I. APPROVAL OF THE LOS RIOS COMMUNITY COLLEGE DISTRICT DAVIS CENTER AND CONSIDERATION OF THE CERTIFIED 2002 LRDP EIR AND ADDENDUM THERETO

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1 CALIFORNIA ENVIRONMENTAL QUALITY ACT FINDINGS IN CONNECTION WITH THE DESIGN APPROVAL FOR THE LOS RIOS COMMUNITY COLLEGE DISTRICT DAVIS CENTER, DAVIS CAMPUS I. APPROVAL OF THE LOS RIOS COMMUNITY COLLEGE DISTRICT DAVIS CENTER AND CONSIDERATION OF THE CERTIFIED 2002 LRDP EIR AND ADDENDUM THERETO The findings set forth below are for the design approval of the Los Rios Community College District (LRCC) Davis Center (the Project) within the West Village area of the University of California ( the University ), Davis campus ( UC Davis ). Design approval by the Board of Regents of the University of California ( The Regents ) constitutes a discretionary action by the University of California for the Project. The Project would be built, operated and maintained by the LRCC under the terms of a ground lease with the University. The Project is a component of the UC Davis campus 2003 Long Range Development Plan (2003 LRDP) and Neighborhood Master Plan (the NMP)), which were analyzed in the 2003 LRDP Environmental Impact Report (2003 LRDP EIR). The 2003 LRDP EIR, State Clearinghouse Number , was certified by The Regents in November 2003 in connection with the approval of the 2003 LRDP, as set forth in the adopted Certification of the Final EIR, Findings, and Approval of the University of California Davis 2003 Long Range Development Plan (the LRDP Findings ) and the NMP as set forth in the Findings and Approval of the University of California Davis Neighborhood Master Plan (the NMP Findings ). Following approval of the 2003 LRDP and NMP, UC Davis undertook an extensive developer selection process and entered into exclusive negotiations with a private sector developer to develop an area of the NMP referred to as the West Village. The campus and the developer team prepared a plan that integrates financial, planning, design, and management guidelines for the successful development of the West Village The West Village Implementation Plan (WVIP). In November 2006, The Regents approved the WVIP based on the LRDP EIR and an Addendum #1 thereto, as set forth in the California Environmental Quality Act Findings in Connection with the Amendment to the 2003 LRDP and Approval of the WVIP Davis Campus (the WVIP Findings ), and determined that the WVIP substantially conforms to the development proposed for the West Village area as set forth in the 2003 LRDP and NMP. Further, in November 2006, The Regents delegated design approval for individual projects within the West Village to the Chancellor of the UC Davis campus. The November 2006 delegation did not include authority to approve the design of the LRCC Davis Center. The Regents has considered the information included as part of the above-described California Environmental Quality Act, Public Resources Code sections 21000, et seq. (CEQA) documentation prior to making the findings in Section II and determinations in Section III,

2 Page 2 below, in connection with the Davis campus request for approval of the Project and finds that said documentations reflects the independent judgment and analysis of the University. II. FINDINGS SUPPORTING APPROVALS A. Description Of Proposed LRCC Davis Center And Comparison To Development Described In The WVIP The WVIP plan and the LRDP EIR described and analyzed a proposal to develop a Community Education Center (CEC ) within West Village. The WVIP and LRDP EIR and Addendum #1 described the proposed CEC, now called the LRCC Davis Center, as a single 4- acre develop with 60,000 assignable square feet of space for classrooms and administrative purposes, exterior landscaping, and automobile parking. While the LRCC Davis Center will eventually include completion of 60,000 asf, the current proposal includes development of the entire site utilities and landscaping, an initial building of 14,000 asf, and a development site for the future buildings that will be constructed to reach the total of 60,000 asf. At full build-out, the CEC included approximately 90 employees and would serve approximately 2,100 enrolled students. The site for the CEC is north of Hutchsion Drive at a point north of the Heidrick Center near the main entrance to the West Village development. The proposed LRCC Davis Center remains the same as described in the WVIP and the LRDP EIR and Addendum 1. The LRCC Davis Center would be located on the same 6.3 acre site north of Hutchison Drive and would include 60,000 asf. The single-story building would accommodate 90 employees and an enrollment of approximately 2,100 students. The site would provide parking for the students and employees and would include perimeter and interior landscaping. The project includes development of the 4-acre LRCC Davis Center site and construction of the 14,000 asf building. The proposed two-story building would include design and certification at the LEED Silver level and would consist of 8 classrooms, 1 computer laboratory, 1 art studio, a career center, wellness space, and administrative offices. The building would be oriented in east/west direction and would include an entry courtyard on the southside of the building. The building would include a flat roof with a parapet and screen wall to cove r the roof-mounted mechanical equipment. Access for trash and recycling services would take place on the west side of the building through the parking lot. The materials and architectural details of the building would include metal panel siding, wood beams, cement plaster, and window specifications that are consistent with the architectural requirements in the West Village Implementation Plan. B. Environmental Review for the LRCC Davis Center In November 2003, The Regents certified the 2003 LRDP EIR and adopted the 2003 LRDP and the NMP. The 2003 LRDP and EIR analyzed the scope and nature of development proposed to meet the goals of the UC Davis campus through academic year and more

