UC-Davis Hotel Expansion: Hotel Owners' Complaint

Final EIR Responses to Comments Comment Letter from William Kopper

HOTEL EXPANSION AND ROAD EXTENSION

Comment Responses

Comment Letter from William Kopper

Comment

Number

Response

D-1 The definition of blight in the state Community Redevelopment Law, Health and Safety Code section 33000 et seq., is broader than CEQA‟s requirement to focus on physical changes. In contrast to CEQA, “blight” is expressly defined under the Community Redevelopment Law to include economic blight as well as conditions, such as multiple owners and irregular lot lines, that present obstacles to economically viable reuse of land. (Health & Safety Code § 33031(a) and (b).) Therefore, the City of Davis Redevelopment Agency‟s determination that parts of the city are blighted is not directly relevant to analysis of blight/urban decay impacts under CEQA. See Master Responses 2, 5 and 7.

D-2 See Master Responses 1, 2, 4 and 7. The HVS Impact Study completed by HVS consulting was prepared to evaluate the potential economic effects on the Davis hotel market. The baseline for the project is the time of the publication for the NOP pursuant to CEQA Guidelines Section 15125(a).

D-3 The HVS Study evaluated market conditions, and the DEIR relied on the HVS Study to evaluate potential impacts on the Davis Market. (DEIR, pp. 34-35 (Impacts AES-1 and AES-2). See Master Response 8.

D-4 See Master Responses 1, 2, 4, and 7. The project impact analysis concluded that the project would not contribute to blight/urban decay based on an analysis of the potentially affected hotel market in Davis. An inventory of existing vacant commercial buildings in South Davis is not relevant to the analysis of the impacts of the economic effects of the proposed project. See Response to Comment D-6.

D-5 See Master Responses 4 and 7. D-6 The HVS Study provides an analysis of Davis hotels and concludes that the project could

result in a net benefit to the area. See Master Response 7. Occupancy rates in Davis had decreased in prior years but have now apparently stabilized and begun to increase even with the 2010 opening of the Hyatt Place Hotel. The HVS report predicts that occupancy rates will continue to increase (HVS 2001a, page 45). The HVS report conducted a site evaluation of existing hotels and did not observe signs of urban decay. All hotels were observed to be in acceptable operating condition for the particular market level of each property. Section 4 of the HVS Study contains the Market Area Analysis (HVS 2011a, page 23).

D-7 See Master Response 2. Based on HVS‟ extensive hotel consulting experience, as with airlines, it is generally understood in the industry that hotels having strong national brands have a loyal client base. These guests often seek out affiliated hotels of a specific hotel chain, even if these properties may not be conveniently located with respect to their destination, in order to



accumulate points through the company‟s frequent stay programs, and guests capitalize on the guest loyalty and recognition afforded by these companies to their loyal guests through added amenities and services including complimentary guestroom upgrades and food and beverage vouchers. The STR data pertaining to the Davis market exhibits a decrease in occupied room nights between 2003 and 2007, which may be attributable to a number of events and conditions, including the aging lodging supply in the Davis market, and the opening of newer lodging properties that are affiliated with strong national hotel brands in the proximate cities of Woodland and West Sacramento. Examples of newer hotels that are affiliated with strong national brands that opened in these neighboring areas include the 55-room Holiday Inn Express West Sacramento Capitol Area in November 2002, the 69-room Holiday Inn Express & Suites in September 2003, the 71-room Hampton Inn Suites Woodland Sacramento Area in May 2007, and the 110-room Hampton Inn & Suites West Sacramento in February 2009. While this data is interesting to review, and provides historical context to peak levels of demand for the Davis hotels, the HVS impact study specifically relates to the recent opening of the Hyatt Place UC Davis hotel, and the potential impacts to the Davis hotel market from the property‟s expansion. As previously discussed in Master Response 7, the STR data clearly support the conclusion that the opening of the Hyatt Place UC Davis Hotel has contributed to an increase in occupied room nights and overall lodging demand to the market, which indicates that prior to the opening of the Hyatt Place UC Davis, there was a demand segment that was not being met in Davis. The HVS Impact Study provides substantial background information (facts) for HVS to make reasonable conclusions about the Davis hotel market. The commenter states that the EIR should provide additional information about the hotel conditions in Sacramento and Woodland in the period of 2003 to 2007. However, arguments related to the allocation of demand segments within the Davis market and peripheral markets are secondary to the primary HVS finding that the Davis hotel market is strong and will continue to be strong with the proposed project and with cumulative conditions. No additional data from 2003 to 2007 is needed to forecast future conditions for the Davis market. From a research perspective, additional data would be interesting to help analyze local, regional, and national hotel trends and conditions during an extended time period. However, such an effort is outside the CEQA requirement and is not provided as part of this CEQA effort. See also Master Response 4.

