Councilmember Brett Lee believes that the draft EIR’s housing analysis for the Mace project is flawed. The Vanguard’s analysis from last week showed ways around the impact of vehicle miles and greenhouse gas emissions through management of the transportation plan. But the developers at Mace keep pushing housing.
Even before the EIR came out, Councilmember Lee was skeptical about the need for housing at the Innovation Parks. In an op-ed a few weeks ago in the local paper, he wrote, “I am against such an idea. If we lived in an ideal world, then yes, it might make sense from a design perspective. Who would argue with the idea that it would be wonderful for the new job-holders to be able to live and work in the same neighborhood.”
The councilmember argues that “there are some real problems with this concept. Unless the residents in such a housing component are required to be employees in the tech park, the vast majority of these people are likely to commute to jobs outside the area.”
In addition, he states, ”Due to the economics of housing in Davis, building housing is easier and more profitable than building commercial space. Over time, would it really be a surprise if the developer shifted the focus from the tech park component to the housing component? Why wouldn’t they want to build the easy part first?”
He concludes, “I believe we should keep our focus on the innovation park and not complicate the proposal with a housing component. I do agree that, as a community, we do need additional apartment units and smaller-footprint homes, but this should be handled as a separate and distinct issue.”
But, as we first reported last week, the press release leads with a title: “Mace Ranch Innovation Center Report Concludes Housing Alternative Reduces Environmental Impacts.” It states, “A draft environmental analysis released today on the proposed Mace Ranch Innovation Center in Davis concludes that incorporating live-work housing into the project reduces its greenhouse gas and traffic impacts.”
They continue, “Among the EIR’s key findings on a project alternative that includes on-site housing: A 13 percent overall reduction in vehicular trips, with a 35 percent reduction during the morning commute period and a 32 percent reduction during the evening commute period. A reduction in daily vehicle miles traveled of more than 25 percent. A reduction in annual greenhouse gas emissions.”
They conclude, “Based on these findings, the study determines that the project alternative with housing is environmentally superior to the innovation center without housing.”
They are not backing down from that. Dan Ramos told the local paper that the housing built at the site would be designed for the employees of the site and would not be “single-family homes.” He believes that this would reduce the chance that residents working outside of Davis would move into those homes and commute to work outside of the city.
While we agree with Mr. Ramos that the structure of these homes would be likely to incentivize local workers over commuters, we remain concerned that the housing inclusion is an unnecessary distraction from the core need for the project.
On Saturday, Brett Lee pointed out flaws with the EIR. He notes, in what he calls the “basic option,” that the report writes, “for the Existing Plus Project case, all trips are assumed to come from outside the City of Davis. Therefore, no bicycle or pedestrian trips are assumed, and negligible transit trips are assumed, and all external trips are assumed to be vehicle trips.”
Councilmember Lee critically comments, “Apparently no one in Davis is assumed to work at the innovation park let alone bike or walk there. Which is odd, because in the housing impact section of the DEIR, it clearly assumes some of the employees will live in Davis.”
He adds that when they evaluate the “mixed use,” the assumptions change. The EIR notes, “8.2 percent expected to be bike/walk based on the following methodology: 32.9 percent of MRIC employees are projected to live in Davis. 22 percent of current Davis residents bike to work. Given the location of the Mixed-Use site at the eastern boundary of the city, 3 percent of employees traveling to the site are estimated to walk to work.”
This is clearly not an apples to apples comparison. Moreover, as the Vanguard pointed out on Saturday, the focus on housing is unnecessary, in part because the DEIR (draft environmental impact report) was really not that outrageously harmful to their project.
As the transmittal letter notes, “The DEIR identifies adverse environmental impacts that may result from development of the project. It also concludes that most of the identified impacts can be mitigated by specific actions called mitigation measures.”
There are some impacts that cannot be mitigated, but, as the developer notes, “This is not an unusual outcome. Given the size and scope of this project, this list is relatively modest. Virtually all large projects in California reach similar conclusions.”
More importantly, on Sunday we cite Section 4.14 of the DEIR which discusses Transportation and Circulation. On page 33, they write, “The proposed project will generate substantial new travel demand related to commuting and other trip purposes associated with the industrial and retail uses on-site. The proposed project is estimated to generate 195,000 VMT at build-out.”
That is a good amount of additional VMT but, remember, build out is not to be for 25 to 40 years. They continue, “As such, it would increase City-generated VMT and GHG, not reduce them.”
But all is not lost. “However, as a concentrated employment center, the project applicant and future tenants have a unique ability to implement programs that promote travel alternatives to the single-occupant vehicle, control the fuel types and efficiencies of vehicles accessing the site, and collectively contribute to the goal of minimizing VMT and GHG growth.”
The EIR calls for the creation of a TDM (Transportation Demand Management) program “for the entire proposed project, including any anticipated phasing, and shall submit the TDM program to the City Department of Public Works for review and approval.” This program would reduce the number of vehicle trips and reduce daily and peak house vehicle trips.
On page 33 and 34, it has a long list of possibilities, including carpooling, busing, telecommuting, bicycling, car-share, and – one of the ideas that I think we should pursue in the long term – enhancements to the bus service, Capitol Corridor and the bicycling network.
Because build out is projected over a 25 to 40 year period, we can start working on new transportation systems to get people from where they live to where they work without ramping up VMTs.
The bottom line is it appears there are flaws in the traffic analysis, failing to account for non-vehicle trips in the initial EIR but not in the alternative, and the EIR itself presents a credible alternative to housing through a transportation program that we should be implementing anyway.
So why continue to push for housing unless you want this to be a housing project? In that case, say so upfront and let the council and ultimately the voters decide. However, a lot of people think this would kill the project and see the clear need for the innovation park.
In short, this is a delicate situation which calls for immediate leadership from the city to take back the discussion.
—David M. Greenwald reporting