Davis, CA – At the end of the day, I still have a lot of issues for how environmental impacts are tallied. In particular, VMT and GHG do not seem to take into account existing commute patterns and how new projects—rather than creating new traffic and emissions—can help to alleviate them by placing more people closer to their jobs.
For this column, I want to look a little more closely at the Village Farms Draft EIR and specifically the environmentally superior alternative.
The analysis concludes: “The No Project (No Build) Alternative would be considered the Environmentally Superior Alternative, because the project site is assumed to remain in its current condition under the Alternative.”
They ultimately exclude that one, because this alternative “would not meet any of the project objectives.”
But this analysis actually, in my view, is part of the problem. I have had some conversations with various conservationists who believe that, while we need housing, we have to do so in an environmentally sustainable way. A point that I agree with wholeheartedly, even if I don’t emphasize it.
At the same time, I think a lot of people—including those who analyze EIRs—are a bit myopic in how they look at environmental impact. The point I keep making is that projects do not generate people and traffic, they relocate people and traffic.
We can think of this in several ways. If we are not building on farmland here, we may well be causing farmland somewhere else to be built upon. So preserving farmland here doesn’t necessarily preserve farmland.
There is another side to this coin, and that is the environmentally superior option is to put more people closer to where they work. And one reason why traffic is so bad in Davis is that people are driving from outside of town to work at the university and people who live in town, are driving to Sacramento and the Bay Area to work.
If you look at the totality of traffic, for instance at Pole Line and Covell—an intersection that is going to go under a microscope for the next ten months or so—you see people heading to and from Woodland, and you also see people driving along Covell heading to and from I-80.
Therefore, the environmentally superior alternative is to put people within the distance of their work so that they can use things like bikes, their own feet, and buses to get to work rather than a car. And, alternatively, if they do drive, driving two miles to work is superior to driving 15 miles.
But the EIR contains little to no analysis on that. In order to assess environmental impacts correctly, we have to understand that more housing closer to jobs is superior to less, and more jobs closer to housing is also superior to less.
A second critical point—there are going to be a lot of people pushing back on the Village Farms project because of the 1800 units and their concerns about traffic.
And yet, from the perspective of the EIR, the superior alternative is the 2700-unit alternative and the inferior alternative is the nearly 1400-unit alternative.
Part of the calculation when we look at this stuff, is that if we do not put housing here, we still have to build housing in Davis to accommodate state mandates. As I have written elsewhere, even approving both Village Farms and Shriners probably does not give us enough housing—especially affordable housing—to meet the state requirements for the seventh cycle RHNA (which has not been released and won’t be for some time).
For the lower number project, “because the Alternative would result in the development of fewer residential units, fewer affordable housing units would be provided, vehicle miles traveled (VMT) per capita would be increased, and a reduced amount of property tax revenue would be generated project Objectives 1, 2, and 7 would be met to a lesser degree than under the Proposed Project.”
These objectives:
- Facilitate development of varied housing options, including affordable housing, and in sufficient quantities to meaningfully help to meet the City’s Regional Housing Needs Allocation (RHNA) expectations for multiple income levels.
- Guide urban growth in undeveloped areas closest to the central City to facilitate compact growth and to reduce potential vehicle miles traveled (VMT) and excessive sprawl.
- Increase City property tax
To me, that No.2 is critical and the point I was making before—more density reduces VMT and reduces sprawl. Because, again, people are not thinking of this stuff in this way, but if you build less here, you have to build more somewhere else—somewhere further, but also just somewhere more.
That doesn’t even address some of the issues of alternate transportation efficiency that comes with density.
Meanwhile for the higher unit—same footprint alternative— “Because the Higher Number of Units – Same Footprint Alternative would include development of the project site/BRPA site with the same uses included in the Proposed Project, all project objectives would be met.”