D-8 The Davis market is the appropriate study area for the economic effects of the proposed project. See Master Response 7 and Response to Comment D-6.

D-9 Figure 6-1 in the HVS Impact Study (p. 75) shows the potential for additional hotel bookings that could result from the proposed project based on the records kept by the Hyatt Place Hotel. UC Davis is unaware of any “rule of thumb” regarding the relationship between numbers of hotel rooms and the size of conferences. Over time, the bookings for conferences are expected to increase. To the extent that the expanded Hyatt Place Hotel cannot accommodate all of the lodging demand for increased conferences, the additional demand (spillover demand) for hotel rooms is expected to be met by rooms in downtown Davis (HVS 2011a, page 75).

D-10 The information requested by the commenter has not previously been collected; therefore, it cannot be provided. The Conference Center opened in 2010, and efforts to systematically



track conference outreach is now starting. Regarding the identification of the portion of hotel visitors who are conference participants, the HVS Study identifies this group as “Meeting and Group” visitors in Figure 5-8. (HVS Study, p. 65.)

D-11 See Response D-7. D-12 The Draft EIR analyzes potential effects of the City of Davis proposed Conference Center

in Impact AES-2. (DEIR, p. 35 and HVS Study, pp. 77-80.) D-13 See Response to Comment D-12 and Master Responses 4 and 7. D-14 The commenter is probably correct in noting that a large amount of hotel demand in Davis

has a direct or partial connection to UC Davis. This observation does not change the conclusions of the EIR.

D-15 The conference center facilities are not part of the proposed project. While facilities such as those described in the comment may be beneficial to the conference center, this observation does not change the conclusions of the EIR. The environmental effects of the UC Davis Conference Facility were evaluated in the UC Davis Conference Center, Hotel, and Graduate School of Management Building EIR (SCH#2001082067), certified in March 2002.

D-16 See Responses to Comments D-9 and D-10. D-17 See Master Response #7. The study area for analyzing the effects of the project is the

Davis market. D-18 See Master Response #7 and Response to Comment D-7. D-19 See Master Response #7 and Response to Comment D-7. D-20 See Master Response #7. UC Davis does not have a policy directing visitors and travelers

to the Hyatt Place Hotel. D-21 See Figure 5-1 of the HVS Study (HVS 2011a, page 44). Page 45 of the HVS Study

concludes that the positive trends shown in Figure 5-1 are due in part to the opening of the Hyatt Place Hotel and in part to the beginning of an economic recovery. See also Master Response 7.

D-22 See Comment Response D-7. Travel times due to variable commute conditions are not relevant to the analysis.

D-23 The information requested by the commenter is not pertinent to the CEQA evaluation. See Response to Comment D-10.

D-24 The model inputs and outputs are provided in the HVS Impact Study. Page 79 (Figure 7-2) of the HVS Impact Study lists all of the projection years and provides the detailed demand estimates for the model. Figure 7-2 illustrates the simple calculations used to determine the forecast demand levels for each projection year. The combined use of Table 7-2 and the demand estimates provided on pages 62-73 of the HVS Impact Study allow the reader to understand the logic used for model assumptions, the actual model inputs, and the model outputs. The HVS proprietary model for projecting lodging demand, which is reflected in the forecast of market-wide occupancy at the bottom of Figure 5-9 on page 67 of the HVS study, relies on the inputs and assumptions provided in chapter 5 of the HVS study. In forecasting lodging demand, HVS researched and categorized the primary sources of lodging demand to the Davis market, and estimated their respective proportions of the Davis market‟s total accommodated hotel demand. These are provided in Figure 5-8 on page 65 of the study. These estimates provide the base year demand levels by segment, from which HVS forecast growth rates based on the assumptions and data discussed in the Base Demand Growth section on page 68 and growth rates detailed in Figure 5-10. The



demand forecast for the Davis lodging market also incorporates latent demand, which is potential demand that is currently not being realized in the market. As discussed on pages 68-73 of the HVS study, the two types of latent demand are unaccommodated demand and induced demand. Unaccommodated demand represents the lodging demand that is being turned away to neighboring areas due to the lack of comparable hotel rooms during peak demand periods. The basis for estimating and projecting unaccommodated demand is discussed on pages 68-70, including peak visitation periods to UC Davis, and an estimate of how much demand is being turned away during peak demand periods. The estimates of unaccommodated demand are based on the number of expected sellout or peak demand days by month, and an estimate of the proportion of each demand segment that would seek accommodations outside of the Davis area due to higher prices and/or the lack of available guestrooms. Induced demand is new demand attracted to a market due to new hotel supply, a new or expanded convention center, or a new visitor attraction, among other conditions. The basis for estimating and projecting induced demand is discussed on pages 70-73 of the HVS study, including potential lodging demand estimates generated from increased utilization of the UC Davis Conference Center. The estimates of induced demand are based on the cumulative total of the number of meeting and group segment hotel rooms forecast to be generated by the ramp up of the conference center, as well as the estimated induced rooms generated by the subject property‟s expansion for each demand segment. The cumulative growth rates for each segment are composed of both base demand growth projections, which range in the low-single-digit percentages, and estimates of latent demand growth from both unaccommodated and induced demand. The STR data show the Hyatt Place UC Davis‟ ability to induce additional demand to the market, as discussed in Master Response #8. This information, combined with the resultant market-wide occupancy projection by the stabilized year, further demonstrates the reasonableness of the HVS forecast of lodging demand. Note that the stabilized market-wide occupancy forecast in 2015 is approximately 60%, as presented in Figure 5-9, which is comparable to the market‟s historical peak occupancy range between 61% and 62%, as presented in Figure 5-1 of the HVS study. HVS‟ lodging demand and resultant occupancy forecast are in line with the market‟s historical peak levels, indicating demand growth is projected to increase in tandem with the recovery in regional and national economic conditions, and the expectation of latent demand to the market, generated by the addition of new lodging supply.

