SECTIONFIVE. Comments and Responses to Comments

Transcription

1 Comment Letter-C 1

2 Comment Letter-C (cont d)

3 Comment Letter-C (cont d)

4 Comment Letter-C (cont d) 8 9

5 SECTIONFIVE Comments and Responses to Comments Response to Comment Letter C 1. The comments regarding the advisability and effectiveness of using mice in research related to human health are not comments on an environmental issue. The comments will be conveyed to The Regents as part of this Final EIR to consider in its approval of the proposed project. It is noted that despite differences between mice and humans in terms of their genome, there are enough similarities and scientific research using mice as a model for human physiology has yielded results that have benefited humans. As noted in the Draft EIR, the mouse is an excellent model organism in which to study the functions of genes and their relevance to human health. Mice have been used in biomedical research for more than a century, and some biomedical research uses mice carrying mutations that were documented as early as 80 B.C. Mouse geneticists breed mice for specific gene characteristics, giving rise to many strains of mice (genotypes) with specific characteristics (phenotypes) that are useful for human health research. Some of the diseases under investigation at UC Davis include diabetes, obesity, heart disease, cancer, and immune function disorders. There is now a rapidly growing worldwide demand for genetically defined mice that have specific genetic traits. The California biomedical research community, including universities and biotechnology companies, has the fastest growing demand for mouse models in the United States. The Jackson Laboratory project at UC Davis will serve not only research at UC Davis, but also elsewhere in the western United States. 2. Although the project would make a contribution to significant unavoidable impacts related to development throughout the Davis region, these regional significant unavoidable impacts could not be avoided by not pursuing the project. The project itself would have no significant impacts and its contribution to regional impacts would not be cumulatively considerable. UC Davis 1994 LRDP includes mitigation measures that substantially reduce the contribution of UC Davis projects to regional impacts related to hazardous waste, the use of hazardous materials, and water consumption. With these measures in place, the impacts of the proposed project would not be cumulatively considerable. However, since UC Davis cannot control the use and disposal of hazardous materials or water use practices elsewhere in the region, there is nonetheless a regional potential for significant unavoidable impacts in these areas. 3. The Tiered Initial Study (August 2000) examined a 65,000 square foot facility on 5 acres, but as explained on pages 1-5 to 1-6 of the DEIR, the Project Draft EIR analyzed a larger 96,064 square foot facility on 6 acres at the request of the project sponsor. TJL envisions that it will require about 96,064 square feet of space to house the number of mice it needs to breed in its West Coast facility to adequately serve the needs of the research community. As noted in Section Three of this Final EIR, this facility would be built in phases with the first phase involving about 73,780 square feet of space to house 185,000 mice and the second phase adding 22, 284 square feet for a buildout of 96,064 square feet and a mouse population of 300,000 mice. 4. Since the certification of the 1994 LRDP, Illness and Injury Prevention Plans called for in Mitigation Measure have been completed for campus facilities and a program is in place to implement and maintain this plan at facilities on campus, as described in the Project Draft EIR under Impact and Mitigation Measure (p. 3-11, DEIR). JAX West would F:\DATA\WEB\JAX\JACKSON LAB FINAL EIR.DOC\2-MAR-01\\OAK 5-16

6 SECTIONFIVE Comments and Responses to Comments prepare a site-specific Illness and Injury Prevention Plan and would be monitored by the campus department of Environmental Health and Safety as condition of the project lease. The Jackson Laboratory also has animal handling protocols in place to ensure against risk of injury in handling large numbers of animals at its other facilities. With inclusion of these measures, the project would have a less-than-significant impact to human health and safety associated with animal handling. 5. Although JAX West would be privately operated, conditions of operation with respect to safety protocols, and handling, use and disposal of hazardous waste would be regulated by UC Davis Department of Environmental Health and Safety as a condition of its lease. With these protocols in place, the impacts of the facility are considered not cumulatively considerable. The impacts with respect to hazardous waste are assessed as significant and unavoidable not because JAX West would be outside the control of the campus (as stated by the commenter), but because the campus has no control over the production, handling or disposal of hazardous materials by other off-campus entities in the region. 6. Energy impacts of the proposed project are discussed on pages 3-27, 3-28 and 3-30 of the Draft EIR. The proposed project includes energy conservation measures pursuant to Titles 20 and 24. In addition, it includes a standby generator that would be utilized in the event of a brown out or interruption of electrical service. The project also would be included in the campus s load management program to voluntarily reduce loads when the State s energy reserves fall below critical levels. With the incorporation of all these measures in the proposed project, project impacts on energy resources are considered less than significant. The State s energy crisis is also acknowledged in the Draft EIR, and it is noted that there is no evidence that the project on its own and in conjunction with other development on campus would result in the need for new generating facilities. It should also be noted that although currently there appears to be an imbalance between supply and demand for electricity in the State, because electricity can be transmitted through the grid, it can be obtained from a wide range of sources, both in and out of state. As a result of this characteristic, it would be speculative to evaluate environmental impacts from the construction and operation of new generating facilities in California that may be triggered by the project in conjunction with other development in the region. Besides, as discussed in the Draft EIR, the California Energy Commission conducts environmental review for all large generating facilities that are proposed in California and prepares a CEQA-equivalent document that analyzes and discloses environmental impacts from the construction and operation of new power plants, and imposes mitigation measures as conditions of project approval to address significant impacts. 7. The Draft EIR Summary Table S-1 included a typographic error with respect to the LRDP EIR mitigation measure that addresses the conservation of domestic water drawn from the deep aquifer. The correct number of that mitigation measure is (a). The table has been corrected. The impact on the deep aquifer cannot be quantitatively assessed since its capacity is unknown. It is for this reason that any water use is considered a significant unavoidable impact (p. 3-30, DEIR). To reduce this impact as much as feasible, water conservation measures are required as part of design, development and operation of all projects on the campus, including the proposed project. The anticipated water consumption of the project F:\DATA\WEB\JAX\JACKSON LAB FINAL EIR.DOC\2-MAR-01\\OAK 5-17

