HomeMy WebLinkAboutFinal ECR EIR 06022000
DEPARTMENT OF ECONOMIC
AND COMMUNITY DEVELOPMENT
PLANNING DIVISION
(650) 877-8535
FAX (650) 829-6639
RE: ERRATA, EI Camino Corridor Redevelopment Plan Amendment Supplemental EIR (SEIR),
Responses to Comments
The attached letter was inadvertently omitted from the Responses to Comments document dated June 2,
2000. As the letter was submitted within the public comment period for the Draft SEIR, a response is
required to comply with CEQA. The following discussion provides a response to the points made in the
letter.
First, the commenter refers to differences among the traffic analyses in the General Plan EIR, the EI
Camino Corridor SEIR, and the Costco EIR. In essence, the Draft SEIR for the Redevelopment Plan
Amendment assumed a more conservative development scenario for the project area, in that it included
development in the Plan Area, City-wide, and the large redevelopment projects from the City of San
Bruno, the General Plan b~ild-out from the City of Brisbane, and development from Pacifica. The
General Plan EIR addressed City-wide development under Plan buildout, and the Costco EIR considered
the Costco project plus development area-wide. The City of South San Francisco cannot control the
development that occurs in other cities; however, the City has taken this development into account when
analyzing the traffic impacts at (and identifying mitigation for) intersections within the City. The analysis
provided in the Redevelopment Plan Amendment Draft SEIR is adequate to address the impacts of the
Redevelopment Plan Amendment.
Second, the commenter refers to the effectiveness of the mitigation for the intersection of Hickey
Boulevard and Junipero Serra Boulevard. Mitigation identified in the Draft SEIR (p. 5.1-48) includes (1)
restriping the eastbound Hickey Boulevard approach to provide an exclusive left turn lane, an exclusive
through land and a shared through/right turn lane; (2) widening the westbound Hickey Boulevard
approach to provide an exclusive left turn lane; (3) restriping the existing shared left/ through lane on the
westbound approach to provide an exclusive through lane; and (4) changing the east-west signal phasing
from split to protected phasing for left turns. These improvements combined would reduce the average
delay to 30.8 seconds in the P.M. peak hour. The effectiveness of these measures was determined using
the same methods used to determine the impacts of the proposed project.
Third, the commenter refers to potential traffic impacts at the intersection of Hickey Boulevard and
Longford Drive. This intersection was considered too minor to be included in the Redevelopment Plan
DEPARTMENT OF ECONOMIC
AND COMMUNITY DEVELOPMENT
PLANNING DIVISION
(650) 877-8535
FAX (650) 829-6639
Amendment SEIR because of the relatively low levels of traffic on Longford Drive. Although the
commenter may have valid concerns regarding the intersection, they are not considered significant under
CEQA.
Fourth, the commenter refers to the impacts of the proposed Redevelopment Plan Amendment on the
community, and public knowledge of the proposed project. The impacts of the Redevelopment Plan
Amendment are addressed fully in the original 1993 EIR on the Redevelopment Plan and the Draft SEIR.
The Draft SEIR for the El Camino Corridor Redevelopment Plan Amendment was noticed as available for
public review in the San Mateo County Times on April 24, 2000. The 45-day public review period was
identified as April 24 through May 8, 2000 in the same notice. A joint City Council/Redevelopment
Agency public hearing was held on April 12, 2000 to accept public comment on the Draft SEIR. Notice of
the public hearing was published in the San Mateo County Times on April 1, 2000. As documented in the
Responses to Comments report, comments were submitted by several agencies and members of the
public.
Finally, the commenter's letter appears generally to express concern about the impacts of the approved
Costeo. Please refer to the Master Response regarding Costco in Chapter 13.0 of the SEIR (Responses to
Comments).
M
C c;::?
l.J..' ,...,
> 0-
..--. CI:)
UJ ,
C~ ~
U.. ;:I:;
Ct ~
'"'( t. C: t. I V F n
rr. ,,~ \, " ,-,
City of South San Francisco.
PO Box711,
South San Francisco.
Cclhfornia 94083.
Attention Allison Knapp Wollam
May 8, 2000 .
"00 HAY -8 P 1 :I:lA
Re. EJ Camino Corridor Redevero~nt
SE1R ["'larch 24.2000
OFFICE OF
CITY CLERK
SO. SAN FRANCLSC(.;
Dear Ms. Wollam,
I wouid like responses to the following in regard to Supplemental EIR:
HiCKEY SOULEVARD/JUNIPERO SERRA INTERSECTION: - Table 1 B{page ~ of 2)
Intersection Level of SstVIce PM Peak Hour
Hickey Blvd/P.M.
JUfllpero Serra Existing: C20.5 Adopted 2010: F64.9 Amended 2010: F9a.5
F is defined as: Delav in excess of 60.0 seconds per vehicle which in unacceptable.
Did J get given a wrong set of facts? - pl9aSQ explain how the figures abovQ do not
correspond to the figures below (rom Rajappan & Meyer report requested on August 18,
1999) How did we getto F64.9 in 2010 and then F9B.5. This intersection is 150'away!
Hickey Blvd/North Langford PM. Existing: 813.8 2010w/Costco C15.5
98.5 seconds in the Amended- sure seems like a siqnificant impact to be mitlQated to me
and information that should hav'Z been dillulqed to the pubiic 2nd !lot kept a bia secret .When
the General Plan EIR and Casteo EiR were before us where was this information on the EI
Camino Redevelopment? ~ I understand there was a report in 1993 and a 1 st Amendment and
then everythinq was put on hold in the Summer of 1999- Are not the traffic impacts in this
Redevelopment SEIR relevant to the General Plan and Costeo and should not the overall
traffic impact have been looked into at the time of the General Plan EIR?YES/NO
I fail to see how the mitigation is going to go from F9B.5secS delay to D36,1 secs.delay(
3/14/00 CTG Pg.29) Taking over 60secs. off the delay by just getting rid of a left hand lane of
traffic and making it for through traffic EastboundlWestbound IS expecting fantastic results end I
think is an outrageous statement tMt n~eds further study and I request further analysis and
explanation of this report and proof that this is an actual mitigation that is feasibl~.
We have a blind intersection at South Longford and Hickey, much traffic w:1I be corn.ing off
280 and going down Hickey East to CasteD and you are fully aware of this and I would request.
some comments as to how you are going to slow this traffic down .Can some mitigation in
this regard be put in this SEIR report at this time YES/NO_ Nor:th Langford will have a
protJ!em getting access to Hickey because of increased traffic and the right turn from Junlpero
Serra - can this be resolved also by mitigation at this time?YES/NO.
! feel ttlis Redevelopment 1=1 Camino Corridor is t,Joinq to have a huqe imoac:t on OUi
Community . Looking at Page 5.2-15 and seeing that the Existing Plan calls for 88,000 sq. ft of
commer~ial and the Amended is talklnq about 443,eOOsq.ft and office sp~ce of Existin~
13 0005 ft. that oes to Amended of 189 900s .ft. Where is the ublic knowled e of this
ro
owz
RE~~CKNOWLEDGED:
DAiE~~ TIME:
~-4
Uv>
o
V>
Since~ely,
~LKt..~ #.IJ//Jla;..,}; .
/ Jack:e H Williams
t 242 Longford Drive, SSF.,Ca.94080
(650)994-7907
EL CAMINO CORRIDOR
REDEVELOPMENT PLAN AMENDMENT
SUPPLEMENTAL EIR
COMMENTS AND RESPONSES
SCH #1999 032051
LEAD AGENCY: CITY OF SOUTH SAN FRANCISCO
June 2, 2000
.~ PREPARED BY IMPACT SCIENCES
TABLE OF CONTENTS
13.0 Comments and Responses................................................................................. ............. ...13.0-1
A. Governor's Office of Planning and Research............................................................ ..13A-1
B. California Department of Transportation...................................................... ........... 13B-1
C. City jCounty Association of Governments of San Mateo County .................................13C-1
D. County of San Mateo.............................................................................................. ..13D-1
E. Headlee, Helen....................................................................................................... 13E-1
F. Hitchcock, Michael Dean........................................................................... ............. 13F-1
G. Marcopulos, Cynthia.......... ..... ..... ...... ....... ..... ........ ..... ..... ........ .......... ........ ..... ...... ..13G-1-
H. Mason, Donald and Sofie .... .................................................................................... 13H-1
I. Scafani, Frank.. .......................................................................................... ..............131-1
J. Wiliams, Jackie............ ...... ................. .......... ........ ..... ........ ..... .................. ..... ......... 13J-1
14.0 Revisions to the Draft SEIR............................... ............................................................ ..14.0-1
i
El Camino Corridor Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
13.0 COMMENTS AND RESPONSES
A. INTRODUCTION
This chapter contains copies of all letters received during the public review period for the Draft SEIR
and written responses to those comments. Each comment in each letter is keyed by number on the copies
of the letters. Responses to each of the numbered comments contained in a particular letter can be found
on the pages immediately following that letter.
Text changes resulting from comments on the Draft SEIR, as well as staff-initiated text changes, are
presented in Chapter 14.0, Revisions to the Draft SEIR, by chapter and section.
This chapter and Chapter 14.0, together with the Draft SEIR, constitute the Final SEIR for review and
consideration for certification by the City of South San Francisco as complete and adequate under
CEQA.
B. COMMENTS AND RESPONSES
B1. Master Response
This response addresses the following comments: E-1, E-4, F-2, F-4, F-5, F-7, G-2 through G-7, G-9, G-10,
H-l, 1-1 and J-2.
A number of commenters discussed the Costco, in terms of its merits, its impacts, and alternatives to its
development. As noted on p. 3.0-6 of the Draft SEIR, the City Council conditionally approved the
Costco project in December, 1999, and approval of the Costco became final on March 7,2000 following a
voter referendum. Therefore, Costco is an approved project, and its construction is not affected by the
proposed Redevelopment Plan Amendment. As shown in Table 3.0-1, the Costeo would be constructed
under either the Approved Redevelopment Plan or the Amended Plan. If the Redevelopment Plan
Amendment were not approved by the City, the land use designation for the Costco site would need to be
modified to reflect the approved Costco, but construction of the Costco would still proceed.
The Draft SEIR analyzes the impacts of the Costco as a cumulative project, that is, it is a reasonably
foreseeable project and thus assumed to be built. The impacts of the Costeo are not, however, part of the
project-specific impacts of the Redevelopment Plan Amendment. These impacts pertain only to those
changes that would occur as the result of approval of the Amended Plan. Impacts of the Costco were
addressed in the EIR prepared for that project and certified in November 1999.
13.0-1
El Camino Corridor Redevelopment Plan Amendment
Camments and Responses
June 2, 2000
. 13.0 Comments and Responses
Several commenters referred to differences among the traffic analyses in the General Plan EIR, the EI
Camino Corridor SEIR, and the Costco EIR. In essence, the Draft SEIR assumed a more conservative
development scenario for the project area in that it included development in the Plan Area, City-wide,
and th~ large redevelopment projects from the City of San Bruno, the General Plan build-out from the
City of Brisbane, and development from Pacifica. The General Plan EIR addressed City-wide
development lIDder Plan buildout, and the Costco EIR considered the Costco project plus development
area-wide. The City of South San Francisco cannot control the development that occurs in other cities;
however, the City has taken this development into account when analyzing the traffic impacts at (and
identifying mitigation for) intersections within the City.
Commenters also noted confusion regarding the trips generated by the Costco. The estimate of 11,000
trips refers to net new trips on the local roadway system. These are trips that would actually appear m
the roadways as the result of the Costco store and gas station. The figure of 14,900 refers to the gross
trip generation from the Costco store and the Costco gas station, when counted separately. The trips
that would appear on the roadway network would be lower because some trips to the Costco or gas
station would be combined. A person driving to the Costco, getting gas, and then leaving would be
cOlIDted as two separate gross trips (one to the Costco and one to the gas station), but as only one net new
trip on the roadway network. Therefore, the Draft SEIR correctly accounts for the trips generated by
the Costco.
H2. Individual Comments and Responses
Comment letters and individual responses are presented on the following pages.
13.0-2
EI Camino Corridor Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
Grav Davis
J
GOHRC';OR
8
STATE OF CALIFORNIA
..60fP~4<
.~~~
IS * ~
ffi ...-. E
~~~~
~o(l-"
.., OF cAllt-.
Governor's Office of Planning and Research
State Clearinghouse
May 10, 2000
RECEIVED
MAY 1 5 2000
PLANNtNG
Loretta Lvnch
J
DIRECTOR
Allison Knapp Wollam
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94083
Subject: EI Camino Corridor Redevelopment Plan Amendment
SCH#: 1999032051
Dear Allison Knapp Wollam:
The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the
enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that
reviewed your document. The review period closed on May 8, 2000, and the comments from the
responding agency (ies) is (are) enclosed. If this comment package is not in order, please notify the State
Clearinghouse immediately. Please refer to the project's eight-digit State Clearinghouse number in future
correspondence so that we may respond promptly.
Please note that Section 211 04( c) of the California Public Resources Code states that:
"A responsible or other public agency shall only make substantive comments regarding those
activities involved in a project which are within an area of expertise of the agency or which are
required to be carried out or approved by the agency. Those comments shall be supported by
specific documentation,"
These comments are forwarded for use in preparing your [mal environmental document. Should you need
more information or clarification of the enclosed comments, we recommend that you contact the
commenting agency directly.
This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft
environmental documents, pursuant to the California Environmental Quality Act. Please contact the State
Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process.
Sincerely,
~~'<
Terry R~erts t
Senior Planner, State Clearinghouse
Enclosures
cc: Resources Agency
1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812-3044
916-445-0613 FAX 916-323-3018 \\i\"l;TW.OPR.CA.GOV/CLEARINGHOUSE.HTML
13A-l
uocumenl Uelall5 rU~fJun
State Clearinghouse Data Base
SCH#
Project Title
Lead Agency
1999032051
EI Camino Corridor Redevelopment Plan Amendment
South San Francisco, City of
Type eir Draft EIR
Description The existing Redevelopment Plan would be amended to change land uses within the Existing Project
Area from primarily high-density, transit-oriented residential (I.e., 50 units per acre) to a mix of
commercial and high-and medium-density residential uses, ranging from 30 t050 units per acre.
Lead Agency Contact
Name Allison Knapp Wollam
Agency City of South San Francisco
Phone 650-829-6633
email
Address 315 Maple Avenue
City South San Francisco
Fax
State CA Zip 94083
Project Location
County San Mateo
City South San Francisco
Region
Cross Streets EI Camino Real-Between Hickey Blvd & Chestnut Avenue
Parcel No.
Township Range Section
Base
Proximity to:
Highways
Airports
Railways
Waterways
Schools
Land Use
Project Issues
Air Quality; Archaeologic-Historic; Noise; Traffic/Circulation; Other Issues
Reviewing
Agencies
Resources Agency; Department of Conservation; Department of Fish and Game, Region 3; Office of
Historic Preservation; Department of Parks and Recreation; San Francisco Bay Conservation and
Development Commission; Caltrans, Division of Aeronautics; California Highway Patrol; Caltrans,
District 4; Integrated Waste Management Board; Regional Water Quality Contml Board, Rsgion 2;
Native American Heritage Commission; State Lands Commission; Department of Housing and
Community Development
Date Received 03/24/2000
Start of Review 03/24/2000
End of Review 05/08/2000
13A-2
Note: Blanks in data fields result from insufficient information provided by lead agency.
A. GOVERNOR'S OFFICE OF PLANNING AND RESEARCH
A-I. Comment noted.
13A-3
13.0 Comments and Responses
EI Camino Redevelapment Plan Amendment
Comments and Responses
June 2, 2000
STATE OF CALIFORNIA - BUSINESS TRANSPORTATION AND HOUSING AGENCY
GRAY DAVIS Governor
DEPARTMENT OF TRANSPORTATION
POBOX 23660
OAKLAND, CA 94623-0660
Tel: (510) 286-4444
Fax: (510) 286-5513
TOO (510) 286-4454
May 3, 2000
RECEIVED
MAY f 5 2000
PLANNING
SM-082-20.66
1999032051
SM082187
Ms. Allison Knapp Wollam
City of South San Francisco Planning Dept.
315 Maple Avenue
South San Francisco, CA 94083
Dear Ms. Wollam:
Draft Supplemental Environmental Impact Report (DSEIR) for the EI Camino
Corridor Redevelopment Plan Amendment; City of South San Francisco
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the above referenced project. We have examined the
DSEIR and have the following comments to submit:
1. Figure 5.1-11B is a duplicate of Figure 5.1-11A. Please include the missing PM peak 8
hour traffic volumes from Chestnut Avenue north to Mission Road.
2. Figure 5.1-8B and Figure 5.1-10B show that the AM peak hour traffic volume for I
northbound State Route 82 (SR 82, EI Camino Real) through traffic approaching the
Hickey Boulevard intersection has decreased considerably from the existing traffic 8
volumes shown in Figure 5.1-3B. Please explain why the northbound volume on
SR 82 under the Existing and Amended Plan in the AM (and possibly PM) peak
period in year 2010 is much lower than the volumes under the existing Plan
conditions.
3. Similarly, please explain why the northbound volume on Interstate 280 (1-280) under ~
the Existing and Amended Plan in the AM peak period in year 2010 is much lower V
than the volumes under the existing Plan conditions.
4. Hickey Boulevard should be labeled in Figures 1, 2-A, 3-A, 4-A, 8-A, 9-A, 10-A and 8
ll-A of Appendix 5.l.
5. Interstate 380 (1-380) should be shown and labeled on all figures in the document. 8
13B-l
Ms. Allison Knapp Wollam
May 3, 2000
Page 2
6. Freeway analysis for the AM peak period should be provided. e
7. Detailed calculations should be provided for all analyses. B
8. The DSEIR indicates that there is some growth on 1-380 under the Existing Plan
(Updated Analysis) and the Amended Plan in year 2010. A traffic operation analysis 8
should be performed on 1-280 from Avalon Court to 1-380, and should include the
mainline freeways, connectors, and ramps.
9. The methodology [e.g., Traffix or Highway Capacity Software (HCS)] used to a
calculate the level of service (LOS) at all intersections should be included in the ~~
DSEIR.
10. Figure 5.1-7 should include another intersection proposed at EI Camino Real
between Hickey Boulevard and the Hickey Boulevard extension at the entrance to
the planned Costco development.
11. Please be aware that the 4-lane section of SR 82 between Mission Road and Hickey
Boulevard is in need of improvement and that Caltrans is currently initiating a
Project Study Report (PSR) for this project.
12. We understand that the City of South San Francisco has proposed a signal at the
SR 82/ Arlington Drive intersection. Please include a discussion of this signalization
in the DSEIR.
11. Finally, please be aware that any work or traffic control performed within the State
right-of-way will require a Caltrans encroachment permit. To apply for an
encroachment permit, all applicants are required to submit a completed application
with environmental documentation and five (5) sets of plans in metric units to:
G.J. Battaglini, District Office Chief
Caltrans, District 04
Office of Permits
P.O. Box 23660
Oakland, Ca 94623-0660
13B-2
8
8
(3
8
Ms. Allison Knapp W ollarn
May 3,2000
Page 3
Should you require further information or have any questions regarding this letter,
please call Nandini N. Shridhar, AICP, of my staff at (510) 622-1642.
Sincerel y,
HARRY Y. YAHATA
District Director
BY~ce~
JEAN C. R. FINNEY
District Branch Chief
IGR/CEQA
c: Ms. Katie Schulte (State Clearinghouse)
13B-3
13.0 Comments and Responses
B. CALIFORNIA DEPARTMENT OF TRANSPORTATION
B-l. In response to this comment, Figure 5.1-11B has been replaced with the correct figure (please see
Chapter 14.0 of this report for revisions).
B-2. The future numbers would be lower because of the Hickey Boulevard Extension and new BART
station; fewer cars would travel north on El Camino Real in the a.m. peak to get to the BART
station in Colma. The New BART station impact is more magnified in the a.m. peak because
. retail developments would not be open then.
B-3. Crane obtained 1;raffic modeling results from C/ CAG, based on the most recent model run. The
projections for 2010 show a decrease on 1-280; C/CAG cited the BART extension to SFO and a
reduction in commute trips on the freeway.
B-4. Hickey Boulevard is labeled on all of the appropriate figures in Section 5.1, Transportation and
. Circulation, of the Draft SEIR. In addition, Hickey Boulevard is shown on the intersection insets
in the figures referred to by the commenter in the appendix.
B-5. The local traffic study area does not include 1-380, so it does not need to be shown on the figures.
B-6. The SEIR included an analysis of p.rn. peak conditions because they were thought to represent
the highest conditions of the day. The total traffic from all projects combined within the
Redevelopment Plan Area is projected to be substantially higher during the p.m. peak hour than
during the a.m. peak hour.
B-7 In response to this comment, detailed calculations have been sent to the commenter.