3 Page 3 specifically implementation of the NMP. The LRDP EIR identified measures to mitigate, to the extent feasible, the significant adverse direct and cumulative impacts associated with growth of the UC Davis campus under the 2020 LRDP and the NMP. In November 2006, The Regents approved the West Village Implementation Plan (WVIP) based on the LRDP EIR and an Addendum #1 thereto, as set forth in the California Environmental Quality Act Findings in Connection with the Amendment to the 2003 LRDP and Approval of the WVIP Davis Campus (the WVIP Findings ), and determined that the WVIP substantially conforms to the development proposed for the West Village area as set forth in the 2003 LRDP and NMP. The University has reviewed and considered the LRDP EIR, Addendum #1, and the findings adopted in support of the approval of the 2003 LRDP, NMP and WVIP, and finds, pursuant to CEQA Guidelines Section 15162, that the these documents contain the environmental analysis and information necessary to support approval of the LRCC Davis Center and that no further environmental analysis is required as discussed in Section C, below. As set forth below, the impacts associated with the Project are adequately analyzed in the certified LRDP EIR and Addendum #1 thereto, and no further environmental review is required and no additional mitigation measures are necessary. C. Project-Specific Impacts An analysis of the potential environmental impacts of the Project in relation to the previously certified 2003 LRDP EIR and Addendum #1 thereto demonstrates that pursuant to Section of the California Code of Regulations Title 14, Chapter 3 (the CEQA Guidelines ), no further environmental review is required because: (1) The Project will not require major revisions of the 2003 LRDP EIR and Addendum #1, and will not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects. (2) There are no changes in the circumstances under which the Project will be undertaken that will require major revisions of the previously certified 2003 LRDP EIR or Addendum #1 thereto, and that no new significant environmental effects or a substantial increase in the severity of previously identified significant effects will occur as a result of the Project. (3) No new information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the 2003 LRDP EIR was certified and Addendum #1 was completed that shows any of the following: a. The Project will have one or more significant effects not discussed in the 2003 LRDP EIR and Addendum #1.

4 Page 4 b. Significant effects previously examined will be substantially more severe than shown in the 2003 LRDP EIR and Addendum #1 c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the Project, but the Project proponents decline to adopt the mitigation measure or alternative; or d. Mitigation measures or alternatives which are considerably different from those analyzed in the 2003 LRDP EIR and Addendum #1would substantially reduce one or more significant effects on the environment, but the Project proponents decline to adopt the mitigation measure or alternative. Accordingly, as documented below, the University has determined that the Project will not result in any new significant environmental effects, or a substantial increase in the severity of previously identified significant effects. Major revisions to the 2003 LRDP EIR and Addendum #1 are not required. While there is new information, it does not show that the Project will have one or more significant effects not discussed in the 2003 LRDP EIR and Addendum #1, that significant effects previously examined will be substantially more severe that previously shown or that there are feasible mitigation measures or alternatives that have not been adopted. Rather, the analysis indicates that the Aesthetics, Agricultural Resources, Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise, Population and Housing, Public Services, Recreation, Traffic, Circulation and Parking, and Utilities effects will remain as determined in the 2003 LRDP EIR and Addendum #1 thereto, and the adopted findings approving the LRDP, NMP, and WVIP. Further, the Project does not effect the mitigation measures and mitigation measures monitoring program adopted in connection with the approval of the 2003 LRDP, NMP, and WVIP, which are hereby incorporated by reference as if fully set forth herein. 1. Aesthetics The 2003 LRDP EIR concluded that scenic resources would not be damaged through implementation of the 2003 LRDP and NMP because no portion of the project area for either the LRDP or NMP is adjacent to a designated state scenic highway. The Regents subsequently approved the WVIP in November 2006 based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and NMP and therefore will also have no impact on scenic resources. The Project is consistent with the LRDP, NMP and WVIP and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis. No additional environmental analysis or mitigation measures are required to address scenic resources. The 2003 LRDP EIR identified the following mitigation measures to address potential aesthetic impacts associated with implementation of the 2003 LRDP, which are hereby incorporated into the Project:

5 Page 5 LRDP Mitigation The Campus Design Review Committee will consider scenic views while planning for projects under the 2003 LRDP to maintain scenic views to the extent possible. Design considerations could include establishing open landscaping and deciduous trees along important view corridors. LRDP Mitigation 4.1-2(a) New structures, roads, and landscaping at UC Davis shall be designed to be compatible with those visual elements and policies identified in the 2003 LRDP. LRDP Mitigation 4.1-2(b) Prior to design approval of development projects under the 2003 LRDP, the Campus Design Review Committee must determine that project designs are consistent with the valued elements of the visual landscape identified in the 2003 LRDP, applicable planning guidelines, and/or the character of surrounding development so that the visual character and quality of the project area are not substantially degraded. LRDP Mitigation 4.1-3(a) Design for specific projects shall provide for the use of textured nonreflective exterior surfaces and nonreflective glass. LRDP Mitigation 4.1-3(b) Except as provided in LRDP Mitigation 4.1-3(c), all new outdoor lighting shall utilize directional lighting methods with shielded and cutoff type light fixtures to minimize glare and upward directed lighting. LRDP Mitigation 4.1-3(c) Non-cutoff, non-shielded lighting fixtures used to enhance nighttime views of walking paths, specific landscape features, or specific architectural features shall be reviewed by the Campus Design Review Committee prior to installation to ensure that: (1) the minimum amount of required lighting is proposed to achieve the desired nighttime emphasis, and (2) the proposed illumination creates no adverse effect on nighttime views. a. Scenic Vistas In accordance with LRDP Mitigation 4.1-1, the Campus Design Review Committee considered scenic views as part of planning the WVIP and in the review of the LRCC Davis Center. The LRCC Davis Center would support the planning approach of preserving, where possible, a view corridor along the northern boundary of the West Village development. WVIP would have a significant impact on scenic vistas. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential aesthetic impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of aesthetic impacts. Further, the mitigation measures prescribed in the 2003 LRDP EIR would minimize this impact to the greatest extent feasible (LRDP Mitigation 4.1-1). No additional mitigation measures or project revisions have been identified that would further lessen the previously identified impact. Therefore, the 2003 LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to address this issue adequately and this impact remains significant after mitigation.

