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Category: Environment

  • Rebuttal to Village Farms Flood Control Claims

    By Rena Nayyar

    This is a response to a recent article by one of the Village Farms partners regarding the project’s proposed flood control. The article makes the claim that Village Farms will be “better protected from flooding than most of Davis.” That claim is just marketing. The Village Farms EIR does not support this claim. Links to city documents are at https://www.cityofdavis.org/city-hall/community-development/development-projects/village-farms-davis

    The article didn’t cite any sources showing a track record for their “sound, proven engineering design principles” that would be employed to reduce flood risk.  The “hundreds of pages of engineering analysis related to the impact of extreme storm events to the project…demonstrate that Village Farms Davis will be better protected against flooding” is exaggerated as these involve modeling based on assumptions and not actual plans for how this will be implemented. In fact, the flood and stormwater strategy is still being assembled piecemeal, after the circulation of the Draft EIR.  It is meaningless for them to praise the merits of a plan in flux. Village Farms is not a simple “raise the pads” project. It relies on a complex coordinated stormwater and grading strategy across a huge site in a flat floodplain basin with known downstream flooding problems. In that kind of environment, there are lots of failure scenarios. This problem requires completed project level planning that has not yet been done. 

    In the Final EIR response to comments on page 2-10,  liners are being proposed for Channel A to try to prevent the contaminated groundwater including PFAS “forever chemicals”  from mixing with the Channel A runoff water. When the City starts talking about Channel A “liners” and isolation measures to prevent stormwater from interacting with groundwater– those are major changes. This is a sign that the system is being engineered around problems that were not resolved when the public reviewed the Draft EIR. 

    Since the flood plan is so incomplete and not yet approved, the project’s flood story may require future changes, for example in maps (Final EIR page 3-12).  On page 4-83 the Final EIR says that because the drainage patterns of the area will change, “a design-level drainage report shall be submitted to the City …for review and approval” when the first tentative subdivision map is submitted.  Similarly, the response to Comment 217-54, page 2-996 says
    “the preparation of a final Stormwater Control Plan, …cannot be prepared at this time ” and “the appropriate time for a Stormwater Control Plan will be when a tentative subdivision map has been prepared”. 

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  • No Certification of the Village Farms EIR  

    By Eileen M. Samitz

    The City Council will soon be making a decision with serious consequences of whether to certify the Village Farms EIR. It is critical that they deny certification. This EIR is seriously inadequate and flawed, and certifying it would expose the City to liability while surrendering the City’s leverage to correct course on this disastrous project.

    Background

    A similar version of Village Farms, Covell Village, was rejected by Davis voters 60:40 in 2005 for many of the same reasons this project and its EIR must be rejected now. The developer, John Whitcombe (Tandem Properties partner) bought the 386-acre parcel in bankruptcy due to the many obstacles making it impractical to develop (originally costing $11 million) for a mere $3.2 million. The site has long been handicapped by an enormous floodplain, unmitigable traffic, access issues, extraordinary infrastructure costs, and toxics from the adjacent unlined Old City Landfill and Sewage Treatment Plant.

    Aberrant, Chaotic, Rushed Process

    The Village Farms “process” has been aberrant. The developer demanded that the City push his project ahead of other projects being processed. The City caved and has been accommodating him ever since, to the detriment of the community. The apparent objective has been to rush this “legacy” project onto the ballot, but the EIR and key documents still contain a plethora of “to be determined,” and “if feasible” language.

    Public meetings were rushed through the holidays, when many residents were unavailable to comment. In backwards order, the City Council held a workshop the day before the Planning Commission was asked to recommend certification of a Final EIR that did not yet exist. Never in Davis’s history has the Planning Commission been asked to recommend certification of an EIR before it was complete, yet staff pressured for that recommendation anyway. That’s not transparency, it’s corner‑cutting. The City has prioritized a June 2026 ballot timeline over the community’s right to a fair, thorough CEQA process.

