The city has drafted an EIR Response to UC Davis that is a consent item on the agenda for Tuesday. The response also includes the January 24, 2017, NOP (Notice of Preparation) comment letter and requests responses to the comments made in that letter as well.
They state, “We believe it is imperative to understand how campus housing will be provided over time as student enrollment increases.” The city also expresses concerns that, while the Draft EIR “describes existing conditions and analyzes future conditions,” it “does not analyze any interim scenarios in between.”
Instead, the city argues, “The EIR must include an analysis of the impacts of development of the LRDP over time based on the University’s projected phasing and sequencing development, including, importantly, development of campus housing verses increasing student population.”
The city writes, “Without a commitment to the provision of campus housing at a rate that keeps pace with the increasing student population, it is not possible to verify the accuracy of the impact analysis or the effectiveness of the mitigation measures.”
Under the Draft EIR, the campus “assumes that development under the LRDP would occur in 2031 and the analysis measures the impacts of that development against a hypothetical future baseline of 
2031.” Instead, the city argues, under current law, “This does not align with the Supreme Court’s guidance in Neighbors for Smart Rail. The EIR must include an analysis of the impacts of development of the LRDP over time based on the University’s projected phasing and sequencing development, including, importantly, development of campus housing verses increasing student population.”
They argue: “It is clear implementation of the plan will lead to the development and operation of facilities/housing and their attendant environmental impacts long before 2031.”
The city is critical of the traffic and parking analysis. They note that “the analysis relies on a general unsupported statement that because total new campus housing exceed total campus population growth, that fewer students and faculty/staff will live in Davis with a commute on local City streets to/from campus and therefore, no adverse impacts on local streets are to be expected.”
Further the city is critical that there is no effort to quantify parking impacts in the local neighborhoods “even though it acknowledges that campus trips are resulting in parking impacts on existing streets in the current condition.” The city argues, “While the analysis in various places assumes current behavior would be replicated in the additional trip growth, in this case, the existing behavior of motorists parking in the city to walk/bike/bus the last mile is ignored with the new growth. A reasonable expectation is that motorists would park in the City rather than on campus thereby exacerbating existing City parking challenges caused by campus parking policies.”
From the NOP, the city notes, “It is unclear from the Project Description of the LRDP provided in the NOP how the LRDP will fully meet the Project Goals and Objectives…”
The NOP says it should explain “the rationale, in a manner that reflects the LRDP’s Project Objectives, for UC Davis’ proposal to house no more than 40% of enrollment on campus, as well as its assumptions and rationale for the percentage of students living off campus and outside of Davis. This is necessary to inform public understanding of the Project, potential impacts, and feasible mitigation measures to reduce potential impacts. “
The city proposes nine mitigation measures in the current document:
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.
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.
Proposed Mitigation Measure #3 – The University will commit to housing students of all incomes, and will incorporate innovative affordable housing models, including cooperative housing.
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.
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).
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.
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.
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.
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.
—David M. Greenwald reporting
The draft LRDP comment letter prepared by City staff is right on target. In January of last year the City transmitted a detailed 9-page letter to UCD on the letterhead of the City Attorney’s law firm, Best Best & Krieger. The letter provided excellent comments and suggestions, which it is evident UCD chose to completely ignore. I developed a similarly detailed comment letter, which it appears was likewise ignored by UCD in developing both the draft LRDP and the recently released DEIR.
I’ve read the entire 100-page LRDP and concluded that it is completely devoid of any meaningful substance. It’s full of attractive photos but limited text. It is hard to believe that UCD spent 3 years developing such a vacuous document. It continually emphasizes how it will contribute to the future “richness” of the campus and how the campus experience will be “enriched,” but provides no useful information on when more campus housing will actually be constructed to accommodate anticipated growth in the student population.
The plan also partially relies on increasing housing capacity by “doubling up” students in the existing West Village complex rather than placing emphasis on erecting new apartment buildings. It also claims to provide more new housing than the number of students expected to be added during the 12 years between 2018 and 2030, but of course completely ignores the fact that UCD still has not achieved the housing construction goals set forth in the 2002 Board of Regents student housing report nor the 2003 UCD LRDP. The plan does nothing to compensate for UCD’s past shortcomings.
