Myths vs. Facts about Village Farms Davis
Opponents of Village Farms Davis have made numerous misleading and/or outright false claims about the Project and its supposed adverse environmental impacts on Davis and its residents. Their allegations are made without almost no quantitative supporting data from independent, verifiable 3rd-party sources to support their claims. Unfortunately, these naysayers instead rely on speculation and innuendo to attempt to disparage and denigrate the proposed Project.
This article is the first in a series that will present detailed information that factually refutes each of these untrue “myths” and false allegations made by project opponents . This first article summarizes the false claims and provides a brief summary response followed by a more in-depth discussion refuting some of the allegations that require additional information to refute them. Subsequent articles in the coming weeks will further address some of these false claims in much greater detail.
II. SUMMARY OF MYTHS AND FACTS
A. Alleged Risks of Flooding
Myth No. 1 – “The Project is partly in a FEMA 100-year floodplain that results in huge onsite flood risks for future residents!”
Fact No. 1 – This is a red herring argument. In fact, the Project is engineered to meet FEMA 200-year floodplain protection standards making it one of the most flood-resilient neighborhoods in Davis. FEMA must certify the lots before construction so that flood insurance will not be required by future residents. (see Further Discussion section below for additional information)
Myth No. 2 – “The Project will cause enormous downstream flooding impacts endangering homes and residents in Wildhorse!”
Fact No 2 – There is not now, nor will there ever be, ANY future runoff from the Project onto Wildhorse Golf Course . Any runoff from the Project will instead be directed north to a detention basin away from the channel which otherwise only conveys flood waters from west and north Davis through the North Covell Ditch to the Wildhorse Golf Course. (see Further Discussion section below for additional information)
B. Alleged Risks of Toxic Contamination from Landfill and Soils
Myth No. 3 – “Toxic contamination from the nearby Old Davis Landfill endangers future residents of the Project”
Fact No. 3– Almost all of the contamination detected in the past in the groundwater beneath the Landfill and the Project has long since dissipated. The California Regional Water Quality Control Board has confirmed in a letter to the City that the groundwater beneath the Project will present “no risk” to Project residents that will otherwise only use Davis municipal water supplies. (see Further Discussion section below for additional information)
Myth No. 4 – “PFASs (“forever chemicals”) detected in groundwater under the Project will seep into Channel A and flow out through Wildhorse Golf Course into Willow Slough and the Yolo Bypass Endangering the Vic Fazio Wildlife Refuge!.”
Fact No. 4 – Village Farms Davis will actually provide increased protection from PFAS infiltration into Channel A. The current Channel A is unlined which theoretically could allow PFAS to enter the Channel – but only if groundwater rises significantly higher than ever before recorded. The new Channel A depth will be deeper but still substantially above the maximum water table ever recorded. Plus the new Channel will be lined with an impervious compacted clay layer to prevent any infiltration of groundwater into the Channel. (see Further Discussion section below for additional information)
Myth No. 5 – “Children will be exposed to the pesticide Toxaphene and Lead in Soil in the Project’s Future Community Park endangering their future health!”
Fact No. 5 – These contaminants were located in only a few discrete locations on the soil surface near the old homestead on the property. But Project opponents fail to disclose that complete removal and remediation of these discretely localized contaminants will be performed under the auspices of and certified by the California Department of Toxic Substances Control to non-detectable levels before commencement of any construction. After removal, the entire site will be completely free of these contaminants.
Myth No. 6 – “The entire Project site will be contaminated with very high levels of arsenic brought in with the soil from the Agricultural Transition Area to the north of the project putting future residents at risk!”
Fact No. 6 – Extensive soil testing (down to 10 ft) in the Agricultural Transition Area show background concentrations of naturally-occurring arsenic average 7.0 mg/kg (ppm). These concentrations are actually slightly less than average arsenic concentrations of 7.1 mg/kg found in the Project site. Further, arsenic concentrations at both sites are actually substantially less than reported regional soil arsenic concentrations (at an average of 10.0 mg/kg) and thus present no risk to future residents of the Project.
C. Alleged Traffic and Public Transit Adverse Impacts
Myth No. 7 – “Huge traffic increases on Poleline Rd and Covell Blvd. will cause massive traffic jams imperiling bicycling safety.”
Fact No. 7 – Of course, any large development will bring increased traffic impacts as will Village Farms Davis once it is built out in 15 years +/-. However, the central location of the Project is within easy walking or biking distance of many destinations thus minimizing future commuting and intra-city automobile traffic. And there are 18 public bus stops near the Project which minimizes future commuting and intra-city automobile traffic.
Nugget shopping center is directly across the street. There are four K-12 schools within ¾ mile. Downtown and UCD are each about 1.5 miles away. As a result, there is no other location in the City that offers this many public transit options and close proximity to so many local destinations. This central location of the Project with so many public transit and biking options results in less traffic and biking impacts than if 1,800 units were otherwise built anywhere else in the City. (see Further Discussion below for additional information)
Myth No. 8 – “The Project will not have any grade-separated crossings of Pole Line Road and the railroad tracks at F St.!”
Fact No. 8 – There will be Grade-Separated Crossings both under Poleline Rd. and over F St. Village Farms Davis will entirely pay for the below-grade crossing under Poleline Road landing near Nugget Fields. For the over-crossing of F. St, the project will provide the land on the project site, fund the design and engineering, and pay for the project’s “fair-share” cost of the over-crossing construction with a landing near Northstar Pond.
D. Alleged Adverse Impacts on Habitat
Myth No. 9 – “The Project will destroy valuable wetland habitat endangering rare plants and animals!”
Fact No. 9 – The Project will preserve approximately 47.1 acres of alkali playa and wetland habitat with a permanent conservation easement and perpetual endowment. This includes the associated watershed and a buffer to protect it from development impacts. This feature will be developed in coordination with qualified conservation/land trust organizations and according to explicit guidelines of the California Department of Fish and Wildlife. There has NEVER been a development project in Davis that has dedicated this much land to native habitat.
Myth No. 10 – “The Project will permanently destroy a thousand trees along Channel A that provides critical habitat for animals!”
Fact No. 10 – The FEIR discloses a total of several hundred trees along the existing Channel A that will be removed of which only 45 are native. Most of the trees are otherwise aged and decrepit and nearing the end of their natural lives. However, all removed trees will be be replanted with drought-resistant species per City requirements. And approximately 3,600 additional new drought-resistant trees will be planted throughout the entire project. This will result in a huge increase in the overall number of trees thus greatly enhancing the urban forest.