6 Page 6 b. Visual Character and Quality In accordance with LRDP Mitigation (a,b), the Campus Design Review Committee considered the project design and compatibility issues with valued campus elements and the development plan for West Village in the review of the LRCC Davis Center. The LRCC Davis Center would support the planning guidelines for West Village. WVIP could have a potentially significant impact on visual character and quality, but that with implementation of LRDP Mitigation 4.1-2(a-b), the impact would be reduced to a less than significant level. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential aesthetic impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of visual character and quality impacts. The Project incorporates LRDP Mitigation (a,b), ensuring that it will result in a less than significant impact to visual quality and character. No additional environmental analysis or mitigation measures are required. c. Light and Glare. In accordance with LRDP Mitigation (a,b,c), the LRCC Davis Center will is designed with textured nonreflective exterior surfaces and nonreflective glass and will outdoor lighting will be designed to minimize light and glare impacts. The 2003 LRDP EIR and Addendum #1 concluded that the potential significant light and glare impacts associated with implementation of the LRDP, NMP and WVIP would be reduced to a less than significant level after implementation of LRDP Mitigation 4.1-3(a-c). The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential light and glare impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter these conclusions. The Project incorporates LRDP Mitigation (a,b,c), ensuring that it will result in a less than significant impact from light and glare. No additional environmental analysis or mitigation measures are required. 2. Agricultural Resources The 2003 LRDP EIR concluded that implementation of the 2003 LRDP and NMP would not conflict with Williamson Act contracts or existing zoning for agricultural uses because the University is not subject to local land use zoning and is a tax-exempt entity. Further, implementation of the 2003 LRDP and NMP were determined to have no impact on the potential for conversion of off-campus land to urban uses. The Regents subsequently approved the WVIP in November 2006 based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and NMP and therefore will also not conflict with agricultural uses under the Williamson Act and would have no impact on the potential to convert off-campus agricultural lands to urban uses. The Project is consistent with the LRDP, NMP and WVIP and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis. No additional environmental analysis or mitigation measures are required to address agricultural resources.

7 Page 7 The 2003 LRDP EIR identified the following mitigation measures to address potential aesthetic impacts associated with implementation of the 2003 LRDP, which are hereby incorporated into the Project: LRDP Mitigation Prior to conversion of prime farmland to nonagricultural uses under the 2003 LRDP, the campus shall preserve approximately 525 acres of prime farmland at Russell Ranch, within the area designated for Teaching and Research Fields, or the Kidwell and McConeghy parcels for agricultural purposes (including agricultural teaching and research). The campus will preserve prime farmland at a one-to-one (1:1) mitigation ratio for prime farmland converted to developed uses and a one-third to one (1/3:1) ratio for prime farmland converted to habitat at Russell Ranch. a. Prime Farmland In accordance with LRDP Mitigation 4.2-1, the campus continues to implement the prime farmland mitigation program and will conduct the identified land preservation ratio for the LRCC Davis Center. The 2003 LRDP EIR and Addendum #1 concluded that even with implementation of LRDP Mitigation 4.2-1, development consistent with the LRDP, NMP and WVIP would result in a significant impact on prime farmland. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential agricultural resources impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of agricultural resources impacts. Further, the mitigation measures prescribed in the 2003 LRDP EIR would minimize this impact to the greatest extent feasible (LRDP Mitigation 4.2-1). No additional mitigation measures or project revisions have been identified that would further lessen the previously identified impact. Therefore, the 2003 LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to address this issue adequately and this impact remains significant after mitigation. 3. Air Quality The 2003 LRDP EIR concluded that implementation of the 2003 LRDP and NMP would result in a less than significant impact associated with objectionable odors and that no mitigation was required(lrdp Impact 4.3-4). The 2003 LRDP EIR further concluded that the direct and cumulative impacts of development consistent with the LRDP and NMP on localized CO (LRDP Impact 4.3-1) and toxic air contaminants (TACs) (LRDP Impact 4.3-5) would be less than significant and that no mitigation was required. The Regents subsequently approved the WVIP in November 2006 based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and NMP. The Project is consistent with the LRDP, NMP and WVIP and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis. The Project involves the construction of an academic building which will not create objectionable odors or TACs, or contribute substantially to CO concentrations. No additional environmental analysis or mitigation measures are required.

8 Page 8 LRDP Mitigation 4.3-1(a) Vehicular Sources. The following measures will be implemented to reduce emissions from vehicles, as feasible. The campus shall continue to actively pursue Transportation Demand Management to reduce reliance on private automobiles for travel to and from the campus. Provide pedestrian-enhancing infrastructure to encourage pedestrian activity and discourage vehicle use. Provide bicycle facilities to encourage bicycle use instead of driving. Provide transit-enhancing infrastructure to promote the use of public transportation. Provide facilities to accommodate alternative-fuel vehicles such as electric cars and CNG vehicles. Improve traffic flows and congestion by timing of traffic signals to facilitate uninterrupted travel. When the campus purchases new vehicles, the campus will evaluate the practicality and feasibility of acquiring low-pollution vehicles that are appropriate for the task and will purchase these types of vehicles when practical and feasible. When replacing diesel engines in existing equipment, the campus will install upto-date technology. LRDP Mitigation 4.3-1(b) Area Sources. The following measures will be implemented to reduce emissions from area sources, as feasible. Use solar or low-emission water heaters in new or renovated buildings. Orient buildings to take advantage of solar heating and natural cooling and use passive solar designs. Increase wall and attic insulation in new or renovated buildings. For fireplaces or wood-burning appliances, require low-emitting EPA certified wood-burning appliances, or residential natural-gas fireplaces. Provide electric equipment for landscape maintenance. LRDP Mitigation 4.3-3(a) The campus shall include in all construction contracts the measures specified below to reduce fugitive dust impacts, including but not limited to the following: All disturbed areas, including storage piles, which are not being actively utilized for construction purpose, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, or vegetative ground cover. All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking. When demolishing buildings up to six stories in height, all exterior surfaces of the building shall be wetted during demolition. When materials are transported off-site, all material shall be covered, effectively wetted to limit visible dust emissions, or at least two feet of freeboard space from the top of the container shall be maintained.

