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CALIFORNIA REGIONAL PRIMATE RESEARCH CENTER IMPROVEMENT PROJECTS, UC DAVIS FINAL TIERED FOCUSED ENVIRONMENTAL IMPACT REPORT SCH. NO. 2000042075 Prepared for Office of Resource Management and Planning 376 Mrak Hall University of California One Shields Avenue Davis, California 94616 December 2001 URS Corporation 500 12th Street, Suite 200 Oakland, California 94607 51-09967068.00

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Page 1: CALIFORNIA REGIONAL PRIMATE RESEARCH CENTER … · 500 12th Street, Suite 200 Oakland, California 94607 51-09967068.00. ... As a public agency principally responsible for approving

CALIFORNIA REGIONALPRIMATE RESEARCH CENTERIMPROVEMENT PROJECTS, UCDAVIS

FINAL TIERED FOCUSED ENVIRONMENTALIMPACT REPORTSCH. NO. 2000042075

Prepared forOffice of Resource Management and Planning376 Mrak HallUniversity of CaliforniaOne Shields AvenueDavis, California 94616

December 2001

URS Corporation500 12th Street, Suite 200Oakland, California 94607

51-09967068.00

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TABLE OF CONTENTS

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Section 1 ONE Introduction..................................................................................................................... 1-1

1.1 Purpose of the Final Environmental Impact Report ................................ 1-11.2 Format of the Final Environmental Impact Report.................................. 1-1

Section 2 TWO Summary of Impacts and Mitigation Measures............................................................ 2-1

Section 3 THREE Mitigation Monitoring and Reporting Program ............................................................ 3-1

Section 4 FOUR Comments and Responses to Comments.................................................................... 4-1

Section 5 FIVE References ...................................................................................................................... 5-1

Section 6 SIX List of Preparers ............................................................................................................. 6-1

6.1 Lead Agency ............................................................................................ 6-16.2 Final Environmental Impact Report Authors........................................... 6-1

Tables2-1 Summary of Impacts and Mitigation Measures In the Draft EIR3-1 Mitigation Monitoring and Reporting Program

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SECTIONONE Introduction

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1. Section 1 ONE Introduction

1.1 PURPOSE OF THE FINAL ENVIRONMENTAL IMPACT REPORTUnder the California Environmental Quality Act (CEQA) and the University of California (UC)Procedures for Implementing CEQA, The University of California at Davis (UC Davis orcampus) is required, after completion of a Draft Environmental Impact Report (EIR), to consultwith and obtain comments from public agencies that have legal jurisdiction with respect to theproposed projects, and to provide the general public with opportunities to comment on the DraftEIR. UC Davis is also required to respond to significant environmental issues raised in thereview and consultation process. This Final EIR has been prepared to respond to agency andpublic comments received on the Draft EIR for the California Regional Primate Research CenterImprovement Projects (CRPRC), UC Davis. The Draft EIR was issued for public review onAugust 31, 2001. The public review period lasted from August 31, 2001 through October 15,2001. UC Davis held a public hearing on September 26, 2001, to receive comments on the DraftEIR. A court reporter prepared a transcript of the meeting.

This document and the Draft EIR constitute the Final EIR. The Draft EIR is hereby incorporatedby reference. Copies of the Draft EIR and the Final EIR are available during normal operatinghours at the UC Davis Office of Resource Management and Planning, 376 Mrak Hall on the UCDavis campus; at Reserves in Shields Library on the UC Davis campus; at the Yolo CountyPublic Library, 315 E. 14th Street, Davis; at the Vacaville Public Library, 1020 Ulatis Drive,Vacaville; and online at http://www.ormp.ucdavis.edu/environreview/.

The Draft and Final EIRs include extensive references to the 1994 UC Davis Long RangeDevelopment Plan (1994 LRDP) and the 1994 LRDP EIR. The 1994 LRDP was designed toaccommodate projected campus population growth and facilities development through 2005-06,and the 1994 LRDP EIR evaluated the environmental impacts of that growth and development.As allowed under Section 15150 of the CEQA Guidelines and as stated in the Draft EIR, UCDavis is incorporating by reference portions of the 1994 LRDP EIR (State ClearinghouseNumber 94022005). Copies of the 1994 LRDP, 1994 LRDP EIR, and all documents that reviseand amend these documents are available at the locations listed above.

As a public agency principally responsible for approving or carrying out the proposed project,the University of California is the Lead Agency under CEQA and is responsible for reviewingand certifying the adequacy of this environmental document and approving the proposed project.Approval for this project has been delegated to the campus by The Regents and will beconsidered by the Facilities and Enterprise Policy Committee.

1.2 FORMAT OF THE FINAL ENVIRONMENTAL IMPACT REPORTA Final EIR is required to include the Draft EIR (which has been incorporated into thisdocument by reference), copies of comments received during public review of the Draft EIR, alist of persons or entities commenting on the Draft EIR, and responses to comments received onthe Draft EIR. This Final EIR is organized as follows:

• Section 1, Introduction, provides an introduction and overview describing the intended useof the Final EIR.

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SECTIONONE Introduction

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• Section 2, Summary of Impacts and Mitigation Measures, lists the environmental impactsthat would result from implementation of the proposed projects, the level of significance ofimpacts prior to mitigation, project-specific mitigation measures that are recommended forthe projects, and the level of significance of the impacts after mitigation.

• Section 3, Mitigation Monitoring and Reporting Program, presents the mitigationmonitoring and reporting program (MMRP) for the proposed projects.

• Section 4, Comments and Responses to Comments, contains a list of all agencies andpersons who submitted comments on the Draft EIR during the public review period. Thissection also contains the comment letters followed by responses to comments. Eachcomment letter has been given an identifying letter, and each comment within a letter hasbeen given a number. Responses are numbered to correspond to the appropriate comment.Where appropriate, responses are cross-referenced between letters. This section alsoincludes the transcript from the public hearing and responses to comments received at thathearing.

• Section 5, References, lists supporting and reference sources used in the preparation of theFinal EIR.

• Section 6, List of Preparers, presents the UC Davis authors, the technical specialists andconsultants, the production team, and other key individuals who assisted in the preparationand review of the Final EIR.

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SECTIONTWO Summary of Impacts and Mitigation Measures

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2. Section 2 TWO Summary of Impacts and Mitigation Measures

Table 2-1 provides an overview of the environmental impact analyses contained in Section 3 ofthe Focused Tiered Draft EIR. The summary table presents (1) environmental impacts, (2) theirlevel of significance prior to mitigation, (3) project-specific mitigation measures, and (4) thelevel of significance with mitigation.

There was a reporting error in Table ES-1, “Summary of Impacts and Mitigation Measures in theDraft EIR”, in the Focused Tiered Draft EIR. Table ES-1 reported “No mitigation required” forImpact 3.1-3. This was inconsistent with the text of Section 3 of the Draft EIR. Page 3-30 of theDraft EIR notes that although Impact 3.1-3 would be less than significant, Mitigation Measure3.1-1 would be implemented to further reduce this less-than-significant impact.