D-25 See response to D-24. D-26 See response to D-24. D-27 See response to D-24. D-28 The Hyatt Place Hotel has not caused a decrease in demand within the Davis hotel market.

On the contrary, it shows that the existing hotel has helped to generate demand. See Master Responses 2, 3, and 4.

D-29 See response to D-24. D-30 See response to D-7. D-31 Not only has the existing Hyatt Place Hotel improved the ability to book conferences at the

UC Davis Conference Center, the proposed expansion of the hotel is expected to assist with booking larger and more frequent events at the conference center. The commenter requests studies, surveys, facts, or data to substantiate this occurrence. The narrative description provided on pages 74 and 75 of the HVS Impact Study describes the results from the simple interview that was conducted with UC Davis staff who have been working on conference center bookings. The UC Davis staff did not survey potential clients to determine whether



clients would have or did commit to booking a conference based on the presence or absence of an adjacent hotel. Rather, staff are frequently asked about hotel availability and have determined that having a hotel adjacent to the conference center is important to groups who are investigating multiple venues for planned conferences. In addition, the staff at the existing Hyatt Place Hotel have tracked (shown on Figure 6-1 on page 75 of the HVS Impact Study) business bookings that were apparently lost because the hotel was not sufficiently large to accommodate a particular group (Crews 2011)3. Collectively, the information from UC Davis and Hyatt Place staff was used to inform the HVS consultants of the recent observations at the UC Davis conference/hotel facilities. When combined with the professional expertise of the HVS consultants (i.e., their knowledge about the lodging industry), the consultants were able to draw conclusions about the relationship between lodging and conferences at UC Davis. These conclusions are presented on pages 74 and 75 of the HVS Impact Study.

D-32 See response to D-24. D-33 The Technical Analysis for Responses to Comments Technical Memorandum includes new

analysis at the 1st Street / Richards Boulevard and Olive Drive / Richards Boulevard intersections. This analysis was performed using SimTraffic, which accounts for queuing effects on adjacent intersection operations. The Technical Analysis for Responses to Comments Technical Memorandum concludes that there are no new or substantially more severe impacts that were not previously identified in the Draft EIR. Analysis of the freeway on ramps and off ramps at Richards Boulevard and I-80 is not necessary. According to the Interstate 80 and Capital City Freeway Corridor System Management Plan (Caltrans, 2009), the Concept Level of Service for I-80 in east of the Solano County/Yolo County line is LOS F. The Technical Analysis for Responses to Comments Technical Memorandum concluded that there were no impacts to the I-80 Westbound Ramps / Richards Boulevard intersection. Additionally, the amount of traffic added to the on ramps and off ramps at Richards Boulevard is minimal. The Hyatt Place expansion adds 1-2 vehicles to each ramp; the Old Davis Road extension adds 17 vehicles to the westbound off ramp in the AM peak hour (4% increase) and 25 vehicles to the eastbound on-ramp in the PM peak hour (4% increase). See Chapter 3 of the Final EIR.

D-34 The Technical Analysis for Responses to Comments Technical Memorandum includes an assessment of the time difference between using the existing Arboretum Drive route versus the proposed Old Davis Road extension. The Technical Analysis for Responses to Comments Technical Memorandum concludes that is not an appreciable time difference between the two routes; therefore, the Old Davis Road extension is not expected to induce traffic from parallel facilities. See Chapter 3 of the Final EIR.