E. Alleged High Housing Costs and Deficiencies in the Affordable Housing Plan
Myth No. 11 – “The minimum cost of a new home at Village Farms will be $740,000. Only very well-to-do purchasers will be able to afford to live there!”
Fact No. 11 -This is a complete fabrication. As Project opponents are well aware, the supposed “minimum” estimated sales price they tout is actually the “average” cost of a home sold in Davis in 2025. In fact, there are about 1,000 lots in the project that will be less than 5,000 sq ft on which hundreds of townhouses and smaller homes/duplexes on the order of 800 – 1,400 sq ft will be constructed.
These smaller lots are specifically designed for first-time home buyers. Of these smaller lots, at least 10% will be for attached townhouses expected to be between 800 and 1,000 sq ft. The remaining lots can either be half-plexes or stand-alone single family units and are expected to range from 1,000 – 1,400 sq ft each.
Assuming the same $425/sq ft sales price as used in the City’s economic analysis described above, the 800 – 1,000 sq ft townhouses would cost less $425,000 and the 1,000 – 1,400 sq ft half-plex/single family homes would range in price from $425,000 to $637,500.
These prices are thus far less than the fictitious “minimum” price of $740,000 otherwise erroneously touted by project opponents. (see Further Discussion below for additional information)
Myth No. 12 – “The 360 dedicated low-income housing units will probably never be built because there are no guarantees that the developer must construct them!”
Fact No. 12 – The proposed permanently affordable, subsidized rental apartments represent 20% of the total 1,800 units for the project. It is supported by an irrevocable 16-acre donation of land and an additional $6 million contributed to the Davis Housing Trust Fund to support construction. This donation is, by far, the largest contribution ever to low-income housing by any developer in Davis. This current customized Low Income Housing Plan is fully compliant with the City’s Low Income Housing Ordinance and was specifically demanded by the City because they believe it has the highest probability that the affordable housing units will actually be built.
III. FURTHER DISCUSSION OF SELECT MYTHS AND FACTS
The following discussion contains more detailed information refuting some of the false allegations made by opponents of the Projectthat are discussed more briefly above
A. Alleged Risks of Flooding
Myth No. 1 – “The Project has Huge Onsite Flood Risks because it is partially in a FEMA 100-year Floodplain!” – Opponents claim a portion of Village Farms Davis is in a FEMA 100-year floodplain which will undoubtedly flood in the future exposing the City to huge liabilities and require homeowners to pay huge flood insurance premiums.
Fact No. 1 – In fact, opponents are fully aware that the Project will meet FEMA 200-year flood protection standards before construction even begins . While a portion of Village Farms is currently in a FEMA 100-year floodplain, the site will be engineered to provide protection for a 200-year flood event as now required by State law. All lot elevations will be certified by FEMA prior to authorization of construction and NO FEMA flood insurance will be required for any homes.
As a result, Village Farms Davis will actually be more flood-resilient than almost all other subdivisions in Davis. Indeed, there are currently over 400 acres of existing housing in Davis that are still in the FEMA 100-year floodplain map including substantial areas in west, north, and central Davis as shown in the following map (the 100-year floodplain is shown in blue cross-hatching).
Myth No. 2 – “The Project will cause enormous downstream flooding impacts endangering homes and residents in Wildhorse!” – Project Opponents Falsely Claim the Project will Result in Increased Run-off Flow under Poleline Rd onto the Wildhorse Golf Course Causing Flooding and Endangering Homes and Residents in the Adjacent Wildhorse Neighborhood.
Fact No 2 – There is not now any runoff from the Project into Wildhorse nor will there be in the future. Project opponents are well aware of the fact that Village Farms Davis does not now & will not in the future convey any runoff water from the project into Channel A and on into the Golf Course. The Project is engineered to maintain existing flow conditions in Channel A and all runoff from the Project will only be directed north to a detention basin away from the channel.
The only water entering Channel A (before & after construction) is water conveyed from the North Covell Ditch. This water flows into conveyance Channel A on the northwest corner of the Project and then flows through it and under Poleline Rd. into the Wildhorse Golf Course. The relocated Chanel A in the future also will not convey any runoff from the Project onto the golf course.
In fact, the Project will actually reduce excess runoff from the North Covell Ditch into the Wildhorse golf course because the newly constructed Channel A conveyance crossing the project will be deeper and wider with greater holding capacity. Additionally, the golf course itself is constructed with a broad floodplain itself to protect it from flooding events.
B. Alleged Risks of Toxic Contamination
Myth No. 3 – “Toxic contamination from the nearby Old Landfill endangers future residents!” -Opponents falsely claim future residents will be exposed to massive toxic contamination leaching into the groundwater from the adjacent former Old Davis Landfill Site.
Fact No. 3 – Almost all of the volatile organic organic contamination previously measured in the groundwater beneath the Landfill and the Project has long since dissipated. Further, Village Farms Davis will NOT be built on top of the former landfill even though there are dozens of other large residential and commercial development sites in California (including K-12 schools) that have been safely built directly on top of former landfill sites without any subsequent contamination or health risks to residents or building occupants.
There are 3 monitoring wells under the former landfill site and 3 under the Project site that have been continuously tested for contaminants since the 1980s and through 2024. Long term monitoring has shown that all of the numerous different volatile organic chemicals (VOCs) detected under the landfill and the Project during the 1980s – 2000s have completely dissipated and are no longer detectable. They are simply gone!
More recently. PFASs (a class of fluoridated hydrocarbon widely used in apparel treatment and food packaging) was detected in one of the 3 wells under the Project in 2024 testing at a concentration above the drinking water Maximum Concentration Limit (MCL) established by the US Environmental Protection Agency. None of the monitoring wells were tested for PFASs before 2024 so it is not known what concentrations of these PFASs pre-existed in the groundwater before 2024 (see below for additional information on PFASs)
However, the Central Valley Regional Water Quality Control Board staff reviewed available records for the Old Davis Landfill case based on written concerns expressed by a Davis resident complaining that there will be unacceptable risks to future residents of Village Farms Davis. In response, the Regional Water Quality Control Board confirmed in a letter to the City that the Project is not at risk due to landfill contamination stating, “ ...Staff 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 and the City water system is the sole means of water used by the development.“.
