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Manual

Volume 2, Chapter 5: Environmental Issues and CEQA Compliance

Updated Mar 16, 2026

All University projects are required to comply with the California Environmental Quality Act (CEQA), and UC has adopted the state’s “CEQA Guidelines” (Cal. Code Regs., Title 14, § 15000 et seq.); thus, these Guidelines in their entirety and any subsequent updates are automatically applicable to University projects. As environmental health and safety issues become increasingly important in transactions involving land and building construction, Facility environmental health and safety (EH&S) offices play a broader role in project development. EH&S offices assist their Facilities in all aspects of project planning. With new construction projects, EH&S provides guidance on industrial hygiene, laboratory safety, sanitation, radiation safety, hazardous waste management, and environmental site assessment.

On most campuses, fire marshals are located within EH&S. Fire marshals interact with the Office of the State Fire Marshal (OSFM) to ensure compliance with all applicable codes and standards. Fire marshals assist planners, architects, and engineers by identifying alternative fire safety solutions to be discussed with the OSFM.

5.1 California Environmental Quality Act (CEQA) Compliance 

CEQA defines “projects” as activities that have the potential to result in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment. A “project” constitutes the whole of an action and applies to typical capital projects as well as certain real estate transactions. The Regents adopted the State CEQA Guidelines and all state guideline updates as the guidelines for UC to follow. Key points about the University's application of CEQA are as follows:

  1. The University is the lead agency for all University projects; it prepares the appropriate CEQA document and evaluates the environmental significance of each proposed project. 
  2. Per Regents Policy 8103: Policy on Capital Project Matters, the certification and adoption of environmental documents is undertaken at the level of associated project approval.
  3. An Initial Study, Negative Declaration, Findings, Environmental Impact Report (EIR), or determination of exemption from CEQA must be completed prior to an irrevocable commitment to a project, which for capital projects is typically defined as design approval. 
  4. Approval, and execution of ground leases and related documents for which ground lease business terms and design approval following action pursuant to CEQA has occurred would not result in a modification to the physical characteristics of an approved project; therefore, such actions are considered implementing actions that do not require additional review under CEQA.

5.2 Environmental Impact Classification Form 

The Environmental Impact Classification Form (EIC) is an internal University of California form that is used to determine whether a University project or action is exempt from CEQA, or if not, what environmental documentation is anticipated. The EIC is required to be included in the Program Planning Guide (PPG) for each project, or separately prepared if no PPG is required. If a project involves a Regental approval, or an UCOP approval, concurrence, or review of the project’s environmental analysis, an EIC must be prepared and approved by the campus and then sent to UCOP Physical & Environmental Planning for concurrence. If a project does not involve Regental approval or UCOP approval, concurrence, or review of the project’s environmental document, an EIC must be prepared by the campus environmental planner and signed locally. The EIC provides a brief description of the project, the type of environmental documentation anticipated for the project, and whether the project is consistent with the long-range development plan. If a proposed project is determined to be exempt from CEQA, the EIC and any necessary attachments must provide justification for the exemption pursuant to the criteria set forth in the CEQA Statute and Guidelines. Should the scope of a project change substantially following local or OP signature on an EIC, it should be amended and re-signed to confirm that the anticipated CEQA document or determination of exemption remains valid. 

5.3 Environmental Health and Safety Liaison 

As environmental health and safety issues become more important in transactions dealing with land and building construction, Facility environmental health and safety (EH&S) offices have a broader role in project development. EH&S offices assist their Facilities in all aspects of project planning. With new construction projects, EH&S advises on industrial hygiene, laboratory safety, sanitation, radiation safety, hazardous waste, and environmental site assessment. EH&S is frequently involved in planning issues that require coordination with Facility planning staff and UCOP. In addition, EH&S informs Facilities about environmental and occupational regulatory requirements and University policies and requirements that may affect a project. See Guidelines-EH&S, Fire Marshal, and Site Analysis During Project Planning. The involvement of EH&S in the pre-design through construction of a project offers the following benefits:

  • Provides EH&S insight into programmatic development and conceptual planning stages of a proposed project.
  • Avoidance of unnecessary project planning and construction delays due to overlooked EH&S issues and resulting cost overruns.
  • Reduction in building occupants' health and safety complaints and Workers' Compensation cases as well as avoidance of significant public health and safety problems.

Environmental health and safety concerns are regulated by a number of federal, state, and local agencies including the California Environmental Protection Agency, which now includes the Department of Toxic Substances Control, Regional Water Quality Control Boards, Air Quality Management Districts, and Cal-OSHA; the Office of the State Fire Marshal; and the federal Environmental Protection Agency. Each Facility's administrative structure differs; as such, there may be other Facility organizations that are involved in EH&S matters. For example, some Facilities have separate fire departments or laboratory animal care offices. EH&S offices refer Facilities personnel to the appropriate department that has jurisdiction over a specific programmatic area of EH&S.

5.4 Fire Marshal and Fire and Life Safety Issues 

Fire marshals are located within EH&S, except at the Davis and Santa Cruz campuses, where there are separate fire departments. Fire marshals interact with the OSFM to ensure compliance with all applicable codes and standards. Fire marshals assist planners, architects, and engineers by identifying fire safety solutions to be discussed with the OSFM. On hospital projects, the Department of Health Care Access and Information (HCAI) is the primary authority during the design and construction period. However, if the hospital facility is a state-owned building, the OSFM still has jurisdiction over occupancy certification. Projects will benefit by coordinating with the fire marshals during the HCAI review process, which includes plan reviews and inspections. See Guidelines-EH&S, Fire Marshal, and Site Analysis During Project Planning.