B-8. The Amended Redevelopment Plan is a plan-level project; therefore, the study in the Draft SEIR
was conducted at a planrring level of detail with respect to the freeway system. Impacts to 1-280
mainline segments were found to be less than significant m the Draft SEIR.
B-9. Crane Transportation Group used the Highway Capacity Manual 1994 software (TRB Circular
209).
B-lO. The intersection mentioned by the commenter was included in the project-specific EIR for Costco,
and was designed to accommodate volumes projected in that EIR.
B-ll Comment noted.
B-12. The intersection mentioned by the commenter is aT-intersection providing access to a residential
neighborhood west of EI Camino Real. The intersection was considered too minor to be included
in the study.
B-13. Comment noted.
13B-4
El Camino Redevelopment Plan Amendment
Comments and Responses.
June 2, 2000
CCAG
CITy/COUNTY ASSOCIATION OF GOVERNMENTS
OF SAN MATEO COUNTY
Atherton" Belmom II Brisbane II Bur/illgame "Colma " Daly City" East Palo Alw II Foster City · Hal/Moon Bay tI1 Hillsboro/lgh "i14crdo Park" Ali1lbrae
Pacifica" Portola Valley" Redwood City#} San Bruno#} San Carlos II San Mateo" Sall,I,lateo County" South Sail Francisco III Woodside
May 2, 2000
Allison Knapp Wollam, Contract Planner
City of South San Francisco
315 Maple Street
South San Francisco, CA 94083
F~t'~C~E~\iE-
f,'J 2 ~,) 2C-.J
PLANNfNG
Dear Ms Wollam:
RE: C/CAG Airport Land Use Committee (ALUC) Staff Comments on a Notice of
Completion - El Camino Corridor Redevelopment Plan Amendment Draft
Supplemental Environmental Impact Report (DSEIR)
The C/CAG Airport Land Use Committee (ALUC) commented on a Draft EIR for the original EI
Camino Corridor Gener~l!;[llan Art1e'dment and the
letter is attached. The '" ents i at letter are
related to noise imp~pt operations
","2,'
The entire rede~~lo roposedi~ditio . s located outside of the 65
dB CNEL air"ft noi 95 ~q{2bOO F ccepte1!:~oise Exposure
Maps (NEor Sancis nal' y:,ft is also locate e of the 65 dB
CNEL aircraft noise contour, as shown on the quarterly noise map for San Francisco
International Airport, for the fourth quarter of 1999 (quarter ending December 31, 1999).
crevelop~f5nt PI
'1 relevant t" the
-an Franci~~b In
'~~199 . "copy of that
osed arne" dment,
ational Airport.
As mentioned in the DSEIR (page 5.3-14) and the 1993 ALUC comments, the project is and will
continue to be exposed to potentially high single-event noise levels from aircraft departing on
Runways 28 at San Francisco International Airport. The DSEIR indicates the following
mitigation measure was carried over from the 1993 Redevelopment Plan EIR (page 5.3-24):
"F1(c) Aircraft Noise
1 O. As a condition of development approval and/or project assistance, all project-
facilitated residential projects in the project area should be designed to achieve the
necessary exterior-to-interior noise reduction to meet the single-event criterion
limits and the City's interior noise standard. This would require specific studies
at the development stage for each individual project to outline the steps necessary
to comply with the applicable standards."
0)
l'
,ft}
;i~
1f
~.
13C-l
555 COUNTY CENTER, FlFrH FLOOR, REDWOOD CITY, CA 94063 Phone: (650) 599-1406
(FRM0034I.WP6i
FAX: (650) 361-8227
Letter to Allison Knapp Wollam, City of South San Francisco, Re: C/CAG Airport Land Use
Committee CALVC) Staff Comments on a Notice of Completion - EI Camino Corridor
Redevelopment Plan Amendment Draft Supplemental Environmental Impact Report
(DSEIR)
May 2, 2000
Page 2
The text on page 5.3-24 ofthe DSEIR also indicates "no additional mitigation is required" for
aircraft noise impacts.
The 1993 ALUC comments noted the mitigation measure language in the 1993 DEIR related to C-1
aircraft noise was "somewhat vague", regarding the interior noise standard to be achieved.
Therefore, the language in the aircraft noise mitigation measure from 1993 should be replaced with
the requested language in the 1993 ALUC comment letter, as follows:
"As a condition of development approval, all dwelling units constructed in the project shall
be designed to achieve an interior noise level of at least 45 dBA, in all habitable rooms, as
measured for aircraft noise events."
Thank you for the opportunity to review and comment on the DSEIR for the above-referenced
document. Uyou have any questions please call me at 650/363-4417.
David F. Carbone,. ALUC Staff
cc: ALUC Members, w/attachment
C/CAG Board Members, w/attacbment
Attachment
ssfdseir.dfc
13C-2
ATTACHMENT
City/County Association of Governments
of San Mateo County (C1CAG)
County Government Center
590 Hamilton Street 2nd Floor
Redwood City, California 94063
(415) 363-4161
March 11, 1993
Ms. Maur.een Morton, Senior Planner
Planning Division
City of South San Francisco
P.O. Box 711
South San Francisco, CA 94083
Dear Ms. Morton:
SUBJECT: C/CAG Airport land Use Committee (AlUC) Comments on the Draft
EIR for the Proposed E1 Camino Corridor General Plan Amendment
(GP-93-47) and Redevelopment Plan
The C/CAG Airport land Use Committee considered the airport noise portions
of the above-referenced document at its February 25, 1993 meeting. The
Committee's primary concern is the potential aircraft noise impacts on a sub-
stantial number of new dwelling units that could be constructed in the project
area.
The Draft EIR indicates the project area is l~cated outside the 1990 and 2006
aircraft noise contours for San Francisco International Airport (SFIA), as
shown in the SFIA Master Plan EIR (San Francisco International Airoort Master
Plan Draft Environmental Impact Reoort, Volume 1, July 1991). The project
area is also located outside the 65 dB CNEl aircraft noise contour. for. SFIA,
as shown in the 1981 Airport land Use Plan. Although future dwelling units in
the project area are not located directly within the 65 dB CNEl noise contour,
they may be subject to aircraft noise and/or overflight from aircraft using
the Runways 28 Gap Departure procedures.
The Draft EIR indicates single-event aircraft noise levels at the project site
could be as high as 79 dBA (based on field measurements). This is identified
as a significant impact. The Draft EIR includes the following mitigation
measure for aircraft noise impacts:
"As a condition of development approval and/or project assistance,
all project-facilitated residential projects in the project area
should be designed to achieve the necessary exterior to interior
noise reduction to meet the single-event criterion limits and the
City's Interior Noise Standard."
35
13C-3
Ms. Maureen Morton
March 11, 1993
Page 2
This language is somewhat vague regarding the interior noise standard to be
achieved. The aircraft noise mitigation measure should be more specific to
identify the performance criterion to be evaluated in the Mitigation Moni-
toring Program for the project. The C/CAG ALUC suggests the mitigation
measure be revised, as follows:
"As a condition of development approval, all dwelling units
constructed in the project area shall be designed to achieve an
interior noise level of at least 45 dBA, in all habitable rooms,
as measured for aircraft noise events."
The proposed densities in the project area indicate future dwelling units in
the project area will be multi-family units. The 45 dBA interior noise level
requirement in the suggested revised mitigation measure is the same interior
noise level standard required in Title 24 of the California Administrative
Code for new multi-family construction. It is also consistent with the City
of South San Francisco's Noise Element policies for noise sensitive land uses.
Thank you for the opportunity to review and comment on the Draft EIR for
the above-referenced project. If you have any Questions, please call Dave
Carbone, LUC Staff Coordi ator, at 415/363-4417.
Land
RBK/OFC:cdn - OFC00475.ACN
cc: AlUCMembers
C/CAG members
(/
''-..:..::
36
13C-4
13.0 Comments and Responses
C. CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY
C-l. In response to City/County of Associated Governments (C/CAG) comments on the previous
(1993) EIR, the mitigation measure for potential aircraft noise impacts was revised. The Draft
SEIR erroneously did not incorporate the revised language. Therefore, Mitigation Measure 10 on
. p. 5.3-24 of the Draft SEIR has been revised as follows:
10. As a condition of development approval andlor project assistance, all project-facilitated
residential projects in the project area should be designed to achieve the necessary
exterior-to-interior noise reduction to meet the single-event criterion limits (i.e.. 50 dBA
in bedrooms and 55 dBA in other habitable rooms) and the City's interior noise standard
(i.e.. 45 dBA. CNEL). This would require specific studies at the development stage for
each individual project to outline the steps necessary to comply with the applicable
standards.
As noted in the responses to comments on the 1993 Draft EIR, the language proposed by C/CAG
was not included verbatim because it did not address single-event noise impacts.
13C-5
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
Qunty Manager's Office
q,...."-~. ~,......-,.
,.;g.~~~~~e:: ~'~...:~: .it~~ ~K.-r;.l~~~~~f.~;~ ~~~}:
MAY 0 R ?n;OfJ
\.J ,-u. l
E&C'D D'};::PAk'L\iENI'
COUNTY OF SAN MATEO
BOARD OF SUPERVISORS
RICHARD S. GORDON
MARY GRIFFIN
JERRY HILL
ROSE JACOBS GIBSON
MICHAEL D. NEVIN
JOHN L. MALTBIE
COUNTY MANAGER
CLERK OFTHE BOARD
COUNTY GOVERNMENT CENTER. REDWOOD CITY . CALIFORNIA 94063-1662 (650) 363-4123
WEB PAGEADDRESS:http://www.co.sanmateo.ca.us FAX: (650) 363-1916
May 3, 2000
City of South San Francisco
City Hall
400 Grand A venue
P.O. Box 711
South San Francisco, CA 94083
Attention: Marty Van Duyn, Director of Economic & Community Development
Robert Beyer, Economic/Redevelopment Project Manager
Re: Proposed Second Amendment to the Redf!velopment Plan/or El Camino Corridor
13D-l
DSEIR COMMENTS
~ If there is a potential for 483 fewer multiple-family residential units (p.2.0-2), and the actual
removal of8 multi-family units removed (p.7.0-9) then: A) How can it be said that there is to be
no displacement of any housing and thus no significant housing impacts (p.1 0.0-1 O)? and B)
How can Environmental checklist (Appendix 1.0, Initial Study pp. 20-21) be accurate?
_ The references to the County Government Center property are confusing - it is not clear
whether the amendment will change planned land uses or not. For instance at page 3.0-8 the
description of the impact on the amendment to Site 11 and to Site 12 is inconsistent and the
discussion at Dl on page 3.0-11 suggests that the County Government Center parcels would be
affected by the amendment. Clarification is required.
~ The Prelimirnrry Report identifies a hazardous waste site in added Area A (Table 1I-5) and even
identifies remedial testing as a specific project (Table IV -1). How then can the Environmental
Checklist (Appendix 1.0, Initial Study p. 13) say 1ha~ no hazardous waste sites or concerns
exist? .
_ If traffic improved tramc circulation and parking is such an important part of the Area B
programs and projects, why is no discussion at all in the EIR with regard to traffic, parking or
circulation at Nora Way, Sandra Court, Brusco Way, and Susie Way (only Willow and Grand is
examined with regard to traffic).
13D-2
I
0)
I
I
E(
I
Y
e
I
13.0 Comments and Responses
D. COUNTY OF SAN MATEO
D-1. The potential for fewer multi-family residential units is not an actual reduction in the existing
number of units but rather is a reduction in the future number of additional units that could be
constructed. The Initial Study checklist refers to the displacement of substantial numbers of
existing housing. See also the response to Comment F-1 of the letter from Michael Hitchcock.
The Initial Study does address the loss of between four and eight residential units in the Willow
Gardens neighborhood, and notes that under California redevelopment law, the Redevelopment
Agency would be required to provide relocation assistance and replacement housing to all
displaced residents. The Agency's Five-Year Implementation Plan indicates that such
replacement housing is feasible. For these reasons, the project would not have any significant
impacts.
D-2. The Draft SEIR is consistent with respect to the County Government Center. In Table 3.0-1, Site
11 is noted as the County Government Center 1. The existing land use on the site is the County
Government Center. The land use allowed under the approved Redevelopment Plan is
residential. The land use allowed under the Amended Redevelopment Plan would be the
existing land use, i.e., the County Government Center. Although the existing land use would not
change, the proposed project would affect this parcel (in comparison to the approved
Redevelopment Plan) by changing the uses allowed on the site.
D-3. The Initial Study states (p. 13) that the General Plan Existing Conditions and Planning Issues
Report lists 114 known sites with leaking underground storage tanks, and that some of these sites
are along El Camino Real. Two of the three sites identified in the Preliminary Report are along El
Camino Real. The Initial Study also notes that should suCh sites exist within areas proposed for
redevelopment, cleanup would be required according to existing law before such sites could be
occupied. These requirements would apply to the sites identified in the Preliminary Report.
D-4. Under CEQA, the EIR is required to focus on significant impacts. The project would not result in
an increase in the traffic generated by or within the Willow Gardens neighborhood, and the
current parking/unit ratio of 1.5 spaces per unit would be maintained. In addition, circulation
within the neighborhood would be improved through the addition of the one-way street along
the eastern boundary. For these reasons, the EIR does not focus on traffic and parking impacts at
Willow Gardens.
13D-3
EI Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
115 Duval Drive
South San Franciscol CA 94080
May 61 2000
City of South San Francisco
Redevelopment Agency
P.O. Box 711
South San Franciscol CA 94083
"~"_.'.""'--l'\ "'''''''''';'G'''l,''''7-:-rl~~~
.~~~;~r;J~j~'::'~.'f~::,f' j.t~~j~ .~, ,,~~...4',~1..~
MAY v 8 /UUU
Attn: Allison Knapp Wollam
E ,.. ".". "i\'liV-~~". 1i:D"".ll.'. ~.f.f1{""'rrr
Cll.:U jUlJi!JCfiJt"l!. n'.ilDl'
Dear Members of the Redevelopment Agency:
I challenge the El Camino Corridor Redevelopment Plan
Amendment SCH 1999 032051. DRAFT SUPPLEMENTAL EIR
South San Francisco has not taken into consideration the
older citizens of the community who have acquired certain
ailments. Being a resident of Winston Manor 11 I know I am going
to be a prisoner in my own home by the City never lobbying the
airport for the funds to upgrade our homes with insulation and
double-paned windows I having the barrage of airplane noise forced
upon us at all times of the day and night.
Now I the City, going against the recommendations of the
Planning Commission, who twice turned down the Costco project,
will be introducing 14,000 more cars per day to our area. Not
only will this have a significant adverse impact on the roadways,
but the air pollution it will generate for those of us with
compromised health conditions will be insurmountable.
With the installation of stoplights on Hickey and El Camino,
the residents of Winston Manor 1 will be forced to enter only on
Hilton since they will not be able to turn left from El Camino
onto Arlington.
Costco, with its traffic congestion, is an ill-conceived
plan.
Very truly,
1~7~
HELEN HEADLEE
13E-l
B
B
8
e
13.0 Comments and Responses
E. HELEN HEADLEE
E-1. The commenter's concern about the impact of aircraft noise levels on her home is noted.
Howe~er, the commenter's home is not within the Existing or proposed Added Redevelopment
Plan Areas. Therefore, the commenter's concern is not related to the content of the Draft SEIR.
E-2. Please see the Master Response with respect to Costco at the beginning of this chapter. As noted
therein, the net trip generation from the approved Costco and gas station would be about 11,000
trips, not 14,000 as mentioned by the commenter. The traffic and air quality impacts of the
Amended Redevelopment Plan are addressed in the Draft SEIR. As shown in the Draft SEIR, all
traffic impacts would be reduced to a less-than-significant level with the mitigation measures
identified in the SEIR. The Amended Plan would contribute to significant regional air quality
impacts, and these impacts have already been identified by the City in the General Plan Update
EIR.
E-3. The City is planning to install a signal at the EI Camino Real! Arlington intersection (this
improvement is not related to the Amended Redevelopment Plan). Therefore, left turns should
not be an issue.
E-4. Please see the Master Response with respect to Costco at the beginning of this chapter.
13E-2
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
Michael Dean Hitchcock Urban Geographer
1508 Redwood Avenue, Redwood City, CA 94061 Phone/Fax: 650.365.6019 amaH: [email protected]
May 7, 2000
R. E,),"-' ,:'~'" 'i", " '
. fIr ~ ;It. -~...... :i~ '!.i"
~'~'~'''-'
City of South San Francisco
Redevelopment Agency
PO Box 711
South. San Francisco, CA 94083
Attention: Allison Knapp W oUam
Re: EI Camino Comdor Redevelopment Plan Amendment Draft Supplemental EIR
The Draft Supplemental EIR for the EI Camino Corridor Redevelopment Plan
Amendment (DEIR) does not adequately address the following issues:
MAY 0 8 2000
E&~C]!) DEPARTMENT
1. Effects of the loss of 483 residential units
The DEIR states that the amended plan would "result in the development of 483 fewer
multi-family residential units" (page 1.0-1) but does not adequately consider the local or
regional effects of1his change. The DEIR apparently assumes that if these 483 units are
not built, then 483 households simply disappear from the environment. TIus is clearly not
the case. The existence of a'market demand for these 483 (and more) units indicates a
desire on the part of households to live in South San Francisco. They may desire to be
there for proximity to jobs, family, established relationships, or many other reasons, but
the desire to be in this location is not eliminated by the amendment of the redevelopment
plan to eliminate these units. Reducing the supply of housing does not reduce the demand.
V&ere then do the 483 households denied the opportunity to live in the redevelopment
project area go? Some will crowd into existing housing in the project area or nearby,
moving in with relatives, sharing with friends, or illegally converting single-family units to 0
multi-family use. The overcrowding and illegal conversions that result will have a negative 0
enviromnental impact and conflict with the project objective of "The elimination and
prevention of the spread of blight, non-confonlling uses and deterioration...." The loss of
1hese 483 units will increase blight and non-confonning uses, rather than eliminate them.
Those who choose to avoid overcrowding in the immediate area will find housing farther
away and drive to their destinations in South San Francisco, creating negative
enviromnental impacts for the region. Open space will be converted to housing and
shopping facilities on the margins of the Bay Are~ and additional highways will be
cons1ructed to move people to work. Opportunities for walking to work or taking public
1ransit will be reduced. None of these crunulative regional impacts are addressed in tbe
DEIR.
2. South San Francisco's ability to provide for its fair share of regional
housing needs
Objective 8 of1he El Camino Corridor Redevelopment Plan is: "The development of a
spectrum of housing types affordable to various segments of1he community in a manner
consistent with the Housing Element of the General Plan...." This objective is a
13F-l
Comment re: EI Camino Corridor Redevelopment Plan DEIR .
May 7,2000
restatement of requirements imposed by the State housing element law (Goven1ll1ent Code,
Article 10.6). The change of use from residential to retail proposed in the plan amendment
may limit the City's ability to meet the plan objective and the requirt:ments of Slate law.
Was the Costco site oue of the sites identified for housing ill the current housing element?
Are the 483 units 1hat will be lost listed in the City's quantified objectives? Will the
housing element be amended to reflect the loss of this site and these units for potential
housing development? Will the City have to provide for higher density on alternative sites
to maintain a certified housingelemellt? What will be the envirOlunental effects of changes
necessary to maintain adequate sites for housing? None of1hese questions are adequately
addressed in the DEIR.
3. Cumulative effects of the measures to mitigate traffic effects
It is a standard practice in environmental review to identify traffic impacts and then to
propose increases in highway capacity as a means to mitigate the traffic impacts. 111ere is
seldom, however, any analysis ofthe cumulative effects ofthese mitigation measures. This
DEIR is no exception; it assumes tha.t building more roads will solve traffic problems,
without examining the role of road building in creating traffic problems. Increasing
highway capacity will increase traffic by its effect on the decision to drive. If there is more
room on the highways, more people will choose to drive. The so-called "mitigation"
measures will have their own traffic impacts that will then need to be further mitigated.
Attempting to solve traffic problems by increasing roa.d capacity spirals on to more traffic,
more roads, more traffie, etc. This process is not addressed in the DEIR; it is simply
assumed that building more roads will solve traffic problems, despite thc past experience
to the contrary.
4. Regional impacts on public transit use
The DEIR states: "According to appendix G of1he CEQA Guidelines... a project could
have a significant effect on the enviromnent when it would: ... Conflict with adopted
policies, plans or programs supporting altemative transportation." (pages 5 .1-30 to 5 .1-31)
However, the DEIR does not consider the project in relationship to regional planning for
alternative transportation. Nowhere in the plalming literature relating to transit-oriented
development could you fInd support for a big box retailer such as Costco as an appropriate
land use adjacent toa BART station. Indeed, tlns is close to tlle worst possible land use on
this site. The decision of tile City Council to reject a transit village concept for this site and
choose Costeo represents a complete disregard for regional planning for alternative
transportation. The DEIR does nothing to remedy tI1is lack of consideration for regional
transportation planning either in plans for the regional BART network or the San Mateo
County Congestion MaJ.1agemellt Plan. The region-wide negative impacts 011 public transit
should be carefully considered in the DEIR. .