D-35 Table 13 of the Transportation Impact Study (TIS) shows the cumulative peak hour and daily vehicular traffic volumes on Old Davis Road between I-80 and California Avenue. Additionally, the TIS on pages 13 and 14, states the following:

“Analysis using the Davis Travel Demand Model showed that closing Arboretum Drive and

3 Crews. 2011. Email from Vermita Crews to Shawn Hong, HVS Regarding Targeted Businss/Lost

Potential Business. March 23, 2011.



adding the Old Davis Road extension resulted in the following:

Trips previously using Arboretum Drive we were rerouted onto the Old Davis Road extension

Some South Entry Parking Structure trips to/from the I-80 / Old Davis Road interchange rerouted to downtown Davis and roadway facilities south of the Olive Drive / Richards Boulevard intersection via 1st Street”

The Cumulative Plus Old Davis Road Extension scenario forecasts reflect the South Entry Parking Structure trips to/from the I-80 / Old Davis Road interchange rerouting to downtown Davis and roadway facilities south of the Olive Drive / Richards Boulevard intersection via 1st Street. Therefore, traffic volumes increase on Old Davis Road between I-80 and California Avenue. Peak hour traffic forecasts at intersections east of the South Entry Parking Structure reflect an increase in traffic due to the Old Davis Road extension; these forecasts are consistent with University estimates of additional revenue generation in downtown Davis.

Neither the Research Park nor the Nishi property projects have an approved or pending development application. Neither is a reasonably foreseeable project as defined by CEQA; therefore, they are not part of the cumulative analysis.

D-36 The Technical Analysis for Responses to Comments Technical Memorandum includes additional assessment of the time difference between using the existing Arboretum Drive route and using the proposed Old Davis Road extension. The Technical Analysis for Responses to Comments Technical Memorandum concludes that is not an appreciable time difference between the two routes; therefore, the Old Davis Road extension is not expected to induce traffic from parallel facilities. Analysis scenarios that include the Old Davis Road extension do show a growth in traffic to/from downtown Davis via 1st Street. Peak hour intersection analysis did “follow trips” from the Hyatt Place expansion and Old Davis Road extension through downtown intersections to determine if there were any significant impacts. Vehicle counts collected for the TIS show that the AM and PM vehicle peak hours occur from 8:00 AM to 9:00 AM and 4:30 PM to 5:30 PM, respectively. Most events in the south campus area are scheduled outside of the vehicle peak hours. All events currently scheduled at the Mondavi Center between September 2011 and May 2012 begin at 8:00 PM. Events at the Robert Mondavi Institute for Wine and Food Science are typically small and do not warrant inclusion in impact analysis.

D-37 The road realignment replaces an existing road and, as described in the EIR, trips may be shifted to the new road. However, the number of trips and the length of the trips would not increase. Accordingly, no operational emissions of GHG would result from the proposed road extension project.

D-38 The comment summarizes several sections of CEQA and the CEQA Guidelines. Comment noted.

D-39 The commenter requests UC Davis to analyze the City‟s proposed Hotel Conference Center



as an alternative to the proposed project. This project, proposed by the lead agency City of Davis, is expected to undergo CEQA review and is appropriately analyzed as a cumulative project because it is reasonably foreseeable. (See DEIR, p. 35 (Impact AES-2) and CEQA Guidelines § 15355(b).) The reasons for rejecting non-UC location for the proposed project are explained in Section 6.2.2 of the DEIR, pages 151-152. In summary, a non-UC location would not facilitate larger and additional conferences at the UC Davis Conference Center, would not make use of existing site improvements (parking, utilities, etc.), and would not minimize automobile traffic due to proximity of the hotel to the conference center facilities.

D-40 That the Richards Boulevard location would generate more greenhouse gas emissions than the proposed project is a reasonable conclusion based on the fact that hotel guests for a UC Davis conference would all travel to the UC Davis Conference Center while only a portion would travel to downtown Davis restaurants and shopping locations. Accordingly, it is reasonable to conclude that a hotel location with increased travel requirements (i.e., commuting to the conference location by vehicle) have more greenhouse gas emissions than a hotel located immediately adjacent to the conference center site.