The significant impacts that would be reduced under this alternative are as follows:
- Conflict with or obstruct implementation of the applicable air quality plan during project operation (remains significant and unavoidable);
- Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (remains significant and unavoidable);
- Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs during construction;
- Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs during operation (remains significant and unavoidable);
- Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b) (significant and unavoidable eliminated); and
- Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b) associated with cumulative development of the Proposed Project or the BRPA in combination with future buildout of the City of Davis (significant and unavoidable eliminated).
This doesn’t completely solve problems that would remain significant and unavoidable, “However, significant and unavoidable impacts related to VMT would be reduced to less than significant under the Alternative.”
The problem of course is that under Measure J, you not only have to convince the policy wonks that this is the superior option, you have to convince the average voter. In that view, 1800 units is going to be a very difficult lift.
But what this analysis shows is that actually we should be arguing for more units here in order to avoid having to build more projects elsewhere.
Yesterday’s headline: “Draft EIR for Village Finds Denser Project Environmentally Superior Alternative”
Today’s headline: “Commentary: Draft EIR Says Denser is Better”
And?
I think its challenging to make simple statements about these issues because there are so many interdependent factors to consider simultaneously.
A “dense” development built in south woodland for example would still be better both terms of household heating and cooling energy usage and would be more affordable by nature than lower-density single family housing build in the same spot… but it wouldn’t be an improvement for those people in terms of trafic impacts and tailpipe emissions.
We also cant simplify our housing needs just around the meeting of generic “units” for the sake of RHNA goals. If we build high-cost single family housing that doesnt pencil economically for our city in the long term and is inevitably going to not be affordable by our local workforce, then it is better that we build nothing at all ( which is course is also not an option)
Finding the optimal solution here requires a series of AND statements:
We need density AND multifamily construction AND mixed-use zoning AND reliable transit service going to it.
Not exactly something that lends itself to a soundbyte. But davis voters are smart. I think they will get it… eventually.
TK say: “But davis voters are smart. I think they will get it… eventually.”
Maybe, but not before it’s too late. Maybe, but our Council doesn’t get it about transportation, so without a mutiny, it’s too late. Build the auto-centric! Build Baby Build! Just build because we “need” housing “now”. The long term effects be d*mned!
Three quick comments and more as we move through the process.
1. There is no project associated with the Shriner’s organization and it is misleading to call it that. Call it by whomever filed the application or perhaps just Eastside.
2. There are places to build that are not on some of the best ag land in the world. Forcing this is a problem with the state building mandate and needs to be changed in the legislature. But, it is not true that if we don’t build here it will just happen on farmland elsewhere. We need to do our part to minimize growth on ag land.
3. I recognize there will be some incremental growth on ag land and Village Farms is a good option. But let’s build as dense as we can. More housing on less land to use land as efficiently as possible. Density is also critical for transit systems.
FYI, the city website and the application both list it as “Shriners Property.” I’m sure at some point they will change the name, but as of now, that’s the name they are using.
“We can think of this in several ways. If we are not building on farmland here, we may well be causing farmland somewhere else to be built upon. So preserving farmland here doesn’t necessarily preserve farmland.”
CEQA practioners have taken a very narrow view of “cumulative impacts.” I ran into this problem when I worked for a firm that did EIRs and the firm’s leads were really unqualified to assess cumulative impacts. (They had other more useful skills.) So it doesn’t occur to them that building in Davis in a more compact fashion is likely to save more ag acreage around the periphery of Sacramento, Elk Grove, Roseville, Vacaville and Woodland than is consumed by Davis development. There’s a myth that stopping development in one location will stop it everywhere else. Of course that’s not true. So the No Action Alternative is likely to be an inferior option based on a valid cumulative impact analysis rather than the fiction used by the EIR.
I’m curious about the assumptions about commuting in the EIR. Using the Census On the Map data and the UCD ITS Travel Survey, there are 17,276 workers who live in Davis and commute outside of the Davis + UCD, 10,471 who both live and work within Davis + UCD and 28,631 who commute into Davis + UCD from elsewhere. Our housing projects need to target this third group to reduce the environmental impact. Adding 200 houses to the “missing middle” out of 1800 isn’t going to do the trick.