5. Inadequate analysis of the effects on freeway operations.
The DEIR states: "The 1993 EIR did 110t find any significant impacts with respect to
freeway operations." (page 5.1-33) The amended pIau, however, includes a large-scale
retail operation by a major chain with regional and national advertising. Large stores such
as Costco must of necessity draw from a large market are~ willi an attendant increase in
freeway traffic. These effects are sigtnficantly greater than the effects of the altemative
Michael Dean Hitchcock
Page 2 of3
13F-2
F-2
F-3
F-4
l
~
Comment re: El Camino Corridor Redevelopment Plan DEIR
ivlay 7,2000
project considered in the 1993 EIR and would require a much more extensive analysis of
freeway impacts.
G. Analysis of trip generation for residential and non-residential
development
The DEIR states: "For new residential and office development, all trips would be newly
added to the local roadway network." (page 5.1-39) The assumption that al11rips
associated with residential development would be newly added is clearly in error. As
outlined in Part 1 above, whether or not residential units are built as a part of this project
does not effect the desire of households to live in the project area. Some proportion of the
residential trips are attributable to persons who currently live in overcrowded conditions
within the project area and would simply moving from an existing unit to a new one.
These would not be new 1rips, but are in fact already existing trips. Another portion of the
trips will be taken by people who currently live farther away and would, as a result of
residential development in the project area, move closer to their jobs. Some may move
close enough to walk to work, other may be moving close to a BART station in order to
take public transit to work. For this segment of the population the construction of housing
in the project area may actually result ill a reduction in trips on the local road network
rather than an increase.
B
7. Inadequate consideration of alternatives
Given that 1here was a competing plan for the Costco site-the "transit village plan-the
DEIR should in all considerations evaluate the redevelopment plan amendment in
comparison to this alternative. TIle comparison should include both local and regional
impacts, and the cumulative impacts and growth-inducing impacts of the plan. South San
Francisco is passing up an opportunity to take a bold leap intO' the future in order to cling
to a failed path, moving the region further 011 the spiral of more roads and more traffic. An
adequate consideration of1he environmental impacts of the proposed project in
comparison to the alternative would clearly reveal thalthis proposed amendment is an
environmental disaster, not only for the City of South San Francisco, but for our region
and our planet.
Sincerely,
F.7
~J)~~
Michael Dean Hitchcock
Michael Deatt l-litchcock
!Jag\! ) 01':3
13F-3
F. MICHAEL DEAN HITCHCOCK
F-1. The land uses analyzed as part of the Amended Redevelopment Plan. are consistent with the
General Plan, approved by the City in 1999. The General Plan notes (p. 2-23) that projects with
(then) current development approvals include about 1,150 housing units. The application of
average assumed densities under the approved General Plan would allow for the construction of
an additional 1,630 housing units. Buildout will result in the addition of 2,780 h~using units to
the City's current inventory of an estimated 19,400 housing units, for a total of 22,180 units.
The City is currently working with ABAG to determine its fair-share housing allocation. Once
the number of housing units allocated to the City is finalized, the City has one year to update the
General Plan Housing Element, in accordance with State law. The City is in the process of
amending the General Plan and anticipates completion and certification of the amendments in
the year 2001. The amended (1999) General Plan provides policies that encourage new housing
development by establishing higher density standards in other areas throughout the City,
including the Downtown Residential area near the Caltrain station; establishing Transit-Oriented
Development areas near the South San Francisco and San Bruno BART Stations; and establishing
a Loft Overlay District in the older industrial area in order to create additional live-work space
while still providing for densities for up to 50 dwelling units per acre in the El Camino Corridor
area.
The commenter is correct in noting that the provision of fewer housing units within the
Amended Redevelopment Plan area could result in the shifting of (future) population to other
locations. An analysis of the impacts of future population growth within the City has already
been conducted, as part of the Environmental Impact Report for the updated General Plan. This
EIR was prepared on the basis of those General Plan land use assumptions and is, therefore,
consistent with the General Plan Update EIR. It would be speculative to determine to what
extent people who might have lived in the Redevelopment Plan area would move to locations
outside the City, where those locations would be, and the corresponding impacts.
F-2. See the response to Comment F-1, above. The City is currently updating its General Plan
Housing Element, in accordance with State law; the Housing Element will be amended to be
consistent with the recently approved General Plan. The comment regarding the ability of the
proposed project to meet its objectives addresses the merits of the project and not the content or
adequacy of the EIR under CEQA. See also the Master Response regarding use of the Costco site
at the beginning of this chapter.
F-3. The mitigation measures identified in the Draft SEIR (see Section 5.1, Transportation and
Circulation) include, for the most part, signalization, signal phasing, and the restriping of
roadways within their existing curb-to-curb widths. Widenings are identified in selected
locations to provide additional turn lanes for the approaches to intersections. An extension of
13F-4
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
13.0 Comments and Responses
Oak Avenue is identified as an alternative mitigation measure for impacts to the intersection of EI
Camino Real/Westborough Avenue/ Chestnut Avenue; the potential impacts of the extension
are identified generally, as the exact alignment is not known at this tinie. The type of major
roadway construction implied by the commenter is not included in the EIR. All of these
measures have been identified to alleviate congestion based on projected traffic volumes,
including traffic to be generated by the proposed uses within the Amended Redevelopment Plan
area as well as other planned uses within the City. Some people may choose to drive instead of
taking transit if there is less congestion; again, however, this impact is already reflected in the trip
generation rates used in the traffic analysis, These trip generation rates do also account for the
proximity of some uses to the Hickey BART station.
F-4. The comment generally refers to the merits of constructing the approved Costco next to the
Hickey BART station, and not to the content or adequacy of the ElR. See also the Master
Response regarding use of the Costco site at the beginning of this chapter.
F-5. The freeway impacts of the Amended Redevelopment Plan are addressed in the Draft SEIR; see
pp. 5.1-45 to -46 and 5.1-59 to -60. The Draft SEIR notes that overall, projected 2010 levels of
service for 1-280 and 1-380 with Amended Plan volumes are better than those projected in the
1993 EIR, and that projected operating conditions under the Amended Plan would be within the
CMP level of service standards for both freeways. See also the Master Response regarding use of
the Costco site at the beginning of this chapter.
F-6. The commenter has not presented any evidence regarding the desires of people to live within the
Amended Redevelopment Plan area, or how such desires might be affected by the construction of
housing. Regardless, the Draft SE1R includes an analysis of existing trips on the local
transportation network, based on a series of counts taken in 1998 and 1999. It would be
speculative to determine how many of the new housing units would be occupied by people
already living within the traffic study area. It would also be speculative to determine how many
people would be moving into the study area to be closer to their jobs and of those, how many
already travel within the study area. Therefore, the Draft SE1R conservatively assumes that all
trips would be new trips.
F-7. Please see the Master Response regarding use of the Costco site at the beginning of this chapter.
13F-5
EI Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
1R) ~~C.~r .s~$~ 1;f"".
<.::l:.-..:....,;1,;-:P L,w;-::- :,-~.:dT.!1J
HAND DELIVERED
Cynthia Marcopulos
106 Sutton Avenue
South San Francisco;, CA 94080
May 5, 2000
MAY 0 8 /ulJU
.I.:"; ,i~~t~D DEP AX:f.~ ,_-..::uE;f\~'r~f
City of South San Francisco
Redevelopment Agency
P.O. Box 722
South San Francisco, CA 94083
Attn: Allison Knapp Wollam
Members of the Redevelopment Agency:
I hereby challenge the El Camino Corridor Redevelopment Plan Amendment,
SCH#1999 032051. DRAFT SUPPLEMENTAL EIR
Under 3.0 Project Description, B. Project Objectives, Item 1, it states, "The elimination
and prevention of the spread of blight, non-conforming uses and deterioration and the
conservation, rehabilitation and redevelopment of the Project Area in accord with the General
Plan, future specific plans, the Plan and local codes and ordinances, as they now exist or may
hereafter be amended."
I hereby challenge this for the following:
1) This project did not calculate the traffic generated through the corridor due to Kaiser
Hospital and the BART station.
e
2) The construction ofthe Costco big box store will accelerate the spread of "blight"
and a "non-conforming" land use as directly across from the Costco site is the up scaled housing
development, the Promenade, as well as the adjoining residential neighborhoods. By allowing
recent development of housing in this area, the land use was changed from retail to residential.
B
3) The "blight" will be the environmental degradation from the 14,000 cars traversing
the corridor daily, the release of the gasoline additive MTBE into the water and the air caused by
Costco's unattended 16-pump gas station and the spillage by customers overfilling their gas
8
13G-l
Redevelopment Agency
May 5, 2000
Page 2
tanks; the numerous abandoned oversized shopping carts littering the neighborhoods; the
wee-hour rumblings of 40-foot tractor trailers delivering product to restock Costco when it is
closed to the public; the numerous trips by tanker trucks hauling thousands of gallons of highly
flammable and toxic fuel through our neighborhoods, near Kaiser Hospital and EI Camino High
School, traversing the roadways, jockeying for position during our early morning commuter
traffic.
By the shortsightedness of the City Council in supporting Costco in the recent
referendum, it has negated the Project Objectives, Item 2, "The achievement of an environment
reflecting higher level of concern for architectural, landscape, urban design and land use
principles appropriate for attainment ofthe objectives of this Plan and the General Plan, as they
may now exist or may hereafter be amended."
How can this land use "meet the NEEDS of. . . the City and ITS CITIZENS" (project
Objectives, item 3)?
1) Through Federal and local taxation, taxpayers are spending billions of dollars on
BART hoping to alleviate the grid lock ofthe horrendous commuter traffic the Bay Area is
experiencing. With BART eventually running to San Jose, the construction oflight retail,
hotels, conference centers, restaurants, housing and day care would take more people off the
roadways and eliminate the traffic congestion by having a transit-oriented community at the El
Camino Corridor. Thus, for example, working people would use BART to travel to and from
their jobs in San Francisco or through San Mateo County, or business people arriving at SFO
would use the BART system in this area, obtain accommodations at the hotels on site, dine at the
on-site restaurants, travel to San Francisco or the rest of the Peninsula by BART to conduct their
business.
Instead, while the rest of the Bay Area is turning toward transit communities, South San
Francisco will be causing further adverse traffic impacts, and an unhealthy living and working
environment. With the explosion of the Bay Area with the influx of people and the increase of
vehicular traffic, South San Francisco missed the opportunity for a well thought out, planned
transit community, instead of a rush for revenue.
In rebuttal to Items 4, 5,6 and 7 of Project Objectives, as WalMart killed Main Street
America, Costco will devour all the small businesses on the EI Camino and surrounding areas. It
13G-2
8
8
8
~
Redevelopment Agency
May 5, 2000
Page 3
will not create nor develop new jobs, but relocate their current employees from the South Airport
Boulevard and San Bruno stores. The "preservation of the area's existing employment base" will
be nonexistent. Planning Commissioner Marc Teglia stated that South San Francisco is the
landlord on the South Airport Boulevard Costco store and there is five years remaining on the
lease, thus causing a loss to our city of one million dollars in annual income with its move to the
El Camino Corridor.
With reference to Project Objectives, Item 8, the "development of ...housing" with a well
thought out plan, the transit village would have provided the "affordable" housing which is in
great demand throughout the Bay Area.
Item 9 of the Project Objectives, the "elimination or amelioration of existing substandard
vehicle circulation and parking systems; inadequate infrastructure; insufficient off-street parking;
and other similar public deficiencies adversely affecting the Project Area," at the May 13,2000
Community Outreach meeting held at El Camino High School, Chief Raffelli and Councilman
Mullin both stated that the overflow parking from BART would impact Sunshine Gardens and
the Promenade, thus compelling the city to issue residential parking permits for residents in the
area and the patrolling of the areas so that the parking code is enforced.
What was purposely eliminated from this study is the traffic generated by Kaiser Hospital
and the BART station which will inhibit the flow of vehicular traffic causing the LOS C and D
intersections to be downgraded to LOS E and F ratings. The thousands of tractor trailers
delivering gasoline and goods to Costco and the additional 14,000 cars on the same roads will
slowly degrade the roadways.
T
8
G-B
By burying BART, Item 10, Project Objectives, South San Francisco believes it will J
"ensure that the Project Area meets its full development potential upon the removal of existing
G-10
blighting conditions." It will enhance the area by putting BART underground, but the true blight
is the big box Costco and its noise, air and water pollution and the congestion that will come
with it.
Under the Amended Redevelopment Plan, page 3.0-2, the first two goals 3.?d objectives
are negligible. The City had ample opportunity to turn the OWone Shell mound and burial
ground on San Bruno Mountain into an educational and cultural center; the city had the
opportunity to turn the last two-thirds of San Bruno Mountain into open space or incorporate it
13G-3
Redevelopment Agency
May 5, 2000
Page 4
into the State Park system; the city could have converted the Colma Creek back into its original
state of a living creek, instead of a concrete culvert; the city could have constructed a performing
arts building attracting people from allover the Bay Area near the BART station with its on-site
restaurants and hotels and light retail.
After reviewing the EI Camino Corridor Redevelopment Plan Amendment as well as the
EIRs for the Costco project and the Terrabay project, it is puzzling how any of you still are
employed in your present positions.
Very truly,
J ~~. ...:.:7
~'~ )J;~'//. ' .~.
:,// "./'''/: /./
! !
,/ CYNTHIA MARCOPULOS
13G-4
13.0 Comments and Responses
G. CYNTHlA~RCOPULOS
G-l. Existing trips to and from the Kaiser Hospital are already reflected in the existing traffic counts
used in the Draft SEIR. As shown on p. 3.0-8 of the Draft SEIR, there would be no changes to the
existing land uses on the Kaiser site. Therefore, Kaiser was not included in the generation of
additional trips shown in the Traffic and Circulation section of the EIR.
The BART station itself is a separate project sponsored by BART, and thus is not part of the
Redevelopment Agency project. Expected trips to and from the BART station (taken directly
from the environmental analysis conducted by BART) were included in the future traffic
assumptions used in the SEIR traffic analysis.
G-2. Please see the Master Response with respect to Costco at the beginning of this chapter.
G-3. These comments appear to refer to the project-specific impacts of the approved Costeo. Please
see the Master Response with respect to Costco at the beginning of this chapter.
G-4. This comment pertains to the merits of the Costco project and the merits of the Amended
Redevelopment Plan, and not to the content or adequacy of the Draft SEIR under CEQA. Please
also see the Master Response with respect to Costco at the beginning of this chapter.
G-5. This comment appears to pertain to the merits of the Costco project, and not to the content or
adequacy of the Draft SEIR under CEQA. The traffic impacts of the Amended Redevelopment
Plan are addressed in Section 5.1 of the Draft SEIR. Please also see the Master Response in with
respect to Costco at the beginning of this chapter.
G-6. This comment appears to pertain to the merits of the Costco project, and not to the content or
adequacy of the Draft SEIR under CEQA. Please also see the Master Response with respect to
Costco at the beginning of this chapter.
G-7. This comment pertains to the merits of the Costco project and the merits of the Amended
Redevelopment Plan, and not to the content or adequacy of the Draft SEIR under CEQA. Please
also see the Master Response with respect to Costco at the beginning of this chapter.
G-8. This comme:nt pertains to the parking.impacts of the Hickey BART station on existing uses within
the City, and to those impacts relative to the merits of the proposed project. The comment does
not relate to the content or adequacy of the Draft SEIR under CEQA.
G-9. See the response to Comment G-1, above.
As noted in the Master Response for Costco, the correct trip generation number is 11,000 net new
trips, not the 14,000 referred to by the commenter.
G-10. Please see the Master Response with respect to Costco at the beginning of this chapter.
13G-5
EI Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
13.0 Comments and Responses
G-ll. This comment pertains to the merits of the project objectives, and not to the content or adequacy
of the Draft SEIR under CEQA.
13G-6
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
~t ~P"1: '!},L""l""'''' .,,_~
Jtl.,~.&.d.1'~;'~"-:::t' tti_~f rt.,.n~"'~\l;~,;
'H'-l:.C.,"S " lit' ""i~lt;f
MAY 0 8 2000
DONALD E. & SOPHI~ MASON
10 ARLINGTON DRIVE
SOUTH SAN FRANCISCO, CA. 94080
IE i~,r..j....7) .~
. f;:;.';t._U lJEPl~ ~;;)Tr"'E>.pp"
.. ~'l:._~.'l:.._,i.. -,.?"J~ l\~ 11.'
City of South San Francisco
and Members of the City Council
May 5, 2000
Re: El Camino Corridor
Redevelopment Plan Amendment
Draft Supplemental EIR
Dated March 24, 2000
We write this ~etter to challenge the above report.
1. Transportation and Circulation:
On page 5.1-51 it states that the daily trip generation ~
for Costco is 14,994. Yet, the information preserited to ~
the voters before they voted was first 8,000 daily trips
and then amended to 11,000.
In the Draft ErR report dated April, 1999 it states that
the current average daily traffic (ADT) at he Costco site
is 24,500 vehicles. Originally the Costco was to add 8,000
vehicles or an increase of 32.65%. The total was increased ~
to 11,000 or 44.90% increasp.. This is the total the voters
were aware of when ,they voted. Now the increase is 14,994
vehicles or an increase of 61.20%. Nowhere in the Trip
Generation under 5.1-51 does it show Kaiser Hospital or
BART.
2. AIR QUALITY:
Since the traffic in the report increased by 16.30% over
what the voters were aware of when they voted the air quality ~
would also be adversly affected more than they were made.
aware of.
3. Noise:
The same applies to noise levels.
The voters of South San Francisco were mislead before they voted.~
If this report dBted March 24, 2000 had been available to the ~
voters prior to their voting on March 7,2000 it very well could
have changed the outcome of the vote on Measure B.
13H-l
-2-
City of South San Francisco
and Members of the City Council
This is our challenge to this report.
~~t! 1a~n /1l a/d &J1
---~+L )~~."J
Sophie Mason
13H-2
H. DONALD AND SOPIDE MASON
H-l. Please see the Master Response with respect to Costco at the beginning of this chapter.
H-2. Existing trips to and from the Kaiser Hospital are already reflected in the existing traffic counts
used in the Draft SEIR. As shown on p. 3.0-8 of the Draft SEIR, there would be no changes to the
existing land uses on the Kaiser site. Therefore, Kaiser was not included in the generation of
additional trips shown in the Traffic and Circulation section of the EIR.
The BART station itself is a separate project sponsored by BART, and thus is not part of the
Redevelopment Agency project. Expected trips to and from the BART station (taken directly
from the BART environmental analysis) were included in the future traffic assumptions used in
the SEIR traffic analysis.
B-3. As noted in the Master Response with respect to Costco, the correct trip generation number is
11,000 net new trips, not the 14,994 referred to by the commenter. The air quality and noise
analyses in the Draft SEIR are based on the correct trip generation numbers.
H-4. This comment pertains to the timing of the Draft SEIR relative to the referendum on the Costco,
and not to the content or adequacy of the SEIR under CEQA.
13H-3
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
Frank Scafani
540 Acacia Avenue
San Bruno, CA 94066
May 5, 2000
City of South San Francisco
Redevelopment Agency
P.O. Box 711
South San Francisco, CA 94083
"'1?"ofY' ;?';::!>'n.\ ~:!1'
- CE" "'j,' '~fj' ~,'" ~'"~
Rlf "". "". ,."" ....
. ., '- ~. ~ J"",~~'" '.:I,.......
.....~' ~
MA'i 0 8 'LOOO
Attn: Allison Knapp Wollam
~. .i,nf'\~ l'ri;lr:P'B'
E&CD DEPAildV.",b;'I\l
Dear Members of the Redevelopment Agency:
I challenge the EI Camino Corridor Redevelopment Plan Amendment SCH#1999
032051. DRAFT SUPPLEMENTAL EIR
As a taxpayer, I am appalled that my tax dollars go for transit systems to take cars off our
highways and streets, yet South San Francisco, with a golden opportunity to make a statement of
how a city could incorporate high tech transit with a well-thought out development, takes the low
road on this issue by planning a Costco store in close proximity to a BART station when BART
itselfhas stated, on Page 5.1-39 ofthe EI Camino Corridor Redevelopment Plan Amendment,
(ii) Reduced Trip Generation by Uses in Close Proximity to BART Stations, "Studies by BART
have shown that residential, office and retail developments constructed in close proximity to an
existing BART station...are likely to have lower than average trip generation."
Also, in its General Plan on its environmental issues, how environmentally sound is it to
concrete the Colma Creek when you could have redeveloped the creek into native plants,
removed the concrete, made it a free-flowing waterway and introduced native habitat back into
this area? Most cities, such as Foster City and San Mateo, use their waterways to enhance the
quality of life of its residents. I'm amazed that South San Francisco would merely concrete it,
line the banks with non-native plants and call it a linear park. It could have wetlands in its
Orange Park and it could have had beautiful trails running through the heart of its city out to the
Bay. A few palm trees lining the concrete trough is not anyone's idea of being environmentally
friendly.