D-41 See Master Response 6. This analysis is tiered from the 2003 LRDP EIR. As stated on page 56 of the Draft EIR, “According to the YSAQMD‟s CEQA Handbook, project emissions that exceed the YSAQMD emission thresholds would have a significant cumulative impact unless offset. As shown in Table 4.1-6 and Table 4.1-7, the proposed project would not exceed the construction- or operational-related emission thresholds. In addition, as noted above, cumulative CO impacts from buildout of the 2003 LRDP would not exceed the ambient air quality standards and would be less than significant. Also as noted above, cumulative health impacts from buildout of the 2003 LRDP would not exceed a cancer risk probability of 10 in one million or a Hazard Index of 1.0 at the MEI and would be less than significant. Based on this analysis, the proposed project would result in a less than significant cumulative impact.” For the same reason, the project would not conflict with the applicable air quality plan, would not violate any air quality standard, and would not contribute substantially to an existing or projected air quality violation. As documented in the 2003 LRDP EIR and the Initial Study for the Hyatt Place Hotel Expansion and Old Davis Road Extension projects, the cumulative impact of overall growth from the 2003 LRDP and surrounding regional growth was evaluated and determined to result in certain significant and unavoidable air quality impacts. Pages 28 to 32 of the Initial Study summarize the 2003 LRDP EIR determination that certain impacts of cumulative growth would be significant and unavoidable and directs the reader to Section 4.3 of the 2003 LRDP for the full discussion of cumulative air quality impacts during implementation of the 2003 LRDP EIR. The Initial Study for the UC Davis Hyatt Place Hotel Expansion and Old Davis Road Extension presented the relevant and feasible mitigation measure that had been previously adopted in the 2003 LRDP and the Initial Study explained that the Draft EIR for the UC Davis Hyatt Place Hotel Expansion and Old Davis Road Extension would conduct additional analysis to determine the specific impacts related to implementing these portions of the 2003 LRDP. As explained on pages 36 to 56 of the UC Davis Hyatt Place Hotel Expansion and Old Davis Road Extension Draft EIR, the anticipated air quality impacts from the hotel expansion and road extension would be less than significant. The thresholds used for air quality impacts are the thresholds adopted by the Yolo-Solano



Air Quality Management District (YSAQMD), which is the air quality management district for the campus and the project site. These thresholds were established by the YSAQMD for purposes of protecting public health and the environment. The YSAQMD thresholds were set to achieve consistency between the projects conducted by Lead Agency‟s within the boundaries of the YSAQMD and the overall goals for improving air quality in the region. Regional air quality planning is conducted in accordance with the federal Clean Air Act and local air districts must demonstrate planning steps to achieve attainment of air quality goals. The YSAQMD has completed this planning process, which was reviewed and approved by the US Environmental Protection Agency. The YSAQMD is implementing programs to achieve overall air quality attainment. These regulatory federal and state requirements for air quality planning are summarized beginning on page 35 of the Draft EIR.4 While the commenter disagrees with the YSAQMD‟s choice of air quality thresholds, the thresholds used in this EIR were adopted through a public process, are in compliance with both federal and state air quality laws, and are supported by substantial evidence. The following further discusses the relationship of the EIR air quality analysis to the Appendix G checklist questions listed by the commenter.

i. The YSAQMD ozone plan was adopted by the YSAQMD Board in 2009. The plan provides the adopted strategy for attainment of the 8-hour ozone standard by a specified attainment date and accounts for expected growth in the Sacramento region for which the UC Davis growth that was planned in the 2003 LRDP is included.

ii. Air quality attainment has been demonstrated by the YSAQMD and the plan approved by the US EPA using the adopted thresholds of significance and without any proposed changes to thresholds of significance. Accordingly, the project does not conflict with the applicable air quality plan and would not hinder implementation of the air quality plan. The commenter argues that more stringent thresholds would achieve attainment at an earlier date. This argument is secondary to the primary consideration of whether the adopted attainment plan can be achieved under the existing thresholds. Given that the YSAQMD proposed and adopted the attainment plan and the US EPA approved the plan, the University has reasonably concluded that the existing thresholds are appropriate.

iii. Bump-ups (as characterized by the commenter) have taken place in the air district. This process is allowable under the Clean Air Act, Section 181(b)(3), however, and does not change the findings of the Draft EIR. Through the bump-up process of designating the status of air quality attainment within the YSAQMD, the YSAQMD has proposed a plan to achieve air quality attainment. The bump-up

4 A summary of the YSAQMD planning process is provided in the following publication:

YSAQMD Triennal Plan and Update. May 2010. Available at: http://www.ysaqmd.org/documents/Final2006_2009TriennialPlan.pdf



designation and the attainment plan have been approved by the US EPA.

iv. The YSAQMD annual tons-per-year threshold for PM10 is appropriate for operational sources of air pollution. There is no reason to expect that emissions from the proposed hotel expansion or road extension would produce a majority of annual emissions during the ozone season. Operational emissions would be distributed throughout each year at a fairly consistent rate. If for example, the hotel occupancy was highly seasonable with low occupancy from fall to spring and then high occupancy in the summer (during the peak ozone season), then the commenter‟s point could be correct. However, the occupancy of the Hyatt Place Hotel is fairly constant throughout the calendar year and would have no peak period of increased emissions.

v. The YSAQMD threshold of 10 tons per year for ROG and NOx (ozone precursors) are actually more stringent than surrounding air districts. For instance, the Sacramento Air Quality Management District has a 65 pound per day operational threshold for ROG and NOx, individually. The YSAQMD 10 ton per year threshold, if divided over 365 days, is equivalent to 55 pounds per day. The YSAQMD has found that the 10 tons per year threshold is adequate for identifying CEQA projects that would require mitigation to adequately control ozone precursor emissions and achieve attainment.

vi. Even though more stringent thresholds are not necessary for attainment of the ozone standard by the attainment date, the YSAQMD still reviews CEQA projects that are within the district boundaries and recommends reasonable mitigation to improve air quality. The YSAQMD has recommended measures for the UC Davis project that will encourage the use of alternative transportation modes. See Response to Comment F-1. UC Davis will be implementing these measures even though the project does not exceed YSAQMD thresholds of significance.