In as much as the Project 1) will rely entirely on Davis municipal water supply and 2) all existing wells on site will be permanently capped before home construction and occupation ensuring no groundwater from the project site can ever be pumped in the future, there is thus no risk of exposure to future residents.
Myth No. 4 – “PFASs (‘Forever Chemicals’) detected in groundwater under the Project will seep into Channel A and flow out through Wildhorse Golf Course into Willow Slough and the Yolo Bypass endangering the Vic Fazio Wildlife Refuge!” – Opponents falsely claim that the Project will result in increased contamination of the Yolo Bypass.
Fact No. 4 – Village Farms Davis will actually provide increased protection from PFAS infiltration into Channel A. The current Channel A is unlined which theoretically could allow PFAS to enter the Channel – but only if groundwater rises significantly higher than ever recorded. The new Channel A depth will be deeper but still substantially above the maximum ground water level ever recorded. PLUS, AND the new Channel will be lined with an impervious compacted clay layer preventing any infiltration from groundwater from the site.
Therefore, according to the DEIR, “…substantial evidence exists to conclude that potentially contaminated groundwater from the Old Davis Landfill would not come into contact with the Proposed Project/BRPA storm water system. As a result, substantial evidence exists to support the conclusion that the project’s runoff would not transport contaminated water into the downstream system.” – DEIR (4.8 – 23). Also see Channel Evaluation Report “.
More Information on PFASs – PFAS are fluoridated hydrocarbon chemicals widely found in waterproof and grease-proof apparel and food packaging through which it finds its way into the environment and the human body. The EPA estimates that 99% of US residents have some levels of PFASs in their bloodstream and 155 million people in the US have some levels of PFASs in their drinking water supplies. Fortunately, PFASs have not been detected in Davis municipal drinking water supplies. However, PFASs are otherwise continuously being released from the Davis Wastewater Treatment Plant (WWTP) into the Yolo Bypass.
The majority of PFASs in effluent from the Davis WWTP are due to human waste – primarily in urine – which contaminants are poorly removed during normal waste water treatment plant operations. In fact, the Davis WWTP sampled its effluent on multiple dates in 2021 and found an average total PFAS concentration of 111 ppb in its effluent of 6 million gallons per day. This is twice the concentration of total PFASs found underneath the project site (59 ppb) which are otherwise not expected to contribute to ANY increase in PFASs released into Channel A and, eventually, the Yolo Bypass.
Project opponents concerned with PFASs entering the Yolo Bypass would do well to instead focus on this massive plume of PFASs otherwise flowing into Yolo Bypass from our own municipal WWTP rather than speculating on some infinitesimal risk that PFASs will somehow enter Channel A from groundwater beneath the Project in the future.
Indeed, if Project opponents are really that concerned with PFASs entering Yolo Bypass and endangering wildlife, perhaps they could all collectively stop urinating in their toilets to eliminate their own personal contributions to PFASs discharged into those wetlands.
C. Alleged Traffic and Public Transit Concerns
Myth No. 7 – “Huge traffic increases on Pole Line Road and Covell Blvd. will cause massive traffic jams and back-ups and imperil bicycling safety!”
Fact No. 7 – Of course, any large development will bring increased traffic impacts as will Village Farms Davis once it is built out in 15 years +/-. However, the central location of the Project is within easy walking or biking distance of many destinations thus minimizing future commuting and intra-city automobile traffic. And, the location of Village Farms Davis is immediately adjacent to or within a short walk of 18 existing dedicated bus stops for six Unitrans (E, F, L, P, Q, and T) and two Yolo Bus (43 and 230) routes.
There is no other location in the City that offers this many public transit options and close proximity to so many local destinations. Nugget shopping center is directly across the street. There are 4 k-12 schools within 3/4mile. Downtown and UCD are each about 1.5 miles away.
This central location of the Project with so many public transit and biking options result in less traffic and biking impacts than if 1,800 units were otherwise built anywhere else in the City.
Additionally, extensive bike path and biking safety-related street improvements along with on- and off-site roadway improvements are required by the Project to minimize vehicular traffic and biking impacts.
Bike Path-Related Improvements
• Construction of new Class I shared-use paths along the Pole Line Road (west side) and
East Covell Boulevard (north side) of the site frontages,
• Construction of new Class I shared-use path connections at all intersections into the Project,
• Construction of 2 grade-separated crossings – one under Poleline Rd and one over the
railroad tracks and F. St.
• Develop over 7 miles of multi-use trails, public bike lanes and walking paths throughout
the Project,
• Agricultural Trail Buffer Improvements north and west of North Village.
Additional Biking Safety and Traffic Related Street Improvements
Construction of the following modifications at existing intersections:
• East Covell Boulevard/L Street – New north leg and accompanying signal modifications,
• Pole Line Road/Picasso Avenue – New west leg and traffic signal,
• Pole Line Road/Donner Avenue – New west leg and traffic signal,
• Pole Line Road/Moore Boulevard – New west leg and roundabout,
• Bike crossing improvements on Cannery Loop near the Cannery Dog Park,
• Three high visibility crossings improvements on Covell Blvd between Heritage Oak Park
& Oak Tree Plaza,
• High visibility crossing improvements on Covell Blvd at Birch Lane, and
• Stripe Class III bike route on Birch Lane from Covell Blvd to Pole Line Road.
Additional On and Offsite Roadway Improvements
• Roundabout at Moore Blvd and intersection improvements,
• Traffic Signals at Donner,
• Traffic Signal at Picasso,
• Improvement to the Pole Line/Covell Intersection,
• Frontage Improvements to Pole line Road and Covell Blvd.,
• Signal timing and transit optimization along the Covell Blvd/Mace Blvd corridor to
improve traffic flow,
• Fair share funding toward cumulative traffic impacts including expansion of roadway
facilities and construction of traffic control and safety improvements along the Covell
Corridor.
E. Alleged High Housing Costs
Myth No. 11 – “The minimum cost of a new home at Village Farms will be $740,000. Only very well-to-do purchasers will be able to afford to live there!”
Fact No. 11 -This is a complete fabrication. Mark Twain once famously said, “There are lies, damned lies, and statistics” when describing how false information is often spread buttressed by the incorrect use of “statistics”.
