DAVIS, Calif. — The City of Davis has released a partial draft response to comments on the previously circulated Draft Environmental Impact Report for the proposed Village Farms Davis project, offering an unusually detailed early look at how city staff and consultants are addressing some of the most contentious environmental questions surrounding one of the largest housing proposals in the city’s history.
The document, made public ahead of the Final Environmental Impact Report, is not required under the California Environmental Quality Act. City materials state that it is being provided “to give the public and decision makers an early preview of the partial responses to comments on the previously circulated DEIR for the project” and that it is being released “for maximum public transparency.”
The city cautions that “minor revisions to this draft document may be required” after the close of the current 45-day comment period, which runs from Nov. 17, 2025, through Jan. 2, 2026.
The Village Farms project, proposed on agricultural land at the city’s eastern edge, has generated intense scrutiny from residents, environmental groups, housing advocates and regional agencies. During the public review of the Draft EIR, the city received 216 written comment letters, along with verbal testimony presented at a Planning Commission hearing.
Those comments raised a broad range of concerns, including the conversion of farmland, impacts to biological resources, increased traffic and vehicle miles traveled, flood risk, hazardous materials and greenhouse gas emissions. The partial draft responses represent the city’s first comprehensive written attempt to address those critiques.
Many commenters challenged the environmental review on a threshold level, arguing that the EIR should weigh in on whether the project should move forward at all. In response, the city emphasized the limits of the CEQA process, writing that “the environmental review process provides an impartial evaluation of the environmental impacts should the Proposed Project/BRPA be implemented” and that it “does not provide an opinion regarding whether the project should be approved or denied.”
The city further stated that policy considerations such as economic benefits, taxes, housing demand and public sentiment fall outside the scope of environmental review. Those issues, the document explains, are “weighed by factors outside the scope of the EIR, including public support, taxes, jobs, economic and social benefits.”
Another sharp critique focused on the EIR’s treatment of alternatives, with opponents arguing that the city failed to meaningfully analyze a smaller or less intensive version of the project. Several commenters cited prior Davis development battles and contended that the analysis should have included a more substantially reduced footprint.
City staff rejected that argument, stating that “the range of six alternatives included in the Village Farms Draft EIR constitutes a reasonable range and permits a reasoned choice amongst the decision-makers, thus meeting the requirement of CEQA Guidelines Section 15126.6(f).”
Those alternatives include a no-project option, two lower-unit alternatives, an agricultural resource preservation alternative, a biological resources preservation alternative and a higher-density alternative. The city concluded that CEQA does not require multiple permutations of similar concepts once a legally sufficient range has been examined.
Some commenters went further, asserting that the EIR improperly excluded social and economic harms from its analysis. The city responded that “the scope of an EIR is limited to a local agency’s evaluation of potentially significant environmental impacts of a project, which by definition are limited to physical conditions, rather than social or economic conditions.”
Traffic impacts drew sustained criticism, with residents warning that the project would inevitably generate congestion regardless of mitigation. In response, the city cited CEQA guidance stating that “responses to general comments may be general” and directed commenters to the detailed transportation analysis contained elsewhere in the Draft EIR.
The project’s higher-density alternative proved especially controversial. Opponents argued that adding units would compound environmental harm rather than alleviate it.
The Draft EIR addresses that critique directly, stating that “the Higher Number of Units – Same Footprint Alternative would include the development of 900 additional residences, for a total of 2,700 residential units.” The city explains that the unit count was selected “in order to reduce per capita VMT below both City and regional average VMT thresholds.”
City staff noted that evaluating higher-density alternatives is common practice in environmental review and has been upheld in previous Davis projects and court decisions. The responses cite state guidance supporting density as a strategy for reducing transportation impacts.
Hazards and hazardous materials generated some of the most pointed public comments, particularly regarding the Old Davis Landfill and groundwater contamination. Commenters warned that the EIR failed to address potential health risks to future residents.
