Op-ed | How City Council Upended the Village Farms EIR Alternatives Analysis

The California Environmental Quality Act (CEQA) requires an Environmental Impact Report (EIR) to examine the potential impacts of a range of reasonable alternatives to the proposed project and evaluate the comparative merits of the alternatives. Under CEQA, the purpose of studying alternatives is to allow meaningful analysis and comparison of alternatives that could reduce significant environmental impacts as compared to the proposed project.

The alternatives must be feasible, meet most or all of the project objectives, and avoid or substantially lessen one or more of the project’s significant impacts. Alternatives are generally evaluated in a qualitative manner rather than to the same degree of exactitude as the proposed project. A “no project” alternative is always included. The “no project” alternative for a project that would develop vacant land would in most cases be the “Environmentally Superior Alternative (ESA),” but not building the project would fail to achieve any of the project objectives.

As a result, the alternative that best avoids or mitigates the most impacts is typically identified as the ESA, but the lead agency (the City of Davis in this case) is not obligated to substitute this alternative for the proposed project. In fact, because alternatives are generally analyzed qualitatively, a lead agency could not approve an alternative consistent with CEQA unless that alternative was also analyzed at the project-specific (i.e. detailed) level, such as the Biological Resources Preservation Alternative (BRPA) for the Village Farms project…

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