Table 2-1 includes Mitigation Measure 3.1.1 for Impact 3.1-3, and renumbers the mitigationmeasure for Impact 3.1-4. These corrections make Table ES-1 consistent with the environmentalimpact analyses contained in Section 3 of the Draft EIR.

Furthermore, the text of Mitigation Measures 3.1-2 and 3.2-1 has been revised to clarify themeasures and strengthen enforcement and monitoring of these mitigation measures. In allplaces, the word “would” has been replaced with “shall” or “will”.

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1 Hazards and Hazardous Materials

3.1-1 The proposed projects would increase the number oflaboratory animals at UC Davis, thereby increasing therisk of animal bites, escapes, and disease transmissionto CRPRC staff and employees as well as to universitycommunity and the public. With the continuedimplementation of control measures currently in place,this impact is considered to be less than significant.

LS No additional mitigation required. LS

3.1-2 Stormwater runoff from the field corrals couldpotentially affect groundwater resources in the projectarea, and thereby affect public health. With thecontinued implementation of control programs in place,this impact is considered to be less than significant.

LS No mitigation required. LS

3.1-3 Stormwater runoff from the field corrals couldpotentially affect surface water resources in the areaand thereby affect public health and wildlife. With thecontinued implementation of control programs in place,this impact is considered to be less than significant.

LS 3.1-1 No mitigation required. To further reduce the impact, theCampus will test the water in the field corral stormwaterretention basin to assure that no macaque-specific viralagents are detectable by culture. If viruses are detected,appropriate measures will be taken to exclude exposure towildlife and disinfect the water to eliminate otherpathways.

LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-4 The construction of the stormwater detention basincould result in outbreaks of avian botulism. Thisimpact is considered potentially significant.

PS 3.1-2 The Campus will implement a number of managementpractices at the stormwater detention basin including butnot limited to, the following: The Campus will monitor thewater levels and drain down the water before the advent ofwarm weather as necessary. The Campus will clean up theedge areas of the basin of decaying vegetation andcarcasses as necessary. It will also control flies.

LS

3.1-5 The proposed projects would indirectly lead to anincrease in the volume and load of hazardous andbiohazardous materials that are discharged to thewastewater treatment plant and thus lead to an increasein exposure for waste management personnel and thepublic. With the continued implementation of controlprograms in place, this impact is considered to be lessthan significant.

LS No additional mitigation required. LS

3.1-6 Implementation of the proposed projects couldindirectly lead to an increase in biohazardous materialsuse at UC Davis that could expose campus occupantsand the public to potential health or safety risks. Withthe continued implementation of control programs inplace, this impact is considered to be less thansignificant.

LS No additional mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-7 The proposed projects could indirectly lead to anincrease in the generation of biohazardous waste at UCDavis that could expose campus occupants to potentialhealth or safety risks. With the continuedimplementation of control programs in place, thisimpact is considered less than significant.

LS No additional mitigation required. LS

3.1-8 The proposed projects could lead to an increase inradioactive material use at UC Davis which couldexpose campus occupants to potential health or safetyrisks.

Due to prior implementation of 1994 LRDP EIRmitigation measures, this impact is considered to beless than significant.

LS No additional mitigation required. LS

3.1-9 Implementation of the proposed projects would lead toan increase in the generation of radioactive waste atUC Davis that could expose campus occupants topotential health or safety risks.

Due to prior implementation of 1994 LRDP EIRmitigation measures, this impact is considered to beless than significant.

LS No additional mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-10 Implementation of the proposed projects couldindirectly lead to an increase in hazardous chemical useat UC Davis that could expose campus occupants andthe public to potential health or safety risks. With thecontinued implementation of control programs in place,this impact is considered to be less than significant.

LS No additional mitigation required. LS

3.1-11 Implementation of the proposed projects couldindirectly lead to an increase in the generation ofhazardous chemical waste at UC Davis that couldexpose campus occupants to potential health or safetyrisks. With the continued implementation of controlprograms in place, this impact is considered to be lessthan significant.

LS No additional mitigation required. LS

3.1-12 Hazardous materials used at the CRPRC may beinadvertently released to the sewer or disposed of withnon-hazardous solid waste. With the continuedimplementation of control programs in place, thisimpact is considered to be less than significant.

LS No additional mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-13 Increased use of biohazardous materials and researchanimals related to cumulative development in the regionwould increase the number of people exposed to healthhazards associated with such use. The proposed projectswould contribute to, but would not exceed, the significantand unavoidable cumulative impact previously identifiedin the 1994 LRDP EIR.

This impact is considered significant and unavoidablebecause the University cannot guarantee that additionalbiohazardous materials and research animals used in theDavis area by entities other than the University would bemanaged safely.

SU2 No additional mitigation required for the proposed project. Noadditional mitigation available for the regional cumulativeimpact.

SU2

3.1-14 Implementation of the proposed projects, inconjunction with the development included in the 1994LRDP and other development in the region thatgenerates biohazardous waste, would place anadditional load on available biohazardous wastemanagement facilities. This impact is considered to beless than significant.

LS No mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-15 Increased use of radioactive materials related to theproposed projects, the development included in the1994 LRDP, and other development in the regionwould increase the number of people exposed to healthhazards associated with the use of radioisotopes. Theprojects would contribute to, but would not exceed, thesignificant and unavoidable impact previouslyidentified in the 1994 LRDP EIR.

SU2 No additional mitigation required for the proposed project. Noadditional mitigation available for the regional cumulativeimpact.

SU2

3.1-16 Implementation of the proposed projects, inconjunction with the development included in the 1994LRDP, and other development in the region thatgenerates radioactive waste, would place an additionalload on radioactive waste management facilities. Theproposed projects would contribute to, but would notexceed, the significant and unavoidable cumulativeimpact previously analyzed in the 1994 LRDP EIR.

SU2 No additional mitigation required for the proposed project. Noadditional mitigation available for the regional cumulativeimpact.

SU2

3.1-17 Increased use of hazardous chemical materials relatedto the proposed projects, the development included inthe 1994 LRDP, and development in the region wouldincrease the number of people exposed to healthhazards associated with such use. The proposedprojects would contribute to, but would not exceed, thesignificant and unavoidable cumulative impactpreviously identified in the 1994 LRDP EIR.

SU2 No additional mitigation required for the proposed project. Noadditional mitigation available for the regional cumulativeimpact.

SU2

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.1-18 Implementation of the 1994 LRDP, including theproposed projects and other developments in the regionthat generate hazardous chemical waste, could place anadditional load on hazardous waste managementfacilities. The proposed projects would contribute to,but would not exceed, the significant and unavoidablecumulative impact previously identified in the 1994LRDP EIR.