9 Page 9 All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at least once every 24 hours when operations are occurring. The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices also is expressly forbidden. Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions by utilizing sufficient water or chemical stabilizer/suppressant. LRDP Mitigation 4.3-3(b) The campus shall include in construction contracts for large construction projects near receptors, the following control measures: Limit traffic speeds on unpaved roads to 15 mph. Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent. To the extent feasible, limit area subject to excavation, grading, and other construction activity at any one time. LRDP Mitigation 4.3-3(c) The campus shall implement the following control measures to reduce emissions of ozone precursors from construction equipment exhaust: To the extent that equipment is available and cost effective, the campus shall encourage contractors to use alternate fuels and retrofit existing engines in construction equipment. Minimize idling time to a maximum of 5 minutes when construction equipment is not in use. To the extent practicable, manage operation of heavy-duty equipment to reduce emissions. To the extent practicable, employ construction management techniques such as timing construction to occur outside the ozone season of May through October, or scheduling equipment use to limit unnecessary concurrent operation. a. Increased Air Pollutant Emissions In accordance with LRDP Mitigation (a,b) the LRCC Davis Center project will implement the vehicular sources and area source air emission mitigations to minimize air pollutant emissions from the project. The project size, location, and development characteristics are unchanged from the prior approval described in the WVIP. The vehicle trips and operational components remain within the level of analysis conducted for the LRDP EIR. WVIP would have a significant impact on air emissions. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential air quality impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of air quality impacts. Further, the mitigation measures prescribed in the 2003 LRDP EIR would minimize this impact to the greatest extent feasible (LRDP Mitigation 4.3-1(a,b)). No additional mitigation measures or project revisions have been identified that would further lessen the

10 Page 10 previously identified impact. Therefore, the 2003 LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to address this issue adequately and this impact remains significant after mitigation. b. Increased Construction Emissions In accordance with LRDP Mitigation (a-c) the LRCC Davis Center project would include the construction air quality mitigation measures to minimize construction related air emissions. The project size and characteristics are unchanged from the LRDP EIR and the LRDP EIR air quality assessment included the project as portion of the air quality emission forecast for the West Village development WVIP would have a significant impact on air quality. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential air quality impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of air quality impacts. Further, the mitigation measures prescribed in the 2003 LRDP EIR would minimize this impact to the greatest extent feasible (LRDP Mitigation (a-c)). No additional mitigation measures or project revisions have been identified that would further lessen the previously identified impact. Therefore, the 2003 LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to address this issue adequately and this impact remains significant after mitigation. c. Contribution to Global Climate Change Project activities will result in greenhouse gas emissions from construction equipment and longterm operation of the project. Although the development proposal would result in buildings that meet or exceed California s Title 24 energy efficiency requirements and this effort would help to minimize operational emissions from the buildings, the project would contribute to greenhouse gas emissions that are producing global climate change. In 2006, after certification of the 2003 LRDP EIR, California passed Assembly Bill 32 (AB 32), which requires CARB to design and implement emission limits, regulations, and other measures, such that feasible and cost-effective statewide greenhouse gas emissions are reduced to 1990 levels by 2020 (representing an approximate 25 percent reduction in emissions). The principal greenhouse gases of concern are carbon dioxide (CO 2 ), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), perfluorocarbons (PFCs), hydrofluorocarbons (HFCs), and water vapor (H2O). CO 2 is the reference gas for climate change because it is the predominant greenhouse gas emitted. As of the date of this analysis, neither SCAQMD, CARB nor any federal agency has implemented an emissions threshold for the purposes of identifying a significant contribution to global climate change. Nor are there rules or regulations in place from CARB, SCAQMD, Governor s Office of Planning and Research (OPR) or other resource agency applicable to the proposed project that define what is a significant source of greenhouse gas emissions, and there are no applicable facility-specific greenhouse gas emission limits or caps.

11 Page 11 Pursuant to Senate Bill 97, the OPR is in the process of developing CEQA Guidelines for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions. OPR is required to prepare, develop, and transmit the guidelines to the Resources Agency on or before July 1, The Resources Agency must certify and adopt the guidelines on or before January 1, In compliance with the UC Policy on Sustainable Practices, UC Davis is currently developing a Climate Action Plan to reduce greenhouse gas emission to support the goals of AB 32. In the interim, the California Air Pollution Control Officers Association (CAPCOA) has prepared a white paper that considers options for evaluating and addressing greenhouse has emissions under CEQA. CARB staff has provided an early action list, which includes 44 greenhouse gas reduction measures. The 44 recommended early actions have the potential to reduce greenhouse gas emissions by about 25 percent of the estimated reductions needed by These strategies are almost entirely targeted at emissions from fuel production and storage, transportation of goods (via haul trucks and ports), cement plants, and energy facilities. In lieu of any official regulatory directive or precedent for identifying significant greenhouse gas emissions, a project could be deemed to have a significant air quality impact if it would conflict with the 44 greenhouse gas reduction measures, set forth by the timetable established in AB 32. If a project complies with the state s strategies to reduce greenhouse gasses to the level proposed by the governor, it follows that the project would have a less-than-significant cumulative impact to global climate change. If a project does not or cannot comply with reduction strategies, the applicant can alternatively reduce its cumulative contribution to greenhouse gas emissions to less-than-significant levels by contributing to available regional, state, national, or international mitigation programs, such as reforestation, tree planting, or carbon trading. In considering applicable directives to reduce greenhouse gas emissions, three types of analyses are used to determining whether the proposed project could be in conflict with the state goals for reducing greenhouse gas emissions. The analysis includes a review of: A. The potential conflicts with the CARB 44 early action strategies (CARB, 2007b); B. The relative size of the project in comparison to the estimated greenhouse reduction goal of 174 MMT eco 2 by 2020 and in comparison to the size of major facilities that are required to report greenhouse gas emissions (25,000 metric tons of e CO 2 /yr), (CAPCOA Significance Threshold 2.3); and C. The basic parameters of a project to determine whether its design is inherently energy efficient. With regard to item A, the proposed project does not pose any apparent conflict with the most recent list of CARB s 44 early action strategies. As previously noted, these strategies are almost entirely targeted at emissions from fuel production and storage, transportation of goods (via haul trucks and ports), cement plants, and energy facilities. The strategies that do address light-duty motor vehicles are directed toward regulatory agencies and not land use development.