    Village Farms: Serious Impacts, Costs, and EIR Inadequacies

    Massive traffic

    Village Farms would add at least 15,415 car trips PER DAY, from 1,800 housing units on the 498‑acre site, the largest residential project ever proposed in Davis. This is likely an underestimation because it assumes substantial public transit use. Covell Boulevard and Pole Line Road, already heavily impacted, would be gridlock, degrading streets to Level of Service “F”. Cut-through traffic would impact many neighborhoods of cars trying to avoid this congestion.

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  • Village Farms will actually be better protected against future flooding than much of Davis

    By Doug Buzbee

    In a recent Op-Ed in the Enterprise (“Commentary: Why a planning commissioner voted no on Village Farms, Jan 2, 2026” [or see longer version on the Davisite here]), Greg Rowe stated he opposed the Village Farms Davis project claiming the site had excessive flood risks.

    He stated that because part of the proposed project site is currently in a 100-year Flood Zone as mapped by the Federal Emergency Management Agency (FEMA) and because climate change will bring more extreme weather events in the future, we simply should not build anything at all in that part of the project.

    While flood risks are real and climate concerns are valid, Mr. Rowe’s comments ignore the fact that proven engineering solutions will be implemented at Village Farms Davis to remove it from the mapped 100-year flood zone, and furthermore, provide protection against a more severe 200-year flood event.

    Village Farms Davis is actually designed to meet higher flood protection standards than significant portions of the rest of Davis, including many older neighborhoods developed before modern flood-protection standards, and over 400 acres within the city limits that still remain within the 100-year flood plain – including swaths of residential West and Central Davis.

    Let me explain.

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  • How City Council Upended the Village Farms EIR Alternatives Analysis

    By Greg Rowe

    The California Environmental Quality Act (CEQA) requires an Environmental Impact Report (EIR) to examine the potential impacts of a range of reasonable alternatives to the proposed project and evaluate the comparative merits of the alternatives. Under CEQA, the purpose of studying alternatives is to allow meaningful analysis and comparison of alternatives that could reduce significant environmental impacts as compared to the proposed project.

    The alternatives must be feasible, meet most or all of the project objectives, and avoid or substantially lessen one or more of the project’s significant impacts. Alternatives are generally evaluated in a qualitative manner rather than to the same degree of exactitude as the proposed project. A “no project” alternative is always included. The “no project” alternative for a project that would develop vacant land would in most cases be the “Environmentally Superior Alternative (ESA),” but not building the project would fail to achieve any of the project objectives.

    As a result, the alternative that best avoids or mitigates the most impacts is typically identified as the ESA, but the lead agency (the City of Davis in this case) is not obligated to substitute this alternative for the proposed project. In fact, because alternatives are generally analyzed qualitatively, a lead agency could not approve an alternative consistent with CEQA unless that alternative was also analyzed at the project-specific (i.e. detailed) level, such as the Biological Resources Preservation Alternative (BRPA) for the Village Farms project.

    Alternatives are selected after the project’s impact analysis has been completed and the project’s potential impacts to the environment are known.  This is a logical sequence because it is impossible to know if an alternative would produce fewer impacts if the potential project’s impacts are not yet  revealed, just as a doctor cannot consider alternative treatments for a patient before the ailment and its source are known.

    In my experience working with EIRs since 1984, once the impact analysis has been completed, there typically will be a meeting among the EIR consultant, the client (in this case, the City of Davis) and potentially the project proponent (in this case, the developer).  For a project such as Village Farms, the EIR consultant and city planning staff would use their professional experience and knowledge of the area and CEQA to devise a range of reasonable alternatives, with which the project proponent may or may not concur. In other words, the selection of alternatives is an objective process based on impartial judgment and professional experience. It should not influenced by political or financial considerations.