:Z4~(
FRANK SCAF
cc: City Council
131 -1
0)
8
13.0 Comments and Responses
I. FRANK SeAFANI
I-I. Please see the Master Response with respect to Costco at the beginning of this chapter.
1-2. The proposed Redevelopment Plan Amendments would not involve placing concrete within
Colma Creek. Therefore, this issue is not relevant to the Draft SEIR.
131-2
EI Camino Redevelopment Plan Ameltdment
Comments and Responses
June 2, 2000
COMMENTS TO THE DRAFT SEIR FOR THE EL CAMINO CORRIDOR SECOND
AJ'v1ENDMENT gleaned and paraphrased from testimony at the regular South San Francisco
Planning Commission meetillg of May 4, 2000 by
Jackie Williams
242 Longford Drive
South San Francisco CA 94080
1. The DSEIR indicates 14,994 cars a day at the Longford-Hickey mtersection. Why is this
number dilierent from prior environmental documents that analyzed illtersections in the
area, such as the Costco EIR 7
2. Everything was put on hold ill February of 1999. The :information in this document [the
DSEIR 7] was available, but we couldn't get hold of it.
3. I didn't fInd out about the DSEIR until the [City Council] meeting of April 12, 2000, and
was not prepared to comment on it.
4. This document [the DSEIR] came out on Mareh 24 [2000] and then on April 12 [2000]
we were told that's it. We had a lot of people here to talk but we didn't know this was
gomg on.
5. We've had closed meetillgs as far the Redevelopment--so the first time the public gets to
know about it, within 12 days you had oral comments and it's all over.
6. On page 5.2-14, it shows that with Costeo gomg in, under the amendment plan it's goillg
to be 757 homes, but before it was going to be 1240 homes. Office space was 13,000 and
under the amended plan, you are going to have 189,000 square feet. Under commercial
retail, existing was going to be 88,000 square feet, but in the new amended plan it is
going to be 443,800 square feet.
7. After all this talk, we are not getting affordable housing.
13 J-1
05/04/00 VERBATIM EXCERPT
Page 1 of 2
Jackie Williams: I thank you for allowing me to speak. I spent the whole day calling City Hall
trying to get the answer to my question. I would like to inquire when the public can have oral input
on EI Camino Redevelopment Plan Amendment Draft Supplemental EIR, date March 24th. I know -
_ for written comments this is Monday, May 8th. But on the meeting of April the 12th, when it came
up we had no idea that this EI Camino Corridor EIR was before us, so we had no comments, but now
we've got the report. We've read it, and today I was told that there would be no further chance for
the public to discuss this EIR orally. They could, like you say, write it down and my question is, in
this document there is a lot of things that I've never seen before. There's things about Costco that
say there is 14,994 cars a day, gonna come into the area.
e
~
I
There's things like there's a problem at the intersection - they looked at 32 intersections, and four of
these intersections are not up to par. And one of those intersections is Juniper Serra and Hickey, and
its an F in 2010. Now what's strange to me is, I don't know how I did before you or how much I did
before Council, but I was really angry when I asked on Costco about what was happening with
Longford and Hickey. And I demanded a traffic study be done on Longford and Hickey. And this
was done and it came back that it was a B intersection and that there was no impact. And I can
remember going and getting Sergeant Massoni and saying keep the intersection clear. It says in this
report its a B but my only recourse was to keep the intersection clear with a Police man. And I said,
if I ever find out that it goes from a B and I need more help, I'll come back to this podium. And
blow me down if I don't get this Redevelopment report and it says its an F, but it will be mitigated.
Out of 32 intersections there's four intersections that are not up to par now that we've got Costco
and BART.
0)
Now none of this came out before and also the 14,994 cars a day didn't corrie out before while we
were discussing Costco. And now your saying we've got to put it in writing. Well I think that we
need - -like a lot of us have spent a lot of time looking at this document. I don't know if any of you
have, but we've spend a lot of time looking at this document and I find out that everything was put
on hold in February. So that we could get to the - - February of 19 - - Wait a minute what year are
we in - - 1999 I guess, it was put on hold while we went through the General Plan. And a lot of the
information in this document was available, but we couldn't get hold of it. New studies were done.
And what my question is, is how come all this information is available now. It comes out March
24th. I don't know anything about it on March 24th. I find out about it on April1th, when I am here
at a meeting, and then Oral Communications is over. And yet in here is a lot of stuff that we would
have loved to have earlier. And I think it's absolutely a crime, and then I come here and I can't talk.
So I really thank you for letting me talk because it's really important that the public knows what's in ..
this document and that we have a chance to comment on it.
G
And that is what I am asking tonight but its Oral Communications and I don't know if I'll get
anywhere. But I am asking anyway that we be allowed to comment on this and have the same
people that were here - - - this document came out March the 24th and then April1zth we were told
that's it-you know we had a lot of people here to talk to us but we didn't know this was going on.
I've gone to School Board meetings and tried to get documentation from Mr. Gudino and I've been
told it's attorney client privilege, you can't have that document. I have come here and there's been
closed meetings as far as the Redevelopment. And so the first time the public gets to know about -
13]-2
05/04/00 VERBATIM EXCERPT
Page 2 0[2
you know within 12 days you had oral comments and its all over and we on to the next thing. And I
don't think that's fair. You know a lot of work has been put into this document and I think we
should have a chance to talk about it and that's why I'm here tonight.
It was mainly about Costco and the intersection, and. . . Oh there was something else interesting too.
On page 5.2-15, it shows that with Costco going in and the - you know the way it is now, it was
going to be an existing residential of 1,240 homes and now under the amendment plan its going to be
757 homes. Office space was 13,000 and now under the amended plan, you are going to have
189,900 square feet of office space. And under commercial retail, existing was going to be 88,000,
with this new amended plan you are going to 443,800 units - uh square feet of retail commercial
space.
See the thing that we are not getting, and there is all this talk about affordable housing, but the thing
that we are not getting is were going to 1240 units to 757. So talk is cheap. If we want housing then
lets get housing. Don't lets just talk about it and talk about it. Because what we are doing is giving
up housing for office and retail space, which is the bottom line because more money comes into the
City. And I've got no problem with that but were talking about affordable housing like were really
trying to do something about it. And if we really -like I've gone to the meetings and everything. If
were really going to do it, lets go get affordable housing for the people that need it.
J-5
13J-3
13.0 Comments and Responses
J. JACKIE WILLIAMS
J-l. The Draft Supplemental Environmental Impact Report (SEIR) for the EI Camino Corridor
Redevelopment Plan Amendment was noticed as available for public review in the San Mateo
County Times on April 24, 2000. The 4S-day public review period was identified as April 24
through May 8, 2000 in the same notice.
A joint City Council/Redevelopment Agency public hearing was held on April 12, 2000 to accept
public comment on the Draft SEIR. Notice of the public hearing was published in the San Mateo
County Times on April 1, 2000.
J-2. Please see the Master Response with respect to Costco at the beginning of this chapter.
J-3. Please see the Master Response with respect to Costco at the beginning of this chapter.
J-4. The survey area for purposes of the Redevelopment Plan Amendment was adopted in January
1999. The project area and objectives were defined at a level of detail that was sufficient to
analyze as a project for the purposes of the environmental analysis. Therefore, data collection
began for the analysis. Typically, this part of the work takes four to six months. This is also the
time period in which the City was amending its General Plan.
During the General Plan process, there was considerable discussion of the proposed land uses in
the E1 Camino Corridor. The El Camino Corridor Plan amendment was held in abeyance until
the General Plan issues, including the referendum on Costco, were resolved. After these issues
were resolved, the Draft SEIR on the Amended Redevelopment Plan was completed and made
available for public review.
J-S. In response to the comment regarding the reduction in the number of projected housing units,
please see the responses to Comments D-1 and F-1. The remainder of this comment pertains to
the merits of the proposed project, and not to the content or adequacy of the Draft SEIR under
CEQA.
13J-4
El Camino Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
14.0 REVISIONS TO THE DRAFT SEIR
A. INTRODUCTION
The following corrections and clarifications have been made to the SEIR text. These changes include
revisions resulting from a' specific response to comments, and staff-initiated text changes to update
information presented in the Draft SEIR. The text revisions are organized by chapter, section and page
number, as they appear in the Draft SEIR. Deleted ;!'rext in this section indicates text that has been
deleted from the SEIR. Text that has been added to the SEIR is presented as double underlined. For
corrections initiated by a comment m the Draft SEIR, references in parentheses refer to the comment
letter and comment number.
B. TEXT REVISIONS
Chapter 2.0: Executive Summary
The revised Table 2.0-1, Summary of Significant Project Impacts is presented at the end of this section
(Staff-Initiated).
Chapter 5.0: Existing Conditions, Project Impacts and Mitigation Measures
Section 5.1: Transportation and Circulation
The revised Figure 5.1-11B, Amended Plan Year 2010 P.M. Peak Hour Volumes is presented at the end of
this section (Comment B~l).
Section 5.3: Noise
Page 5.3-24, Mitigation Measure 10 (Comment C-l):
10. As a condition of development approval and/or project assistance, all project-facilitated
residential projects in the project area should be designed to achieve the necessary exterior-to-
interior noise reduction to meet the single-event criterion limits (i.e., 50 dBA inbedrooms and 55
dBA in other habitable rooms) and the City's interior noise standard (i.e., 45 dBA, CNEL).
This would require specific studies at the development stage for each individual project to
outline the steps necessary to comply with the applicable standards.
14.0-1
El Camino Corridor Redevelopment Plan Amendment
Cfltnments and Responses
June 2, 2000
14.0 Revisions to the Draft SEIR
Section 5.5: Cultural Resources
In response to information developed by City staff, Section 5.5, Cultural Resources has been revised, and
is presented at the end of this section (Staff-Initiated).
14.0-2
EI Camino Corridor Redevelopment Plan Amendment
Comments and Responses
June 2, 2000
E:l
~
1i- ro
;..
Cl .8 ro
<u "d .8
':5 0) "d
.E ~ 0)
"d ~
'" 0)
.....
~ 0) 0)
c ,.0 .....
... "d....... 0)
'" ,.0
... ~~ "dol
..
<u o..s:i ~g;
~ ~.... 0.....
c::;, tja ~....
~ ('j..~ tja
1"01 ~~ ~.~
.So II
.........
u <IJ
0)' tj 'Ui
.~J::
8 ro .~6
p;.5 8 ro
0)' P.;:S
...c:~ ~~
r-<..s:i
E-<..s:i
<!:Gg
"''''0
~6<--1
E !3-c-.1"
;; ~ ~
;:]2:.
~ <:::
o::~
.... 5
E ;::
l:: ;::
~a
~
R:;
...
c
='"
~
c
.~
g
'"
u
~
o
JJ;;I
r.n
$=
~
~
r.n
~
U
~
~
-
~
U
JJ;;I
0'
~
~
~
Z
~
-
~
-
Z
~
-
r.n
~
o
~;>c
q~
t'-l<
JJ;;I~
~~
<~
~IJ:J
e:1
~
C/'J
J:: .....
..8 [l
~ ~
~ 0) ~
.;:: o:S'~
0..... .....
u~ QJ
QJ S is:
-E, CIl~
J:: !:< p...
.9E 0
~:aJ::
<@So
B~a
u &: 15
QJ~"d
~Q)~
...c:,.oo
UlQ)~
.!:l ~....
JS Q) ctl
ro!ilo:S
~~ ~
';i"d 0
0"'9:!:E
0) ':t:l "d
..... >,t::
1;;,.0 8
-E"g"d
~.5 g
.9 S c:
~J-I..!9
1rl~0..
I!l~"d
QJ QJ 0)
~,.o"d
.~~ ~
&~~
:E
....
.S
't:l
'll
.-
~
'"
~
'"
~
~
~
\0
~ t-...
..... N
II OJ II
>.
ctl cod ~
en _~a1
p 8~P
0) ~...... QJ
00 ...UlOO
~ 815~
Q) 6buO)
i 'Ui ~ ~
~ ~2l
OCfJ ..... 0 CfJ <IJ
UlUO....
,....J 15~,....J g
i:: ..... .. S
.9 8 6 Q)
.... .....:t:::P5
~ t::Q)ctl~
QJ 8-!il1:::
00.. p..."d o.."d
.8S0~
.~ UlO>-1.g
1=:0 ~0:8gc:
:8:I: ~[J:I:8
~~ ,..!,:s:~ So
QJI!l ~ OJ + 0)......
,uo..<IJ
1; ~.' ,e.<J:1. 0..
~ QJ1J~.8
QJ <r: .::; ........... '"
.::l .... 1;; "d"'" 0.....
- I=: c: t::.....'-I'<
~ro<IJ.....~C:<IJ
bo.:::;"d 2 0 2"d
ti'l~ S-:l0:8~ c:
QJU<t;UlUl8
"";P::rJ5NgJ~J5
,
..
"dO
~'t:l
0;::
~ 6
Ul'"'"
......t:
u....
ro ;::
!3-05
S
.....c
QJOO
u<--l
'Et:S~
~.t:> ;::l
...., ;:: !2
00.....
'Q) ;::~
:> 0 ro
QJ- QJ
_t:;P-.
...."::;E
~5~
<J:1ctl~
';:1 ~ ;;:
Soul'::
....... CJ t:i
CfJO~
'"
:E
.....
.....
ctl
"d
QJ
1::
ctl
l:1
ro
is:
.~
t::
.9
.....
ctl
.::l
OJ
So
......
'"
t::' J:l
00
.""""......
..........
...... u
"dO)
"dUl
ctl!i:l
.E]
Joj o"d
ctl QJ ..... ~ a.a "'0
s E,.o . S Ul:> 'Ui ;.a . QJ ~
.8 ~ ~ .~ ~ ~ -3 ~ '1:i S 13.~ oj] 1U
"d:E 0 tj 8 'E:l >"1:: 0 x ~ "d ~ 0 .::; -""3 Q)
~~~ ~ c:-;~p~~ 1U ~i c:offi~]
~t~] ~ ~~:;: 8] ~H~~J 5 ~
~ P-. ctl ctl :;:: e.o ~ 0) .8 ~ Q) i:O J::"d e.o!ib:S-tl
..... Q) s !i:l ~ OJ I::: -E I :f ~ QJ ~ g QJ ..... t:...... .8
8~"'~ .....&.8.8;:Jc:0].(j &~0:r:1::
"d Ul..s:i Ul ;s..... 00<11 ro 0 i:O""'"l ctl.:t:: >LI c: >'Q)
QJuc: ....ctls ........c::>-J:l"dQJs -..cs
] ~:EQ) 8 .:; ~ :!:l.~ ~ t:~,J..< s:;S 8 ~ ~ O)~ QJ
.,...... ,.....OUl....."dOUO<uo....,......:>
i> QJ :> ClI ctl QJ c: c: c:........... "d,.o ....,.... c: 0
~:>?:l15 1UE"d80'Q):I:1:: ~ p~olS
'1:: ~ -E l ""3 E Jj .8 ~ ~ E' S 1U ~ .8 ~ ~.... E
p >.......1 ciS ,J:r~ "d g b ~ QJ ~ ~ 1:: ......5 ~.8
c: C! is: r-< . ClI .2jlb ~ ... 0 9:! 5 0 - bo ii.!:l u.....
QJ 0 l-1 <1l"d..... "d'''; ... ........ i:O - ............. '" u.......
QJ ;::J ci..... ......"d ..... ;:l:8 bo QJ S OJ'~'" OJ ~ ro..s:i
~ ~ .8 B ~ S ~ ~ 2" ~ .8 0:5 ~ ~..... ~ 11 OJ .9 "2
0) 0 ~ N 1:::"'" 0)'" Ul.!:l '" Ul ro - - :> "'d :::l
Jj i3 ctl 5 ~ ......5 ~ $ !i:l gj gj S -E 11 ~'I:: QJ 0
QJ~' 0 ~ s o"d...."d ~.:t:: :I: 0) ;> ~"S b
B I!l .!:l ~ 0 E ~ ~.5 QJ ctl..s:i 00.::; ~ >. c:: I:T'S
... ~:2S !2 ~ OJ..... "d 0 c:.~ o"d 0C:,.!:: 0)""" &: ~ u
....... c...........!:1 ...c:'''''''' 0 .......... OJ I-I:>!:<..... -
Ul .;::l ...., ~ bo t:: ~ ;>'Cil P "d:::l OJ c:...... 0 be ClI ctl
~QJ.~ ClI "'.8 .!S'I::;;J Q) J:: J:: ~ 8 c: O),.!::::g 51..c So
,.l::i...c:: OJ .,."d ,J..<:> 0) Q).,,;.... ro Q) H ;;J ;;. "'d .....
.......... p...;> QJ.8 '1:: x 0) ;;J I=: ;.a libc: 0>LI';:l Ul
'Oc~::2 S2111p>LIlib2"8 ~!i:l&:iS:boOctl
:> c:.:::l ...Q ctl c: ~ c:"d !i:l ..... OJ 1'<:> lib ~ c: ~ 0
ss~~QJ~s]~~&$SO~~!i:l~~~~~
.8 ~ E...c:: -E :> ~ 0:5 lib QJ oo:Q'Cil "d ro :> ClI Ul ctl 0 ctl
""'E;;;'.8 8 0 ~~"" ,,". ."-,,," s ~ ~.@ ~
j a.~ \I '" S z&Jl~ ~ ~ J! ~ ~1!E] J'J""
c<:i.,..,:E ;::l.:> ...., ,.0 or-<P!:O~,Q
Ul...."d!ib. -
Cf)
I
o
..;<
..-<
.
1:
<:::
[:)
"d~
"8;:::
00
is:~
1l:-S
U '"
ro~
StE
'.-4~
af~'-'"
.~ ~ ~
~ ~ 5
~-<e:...c::
~~~
o..,ctl
.....'llCll
0) ... 0..
:>~
..s:i"'~
....."0..
~~"d
u.... c:
<J:1ctlro
.~~
..... ~~
CfJO~
~
~
tI)
~
"'"
o
Ql
t:
oS
'"
;:::
o
....
'"
....
t::>
Ql
~
Q
",;
.-;
ell
.9
"'d
CIJ
~
"'d
~
CIJ
..c.
"'dOJ
"SiiJ
0-
~~
l!
]r1f
.O'~
......c=
0.<.....
I
CIJ en
..c=en
E-t~
Cti
I::
CIJ
S
CIJ
~
....
0-
.8
bI;
.Ei
;;:
o
;:::I
..9
CIJ
-B
"'d
....
ell
;;:
.9
S
:;::
;::1
:oS
-E
o
u
CU
....
ell
..c=
en
....
.....
..is
ell
CU
"'d
.....
>
o
.....
P-.
-.:t< .
~
l;;
"'dt::>
"S-q;;
0-
;;:.tj
en....
..... '"
u""
ell;::
,.... "'C f,:l..;::
....CUs:<c
Z ;::l'=~
< = ~ ~-
z .~ 'E ~ g
9 8 ~~..c=
~z~'tl-:::~
~ .....-4~ClJ
E-< 0 CU.t:; f,:l..
~- iiJ "'"'"
OE-4_<U"'::;
~<'EDP-.
~S]i;jl
< u .~ Si
~ ue= ..... 1j~
r- [J)O_
ClJ 11
,.....E:: ..... >.
rt3;g ;::1 C'i~
~u g .g c::lo
.~ 1;3 .p ~ 11 ClJ
os:: gJ U >.co
..... ctl ..c= s:: ell ~
~ U ~ Ci:l~
'.6 ~ ] gj ~i
ctl s:: 0 ;;: ~
Octl ..c I....[J)
F::"": ti ti,.c; ClJo
f,:l..ctl~ cu ctl.....~,...J
.... ;;: cu51'oo
cuo ClJ ;:P'{lUS
::l 1= -B '53 ofi [J) :Jj
5i~ g ctl....o~
";::.E:: s: "&g~ ~
.....00 ..... '(dbOS::O
.s .fl ~ ~.~] t1
'" 1;3 E 'c;l~ ~ 0
~ s:: BE f,:l..~::r:
U ell .::t:: B'(dO~
~"E~ ~ .::t::~t1&
] ;::1 ,!S ~ ~'c;l 0 .
u ..c ~ 'c;l.c: "'d::::::r::::E
cu~ ::l~.l!:!-;::v.p.;
~~ aiuouti:"'<il.....
.l!:! ~.::t:: a 1;3!l. .l!:!"'d& ~
.S ..c= ~ ...... C f,:l.. 8 ~ . ,;:;
CIJ ..... QJ ~ rn ell f,:l.._:::E;::J
N cu> QJQJ CUQJ .0000
;.::l .f,:l...tiJ "d::l "d ::l < QJ "d
~ E.E 11 .~ ffl .~ ffl ] ~, S
..... gJ ~ co 8 ~ 8.;:;..... "d aJ
[J) ~ cu'l:: P-........ P-........;3 s:: [J)
<1)01.0
l!J U .