Because the University cannot guarantee that othergovernment entities would take steps to mitigate thisimpact within other jurisdictions, this impact isconsidered significant and unavoidable.

SU2 No additional mitigation required for the proposed projects. Noadditional mitigation available for the regional cumulativeimpact.

SU2

3.2 Land Use Compatibility

3.2-1 The proposed projects would result in construction andoperational air emissions, which could affect adjacentland uses. This impact is considered less thansignificant.

LS No mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.2-2 Project implementation could result in vehicular trafficthat could potentially affect pedestrian safety. Thisimpact is considered potentially significant.

PS 3.2-1 Trucks that haul dirt from the stormwater detention basinshall not use CR 98 in front of GVCC and will havelimited use of the County Road 98 and Russell Boulevardintersection. A truck access road parallel to CR 98 willbe constructed from the basin site to the CRPRC entranceon the interior of the CRPRC fence line. From theCRPRC entrance, trucks will be required to turn right(south on CR 98) toward I-80 for destinations south of theCRPRC. Trucks must use Hutchison Drive to Highway113 for destinations east and north of the CRPRC. Fordestinations west of the CRPRC, trucks will utilize thenorth gate and turn west on Russell Boulevard. Fordestinations north of the CRPRC and near County Road98, between Davis and Woodland, trucks will turn eastonto Russell Boulevard and then north on County Road98. Trucks will use the same routes when returning to theCRPRC for additional loads.

LS

3.2-3 Construction of the proposed improvements couldresult in elevated noise levels at off-site locations. Thisimpact is considered potentially significant.

PS 3.2-2(a) Construction activities associated with the field corralretention basin and the stormwater detention basin willbe conducted between 7 a.m. and 5 p.m. Mondaythrough Friday. No excavation or grading will beconducted on the weekends.

3.2-2(b) The construction contractor will be directed to completehigh noise generating activities as quickly as possible.

LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTWO Summary of Impacts and Mitigation Measures

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Table 2-1 (continued)SUMMARY OF IMPACTS AND MITIGATION MEASURES IN THE DRAFT EIR

ImpactLevel of

SignificancePrior to

Mitigation1

Mitigation MeasuresLevel of

SignificanceFollowing

Mitigation1

3.2-4 The proposed projects would add new facilities to theproject site which could change visual conditions. Thisimpact is considered to be less than significant.

LS No mitigation required. LS

3.3 Energy

3.3-1 Implementation of the proposed projects wouldincrease demand for electricity and related servicesystems. Electrical facilities would be in place to servethe proposed projects. This is considered a less-than-significant impact.

LS No mitigation required. LS

3.3-2 Cumulative development in the Davis area, includingdevelopment of the proposed projects in conjunctionwith development included in 1994 LRDP EIR asamended, would result in increased demand for use ofelectricity and related service systems. This isconsidered a less-than-significant impact.

LS No mitigation required. LS

1 LS = Significant; PS = Potentially Significant; S = Significant; SU = Significant, Unavoidable 2 Impacts are significant on a cumulative level only; project level impacts will be less than significant

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SECTIONTHREE Mitigation Monitoring and Reporting Program

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3. Section 3 THREE Mitigation Monitoring and Reporting Program

CEQA requires that a lead agency establish a program for monitoring and reporting onmitigation measures adopted as part of the environmental review process. The MitigationMonitoring and Reporting Program (MMRP), set forth in Table 3-1, is designed to ensure that, ifthe proposed projects are approved, the mitigation measures identified in the Draft and FinalEIRs will be implemented.

Along with this project-specific MMRP, these Projects incorporate relevant 1994 LRDP EIRmitigation measures, including 1997 WWTP EIR mitigation measures, previously adopted byThe Regents. The relevant mitigation measures are presented in the Draft EIR and the April2000 Initial Study included as Appendix A of the Draft EIR. Compliance with the 1994 LRDPEIR mitigation measures during the implementation of the CRPRC improvement projects willbe monitored pursuant to the 1994 LRDP EIR monitoring program previously adopted byThe Regents.

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SECTIONTHREE Mitigation Monitoring and Reporting Program

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Table 3-1California Regional Primate Research Center Improvement Projects, UC Davis Final EIR

Mitigation Monitoring and Reporting ProgramMitigationNumber Mitigation Measure

Monitoring and ReportingProcedure Mitigation Timing Mitigation Responsibility

3.1-1 The Campus will test the water in the field corralstormwater retention basin to assure that no macaque-specific viral agent are detectable by culture. If virusesare detected, appropriate measures will be taken toexclude exposure to wildlife and disinfect the water toeliminate other pathways.

CRPRC Staff will create aschedule, protocol, andreporting database for theCRPRC maintenance stafffor testing water in the fieldcorral stormwater retentionbasin.

Prior to completion ofconstruction of the

stormwater retention basin

CRPRC and Office ofResource Management and

Planning (ORMP)

3.1-2 The Campus will implement a number of managementpractices at the stormwater detention basin including, butnot limited to, the following: The Campus will monitorthe water levels and drain down the water before theadvent of warm weather as necessary. The Campus willclean up the edge areas of the basin of decayingvegetation and carcasses as necessary. It will alsocontrol flies.

The Campus GroundsDivision and ORMP willdesign and implement amanagement plan for thestormwater detention basin.

Prior to completion ofconstruction of the

stormwater detention basin

Campus Grounds Divisionand ORMP

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Table 3-1 (continued)California Regional Primate Research Center Improvement Projects, UC Davis Final EIR

Mitigation Monitoring and Reporting Program

MitigationNumber Mitigation Measure

Monitoring and ReportingProcedure Mitigation Timing Mitigation Responsibility

3.2-1 Trucks that haul dirt from the stormwater detention basinshall not use CR 98 in front of GVCC and will havelimited use of the County Road 98 and Russell Boulevardintersection. A truck access road parallel to CR 98 willbe constructed from the basin site to the CRPRC entranceon the interior of the CRPRC fence line. From theCRPRC entrance, trucks will be required to turn right(south on CR 98) toward I-80 for destinations south of theCRPRC. Trucks must use Hutchison Drive to Highway113 for destinations east and north of the CRPRC. Fordestinations west of the CRPRC, trucks will utilize thenorth gate and turn west on Russell Boulevard. Fordestinations north of the CRPRC and near County Road98, between Davis and Woodland, trucks will turn eastonto Russell Boulevard and then north on County Road98. Trucks will be required to use the same routes whenreturning to the CRPRC for additional loads.

The construction contractwill include requirementsfor the constructioncontractor to design andconstruct the truck accessroad that will be parallel toCR 98. The contract willalso require the contractor toprepare a constructiontraffic management plan andto educate truck driversabout appropriate routes todrive. Copies of therelevant portions of theconstruction contract will besent to ORMP.