The original reference to the “minimum” price of a home was incorrectly excerpted by Project opponents from an economic analysis of the property taxes that might be generated by the project. The analysis was done for the City by BAE Associates for the City. That study estimated future property taxes,in part, by assuming the “average” size home on “medium density lots” would be 1,741 sq ft selling for an “average” of $425 /sq ft – or an “average” sales price of $740,000. But that data was based on historical market data on recent home sales prices in Davis, as follows;
“Assessed Valuation
The assumed starting valuation for the residential units is split among medium density,
low density and market rate apartments. The estimated market rate for medium density
units is $425 per square foot (or $740,000), with low density set at $480 per square foot
($1,340,000). Apartments are set at $400,000 per unit. These assumptions are
generated from current market data and staff believes are reasonable.” (see Staff Report 06A-Village-Farms-BAE Fiscal-Impact Memo_4-2-25.pdf)
As project opponents are fully aware, this analysis had nothing to do with what size homes and pricing were actually proposed for the project. In fact, as recently approved by the City Council, there are 1,017 lots in the project that will be less than 5,000 sq ft on which hundreds of townhouses and smaller homes/duplexes will be constructed.
These smaller lots are specifically designed for first-time home buyers. Of these smaller lots, at least 10% will be for attached townhouses expected to be between 800 and 1,000 sq ft. The remaining lots can either be half-plexes or stand-alone single family units and are expected to range from 1,000 – 1,400 sq ft each.
The actual per square foot sales price of these townhouses and smaller half-plex/single family homes will be highly dependent on then current construction costs. But assuming the same $425/sq ft sales price as used in the City’s economic analysis described above, the 800 – 1,000 sq ft townhouses would cost less $425,000 and the 1,000 – 1,400 sq ft half-plex/single family homes would range in price from $425,000 to $637,500.
These prices are thus far less than the fictitious “minimum” price of $740,000 otherwise erroneously touted by project opponents.
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Partial response regarding the bus stops on the other side of F St: the required height over the railway will necessitate a very long route! The industry standard is a 4.2% gradient, with a maximum of 5% before certain measures are needed per ADA. Consider the existing over crossings in town: Mace, Pelz, Pole Line, Richards: all of them are about 6 to 7%. The freeway adds a lot of width, but so does the flood channel and F St. itself. It seems that the over crossing length will be similar to the existing ones. Do we expect people to walk from the equivalent of Chiles to 2nd or Research Park Drive to Olive Drive to catch a bus?
Aside from accessing public transportation, what’s all the other stuff that’s easy to walk to? Nugget? CVS, a couple of other stores? There’s no entertainment, perhaps one future corporate café. There’s already a lot of people closer in to the rest of the city, and how many of them ride bikes, especially those who have cars and aren’t going to campus? Not a lot.
Yes, ownership of cars! The empty “easy cycling distance” is too often in Davis the B-side, hardly listened to. The record, straight: The A-side is that owned car, very close by for so many people that live here and it’s gonna remain in the top of the charts!
There’s absolutely no planned improvements for anything south of Covell. This would require an huge amount of parking removal. This means that it’s gonna be just as difficult or as an interesting as now for people to cycle, that way, unless they have to.
More generally, I’ve never seen this kind of proposal for good public transport access which shows the entirety of stops outside of the project, and none of them a major mobility hub.
Finally, especially given what the author has worked on – nobly, for years – it’s quite curious to see a mention of road expansion as a good thing or necessary.
A lesser of two evils has some gravitas, true, but so much of the analysis and assumptions here are thin or wrong that I question the entirety of the transportation piece in this… straight record.
Re: “I’ve never seen this kind of proposal for good public transport access which shows the entirety of stops outside of the project, and none of them a major mobility hub.”
Discussions with Yolobus/Unitrans re extending some routes into a centralized mobility hub in the project have apparently commenced. But the agencies will not make any commitments until the project is well underway and the population demographics/ridership profile can be determined.
Re: “… it’s quite curious to see a mention of road expansion as a good thing or necessary.”
Although mentioned as a future possiblity for study in the mitigation measures, I do not see any major road expansions resulting from this project. There are only lots of intersection improvements and bike path construction projects listed in the transportation mitigations actually proposed.
Will look at this later in more detail, but no one knows why Alan has been such a staunch defender of this proposal right from the start.
But at least the Sierra Club ultimately did not take a position on it.
By the way, it seems to me that there is no such thing as a new, detached, single family house in Davis that’s going to sell for less than $835,000 (for one that’s 1,472 square feet), if Harvest Glen is any indication:
https://www.centurycommunities.com/find-your-new-home/california/northern-california-metro/davis/harvest-glen/?utm_source=google_local&utm_medium=organic&utm_campaign=harvest-glen_gmb_ccs&utm_content=california
Bottom line: Get yourself some money, or buy a used one (which still requires money). Or better yet, buy one somewhere else (which also requires money – but less of it).
If you can build at $500 – which from all my inquiries is possible in Davis, then yes, you can sell for less than $835.
Seems to me that the cost to build is both hidden and irrelevant.
All I can tell you is that new ones are selling for $835,000 for a 1,472 square foot house with no yard. There’s your “starter home”.
It’s actually a better deal to get one in that same development that has an ADU, for not much more. (I looked at the model yesterday, and was impressed). The guy told me that they’ve sold two of the ones with ADUs, already.
They only have that one model to visit (with a built-in ADU).
Get yourself one of those, and some of your costs will be deflected via rent.
I didn’t ask, but I suspect this development also has lower Mello Roos than anything that would be built outside of city limits, such as Village Farms or Shriner’s.
If I was in the market and able to afford it, I’d seriously consider the one with an ADU.
The $500 includes a 20 percent gross margin. Alan actually does the math in one of his sections…
Unless there’s a legally-binding agreement to sell all houses with no more than a 20 percent markup, and assuming that you know what the costs are in the first place, that type of analysis is completely and totally meaningless.
They’ll sell them for whatever they can get. And since new single-family houses are selling for $835K for a 1,472 square foot one at Harvest Glen, that likely sets the “low bar” for new housing that’s built on farmland outside of city limits several years from now (with higher Mello Roos, to boot).
You and Alan are essentially claiming that people who bought their houses 40 years ago (for $100K) “should” sell them for $120K – plus “normal” inflation, I assume).
When they might be worth $800K.
Pretty sure it doesn’t work that way. Costs are irrelevant. The market dictates price, not costs.