D-42 See response D-41, regarding project-emissions and the conclusions related to project emissions. As determined in the Draft EIR, the project emissions would be less than significant.

This EIR is tiered EIR from the 2003 LRPD EIR, as encouraged in the CEQA Guidelines. Regarding cumulative emissions, including indirect emissions, see Master Response 6. The Initial Study for the project identified that the cumulative impacts of the project were adequately considered in the 2003 LRDP EIR. Pages 28 to 32 of the Initial Study provide the conclusions and mitigation measures related to cumulative impacts. See Comment Response D-41 regarding cumulative impacts and adopted mitigation measures from the 2003 LRDP EIR.

D-43 See response D-41, regarding project-emissions and the conclusions related to project



emissions.

This EIR is tiered from the 2003 LRDP EIR, as encouraged in the CEQA Guidelines. Regarding the analysis of cumulative emissions, including indirect emissions, see Master Response 6. The Initial Study for the project identified that the cumulative impacts of the project were adequately considered in the 2003 LRDP EIR. Pages 28 to 32 of the Initial Study provide the conclusions and mitigation measures related to cumulative impacts.

D-44 See Comment Response D-41.


D-46 This EIR is tiered EIR from the 2003 LRDP EIR, as encourage in the CEQA Guidelines.

Regarding cumulative emissions, see Master Response 6. The Initial Study for the project identified that the cumulative impacts of the project were adequately considered in the 2003 LRDP EIR. Pages 28 to 32 of the Initial Study provide the conclusions and mitigation measures related to cumulative impacts. Section 4.4.6 of the Draft EIR provides the reader with a link between the project analysis contained in the Draft EIR with the analysis provided in the Initial Study and the 2003 LRDP EIR.

D-47 Pages 77 to 79 of the Draft EIR explain the standards of significance used to evaluate greenhouse gas emissions. The Draft EIR explains the rationale for selecting the 900 MTCO2e threshold presented in the 2008 California Air Pollution Control Officers report titled CEQA and Climate Change: Evaluating and Addressing Greenhouse Gas Emissions for Projects Subject to the California Environmental Quality Act. The report is clearly referenced as CAPCOA 2008 in the Draft EIR (page 86 of the Draft EIR). These standards are consistent with the requirements of CEQA. The YSAQMD has no adopted standard of significance for greenhouse gas emissions and the State of California has not published a definitive standard of significance as guidance for lead agencies to follow.

Regarding the second standard of significance (potential conflicts with an applicable plan, policy, or regulation…), the commenter asks whether the proposed project would conflict with the UC Davis Climate Action Plan (CAP). The Draft EIR addresses this issue on pages 79 and 85. As a tiered project within the overall growth planned and evaluated in the 2003 LRDP and 2003 LRDP EIR, the proposed project would not conflict with the CAP. The CAP sets forth emission reduction opportunities within the context of the entire 2003 UC Davis LRDP program of development, of which this project is a part. Because the project would not exceed the growth levels contemplated in the 2003 LRDP, there is no possibility that the project would conflict with the CAP. The UC Davis CAP is referenced in the Draft EIR on page 87. The CAP accounts for all 2003 LRDP growth and, within that context, sets forth emission reduction opportunities that could be pursued with or without continued growth under the 2003 LRDP. As described on page 12 of the CAP, the CAP was developed within the context of the adopted 2003 LRDP which includes growth at UC Davis through the planning period of the 2015-16 academic year.

With regard to the comments concerning AB 32, now that the campus has an adopted CAP,



CEQA requires an evaluation of the proposed project and the determination of impacts related to greenhouse gas emissions in the context of compliance with the CAP. CEQA Guidelines §15064.4. Nevertheless, it should be noted that a 30% reduction of campus greenhouse gas emissions is fully compliant with the goals of AB 32.

D-48 See Comment Response D-47. The proposed project does not conflict with the UC Davis CAP. The proposed project is within the overall levels of growth envisioned in the 2003 LRDP; it is a tiered project within the context of the 2003 LRDP EIR, as clearly described in the Draft EIR. Section 1 “Environmental Review Process” on page 1 of the Draft EIR describes the use of a tiered EIR. This explanation is further described in Sections 1.2 (Scope and Purpose of the EIR), Section 1.3.4 (CEQA Findings and Mitigation Monitoring), and Section 1.4 (Relationship to the 2003 LRDP and LRDP EIR). The Initial Study for the UC Davis Hyatt Place Hotel Expansion and Old Davis Road Extension project also describes the use of a tiered document for CEQA purposes on pages 2 (Section 2.2), 17 (Section 4.5), and in the

See also Master Response 6.