. ~J5~
.
.
en
:E
....
....
ell
"d
QJ
I::
ell
.....
....
cd
;;:
.~
s::
o
.....
....
ell
N
;.::l
cd
~
.....
<I)
s::' g
]:;::
..... u
"dQJ
"'d~
ctlCU
,s]
ctl
.9
"d
QJ
::l
"'d
l!J
.....
QJ
..c.
"'dOJ
;3>
o~
~I::
tie
ctl<.l:i
f,:l.......
.s ~
~ ''[1
'0' a
......c=
0.;.....
I
l!J'"
..c=<I)
E-t~
==~8
:;1::0
~ 2.~
ti"'("'l
;: ~ ~
"<t::"g .E!..
l:: '"
"s",
i:>.,.....
..... 1;;
1;; ;:
;: E:
]-8
~
"'=l
OJ
~
....
~
'E
8
c
.E
E
o
;:q
.l!i To.....
ala s::::c..9
SQJ"'d ltl8 co,....,
cu "'d l!J QJ ..c= .S cO
~ 'i> ~ :'S! , ~ Ct'J
..... o..c= >.::t:: ..c= 11
~!l.~ ~ ~ E
'bI;.9] .8 ~ tj OJ
.S {i QJ {i ~ .l!:! ~bO
~ S~ ~~ 8 ctl
;:::I f,:l........ !:L.S 0... [j
..9 liMb 0... 'Ii) .8 ~
ClJ ""0 ~ t'Ij .x ;E ~
ofi....o "'OQJ 0...,.1,
_ctl1= .....QJ 00.....
~ iiJ.... ~..c= S [J)
ctl;3CU ClJ~ 0 0
~ 0.E:: ;3 f,:l.. ...J:: ,...J
.8~;g ~EgjbO ~
s:: ~u >.[3~.S ]
.9 ~ >< OJ ~ ~ ~ rd
::; u~ ~"'dbO..c= [j
~tErn .~g5= f,:l..
Jj"'daJ~ QJ1=ltl 0
g s a'!s "2 g.....[o ~
U o......~ ::c...... cu 00 0
cu ,.0 ~ 0 E.:::.... ::r:
J-,(oIJ ...c CIlU)
ctl 00 ....::l::l ClJ ~
..c= ctl.......... ~.........;;: ctl
~ ~.::t::To ;;:.::t:: ~ ~ l!J
'Cd ..c= ~'I:: ClJ ~ QJ ~ P;
..... ~QJ'""......ofiQJa QJui:::E
ctl f,:l..'::: To s::.::: en ~ E p.;
~ '1:: ;g::l ClJ;g C<l c.8.....
-1""4 ....-.l 0 '"0 ~ C1J Cd c:
> [3 u .E ..... u a ..c=.::t:: rn-i3
8~1;3.....~1;3......u~~s::
P-. ",0
l!J U
~J5
'<Ii
I
o
""
,.....
LO .
.
.
"'dt:;
;3t
0'"
;;:<.1)
2t
~.B-
0...""
S 9
,"""!:::::::-.-...
[IrE ~
..... t:; 0
i:;t::>,.r::
CU~~
en ;:: ctS
..... C QJ
o J:Q 0...
g!~
cu'ti .
.......,...0-.
....::r:::-
a...."E
.~ C<l lS
~~.... '"
;::1....
U ;:
...... U 0
[J)0i:Q
E:l
~
t/)
~
lo..
o
~
':S
.e
'"
;::
c
...
Ul
...
t:l
~
~
Q
~
.....
etl
.9
"1:l
QI
U
;:l
"1:l
QI
....
QI
..0.
"1:lQJ
'"S~
0.....
~l::
t;jetl
('lj.~
o..~
.S So
t;j . Uj
.~6
0'"
.....s:;:
0.<....
1
QI<Il
r5JJ
~
~ .0
~~~~ QIQI ~ ~~B
00' s..c aOOE-tg,j
>-':0 :0 ;E O' '+l...... :0 ~.... ....
..o'U ro CO .... C"'ld t...: ~. ~gj~"d
] g,j a:;';::: QI ..g QI QI c<) UJ...... ~.5 <tl
@a:; g.l!::9 ~=@~ ~ 022) s..... ~~
~~....~~ _ ~ s~ _00
0....... ;:l U'.... ~..... ~ .....QI 'S.::1 m t;j :> "d a
Oftl-<OQlo.. -..... <tlQlQlQl~QI-
uv;:l.s:;:l-<"d ro~O Q u;:l.s:;:<Il<tl"dOO
.S ..9...1<: til "S ~ ~ .~ QI ..... ffi..... 2 0.. ~ -8
~:::lm.s:;:.....o iJ~ ~ ~:>S~"dOO"""
QI . <d 0....... ~ u""" .... ClJ ~ 0..... QI ClJ.......
~a~~w ~~~ ~ ~~~~]g~
t::oo......~QI ~O...... ~ goetl~E"2ffi
"dii~ ~ t; .5 ~'Q ~ ~....... ~~~ ~~
~"d..o ;> ..... UJ ClJ CJ} .c"d U 0 .c
~~!~~ ~~] 0 ~]$~~~~
n..oClJ~~ .... ~ ~~etl.s:;:~~o
=I-<U.....etl O'UJ .. o!:::l:ico i>
~?~m'Q i~~ ] ]~~~j~~
~B~~~ ~""'ClJ ~ ~S;:lOe~'Q
~ld~m..8 uEii a:; ~~g~~<Il~
~~8S~ m~~ ~ QI~~~O~~
l-<uo..Qll:i "d.s:;:0 I-i e....1i)O>!:l.....ro
~ Ern:E;g 8 .~ca ;:l QI "d .~ 'OJ 0 0 J:j
.::1:.... 0 ell 0 ~ 0 I-<:J:l :f: ~ a "d ;:l.s:;: E <tl
..9:!.~ u 8 U 0...0 ~ <tl "'" ClJ"1:l g ~ QI So
"Ox....QI....o-ii-.s:;: ...I<: ...I<::>~:>Q)"'O-
..... Q) 'tl ...... .....;:l <Il U . <d <tl..... ~ ~ 0.....0 00
gj ClJ;Eca ~ e oE ~ & ocs ~ 'o-;:j"d
J!Jii~o.O~<Il~O" "'"' ClJ~~~a
g ~ ",E'~ oj:! ClJ ~~~ ~ ~~.sp..; ~ 00 ~
ClJ :B J:! ....~.2.. ~ -;; a ~ ~ ....g ~ 8 ~ ~.!! ~ J:! .9
.....i:C U ClJ u,"= Q) Q) 'u 00..... >j QI""'..c 0 u .....
etl~<tl:>uS"d"d'QClJ....."d:>~cU<tl-<tl~
~ _____ 8 ~ etl ~..... ..!. ~ "S ~ 8::::. 1Cl....... p"';g e ~
~ Eo.. 0 ~ ~ ~ 8 ~~ ID ~ ~ :Jl:E re ~ ~ 8::~
E-t U ~ ~ ro \Ci 0..';:::.5 p::l CJ} t--: ~ E-t p::l <tl ClJ ro.S
~
31 .2
;:l ...I<:
o <tl
~~ ClJ
",g:oo.
...... c .
~5~
c::l '"0 tt! E::-
2 ~ ..... ~ <u'
~ = (lJ,;:::
.""" .~ -.. ;:
z 1:: i:::il ~
o 0 (lJ~~
I-ltJtr.lo~
E-< ~'Q;::-
<:2......;:: E
t2~ ~a]
o<:::-~
~ ~ c:>L1~
Cf.l id.......
z;;J J:j ro_ g
<u'j:l~~
!:l::!:l:: Sou ;::
'-'u-.....u 0
... CJ} 0 I':q
"1:l.
g"E ai.....
ClJ SO
.~ a..p'~-
o ClJ 00.....
......SUl;E"d
~ Ul >-...... c:
(3u~~~
(l:i<tli>~:>
'~.n ~:g
'Uj 6 ~]]
.S:o (lJ ...... 0..
;!::~~g",
;:l .I:i (lJ QI
ID <11 ii .~ ..c
.... j::; co >-'''d
~ 8 c: ro"S
.~ ~~~ ~
~ .... ClJ 0 '"
'..-1 o.~ ~u
31 ~g~ <tl
;:l ICl ..... 0..
o ~J:j...... ~
U Ul...... 0.::1
C:etl.tl"E~
.9 ..g "d ~ .c
~ 5l- ~ So..E
>< u)~""~ ~ .
ClJ u......oca.....<
Uletl ua
..... o..s t;j ~
iiE....~UlU
....... "d Q)......
ocaClJQ)o1i)
s"E ~~ a"d
:oQ)~~:OS
Ub.u.s:;:etl"d
E i::.s.... J:j Q)
;g .g ~ 5 :g 's
o ~ ;g.E:: (lJ cT
u Q)"dC):9 l!:
etl
o
....
'"0
QI
~
'"0
~
QI
..0.
"1:lal
"3:>
o~
?:"E
......etl
U U
etl(l:i
o...~
.!Hb
...........
u '"
.~6
o etl
......c
P-<......
,
QI '"
..cUl
E-t~
~
<Xi
c<)
II
>-.
ca
QJ
Cl
(lJ
co
etl
I-<
(lJ
:>
i
Q
CJ}
o
~
i::
.9
.....
<tl
I-<
Q)
0..
o
I-<
::s
o
~
...I<:
etl
ClJ
~
::E
p..;
~Ul
...."d
~s
IDa1
p::lCJ}
QI
,.0
o
......
"1:l
~~
~'6
"'....
.... QI
'a 1i)
....."1:l
etl......
.....
QI ,
"1:l~
..... 0
>:.e
au
.... QI
o..Ul
"1:l....
~~
etl.S
~ '"
0.....
......s:;:
...... ......
u.....
~o
.... ~
~o
~:.e
..... etl
<1l N .
:E~ ~
'Q.~.~
~ '" ~
.9~~
~etl~
.... ~.....
ClJoU
0........ (lJ
o~.s:;:
....0......
O:.e >,
'2 ;:l..c
0:9]
::;Sl:i"d
. 6 ~
oou....
~
o
.....
......
U
Qlh
~p,:;
~~
.8~
1j .e
..........
-:;;0
"'O&:i
QI '"
i:l~
~~
~~
~~
.~]
c
s~
:.Cl::
etlC
N'-
~~tri
rd...... Cf)
5,~ ~
U5'Q~
etl
o
......
'"0
~
.g
ClJ
....
QI
..c.
"dal
"S:>
o~
~i:l
t;jetl
caJ:j
.t&,
u'<iJ
.~6
o etl
.....s:;:
P-<......
,
J;!ffJ
E-t.!!
~~8
:;:0
.{J fl.. N..
5"'N
;:~ ~
"':t: '"1::l,E,
e a
- '"
R.l:!
.... <U
;: :::
E g
g-(3
l
<U
~
...
..g
'E
(3
o
.g
8
~
(lJ
..c
o
......
"d
QlClJ
19
<1l ....
.!:I~
etl QI
......"d
etl......
.....
QI ,
"1:l~
..... 0
:>:0
o U
.... OJ
o..Ul
"1:l....
c:~
etl ~
~.;;;
0.....
:o-:E
u......
~o
.... ~
~o
~ ',p
.~ etl
'" N .
;E;.:::I ....
.....etlaJ
......~
0.....
~ '" ~
.9"E~
~etl
.... ~.....
QloU
0.. ...... QI
O~..r::
....o";j:l
0.....
.............
'S ;:l......
0:9]
""...."1:l
""""EQI
. 0 S:!
0\ U ....
lI")
,
o
~
......
~
o
:.C
U
OJ
'"
....
QI
:8
OJ
:S~
"to;::
~~
~-<<:
g'";!
.... -
.... t::l
etl ....
~~
"'~
..... <::
6~
:0;::
etlc
.~ "en
..... <1l
etl.-
5,~
...........
CJ}o
~
CJl
~
lo..
Q
1ll
~
oS
'"
;::
o
....
'"
....
1;)
1ll
i:l:<
Q
~
>'"i
O"tl
z4>
<6
z~
00
....<:.1
E-< '
<z
E-<O
~-
o~
j;l.c...:l>-o
(J);:Jh
~UfJ.J
~~'"'"'
E-<U~
"tlQJ
;3:>
OQ)
~""""t:l
2~~
Uu:c
rtll.t: I::
o....~ .OJ
S So. 'Q
:e-'~ Ji
$rtl......
rtlii 0
ell'I::<Ii
"2 gJ.9 Q)
~~~ ~
ctiro1::~
I::O~OJ
0..... ~ S
:c "t:l OJ
~ ~P..s 6
Q)..... :c
o..."t:l. rtl
o ~~.ff
:;j 2 ~ 's
E:i
fJ.J
~
0-,
0-,
N
..,
OJ......
:=; o:S 0
<Ii gp ID
1::0:9
Q) cti ell
SOJo:S
g<ao
............,.0
OJ I:: bO
~B:~
~.:t::......
Q) OJ ell
1::...... :>-.
~ ~~
rtl ~ OJ
bOb:>
c: ......
.~ i .t;
Q) (/J S
ell::l'~
ell 0 rtl
[a'::IS
~:Eo:S
Q) 1::......
.~ 0 ~
I-< U ell
"Cl rtl I::
l:l'C5~:8
<U J-4.....t ctS
U Q) > u
u~ 0 0
-< ;3 1-<......
..... I:: ~.S
a:J ~:>-.
._~,.o rtl
e "+l'OO ~
j;l.cJQ)~"'g
....... 0...0
~ ... J.-t .
:;:j. 0..... dJ
"T:l I:: I:: Q)
....... (/J Q) Jj
.=: .~ ~ en
""g cd! :0 Q)
................rtlii
;:
e
'"'"'
1!
~
....
o
'"'"'
"'1::!
..,
';::
....
a
'"
~
u;
'"
~
......
rtl
~
o
.~
rtl
U
.......
"'"
Q)
ii
~
o
ell .
cd ell
~[a'
cd~
I::1IJ
:8.e
~.t;
'*S
&J .@'
"ClS
~ ~
.....1::
..........
ibcti
'J:: .E
Q) ell
"t:lQ)
'~;'5
o rtl
3::8
0...
:::~
aiO
:;:j..!!1
.b I::CU
Q)bO OJQ)bO
~ iil" .;:!iJ :E
I"i ell 0......'" > ell
o ell cti 0 ~ ~'x
ellrtlell~rtl...."'"
.S~"Cl 00 ~ OJ
.... Q) aJ...... - o.....c:
"S ~ ~.~ "g Ei"+l
gj ell ell 0 0...... S
I-<rtlQ)I-<~OJ......
"Cl tJ.~ ~ g ] ~
:10 rtl ID o:S ...... E-< "'"
Po.u ell (1")
~c:x"t:lJJ......;O\c:
c:.S Q) 1::,.2; cu 0\ Cd
Cd ~o rtl Cl)............
......,J:......Q)~Cl)tl..
tl..Cl)"t:l:>I::0~1::
"t:l iil Q)'J::.Q ~.... Q)
Cl) ellitlp cu. c:c:
"Cl C:""" ell .::1 I'<
53Cd~53:>-.CU"t:lPo.o
~...... CUU Q)
.bellQ)~......$a:l
g)~~Cl)",":....iii
E5Q)"Cl Po.s 1IJ.~ "t:l 53 "t:l
Q) ;>....c:"ClQ)
0.. "'" "Cl ro...... ~
u
ttl
rtll-<bO
~1'~
.S~
"Cll-<U
3J :=; J:j
Po........
"'~cd
~:8.b
OJrtlbO
.~ ti.S
QE-<:-E
f::~ 6
3J~ tt
5OOJ....
!iJii~ <Ii
:> ...... ...... "Cl
","ogJQ)
b.ObOOOJ
c:.1; u fE<
.9~S:;Q)
rtl 0..,.0 U
....o:o:;:j
53 OJ g<"g
S-B c: ~
OJortl.....
u.............~
EJOJ02J
'i:: :;:j f:: J::j
bO OJ "Cl.~ ell
=:'1:lS'E~
.... Q) Q) OJ ':i:l
~~SbO
OJ ell 84> 8
Q., OJ Po. ~ ......
(J)~rtlOcd
~bg)1J~
.~..s Ei'1:l '"
..c:: OCllCU
OJ .UCllOJ
>~~fE<S
~"'o
Sil\lC
<<s::o
"''''''I
""'1'>..-
Si"'''I
E R! ~
...."'" ;::
....s::-
s:: '"
oS",
i:l.,1;:
~E
E ~
]-u
~
'"
~
...
.g
'E
a
o
s::
.~
o
1:i:l
~
....
~
CI'J
(/J
:E
....
=:
....
OJ ..0
"g -:5 "Cl .9 's
$.S s::.l!.l....
.... Q) rtl " OJ
53> "OOJQ)
"0 'J:: rtl "Cl .b
......0 oE trJ
s:: ~",aJ
Q) s:: ......... o:S
~2j OjCl)bO
~5o .~ .S
""CJ J-t ..... rn
;3aJ ::Eo~
0& ..........tl
~"O 0 ~s
~ 5 :>-'cd 0
;::l '" cd 1:: ~
"'"0 ~ 0
ctS(Ij ~J-Itf.l
~,9 0......1::
~~ ~o~
b.OS:: . ~ 0 u
.S.9'O .~.E
~ ell 0 I-< <Il <Il
o .~..c: lj Q) ~
~::EcX ....-:5 cd
.Q S::~ .S gf~
Q) o.~ -:5 0 8
-:5 l!J:r:: ...... Cd .~
......!iJ0 ~aJ"Cl
>-.3u~ bO>"t:l
....-0 s::.::l .S';::: s::
~.... 0 S ...... r.. cu
""""""'..... t.J ~ ....-l~
~ .rs.bU r:l 5 ~
53aJE:I cdaJrtl
;Sid......~bb~~
.... Q) '" 0 rtl.... ~ U
...- b.O>-. ti aJ 00
-:;; B-""..... s:: > ...-
4> ..!:I :8'i:l .- "'" u,.o
~ ..~'O
~ ~ 6j'S: .
\D
,
o
""
,...;
"tl
Q)
....
:-::
....
=
OJ
"tl
.....
'"
OJ
...
:;:j
(/J
rd
QJ
.::;
~ ]
S..........
CI') '<tl S ~
~ S' (lJ
(lJ "0 Ei
~ .....~ 0..
Cl :sl:tl.Q
OJ ;:l ~ (lJ
':5 o (lJ Iii
Q ~ :g "0
oj.> OOOO~
fIl ti<tl
;:: ~ ....... b.O
Q o..~E
.... s <tl'
fIl
.... . t~
l::> &l' ~
OJ
r:::< .S (lJ
Q ~'c;j -:s
"<ti S >.....
""" :p::O..E
UIll~
;:l :g I-<
J::O~
~ :>Ct') c::
o III 0\ <tl
uS~p:;
00 "0 OJ
III "0 0 -:s
Jj(lJ {3~ 0
00 ......
......J:: ;:i<tl ~Ls 0
<tl.... ",,,, <Il
J::.S ..:-~ 0",
0 '" .... <tl
~"O 1i5 CC 00 (lJ OJ
S~ ~~ ....
~ ;:l (lJ...... en <tl
J::ta~ (lJ ~
k1 00;3 ctl .s 0..'" S S 0
...... ev ....
:::: .S ~ 00 ;:i.... 8 [l 1)
t::: ~ 0"00
i:i:; "0 '" ~ . ev~ .~ 0.. ::I
;:i",<tl~ C ~:p ctl 8 b
- 'U~(/)fi'S '"
:::: 0 000 >'0.. ~
._.".-4
<l.l S .J::O :p ......x "g-:s 0
;: . jl......N '" Uev U
f5- ell' ev ~C"l ;:i ;:i>. a'~ ......
.~.J:: ex:> 'S b..o U
~ "'.... OJ
........ (IJ ~ ~ctl .J:l.... "Q'
~ .E .9 -:S ] 0 Oev .... ~ ....
<l.l V
'"t::: co uc its 0..
<l.l ~ 3f'd Irl OOs ......
r:l::; Ei .S 0 ......' 0.. 0
CON(/) C'S ......
C"<) o ~ ' ev ~J:4 evO" (IJ
0) ".0 .cO ~ .... ~
0) .S (lJ- S ev
..... U 0...... 0 ..... ~r:l .e-ro o .
;:l (IJ:P 0 ~:p ;:i ev 000
;: l:: >..... ctl en 0,..8
c ~~n 00 ,U(lJ O".!::l
.S &j!:l'" (lJ .... ,...;....
O.....J:: :g ._ o..;:i ~.9 ~ ....