7 SECTIONFIVE Comments and Responses to Comments falls within the levels predicted for campus development under the 1994 LRDP, and for this reason the contribution of the project to the significant unavoidable impact is not considered cumulatively considerable. It would not be feasible to use recycled wastewater at the JAX West facility. The campus wastewater treatment plant is approximately 2 miles away and no system is in place to convey treated effluent to the project site. 8. Please see Response C2, above. 9. As described on page 79 of the Tiered Initial Study, included as Appendix A of the Draft EIR, the campus conducted a survey of the entire West Campus Enterprise Reserve in 1998 for special status plant and wildlife species. The project site does not include appropriate nesting sites for the species. As discussed on page 80 of the Tiered Initial Study the site does provide foraging habitat for the Swainson s hawk and other avian species, and the implementation of the project would remove 6 acres of this foraging habitat. The removal of this habitat was anticipated in the 1994 LRDP EIR and mitigation measures and 4.7-9(a) were identified to address this impact. F:\DATA\WEB\JAX\JACKSON LAB FINAL EIR.DOC\2-MAR-01\\OAK 5-18

8 Comment Letter-D 1

9 Comment Letter-D (cont d) 1 2 3

10 SECTIONFIVE Comments and Responses to Comments Response to Comment Letter D 1. The commenter expresses concern with respect to traffic hazards for non-vehicular traffic on Hutchison Drive and Hopkins Road due to the increase in traffic volumes in the area and the lack of bicycle/pedestrian facilities along these roads. As discussed on pages of the Tiered Initial Study included as Appendix A of the Draft EIR, the project would not introduce new safety hazards because of new equipment and because current pedestrian and bicycle usage is limited. The LRDP includes a proposed bike path along Hutchison Drive, which has not yet been constructed because of low levels of pedestrian/bicycle activity along the road. The campus will examine the current and projected pedestrian/bicycle activity and will implement the bike path, if warranted, taking into account traffic safety issues. 2. Placing underground utilities beneath existing roadways is standard campus design practice where feasible. This approach minimizes disturbance to existing landscaping or adjacent land uses, and allows maintenance or upgrade projects without these types of disturbances. Therefore, if and when Hutchinson Road is widened, the sewer lines would be placed beneath the widened road. Utility poles may or may not need to be relocated depending on how and which direction the road would be widened. Road widening and/or utility work would pose no constraint on the campus ability to implement a bikepath, if warranted. See Response D1 above. 3. As discussed on page 40 of the Initial Study (Appendix A of the Draft EIR), the development of new facilities in the Enterprise Reserve and at the Primate Center was anticipated in the 1994 LRDP cumulative traffic analysis. That traffic analysis was subsequently updated by the Major Improvement Projects SEIR in 1998 and by the Veterinary Medicine Laboratory and the Equine Athletic Performance Facility EIR in 2000 to account for redistribution of some of the growth from the central campus core to the Health Sciences District. These updated cumulative traffic analyses address the growth in traffic along Hutchison Drive west of Highway 113 including the proposed project and show that the intersection of Hutchison and Hopkins Road would operate at an excellent level of service. The addition of traffic by the proposed project would not adversely affect the operation of the roadways. The commenter is referred to Response D1 above with respect to safety concerns noted in this comment. F:\DATA\WEB\JAX\JACKSON LAB FINAL EIR.DOC\2-MAR-01\\OAK 5-21

11 Comment Letter-E 1 2 3

12 SECTIONFIVE Comments and Responses to Comments Response to Comment Letter E 1. Humane treatment of animals used in the facility will be ensured through compliance with the guidelines of the American Association for Accreditation of Laboratory Animal Care (AAALAC). See Appendix B of the DEIR. 2. See Response C1. 3. No project-specific significant environmental impacts were identified by the commenter. F:\DATA\WEB\JAX\JACKSON LAB FINAL EIR.DOC\2-MAR-01\\OAK 5-23