D-49 The commenter identifies that the UC Davis CAP does not quantify mobile emissions and

that the Draft EIR does calculate mobile emissions. This is correct, and illustrates that the Draft EIR, as required by CEQA, thoroughly analyzes the entirety of greenhouse gas emissions that would be associated with the proposed project. The CAP does not have such a requirement and instead addresses a different set of UC Davis emissions. The Draft EIR includes mobile emissions in determining whether the project would result in a significant impact. See Draft EIR, Table 4.2-5.


D-51 The commenter alleges that the Strategic Energy Partnership Program (SEPP) already

exists and, therefore, should not qualify as mitigation for the proposed project. As concluded on pages 81 to 84 of the Draft EIR, the project would result in less than significant impacts without mitigation. Since the project‟s greenhouse gas emissions are already below the threshold of significance without mitigation, the University is not depending on Mitigation GHG-1 to reduce the project‟s greenhouse gas emissions impacts to below a level of significance. As such, the University is not required to adopt any mitigation to reduce the project‟s greenhouse gas emissions. Nevertheless, as a voluntary practice the University has applied Mitigation GHG-1 in order to commit UC Davis to a net-zero approach to greenhouse gas emissions for the proposed projects. Linking the SEPP implementation and project implementation commits UC Davis to continuing the SEPP program and implementing the identified emission reduction, above and beyond CEQA requirements. As encouraged by CEQA, the University has identified a feasible



mitigation measure and committed to completing the identified mitigation.

The SEPP program is established in the CAP as an option, not a requirement, for purposes of emission reductions. Emissions achieved with the SEPP program are being tracked to ensure that double-counting for emission commitments does not occur.

D-52 The commenter asks the University to use the SMAQMD Roadway Construction Emissions Model to calculate emissions from construction of the Old Davis Road Extension project. Discussions with YSAQMD staff have indicated that using either the SMAQMD Roadway Construction Emissions Model or the CalEEMod Model for construction emissions of greenhouse gases is appropriate. The University used the SMAQMD Roadway Construction Emissions Model and determined that the results from the CalEEMod model are more conservative (higher total emissions); therefore, the CalEEMod results are presented in the EIR. The CalEEMod provides a thorough accounting of construction emissions within different phases of construction. Further, the use of model inputs for constructing a parking lot are a suitable proxy for road construction because the timing, construction equipment and techniques, paving, and other activities are similar. The commenter has not provided evidence of new or substantially more severe impacts that were not previously identified in the Draft EIR.

D-53 The Technical Analysis for Responses to Comments Technical Memorandum includes new

analysis at the 1st Street / Richards Boulevard and Olive Drive / Richards Boulevard intersections. This analysis was performed using SimTraffic, which accounts for queuing effects on adjacent intersection operations. The Technical Analysis for Responses to Comments Technical Memorandum concludes that there are not new or substantially more severe impacts that were not previously identified in the Draft EIR.

D-54 According to the DEIR page 7, the Old Davis Road extension project objectives are to:

“Simplify the routing and experience for new visitors to the UC Davis campus by making route-finding simpler and more intuitive so that new visitors better understand the concept of the campus loop road and the traffic flow along the look road.

Improve the connection between the UC Davis Mondavi Center for the Performing Arts, the UC Davis Conference Center, and the Hyatt Place Hotel, and the City of Davis downtown area.”

The TIS, on pages 13 and 14, states the following:

“Analysis using the Davis Travel Demand Model showed that closing Arboretum Drive and adding the Old Davis Road extension resulted in the following:





The TIS assumptions regarding increased traffic through downtown Davis due to the Old Davis Road extension project are consistent with the stated project objectives. Simplifying the routing for visitors to the UC Davis campus should attract more traffic through downtown Davis and the Richards corridor. Additionally, the South End Parking Structure is the main parking facility for both visitors and staff of South Campus destinations such as UC Davis Mondavi Center for the Performing Arts and the UC Davis Conference Center. It is logical that an improved connection between South Campus destinations and downtown Davis would cause increased traffic to downtown Davis and the Richards Corridor, despite congestion at intersections on 1st Street and Richards Boulevard.

D-55 The Technical Analysis for Responses to Comments Technical Memorandum includes revised forecasts that reflect a reasonable diversionary effect on the contra-peak traffic flows. The Technical Analysis for Responses to Comments Technical Memorandum concludes that there are not new or substantially more severe impacts that were not previously identified in the Draft EIR.