The truck access roadparallel to CR 98 will be

constructed prior toexcavation of the

stormwater detention basin.The identified truck routes

will be used throughoutexcavation of the

stormwater detention basin.

ORMP, Architects andEngineers and the

construction contractor.

(a) Construction activities associated with the field corralretention basin and the stormwater detention basin willbe conducted between 7 a.m. and 5 p.m. Mondaythrough Friday. No excavation or grading will beconducted on the weekends.

3.2-2

(b) The construction contractor will be directed tocomplete high noise generating activities as quickly aspossible

The construction contractwill include requirementsfor the constructioncontractor to comply withthe construction scheduleset forth in the mitigationmeasure. Field inspectionswill be conducted duringconstruction. Copies of therelevant portions of theconstruction contract will besent to ORMP.

During construction contractfinalization. The schedule,created prior to the start ofconstruction, will be used

during construction.

ORMP, Architects andEngineers, and the

construction contractor.

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SECTIONFOUR Comments and Responses to Comments

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4. Section 4 FOUR Comments and Responses to Comments

Seven written comment letters were received during the public and agency comment period onthe Draft EIR. These letters and the public hearing transcript are included in this section. Allagencies and individuals that commented on the Draft EIR are listed below.

List of Agencies and Individuals Commenting on the Draft EIR

Letter Date Agency/Individual

A October 16, 2001 Governor’s Office of Planning and ResearchState Clearinghouse

B September 12, 2001 Department of Toxic Substances ControlGuenther W. Moskat

C October 18, 2001 California Regional Water Quality Control Board,Central Valley RegionChristine Palisoc

D October 15, 2001 Animal Protection Institute/ Law Office of J.William YeatesKeith G. Wagner

E October 12, 2001 In Defense of AnimalsElliot M. Katz

F October 4, 2001 Animal Protection Institute/ Law Office of J.William YeatesKeith G. Wagner

G October 10, 2001 Wesley R. Wooden

Public Hearing on September 26, 2001

No comments were received at the Public Hearing.

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Response to Comment Letter A

Response to Comment A-1. This letter indicates that UC Davis has met the requirements withrespect to the review of the Draft EIR for the California Regional Primate Research CenterImprovement Projects, UC Davis.

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Response to Comment Letter B-California Department of Toxic Substances Control

Response to Comment B-1. Comment noted.

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Response to Comment Letter C-California Regional Water Quality Control Board, CentralValley Region

Response to Comment C-1. Construction activity associated with the proposed project wouldbe covered under the General Permit for Discharge of Storm Water Associated with Constructionfor the entire Davis campus. In compliance with the permit, and as correctly noted by thecommenter, a New Construction Project Information Form would be submitted for the proposedproject before construction begins. In addition, a Storm Water Pollution Prevention Plan thatincludes site-specific Best Management Practices would be prepared and implemented.

Response to Comment C-2. Comment noted. Dewatering activities are not anticipated to occuras part of the proposed project. In addition, it is campus policy to discharge water used inpipeline testing/flushing to the campus sewer system, rather than to the storm drainage system.

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Response to Comment Letter D-Animal Protection Institute/Law Office of J. WilliamYeates

Response to Comment D-1. The Draft EIR does not utilize the 1994 LRDP to analyze projectlevel impacts nor does it utilize the findings of the 1994 LRDP EIR to find a project-level impactless than significant. Project-level impacts with respect to hazardous materials are analyzed anddiscussed on pages 3-23 to 3-49, and mitigation measures are included in the Draft EIR wherenecessary. Project-level land use compatibility impacts and impacts on energy resources areanalyzed on pages 3-55 through 3-62 of the Draft EIR. Impacts relative to all other resources areanalyzed in the Initial Study (Appendix A of the Draft EIR). For impacts that were found to bepotentially significant, the Initial Study notes that previously adopted mitigation measuresdeveloped in the 1994 LRDP EIR would apply to the project and would mitigate those impacts.

The Draft EIR uses the analysis and conclusions in the 1994 LRDP EIR only with respect toimpacts of the projects in combination with 1994 LRDP development and development in theregion. That use of the 1994 LRDP EIR and its findings is appropriate under CEQA because the1994 LRDP EIR is a program EIR that addresses the impacts from the growth of the campusthrough 2005-06 (UC Davis 1994). To the extent that a project falls within the parameters of thegrowth envisioned and analyzed in the 1994 LRDP EIR, its impacts in conjunction with thosefrom the other growth envisioned for the campus, are considered to be adequately addressed inthe 1994 LRDP EIR. The consistency of the proposed projects at the CRPRC with the 1994LRDP EIR is analyzed and demonstrated on pages 1-6 through 1-11 of the Draft EIR. Pleasealso refer to response to Comment D-2 below.

Response to Comment D-2. The Draft EIR’s approach to the significant and unavoidablecumulative impacts that were previously analyzed in the certified 1994 LRDP EIR is as follows,and is consistent with the tiering provisions of CEQA. The 1994 LRDP EIR fully analyzed theimpacts of the 1994 LRDP (project impacts), as well as the impacts of the 1994 LRDP incombination with regional growth (cumulative impacts), and identified feasible mitigationmeasures. For most cumulative impacts that were determined to be significant and unavoidablein the 1994 LRDP EIR, the contributing project impacts of the 1994 LRDP were mitigated to aless-than-significant level by the adoption of mitigation measures. See, e.g., 1994 LRDP Impact4.4-3 at pp. 4.4-25 to 4.4-26 (1994 LRDP development could expose occupants to significantnoise levels; mitigated to less-than-significant level) and Impact 4.4-4 at pp. 4.4-26 to 4.4-29(1994 LRDP plus regional development could expose occupants to significant noise levels; samemitigation measures adopted by University, but University cannot guarantee implementation inareas outside its responsibility and jurisdiction). Thus, for most of the cumulative regionalimpacts, while the contribution of the 1994 LRDP could be and was mitigated to a less-than-significant level through the adoption of mitigation measures, the cumulative regional impactremained significant and unavoidable because the regional aspect of the impact is within theresponsibility and jurisdiction of another public agency to mitigate, and the University cannotguarantee that the regional impact would be mitigated.

This is not to say that the 1994 LRDP did not have significant and unavoidable impacts of itsown. However, these impacts (loss of prime farmland, air quality impacts due to 1994 LRDPconstruction and operation, impacts on cultural resources, and water demand from the deepaquifer) were identified and fully analyzed in the 1994 LRDP EIR and there is no evidence that

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mitigation measures other than those identified in the 1994 LRDP EIR would mitigate any ofthese impacts to a less-than-significant level.

