HomeMy WebLinkAbout04_03_BioCity of South San Francisco
Environmental Setting, Impacts, and Mitigation
Biological Resources
751 Gateway Boulevard Project 4.3-1 September 2020
ICF 0662.19
4.3 Biological Resources
4.3.1 Introduction
This section describes the environmental and regulatory setting for biological resources. It also
describes impacts associated with biological resources that would result from implementation of
the proposed project and mitigation for significant impacts where feasible and appropriate.
4.3.2 Environmental Setting
The 7.4-acre project site is completely developed. It includes a six-story, approximately 170,235-
square-foot office building at 701 Gateway Boulevard and surface parking lots with 558 parking
spaces. The project site is bounded by a commercial and office building (901 Gateway Boulevard)
and a surface parking lot to the north, Gateway Boulevard to the east, a surface parking lot to the
south, and commercial and office buildings to the west. Landscaping on the project site is limited
to trees and ornamental landscape features, such as parking and building buffers. The project site
contains approximately 227 trees, including 35 protected trees.1,2 The trees and buildings on or
adjacent to the project site could provide nesting substrate for bird species. No sensitive natural
communities, wetlands, streams, or other aquatic features are present on the project site.
The determination rationale regarding the potential for special-status species to occur within the
biological resources study area3 is discussed in Section 4.3.4.2, Approach to Analysis.
4.3.3 Regulatory Framework
4.3.3.1 Federal
Federal Endangered Species Act
The federal Endangered Species Act (FESA) (16 United States Code [USC], Section 1531 et seq.)
designates threatened and endangered animal and plant species and provides measures for their
protection and recovery. Take (i.e., to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or
collect or attempt to engage in any such conduct) of listed plant or wildlife species is prohibited
without first obtaining a federal permit. The FESA also generally requires a determination of critical
habitat for listed species. If critical habitat has been designated, impacts on areas that contain the
primary constituent elements identified for the species, whether or not the species is currently
present, are also prohibited. FESA Section 7 (for actions by federal agencies) and Section 10 (for
actions by non-federal agencies) provide pathways for obtaining authority to take listed species.
1 Arborwell. 2020. 701 Gateway Boulevard Tree Inventory and Assessment, 701 Gateway Boulevard, South
San Francisco, California. February 12.
2 City of South San Francisco. n.d. South San Francisco Municipal Code. Chapter 13.30, Tree Preservation.
Available: http://www.qcode.us/codes/southsanfrancisco/?view=desktop&topic=13-13_30-13_30_080.
Accessed: March 25, 2020.
3 The biological resources study area varies depending on the type of resource (e.g., a one-mile radius from the
project site, the 7.5-minute quadrangle in which the project site is located and the adjacent quadrangles, etc.).
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Migratory Bird Treaty Act
The federal Migratory Bird Treaty Act (MBTA) (16 USC, Section 703, Supplement I, 1989) prohibits
any attempt to take, kill, possess, sell, or trade migratory birds, except in accordance with
regulations prescribed by the Secretary of the Interior. This act applies to whole birds, parts of
birds, and bird nests and eggs. Although the MBTA itself does not provide specific take avoidance
measures, the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and
Wildlife (CDFW), over time, have developed measures regarding take avoidance with respect to
nesting birds. These measures include avoiding vegetation removal or ground disturbance during
the nesting season (typically February 15–September 15), conducting preconstruction nesting
bird surveys in a project area during nesting season, and establishing appropriately sized
protective buffers if active nests are found.
Federal Clean Water Act, Section 404
The Clean Water Act is the primary federal law that protects the quality of the nation’s waters,
including wetlands, lakes, rivers, and coastal areas. Section 404 of the Clean Water Act regulates the
discharge of dredged or fill material into the waters of the United States, including wetlands. The
Clean Water Act provides that all discharges into the nation’s waters are unlawful unless specifically
authorized by a permit; issuance of such permits constitutes its principal regulatory tool.
