Commentary: Draft EIR Says Denser is Better

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:

1. 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.
2. 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.

7. 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.

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