With regard to whether the impacts of the CRPRC projects are within the envelope of impactspreviously analyzed for the 1994 LRDP, the scope of the 1994 LRDP impacts is tied toquantified growth parameters such as number of students, number of faculty and staff, buildingsquare footage, and to physically observed conditions such as acres of prime farmland to bedeveloped, plant and animal surveys, etc. See, e.g., Draft EIR, App. A (Initial Study) at pp. 23-25 (summarizing how CRPRC project fits within population growth and building square footageprojected under the 1994 LRDP) and p. 40 (CRPRC projects would occupy an additional 3.54acres of prime farmland, which was included within the 180 acres of prime farmland anticipatedto be converted to urban uses under the 1994 LRDP). Inasmuch as the proposed CRPRCprojects are on land that is within the boundaries of the existing CRPRC, and the proposedactivities do not exceed the quantified parameters and conditions set forth above, most of theproject’s impacts were previously accounted for and analyzed as part of the 1994 LRDPdevelopment. For certain potentially significant project-specific impacts that were not identifiedin the 1994 LRDP EIR, such as impacts on neighboring land uses, the potential for avianbotulism in the stormwater detention basin, construction noise, and construction vehicle trafficon local roads, further analysis is provided in the Draft EIR.

Response to Comment D-3. It is unclear what the commenter means by the statement that“CEQA does not allow a prior, programmatic-level Statement of Overriding Considerations to beadopted as a later, project-level finding of no significant impact.” That approach was not takenin the CRPRC EIR, which is a tiered and focused EIR pursuant to Public Resources Code section21094 and CEQA Guidelines sections 15152 and 15168. For significant and unavoidablecumulative regional impacts, as described in response to Comment B-2, above, because theCRPRC projects fit within the envelope of development planned under the 1994 LRDP, thesignificance conclusions remained the same. Hence, except for impacts on prime farmland, airquality, cultural resources and water demand from the deep aquifer, as explained in response toComment D-2, above, the impacts of the 1994 LRDP were determined to be mitigated to a less-than-significant level.

For those cumulative regional impacts that were fully analyzed and found in the 1994 LRDP EIRto be significant and unavoidable because they are within the responsibility and jurisdiction ofanother public agency, the impacts remain significant and unavoidable for the CRPRC projects,not less-than-significant as the commenter believes. However, because these significant andunavoidable cumulative impacts are within the responsibility and jurisdiction of public agencies,there are no further mitigation measures within the power of UC Davis to adopt. Therefore, it isappropriate to rely on the analysis in the previously certified 1994 LRDP EIR for thosecumulative regional impacts. The reasoning in the Findings and Statement of OverridingConsiderations adopted in connection with the approval of the 1994 LRDP EIR still applies tothose impacts as well.

Response to Comment D-4. The current regional environmental setting of the project ispresented on pages 3-1 through 3-23 of the Draft EIR with respect to hazards and hazardousmaterials, on pages 3-54 through 3-55 with respect to land use, and on pages 3-59 and 3-60 withrespect to energy. For all other resources, please see Appendix A. As explained in response tocomments D-1, D-2, and D-3 above, the Draft EIR does not utilize the 1994 LRDP EIR or its

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findings to present project-level impacts, but uses the analysis from the 1994 LRDP EIR topresent cumulative impacts. The statement with respect to “no changes in circumstances, newinformation, or new mitigation measures” in the Draft EIR refers to the fact that these conditionshave not changed requiring a reanalysis of the cumulative impacts analyzed in the 1994 LRDPEIR. That statement is not made with regard to project-level impacts.

Please see response to Comment D-3 above regarding the identification and treatment in theCRPRC EIR of significant and unavoidable cumulative impacts that were identified andanalyzed in the certified 1994 LRDP EIR. As explained in response to Comment D-2, withregard to significant and unavoidable cumulative regional impacts, however, measures tomitigate the regional contribution to the impact would be within the responsibility andjurisdiction of public agencies other than UC Davis to adopt and enforce.

With respect to the adopted 1994 LRDP EIR mitigation measures, there is substantial evidencethat these measures have and will continue to mitigate the impacts of 1994 LRDP developmentto a less-than-significant level, as the 1994 LRDP EIR concluded. See, e.g., Draft EIR,Appendix A (Initial Study) at pp. 75-79 (previously adopted 1994 LRDP EIR hazardousmaterials mitigation measures that are incorporated into the project). Since 1994, several of the1994 LRDP EIR mitigation measures pertaining to hazardous materials have been implemented(see pages 3- 35 through 3-42 of the Draft EIR) including implementation of a hazardous wasteminimization program. The data show (Table 1) that despite increases in research activities onthe campus, the volume of hazardous waste requiring disposal has been declining.

Table 1Hazardous Waste Generation

Type of Waste Volume (1996) Volume (1999)

Chemical Hazardous Waste (inkilograms)

141,762 79,206

Radiological Waste (cubic feet/dryweight)

1,711 1,413

Radiological Waste (liquid in liters) 12,645 10,794

Radiological Waste (mixed in liters) 1,347 862

Source: Majewski, 2001.

The commenter asks that UC Davis examine the ability of hazardous waste managementfacilities to handle the increased hazardous (including radiological and biohazardous) wastes thatwould be generated with the expansion of the CRPRC breeding facilities. The majority of thehazardous waste that is generated on campus is landbanned (cannot be disposed in a landfill) andis incinerated in out-of-state incinerators. Only some of the waste is such that it can beneutralized or rendered nonhazardous before disposal in a landfill. UC Davis disposes itshazardous waste in two ways: (1) by treating some of the waste to render it nonhazardous andthen disposing it in the campus landfill, and (2) by contracting with two vendors for disposal offsite.

As described in the Draft EIR (page 3-36), biohazardous waste consists of laboratory tissues,cultures, fluids, infectious animal wastes and carcasses, cage washing solutions, worker’sdisposable protective clothing, and sharps. Some of the biohazardous waste (worker’s protectiveclothing and sharps-) that would be generated by the research facilitated by the projects would be

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taken to the UC Davis Medical Center where it would be rendered nonhazardous by autoclaving.The waste would then be shredded and disposed of at the campus landfill. The campus landfillhas adequate capacity to handle this increase in waste. The rest of the biohazardous wastes(animal carcasses, tissue and all other chemical and radiological wastes) would be removed byoutside vendors. Because most of the hazardous waste hauled off site by the vendors cannot bedisposed in a landfill, and only a small amount of waste can be neutralized and landfilled, theincrease in waste generated by the proposed projects would not affect the capacity of regionallandfills (Majewski, 2001).

Techniques for reducing exposure to radioactive isotopes have not changed since the 1994 LRDPEIR was adopted. However, UC Davis remains well informed about changes in researchtechniques with hazardous materials. It should be noted that the use of radioisotopes at UCDavis has not increased since 1994, even though the campus research facilities have increased.Within the academic research community, laboratory techniques using fluorescent compoundshave been replacing some of the laboratory techniques that at one time used radioactive isotopes.As a policy, UC Davis encourages its laboratories to, whenever possible, follow laboratorytechniques using fluorescent compounds over laboratory techniques using radioisotopes(Westcott, 2001). The CRPRC has also begun to phase out the use of radiological materials inresearch where feasible because of the high cost of disposal and potential for health risk. TheCRPRC continues to examine ways to minimize use of these materials, and as noted earlier thevolume of radiological wastes generated by the campus has been declining. Additionalmitigation is not considered necessary.