Also, I don’t understand why “increasing property taxes” is an “objective.” Shouldn’t the objective be “improving the City’s net fiscal situation”?
So it doesn’t occur to them that building in Davis in a more compact fashion is likely to save more ag acreage around the periphery of Sacramento, Elk Grove, Roseville, Vacaville and Woodland than is consumed by Davis development. There’s a myth that stopping development in one location will stop it everywhere else. Of course that’s not true. So the No Action Alternative is likely to be an inferior option based on a valid cumulative impact analysis rather than the fiction used by the EIR.”
No one is stating that stopping development in one location will stop it elsewhere – what is your source for that claim? In fact, your claim is the exact opposite (which is also not true): That building it in one location will prevent it from occurring elsewhere.
Surrounding cities will (still) actively pursue growth even when the overall population is declining. The birth rate (nationwide) is far-below replacement levels.
The truth is that all of the surrounding cities actively pursue sprawl, and will continue doing so regardless of what Davis does (or doesn’t) do. These plans are available to anyone who wants to look them up.
The only “choice” that Davis has is whether or not to sprawl outward, in ADDITION TO all of the sprawl that other cities are pursuing.
So because every other town is growing like a weed, Davis has to grow like a weed? Shouldn’t we be thinking about the environmental effects of unlimited growth? Do we want the Sacramento Region to resemble the Los Angeles basin? Despite all the slams on saving the ‘smelt’ after the So-Cal fires, I actually do care that water is poured out to sea to sustain the fish, rather than increasing used to fuel growth.
I see the “Density” is the magical unicorn solution to development (housing and otherwise) crowd is out in force and vocal again.
“But davis voters are smart. I think they will get it… eventually.”
Lol…that’s the problem…all the “smart” people who think they’re urban planners and agents of economic development. How’s that been working out for the past 20 years?
“There’s a myth that stopping development in one location will stop it everywhere else”
Do not ruin the belief of the faithful that Davis is a shining beacon of social and environmental responsibility! Other communities will know the legend of Davis and be inspired to follow suit. We must continue to signal to the rest of the world.
“So because every other town is growing like a weed, Davis has to grow like a weed?”
Again…lol…OH MY GOD THE SKY IS FALLING!!!! If we let a little development happen it’ll be like letting communism take foot in country and the URBAN DOMINO EFFECT will happen! We won’t be able to stop it! The agony of allowing a housing development to happen and then another will happen against our will because…uh reasons? OH MY GOD IF WE ALLOW A COSTCO to be built….against our will a (god forbid…think of the children!) Walmart will pop up in the middle of the night against the wishes of the good citizens of Davis.
Keith E states: “There’s a myth that stopping development in one location will stop it everywhere else”
As already noted, there is literally no one saying that. Instead, the development activists are claiming that approving development will stop it everywhere else.
(The exact opposite of the myth that has been put forth twice, now. Which is also a myth.)
Nothing that Davis does, or doesn’t do will impact any of the developments that other cities have already created plans for. Those cities love sprawl – can’t get enough of it. One would think that the growth advocates would be happy with that, but no – they want it for Davis, too. And the more it’s resisted, the more they want that.
Keith E states: Lol…that’s the problem…all the “smart” people who think they’re urban planners and agents of economic development. How’s that been working out for the past 20 years?
I personally think it’s been working out pretty well, though I hate to see the loss of some places (e.g., ACE housewares, Hibbert’s, etc.).
Good thing that Davis is getting a rehabilitated mall – despite the efforts of the growth activists.
Two points about building on farmland.
In the last 20 years we have preserved much more farmland around Davis through conservation easements than we have built houses on.
Secondly, the people advocating for preserving farmland most likely live on what used to be farmland.
Once again we see a lack of leadership by example.