    A knowledgeable but now retired land use consultant once told me that in his long experience, impacts to biological resources, traffic, and air quality tend to be the primary factors that influence the identification of alternatives. Typical alternatives might include any or all of the following:

    • The same footprint or area but with fewer units (meaning lower density).
    • A smaller physical footprint but with the same number of units, which would typically avoid impacts on sensitive biological resources on the property.
    • A reduced project area footprint that includes the same number of housing units, but with a different mix of housing types.   
    • A lower number of housing units on a smaller footprint.   
    • Developing the project at an entirely different location, if acquiring such land for an alternative is feasible.
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  • Davis Planning Commissioner Explains His “No” Votes on Village Farms

    [Note: a shorter version of this article appeared in today’s Davis Enterprise. This longer version gives additional details and background for Commissioner Rowe’s votes.]

    By Greg Rowe

    Introduction

    The planning commission’s marathon December 17 meeting concluded with two recommendations to city council for the proposed Village Farms development: certify the project’s Environmental Impact Report (EIR); and approve the project for a Measure D election.  It is expected that by January 20, Council will consider those recommendations and decide whether to place the project on the June ballot.  (January 20 is the last meeting date when Council can meet the County’s deadline for June ballot measures.) Voter approval would be followed by a general plan amendment, pre-zoning, and annexation of the site from Yolo County.   

    I voted against certifying the EIR because of what I am convinced are serious procedural irregularities, based on working with the California Environmental Quality Act (CEQA) since 1984. I likewise declined to support the project because I am convinced its location within a flood hazard zone would compromise the safety of Davis residents within Village Farms.   

    What is Village Farms?

    The developer proposes to build 1800 market rate and affordable homes of various types, ranging from apartments to single-family detached homes. There would also be parks, open space, a protected 47-acre wetland habitat, a site for pre-K daycare, and a small land dedication to the City of Davis for public facilities. The property comprises 497 acres situated at the intersection of Pole Line Road and Covell Blvd, extending westward along Covell and north along Pole Line to the Blue Max Kart Club and Davis Paintball.  

    The proposed project would border The Cannery neighborhood, wrapping around that community on its north side and extending northward along the east side of F Street.  A major City of Davis drainage course (“Channel A”) flows west to east through a portion of the Village Farms site. The developer has stated that grading and infrastructure installation would take about two years, and buildout would occur in four phases lasting an additional 15 years. Pursuant to the draft Development Agreement (DA) between the developer and the City, the developer would install grade-separated bicycle and pedestrian crossings of Pole Line Road and F Street.     

    Climate Change and Floods

    The Central Valley has long experienced devastating floods, as described in historian Robert Kelley’s seminal 1998 book, Battling the Inland Sea.  The risk of flooding is now much greater because of a warming climate and a higher population that would be exposed to flooding caused by large and intense storms.

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  • 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.

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  • Comments on the Village Farms recirculated draft EIR

    By Roberta Millstein

    In an earlier article, I mentioned that there was a recirculated (and partial) Draft Environmental Impact Report (DEIR) for the Village Farms proposal, necessitated by “new information” related to the City’s overall Wastewater Treatment Plant (WWTP) capacity.” I also noted that the City was taking public comment on the recirculated (partial) DEIR, with comments due by 5 PM, January 2. As that day is very soon upon us, I thought I would share my own comments here.

    Anyone thinking of submitting their own comments should note the following:

    “Pursuant to CEQA Guidelines Section 15088.5(f)(2), the City of Davis directs that public comments must be restricted to the newly circulated information contained in this document related to wastewater treatment capacity. The City is not obligated to respond to any new comments that are directed to the portions of the Draft EIR that were not revised and are not being recirculated in this document.”

    Comments must be directed to:

    Dara Dungworth, Principal Planner
    City of Davis Department of Community Development
    23 Russell Boulevard, Suite 2
    Davis, CA 95616
    ddungworth@cityofdavis.org

    My public comments (submitted earlier today) are as follows:

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  • Give your feedback to the city on the Village Farms project proposal

    By Roberta Millstein

    Heads up for Davis City Council “workshop“ on Village Farms, Tues, Dec 16, approx 7:20 PM. This is an opportunity for you to let the city know your views on the project.

