Dear Editor,

In 2016, Stanislaus LAFCO (Local Agency Formation Commission) approved the City of Riverbank’s Sphere of Influence expansion, adding approximately 1,479 acres, intended to accommodate growth over the next 20 years. Again, Riverbank is requesting to expand its borders by 1,552 acres to accommodate River Walk, a 2,500 to possibly 5,000-unit housing project. The annexation would be bordered by the Stanislaus River and take in all farmland to the Del Rio community. The River Walk project will be built on unincorporated land zoned for agricultural uses, the majority of which is classified as prime agricultural farmland and superior soil for groundwater replenishment.

Stanislaus LAFCO is requiring Riverbank to identify a range of alternatives that focus on lands within the existing Sphere of Influence on non-prime lands and cites ample acres in the city’s 2016 expansion, within city limits, to accommodate housing. This is demonstrated in Riverbank’s current Housing Element inventory of 6,712 potential housing units. “While an analysis of project alternatives need not include every possible alternative, an alternative that focuses on similar uses on lands already within the City’s Sphere of Influence is a reasonable expectation to be considered in the document and is noticeably absent.”

From the City of Modesto — “the EIR’s (Environmental Impact Report’s) cumulative impact analysis is fundamentally flawed … that render the rest of the EIR in violation of CEQA (California Environmental Quality Act) including but not limited to the distorted Project Description, the deferred impact analysis, and the ineffective and incomplete analysis of mitigation thereto. A revised, adequate cumulative impact analysis would necessitate recirculation of a Draft EIR pursuant to CEQA … Failure to recirculate the new EIR would deprive the public of a meaningful opportunity to comment on the Project …”

Stanislaus County’s formal response to the proposed River Walk project states, “It is premature and does not maintain a logical land use pattern.”

Organizations Opposed to the River Walk Project: Farmland Working Group, Friends of the Swainson’s Hawk, League of Women Voters of Stanislaus, Yokuts Group Sierra Club, Stanislaus Audubon Society, Tuolumne River Trust, Valley Improvement Projects and Voters for Farmland.

Sincerely,

Farmland Working Group, Advisory Committee —

Matt Beekman, Jeani Ferrari and Garrad Marsh