"E U ou (lJ 0","0 00 :E~
"0 "':..........~ ~ctl~ :ps
t::: .l!:!~~(lJ ~ ~.s
~ ~....<tl :3:;:: ;:::,$
.... ctt"fjj fJ'~ <tl ctl....... b~
~ .... 0 00 <tl..... (lJ <Il;:i
~ <tl.SZ '" ~"':> ~ C1i ...."0
(lJ Octl:p Oev
~ (lJ S"O ' U :p ,...... 0-
000....(lJ (lJ .ae3~ u<9 ;:g.J::
'i:: d;J::O] ~ .....Cf)~ oo1i5
.... ",0(lJ ev '" (IJ '[l C
0 .15 "0 ~ U _ooCll .... 0 "0
-CIl , &::1:)
C ~'S ro .... ctl(lJ(lJ ~O
.... (lJ tl,.~ ..ctl
~ ..0 ti~b.O
] .9 Z .& .~ :E taSO .... ;:l
. bO..",,u 0 u C ,$ (lJ.S OJ::
tii .... 00.... (lJ~"O:;
~ ....J.S~~ ll.. ....J u ev CIl.J:: l:j ZCIl
.....J:: ~
,....; &D::E cri ........... u)~~ \!i 0
"<I< ctl 0 U
CIl
~ ~ .S ~ .f9
:: 0..] S ~
51 ,S::E g< S" .
s S ~............ a
g<~~ ~alp:;
- I .... "0 CIl "0
~1i~~~~
"O.J:: a) OOu ~
(lJ '" '" S
"-Ll ~.....s.s..... ~
~ "O~~tlo
OJ U 'I""'l
~ "o~~><~QJ
~. .9 ~ (lJ 0:5
;z; ~ tJ(lJ~....
.... ;:i -:S 0 (lJ
0 "'.... ~ "0
C.......... S
t:: QJ"..... ~ J2 ~r
u ~1i8~liiB
:::l
~ o gj o~ ~
1j..........Ct')og
~ o"O"OO\.J::"O
"0;3 ~ ~ ";3
0 '9 o"!s (lJ,m 0
u p:j ~ ~-:Sll.. ~
~~8
E6~
'1:l I:>.. '
~:aN
E R:; ~
~'1:l.::.
::: Ei
.s~
I'l; :::
1i ~
E ~
~u
~
"
R:;
...
~
'E
1:3
c
:::
'E
a
i:i:l
~ ~ ~ QJ~
~ Q) ~ ~ ~.~
6 E5 ~ ~ .S ~ 0..
o...u@ "E~oco
gj1J5evca OO~~
.......... CIl (lJ 0..0 lV.... ::i
0.-.... U.J:: - :> '"
(lJ co..... (lJ b.O (lJ.... ....
..0 ~ <tl '"Ci u........o"O ev
:sl 6]0:5.l!J C ~"O.s~
::I..c......ev~ll ;3C;3
o ~ 'O.~ ~ ~ t 0 <tl C
~ b Q) &!iJ tl ~1i.i"O (lJ
o CIl CIl (lJ _._ (lJ >. C C
.J:: ~ ;:l .... 0.."0 CIl tJ - <tl 0
~ 8 r:l;:g.s ~ ~ ~ 5-&
.... ...... Q) ;:> ev ':;:J:p OOta Q)
~ 5 -:S ~..o 5 8 <.S-:S
~..o Q) 0> S..... Q) (lJ "0 blY":--
:0 ~.S"2 ~ ..olil 0:5 E5 50..8 ~
..........S<tlo~~........ ",u
8.S [l ~ .... ..... u o:p
u,.!S Qj [l o......~~ eJ 0..8
Q)Q-rdc;::ev..... c....
i:js"O';j0:5~-5alll..E~
.E 8;3 S ~..8 .S ~ ] ~ al
] [S ~ 11 g ~"2 6'~'~ {3
CIl 0......0 uQ:l i"d:Jj"O 0 '"
:0-.9 >.0.... (lJ u &l o..C
Q) ~ <tl 'j:1...... <tl.'l:: ;:l.- gj.9
"'.....s 1ll"O.....CIl.t:J 0....""
'S ~:o (lJ .l!J 13 ~ ~ i:: (lJ ~
~ ...... 5 0 ~ o..,g 0 <tl..o b
III ooo.s .... >.u u bJ::rO ~
(lJ.fi u 00 1;j Cil ::i~.S;3 0
......;.a (lJ i:: ~ ;:lb':;:J..... 0 u
~6~"-E '" g ~ 00~1i.i 00
'c;j ~11 ~ ~.~ 8 ~'fil Cl ~
~ ~] ~ ~ ~] ~ ~ ~'>
'"""'....CIlC>pQ)S......OO....oo
t-.:..E:O~SUta~..E ~i:L
t-..
,.
o
"<1<'
r-i
~
CJ:l
~
l-.
Cl
...
'ti
Q
....
<Il
;::
Q
...
<Il
'S
...
~
Q
"'l1
H
~
co"', OJ Q) ",I.!)
.~...... ctl u ..0 OJ ~
.....--.,Q) ~ '" .....:IHO
!::: .HQ)"O OJ O~;:l"",
QJ ctlUlQ) ..r:: ..... Ul
co ~......~ H '" Ul ctl..!!l'
!:<Q)()O"O';::I ~Q)Q)
g.'~ '5- ~ !::: 6 ~ .S .S ? S 1;;
oJHH()ctlO..... "0--.,_......
;> U o..::i.....:l 0 ID .l!l~i:O e ~
OJ OJ "0 i:-LI H .~ ~......:c.~
"O.~ Q) Z Q) OJ ..0 v Ul 0
o ..... H - "0 ~O::i!:::
li:J H!::: ou..o 0_..::-.'-0 0 H
..r:: o...~ ..... ,-...lS U ,~.:= '" u 0
..... - ","0 <t:.~ QI..... j:i "0 <1l '1:1
o ~ C;; 2 i:O~.;> &i JS ru.o2
"0 "0 :> C ..r:: :p "O.,!. ():c co
~.... 0 it!"O co el'Cil:'" x !:::,;::<
.::; ~ fj I.!) .;::< ..... QI '3 QI OJ ~
c;;"O -;a'" '.'" I-< CO......"O
:c co 0.. > >...... ~ :>, J:; QI.~
!:::,;::< ~ ;> ;;. i:-LI. :-<;::::> 0 ~
QI bQ..... Ul...9 Z ,:I ~ ~ ..... .::1
"0 ~ ~ ctl QlU"O j:i..... QI"O ~
.,.,. .~"O..o ......'~ ~ Ul OJ co
'" 0 Q) ,-...... ~ ofi.... S M
~"op..~.B$.<1l~Ql81-<:'-' .
QI ...... _ ;::> Ul!Xl ,:I ;::> H ...,.2 a co
I-< v ~ 0"' tll "0 t:: co'!:;l ....r-.:<.S M
B ~:c f:: ~ I.!)..e J:; 5<'S OJ...... 8
-E '" s:: OJ tll~;::I ~ OJti 0...9 I-<
...... ~..gj..o ~ ~ tll QI I-<'R :>, I-< ~
o ~'{j)"O ::i 0 U !::: ~ OJ"g..gj..o
~QJ Q)"'" 1-<...... Q);::: I-< QJ... I-< tll
,.;;'..0 I-< ;::>0 0 ~..r:: ctl ctl..r:: Ul 0::::
';:::l -..s:;:o-.....o"o.....- ..0
:.0 ~ ~ Ul"O 0 ~..... !::: ~ 13.S 1
:c ;:J"O Ul 'E -;;; ~.lS Q):C "0
~.... OJ 0 oJ C!l 0.. Ul..r:: :g OJ FE'
co "'.::; ~ >-.;> OJ 0.. ~ ~ o's <1l
J:; ca"O Ul i-<-QlO:;:: ca OJ '" U ......CO
o QI ~ ctl tll.................s:;: ca ctl Q)';::<
U 1-<';::< OJ H QI E-< ca E-< OJ C I-<
& ca '0 S'E.~!:l'ofi .:ti it! OJ ~
.... U !::: 0.. 0 0 Ul ~ co OJ..o Z
8 QI a 0 co c.... "0 ',:1.;::< :> >-.."
'0':c:C.;::< I-<.'l:: I-< t:: "0 ctl (aV
l! 1-<.,., ~.Sl "O.@ 0 Q).z S,-..
E-< o..~:c Q) !il 11 s:: ~ 'tlj Ul .....$
l! 0',:1 :> ..... s:: it! ca () ~ 1l!Xl
00..... () j:i~.Sl-<tiu...9 s....."O
ca
.9
"0
~
;::I
"0
~
Q)
..0.
"0 oJ
'35i
0......
~'E
uG
ca~
.~~
u'(il
.!l:!..~
o ca
I-<..r::
p.......
I
QJ'"
..r::'"
E-<~
~
i:l.l
;::
..!:!
R..,
.....
;::
\U
;:::
f}
~
;:,
\U
'""=!
\U
R:;
N')
O"l
O"l
r-<
;:::
<:>
;..:
~
....
~
'""=!
\U
'1::
....
o
~
Vi
~
"0 ~
.S ] 0\ "0
(t! u '";;; '3
QI'" QJ..r::O
p::;OJca..o.....~
'" QI...... :>,
O;::l..ov..o.l!l
.S c;; "0 ] "0 :;J
S:c'3 > OJ p..
ctl!:::o;;.gJS
u..gj ~ U ~....
.......,., '" ca"O "0
i:-LI g);E ~ ~
bQl-<.....stlltll
C"O .,' !::: OJ
~ ~~~lL~
oJ gu tJ ~ (S
1;; ~?ctl..r:: ~
...... ~ p..'E QI
.~ ~Eg .s..o ~
8 ',:1 !2 ~ ~ !:::
QJ .::1 () u "0
..... U"O~u:l!::: .
'f{n;: ru'c:l'a _~ ~
!:::QJ()6b~()
o ofi ~'cr;'cr; i:-LI g
.S
.:!;jQ)
;:J::::
"'Ul
~~
'00
!:::'tlj
"OUl
'3 OJ
o~
~~
UU
iE.s
caQJ
.!:i.~ en
"0 S !5
2.;:.....
Cl s:: ~
QI ca U
!::: d:j QJ
~.2 ~
iJ .~:E
OJ 00...-1
"5' :>, l!l
d::@~
.....:I
i:-LI
OJUl OJZ
ID S3 ..0 U
E5til~ctl<t:
...;C:OJS!Xl
'8 ~ ~ 'tlj "0
........!5 ~ :: ofi ~
..... () Ul ID .8
C;;...9E~
UQJ,.JUl
B~~
UlU
0\
.....
;::
\U
i::
g.
'OJ
;:,
\U
'""=!
\U
r:.::
l'V')
0)
0)
......
;::
8
ct;
~
l::l
S ~
o <:>
8 ~
'""=!
OJ \U
:g 'E
..... l::l
:g U
..s:;: ~
u;
~
~
tll
.9
"0
'OJ
u
::i
"0
OJ
....
OJ
..0.
"Ow
~1;;
0......
~'E
tJG
<1lu:l
o....~
.8 So
.........
U Ul
.~b
o !1:l
......s:;:
0........
I
OJ Ul
..s:;:Ul
E-<~
5~2
;:6~
'1:;;::..,
5"'''1
E ~ ~
";:'"1::1.2:.,
Ei ~
-~
~ 63
5 i:
;: i:
~a
03
~
~
....
~
'E
a
c
.5
;:
a
~
e:i
J:.L1
, < ~
~ QI ~ Eg I.!)]I-m :€
<1l ..0 o I.!) ...... i:i:
tl "O:c I.!) ~ ~ :>,
'(ii '3 u"O .,., S P..
Ul o::lliJ"O p..co
~ ..r::] Ul ;; 0 15
U "'.....s"Ow u
.~ S3 QI 0 s:: :> 0
o ......~ 0 ca QJ .....
HcaOI-<....."O:;..,
0... ..... S::"O '" OJ ;,...
HU.....QJ~..r::ctl
o OJ 0..0 .,., ..... Ul
........... 'S'~ c:: 0 ....... ID
"0 I-< li:J'~ !::: tll u
C p..-:=: <r: I-< g) QJ
~ OJ.;::< i:Q .S1;..a !:::
ctl ofi 6 "0 li:J .B ?<
~ !:::";'o -:=: Ul .:::
H ...... 1:: I.!) .~ u '"
2: ~.;::: al ,rJl ~ QJ
Ol QJ 2....; ~ U o:S
~ ocr >< [/) 0.-4 CIJ QJ
CHOJ....Ug..S
OJ p.. :>,'a QJ OJ ;......
~ c;; ;;lj o:S .!:l "5
:o~!:::"O~o
..9!:::QJo....O"'o
c1J 0) u,~ ~ OJ -4-'
;>"oQI..... H....
OJ ..... .:: 2 Ul"O ~ en
"0 g) OJ';::: S '3 '0'"0
....... I-<..co u 0 1-<'"
o"o':+:l.....o>~
s:: QI!::: 0 ;;. ""'"U
02;>QJHUl(t!!:::
:c .lS.QJ 5i ~ ;E ::l.lS
.~ .~:8 ' ..0 E-< "0 '"
"'0 ':;:l u OJ (lj ...... Q)
8~B]o~~.~:g
ctl . U "0 Ul ..s:;: ~ .S.:=:
-< OJ QJ HZ..........
.~ ClJ..c: OJ U - p..
8 So1: ..r:: ~ p..
. p...... ClJ. ..... < ClJ ~
~11;;a~ S .5 Eg .8.B
00
I
o
~
.-<
....
8
Q:;
IJ.J
~
o
:2:
h
~
~
u
e:i
~
CI"l
cIDOJO\
.~ ",..0 ~ "0
.=:::l:gQJ'3
~-::>..s:;: 0
g).lS 0 ..... ~
H'E ~E.l!l
~..gju"O~
;:J.... <1l Q) p..
8 ~ ~ ~ .S
~ ii:'~ I-< "0
OJ QJ OJ"O QI
~ s::E5~ ~
:>,'tlj .!::: ~
l:i:iUl!1:lOJU
~CJ ~~.s
Ol:>!1:lUl.....
H Q)..... !1:l 0
U......u..r::'>
.~ Q).~..... ;;.
ctl.~ 8 ::l ~
..... 0 p....o I-<
~ !::: OJ..... g
~~ofi@"O
tl~~ _~ ~
cu.....~()
en ~.~ 'co ~ es
f:=
~
CI".l
~
...
Cl
..
':5
oS
<I:l
;::
<::>
....
<I:l
'1:)
..
i::::<
Q
"l1
>-j
.9
'"@
~
"0
~
Q)
..n
~ai
o ~
~......
"'I::
tJ~
l1:l U
.n
Q)....
~~
11
u..9:!
.....
~
Q) Q)
s~
0..l1:l
..Q"3
Q) 8
iiJ :3
"Ou
~.&
C1'Jl1:l
~.~
~.~
ii'"O
sg
..g~
....'"
Q).....
;> ~
00..
'"@.S
'E 35
~.-
uO
C1J ~
;> u
0;J:l
..n"""'
l1:l~
",.l::
<1) Q)
~:~
",'"
<o~
s~
I::..B
.g~ .
...........JIJ
cd r;.t;I U
~~ ~
..... ~ g-.
::E p:: .~
~
~
'"dO
~z
~~
Sh
<J~
~::5
tI)
a~
Zu
.--..Q)
~.8 CIl <1)
S~.E~~ ~ l5
8~.9.....;c:~~
-S2Jme..nQ)
J:i o..ur:::::~~ ~
...... 0 ~ . ,... 0
<oal 0..0 - I::
. .l:: ;> ~.5._ "S '"0 ..;
~.~ S "'..c s:; ;J
~Q)Q)~Q).....<o[:J
{J ~ '15 u..c ~ ~ 0
;:l'"O~"""'"Ou"""'"O
_ Q) r;.t;I"3~r;.t;I-::j
U'"OQ) o' C1'J;::l
5g~gp~ 0\0
~.!- 0............... ~
J:i SCiJu"'Q)2J
"""' cdQ),.J:ju
cd C1J.E [jJ g...c..... ~
.l:: _~..... CIl ::l '"0 >. 0..
<1)-.:J-::j::S' "3..n~
;>"""' ;..l_ Q) 0_.::1
:p2[jJ~~~Q)'"O
cd::l"'l::cd ",Q)
"3o'"OQ)-::jt[jJ.~
E! '"0 "3 '"0 ;::> cd .... Q)
:3:S O'en ~ 0..'"0 tJ
U..n is: ~ u.S].S
~
.....
<.I)
<.I)
~
J:l.1
Z
,... 0
f-l h
.......u
~:::1
;::l ~
OI~
e:lo
<t:u
~
ctJ
-:5
I
'"
.....'"
'" Q)
::s-
'"OctJ
1::0
0.....
tl"2
::lU
.l::::l
;g"2
0....
uQ)
o..n
..."'O~
'"0"3 Q)
C1Jo;>
~iS:..9:!
e!;gl::
2Jof3
u.t;;t.
~ "'.
o..'::;l
I:: 1::......
,.!::l C1J CIl
-:::
~
E
'"1::!
:::
IU
E
~
.....r::::: I::
~~:8
s ~
0- <lJ be
o~:.o
al '"0 's
iiJO-
a:]::;J'"O
r:::::atiJ
'"[j......'"O
cD Cl.. s:;
'"0...... ~
Ct1l.....
Q) '" CIl
8 ~ Q)
~Q)'"
l:)ctJ
Q)
.c: Q) '"
-.:J -:5 0
"""'
o ~^
.... ~
[jJ1::Q)
~:8~
~rn~
~~irl
Q) ';::1'0'
",I::",
ctJ",p.,
",ctl
~"2.E .
~~ o.b
Q)I::.....O
SQ)>'Q)
oc:sl 'i:l,.J:j
.~ ~ r;-1j
o ..c '"0 -E
::::: Q)';3 Q)
J:l~oEi
Q),.J:j ~ Q)
E5 ~''"O'S
....... a ar
.....p.,~",
...
(;f
~
-
:;::
IU
E
g.
~
'"
IU
'"1::!
<l.l
r:l::;
Cl
-
l0-
ci::
'"
t::
11
'"
o
e-
~
'"
~
1ii
~
~
I
en
a]
I:: .l:: ~
:8<lJS.8
uo:S u.....
::l.......... u
.l::::lgJctJ
'" ..c '"0 g.
6 ...... Q) .Ej
u J:::- tI)
:>-. f3 fil :.s
..cq::::u.....
'"0 ';:l;::l <lJ
.& 002:~.....;
t1l.... ctl..... Q)
",,,, '"';>
~ C1Jo~..9:!
Q)'Os:;,"o.....
bli'"O o;:l J::
ti"3:Cof3
::l0.:3:;'~
'"0 U ~ ~'r:!
Q)[jJ<lJ<lJ00
;>..0 Ei ~....
:c.... Q) ;J 'P
.So.=::...... ~ I::
;:l.....g-.<lJctl
""' ~.~ Ei ii
:::::1::
cdO
,.r:::;;
'" U
t2
<1)ti
'813
o-u
Q)-
-:5CiJ
'OC
~.5
'... ~
~'"O
'- '"
-Q)
G!:l
'"
~<o
gs
uo
c.l:J
::;ss
QlU
~~
!:Q'"O
Q)bC
o:S .5
,.J:jiS:
.....0
.~~
OJ Q)
~-:5
.g.......
'" 5j [jJ
8s:c
U QJ'- ·
ctl'E.E
,E.S ~
S '" gJ
U'J o.~
>. cU .El -ci .....
.g ...... :o.~ liJ Q) :-;::: '"0 ",'
~ I:: '0 '(jj 6J.8 o:S ~ a ] -
~ tl ~ ~ 8. g gj ~ . .~ ~ 8.'~
'"0 S .=:: 'x '" OJ J:: ,.J:j'& .9 ~ ~.m..9:!
OJ 'ot! ~ ~gso ~'C;; ~t1l ~'c;;<9
~.....ro I:: _O.....~Q)ObO UI::~
~ en .E 0..-:. -6 -;: gj ",.f S:;.5 ~ il ';> ui
+.t 5J ~ ~ cJ ....-1 cu ~ 0 bO ~ <l) {J ~ OJ
'" .!::l OJ l:">tJ 5-<.f ~ ~.5 '0.. ~ ;> ;:l .--.. Q)
.m:::lliJ 0..,,,, o.r; u;>o,o, [~~.l:J
~'"O 0..] cd '"0.... ::s m ~ rJl _ s:; ~~
~ -+-' OJ ce 1:d Cfj ~ ~ Jjl""""l o'"'d 1""""1 0 a;;.:::l
;; '"0 S tIl cd t1l OJ bO..... ,cd ;::. U OJ.o
~ .-t ro .. -:- ~ "'C'-' ~ ~ ~ 8 C/) ~ ~ ~
Q) fil 50 ,e..!:: ctl I:: ~ :E S ';2 '" gJ li:J ~ ~.....
