Comments needed requesting the “Reduced Footprint” alternative be included in the Village Farms DEIR by this Friday Jan. 2 at 5pm

By Eileen M. Samitz

The Partially Recirculated Village Draft EIR has included the five alternatives in Chapter 7,  “Alternatives Analysis” from the original DEIR. This opens that door to comment on adding the “reduced footprint” alternative proposed by Davis citizens requested at  the Dec, 12, 2023 City Council meeting. This alternative should have been included, which is similar to the “environmentally superior” reduced footprint alternative which was included in the previous Covell Village Draft EIR. Because this “Alternative Analysis” chapter is included in the Partially Recirculated DEIR, comments on the Alternatives Analysis are now “in-scope” until Jan 2nd at 5 pm. That means the city has to evaluate and respond to all significant points you make related to this topic. It’s your right under CEQA. Here’s a definition of what makes a point significant:

“A “significant point” is a substantive comment that raises a material environmental issue or identifies a   specific deficiency in the EIR’s analysis, conclusions, or mitigation such that the agency must address it with a reasoned written response grounded in the record (not a mere acknowledgment).”

Because the Village Farms process has been so aberrant and fast-tracked from the beginning, our public input has been compressed timewise. Because all of this was piled on during the holidays, including back-to-back public meetings, we now only have until this Friday Jan. 2, at 5pm to submit our comments to ask for this reduced footprint alternative.

We can also ask why it took the City more than a year to let the community know about the erroneous information in the Draft EIR about the waste water treatment capacity? Apparently, the City is using a huge amount of Davis wastewater capacity to process leachate from the Yolo County Landfill. Why is that, and how long has that been going on given its significant impacts? Why is Davis processing Yolo County landfill leachate which serves the entire County of Yolo?

While the city NOP statement claims that public comments have to be limited to the Waste Water Treatment Plant, this is false. Under CEQA rules, you may comment on anything in the Partial Recirculated DEIR. That includes Chapter 7. The city is “not allowed to narrow the recirculation to a single topic by directive.” This means that significant comments addressing the adequacy of the Alternatives Analysis are within the recirculated scope and would require a written response in the Final EIR. If they fail to do so, this created yet another CEQA vulnerability.

The City needs go back to the drawing board and come forward with a proposal for a development limited to south of Channel A. This development would be limited to below the channel “reduced footprint alternative” was proposed by Davis citizens at the 2023 City Council meeting item addressing the Village Farms alternatives. This alternative needs to be added which would still allow the developer to build about 900 to 1,000 homes, but would still preserve the vernal pools. In addition, it would avoid the huge flooding risks of building houses on the enormous 200-acre flood plain. It would also distance the houses from the toxics including the carcinogenic PFAS’ “forever chemicals” leaking from the directly adjacent unlined Old City Landfill and Sewage Treatment, a site which also operated as a burn pit for over 30 years.

So, it would be worth a few moments to submit your comments asking: 1) for the “reduced footprint” alternative limited to below Channel A described above to be analyzed in the Village Farms DEIR; 2) why there was more than a year delay in revealing the water treatment capacity issue, and 3) why is Davis processing all the leachate from the Yolo County Landfill for the entire County.

Please send your comments to City Staff member Dara Dungworth at DDungworth@cityofdavis.org regarding your comments on the Partially Recirculated Village Farms Draft EIR, before the deadline this Friday, Jan. 2^nd at 5pm.