Maybe you or Alan can get something in writing from the Village Farms developer that they won’t sell their homes for more than $740K, as they’re built over the next 20 years or so – if approved. Or alternatively, that they won’t sell them for more than 20% markup, and will fully disclose their costs along the way (which would still result in houses costing more than $740K, over time).
Can’t have a binding contract on market rates but ultimately houses sell for the highest bidder.
You would need to look at the specifics of the Harvest Glen house and figure out why it is selling for $835K… From the link there appears to be a yard and a garage, so that might be the start of an explanation.
The model I saw did not have a yard (other than a small side yard, facing the entrance/exit to the development). It will have a garage. It appears that there won’t be any street parking, but that there will be dedicated, separate spots for visitors, those who don’t park their cars in garages, etc. (Just like two other recent developments in Spring Lake – one of which has recently been completed.) Almost certainly not enough to accommodate “demand” at any of these developments.
Are you or Alan actually suggesting that there won’t be garages for housing (single-family, or otherwise) at Village Farms? How about dedicated spots such as those described above?
Looks like a yard to me:
Fake picture – I was there. No yard at the model house (other than a tiny side yard).
They also show a fake picture (with a yard) for the model house #3, on that website. Go there and take a look, and tell me if you see a yard. What you will see is the sales office where the garage will be, a parking lot in front (which will be needed to accommodate future driveways, etc.).
The development is in its early stages, so the street is blocked off beyond the model house.
I did not ask the size of the square footage of the lot, but that would also provide a clue.
In Spring Lake, I once saw model homes with trees planted IN the future driveway, which made me laugh. (Obviously, would be removed upon completion.)
I was just going by the listing. But the bottom line is you would need to evaluate where the extra cost is coming from.
Again, the cost is irrelevant – market dictates price.
The sales guy did tell me that they use some kind of “tension” (or “torsion”) foundation, that isn’t always used at other developments (but should be, due to the settling of soil in this area). He said that failure to do so can lead to problems/lawsuits, due to houses settling.
He said that they should have used that at The Cannery.
I believe that guy (unlike a lot of sales people) actually knew what he was talking about.
And now that I think about it, aren’t they planning to dump a lot of soil from the onsite dig pit onto the proposed housing sites at Village Farms?
I can tell you that this (in general) can be a very big issue. I seem to recall that in extreme cases, houses are actually rendered unlivable from settling.
So yes, I’ll take the one with the torsion foundation – on soil that wasn’t dumped onsite the year before.
This article overlooks several key issues and includes some incorrect information. First I suggest that Alan read the set of articles written by the Davis Citizens Planning Group that address many of these issues: https://davisvanguard.org/author/the-davis-citizens-planning-group/
To start, the average house value in Davis today is $824K, not $740K. https://www.zillow.com/home-values/51659/davis-ca/ (Redfin gives a similar value). We looked at the proposed housing types and matched them with house prices in Davis and estimated that the average price would be $840K or $100K more than what the developers claimed. A household would need an income of $200K for that housing to be affordable. Only 8% of the proposed housing for purchase would be affordable to households earning $150K.
I’ve reviewed the EPS workpapers that included the estimation of the average housing price from BAE. It included a historic prices series that went back 15 years which is not relevant to the current housing market. We know what the market rate is today and we can look at recent trends or we can project from today using past trends. The latter method would lead to a much higher future price than today. The trend since 2022 has been flat so we can make a conservative assumption that these prices will similar over the next few years.
The problem is that this single-family detached housing is being built for older households with workers who commute out of town. In 2020 and 2022, Alan pointed out that the proposed DiSC projects were likely to have higher than region-wide average annual VMT (miles driven) because it would have a large number of commuters. VF is even more heavily weighted toward commuters. That’s why we have advocated for a significant increase in attached wall housing that will have a much lower price that is affordable to many workers who now commute into Davis but can’t afford to live here. Those workers who live here are much more likely to walk, bike and ride transit to work–we have the Travel Survey data for UCD employees that proves this. Only one-third of UCD employees who live in Davis drive to campus, while more than 90% who live outside of town drive. https://mcubedecon.com/2025/11/24/reconciling-census-on-the-map-commuter-patterns-with-other-employment-data-a-case-study-in-davis/ And when a worker drives, they tend to combine other errands and drive locally to those activities. That commerce and schools are close by won’t matter once a resident gets into a car to commute to work.
As for transit, VF fails to put transit close to housing. As we have written many times, to be effective housing densities approaching 14 units per acre must be located within a quarter mile of a transit stop. Instead, VF places a large park on the southern edge along Covell which creates a large barrier–essentially a moat–between housing and the transit line. Also, biking also will take longer because of the placement of that park. As it is now, we can expect that more than 90% of trips in and out of VF will be by car. With a much higher density and better transit orientation, we can expect that those trips drop to 70%.
And without a true transit oriented development, it is highly unlikely that the developer or the City will be able to land funding from the Strategic Growth Fund for the Affordable housing component. That means that we are unlikely to ever see the subsidized Affordable housing apartments.
Finally, this article overlooks what might be the biggest environmental and community impact from construction–moving one million cubic feet of soil from north of the project to build up the flood protection. That is 100,000 dump truck loads to be moved within a two year period. That’s 5.7 loads per hour running 24/7/365. If we scale that to 2,000 work-hours per annually, that’s 25 trips per hour! That’s a massive amount of traffic with unknown consequences. And developer admits that this solution may not even be feasible!
The better option would have been to choose a scaled down version of the environmentally preferred Alternative 4 in the EIR to accommodate 1,800 houses instead of 2,700. That would increase the density from 8 to 12 units per acre. (For an unknown reason, this scaled down alternative was not included in the EIR, a serious oversight. In contrast, Willowgrove includes this type of alternative in Alternative 3.) The City would not have to adopt overriding considerations to certify the EIR and wouldn’t have to ignore the adopted Climate Action Plan. Instead we’re getting a recycled version of Covell Village which was already rejected in 2005. That project’s density also was 8 units per acre. The developers can do better than that.
I primarily advocated against DISC because it had way more jobs than housing further exascerbating our extreme local jobs:housing imbalance; and thus inviting more commuters. I stated then that we needed much more local housing to support the huge influx of UCD workers so they do not commute daily into town. VFD is almost entirely housing which seemingly helps meet this need.
And RM acknowledges this fact in his post when he says, “Those workers who live here are much more likely to walk, bike and ride transit to work–we have the Travel Survey data for UCD employees that proves this. Only one-third of UCD employees who live in Davis drive to campus, while more than 90% who live outside of town drive“. VFD would seemingly meet this goal of “local living, local working”.
But almost in the same breath, RM says, “The problem is that this single-family detached housing is being built for older households with workers who commute out of town”. He also says “VF is even more heavily weighted toward commuters.”. Both of these statements seemingly directly contradict what he said only sentences earlier. I don’t get it…?
It’s also interesting to note that most folks who publicly oppose VFD are generally older who live in larger single family homes with expansive yards and certainly not within a quarter mile of public transit public transit as RM advocates. But somehow these detractors feel they can nobly tell other young families who just want to realize the American dream of a small starter home with a yard that they instead have to live in higher density attached units or apartments with no yards so we can collectively meet our climate goals.
But how many of these project opponents have themselves contributed to reducing their own environmental footprint by downsizing and moving into modest-sized apartments or smaller attached homes in recent years so other families with kids can replace them in their larger homes? …Or how many have added rental ADUs on their property so they increase the living density of their own properties?…Or how many even rent extra bedrooms in their homes to local students or young service workers to reduce other housing or commuting demands and thus reduce their own property’s environmental footprint? I think the answer is NONE. It seems to me the prevailing attitude of most VFD opponents who object to the project on “housing sizing” grounds is “Do as I say, not as I do?”
Additionally, I’m not sure what RM is referring to by his statement re the movement of soil required for flood protection, “That’s a massive amount of traffic with unknown consequences.” I assume he’s referring to the statement he previously made in the Vanguard, “…if those loads are running down Poleline, the road will be destroyed and have to be reconstructed. In addition, the soil is unlikely to compact evenly, creating infrastructure damage in the new development as it settles. Who is going to pay for those repairs?”
But that steatement is factually incorrect for several reason. Firstly, no dirt haul traffic would ever take Poleline Rd to deliver their loads to the project site. That would require them to run due north from the borrow site to Road 29. Then drive east to Poleline. Then drive south on Polelinet then drive west on the project site to dump their loads. Google Earth tells us that is a 3+ mile jouney…and yes it would be very disruptive to traffic and use a huge amount of extra diesel fuel to make this trip. But it would be crazy to do that when, as fully disclosed in the EIR, all the dirt hauled can go directly from the borrow pit to the adjacent building sites without ever leaving the property or travel on public roadways. This would reduce travel haul distance down to about ¼ mile to less than a half mile. This would reduce the diesel used by 85-90% and completely eliminate any on-road travel. Plus there are very rigid compaction standards for any construction built on fill which are explicitly designed to prevent further settling. It is done all the time.
And while we are talking about moving dirt for flood control, it’s interesting to note that ALL of Davis was once in a floodplain and was inundated almost annually. Davis now exists only because tens of millions of cubic yards of soil were moved from miles and miles away to create the Yolo Bypass levess, and dig the North Covell Ditch, and deepen Willow Slough, and completely divert Putah Creek entirely south of town so that current occupants of our fair City are now out of harm’s way. Yet they now claim that further flood protection measures by moving dirt a quarter to a third of a mile away are irresponsible. It seems to me the prevailing attitude of VFD opponents who object to these flood control measures is, “I’ve got mine, you go get yours elsewhere.”
Alan Pryor said … “But almost in the same breath, RM says, “The problem is that this single-family detached housing is being built for older households with workers who commute out of town”. He also says “VF is even more heavily weighted toward commuters.”. Both of these statements seemingly directly contradict what he said only sentences earlier. I don’t get it…?”
Alan, it really is very simple. The fiscal analyses of Village Farms by both BAE (for the City) and EPS (for the developer) show a lowest priced for sale home of $740,000. In Davis the annual housing costs for a $740,000 with the level of mortgage reported by EPS is over $81,000 per year … more if there are any building repair/replacement maintenance costs. Based on the EPS-reported HUD standard of housing costs being no more than 30% of total Household income, that means more than $270,000 as. The minimum household income to afford a Village Farms home.
Richard’s point is that there are very few jobs in Davis that provide that level of income for a household, so that means the Village Farms homebuyers will have to commute to out-of-town jobs.
Richard’s point is that Davis needs homes that are priced so they can be purchased by the existing Davis workforce.
Do you get it now?
Uh, duh…I still don’t get it.
C’mon Matt – You of all people know how statistics can be manipulated to get a desired end point. BAE did a gross estimate of possible housing costs for estimating property taxes (and they probably put their thumb on the scale to increase the financial return showing for the City – no surprise there as you know from your years on the Finance Committee).
But BAE assumed a smallest home size of 1,741 sq ft in their valuation (1,741 sq ft x $425/sq ft= $740,000)! That’s crazy because VFD is planning over a 100 townhouses of 800 – 1,000 sq ft. Are you saying these postage stamps will sell starting at $740,00 – or pushing $800+/sq ft. Nobody would buy them when other homes sales in Davis are going for an average of less than less than $500/sq ft.
VFD is also proposing approximately 900 single family/half-plex homes on the remaining “medium density lots of 1,000 sq ft to 1,400 sq ft each. Even at an inflated average sale price of $500 per sq ft, these units would sell for $500,000 to $700,000. Gee, according to my math, that’s a hell of a lot less than a “lowest” price of $740,000 you claim is justified because BAE pulled a number out of their asses..
The problem in the BAE analysis is that they made gross estimates of what is the minimum size of house to be built but they never even bothered to talk to the developer as to what sizes of homes they were actually planning to build. I’m not sure if that constitututes ignorance or negligence.
Oops, my bad…I forgot that BAE did get Staff to agree their estimates of minimum housing sizes and prices was “reasonable”. I guess you figure that settles the debate, eh?
Why do you take any of this personally, Alan?
You support the development (for whatever reason) and it’s certainly your right to do so.
Yes, it does sound like an 800 square foot townhouse unit would sell for an “affordable” price – all “100” of those “postage-stamped” sized units, per your comment.
1,472 square foot homes are selling for $835K now, and more than that in the future.
And again I’d ask – so what?
What’s the supposed goal, here – and why?
Alan Pryor said … “ But how many of these project opponents have themselves contributed to reducing their own environmental footprint by downsizing and moving into modest-sized apartments or smaller attached homes in recent years so other families with kids can replace them in their larger homes?”