D-56 Figure 2 of the TIS shows that 20 percent of Hyatt Place expansion trips are bound to/from Davis via A Street without the Old Davis Road extension. Figure 3 shows that 30 percent of Hyatt Place expansion trips are bound to/from downtown Davis via A Street with the Old Davis Road extension, a 50 percent increase in hotel trips. It is reasonable to expect that more hotel trips will use the First Street / A Street intersection with the Old Davis Road extension than without it. The TIS, on pages 13 and 14, states the following:

“Analysis using the Davis Travel Demand Model showed that closing Arboretum Drive and adding the Old Davis Road extension resulted in the following:



The 17.3 percent and 21.7 percent increases in AM and PM peak direction traffic are the result of rerouting of South Entry Parking Structure trips. There is no correspondence between these increases and increases from Hyatt Place expansion trips.

D-57 In the Technical Analysis for Responses to Comments technical memorandum. Land use refinements were made to the Davis Travel Demand Model and new Cumulative No Project forecasts were produced. The new forecasts retain the existing inbound/outbound traffic pattern for Downtown Davis: inbound traffic is greatest in the AM peak hour and outbound



traffic is greatest in the PM peak hour.

Final EIR Responses to Comments Comment Letter from Reed Youmans


Comment Responses

Comment Letter from Reed Youmans

Comment

Number

Response

E-1 The Hallmark Inn is included in the HVS Impact Study for the Hyatt Place UC Davis Hotel. Since the opening of the existing Hyatt Place Hotel, the local Davis hotels have not experienced decreased demand (See Master Response 7). Also, see Master Response 7 regarding Transient Occupancy Tax and Master Response 2 regarding application of CEQA to economic impacts.

E-2 See Master Response 5 regarding the Relationship of Proposed Project to the CEQA Analysis for the Existing Hotel. The proposed project did not include a waiting period of any sort pertaining to future hotel development or expansion. Regardless, the Hyatt Place Hotel opened in March 2010, over one year ago. As part of the process to consider approving the proposed expansion, the campus prepared the HVS Impact Study for the Hyatt Place UC Davis Hotel (HVS 2011a and 2011b). Please see Master Response 7 concerning the Effect of Existing Hyatt Place Hotel on the Local Market.

E-3 Commenter mistakenly states that “the reason for expansion is to prevent people attending the conference center from having to stay in Davis to reduce greenhouse gasses.” Three project objectives for the hotel expansion are listed on page 22 of the DEIR. One of these goals relates to minimizing greenhouse gas emissions by providing facilities in proximity to the conference center.

E-4 The Old Davis Road Extension and the Hyatt Place Hotel Expansion are independent projects in that approval and implementation of each project can proceed with or without approval and implementation of the other. The EIR analyzes the impacts of both projects independently and together. They are both included in this EIR due to their close proximity geographically and temporally. CEQA encourages environmental analyses to address the cumulative effects of projects with potentially overlapping impacts.

E-5 As of August 1, 2011, Richfield Hospitality Management Group became the management company for the Hyatt Place Hotel.

E-6 This observation is incorrect. The Hyatt Place Hotel is located in Yolo County. The Transient Occupancy Tax in Yolo County is 8% . All of these taxes are paid to Yolo County. Please see Master Response 7 regarding Transient Occupancy Tax.

E-7 Please see Master Response 7 regarding Smith Travel Research data. E-8 Please see Master Response 7 regarding Transient Occupancy Tax. E-9 Please see Response to Comments D-7 and D-22. E-10 Figure 5-4 presents data for three 12-month periods, each beginning in February and ending

in January (HVS Study, p. 50.).

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Final EIR Responses to Comments Comment Letter from YSAQMD


Comment Responses

Comment Letter from Yolo-Solano Air Quality Management District

Comment

Number

Response

F-1 The commenter noted that the existing hotel has bicycle parking and an existing bicycle sharing program for hotel patrons. The YSAQMD recommended additional bicycle parking to serve the proposed hotel expansion and the provision of higher quality bicycle racks. The campus policy is to expand bike parking as needed to ensure that all locations on campus have adequate bicycle parking. The existing bike parking is adequate and is expected to be adequate to serve the proposed hotel expansion.

F-2 Comment noted.

Final EIR Responses to Comments Comment Letter from Department of Conservation


Comment Responses

Comment Letter from Department of Conservation

Comment

Number

Response

G-1 No oil or gas wells are within the project boundaries. UC Davis will contact the Division of Oil, Gas, and Geothermal Resources if oil or gas wells are encountered.

Final EIR Responses to Comments Comment Letter from Public Utilities Commission


Comment Responses

Comment Letter from State of California Public Utilities Commission

Comment

Number

Response

H-1 The project would have no effect on safety near the rail corridor. Crossings of the railroad would not increase or be altered in any manner as a result of the proposed project.

H-2 See response H-1 H-3 UC Davis will seek approval from the Public Utilities Commission for any modifications of

an existing highway-rail crossing or proposals for a new crossing. The proposed project would not alter the existing rail crossings and would not result increased use of rail crossings.

Documents

UC-Davis Hotel Expansion: Hotel Owners' Complaint