12 Page 12 With regard to item B, CO 2 emissions from construction and operation have not been quantified as this process of emission quantification is being developed concurrently with the UC Davis Climate Action Plan. The magnitude of the proposed project in relation to the overall operations at UC Davis is fairly small and is not anticipated to disrupt future emission reduction programs. The project helps to provide a local option within Davis for students seeking coursework credit from the Los Rios Community College District and is expected to minimize vehicle trips by employees and students who would otherwise travel outside of Davis for such courses. The project will be served by energy efficient building design and will be designed to achieve a LEED Silver designation. Hence, this impact is considered less than significant. Additionally, consistent with item C above, the new construction would also be required to meet California Energy Efficiency Standards in the state Building Code, helping to reduce future energy demand as well as reduce the project s contribution to regional greenhouse gas emissions. As a result, the proposed project would have a less than significant impact on greenhouse gas emissions 4. Biological Resources The 2003 LRDP concluded that implementation of the 2003 LRDP and NMP would not conflict with an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) because the campus does not fall within the boundaries or nor is it adjacent to an adopted regional HCP or NCCP (LRDP EIR, Vol. 1, Section ). The 2003 LRDP EIR further concluded that implementation of the NMP would not impact special status plants (LRDP EIR, Vol. 3, section ), impact important/specimen trees (NMP Impact ) because the NMP site has been surveyed and no such plants were identified and no trees are present. The 2003 LRDP EIR further concluded that construction of new or enlarged storm drain outfalls in the NMP project area in or along Putah Creek and/or the Arboretum) could potentially impact the northwestern pond turtle, wetlands and/or waters of the United States, and special status fish species, but that implementation of specified mitigation measures would reduce these potential impacts to less than significant levels (NMP Impacts , , and , respectively). Implementation of the storm drain improvements were approved as part of the WVIP, based on the LRDP EIR and Addendum #1 thereto, and are not part of the proposed Project. The location of the Project -- identified in the WVIP but for which design approval was not granted at the time the WVIP was approved -- has not changed. The Project site remains in a disturbed agricultural field more than 1/2-mile from Putah Creek and the Arboretum. Accordingly, the Project will result in no impacts to the northwestern pond turtle, wetlands and/or waters of the United States, and special status fish species, no further environmental analysis necessary and no mitigation is required. Similarly, the 2003 LRDP EIR concluded that development consistent with the NMP could result in impacts to nesting efforts by Swainson s hawk or other birds of prey, and VELB habitat, but that implementation of specified mitigation measures would reduce the potential impacts to less than significant levels (NMP Impacts and 2.4-9). The mitigation measures require preconstruction surveys of trees greater than 30 feet in height within one-half of a mile from the project site and for elderberry shrubs and habitat along Hopkins Road near Putah Creek, in the area of the North Fork Cutoff, and near the Arboretum. The location of the Project is in a tree-

13 Page 13 less, disturbed agricultural field and is not in or near Putah Creek, the North Fork Cutoff or the Arboretum. Accordingly, the Project will result in no impact to nesting efforts by Swainson s hawks or other raptors, and will not impact VELB habitat. No further environmental analysis necessary and no mitigation is required. The 2003 LRDP EIR identified the following mitigation measures to address potential biological impacts associated with implementation of the 2003 LRDP and NMP, which are hereby incorporated into the Project: LRDP Mitigation 4.4-3(b) The campus shall survey proposed development areas with potential habitat for the presence or absence of burrowing owls. LRDP Mitigation 4.4-3(c) The campus, in consultation with the CDFG, shall conduct a preconstruction survey of proposed project sites during the breeding season (from approximately February 1 through August 31) during the same calendar year that construction is planned to begin. The survey shall be conducted by a qualified biologist to determine if any burrowing owls are nesting on or directly adjacent to any proposed project site. If phased construction procedures are planned for the proposed project, the results of the above survey shall be valid only for the season when it is conducted. If the pre-construction breeding season survey does not identify any nesting raptor species on the project site, then no further mitigation would be required. However, should any burrowing owls be found nesting on the project site, then LRDP Mitigation 4.4-3(d) shall be implemented. LRDP Mitigation 4.4-3(d) During the breeding season, the campus, in consultation with the CDFG, shall not disturb an occupied burrowing owl burrow while there is an active nest and/or juvenile owls are present. Avoidance shall include the establishment of a non-disturbance buffer zone around the nest site consistent with CDFG guidelines. The buffer zone shall be delineated by highly visible temporary construction fencing. The occupied nest site shall be monitored by a qualified biologist to determine when the juvenile owl is fledged and independent. Disturbance of an occupied burrow shall only occur outside of the breeding season and when there is no nest or juvenile owl based on monitoring by a CDFG-approved biologist. Based on approval by CDFG, pre-construction and pre-breeding season exclusion measures may be implemented to preclude burrowing owl occupation of the project site prior to project-related disturbance. These include the following measures: Obviously inactive burrows in the project area will be closed. Active or potentially active ground squirrel burrows will be monitored to confirm use by ground squirrels and not by burrowing owls before ground squirrels are removed and the burrow is closed. One-way doors will be used on active burrows if use by ground squirrels cannot be confirmed. The owls will be displaced from the occupied burrows according to the CDFG burrowing owl guidelines. The owls will be displaced from their burrows by installing one-way exit doors in occupied or potential burrows within the area of disturbance. After 48 hours with the doors in place, the burrows will then be closed to prevent reoccupation by owls.

