Environmentally Superior Alternative, Housing

Open Letter to the Benicia City Council: ‘It didn’t have to be this way’

[Editor – Excellent analysis and critique of Council’s ‘Housing Element’ decision on January 24.  For additional background, see earlier stories on BenIndy below.  – R.S.]

Historic Benicia Arsenal Advocates address City Council on Housing Element decision

January 30, 2023

Benicia City Council Benicia City Hall
250 East L Street
Benicia, CA 94510
RE: 2023-2031 Housing Element – January 31 Agenda Item 10.A

Dear Mayor Young and Council Members:

At the January 24 meeting, despite testimony from many community members advocating for a better alternative, the City Council approved a Housing Element that threatens Benicia’s precious historic resources, puts future residents directly in the path of environmental hazards, and fails to further fair housing goals. [Agenda, Minutes, Video]

(Click image to see the 1999 General Plan)

It didn’t have to be this way. Throughout the 12-month Housing Element update process, concerned community members raised these issues and pointed to better alternatives. And unlike many cities, Benicia had a large number of viable and desirable housing sites to choose from. The Council rejected many suitable sites, often at the request of a handful of neighbors, and yet chose not to consider the larger issues of historic preservation, fair housing, and environmental hazards that civic-minded community members have raised throughout the process. The comments from these community members represented longstanding City policies and values enshrined in the Benicia General Plan.

Click image to view the Housing Element Draft EIR (532-pages, slow download)

At the January 24 Council meeting, a near-capacity crowd asked the Council to approve the Environmentally Superior Alternative as identified in the Housing Element Environmental Impact Report (EIR). As stated on page 6-23 of the EIR, the Environmentally Superior Alternative would meet all the project’s objectives. This alternative would have reduced impacts on historic resources in the Arsenal and downtown and helped address hazards and fair housing concerns while still meeting the City’s housing needs and State of California requirements.

The rationale for the Council’s decision was apparently that, based on advice from the City’s consultants and staff, the Environmentally Superior Alternative might not actually be feasible. The California Environmental Quality Act (CEQA) requires that alternatives evaluated in EIRs be feasible. If the Environmentally Superior Alternative was not feasible, the Housing Element EIR is inadequate and should not have been certified.

The staff and consultants also claimed that the Council really had no choice but to approve the Housing Element as currently drafted, due to the looming January 31 deadline for Housing Element adoption, the cost of making changes, and the fact that they had not evaluated the Environmentally Superior Alternative for fair housing compliance. If that were the case, it would appear that the City designed the process and schedule to prevent meaningful consideration of EIR alternatives, violating the public’s trust as well as the requirements and intent of CEQA.
Let’s be clear: The Council had a choice. At the January 24 meeting and throughout the process, the Council had better options but chose not to act on them out of expediency or fear of State repercussions. The Council had an opportunity to present a vision for the future of Benicia and failed to meet the challenge.

Sincerely,

Benicia Arsenal Park Task Force,
Benicia Arsenal Defense, and
1000 Friends Protecting Historic Benicia

cc. City Clerk, Community Development Director,  Benicia Herald, Benicia Independent, Vallejo Times-Herald, Vallejo Sun

See earlier on BenIndy: