The city of Davis during the course of the university’s LRDP (Long Range Development Plan) process sent a series of letters to the university, most recently on May 18, 2018, from Interim Community Development Director Heidi Tschudin referencing concerns with the Draft EIR.
The letter noted, “We believe it is imperative to understand how campus housing will be provided over time as student enrollment increases.” The city then laid out a number of proposed mitigation measures, writing that “we respectfully propose the following reasonable and feasible mitigation measures be incorporated into the EIR and committed to by the university in the required Mitigation Monitoring and Reporting Plan.”
Proposed Mitigation Measure #1 — The University will commit to housing a minimum of 100 percent of the projected student enrollment of all new incoming students and at least 50 percent of total University campus student population in the LRDP.
Response: Beginning with comment L2-6 through comment L2-14, the commenter provides several suggested mitigation measures. The commenter’s proposed mitigation measure #1 reflects a request for a commitment by UC Davis to house 100 percent of new incoming students and at least 50 percent of total student enrollment. The comment does not identify what potentially significant environmental impact the mitigation measure is intended to reduce. The suggested mitigation measure is considered a request to change the Draft LRDP and not a mitigation measure intended to reduce the potential physical environmental impacts associated with the proposed 2018 LRDP. Please see response L2-4; as described, new housing would exceed new enrollment and is planned to be provided in the very near term and in advance of most of the enrollment.
The 2018 LRDP would reduce the proportion of total student enrollment living off-campus. The comment does not address the adequacy of the EIR analysis. The comment is included within the record for consideration as part of the 2018 LRDP.
Proposed Mitigation Measure #2 — The University will commit to higher densities (e.g. four-plus stories) in redeveloped and new student housing than are currently being provided, taking into account neighborhood context.
Response: The comment requests adoption of mitigation that commits UC Davis to higher density student housing with structures greater than four floors. See response to comment L2-5 above regarding construction costs of a 5-story building. It is also unclear as to what potentially significant environmental impact the mitigation measure is intended to reduce, and appears to be a comment on and a request to change the 2018 LRDP. The comment does not address the adequacy of the EIR analysis. The comment is included within the record for consideration as part of the 2018 LRDP EIR.
Proposed Mitigation Measure #3 – The University will commit to housing students of all incomes, and will incorporate innovative affordable housing models, including cooperative housing.
Response: The comment requests adoption of mitigation committing UC Davis to “affordable housing.” Refer to Section 2.2.4, “Master Response 4: Student Housing Affordability.”
Proposed Mitigation Measure #4 — The University will develop a construction and financing implementation strategy to ensure the delivery of campus housing units and facilities in a timely manner commensurate with levels committed to by the University in these mitigation measures.
Response: The comment requests adoption of mitigation related to development and implementation of a construction and financing strategy. It is unclear what potentially significant environmental impact the mitigation measure is intended to reduce, and appears to be a comment on the 2018 LRDP. The comment does not address the adequacy of the EIR analysis. This comment is included within the record for consideration as part of the 2018 LRDP. Also, see response L2-4 regarding the timing for providing housing in excess of new enrollment growth and Master Response 5 regarding Level of Detail.
Proposed Mitigation Measure #5 — The University will enter into an agreement with the City to compensate for the direct and indirect impacts of students on city infrastructure and services (e.g. transportation, transit, utilities, water supply, wastewater treatment, stormwater conveyance, parks and greenbelts, community services, recreation facilities and programs, police and fire service).
Response: The comment requests adoption of mitigation to compensate for the direct and indirect impacts of students on city infrastructure and services. As noted above in response to comment L2-4, the 2018 LRDP would reduce the number of students living off-campus, thereby reducing the potential direct impacts on city infrastructure and services with its implementation. Potential indirect impacts are evaluated, where appropriate, within the Draft EIR. The comment and suggested mitigation measure do not identify a particular infrastructure or service maintained and operated by the City that would be adversely affected by implementation of the 2018 LRDP and does not provide any substantial evidence showing any such significant impact, and as such, the mitigation measure is not considered necessary to reduce potentially significant impacts of the plan. No further response is necessary; however, this comment is included within the record for consideration as part of the 2018 LRDP.
Proposed Mitigation Measure #6 – The University will regularly demonstrate to the City (eg. Reporting to the City Council at least annually) that the housing target has been achieved and identify appropriate measures to improve performance if necessary.
Response: The comment requests adoption of mitigation that would require UC Davis to report to the City Council and potentially adjust how the 2018 LRDP is implemented. The commenter does not identify what potentially significant environmental impact the mitigation measure is intended to reduce, and appears to be a comment on the 2018 LRDP and continued cooperation between the City and UC Davis. Of note, UC Davis remains committed to working cooperatively with the City to the benefit of both entities; however, the comment does not address the adequacy of the EIR analysis. The comment is included within the record for consideration as part of the 2018 LRDP.
Proposed Mitigation Measure #7 — The University will enter into an agreement with the City to compensate for lost property tax revenue associated with the University’s leasing of property within the city limits.
Response: The comment requests adoption of mitigation related to compensation of lost property tax revenue associated with the University’s leasing of property within the city limits. The 2018 LRDP would allow for substantial on-campus development and does not identify the potential increase leasing of property within the City of Davis, such that potential physical environmental impacts would occur with implementation of the 2018 LRDP. As such, the comment relates to activities that are not part of the project under the 2018 LRDP analyzed in the EIR and does not address the adequacy of the EIR analysis. No further response is necessary. Furthermore, the comment raises an economic issue (loss of property tax) that is not required to be analyzed under CEQA. The comment is included within the record for consideration as part of the 2018 LRDP.
Proposed Mitigation Measure #8 – The University will commit to engaging the City in and assisting in the funding of a collaborative process for joint planning of shared edges and corridors to ensure mutually workable and coordinated results.
Response: The comment requests adoption of mitigation related to a commitment by UC Davis to engage with the City in and assist in the funding of a collaborative process for joint planning between the two agencies. See response to comment L2-11 and Master Response 3. Historically and as part of LRDP implementation, UC Davis has engaged and looks to continue engaging with the City of Davis on collaborative and potential shared planning opportunities. Examples of this include the Nishi development extended planning effort in 2015 and 2016, more recent Nishi planning and signing of an MOU in 2018 to provide UC Davis road access supporting housing for 2,200 people at the Nishi site, contributing more than $250,000 to a City of Davis priority project at the entrance to campus at Third Street, allowing the City of Davis to use the UC Davis traffic computer model, proposing collaborative planning along Russell Boulevard and at the University Mall, participating in planning efforts along Anderson Road, and substantial planning efforts for the City of Davis Downtown Specific Plan. UC Davis views these partnerships as very positive and as a clear example of the ongoing collaboration that will continue between the two entities and would like to continue discussions regarding these collaborative opportunities that are outside of CEQA requirements. Inclusion of a mitigation measure or funding for these partnerships appears to be a request and not based on CEQA requirements. No further response is necessary for purposes of CEQA.
Proposed Mitigation Measure #9 – The University will enter into an agreement with the City of Davis to actively participate in and assist with funding the City’s rental registration and inspection program to help address the indirect effects associated with increasingly overcrowded student housing conditions off-campus.
Response: The comment requests adoption of mitigation related to a commitment by UC Davis to assist the City in funding of a rental registration and inspection program to support off-campus student housing needs. The concept of helping students with rental resources is not considered germane within the context of CEQA but is important and appealing to UC Davis as part of the overall concept of providing a cohesive and sustainable community. As noted in response to comment L2-13, UC Davis seeks feedback from the City of Davis on an opportunity to continue this discussion of a non-CEQA issue and opportunities for ongoing collaboration on important planning topics that affect the City of Davis and UC Davis.
Response 2-4
Since a number of the responses refer back to 2-4, here is the key section…
- The resolution requests that a minimum of 100 percent of new student enrollment growth in on-campus housing, as well as housing for 50 percent of the total UC Davis student population.
After the resolution was passed, the LRDP was revised to increase on-campus and related student housing. Whereas new housing for 6,200 students was originally projected, the 2018 LRDP now includes a new housing projection for 9,050 students. The 2018 LRDP would accommodate enrollment of up to 5,175 new students (compared to the 2015-2016 academic year), so would exceed the goal of housing 100 percent of new student enrollment growth. As revised since the NOP and subsequently evaluated in the Draft EIR, the 2018 LRDP includes housing for 175 percent of the potential enrollment increase and 48 percent of the total future enrollment.
Total housing is more complicated. Both student and faculty housing are provided on campus. Of the current 10,424 beds on campus, 9,818 are for students. The additional housing opportunities afforded by the 2018 LRDP could raise the total on-campus housing to 18,868 beds. The 2018 LRDP accommodates up to 39,000 total students (existing plus the 5,175 new students). If both the maximum housing and student growth accommodated by the LRDP were to occur, the 18,868 beds would total be 48.4 percent of total student housing, approximately equivalent to the City’s desired total.
- The resolution requests that non-residential space expansion be clearly delineated in the LRDP.
The LRDP proposes no expansion of off-campus non-residential space. The LRDP includes maps and tables, illustrating areas of proposed growth (all within campus lands) which are also reflected in the Draft EIR. Please see Chapter 2 of Volume 1 of the Draft EIR, particularly Exhibit 2-4 and Table 2-2.
- The resolution requests a financing and implementation strategy that would ensure delivery of increased housing to accommodate enrollment growth, and absent the timely delivery of housing, that enrollment growth is curtailed.
UC Davis recognizes the community—and campus—need for more student housing and is aggressively seeking to establish housing as soon as it can. To that end, up to 3,800 beds at West Village and 1,400 additional beds at Orchard Park are included as initial phases in the project. These beds would be constructed through public-private partnerships, and developers have already been selected for these projects. In an effort to advance these projects as soon as possible, Volumes 2 and 3 of the Draft EIR provide project-specific analysis of these housing developments. The 5,200 beds that the upcoming projects would potentially provide would exceed the total potential LRDP enrollment growth of 5,175 students in the LRDP helping to achieve the housing goals of 100 percent and 50 percent desired by the City of Davis, so this goal would be met. Additional housing is also planned, as described above.
Basically the university doesn’t respond to the city’s request they go up to 10,000 beds (or 50%). As I said before, I’m fine with 9050, but I really don’t understand from the university’s perspective why they went with 9050 instead of 10000.
Based on its narrowly defined purview and ensuing quality and substance of the exchange between the city and the university, it would appear that CEQA may be the least helpful, most damaging intrusion on institutional communications that one could imagine.
Of course the environment is important and needs to be respected and protected, but from the stilted nature of these communications it appears that common sense can left at the door by either or both parties, while legitimate issues involving cumulative, long term impacts from associated demographic changes, spending patterns, taxation policies, and technological evolution – issues which threaten the fiscal and economic sustainability of one or both parties – can be summarily dismissed as irrelevant to the conversation.
No way to build or evolve an actual relationship – that’s for sure.
John D, you are absolutely correct. Problem solving through a meaningful mutual relationship is always better than trying to achieve change and forward progress through a process as rigidly defined as CEQA.
As someone who has been involved in this issue for the past 3 years, however, I can tell you that members of the City Council and city staff have made numerous attempts to establish and carry out a meaningful dialogue with UCD about the LRDP–particularly as it relates to on-campus student housing–and were generally met with a complete lack of cooperation. UCD simply did not respond in any meaningful way. As an example, both the City Council and Board of Supervisors took steps to establish an LRDP “2x2x2” committee, but to my knowledge UCD never appointed its 2 representatives, so nothing happened.
As private citizens, myself and others attempted to meet Chancellor May to discuss the student housing problem, but instead were shunted off to meet with other campus administrators with whom we had already met on several occasions. This, even after Gary May told us in person that he’d be happy to meet with us.
Other cities (Santa Cruz, San Diego) have had to resort to litigation in order to alleviate the negative impacts of campus growth. It will be unfortunate if the City of Davis has to resort to such measures, but UCD’s past history of missing housing goals and its disregard for local concerns as the 2018 LRDP evolved may leave the City (and County) with few other options.
No surprises, here.
If the city of Davis wants to address the impacts of UCD’s plans (both past, and current), it will need to pursue litigation. (That also goes for the fiscal impacts, as outlined in proposed mitigation #5, above.) Financial contributions (and other measures) from UC Santa Cruz to help offset its fiscal impacts are also addressed in their agreement with that city.
If the city starts whining about the need for some mega-development to solve all of the city’s fiscal challenges, it had better look into this, first. However, I don’t have much faith in that, based upon unexplained squeamishness regarding pursuing an agreement, and the failure to properly address rising employee compensation. Rich Rifkin posted an illuminating article, regarding that (see link, below).
https://lrdp.ucsc.edu/settlement-summary.shtml
https://www.davisenterprise.com/forum/opinion-columns/rich-rifkin-expect-city-services-to-deteriorate-more/
“f the city of Davis wants to address the impacts of UCD’s plans (both past, and current), it will need to pursue litigation”
That assumes that the EIR and the LRDP are the only mechanisms by which to address iMo acts. They are not.
David: Nothing I stated presupposes that.
However, I would add that if fiscal impacts are not addressed/included, then it’s probably not worth pursuing an agreement (for 950 beds).
I’m not sure where the “squeamishness” (reluctance) comes from. (Direct connections with UCD? Potential allegations of hypocrisy, in regard to whining about the multiple lawsuits AGAINST the city – for developments approved by the city?)
Yes, I think your paragraph on the need for litigation does presuppose that. Litigation is not the be all and end all either, clearly Santa Cruz is not satisfied even with their agreement.
Your statement to me was regarding to the EIR and LRDP, not litigation. So, I’m not even sure why you made the comment in response to mine.
Regarding Santa Cruz’ apparent dissatisfaction – maybe so, but where would they be without that agreement?
In general, there will be no agreement out of the “goodness of their hearts”. Each entity will pursue its own best interests. (Actually, in the case of the city, I’m not confident of that. For example – see link to Rich Rifkin’s article, above.)
You’re mistaken. My comment to you was in response to your comment on litigation being the only remedy (implied in your comment quoted above). My response was that presupposes that the only mechanism to address those issues that you cited, which they are not.
Maybe Santa Cruz would be a better position to work with their university if they hadn’t poisoned the waters through litigation. This is not a binary world.
David: If you look at the comments elsewhere on this page, they might be best summed up as “been there, done that”.
And, I strongly suspect that applies to Santa Cruz, as well. (That is, there were probably significant efforts to resolve conflicts, before the litigation arose.)
However, probably not worth it for 950 beds, unless it also addresses fiscal impacts of UCD’s past, current, and future plans.
I think you need to stop taking an adversarial view of the university. That’s not to say they are strictly a benevolent force or don’t operate at times as the 800 pound gorilla in the room. However, I believe they are on the whole a net positive for the community. Taking that view, I think you work with the university for the best mutual interests. Taking a more adversarial stance means that the university simply pushes more into Sacramento and ignores Davis. That’s not in our best interest. Yes, they hold a lot of the cards and we have to recognize that as well.
David: That attitude is probably best summed up as, “Thank you sir, may I have another?” 😉
They’re already sticking it to the city with the cost and impacts of student housing, while pursuing other activities elsewhere. (As you pointed out, they didn’t want traffic going through their property, in regard to an innovation center component at Nishi.) Even under the current iteration of Nishi, they want to be reimbursed for the use of their land.
UCD might be good for individuals (including some decision-makers), but that doesn’t necessarily translate into benefits for the city.
Do you view it as beneficial that Aggie Square is going to Sacramento and not Davis?
I’d have to look at the proposal, more carefully.
But again, they’re already doing this WITHOUT any litigation or agreement. Since you no doubt view Aggie Square as a benefit to a host city, I’m not sure what you’re arguing about.
No, they did it because we have put up impossible barriers to economic development.
They did it because they (UCD) didn’t want it at Nishi. (Don’t you think the developers might have spoken to them about this, before presenting it to voters?)
Strange, how some complain about “impossible barriers” to build commercial developments, while the city is simultaneously approving tons of student housing.
You’d think that it might be the opposite. (But, probably reflects the profitability/demand of building housing, vs. commercial developments.)
And I’d point out that your answer reflects the problem as well – you can’t say if it would be beneficial to Davis, you’d have to look at it first. We all know that if there was a concrete proposal in Davis, you’d be opposing it. Just as you did Nishi.
I find it hilarious that you hold out Nishi with an innovation center as some sort of answer – you opposed Nishi with an innovation center. The lesson there is if you say no, you don’t get necessarily get a second chance.
I find it more interesting that you’d automatically assume that Aggie Square would be a benefit. Do you even know what it consists of? (I don’t, hence I’m not opining.) Does it include housing? What portion of it will be occupied by UCD? Is there an agreement to offset the taxes that UCD doesn’t pay, for space it occupies? Are there commercial tenants already lined up?
Also, Sacramento is entirely different than Davis, regarding its ability to (more seamlessly) absorb a development. (Half a million people living there, already? Probably a lot more of whom need jobs, for that matter.)
Regarding Nishi 1.0, there were significant concerns regarding the impact at Richards/Olive, for one thing. (Not entirely resolved by Nishi 2.0.) There are still unresolved issues and litigation. We’ll see how that plays out. But, as usual, UCD is the “winner”, simply by staying out of the fray. And, letting it be known (behind the scenes) that they didn’t want traffic from a commercial component going through their property.
If you want to continue doing their bidding, that’s your decision.
This is why we’re in trouble – paralysis by analysis. So while we dither, others move. It’s a competitive environment and those who are risk averse will lose.
Those who oppose UCD paying for its impacts are a large part of the problem. Coupled with the city’s decisions, regarding rising employee compensation.
Did you even read Rich Rifkin’s article, above? (While doing some past research, it appears that he used to comment on here, but became frustrated doing so. At least, that’s what I recall, while reading past articles.) (I realize he would strongly disagree with me regarding other issues.)
My problem is that your analysis of UC Davis’ impact is heavily weighed on the negative side of their impact without enough consideration for the positive side.
I’ll have a response to Rifkin’s column later this week.
The city needs to quantify the adverse impacts if it is seeking compensation. Those impacts would need to be weighed against the fiscal benefits of increased enrollment. The city, in seeking an agreement or in litigation, would have to prove that the costs of added enrollment on infrastructure outweigh the fiscal benefits from increased economic activity.
As has been pointed out previously, 100/50 was not an actual attainable number. Focusing on 100% of new enrollment gave UC an out as to which number to attain. It seems a lot people didn’t understand that during the whole debate.
A more important focus, IMO, is the rate at which housing will be provided. UC quietly pushed the timetable out three years as they announced their increase in housing numbers. I hope the council will push back on that.
It’s a good thing the city’s letter has been entered into the record here, but that’s all that’s happened. UC is basically saying: the ball’s in your court. In order to get anywhere, the city needs to provide numbers.
I assume that Santa Cruz is generally aware of the negative and positive, as well. And yet, found enough negative to pursue litigation.
Most of the city’s problems you continuously discuss are related to UCD, either directly or indirectly. So, perhaps it’s you who is overly-negative. I’m just pointing out possible solutions, and trying to point out the problems of pursuing ill-advised ones.
Regarding Rich Rifkin, it’s a shame that he apparently doesn’t comment on here anymore.
“Most of the city’s problems you continuously discuss are related to UCD”
That’s probably true in a non-meaningful way. The demand for housing, the good schools, the general desirability of the community are all related to UC Davis. Some have suggested that Davis would be Dixon without the university, that’s one possibility. Or we could be Woodland or West Sacramento. Given that, I think it’s impossible to separate what is and what is not related to the university.
However, our lack of per capita retail sales is not related to the university, our employee compensation decisions is certainly not in any meaningful way related to the university, our anti-growth policies are also not related to the university.
Again, I don’t find the comment all that helpful because in most respects Davis and UCD are so interwoven there is no meaningful way to separate them.
I’d start by examining the agreement with UC Santa Cruz. There are specific dollar amounts (contributions from UC Santa Cruz), in that agreement. Along with other measures to limit traffic generated by that university.
http://lrdp.ucsc.edu/settlement-summary.shtml
I can think of one example, off the top of my head (in which impacts can pretty much be attributed directly to UCD). The impacts of (and damage from) Unitrans buses on city streets. (Learned from Howard that buses do quite a bit of damage to streets.)
Of course, it’s still probably challenging to come up with the “portion” of costs that are attributed to this specific damage.
Anyway, that’s just one example.
David Greenwald said . . . “However, our lack of per capita retail sales is not related to the university”
I wholeheartedly disagree David. Our lack of per capita retail sales is a direct result of (1) the monoculture University-Town nature of our demographics, and (2) the monoculture University-Town nature of our local economy. And what is truly frightening is growing intensity of that monoculture University-Town nature.
Evidence of that University-driveninfluence can be found in Figure 4 on page 27 of BAE’s June 5, 2018 DRAFT Economic Background Analysis – Downtown Davis Plan What that graphic shows are two things, (A) the paltry amount of personal discretionary spending attributable to University students, and (B) the importance of Office Worker spending near the building where they are employed. (B) is particularly important in Davis because neither the University nor the community have tried to retain the intellectual capital (created by the University each and every year) in the form of office worker jobs driven by that intellectual capital.