14 Page 14 LRDP Mitigation 4.4-4(a) The campus shall conduct a pre-construction survey of trees on and adjacent to a project site during the raptor breeding season (approximately March 1 to August 31). Additionally, the campus shall conduct surveys within a ½-mile radius of the site to determine the presence or absence of any nesting Swainson s hawks. The surveys shall be conducted by a qualified biologist during the same calendar year that the proposed activity is planned to begin to determine if any nesting birds-of-prey would be affected. If phased construction procedures are planned for the proposed activity, the results of the above survey shall be valid only for the season when it is conducted. If any Swainson s hawks are nesting within a one-half-mile radius of the project site or if other raptors are nesting in, on or adjacent to the project site, a qualified biologist shall determine the potential for disturbance to nesting raptors, including Swainson s hawks. If the biologist determines that there is a significant potential for disturbance, the campus shall implement feasible changes in the construction schedule or make other appropriate adjustments to the project in response to the specific circumstances. If feasible project changes are not readily identifiable, the campus will consult with CDFG to determine what actions should be taken to protect the nesting efforts. If after five years, a previously recorded nest site remains unoccupied by a Swainson s hawk, it will no longer be considered as a Swainson s hawk nest site subject to this mitigation. LRDP Mitigation 4.4-6(a) During the project design stage and as a condition of project approval, the campus shall: Conduct a project-specific survey for all potential VELB habitat, including a stem count and an assessment of historic or current VELB use; and Avoid and protect all potential VELB habitat within a natural open space area where feasible. LRDP Mitigation 4.4-6(b) For those areas where avoidance is infeasible, the Russell Ranch Mitigation Area shall include approximately 20 acres within and adjacent to the riparian corridor of Putah Creek and within and adjacent to the existing drainage in the northeast corner of the site that will be used as a receptor site for transplanted elderberry shrubs and the associated elderberry seedlings and other native pant seedlings required to be planted in accordance with the USFWS VELB Mitigation Guidelines (USFWS 1996). The site is estimated to support between 100 and 500 transplanted elderberry shrubs, depending on the size and number of stems on the shrubs at the time they are transplanted. a. Foraging Habitat The 2003 LRDP EIR concluded development consistent with the 2003 LRDP to result in the loss of general wildlife habitat (approximately 550 acres of Agricultural Land and Ruderal/Annual Grassland habitat) for resident and migratory species, including the Swainson s hawk (LRDP Impact 4.4-2). The 2003 LRDP EIR further concluded that implementation of the NMP would impact 225 acres of agricultural land and that with implementation of LRDP Mitigation Measure requiring the campus to create the Russell Ranch Habitat Mitigation Area -- the impact is reduced to a less than significant level (LRDP EIR, Vol. 3, Section ). The Regents

15 Page 15 subsequently approved the WVIP based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and therefore will also have a less than significant impact on wildlife habitat with implementation of LRDP Mitigation Measure The Project is consistent with the WVIP, and is located on a portion of the 225 acres of Agricultural Land and Ruderal/Annual Grassland habitat identified in the LRDP EIR. As required by LRDP Mitigation Measure 4.4-1, the campus established the Russell Ranch Habitat Mitigation Area in 2004, thereby mitigating the Project contribution to this impact to a less than significant level. No changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis. Accordingly, the Project would have a less than significant impact to foraging habitat and no additional environmental analysis or mitigation measures are required. b. Burrowing Owl Habitat In accordance with LRDP Mitigation 4.4-3(a), the campus has provided for at least 65 acres of grassland habitat suitable for use by burrowing owls at the Russell Ranch Mitigation Area established pursuant to LRDP Mitigation and described in section b, above. Further, consistent with LRDP Mitigation 4.4-3(b) the campus has previously surveyed the Project area approximately every three weeks since 2004, which indicated that the site is not used by burrowing owls. A component of the Project is compliance with LRDP Mitigations 4.4-3(c,d), such that if Project construction commences during breading season (February 1 through August 31) a pre-construction survey of the Project site will be conducted by a qualified biologist to determine if any burrowing owls are nesting in the area. If nesting owls are identified, the LRDP Mitigation Measure 4.4-3(d) will be implemented. The 2003 LRDP EIR and Addendum #1 concluded that with implementation of LRDP Mitigation 4.4-3(b-d), the impact of development consistent with the LRDP, NMP and WVIP would be less than significant. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential burrowing owl impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the analysis of burrowing owl impacts. Further, the Project s incorporation of mitigation measures prescribed in the 2003 LRDP EIR ensures any potential impact remains less than significant (LRDP Mitigation (b,c,d). Accordingly, no additional environmental analysis or mitigation measures are required. 5. Cultural Resources The 2003 LRDP EIR Initial Study concluded there are no unique paleontological resources or unique geologic features on campus and that the NMP has no potential to impact historic resources because the project site contains no structures and no remains of structures. The Regents subsequently approved the WVIP in November 2006 based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and NMP and therefore will also not affect paleontological, unique geologic features, or historic resources. The Project is consistent with the LRDP, NMP and WVIP and no changed circumstance or new information is present that would alter the conclusions of the 2003

