunity to provide comments to the commission, City staff, the CEQA consultant and the project applicant. Be aware that oral comments are limited to 3 minutes, so be sure to organize your thoughts before the meeting and consider practicing your presentation to make sure you can say everything important to you in 3 minutes or less.
Hint: don't take up valuable time by saying how long you've lived in Davis, that you are a proud UCD alumnus, how many of your children graduated from Davis schools, etc. Doing so reduces the time you have available to focus on the important topic at hand. During the 7 years I've been on the Planning Commission I've seen many speakers disappointed that they did not have a chance to discuss the items of most importance to them because they used up too much time mentioning things there were not relevant to the subject matter. (I'm sorry if that sounds harsh, but that's my honest assessment and advice).
I'm a planning commissioner, but the comments herein are strictly my own and do not reflect an official or formal position of the commission or City of Davis.
Posted by: Greg Rowe | February 02, 2025 at 08:34 PM
"A particular project may result in drivers being stuck in traffic longer than previously, but that is not an impact within the realm of CEQA."
This is my major concern, but since it is not an "impact," I guess there is no point in mentioning it. I do question though how more and more pressure can be put on infrastructure designed for a much smaller town before everything just breaks down.
Posted by: George Galamba | February 02, 2025 at 09:03 PM
Greg, is the focus on VMT per capita or total VMT, or both? I thought it was both.
Also, as I am sure you know, but others may not: greenhouse gases (GHG) are also considered in the analysis, which is related.
Posted by: Roberta L. Millstein | February 03, 2025 at 08:30 AM
We’ve been by the consultants during planning commission meetings that the main criteria they look at is per capital VMT. This topic engendered a lot of iscussion the recent hearings on the Palomino Place project.
Posted by: Greg Rowe | February 03, 2025 at 08:40 AM
Thanks, that's interesting. That is what the consultants look at, OK, but what does the law say? When I looked it up I didn't see anything insisting that it had to be per capita VMT.
Posted by: Roberta L. Millstein | February 03, 2025 at 09:00 AM
For example, this page:
https://lci.ca.gov/ceqa/sb-743/faq.html#what-is
says:
“ Starting on July 1, 2020, agencies analyzing the transportation impacts of new projects must now look at a metric known as vehicle miles traveled (VMT) instead of LOS. VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto our roads, the project may cause a significant transportation impact.”
That doesn’t say that the analysis has to be per capita. In fact, it sounds like total VMT to me. So is the DEIR inadequate because it only uses per capita VMT?
Posted by: Roberta L. Millstein | February 03, 2025 at 09:25 AM
Roberta brings up some interesting/relevant points, here.
In any case, the switch from LOS to VMT's is direct evidence of corruption/interference by the state, to discount/hide environmental impacts of development proposals.
You don't need a degree in physics to realize that vehicles stuck in traffic create far more greenhouse gasses per mile, vs. cars that travel without obstruction.
That's why, for example, cars traveling from Woodland to UCD (down Highway 113) probably create LESS total greenhouse gasses than cars traveling from the east part of Davis through town to campus. Despite the fact that VMTs would be higher from Woodland.
(This is not intended as a comment advocating for development in Woodland, and is just an example of the problem with switching from LOS to VMTs.)
Posted by: Ron O | February 03, 2025 at 10:11 AM
Ron, but that's why I brought up GHGs. They are still part of the analysis -- assuming the analysis is done in a robust way -- and so that should be taken into account.
I'm not defending the switch, just pointing out that people who are concerned about LOS might look at the GHG analysis.
Posted by: Roberta L. Millstein | February 03, 2025 at 11:36 AM
I am now reviewing the Transportation chapter in the Village Farms DEIR (Chapter 4.13), and it states on page 12 of the chapter that residential per capita VMT is the methodology used in the analysis. (This is not necessarily to say that this is the approach that is legally required; it is just what the document says is being used for this particular analysis.)
Posted by: Greg Rowe | February 04, 2025 at 10:16 AM
Since this is referring to people who don't live in Davis, does it state what the "per capita VMT" (or GHGs) are being compared to?
I suspect that most people who move from the Bay Area to a new development in Davis end up driving more than they used to.
Truth be told, EIRs don't even come close to considering all of the resulting impacts - which also spread well-beyond a given city.
Posted by: Ron O | February 04, 2025 at 11:03 AM
I was going to mention a new much larger development in Utrecht called Merwede where there will be no owned cars and one car share car for every three households....
But there's really no point using this as an example because Utrecht has about 50 times as much rail service as Davis will have in any conceivable future.
I wish that there was a government agency with enough power to step in and not let us add so many cars to our streets... Obviously SACOG can't do anything about three huge sprawling car dependent disasters being built in West Sacramento, near Rancho Cordova and in another community to the north of the city.
I would be slightly more optimistic if the Village Farms plan included robust public transport and cycling possibilities ALL the way to downtown and campus... But it does not.