That comment illustrates another fatal flaw of Village Farms. Where are the smaller homes that will support downsizing? There are none. In fact the supply of homes throughout Davis for downsizing to age in place is virtually nonexistent. A person can’t downsize if there is nowhere to downsize to.
Since you are throwing insults around, you might want to ask yourself when was the last time you downsized? … or even considered downsizing? If you have given that consideration you know how ridiculous and insulting your comment is.
I thought you were better than that. Mudslinging does not become you.
“Where are the smaller homes that will support downsizing? There are none. In fact the supply of homes throughout Davis for downsizing to age in place is virtually nonexistent. A person can’t downsize if there is nowhere to downsize to.”
Old people need MORE space – not less (since they’re home all the time). My 94 year-old grandmother had a 3 floor house (not including what we now call an “ADU”) within that same building. The stairs were her only “exercise” (and she absolutely made it up there almost every day, despite having the appearance of an oversized sack of potatoes in a dress).
But there are places to “downsize” to, if one is stupid-enough to pursue it:
$835K, 1471 square foot house at Harvest Glen.
$710K, for 1,227 square foot house at Bretton Woods
Existing housing (e.g., Stanley Davis homes)
The “old people” mobile home park on Pole Line (I was actually impressed regarding that, in regard to both condition and price).
(Actually, when looking again at the website for these places, it’s more if you want the “rust-resistant undercoating”.)
Thankfully (perhaps?) they do include cheaply-made rear truck bumpers made out of plastic, these days. So you don’t have to purchase them separately, as I did. Then again, that fact allowed me to pursue a custom-made “bad boy” metal one, instead – without having to pay for and discard the cheap plastic one, first.
2X4’s actually measured 2X4, in the old days.
And this was more than 30 years ago, at this point. Well-beyond the point that they already started making houses out of glued-together sawdust.
Matt – Re: You asked, “Where are the smaller homes that will support downsizing?” This has been asked and answered above. There will be hiundreds of homes at VFD that will be dramatically smaller than the minimum size you otherwise report of 1,741 sq ft.
And for full disclosure (since you asked), my wife and I have lived in the same 1,200 sq ft tract home (3 bdrm, 2 bath) for 30 years in which both my kids lived with me for a number of years and attended Davis High. My lot is about 7,500 sq ft (admittedly huge) on which I extensively grow permanent crops (17 fruit trees, 75 ft of boysenberry vines, kiwi vines, and 6 blueberries in pots) that I maintain entirely myself. On the rest of the property, I intensively cultivate vegetable crops including potatoes, yams, lettuces, tomatoes, peppers, cucumbers squash, melons, broccoli, cauliflower, sweet peas, shallots, garlic and corn – plus an awful lot of pollinator perenials to feed my bees and other critters. I pretty much grow all my own fruits and vegetables on an annual basis. I admit to buying some produce seasonally but it is more than offset by what I give away. I also produce my own eggs and harvest 5 gallons of honey a year from my bee hives which I mostly also give away. I also have solar PV and battery backup to shed peak hour electricity use from the grid and electric heat pump heating and cooling. I pretty much do everything I can to reduce my carbon footprint in the world including driving less than 5,000 miles a years in a 14 year old plug-in hybrid Prius (my first new car ever).
I know I’m bragging now but doing so to preface the fact that I admit I have no intention of downsizing. This is because I could never get another place on which I can produce almost all of my own food and that operates on such low energy consumption. But I am not the one who is claiming all newcomers to Davis should live in townhouses or apartments either. I was fortunate to be able to buy a home here in Davis with a yard and happen to think other families should also be given that opportunity to realize their American dream here in Davis.
Now since you and Ron O both seem to be busting my chops here, perhaps you could both also enlighten this audience on your personal living situation and carbon footprint AND whether you intend to downsize too…?
And I can’t resist throwiing this in – “…mudslinging does not become you either.”
Alan Pryor said … “Now since you and Ron O both seem to be busting my chops here, perhaps you could both also enlighten this audience on your personal living situation and carbon footprint AND whether you intend to downsize too…?”
Alan, I try and avoid any pot calling the kettle black situations, as well as avoid being a hypocrite. With that in mind, I downsized more than a decade ago and for that decade period have been writing a monthly rental check.
1,741 square feet isn’t downsizing. A typical downsizing target is between 900 and 1,200 square feet.
Please share with the Vanguard readers where in the Village Farms layout there is a market rate residence with 1,741 square feet. All the official documents show that 100% of the apartments will be deed-restricted. Very few downsizing seniors will have sufficiently few financial resources to qualify for those apartments.
So, please provide documentation, ideally with links to source documents, that supports your assertions.
Alan, you are throwing around some wild numbers that to date I have seen no documentation of from either the Vity or the developer.
Once upon a time, and it was even documented in writing, there was a First Time Buyers Program that was designed to help make market rate homes more affordable, but the Planning Commission was blind sided by the unannounced elimination of that affordability feature. So, until and unless you provide visual documentation of official publications with number of units with their square footage size and expected sales prices … numbers that Village Farms will stand behind … then everything you are saying is hearsay and/or spin. In my one-to-one meetings with members of the development team, they have made nothing like the commitments you are making here.
In addition, neither they nor the City questioned in any way the BAE analysis. In fact, EPS, the developers’ own consultant cited the BAE report, again without any questioning of the numbers they were citing.
With all the above said, your providing support for the optimistic numbers you have provided would be good news, but it bears repeating that your descriptions are at odds with both my personal conversations with members of the development team, as well as being at odds with their public presentations on the community.
Alan, one more piece of data that flies in the face of your numbers is the following three listings from Bretton Woods currently listed on Redfin:
$899,500 for 1,711 square feet
$892,500 for 1,711 square feet
$839,500 for 1,564 square feet
$725,900 for 1,350 square feet
$725,500 for 1,350 square feet
$698,500 for 1,350 square feet
Matt – Re: I downsized more than a decade ago and for that decade period have been writing a monthly rental check.”
Well my apologies for inferring otherwise. You do walk the walk and I commend you for it.
Character assassination does not become you.
Matt, recently you said something about how I was wrong about DJUSD being anywhere near being able to build workforce housing on its property. Last week DJUSD announced the purchase of new space for its district offices with the intent of building housing on the B Street site.
Ron, as we have seen in the Hibbert Lumber proposal and the 5th and G proposal and the Davis Ace South building proposal, redevelopment downtown has costs associated with it that makes affordability of the proposed units extremely hard to achieve. The prospect of owner occupied residences rather than renter occupied residences has also been hard to achieve given the redevelopment costs.