16 Page 16 LRDP EIR analysis. No additional environmental analysis or mitigation measures are required to address paleontological, unique geologic features, or historic resource impacts. The 2003 LRDP EIR identified the following mitigation measures to address potential cultural resources impacts associated with implementation of the 2003 LRDP, which are hereby incorporated into the Project: LRDP Mitigation 4.5-1(a): As early as possible in the project planning process, the campus shall define the project s area of potential effects (APE) for archaeological resources and, if structures are present on the site, for historic structures. The campus shall determine the potential for the project to result in cultural resource impacts, based on the extent of ground disturbance and site modification anticipated for the proposed project. Based on this information, the campus shall: (i) Prepare an inventory of all buildings and structures within the APE that will be 50 years of age or older at the time of project construction for review by a qualified architectural historian. If no structures are present on the site, there would be no impact to historic built environment resources from the project. If potentially historic structures are present, LRDP Mitigation 4.5-1(c) shall be implemented. (ii) Determine the level of archaeological investigation that is appropriate for the project site and activity, as follows: Minimum: excavation less than 18 inches deep and in a relatively small area (e.g., a trench for lawn irrigation, tree planting, etc.). Implement LRDP Mitigation 4.5-1(b)(i). Moderate: excavation below 18 inches deep and/or over a large area on any site that has not been characterized and is not suspected to be a likely location for archaeological resources. Implement LRDP Mitigation (b)(i) and (ii). Intensive: excavation below 18 inches and/or over a large area on any site that is within 800 feet of the historic alignment of Putah Creek, or that is adjacent to a recorded archaeological site. Implement LRDP Mitigation (i), (ii) and (iii). LRDP Mitigation 4.5-1(b) During the planning phase of the project, the campus shall implement the following steps to identify and protect archaeological resources that may be present in the APE: (i) For project sites at all levels of investigation, contractor crews shall be required to attend an informal training session prior to the start of earth moving, regarding how to recognize archaeological sites and artifacts. In addition, campus employees whose work routinely involves disturbing the soil shall be informed how to recognize evidence of potential archaeological sites and artifacts. Prior to disturbing the soil, contractors shall be notified that they are required to watch for potential archaeological sites and artifacts and to notify the campus if any are found. In the event of a find, the campus shall implement item (vi), below. (ii) For project sites requiring a moderate or intensive level of investigation, a surface survey shall be conducted by a qualified archaeologist during project planning

17 Page 17 (iii) and design and prior to soil disturbing activities. For sites requiring moderate investigation, in the event of a surface find, intensive investigation will be implemented, as per item (iii), below. Irrespective of findings, the qualified archaeologist shall, in consultation with the campus, develop an archaeological monitoring plan to be implemented during the construction phase of the project. The frequency and duration of monitoring shall be adjusted in accordance with survey results, the nature of construction activities, and results during the monitoring period. In the event of a discovery, the campus shall implement item (vi), below. If a resource is discovered during construction (whether or not an archaeologist is present), all soil disturbing work within 100 feet of the find shall cease. The campus shall contact a qualified archaeologist to provide and implement a plan for survey, subsurface investigation as needed to define the deposit, and assessment of the remainder of the site within the project area to determine whether the resource is significant and would be affected by the project. LRDP Mitigation 4.5-1(b), steps (iii) through (vii) shall be implemented. LRDP Mitigation 4.5-2(a) For an archaeological site that has been determined by a qualified archaeologist to qualify as an historical resource or a unique archaeological resource through the process set forth under LRDP Mitigation 4.5-1(b), and where it has been determined under LRDP Mitigation 4.5-1(b) that avoidance or preservation in place is not feasible, a qualified archaeologist, in consultation with the campus, shall: (i) (ii) (iii) Prepare a research design and archaeological data recovery plan for the recovery that will capture those categories of data for which the site is significant, and implement the data recovery plan prior to or during development of the site. Perform appropriate technical analyses, prepare a full written report and file it with the appropriate information center, and provide for the permanent curation of recovered materials. If, in the opinion of the qualified archaeologist and in light of the data available, the significance of the site is such that data recovery cannot capture the values that qualify the site for inclusion on the CRHR, the campus shall reconsider project plans in light of the high value of the resource, and implement more substantial modifications to the proposed project that would allow the site to be preserved intact, such as project redesign, placement of fill, or project relocation or abandonment. If no such measures are feasible, the campus shall implement LRDP Mitigation LRDP Mitigation 4.5-4(a) Implement LRDP Mitigation 4.5-1, and to minimize the potential for disturbance or destruction of human remains in an archaeological context and to preserve them in place, if feasible. LRDP Mitigation 4.5-4(b) Provide a representative of the local Native American community an opportunity to monitor any excavation (including archaeological excavation) within the boundaries of a known Native American archaeological site.

18 Page 18 LRDP Mitigation 4.5-4(c) In the event of a discovery on campus of human bone, suspected human bone, or a burial, all excavation in the vicinity will halt immediately and the area of the find will be protected until a qualified archaeologist determines whether the bone is human. If the qualified archaeologist determines the bone is human, or if a qualified archaeologist is not present, the campus will notify the Yolo or Solano County Coroner (depending on the county of the find) of the find before additional disturbance occurs. Consistent with California Health and Safety Code (b), which prohibits disturbance of human remains uncovered by excavation until the Coroner has made a finding relative to PRC 5097 procedures, the campus will ensure the remains and vicinity of the find are protected against further disturbance. If it is determined that the find is of Native American origin, the campus will comply with the provisions of PRC regarding identification and involvement of the Native American Most Likely Descendant (MLD). LRDP Mitigation 4.5-4(d) If human remains cannot be left in place, the campus shall ensure that the qualified archaeologist and the MLD are provided opportunity to confer on archaeological treatment of human remains, and that appropriate studies, as identified through this consultation, are carried out prior to reinterment. The campus shall provide results of all such studies to the local Native American community, and shall provide an opportunity of local Native American involvement in any interpretative reporting. As stipulated by the provisions of the California Native American Graves Protection and Repatriation Act, the campus shall ensure that human remains and associated artifacts recovered from campus projects on state lands are repatriated to the appropriate local tribal group if requested. a. Effects on Cultural Resources The project-level evaluation contained in Volume II of the 2003 LRDP EIR identified no impacts to historical resources or unique geological features that could support paleontological resources from implementation of the WVIP. Although no archaeological resources were encountered during a survey of the site, the 2003 LRDP EIR found that extensive excavation associated with the WVIP including some off-site utilities could potentially uncover archaeological resources or human remains. In accordance with LRDP Mitigations (a,b), (a), and (a-d) the LRCC Davis Center project includes requirements to minimize any effects on resources that could be revealed during project construction. The project remains in the same location and consists of the same components as described in the 2003 LRDP and Addendum #1. WVIP could have a potentially significant impact on cultural resources. The Project is consistent with the LRDP, NMP and WVIP, would not introduce any new potential cultural resources impacts not already assessed in the 2003 LRDP FEIR and Addendum #1, and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of cultural resources impacts. Further, the mitigation measures prescribed in the 2003 LRDP EIR would minimize this impact to the greatest extent feasible (LRDP Mitigation (a,b), (a), and (a-d)). No additional mitigation measures or project revisions have been identified that would further lessen the previously identified impact. Therefore, the

