Planning Services Division
SAEED IRAVANI
Building Official
Building & Safety
ALLAN CALDER
Program Manager
Planning Services
EDMOND STRICKLAND
Manager
Environmental Health
SARAH PAPPAKOSTAS
Administrative
Services
Manager
MATT TUGGLE
Engineering Manager
Public Works
Engineering
MATTHEW HARDY
Operations Manager
Public Works
Operations
CHRIS DRAKE
Parks Services
Manager
Parks
MISTY KALTREIDER
Water & Natural
Resources Program
Manager
JAMES BEZEK
Director
(707) 784-6765
ALLAN CALDER
Planning Services Manager
(707) 784-6765
DEPARTMENT OF RESOURCE MANAGEMENT
675 Texas Street, Suite 5500
Fairfield, CA 94533-6342
(707) 784-6765
Fax (707) 784-4805
www.solanocounty.com
September 9, 2024
Jessie Hernandez, Associate Planner
Community Development Dept.
1000 Webster Street, Second Floor
Fairfield, CA 94533
[email protected]
Subject: Solano County comments on Draft Fairfield General Plan Policies and DEIR
Dear Jessie:
The County has received your request for comments on the above referenced draft General Plan policies and DEIR. We appreciate the opportunity for review. The following summarizes the County’s comments:
Planning Services Division (Please contact Matt Walsh with questions, [email protected])
• Figure 6-1 Open Space, Greenbelts, and Agriculture: This map appears to identify the open lands west of Cordelia as “Vallejo-Fairfield Greenbelt”. County staff is not aware of such a greenbelt.
However, this area is within the “Tri City and County Cooperative Plan Area” boundary. Is a re- labeling of the map needed?
While the text within Chapter 6 does reference the Tri City and County Cooperative Plan and maintaining consistency with it, it does not appear that the proposed General Plan incorporates the Plan in any way. Pursuant to the Plan, it is required of the County and each city to consider adoption of the Plan as part of its General Plan to ensure consistency in policy implementation among the member agencies of the JPA (Benicia, Fairfield, Vallejo, and Solano County). Will the Tri City and County Cooperative Plan be incorporated into the City’s updated General Plan?
• Nelson Hill development area: The County appreciates the additional text that was added relating to the potential reactivation of this existing quarry. However, the County’s previous comments (letter dated May 2024) relating to the feasibility for development of this site still apply. Due to soil stability, geotechnical concerns, and ingress and egress constraints, this site’s suitability for future residential use is questionable.
• Hale Ranch Study Area, LU-23: The County’s comments in its May 2024 letter generally still apply.
This site is located within the County’s Suisun Valley Strategic Plan boundary. Both the Strategic Plan and the current zoning of A-SV-20 envision agriculture and ancillary agriculturally related or agritourism uses that directly serve or benefit the Suisun Valley Agricultural Area. The Policy, as drafted, does not make a connection to the Suisun Valley and is therefore inconsistent with the intent of the Strategic Plan.
Hydrology and Service Systems
• Groundwater Impacts: The EIR identifies existing groundwater quality issues in the Suisun- Fairfield Subbasin, particularly elevated levels of boron, total dissolved solids (TDS), and volatile organic compounds (VOC) near Travis Air Force Base. It is crucial to acknowledge that the City of Fairfield, while not directly reliant on groundwater for its water supply 1, is situated within a larger hydrological system where numerous domestic and agricultural wells, as well as State Small Water Systems in unincorporated areas of the Suisun-Fairfield Valley, depend on groundwater. The EIR sources indicate that while the Suisun-Fairfield Subbasin is designated as a low priority basin and not subject to Sustainable Groundwater Management Act (SGMA) regulations; however, due to the reliance on groundwater in the unincorporated areas of Suisun-Fairfield valley, a comprehensive assessment of potential impacts from new development on groundwater quality is essential. This evaluation should not be limited to within city limits but consider the basin-wide implications, recognizing that hydrological effects extend beyond political boundaries.
• Groundwater Basins: The EIR incorrectly refers to the groundwater basin in the Fairfield valley as the Suisun-Fairfield Valley Subbasin, which should be changed to Suisun-Fairfield Valley Basin 2 throughout the document. The EIR also incorrectly identifies the Solano Subbasin as being managed by a single Groundwater Sustainability Agency. The Solano Subbasin is managed by five Groundwater Sustainable Agencies (GSAs) under one groundwater sustainability plan (GSP)3.
• Stormwater Management and Flood Control: The EIR should incorporate a regional and watershed-based approach to flood control and stormwater runoff management, recognizing that hydrological impacts are interconnected. The proposed focus on local drainage infrastructure, as indicated by the West Yost Technical Memorandum, might be insufficient to mitigate potential flood risks effectively 4. A comprehensive analysis of regional flood impacts, particularly in the context of sea level rise (SLR) and the proximity of several infill and growth areas to the Green Valley Flood Control Project and Suisun Marsh, is necessary.
• The EIR should include the Best Management Practices (BMPs) specific to the projected development rather than just provide general measures. For example, describing the types of erosion control methods like silt fences and sediment basins, along with how these will be monitored and maintained, would provide better guidance.