~ .... '"0 '"0 ro I:: >< 0.."0 gJ ~ 0, cd Q) s:;
c: .~ ~ rn --- ClJ CIl 0..-1 QJ -::I en u en llJ llJ ...... QJ
o Xen '"013'Od'ro.......;::l Q)UI:: OJ.... ctlu
......-:. .8 ::l ~:::I!:l'o S CiJ g' S t1l 0 ~ ctl ~.t1l
t!..9:! ~.8 .... 0, ti tIl' ro .... '"0 :p '"O:P '" bO ,.J:j '"0
::S:9 0;> i'tl;a ~ E J:l 1=< OJ g::3 li1.a:t:: ctlo
J:j ~ ~ ~ '" 0 ro .~ 0 tIl <0 ~ ctl J:l ~ cd :?;.....
;go~ Q).... ~-..... ....CJ1,.c;0'''' is:.....-1::
o 0, 0.. en ~ ~ .!:: @ <Il ~ -6 ..... I:: I:: '" >. 0
U~ ,... ro :;. <lJ 0 ,.J:j~ '" E ....;:j 0 ii;:! :::1'"0
Q) ~ OJ i:> en...... U ~ ClJ,......j U ...... 1-1 ctl: C1J
;> ",' ~ '" '0 ~ ~::l:;. ~ ctl..... :;. <0 '"0....
...-1 CI) ;... ctS a; ~..... u Jj i>- ::::l > co...=:.. 00' C/} ~
t! iti 0 ~ ;> x Q) '::l- - <0 i> I:: '" cd..... ctl
t'tl '> '"00 0 C1J bI) J:jctl &l..... >.0 re ~Q) OJ U
_ i> C1J:C u 0 ~ ....... bli,.J:j 0 '0.. ~ .... 'cr; to ~.~
ctl"2 g.; ~ Q)' -;;; .. ctl Ei ~ ~ 0, <1) <0 '"0 bI) ti ctl
"'...... 0 '" . "'.... !:: ",'", ...... U <O.!::l abI) 0,] 0,'-
.& ~ ..l:i t] -Q) ,.Q Q) ~ OJ'", ctl cd C1J':::I. Q) . OJ "'.
ro"-''"'J:;'" u'"O o,:>;::l......l:J;>.o Q) Q)'&
> a:J >. 0 ~ ,fi'~ 2 UO g" ~.... t1l.:3 oS ~ to :?; ~
~"'~U~___ "'......op.,"''''~o,~~
o:S
I
.
..
.
.
.
.
.
.
1i~8
;:::::0
'1::lo"'l
~ frc-.i"
E ~ ;!
-q;;"1::!.:;:,
::: Ei
~~
~ 1j
::: :::
~ E;
s-B
]
..
~
....
.g
"E:
a
o
:;::
'g
o
EQ
0\
I
o
<:fi
.....
~
~
Vl
~
lo.
o
~
':5
.8
<Il
~
C
....
<Il
.~
~
!:::j
C>
"Ii
l-I
......
~ ~
O~ 1::. tj....~ . "tl
<Ii 'itl O"tl <li8..r::oa
] g [ 1j E . ~.~ e- ~ :UlEJ'" ~i~.E
CIl:r:l.8 .....U 6J6:jctl 0... "tl<li
] ~ '" bQ::! o....r:: gJ 0 <Ii <lifi
8 b ~ .~ tJ ~ ~ [lj "tl ~ ~ Qi ~ .
"tl~ iil -5.8 iijS"~ ~ell~~~~
~ 8bQ ~ ~o .~ .~ 8 ~ .m ~ ~ ~ .E ID
~.5 ~ S1 ~~,sn ll~ ~~ 8 ~
... El b bQ'" 0 I=: 6J c:: ~ c:: u ~
O..."tl s:: I=:C:: ....0..... 1:<. Q)l:<bQ<Ii
~ 0 "'""I .;=< ....:r:l ctl 0 ..o"tl ~..r::
"'~ u '1:J~ .8ctl;::..... 1=:';::
'"00 I=: :-:::~ u....Q) ~ -;artl >-
~ ~ .9 ui .E u:: ~ [i ~ .8.8 -5i is 0 'i:l
C/l Q) 13 ~ <Ii "d I=: S Qi U '" C/l..... . 0
Q)o-'....:::: 13~ O..9:ltllSellOJu~bQ
]~ ~]]] ~ g..5 1:: 53'S1~,9';
Qi ;::I -'" 0 <Ii.-;j .o.::l 0 8 'E I=: !:!l gJ .
:> t:: '::;:J .... ,y :p w..... w Q)'~';:l
..... 0 0 u .8 li:J ~ -:511 S s ~.~ t:: ....
's ~ !:J:E ~.~ tJ ~ rtl :e .0.....8] ~ ~
::: ;; ~ [ ~ 4-< S ~ ~ .E g. ~r5 ~-;a
~'s ..0 0 "tl 0 U :> 5:h '" ~..g ~-5i
.....00 '"0..... "'I=: woo I=: 0 I:<'"OQi....
;9'"O~::S~:8 -:S.8i5..8:p8~w[i
5b~ tf.l s:: I=: l1l . OJ ~...... w U2 'itl .....~ a
'Ul !:i :::::;:j !3.~ [J 'S 0 8 .!:;.... c:: ctl S 0...
.....,p ,S.... w...... S 0-< tf.l..... 6-< ~ 51 ~'5 .~
~;fJ .E~ ::J ~jg ~ ~~ ~ 8 ,8 2d~ ~
.
.
.
.
.
"C
OJ
;:j
.S
"E
Q
u
,...
Eo-<
......
.....
<
:::>
01
~
......
<
"tl
w
U
;::l
"C
QI
....
QI
..0
"tl.
"'3~
o :>
;s..!!:i
~'E
.~ III
xu
O~
:9'~
"'d -en
.8i!:
ell III
w:s
....,
<Il '"
....'"
U QI
rtl-
~~
...........
~~8
:.:0
{j R~
5l3N
l::: R:; ~
~'g~
:::: <::
..s!",
0......
....5
5 l::
i:: l::
]-8
~
~
~
r:.:;
...
{l
'I::
...
a
"
,S
i::
a
Ell
e::
~
V)
Qi...... ~ '" 0)- 00
] ~ ;J'~ s,g ~
'U"......ONI=:CIl
c: .Q .~ ~ $-4 Ou ctlOJ
.~ CIJ U .... Q)
........QI....o~oS
~ OJ: ;:J....
~ ,s a ~..o .c S 1l
00 "0 a "0 OJ,~:P ell
-m QI 8 00:513 ffi:'>::
.... ~.............. 4-< ctl ',jj 0...
-< E-<:;:l 0 04-<';::1 B
..... .'s"'''lQlt::o...
1rl ~ ~O) 0..0:5 .... g-.
.- Ul :> .~ ..... 0
8~ bC..!!:i ~ ctl"tlCi
p.. Ill.El QI OJ I=: 0 I=:
QI:ti:E: u s:; Q)..... <Ii
..r:: ~ U ~ .::l..lli ctl ....
..... ~ 13 gJ "O's-:5 ~
j '!iJ tl 'S .8 <Ii "d ID
.....QI1=:1=: ctl,oQJu
.;; ;: <Ii 0 '!:: 0 '0 ~
i>~QJ.....p..""I=:<Ii
ID Qlu 0:5 Ul 8 ~ QJ:9
C/l III [lj p..o..o ID
::! '-iij ~ p..:P"tl ....
......ll..r::QlctlUo-:::I<Ii
rtl ...."OQlctl;..l~
'0 Ei '~-'" w 0.....
.... 0 <Ii ~'::;:J!:i~ .
~OJ .... El .... bC.P <Il Cl!
4-< CIJ..... c:: ::l.=:<:="
QI .. ~.~ <J:. '"
oSQl[lj-5ili:J...-:..6
U N ID co 0""" "'0 (1) ~
"tl .... ;:>;u;:c,~ 6J 6}
~~ S ell,S~'=: ~
~~Q)Q)CI)OG:l~
.~ ;:> ~ Ul QI U Qi
ctl,oooc::-",~
-aJQlNO"'.::i'itlctl.....
......... x ~-'"....
QJIll....QluiUlUIll
!-j;::l~""'..>.;:j"O
.2 ~~ 8.g ~'$2
::! "0..0 Ul ~Ul U .... QJ
p:..IllQiQl' QiObQ
Na0:5,gQi0:5].s
o
,...;
I
o
-<:t<
......
.~
':S
-
'-
'"'=l
<u
.-
.....
.:
<u
;.:::
~
Ui
~
~
(J)
u
~
o
h
~
~
~
10..
Q
...
':5
~
CIl
;:
o
...
CIl
'15
...
~
Q
"li
~
::s
~
o
f:::
o-..l
tr.J~trJ
~U~
~ ~U)
::> ~c::i
O~U
tr.J >.1.:1 k1
>;Q >.1.:1 U
~ ti:;:
...;! [-.,0:::
<......>.1.:1
~ -'trJ
::> ~O:::
E-< trJ ~
...;! k1 ["""0
::> ~;S
UU.,.
u .S 6:l
~ i;j
~.~ ~
. S ~
~ 's
u.B
~.-i _...-I
~ ca
tjU
~.fi
] 6
,....;
C1J"'C~
:~ ~ .~ 't:i
eLl ti Ei
~~~~
.0 <tl t::
U 'S :8
~ .... <tl
"E ~ .~
~Ll~
....
~ QJ ca
<tl .fj 's
~..r::: 0
.~ ~ ]
~ 13 ~
<tl '"t:l t::
U tl <tl
_~ u "0
':;:l ~ ~
6 ~ S
"0 eLl
s~1iJ
.B~C/)
;;:: CIl 6
CIl eLl ~
o ...... <tl
Q) 'r;; S
'"t:l ....
m ]
:g U CIl
's ~ ~
eLl CIl 0
.:Ej 1 gj
Clu~
~ ~~ ~1{j!~
Ul '" Q) "0 .'" "C
~ ~.fj:3 ~'o
l"i;;;l 0 CIl i>
t::.fi~~fi.fi~
o Q) H
...... ~ a .9 "C
1ii 0 Q)
::r:: "0 !iJ
-E:!"C
-@ '@
.... 8
OJ
.0
"C
'"3
o
~
1
I
......
Ul
...... "C
u
<tl '"3
x ..8
OJ
'"
.B "C
'~ :B
E
'"
III
2 Q)
~ ....
ca
0 Q)
...... -E
eLl
;g
'"
CIl
0
~].B
;j u
uSa;
.S ...... "0
~ S
~o
~ g; ]
......
..l<: ~ til
Ci l E;
~ 0 ~
"0 ..0 .~
...... Q) ~
~-:5~
Q) S
]~Q)
E-<~0:8
Q)
.t:=l
....
Q)
.....
U
<tl
....
ca
,..c::
u
"0
8
.B
......
o
I:<
o
:P
<tl
;:l
......
<tl
:>
Q)
~
o
a:l
fij
"0
Q)
..0
.-<
ca
,..c::
'"
tri
<tl
_ ca :3
\~""'~nj'"d
,S ~ 'S 'S Q)
fi......"Q) ti~
...... c - ...... Q)
~28~"O
OJ 6:l .~ U '"
8 u <tl
"C "0 ~ Cl
OJ8~tj<tl
.0 <tl .~
'EaOE
8C/)u~
eLl <</_
.... .... <tl
1::U
Q)
U u
'""d 'J::
8 ~
:E
cu
....
:El ca
u Q)
...... ....
><
.
~~2
1;;;::0
~ ~~
!)iil"l
E ~ ~
"<<::]2.
;:: '"
..>;'"
R,-
_ 5
!) E
E E
sa
1
~
...
.g
'E
o
u
o
;::
'g
a
m
.-<
.-<
I
o
'<l'
....
,
JI
1{ .~ 1:: ;:g
t:: OJ;:l .
'""dtiSogj
g~~~ ~
ucaOJ<tlo
",u iii ~ gj
~'"t:l"C<G""
g 8] u ~
g; ~ ,.5-0:8
....gjg;......o
"""u:;::~l:l
III "'cu.....
'EJ: ~ 2-B~
-@~ ~Cl.9
Q),..c:: ~ ",-
2U86~
8 Q) Q)...... C
Ill.fj ut-E:!
.... c'::;: 0 0
co""p..p..
rl.....~&ll
~I:<....Q).....
.~ Q) Q) 0:8 cu
@:: g; <<i :>
U'i tl~.S 1l
..l<:
....
<</ ......
0
c I:<
0
~ 0
......
...... ......
'"t:l ca
'"t:l u
<G ..9
" N
~
~
U)
~
l-..
o
..
':E
<:;)
~
tIl
;::
o
...
tIl
'S
..
J::::
Q
'O!i
l""I
~~8
E6~
'1::!l'l..'
!iigjN
E>>::i ~
<<:;'1::!~
;: e
s'"
R..-
_ !ii
!ii E
E ~
lS-u
]
III
~
...
.g
'E
c
u
c
;:
-g
(j
m
Q) Ul .....
-B Ul i:: il
Q) <tl
U U ~
0 ~ <tl
~ ~ Q)
Ul
ctl B Q)
....... p:::
~ Q)
-B ~ i::
~ .5 0 0
Q) :c :c
'0 ttl <<l
..... ;:l :>
~ ....... <<l
Q) <<l Q) u
-:S :> :i ><
Q) Q)
Ei Q)
0 o:S ''0
J:i Q) ~
.....
ttl
~
III ~
:> ca
:c
ttl u
Z .8
ca
u ca
::::l .9 b ~
<<l .9
u ..... Ul
i.I:l 0 Q) .....
:c Ul ~ <tl
.....
i:: III <tl Ul III
Q) :> :;::
Tl '.P '0 Q)
<tl Q) i ~ Ul
CJ:l ..... 1:: .E
Q) i::
u III ~ '0
~ Ul
;:l III i:: .8
0 0 ~ ..... <tl
U -;:::: Ul
U Ul ~ 0 Q)
.6 ell <tl ell
~ '0 ell ~ Cl
. . .
~
'"tl
Q)
::l
.s
i:l
o
u
ciS
~
u
~
;:J
o
tI'J
~
~
...:l
<
~
;:J
E-<
...:l
;:J
U
Q)
,.c
'0
"E
.8
CJ:l
CJ:l
ti
<tl
C'l
,.-!
I
0
~
,...;
.....
0
CJ:l d
<tl
ell 0
~ :P
<tl ctl
'0 ;:l
~ Cil
:>
III
E:l
~
<:I)
~
..
Q
~
'.t:i
.a
Ul
;::
Q
....
Ul
....
r::>
~
i:'l:;
Q
'<:Ii
....
~g]8
i::~~
11 1i} N
~~ ~
<<: ;:! 2:.
.: <;
..!;!'"
Q,~
~ 5
5 i::
E E:
~(j
OJ
iil
"1:!
llJ
J:<:
...
,g
"E
"
u
.~
8
~
g "Cl Ul
!:< ~
:p <tl .9
ctl .....
<tl
] :>
ell
..... CJ
QJ X
..... Q)
<Il
S !:<
,.J:l .9
"Cl '"d .....
CJ
~ Q) ;:J
~ I jj
Ul
u B
Q) u
.....
...... -:S
0 .~
ui
'ti
Q)
::l
.s
-=
o
'-'
r,jj
~
u
::J
o
rr.,
~
I:l:::
~
I:l:::
::J
I-<
...:I
::J
U
ct'l
......
I
o
"'"
......
..0
Not 10 Scale
SOURCE: Crane Transportation Group
FIGURES... 1 -1 "'1 B
Amended Plan Year 201 0 PM. Peak HourVolumes
2/00-367-01
EL CAMINO CORRIDOR REDEVELOPMENT PLAN AMENDMENT SEIR
5.5 CULTURAL RESOURCES
A. SUMMARY
This section focuses on impacts to potential archaeological resources on the California Water Service
Company and Chestnut Creek sites (other impacts to cultural resources within the Project Area h a ve
been addressed by the 1993 EIR). An updated literature searchf tm:ti:-field survey, au~erin~ and soil
corin~s of the sites were conducted in March and April 2000. The literature search confirmed that no
known prehistoric archaeological sites have been recorded within the California Water Service
Company and Chestnut Creek sites, The field sursey identified midden deposits within a man m3-de
earthen feature on the C$llifornia lV.'iter Scr'l3ice Company site; it was eBncluded that the midden
dcpasit was imparted from anather location. Due ta st-tmding water an the sites, the 9.rch9.eolagists
were unable to lJcrify the presence ar absence of prehistoric materials on other portions of the sites. Th e
other work conduded b1f Holman and & Associates found midden on the California Water Service
Compam/ and Chestnut Creek sites. There is potential for this to be a si9:Ylifieant arehaeolo9J-eal
resource that could be affected bv the project. The imple11tmtatian of a meehtl1'l.ieal aug-cr pragram and,
if necessary, hand excavation and resellree recoZ1ery and docu1ncntatifJ11 wellld 1'edllee impacts rcZated to
dcsclapment an the California Water Seri1icc Campany amI Chestnut Creek sites ta a less than
sig'l1-ificant [Cod. Miti~ation measures identified in this EIR include the use of a data recove11J
pro!(ram. However, the use ofa data recoven/ pro~am would be eeowmieallv infeasible at this time;
th erefore, impacts rela ted to th e midden deposit would be considered una voidabl1f sif<Ylifica nt.
B. INTRODUCTION
The Initial Study, published on March 9, 1999, determined that the Amended Redevelopment Plan
would have no new or increased significant impacts related to cultural resources. This determination
was based on the conclusion that the only recorded archaeological site within the Project Area
(CA-SMA-299) had been destroyed, and that impacts related to unknown archaeological resources
would be mitigated by conducting field investigations prior to construction, monitoring during grading or
trenching, and proper documentation of resource finds. The only potential historic resources within the
Project Area were the structures on the McLellan Nursery site, which has since been approved for the
development of 179 single-family homes (under construction) and 34 townhouses (recently occupied).
The Initial Study was prepared using the latest guidance from CEQA regarding impacts to cultural
resources.
14,0-15
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
Subsequent to publication of the Initial Study, the City received information that archaeological
resources could be present on the California Water Service Company and Chestnut Creek sites. This EIR
section presents an evaluation of potential impacts to cultural resources em those sites. The description
discussion is based em an updated literature search and field investigation conducted by Holman &
Associates in March and April 2000.1~ Historical background information is based on the cultural
resources discussion in the 1993 EIR.
C. EXISTING CONDITIONS
Cl. Geographic Setting
The Project Area is within one mile of the San Francisco Bay shore in an area which has been heavily
urbanized with a variety of residential, commercial, and institutional land uses. Prior to the first
development of the area in the 1890s, the corridor site was located near the edge of an extensive tidal
marshland habitat.3 The earliest maps of the area were made in the 1850s and are curated at the U.S.
Geological Survey in Menlo Park, California. These maps delineate a complex system of sloughs that
bordered the Bay shore. The edge of this marshland was marked by grasslands and mixed hardwood
forest.
C2. History
C2 (a) Native American Period
The native peoples who occupied the Project Area vicinity (i.e., the San Francisco Peninsula) at the
time of European contact are known. as Costanoan, a term derived from the Spanish word "Costanos"
meaning coast people. (Native Americans currently living in the Bay Area prefer the term "Ohlone"
meaning "abalone people"). These people subsisted by hnnting, fishing, and the gathering of mussels,
other shellfish, and native plants.4 The immediate ancestors of the local Costanoan people are
1
Holman and Associates Archaeological Consultants, Archival Search and Field Inspection of the Chestnut Creek
Site, South San Francisco, San Mateo County, California, March 16, 2000.
Holman and Associates Archaeological Consultants, Initial Subsurface Archaeological Reconnaissance of Two
Redevelopment Parcels on Chestnut Avenue in the City of South San Francisco, California, April 17. 2000.
California Archaeologist Consultants, Inc., An Archaeological Survey of the Proposed Corporation Yard for the
<:ity of South San Francisco, November 1991.
Ibid.
2
3
'4
14.0-16
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
believed to have moved to the San Francisco region around A.D. 500 from the San Joaquin-Sacramento
River Delta area.S
The Project Area contained one recorded cultural resource site, a Native American archaeological
village (CA-SMA-299)j according to the 1993 EIR, the site has been destroyed.
C2 (b) Spanish Period
The first Europeans to reach the San Francisco area were Spanish explorers. The first expedition in
1769, led by Gaspar de Portola, traveled down the peninsula as far south as present-day Menlo Park.
The second expedition was led by Fernando Rivera and Fray Francisco Palou in 1774. This expedition
followed an inland route.up the peninsula as far as the Golden Gate in search of a suitable mission site.