    Item 6: Staff recommends the City Council conduct a public workshop on the Village Farms Davis project (VF) applications, as follows:
    a. Receive Staff presentations on the proposed project;
    b. Receive Applicant presentations on the proposed project;
    c. Take public comment; and
    d. Consider the following project applications and documents and provide feedback:


    i. Pre-General Plan Amendment, including provisions for Baseline Project Features as required by Chapter 41 of the Davis Municipal Code; and
    ii. Pre-Zoning and Preliminary Planned Development; and
    iii. Development Agreement.

    Details here: https://documents.cityofdavis.org/Media/Default/Documents/PDF/CityCouncil/CouncilMeetings/Agendas/2025/2025-12-16/06-Village-Farms-Workshop.pdf

    IN PERSON PUBLIC COMMENTS:
    Speakers will be asked to line up at the podium and state their name for the record. Comments are limited to no more than 2 minutes per speaker.

    WRITTEN AND VOICEMAIL PUBLIC COMMENTS:

    1. Submit written public comments to CityCouncilMembers@cityofdavis.org. Emails are distributed to City Council and staff. To ensure the City Council has the opportunity to review information prior to the meeting, send emails by 3:00 p.m. on the meeting date.
       
    2. Submit comments by voicemail prior to the meeting: Call the city’s dedicated phone line 530-757-5693 to leave a voicemail message for public comment. Staff will play comments during the appropriate agenda item. Comments will be accepted from 12:00 noon until 4:00 p.m. on the day of the meeting. Voicemail public comments will not be accepted after 4:00 p.m. Speakers will be limited to no more than two minutes.
       
      Note: You must leave a separate voicemail for each item you wish to comment on. Please indicate your name and which item you are speaking about.

  • Why is a Portion of the Village Farms DEIR being Recirculated and has the Proper Process been Followed in Doing So?

    by Alan Pryor

    A portion of the Village Farms DEIR (contained in the Utilities and Services chapter) is being recirculated because the City, as the “lead agency” in the EIR process, has received a last-minute report from Brown and Caldwell dated November 7. This report indicates that the City’s existing Wastewater Treatment Plant (“WWTP”) is perilously close to exceeding its maximum flow capacity and needs to be upgraded to meet the City’s wastewater treatment permit issued by the Regional Water Quality Control Board. This information was not known by the City when they prepared and circulated the current Village Farms DEIR for comment.

    However, since the new information impacts the analysis of the Village Farms project’s impact on the City’s WWTP, the City determined that the portion of the Village Farms DEIR addressing Utilities and Services needs to be recirculated with the updated information for public comment prior to consideration of the revised FEIR for certification by the City.

    Unfortunately, the City has done a poor job explaining this need to the public when they recirculated the portion of the DEIR needing additional comment. Two questions immediately come to mind that should have been answered by the City in more detail and explained better when the DEIR was recirculated.

    1) What Information Came to Light that Necessitated the Recirculation of the Portion of the Village Farms Davis DEIR?, and

    2) Is this Process Proper and Legally Compliant with CEQA and State Regulations Regarding Public Noticing and Subsequent Consideration by the Planning Commission and the City Council?

    The following discussion addresses these questions.

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  • Planning Commission declines to even discuss Village Farms evaluation process

    By Roberta Millstein

    At last night’s Planning Commission meeting, I was the only (!) oral commenter, via the call-in option. I raised a series of concerns about the process and timeline for evaluating the Village Farms proposal, which I will paste in below. Yet neither staff nor any member of the Planning Commission chose to acknowledge the existence of my concerns, much less respond to them. I will let the reader decide whether I am making a mountain out of a molehill (possibly) or whether the Planning Commission shirked its duty by not even discussing the concerns.

    As background, the sole point of the meeting was to decide whether to “continue” the Dec 2 meeting until Dec 17, to “to allow for the final negotiations of the project’s draft development agreement to be completed such that the Planning Commission can take action before the draft is forwarded to the City Council for consideration.”

    Here is the slightly longer version of my comments that I emailed to members of the Planning Commission prior to the meeting, differing primarily in the second paragraph which I had to cut for time in my oral comments.

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