Response to Comment D-5. The commenter is correct in noting that the California Departmentof Fish and Game (CDFG), the California Department of Food and Agriculture, and US Fish andWildlife Service (USFWS) are responsible agencies for the state’s wildlife and agriculturalresources. These agencies were not specifically mentioned in the EIR because no permits orapprovals are needed from these agencies for the proposed projects. These agencies wereprovided copies of the Draft EIR for review by the State Clearinghouse (see Document DetailsReport, State Clearinghouse Database provided on page 4-37). In addition, this information canbe viewed on the State Clearinghouse website, www.ceqanet.ca.gov. UC Davis also directlymailed a copy of the Draft EIR to the CDFG and the USFWS. No Comments were receivedfrom any of the agencies.

Response to Comment D-6. The commenter requests a demonstration of compliance withCalifornia Fish & Game Code Section 2150(e), and requests that CDFG and CDFA be given theopportunity to review the Project and the Draft EIR's proposed mitigation measures. As notedabove in response to Comment D-5, both CDFG and CDFA were provided copies of the DraftEIR by the State Clearinghouse and by the campus directly as part of the CEQA process. Theseagencies did not provide any comments on the Project or on the proposed mitigation measures.

Wild animals, including primates, may not be possessed in California without a permit, unlesssome exemption applies. Fish and Game Code section 2118 states that:

"It is unlawful to import, transport, possess, or release live into this state, except under arevocable nontransferable permit as provided in this chapter and the regulations pertainingthereto, any wild animal of the following species: . . . (b) Class Mammalia (mammals), OrderPrimates, All species except those in family Homonidae." [emphasis added]

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"Wild animals" are divided into two categories: (1) "detrimental" species (those that pose apotential threat to agriculture, native wildlife or public health); and (2) "welfare" species (thosewhose possession is prohibited in order to prevent the depletion of wild populations and toprovide for the welfare of captive animals (14 Cal. Code Reg. Section 671). All primates arespecifically identified as a "welfare" species, that is, they are not considered by CDFG to poseany potential threat to the State and they are regulated for their own protection. [See"Importation, Transportation and Possession of Wild Animals" Dept. of Fish & Game ManualNo. 671].

The statute cited by the commentor, Fish and Game Code section 2150(e), grants a permitexemption to universities and other listed entities that engage in scientific or public healthresearch, so long as the wild animals are not considered detrimental:

"[a]ny university, college, governmental research agency, or other bona fide scientific institution,as determined by the department, engaging in scientific or public health research is exempt fromany permit requirement pursuant to this chapter except for animals whose importation,transportation, or possession is determined by the department, in cooperation with theDepartment of Food and Agriculture, to be detrimental or cause damage to agriculture, nativewildlife, or the public health and safety."

As stated above, primates are not considered detrimental by CDFG; therefore, the University hasno further obligations under this statute.

Response to Comment D-7. As stated above, USFWS and CDFG were provided copies of theDraft EIR by the University for review and comment. No comments were received from theseagencies.

Response to Comment D-8. The commenter suggests that instead of the current practice of livetrapping, new measures to exclude wildlife from the area of the field corrals be developed asmitigation measures for the proposed project. It should be noted that no mitigation measures arerequired in this matter because the project will not change the need for trapping animals at thefield corrals. The entire CRPRC is enclosed by a field fence, and the area of the field corrals(including the expansion area) is enclosed by a second field corral perimeter fence. Theperimeter fence is constructed to extend 1 foot below grade in order to discourage burrowinganimals from entering the corrals. The fence itself is 6 feet high with three strands of barbedwire on top. The corral area are in themselves fenced areas and are canopied. No new fenceswould be necessary and no changes to the current practice of live trapping would be necessarybecause the affected area would remain unchanged with the projects.

Consultation with Yolo County Animal Services reveals that with the exception of skunks, andwild cats and squirrels that show signs that they could be a threat to others, all wildlife turnedover to Animal Services are released. (Andrade, 2001).

Response to Comment D-9. The commenter indicates that the DEIR failed to investigate thefeasible mitigation measure of retiring primates that have been used in invasive testing. Theimplication is that this would reduce or avoid impacts associated with disposal of animals thathave been used for experiments. The commenter indicates that API has accepted various retiredprimates from other facilities around the country. The animals that are addressed in the DEIR, asa projected waste stream, are animals that have been used in studies where examination of postmortem tissue is part of the experimental design. For animals that are involved in non-invasive

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studies, these animals are maintained by the CRPRC for further non-invasive studies onmetabolism, behavior, and nutrition. The CRPRC animal studies range from neonatal biology togeriatric health problems. Since the purpose of the proposed expansion is to meet the nationalneeds for primates to help study human health problems, it is not feasible to consider “retiring”animals that are already in short supply.

Response to Comment D-10. The commenter requests clarification on the need for 175additional macaques and why that number exactly equals the proposed number produced by thepopulation expansion. The proposed expansion will in fact, not meet the national need orregional need for rhesus macaques. The number 175 does reflect the capacity for expansion. Ifthe CRPRC could currently accommodate further expansion, this number would be higher. Thecommenter is referred to the article in the February 11, 2000 issue of Science entitled “AIDSresearch. Vaccine studies stymied by shortage of animals.” A quote from the article indicatesthe need, “ The demand for rhesus macaques, the animal of choice for Johnson and a growingnumber of AIDS researchers, far outstrips the supply” and, “To make matters worse, researchersin reproductive biology, malaria, and other fields also have begun to rely more heavily on rhesusmacaques.” The CRPRC recently had to turn down a project from a nonprofit foundation todevelop an AIDS vaccine because it cannot provide the 150 animals needed for the study. TheCRPRC has been approached about supplying rhesus macaques to test new treatments foranthrax, but does not currently have rhesus macaques available to meet this request. TheCRPRC did not mean to indicate in the Draft EIR that the expansion will meet either the regionalor national needs, only that this is what UC Davis can do at this time to meet this national crisis.The commenter cites p. 5-12 “ The proposed number of field corrals and corn cribs are theminimum numbers needed to meet program needs.” This is correct. Regarding the additionalavailability of nonhuman primates by the addition of the South West Regional Primate ResearchCenter (SWRPRC) to the primates centers program, the commenter should note that theSWRPRC is not a new primate facility; rather, it has been in existence longer than the CRPRC.SWRPRC’s funding by NIH does not add any additional animals to the national population.What is new is that they have increased funding from NIH. Secondly, their primate population isprimarily baboons and chimpanzees, not rhesus macaques. The purpose of the proposed CRPRCexpansion is to produce rhesus macaques.