19 Page LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to address this issue adequately and this impact would be reduced to a less-than-significant level after mitigation. 6. Geology, Soils, and Seismicity All WVIP impacts associated with geology, soils, and seismicity were adequately addressed in the Final EIR and there are no geology and soils mitigation measures required for the LRCC Davis Center project. The LRDP Initial Study concluded that there are no known earthquake faults on the west campus and thus the project would not expose people or structures to the impacts of rupture of earthquake faults. The Initial Study also concluded that the campus would not be subject to landslides due to the level topography, and that development under the 2003 LRDP would not have an impact on mineral resources. Therefore, the LRDP concluded that no project-level analysis of these issues was required. The project would not include septic tanks or alternative wastewater disposal systems; therefore, impact related to construction of these systems are not applicable to the project. The proposed project would involve extensive grading, and most utilities would be buried. Because most of the structures in the proposed NMP development would be relatively low (generally four stories or fewer) and the types of soils on the campus, deep pilings would likely not be necessary for the project. Furthermore, as specific phases of the NMP are proposed, a geotechnical investigation of the site would be conducted which would provide specific recommendations regarding foundations types and other considerations for the final design of each project, in compliance with the California Building Code (CBC). Therefore, although development of buildings in the NMP could expose people or structures to the effects of seismic ground shaking, and secondary seismic effects, such potential impacts are addressed at the LRDP level (LRDP Impact 4.6-1) and mitigated to less-than-significant levels by state and campus safety programs already in place. The campus also adheres to the University of California Seismic Safety Policy, and the campus Standards and Design Guide, which requires seismic safety measures. Procedures mandated by the campus Office of Environmental Health and Safety and departmental emergency response plans further reduce the hazards from seismic shaking. Section 4.6 (LRDP EIR Volume I) concluded that potential impacts related to unstable and expansive soils were less than significant and did not require mitigation, because of building codes, regulations and best management practices (BMPs) already in place (LRDP Impacts and 4.6-3). Compliance with existing procedures and regulations will ensure that impact potential is less than significant. No project-specific mitigation is required. The Project is consistent with the LRDP, NMP and WVIP, and would not introduce any new potential geology and soils impacts not already assessed in the 2003 LRDP FEIR. No changed circumstances or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis of geology and soils impacts. Therefore, the 2003 LRDP EIR and Addendum #1 analysis is sufficient and comprehensive to adequately address this issue.

20 Page Hazards and Hazardous Materials The 2003 LRDP EIR evaluated impacts related to wildland fires on campus and safety hazards associated with a private airstrip concluded that these impacts were less than significant for the project, including the NMP. The NMP does not include any listed hazardous materials sites. The implementation of the NMP would not require building demolition or renovation, so the project does not hold the potential to expose construction workers or campus occupants to contaminated building materials. No impacts would occur in these areas. The Regents subsequently approved the WVIP in November 2006 based on the 2003 LRDP EIR and Addendum #1 thereto, and concluded that the WVIP is consistent with and within the scope of the 2003 LRDP and NMP and therefore will also not contribute to wildland fire risk, private airstrip safety concerns, listed hazardous materials site impacts, and building demolition impacts related to worker safety. The Project is consistent with the LRDP, NMP and WVIP and no changed circumstance or new information is present that would alter the conclusions of the 2003 LRDP EIR analysis. No additional environmental analysis or mitigation measures are required to address widland fire risk, private airstrip safety concerns, listed hazardous materials site impacts, and building demolition impacts related to worker safety impacts. The 2003 LRDP EIR identified the following mitigation measures to address potential hazards/hazardous materials impacts associated with implementation of the 2003 LRDP and NMP, which are hereby incorporated into the Project: LRDP Mitigation For projects proposed by non-uc entities on campus that involve laboratory space, non-uc entities shall be required, through contracts and agreements, to implement programs and controls that provide the same level of protection required of campus laboratories and departments. The following project-specific mitigation measures would be implemented for non-ucd tenants: (i) (ii) (iii) Non-UC entities shall submit the qualifications of designated laboratory directors to UC Davis EH&S Office prior to commencing laboratory operations. Such documentation shall be in the form of educational and professional qualifications/experience. Non-UC entities shall submit certification of compliance with NIH biosafety principles to the UC Davis EH&S Office prior to commencing on-site research or pilot plant manufacturing activities. Non-UC entities shall submit copies of completed medical waste management plans, biosafety management plans, inventories of infectious or genetically modified agents, applicable permits and updates. If hazardous material quantities are proposed to be increased above applicable threshold quantities as defined in California Code of Regulations, Title 19, Division 2, Chapter 4.5, non-uc entities shall implement a Risk Management Plan/California Accidental Release Prevention Plan (RMP/Cal-ARP), which discusses the handling and storage of acutely hazardous materials on site. The