Affordability and owner occupancy for the current Davis workforce, especially for DJUSD teachers, will similarly be a huge challenge given the stated desire of DJUSD to garner $8.5 million for the land value of the 5th and B parcel.
Success from DJUSD in building affordable workforce housing is much more likely to come from the parcel behind Harper Junior High School. That is what I heard in my one-to-one meetings with DJUSD Board members last year.
“…redevelopment downtown has costs associated with it that makes affordability of the proposed units extremely hard to achieve.”
The district isn’t looking to make money by building housing so those costs are not prohibitive if the district can obtain money to subsidize its workforce housing.
Ron, you are correct that the Didtrict isn’t looking to make money, but they aren’t looking to lose money either. Thus the market cost of the 5th and B Streets parcel being set at the same $8+ million cost.
Then you also have the reality that the District does not have either the skills or resources to build the housing themselves. They will either sell the property outright to a developer/builder, who will be looking to make money from the project, or use a mixed ownership model like UCD has used in West Village.
You are correct about the “subsidize its workforce” motivation, and I strongly, strongly support that motivation. However, my strong suspicion is that the vast majority of the DJUSD workforce looking to live in Davis wants to be owner-occupants of their residence. Owner-occupancy units at 5th and B are going to be very hard to accomplish because of the land costs and the demolition of existing structures costs.
In addition, the City imposes its entitlements costs (fees and taxes) on a per unit basis, giving the developers little or no ability to reduce those costs on a per unit basis by spreading those fees and taxes across more units. If the City (and DJUSD) were to reconsider that, and set the level of fees and taxes on a per project footprint basis these per unit affordability of the units built could be greatly improved by the developers.
It looks like Alan will be working full time with the Village Farms developers from here on in to try to defend their disastrous Village Farms project. Clearly, this very lengthy and desperately defensive piece of work has been in progress for quite a while. It is notable that he is using the same format that the Village Farms developers are using of “Myth vs Fact”. What a “coincidence”.
Speaking of facts, recall that the Village Farms developers originally planned to bulldoze and develop housing on the vernal pools in their initial proposed project. They ultimately came forward with their so-called “Biological Resource Preservation Alternative” after considerable opposition arose from the environmentalist community. Yet, Alan is on the record undermining the existence of the vernal pools, despite the City Biologist and many qualified local biologists all agreeing that they were vernal pools. It took finding endangered Vernal Pool Tadpole Shrimp (plus a whole ecosystem of other vernal pool “indicator species”) to refute any denials (like Alan’s) of the vernal pools existence and save the endangered and rare species from destruction from this Village Farms development. It’s also a fact that the vernal pools were disced shortly before the first biological assessment, but they fortunately recovered by the following wet season assessment.
Further, for Alan to call opponents of the Village Farms project “naysayers,” is rather comical. This Village Farms project is an obvious environmental disaster. Yet, given how many projects Alan has opposed over the years, but now his sudden advocacy for this environmentally disastrous project and its developer is certainly eyebrow-raising to say the least. Plus, his recent attempt to try to shepherd through a Sierra Club endorsement failed because it was met with unanimous public testimony strongly opposing the project by more than 35+ attendees.
Meanwhile, there is widespread opposition against this project, particularly amongst progressives. The many reasons include the enormous 200-acre FEMA Hazard Zone A flood plain and the flooding risks, the PFAS “forever chemicals” leaking from the adjacent unlined Old Davis Landfill/burn dump to the project, serious concerns about contamination of the Channel A runoff and polluting regulated waters downstream (like the Yolo Bypass Wildlife Area and the Sacramento River), the extraordinary infrastructure costs of building in the flood plain plus multiple grade-separated crossings, the massive traffic (over 15,000 more car trips a day near the already impacted Covell Blvd. and Pole Line Rd. intersection) and the housing unaffordability based on the BAE fiscal report on Village Farms which states that the housing costs would be $740,000 -$1.3 million. So there’s no “myth” here except Alan’s denial of the actual facts and then him inventing new “facts” to try to make the project look less egregious. Further, these Village Farms housing costs are very likely underestimates given the huge infrastructure costs that will be passed on to the home buyers.
Village Farms is the worst project ever proposed in Davis with massive impacts and would expose the City to long-term liability. Village Farms must be rejected on the June ballot, like its predecessor Covell Village.
Fact: The concentration of total PFAS found within feet of the project site in the DM-MW1 well is as high as 1600 ng/L. This is about 300 times higher than the EPA maximum containment level. You can find PFAS levels in the City’s Groundwater Investigation workplan on table 3. https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo_report/9738538801/T10000021241.PDF. PFAS levels are above the EPA maximum containment level in 6 wells in and around the Old Davis landfill/burn-Dump directly adjacent to the north side of the project. The California Water Board is concerned enough to order testing of groundwater within approximately 1 mile of the north side of the project where the Old Davis Dump is located. See https://documents.geotracker.waterboards.ca.gov/regulators/deliverable_documents/8021329581/old_davis_lf_2024_gmr_rsp__final.pdf. For example, one of the wells they will begin monitoring for PFAS from the Old Dump is located on Nugget Fields in Davis (see Vicinity Wells on page 148 in the first document referenced above).
Fact: The EIR states that in a 100-year (1%) storm event, 1,100 cubic feet per second of channelized water will travel past the Old Davis Dump and on to Pole Line Road (see page 4.8-28 and 31 of the DEIR). It will travel past the spot (DM-MW1) where the PFAS level is 300 times the EPA maximum containment level. The FEIR is so concerned about contamination of that water by PFAS and other contaminants that they will install a liner there. If you want to see what 1,000 cubic feet per second of water that is narrowly channelized looks like take a look at this youtube video. https://www.youtube.com/shorts/Nvd3fi_NvJg. It can only be assumed that this high flowrate water will be emptied onto Pole Line Road over a very narrow segment of Pole Line Road because it is channelized. The EIR assumes that the 1,100 cfs of water will take a straight path from the west side to the east side of the property. It assumes that there will never be any blockage of that 1,100 cfs of water, and that the retention basin will never be filled. However, if any of those assumptions are not met, those 1,100 cfs of water will back up at Village Farms. The only other channelized exit will be under the box culvert at Pole Line which will already be flowing at its capacity of 600 cfs according to the EIR.