David Greenwald said . . . “our employee compensation decisions is certainly not in any meaningful way related to the university”
Here too I wholeheartedly disagree. The overall complacency and self-satisfaction of the Davis populace is very clearly University-related. The vast majority of Davis households have (A) a “tenure bias” when thinking of employee compensation, and (B) a “selection bias” because there is one or more than one government employee in the household.
David Greenwald said . . . “our anti-growth policies are also not related to the university.”
Again, I wholeheartedly disagree. For the most part the faculty and staff of Universities are academically liberal, but personally conservative. University compensation policies create a populace that is “fixed income”oriented (long before the individual members of that populace actually retire and have to rely on the fixed income of their pensions. Housing values are one of the ways that a family living within the University compensation model can leverage their capital and create high annual ROI in at least one portion of their composite fiscal picture. Bottom-line, the anti-growth policies are a very logical bi-product of the University business model. With that said, if the nature of our local economy were not a monoculture University-Town, our housing policies would have a much harder time being monochromatically anti-growth.
David Greenwald said . . . “in most respects Davis and UCD are so interwoven there is no meaningful way to separate them.”
Four for four David. As I told you yesterday, I was recently talking to the Dean of Biological Sciences of the University of Pennsylvania and amongst the numerous topics we discussed, he told me that the Mayor of the City of Philadelphia and the senior leadership of the University meet once a week to build/maintain a constructive relationship. That is what “interwoven” looks like. Ask Robb Davis how many times he has sat down with the UCD Chancellor and talked about the City’s and University’s interwovenness.
Matt: Furthers my point that the two are just too tightly linked to disentangle. It was pointed out to me that while I think the scenario is a good idea, the city has not gotten much in the way of traction trying to meet with the university.
David, can you point to a single example of “entanglement” or “linkage” between the City and the University?
The only outward and visible sign those two organizations have come to such a linkage came in the form of Nathan Trauernicht. The next closest is UCD’s participation in the Surface Water Project. After that I can’t think of a single example.
You are conflating “cause and affect” with “entangle and link.” They are very different. Very different indeed.
You just named four of them, did you not?
None of those four are “entanglement” or “linkage.” To have entanglement there needs to be engagement between the two organizations (City and University). What we have between those two organizations is estrangement … for the most part, the sounds of silence. Each of the two organizations is passive toward the other … or at best passive-aggressive.
If the city can’t or won’t compile and articulate a compelling case for the myriad of related and unintended consequences of a state university dominated local economy – apart from pressures on the housing sector – is that the fault of the university and its leadership? On the other hand, if there is no interest on the part of the university in an open and honest exploration of the issues – that’s a different matter. Having been involved in neither, I’m left to express my disappointment and frustration with the artifact of CEQA as the apparent medium of interaction.
I’m pretty sure that they have the subcommittee that has been meeting and working with UC Davis so that CEQA is not the only means of communication between the two entities
David, I was talking to the Dean of Biological Sciences of the University of Pennsylvania recently and amongst the numerous topics we discussed, he told me that the Mayor of the City of Philadelphia and the senior leadership of the University meet once a week to build/maintain a constructive relationship.
That is what a mutual commitment to win-win between a world-class University and its host city looks like.
I agree with your comment Matt. I prefer that approach to one of litigation or threatened litigation.
May I remind all that CEQA was intended to be a disclosure process… using it as a “communications channel”, or a “negotiating tool” is just ‘wrong’…
Right but there are impacts that need to be mitigated and some of those include water, traffic, etc. So while your point is correct, the city’s use of CEQA comment is not inappropriate.
You’re missing the “tone” of several posters, including yourself… be honest, the tone set was ‘housing’ and ‘economics’, with very thin links to any environmental issue… seen by some to be a ‘negotiation tool’
Howard,
What is the official, recognized mechanism for identification, discussion and negotiation of attributable, economic impacts.
Given UCD’s responses, I’m curious if the City’s comments were backed up with discussion and analysis of CEQA-based environmental effects. I could see how there are impacts that could be tied to the mitigation measures, but UCD appears to wonder what these impacts are. Is there a link to the City’s comments somewhere that we can check if the City provided sufficient evidence of CEQA-based impacts? If not, then the City will be in a very poor litigation position.