• Wastewater Treatment Capacity: The EIR should address concerns regarding the capacity of the Fairfield-Suisun Sewer District's wastewater treatment plant to accommodate increased flows from projected development. While the plant has a current capacity of 23.7 million gallons per day (mgd) average dry weather flows (ADWF), with anticipated increases to 15.2 mgd under the Proposed Project, a remaining capacity of 8.5 mgd might be insufficient to handle potential wastewater flow
1 Page 3.9-5 states; The Suisun-Fairfield Subbasin is rarely used for drinking water because of its low yields and poor water quality. Poor water quality of the basin is due to the impacted creeks and wetlands from urban development and hydromodification, as well as the high salt content.
2 Department of Water Resources Bulletin 118 Suisun-Fairfield Valley Basin (2-003)
3 The last paragraph, page 3.9-14 refers to the Sustainability Groundwater Management Act (SGMA) compliance for groundwater basins and subbasins in Solano County. There are three alluvial groundwater basins or subbasins in Solano County of which only the Solano Subbasin is regulated under SGMA. The other two alluvial groundwater basins/subbasins; Suisun-Fairfield Valley Basin and the Napa-Sonoma Lowlands Subbasin are designated low priority and not required to be regulated under SGMA. The Solano Subbasin is managed by five Groundwater Sustainable Agencies (GSAs) under one groundwater sustainability plan (GSP). 4 West Yost, July 2024 (DEIR - Appendix I)
increases from other tributary agencies 5. The EIR should include a thorough evaluation of the cumulative impacts from all potential sources, including Suisun City, Travis AFB, and unincorporated areas, and outline mitigation measures to ensure adequate wastewater treatment capacity for the entire service area.
• Regulatory Setting: The EIR should provide plans on how the project will meet the requirements of key regulatory frameworks, such as the Clean Water Act and the Porter-Cologne Water Quality Control Act. Although these regulations are mentioned, the EIR should provide an outline with actionable steps to ensure compliance with each regulation.
Additional Environmental Considerations:
• Loss of Agricultural Land: The EIR project alternatives, particularly Alternatives 1 and 2, may result in the conversion of agricultural land to urban uses. This raises concerns about the long-term viability of agricultural operations and the potential for conflicts with existing agricultural land preservation policies.
• Impacts on Biological Resources: The proposed city development could potentially affect sensitive habitats and species within the Planning Area. Development projects in the area should thoroughly assess these impacts and propose appropriate mitigation measures to ensure the long- term conservation of these resources.
• Air Quality and Greenhouse Gas Emissions: The anticipated population and employment growth will likely increase traffic and energy consumption, leading to a rise in air pollutants and greenhouse gas emissions. It is crucial to implement measures that mitigate these impacts and promote sustainable transportation options, energy efficiency, and renewable energy sources. Vehicle Miles Traveled (VMT) due to construction should also be analyzed for potential impacts on air quality and greenhouse gas emissions.
• Sea Level Rise Considerations: While the EIR briefly mentions sea level rise (SLR), it lacks a comprehensive assessment of its potential impacts in the areas subject to SLR including shoreline areas, infrastructure, and the community. Given the City’s proximity to the Suisun Marsh and the projected acceleration of SLR in the coming decades, a more thorough analysis is imperative. The EIR should include recommendations for detailed projections of SLR for different timeframes, considering both optimistic and pessimistic scenarios.
• Climate Change Adaptation: The Draft EIR should expand on how the City will address the compounded effects of climate change, specifically:
o Evaluating the vulnerability of specific risks posed by climate change to Fairfield’s water resources, including drought, sea-level rise, and extreme precipitation events. o Incorporate climate change projections into the design and capacity planning for all water- related infrastructure projects to ensure long-term resilience. o Outline specific adaptation measures beyond general policy statements that will be implemented to address the identified climate change risks, such as water conservation programs, flood protection measures, and drought contingency planning.
Transportation
• The EIR should include more detailed plans for managing traffic during the development phase.
A comprehensive study is needed to assess the potential effects on local traffic patterns,
5 DEIR pg. 3.16-35, Wastewater Collect System Master Plan update, 2020
particularly during peak hours. The study should consider current traffic levels, anticipated increases, and the steps necessary to prevent congestion. For instance, developments near I- 80 and Cordelia Road could significantly impact traffic on Cordelia Road at the Lopes Road intersection, which already sees heavy traffic in the mornings.
• The EIR should consider the impact of new developments on nearby regions and how these areas connect to the current road network. It is important to evaluate how regional traffic flow is being addressed in the study to ensure a comprehensive view of potential impacts.
• The EIR should consider potential impact of Vehicle Miles Traveled (VMT) due to construction.
Including this information is essential for a complete understanding of the total environmental impact through the entire duration of the projected development and the necessary mitigation measures to be implemented.
Thank you for the opportunity to submit comments. Please feel free to contact me at (707) 784-6765 with any questions.
Sincerely,
James Bezek
Director of Resource Management
Cc:
Bill Emlen, County Administrator