A third expedition was led by Juan Bautista de Anza in 1776. This expedition resulted in the
establishment of Mission San Francisco de Asis (Mission Dolores). A few months later, Mission Santa
Clara de Asis was founded to the south. EI Camino Real (the trail established by de Anza in 1776)
became a heavily traveled route between the two missions and their outposts.6
C2(c) Mexican Period
During the Mexican rule of California (1822 through 1848), large tracts of land were issued to private
individuals, usually cattle ranchers and hide and tallow traders. The Project Area vicinity was part of
Jose Antonio Sanchez's 14,639-acre Rancho Buri Buri, one of the largest grants an the peninsula. The
rancho owned 10,000 cattle and 1,000 horses as well as several sheep herds. The rancho contained two
adobe houses, a grist mill, and boat landing on a slough from which hides and tallow produced at Buri
Buri were shipped.7
C2 (d) Early American Period
Califomia became part of the United States in 1848 as a result of the treaty of Guadalupe-Hidalgo.
The Gwin Act of 1851 established a commission to settle disputes over the validity of Mexican land
grants. The Sanchez Family ownership of Buri Buri was upheld in 1852. In the following years through
the 1870s, several wealthy Americans including Charles Lux, Ansel L. Easton, and Darious O. Mills
purchased thousands of acres of the Buri Buri Rancho. By the 1850s El Camino Real had grown into a
S Unnamed Archival Review of Cultural Resources on the San Francisco Peninsula.
6 Ibid.
7 Ibid.
14.0-17
EI Camino Corridor Redevelopment PIan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
highway traveled by wagons and stage coaches.8 The 1/12 Mile House", as stage coach station
constructed in 1860, is located adjacent to the Project Area. This station was the origin of the community
of Baden, a multi-ethnic community with an economy based on fishing, agriculture, livestock, and meat
packing. In 1908, the community was incorporated and renamed South San Francisco.
C3~ Undiscovered Cultural and Historical Resources
The Project Area is within a substantial area of potential cultural and historical resources. The ecotone
which existed between marshland and upland habitats described above was attractive to prehistoric
people who subsisted m shellfish, marine mammals, waterfowl, fish grass seeds, acorns, deer, elk,
antelope and other local resources. The location of Colma Creek through the Project Area increases the
likelihood of past use of the area by prehistoric peoples. The peninsula vicinity also has a rich
history from the Spanish, Mexican, and early American periods. Although the Project Area is heavily
urbanized, it is possible that additional undiscovered resources could still exist within the area tha t
could be uncovered during construction-related grading.
C4. Archaeolo~ical Resources on the California Water. Service Company and
Chestnut Creek Sites
Since publication of the Initial Study, the City received information t hat prehistoric archaeological
resources might be present within the California Water Service Company site. During March and
April 2000, Holman & Associates Archaeological Consultants conducted an archaeological records
search, initial surface reconnaissance, preliminary subsurface testing by hand au gering, and subsurface
archaeological reconnaissance via soils coring at the two sites.
A records and base map search at the Northwest Information Center showed that the siteshad not been
previously surveyed for archaeological resources, but that archaeological resources had been found in
several neighboring areas and a potentially significant prehistoric archaeological site was recorded m
the banks of Colma Creek upstream of the sites. The surface reconnaissance found evidence of midden
deposits (a refuse heap of a primitive habitation) within a man-made earthen feature on the
California Water Service Company site, but nothing on the current surface of the rest of that site, or m
8 Ibid.
14.0-18
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
the Chestnut Creek site. Shallow augering conducted by Holman & Associates also produced ro
evidence of cultural resources.
Based 00 information provided by the geotechnical consultants for the project planned on the Chestnut
Creek site, Holman & Associates conducted soils coring at 16 locations, ranging from 12 feet to 28 feet
below the current ground surface. Holman also analyzed materials from four soils cores conducted by the
geotechnical consultants. -Midden was found in six of the seven corings on the Chestnut Creek site. The
midden was five to nine-plus feet below the surface,. and ranged from eight inches to six feet thick.
Midden was found in four of the thirteen corings on the California Water Service Company site. All of
the corings with midden were in the southwest part of the site. The top of the midden ranged from 15 to
24 feet below the surface and was eight inches to seven and one-half feet thick. Holman & Associates
concluded that the midden deposits found on the two sites are part of a continuous shell mound. It
should be noted that a six-lane roadway (Chestnut Avenue) and the creek channel cross the midden and
separate the two sites.
Based on the midden found in the coring-s, Holman & Associates concluded that the prehistoric shell
midden deposit is large, deep, and thick, seems to display intact strata and a definable shape, and
contains materials typical of a habitation site of long duration. The deposit is deeply buried and
appears to be under natural alluvial fill as well as historic artificial fill. The layers of natural fill
rouldindicate the midden is of considerable antiquity, and Holman concludes that the deposit could be
one of the oldest sites m the Peninsula (and thus a highly significant archaeological resource).
Holman notes that, although the site could be the eastern end of previously recorded Site SMA-299,
there is no evidence at this point that the midden is connected to that site.
In addition, pre-and early twentieth century historic materials were found on the California Water
Service Company site; it is yet undetermined whether any intact or potentially significant historic
deposits are present. These historic remains could contain information related to the fonnders and early
inhabitants of the City of South San Francisco.
14.0-19
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2,2000
5.5 Cultural Resources
D. POLICY AND REGULATORY FRAMEWORK
01. South San Francisco General Plan
The following policies in the Historic and Cultural Resources section of the Open Space and
Conservation chapter of the South San Francisco General Plan would apply to the proposed
Redevelopment Plan amenqrnent.
Guiding Policies
· 7.5-G-l: Conserve historic, cultural, and archaeological resources for the aesthetic, educational,
economic, and scientific contribution they make to South San Francisco's identity and quality of
life.
Implementing Policies
· 7.5-1-4: Ensure the protection of known archaeological resources in the city by requiring a records
review for any development proposed [in] areas of known resources.
· 7.5-1-5: In accordance with State Law, require the preparation of a resource mitigation plan and
monitoring program by a qualified archaeologist in the event that archaeological resources are
uncovered.
02. National Historic Preservation Act
The u.S. Department of Housing and Urban Development will partially fund or at minimum oversee
construction of the senior housing project. Therefore, this project must comply with Section 106 of the
National Historic Preservation Act, which requires that any archaeological resources within the
potential impacts zone of an undertaking with Federal involvement be evaluated for eligibility to the
National Register of Historic Places. In order to satisfy the Section 106 requirements and receive
federal funding for the senior housing project, the City is currently undertaking a data recovery program
for the midden deposit found m the Chestnut Creek site.
14.0-20
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
E. PROJECT IMPACTS .
El. Significance Threshold Criteria
To determine whether cultural resources could be significantly impacted for CEQA purposes, the
significance of the resource itself must first be determined.
El(a) Historical Resources
Pursuant to Section 15064.5 of the CEQA Guidelines, an historical resource (including both built
environment and prehistoric archaeological resources) is presumed significant if it is listed on the
California Register of Historical Resources (CRHR) or has been determined to be eligible for listing by
the State Historical Resources Commission. An historical resource may also be considered significant if
the lead agency determines, based on substantial evidence, that the resource meets the criteria for
inclusion in the CRHR. The criteria are as follows:
1. Is associated with events that have made a significant' contribution to the broad patterns of
California's history and cultural heritage;
2. Is associated with lives of persons important in our past;
3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or
represents the work of an important creative individual, or possesses high artistic values; or
4. Has yielded, or may be likely to yield, information important in prehistory or history.
Section 15064.5 of the CEQA Guidelines also assigns special importance to human remains and specifies
procedures to be used when Native American remains are discovered. These procedures are spelled out
under PRC 5097.
El(b) Archaeological Resources
Pursuant to Section 15064.5 of the CEQA Guidelines, archaeological resources, not otherwise determined
to be historical resources, may be significant if they are unique. Pursuant to PRC Section 21083.2, a
unique archaeological resource is defined as an archaeological artifact object, or site about which it can
be clearly demonstrated that without merely adding to the current body of knowledge, there is a high
probability that it meets one of the following criteria:
14.0-21
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
1. Contains information needed to answer important scientific questions and there is a demonstrable
public interest in that information;
2. Has a special and particular quality, such as being the oldest of its type or the best available
example of its type;
3. Is directly associated with a scientifically recognized important prehistoric or historic event or
person.
A nonunique archaeological resource means an archaeological artifact, object, or site that does not meet
the above criteria. Nonunique archaeological resources receive no further consideration under CEQA.
El(c) Human Remains
According to Section 15064.5 of the CEQA Guidelines, all human remains are significant.
E2. Impact Criteria and Methodology
E2(a) Impact Criteria
Section 15065 of the CEQA Guidelines mandates a finding of significance if a project would eliminate
important examples of major periods of California history or pre-history.
In addition, pursuant to Section 15064.5 of the CEQA Guidelines, a project could have a significant
effect on the environment if it "may cause a substantial adverse change in the significance of an
historical resource." A "substantial adverse change" means "physical demolition, destruction,
relocation, or alteration of the resource or its immediate surroundings such that the significance of an
historical resource is impaired." Material impairment means altering "in an adverse manner those
characteristics of an historical resource that convey its historical significance and its eligibility for
inclusion in the California Register of Historical Resources."
According to Appendix G of the CEQA Guidelines (Environmental Checklist Form), a project could have
a significant effect on the environment if it would cause a substantial adverse change in the significance
of an archaeological resource or disturb any human remains.
Impacts to these cultural resources not determined to be significant according to the significance criteria
described above are not considered significant for the purposes of CEQA.
14.0-22
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
E2(b) Impact Methodology
Project activities that would disturb soils and underlying formations have a potential to disrupt or
destroy historically significant or lIDique archaeological resources and human remains. Significant
impacts are most likely to occur when construction-related excavation would damage or destroy an
archaeological deposit, because it may damage or destroy the data potential of the resource that
conveys its historic or scientific significance or uniqueness.
The presence of archaeological resources within a project area prior to development generally is
determined through archaeological reconnaissance--that is inspection of exposed ground surfaces--
sometimes augmented by limited subsurface testing. Many archaeological sites have no surface
manifestations. An area where no sites have been discovered may be assessed as archaeologically
sensitive m the basis of proximity to known archaeological deposits, history of site use, or known
aboriginal or historic settlement patterns. Pursuant to Section 15064.5 of the CEQA Guidelines,
archaeological monitoring during construction and other 11 discovery provisions" may be identified as a
measure to avoid impacts to deposits that might be uncovered during construction. Assessment of the
significance of the known or potential archaeological site or deposit may require additional archival
research or archaeological excavation to ascertain the origin of the deposit, classes of data present,
vertical and horizontal extent of the deposit, and site integrity.
E3. Summary of Impacts in the Previous EIR
The previous FEIR identified the following impacts of the original project (the approved
Redevelopment Plan).
Prehistoric resources within the existing Native American archaeological village site in the project
area could be subject to disturbance during project-facilitated construction. (1993 Final EIR, page IV.K-
3) The Final EIR found that no significant impact would occur if the following mitigation measure is
implemented: a field inspection and evaluation of the identified cultural resource is conducted by a
qualified archaeologist prior to development of the site.
Previously undiscovered cultural or historical resources could be disturbed during construction activity.
(1993 Final EIR, page IV.K-4) The Final EIR found -that no significant impact would occur if the City
requires the implementation of the following mitigation measure: field inspections are conducted prior
to construction, grading or trenching activities are monitored and resource finds are properly
documented.
14.0-23
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2,2000
5.5 Cultural Resources
The project would change the use and character of the Rod McLellan Nursery site, an important element
in the local history. (1993 Final EIR, page N.K-4) The project would change the Rod McLellan
Nursery from a wholesale and retail nursery complex to a residential neighborhood. While the site is
not designated architecturally or historically significant, the project would result in the loss of this
important element in the local history.
E4. Impacts of the Amended Plan
As noted earlier, one prehistoric archaeological site, CA-SMA-299, was recorded inside the Project
Area. CA-SM-299 was evaluated as part of the BART Extension EISjEIR, and it was determined that
the integrity of the site had been "completely destroyed" and that the resource was absent where it
had previously been identified. The Initial Study for this SEIR concluded that the Redevelopment
Plan Amendment would have no impacts on this identified archaeological site at its recorded 1 oca ti on
Sincc publication of t he Initial Study, the City received information that prehistoric archaeological
r-csourccs might be present 'within otr.er portions of the Project Area, v;ithin the California '''later
SerT;ice Company and Chestnut Creek sites. ...'\11 updated archh'al search and field inspection v,;ere
perfurmed :ifl March 2000, spceifieaUy focusing on these portions of the Project /...rea. l... review of
prc;ious reports at the North,Nest Information Center concluded that a two kilometer long midden
deposit had oocc been identified along Cornu Creek in. the area; hov,'c;er, auger testing conducted in
1994 as part of thc C^~ S1L^~ 299 site record fOtHld no C',lidcncc of this reSOllee along the creek. It 'was
confirmed that CA SM:/... 299 is located outside the California Water Ser;icc Company and Chestnut
Creek sites.
The updated field survey found evidence of midden deposits vdthin a man made earthen f-cature on the
California 1Natcr Ser;ice Company sitc. This midden appears to haT;e been imported from. another
location as part of the construction of the earthen featurc. The site report f-or C^~ SM...'\. 299 notes tha t
areas along the creek "l;ere historically mined for topsoil, ;,;him resulted in spreading around the
remains of shell middens to al'ei1S outside the actual prehistoric sites. Due to standing water, Holman
& l~ssocii1tes ...;as unable to ";erify the presence or absence of armaeological materials on other portions
of the California Water SerT;ice Company and Chestnut Creek sites. ...'\3 sum, significant
archaeological resources could be present all those sites, and dc;clopmeIlt in these portions of the Project
Area ,,'I;ould have the potential to disturb those resources. Thi3 ~\;ould be a significant impact.
14.0-24
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
. 5.5 Cultural Resources
As discussed previously, Holman and Associates determined that the California Water Service
Company and Chestnut Creek sites contain "definite and very possibly significant subsurface
prehistoric archaeological deposits."
The footprint of the fire station proposed for the California Water Service Company site is not known
because it has not been designed or sited. If t he fire station is constructed in the part of the site where
midden was found, excavation, structural design and installation of utilities could affect the midden.
This impact would be significant. Disturbance of historic materials found on the California Water
Service Company site could also be significant, if the materials are found to be historically significant.
The geoteclmical consultants for the Chestnut Creek Senior Housing Project have recommended that
overexcavation of the site be reduced to 30 inches below the stripped subgrade, which would result in
excavation three feet below existing grade. Excavation would be about two feet above the shallowest
midden. Excavation would be made with track equipment rather. than rubber tired equipment to reduce
the potential for deep rutting. The geotechnical consultants would examine the bottom of the
excavation to determine whether the subgrade soil can be compacted as originally recommended.
Either (1) an attempt will be made to compact it to at least 90% relative compaction, without
scarification, or (2) a layer of geogrid would be placed at the bottom of the excavation, and engineered
fill . would be placed over the geogrid. However, Holman & Associates have reviewed these
recommendations and believe that the midden could still be affected; therefore, the impact is
considered significant.
F. MITIGATION MEASURES
Fl. Measures Carried Forward from Redevelopment Plan EIR
The California Water Service Company and Chestnut Creek sites were not identified as potential
archaeological resource sites in the 1993 EIR, and no specific mitigation for those sites was identified.
F2. Measures Identified in this SEIR
1. .^~ program of mcrnooical subsurface testing shall bc conducted by a qualified archaeologist to
determine the extent of archaeological depoDits on the Califomia '^luter Department and Chestnut
Creek Dites. The site of the midden deposit found en the California Water Service Company and
14.0-25
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
Chesb.1ut Creek sites shall be recorded with .the California Historical Resources Information
System and a new trinomial designation obtained.
2. Additional fieldwork shall be conducted to determine the exact location of the midden deposit. If
possible, the area studied should extend outside the two sites. This field work shall include
g-eomorpholog-ical expertise to help define the boundaries of artificial and natural fills and
characterize the materials over and under the midden deposit.
3. A Research Design shall be developed to g-uide evaluation of the potential sig-nificance of the
midden deposit.
. This evaluation sha 11 be done within a context considering- the archaeolog-ical record and
extant data base in the immediate vicinity, the area (San Francisco Peninsula), the region (the
Bay Area and Central Coast of California), and the wider setting- (prehistoric California as
defined archaeolog-ically and historically).
. Current research concerns, questions and techniques should be incorporated into the Research
Design and a practical plan developed to obtain sufficient data to place the resource within the
contexts noted above in support of a statement evaluating- the resource scientifically.
. Representatives of local Native American groups with documented ancestral ties to the area
should be contacted for involvement in evaluating- the site. Specifically, a recognized Ohlon.e
representative or group shall be brought into the process early and become the primary channel
for dissemination of information and g-athering of input from the wider Ohlone community.
. The potentially significant historic deposits shall be addressed. Thorough archival research
shall be conducted to provide a report of the historic uses of the site. If a potential for
significant historic deposits is demonstrated, a plan for excavation and evaluation of historic
deposits shall be included in the Research Design and addressed in a mitigation plan.
4. The best available construction plans for the proposed senior housing project and fire station shall
be scrutinized to assess potential impacts to the site in order to calibrate the evaluation effort to
the potential for adverse impacts, and to minimize the adverse impacts caused by archaeological
14.0-26
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
testing and excavation itself, i.e., destructive evaluative techniques should be focused on primary
impact zones and areas of lesser or no impacts should be minimally impacted by evaluation.
5. If the midden deposit is found to be potentially significant, a mitigation plan shall be prepared to
minimize impacts and to guide mitigation efforts. If the projects cannot be modified to avoid the
deposits, a data recovery program shall be undertaken, to include hand excayation of the deposit,
laboratory analysis of recovered material, and documentation in a technical report.
6. Cost and adverse impacts to the site shall be minimized by coordinating archaeological
excavations, if any, with construction excavations dictated by engineering requirements.
4.If significflfit archeological l'e30UI'CCS MC identified, a data rcco';ery progrfl:Hl for archacological
impacts shall be undertaken as follo',vs:
· Hand excavation of the deposit.
· Field data collection 'would be follm','ed by laboratory flfialysi3 of reeo';ered material.
· The results of the data collection and a:nalysis would bc docum.ented ill a tcchftical rcport.
G. CUMULATIVE IMPACTS
Impacts upon cultural resources tend to be site-specific and are assessed on a site-by-site basis. Where
such resources exist, buildout of the Project Area, together with other development in the City and
region, would result in an incremental adverse impact to cultural resources. fu. this case, the cumulative
impact would be to prehistoric and historic archaeological resources. These impacts were addressed in
the 1993 EIR and in the Initial Study for the Amended Redevelopment Plan. The only prehistoric
archaeological site, CA-SMA-299, recorded within the Project Area has already been destroyed and
was previously evaluated as part of the BART Extension EIS/EIR. No other archaeological sites would
be affected by the Amended Plan. It should also be noted that the 25.73-acre preservation parcel on the
eastern slope of San Bruno Mountain within the City of South San Francisco was created and will be
dedicated as open space in perpetuity to preserve CA-SMa-40. Given that the extent of the impacts to
archaeological resources have been fully identified, no significant cumulative impacts are anticipated.
Pro';idcd that mitigation as defined by CEQ/~ and the City of South San Francisco is impIcmcnted in
conjnnction v;ith eumulati';e dc-;elopmcnt in the area, no significant cumulative impacts arc
anticipated.
14.0-27
EI Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000
5.5 Cultural Resources
H. CUMULATIVE MITIGATION MEASURES
No additional mitigation is identified for cumulative impacts.
I. SIGNIFICANCE AFTER MITIGATION
In the absence of a detailed subsurface invcstigation, the typc and extent of prehi3toric archaeological
resources m the California 'Vater Scrvicc Company and Chc3tnut Crcek 3itCS arc not knov.rn at thi3
.fime.:.The significance of the prehistoric and historic remains in the midden deposit on the California
Water Service Company and Chestnut Creek sites is not known. The planning of conshuction to avoid a
significant archaeological site is a typical mitigation measure accepted under CEQA. However,
avoidance of the midden deposit m the California Water Service Company site is speculative, given
that the specific location and development footprint of the fire station is undetermined at this time
and that the extent of the midden deposit is unknown. The requirements for the fire station, identified
by the City as needed to provide adequate fire services, could therefore make avoidance of the midden
deposit infeasible. Furthermore, the City has indicated that implementation of a data recovery
program would be costly and economiCally infeasible, with typical costs ranging from approximately
$100,000 to $400,000. (As mentioned above, data recovery efforts are already required per Section 106
and currently underway for the Chestnut Creek site. These efforts will be leveraged through a
partnership between federal and redevelopment agency funding.) Given that avoidance of the midden
is speculative at this time and that the use of a data recovery program would be economically
infeasible, impacts related to the midden deposit would be considered unavoidably significant.GiveR
thllt futu1'c dC.Tlopmcnt under thc ",'.mendcd Rcde.'cloprncnt Plan could affect significant prchistoric
resources on thesc sites, impacts ','.ould be considered ur.a'.oidably significant.
14.0-28
El Camino Corridor Redevelopment Plan Amendment
Responses to Comments
June 2, 2000