Response to Comment D-11. The commenter inquires as to how the CRPRC will check healthon 2,400+ primates on a daily basis and complete the three times per year “full blown” healthexams on all outdoor housed primates. Each outdoor cage is entered on a daily basis by twoanimal care staff and all animals are visually inspected for signs of illness or injury. Anyanimals with signs of health problems are captured and brought into the veterinary clinic. Forthe veterinary exams, the CRPRC currently has a weekly schedule of physical exams for theoutdoor corrals. One corral is examined each week. A team of 10 animal care staff, animalhealth technicians and veterinarians anesthetize and perform a physical exam on each animal inthe corral on that day. Currently, with 17 corrals and exams three times/year, corral healthexams are performed 51 weeks of the year. When the corral number reaches 24, two corrals willbe examined each week for 20 weeks of the year.

Response to Comment D-12. While the groundwater testing performed for the DEIR in 2000provides substantial evidence that the CRPRC has not adversely affected groundwater quality,the Draft EIR does not rely solely on the groundwater testing to assess the potential forsignificant impacts from CRPRC field corral operations. The Draft EIR explains that the animal

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health program at the CRPRC controls disease in outdoor animals. Although some commonpathogens may be present in the runoff from the corrals, the concentrations in the pond water areand would continue to be low due to exposure to sunlight and travel of runoff through grassyswales. Furthermore the site geology indicates that the soils are clayey and therefore thepotential for transport of pathogens to the fairly deep groundwater table is limited. To furtherreduce this less-than-significant effect, the CRPRC has committed to continue monitoringgroundwater in the new wells to detect any impacts and take appropriate actions if a problem isdetected. Additional analysis is not considered necessary. A rule of reason governs thepreparation of an EIR; an EIR must be prepared with a degree of analysis that is reasonablyfeasible (CEQA Guidelines Section 15151).

Response to Comment D-13. The 3-acre field corral stormwater basin (figure 4 in the DraftEIR) is proposed to retain the runoff from the corrals (i.e., the corral stormwater will notdischarge water to another waterbody). This basin is not intended to be developed with habitatvalues and will therefore be maintained by clearing unnecessary vegetation as necessary.Aquatic species would not be encouraged to nor are expected to occupy this basin because ofperiodic maintenance that would be implemented at this basin.

The larger, 18-acre stormwater detention basin (which would temporarily detain and then releasewater to Covell Drain) would be developed with habitat values and would therefore be vegetated.Aquatic species would be encouraged to occupy this basin. To avoid avian botulism (MitigationMeasure 3.1-2), this basin would be drawn down and managed by removing decaying vegetationand carcasses. Careful management of wetlands (including draw down) is recommended by theresource agencies, including USFWS, and is not considered to be harmful to aquatic species thatmay occupy the wetlands. The commenter is referred to the USFWS leaflet 13.2.4 on AvianBotulism (Locke and Friend, 1989).

Response to Comment D-14. As explained in response to comment D-12, UC Davis hasdetermined that at this time there is no reason to believe that the stormwater in the field corralbasin would have the potential for public health or wildlife impacts. The campus will test thewater for pathogens, as required by proposed Mitigation Measure 3.1-1, and take additional stepsif necessary, as stated in the Draft EIR. No further mitigation is needed.

Response to Comment D-15. The UC Davis campus, similar to all UC campuses, has a verydetailed and rigorous control program with respect to use of biohazardous materials. As statedon pages 3-19 and 3-20 of the Draft EIR, prior to commencing a research project involvingbiohazardous materials, every researcher is required to prepare a protocol describing thematerials to be used, quantities involved, and procedures that would be employed to safeguardresearcher and public health. The protocol is then submitted to the Biological SafetyAdministration Committee for review. If the committee is satisfied with the protocol, it issues aBiological Use Authorization (BUA) for the research program. It is in the preparation of theprotocol that researchers often seek help from the EH&S department. This is not a mandatoryrequirement. All campus policies and procedures governing the use of biohazardous materialsare contained in the Biosafety Manual developed by EH&S, which is also available toresearchers for their use in the preparation of the protocol and for use during their research.Because every researcher must develop this protocol and have it approved, the DEIR concludesthat the impact is less than significant.

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Response to Comment D-16. The Draft EIR on page 3-57 notes that land uses near the projectsites include homes, a church with a school on CR 98, and homes along Russell Boulevard. Theestimated construction noise impact identified for the church (70 dBA) also applies to the churchschool. An exterior noise level of 70 dBA would be reduced to 45 to 50 decibels inside theschool with the windows closed and these indoor noise levels would not interfere with normalteaching activities. The Draft EIR also notes that the 1994 LRDP EIR Mitigation Measure 4.4-1for construction noise would be applicable to the projects (see pages 54 and 55 of the InitialStudy in Appendix A) which would address the impact to the school. Furthermore, constructionnoise would occur over a short duration. Therefore, with the implementation of 1994 LRDP EIRMitigation Measure 4.4-1, construction of the stormwater detention basin and the field corralretention basin would not result in a significant noise impact on school operations. It should alsobe noted that the school is located in an area of agricultural operations where grading and heavyequipment use occurs routinely. Campus Agricultural Services periodically conducts gradingand agricultural operations on the fields across CR 98 from the Grace Valley Christian Center(GVCA), and the campus has received no complaints from the school with respect to noise.

The commenter should also note that because the time restrictions contained in 1994 LRDP EIRMitigation Measure 4.4-1 do not address prayer activities in a church, project-specific MitigationMeasures 3.2-2(a) and (b) are recommended to be incorporated into the field corral basin and thestormwater detention basin projects.

Response to Comment D-17. Wetlands can produce odors, generated by bacterialdecomposition of organic matter in anaerobic conditions. Anaerobic conditions may occur whenthe soil is saturated or inundated and it becomes deoxygenated (all the oxygen is used-up).Bacterial reactions in anaerobic conditions cause the release of sulfur dioxide (marsh gas) whenthe marsh is disturbed. This gas has a distinctive, unpleasant odor. These conditions generallyoccur in warm summer months, in a system without sufficient mixing or with a largebiochemical oxygen demand (i.e. lots of organic matter that needs to be decomposed). Algalblooms can also produce odors, most often the odors are caused by bluegreen algae growing inponded, stagnant water.

Most seasonal wetlands do not produce odors. This is because seasonal wetlands only pondwater in the cooler, winter months. By definition, seasonal wetlands are dry in the warmsummer months. Stormwater detention basins are unlikely to generate odors because thedetention basin is likely to be dry or contain very little water during the summer. Although thedeepest portions of the basin would be up to 6 feet deep, it is not expected that the pond wouldbe full during summer months. The basin will continue to discharge water to Covell Drain, andwill therefore not develop a deep pool of water that would persist into the summer months.Algal blooms are also not considered likely for the same reason, i.e., the low potential for theponding of deep water during the summer months. Furthermore, the project is located in anagricultural area where any potential odors that could occur from the unseasonal collection ofwater would likely be indistinguishable from odors due to fertilizer application.