The plan also makes no commitment to the kind of high-rise, high density on-campus apartment construction that other UC campuses are pursuing, which would demonstrate a true commitment by UCD to sustainability and stewardship of public land. A good example is the redevelopment of Webster Hall. UCD is replacing a 3-story building accommodating 266 beds with a new structure only one floor higher and with just 390 beds. In other words, $45 million of public funds is being spent to add just 124 beds. This is a tragic waste of public funds and a missed opportunity to build a much higher building scaled to UCD’s future housing needs.
It’s also evident that the LRDP and DEIR continue UCD’s habitual disregard for the negative impacts and infrastructure needs that its growth exerts on its host city. The City staff is to be congratulated for an excellent summation of the shortcomings of the two documents and recommendations for truly meaningful mitigation measures. The City Council is encouraged to authorize transmittal of the letter.
Moreover, I suggest that the Council should go even further by requesting that the entire LRDP process be halted so that UCD can “go back to the drawing board” and develop a truly substantive LRDP that addresses how to accommodate and mitigate future growth in a meaningful way. If UCD fails to do so, it may be opening itself up to the kind of litigation that has been successfully pursued against UC and Cal State campuses elsewhere in California.
Building the housing in the City allows for the collection of development fees and taxes that fund the needed improvements to our infrastructure. It is the demand by Davis residents that housing is built on campus instead of in the City that creates this negative impact.
Thanks Mark for the opinions based on logic and fact.
It seems that some support campus housing because it is not in their back yard. However, the people added to the community will still consume city services, drive on city roads and bike paths. However, when the housing is built by and owned by UCD, the city will get no property tax revenue to help offset the cost of this use of all these city services and infrastructure.
In the end, it is really an irrational position to demand that UCD build the housing because the housing is still in someone’s back yard, and the number of people in the city would be the same in both cases.
The mitigations proposed in the article above are great, and address issues beyond student housing (including compensation to the city, resulting from UCD’s impacts). In that way, it is not unlike the agreement forged between Santa Cruz and its UC:
http://lrdp.ucsc.edu/settlement-summary.shtml
Again, there are analyses which show that the Nishi proposal can create permanent deficits for the city, ranging up to $750,000 per year.
For example, Matt’s article, regarding Nishi:
http://www.davisvanguard.org/2018/04/nishi-numbers-dont-add-honesty-transparency-missing/
Ray Salomon’s analysis, regarding Nishi:
http://documents.cityofdavis.org/Media/Default/Documents/PDF/CityCouncil/Finance-And-Budget-Commission/Agendas/20180312/07C-Solomon-Updated-Fiscal-Models.pdf
There is also an article in the Davisite today, which describes these concerns.
“Again, there are analyses which show that the Nishi proposal can create permanent deficits for the city, ranging up to $750,000 per year.”
Thats like saying there are people who believe the world is flat. There are. That doesn’t make them right.
Matt’s main point (as explained in his article, referenced above) is that the city is not presenting a range of possible outcomes, as they had with Nishi 1.0.
As you know, the city used an external analyst for Nishi 1.0, which corresponds with the methods used by two finance and budget commissioners (Matt and Ray) for Nishi 2.0. (Unfortunately, an external analyst is not being used, for Nishi 2.0.)
As previously pointed out, there was no basis put forth for the “75% of cost” allocation across a broad range of cost categories, in the model that’s being put forth by the city this time (for Nishi 2.0). That is truly a “flat earth” (blind faith) model, if there ever was one.
So, we have one model which shows a “slight” surplus, vs. two models which show “significant” deficits. (And, it seems likely that we’d have a third model showing a deficit, had EPS been used this time.)
I understand Matt’s main point
I wonder when it came to be best practices for the initial builder to not only pay for the initial infrastructure but also the replacement costs simultaneously. And why you would count that as a deficit if they don’t double pay for the infrastructure. That’s a weird position to take. Matt’s taking it and you’re buying into it.
I read a while back that (author) Joan Didion’s brother paid over $13 million for the big new industrial building just east of the 2nd street bike bridge. Over the next 20 years (with the annual Prop 13 bumps) the owner of just that one building will pay about $3.5 million in property tax. It seems like the cut of the $3.5 million the state gives to the city should be more than enough to maintain the infrastructure around the property (especially since taxes keep going up the state will get over $5 million in the next 20 years even if the property is not sold and re assessed).