It's likely that the developer will offer a few pieces of candy, but let's look at how they are managing Nishi 2.0 in tandem with the city and campus: a key part of the annexation campaign was a fraud as formal documents included a grade separated crossing, but visuals and many optimistic claims from the city assured us that Union Pacific would agree to an undercrossing. Then they essentially hid this issue - the post annexation daniel from Union Pacific for an undercrossing - for 5 years. And the proposed active transportation network inside the development is awful, and a related mitigation for I-80 involving the Putah Creek path is a complete joke, especially from the brown nosing transportation engineers who support it or are staying silent about it.
I'm always open to miracles as I am at my core an optimist, but I'm planning to vote "no".
Just to waste a bit of time: I've lived here for 8 years and wouldn't have children here.
Posted by: Tuvia etc | February 04, 2025 at 12:58 PM
Ron, from materials shared with me:
Compares Village Farms-generated VMT per capita to:
• City of Davis VMT per capita
• SACOG region VMT per capita
I assume that's in the DEIR somewhere but I have not delved in deeply myself.
Posted by: Roberta L. Millstein | February 04, 2025 at 01:20 PM
Tuvia says, "Obviously SACOG can't do anything about three huge sprawling car dependent disasters being built in West Sacramento, near Rancho Cordova and in another community to the north of the city."
You've got that backwards. SACOG SUPPORTS developments like that. Our entire system is geared toward supporting it.
Posted by: Ron O | February 04, 2025 at 03:15 PM
Comments on Section 4.13 Transportation
This analysis isn’t worth the paper it’s written on, or the pixels it lights up on my screen.
It relies on ITE trip generation numbers and SACOG’s SacSim19 model for VMT which don’t pass the sniff test. It appears to be a case of “garbage in, garbage out”.
For example:
I find it hard to believe that Davis citywide residential Vehicle Miles Traveled is 30.1 miles per capita. This only counts trips that start or end at a residence on a typical weekday. So the SACOG model is saying that the average Davis two-person household drives 60.2 miles per weekday; and the average household of four drives an average of 120.4 miles per day in trips that begin or end at home. That doesn’t include miles after dropping the kids off at school or daycare on the way to work, or before stopping at the grocery store on the way back from lunch downtown. We have many two bedroom apartments with four UCD students. If they aren’t driving 120 miles to campus and back, then the rest of us must each be driving much more than the average 30 miles per day.
The trip generation figures also seem suspect. I realize the ITE trip generation rates are considered reliable. But when they indicate a single family market rate detached household generates about twice as many daily trips (9.43) as an affordable rate household (4.81), I have to question the data.
The analysis jumps from trip generation numbers to average VMT/capita without telling us either the numerator or denominator used to arrive at that figure. i.e. it doesn’t tell us the total new VMT caused by the development or the anticipated number of residents.
The recommended mitigation measures are proposed without telling us how they arrived at them.
I don’t like the idea of any new traffic signals in Davis, especially two very closely spaced ones on Pole Line Road, very close to one of the busiest signalized intersections in that part of town (Covell/Poleline). I would rather see roundabouts constructed at Picasso and Donner than new traffic lights. I could get on board with the new roundabout proposed at Moore. It appears the new northernmost project intersection near the existing city limit is proposed to only get a stop sign on the side street. That should also be a roundabout, otherwise we’ll quickly end up with a 4-way stop like we currently have at Moore and Poleline (not a good situation).
The 7th bulleted mitigation measure listed in section 14.3-2 —a bike undercrossing at Poleline and Moore and a grade separated crossing at F Street will never happen because they have the qualifier “if feasible”. No developer will ever say it is feasible to spend a few hundred thousand extra if they just have to claim it is not feasible. Who is to determine feasibility?
Posted by: Jay | February 07, 2025 at 09:21 PM
Jay good to have you posting, there is NO WAY that Davis has a a "per capita" driving of even close to 30 miles a day. There are some "super commuters" in town that drive to Cupertino five days a week but they are a tiny minority with the majority of people in town young and/or UCD students and/or olderamd/retired who drive even less than the students.
Posted by: South of Davis | February 08, 2025 at 09:42 PM
Yes I agree. Good analysis by Jay
Posted by: Alan C. Miller | February 09, 2025 at 09:53 AM
"The release of the Draft Environmental Impact Report (EIR) for the Village Farms project is a crucial step in ensuring that all potential environmental impacts are thoroughly assessed. It's great to see the City of Davis inviting public comments on this important document. Community engagement is key to making informed decisions that balance development with environmental sustainability. I encourage everyone to review the EIR and provide their feedback."
Posted by: Michael Forster | February 16, 2025 at 12:21 PM
I believe that, by CA law, the City is required to notify citizens about the availability of DEIRs, and that by CA law, citizens have the right to comment on them. So the City doesn't really earn any kudos here, although I agree that community engagement is important for informed decision making.
Posted by: Roberta L. Millstein | February 16, 2025 at 01:35 PM
"So the City doesn't really earn any kudos here"
You can say that again :-|
"So the City doesn't really earn any kudos here"
Thank you :-|
Posted by: Alan C. Miller | February 16, 2025 at 02:49 PM