Odors are also not considered to be an issue for the field corral retention basin because it is notexpected to support vegetation and should be dry during the summer. Odors from animal wastein the runoff are not likely because as explained in the Draft EIR, very small quantities of wasteare expected to reach the basin.

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Response to Comment D-18. EI2B, the electrical improvement project on West Campus iscurrently under construction and will be completed by the end of 2002. This will be adequate toserve the needs of the proposed projects. A backup feeder would not be necessary.

Response to Comment D-19. The commenter is incorrect in stating that the Draft EIR suggeststhat the use of alternate research methods would totally eliminate the entire CRPRC. That is notsuggested in any way in the Draft EIR. The text in the Draft EIR on page 5-10 states veryclearly that this alternative “…thereby eliminates the need for new corrals, corncribs, or anyother animal facilities.” On page 5-11, the Draft EIR notes that “the use of alternate researchtechniques is not a viable alternative to the proposed field corrals and corncrib expansionprojects.”

The commenter should note that in the event that the new field corrals and corncribs are notconstructed, the campus is not required to construct the retention or detention ponds. As statedon page 2-6 of the Draft EIR, both the stormwater drainage improvements and the field corralpond are proposed in order to implement LDRP EIR Mitigation Measure 4.8-7 which is triggeredonly if new facilities are constructed at the CRPRC. Therefore, as correctly noted in the DraftEIR all impacts that are associated with the drainage improvements and the field corral retentionbasin would be avoided under the alternative of using alternate research methods.

The Draft EIR noted the use of hazardous materials to be similar and energy use potentiallygreater for the alternative involving alternate research techniques on the assumption that thealternative research techniques would use chemicals and equipment more intensive than animal-based studies. The analysis of use of hazardous materials and energy consumption foralternative research techniques is difficult to perform since there are no known alternatives formany of the studies conducted at the CRPRC. A specific requirement for approval of aninvestigator’s protocol at UC Davis to use nonhuman primates is a demonstration that there areno known alternatives to the use of animals for this research. Human research is often the onlyalternative to conducting the study in nonhuman primates. The invasive nature of many of thesestudies precludes them from being performed in humans. To use alternative methodologies forthese areas of research would not only require development of new technologies that do not existbut also conducting these novel experiments in parallel to existing experimental designs usingnonhuman primates to validate the alternative system. This proposal would have the potential todouble the use of hazardous materials and energy to obtain the same information from twodifferent experimental systems, at least until these alternate research systems are validated.Without having these new, undiscovered alternative systems to analyze, however, any analysis ofthe use of hazardous materials or energy is speculative.

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Response to Comment Letter E-In Defense of Animals

Response to Comment E-1. Comment noted.

Response to Comment E-2. Please see responses to Comments D-1, D-2 and D-3.

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Response to Comment Letter F-Law Office of J. William Yeates

Response to Comment F-1. The campus responded to this request for an extension of thedeadline to submit comments on the Draft EIR in writing and explained why an extension wasnot considered necessary. See letter from the campus that follows.

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Response to Comment Letter G-Wesley R. Wooden

Response to Comment G-1. The commenter may be referring to a groundwater contaminationplume of volatile organic compounds (VOC). This plume mainly contains chloroform. Itoriginated in some chemical burn trenches located within the bounds of the landfill site at thewest end of the UC Davis campus. This plume was characterized 5 years ago and a groundwatercleanup system has been installed. Remediation of this plume has proven to be effective. Thecampus has an ongoing groundwater monitoring program that collects samples on a quarterlybasis. The landfill is operating in compliance with its Waste Discharge Requirements (permit)granted by the Central Valley Regional Water Quality Control Board and local permittingagency (Phillips, 2001).

Response to Comment G-2. The issue of risk to health and safety was addressed in the DraftEIR. The commenter is referred to pages 2-3 through 2-8 for a description of the proposedproject and referenced specifically to page 2-3 stating that “all infected animals are housedindoors.” The commenter is also referred to page 3-5 for a description of the types ofbiohazardous materials considered in the Draft EIR and to the extensive discussion ofbiohazardous materials beginning on page 3-4. Potential risks from biohazardous materials thatcould be associated with the proposed project are discussed extensively in the impact discussionof the Draft EIR beginning on page 3-23. The Draft EIR contains sufficient information toanalyze the potential for impacts due to biohazardous materials at the CRPRC.

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5. Section 5 FIVE References

Andrade, E. 2001. Yolo County Animal Services, Personal Communication with URS.November.

Cohen, J. 2000. Aids Research: Vaccine Studies Stymied by Shortage of Animals. Science,February 11.

Locke, L.N. and Mitlon Friend. 1989. Avian Botulism: Geographic expansion of a historicdisease. U.S. Fish and Wildlife Leaflet 13.2.4.

Majewski, A. 2001. Environmental Health and Safety, UC Davis. Personal communicationwith URS. October/November.

Phillips, D. 2001. Facilities Services, UC Davis. Personal communication with URS.October/November.

U.C. Davis 1994. U.C. Davis Long Range Development Plan: 1994–2005, Draft EnvironmentalImpact Report. Prepared by EIP Associates. Sacramento, CA. April.

Westcott, G. 2001. Environmental Health and Safety, UC Davis. Personal communication withURS. October/November.

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6. Section 6 SIX List of Preparers

6.1 LEAD AGENCYThe University of California, Davis

6.2 FINAL ENVIRONMENTAL IMPACT REPORT AUTHORS

Individuals ConsultedSteve Cello, UC Davis, California Regional Primate Research Center

A. Sidney England, UC Davis, Office of Resource Management and Planing

Matt Dulcich, UC Davis, Office of Resource Management and Planing

Andrew Majewski, UC Davis, Environmental Health and Safety

Brian Oatman, UC Davis, Environmental Health and Safety

David Phillips, UC Davis, Facilities, Water and Waste Services

Jeff Roberts, UC Davis, California Regional Primate Research Center

Jerry O’Hearn, UC Davis, Architects and Engineers

Report PreparersShabnam Barati, Project Manager, URS

Suzanne Eastridge, Senior Staff Scientist, URS

Orion Fulton, Staff Scientist, URS

Usha Vedagiri, Senior Risk Assessor, URS

Joy Mashaal, Staff Scientist, URS

John Koehler, Senior Air Quality Specialist, URS

Phillip Mineart, Senior Hydrologist, URS

Laura Perez, Staff Scientist, URS

Lily Panyasocit, Senior Staff Scientist, URS

Geoff Thornton, Staff Scientist, URS