In response, the city relied on California Supreme Court precedent, stating that “agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project’s future users or residents.” The city explained that CEQA analysis is triggered only if a project would worsen existing hazards.
Based on site investigations and regulatory agency input, the city concluded that the Village Farms project would not disturb contaminated soils or groundwater. The project would rely exclusively on municipal water supplies.
A letter from the regional water board cited in the EIR states that it “does not believe a risk is posed to the residential and commercial properties proposed for development if the development is connected to the existing City municipal water system.”
Concerns about soil contamination, particularly arsenic, were also raised repeatedly. Some commenters characterized the land as unsafe and demanded additional remediation.
The city responded by citing supplemental soil sampling conducted after the Draft EIR was released. According to the responses, arsenic concentrations across both the development area and adjacent agricultural land were consistent with regional background levels. The city concluded that arsenic “is not considered to be a contaminant of concern.”
Flooding and drainage impacts represented another major line of critique, especially in light of climate change and existing downstream constraints. Residents questioned whether the project could worsen flooding in surrounding neighborhoods.
The city’s responses describe hydraulic modeling that evaluated storms up to a 200-year, 10-day event. According to the EIR, “peak flows in the 200-year, 10-day storm event leaving the project site are anticipated to be equal to or reduced compared to the existing condition.”
City staff added that any development within designated flood hazard areas would require FEMA approvals and compliance with local floodplain regulations. Drainage improvements, the document states, are designed to exceed minimum federal standards.
Some commenters argued that the scope and substance of revisions required recirculation of the EIR. The city rejected that claim, stating that recirculation is required only when “significant new information” deprives the public of meaningful review and concluding that “recirculation of this EIR is not required.”
Beyond individual technical disputes, the partial draft responses underscore a central reality of the project. The city acknowledges that even with mitigation, Village Farms would result in several significant and unavoidable environmental impacts.
Those impacts include effects on agricultural resources, greenhouse gas emissions, biological resources, noise, population and housing and transportation. Under state law, approval would require the City Council to adopt a Statement of Overriding Considerations.
That statement would require elected officials to explicitly conclude that the project’s benefits outweigh its environmental harms. It is a political and policy judgment that extends well beyond the technical findings of the EIR.
City staff emphasized that the partial draft responses do not constitute the Final Environmental Impact Report. The Final EIR, they note, will incorporate revisions as needed after the close of the current comment period.
Certification of the Final EIR and any subsequent project approvals will occur at a future City Council meeting. Council members are expected to weigh the environmental record alongside housing needs, state mandates and public sentiment.
City staff emphasized that the partial draft responses do not constitute the Final Environmental Impact Report. The Final EIR, they note, will incorporate revisions as needed after the close of the current comment period.
The Davis Planning Commission is scheduled to meet this week to consider whether to certify the Environmental Impact Report, a key procedural step before the project moves on to further review and potential action by the City Council.
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Don’t count on solutions from the response to the Village Farms Draft EIR for concerns and issues raised. This “partial responses” release so far dismisses a multitude of issues which cannot, and should not be ignored. It is typical of EIR’s whose job seems more to come up with deflections and excuses, rather than addressing the issues and being honest about the problems. You cannot wish away toxics including carcinogenic PFAS’ leaking from the adjacent unlined Old City Landfill, nor can you wish away the flooding risks from the 200-acre flood plain. Nor should you dismiss the impacts of re-routing of Channel A which is the main drainage system of the City from the west end of Davis to the east side of Davis and eastward through Wildhorse neighborhood then via Willow Slough Bypass to the wetlands habitat with wildlife to the east and water ways beyond. The Draft EIR acknowledges that Channel A’s runnoff water could potentially mix with the groundwater with these PFAS ‘ toxics and other chemical contaminants. What a catastrophic outcome that would be for the Vic Fazio Wildlife area and Yolo Basin were to be polluted due to Village Farms contaminated runoff.