The U.S. Army Corps of Engineers (USACE) is authorized to issue Section 404 permits, which allow
the placement of dredged or fill materials into jurisdictional waters of the United States under
certain circumstances. The USACE issues two types of permits under Section 404: general permits,
which are either nationwide permits or regional permits, and standard permits, which are either
letters of permission or individual permits. General permits are issued by the USACE to streamline
the Section 404 permitting process for nationwide, statewide, or regional activities that have
minimal direct or cumulative environmental impacts on the aquatic environment. Standard permits
are issued for activities that do not qualify for a general permit because they may have more than a
minimal adverse environmental impact.
Federal Clean Water Act, Section 401
Under Clean Water Act Section 401, applicants for a federal license or permit to conduct activities that
may result in the discharge of a pollutant into waters of the United States must obtain certification
from the state in which the discharge would originate. Therefore, all projects that have a federal
component and may affect state water quality, including projects that require federal agency approval,
such as issuance of a Section 404 permit, must also comply with Clean Water Act Section 401 and the
Porter-Cologne Water Quality Control Act (PCWQCA). In California, Section 401 certification is handled
by the nine Regional Water Quality Control Boards (RWQCBs) and the State Water Resources Control
Board (SWRCB). The City of South San Francisco falls under the jurisdiction of the San Francisco Bay
RWQCB. The San Francisco Bay RWQCB must certify that the discharge will comply with State water
quality standards and other requirements of the Clean Water Act.
4.3.3.2 State
California Endangered Species Act
Administered by the CDFW, the California Endangered Species Act (CESA) prohibits the take of listed
species as well as species that are formally under consideration for listing in California, referred to as
candidate species. Under the CESA, take means to “hunt, pursue, catch, capture, or kill or attempt to
City of South San Francisco
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hunt, pursue, catch, capture, or kill” (California Fish and Game Code Section 86). Under this definition,
in contrast to the FESA, the CESA does not prohibit harm to a listed species. Furthermore, take under
the CESA does not include “the taking of habitat alone or the impacts of the taking.” However, the
killing of a listed species that is incidental to an otherwise lawful activity and not the primary purpose
of the activity constitutes take under the CESA.
State Fish and Game Code, Section 1600–1616
The CDFW has jurisdictional authority over streams and lakes, as well as wetland resources
associated with these aquatic systems, under California Fish and Game Code Section 1600 et seq.
The CDFW has the authority to regulate work that will “substantially divert or obstruct the natural
flow of, or substantially change or use any material from the bed, channel, or bank of, any river,
stream, or lake, or deposit or dispose of debris waste or other material containing crumbled,
flaked, or ground pavement where it may pass into any river, stream, or lake” (California Fish and
Game Code Section 1602.). An entity that proposes to carry out such an activity must first inform
CDFW. Where CDFW concludes that the activity will “substantially adversely affect an existing
(2014) fish or wildlife resource,” the entity proposing the activity must negotiate an agreement
with CDFW that specifies terms under which the activity may be carried out in a way that protects
the affected wildlife resource.
Porter-Cologne Water Quality Control Act
California Water Code Section 13260 requires “any person discharging waste, or proposing to
discharge waste, in any region that could affect the waters of the state to file a report of discharge
(an application for waste discharge requirements).” Under the Porter-Cologne Water Quality Control
Act (PCWQCA) definition, waters of the state are “any surface water or groundwater, including saline
waters, within the boundaries of the state.” Although all waters of the United States that are within
the borders of California are also waters of the state, the reverse is not true. Accordingly, California
retains authority to regulate discharges of waste into any waters of the state, regardless of whether
USACE has concurrent jurisdiction under CWA Section 404. If USACE determines that a wetland is
not subject to regulation under Section 404, CWA Section 401 water quality certification is not
required. However, the RWQCB may impose waste discharge requirements (WDRs) if fill material is
placed into waters of the state.
Waters of the State
Under the recent Wetland Riparian Area Protection Policy (May 28, 2020), RWQCBs will maintain
jurisdiction over features excluded in the U.S. Environmental Protection Agency (EPA) and the
Department of Army’s Navigable Waters Protection Rule (NWPR). The newly adopted regulations
(April 2, 2019) create a new statewide wetland definition that expands to features not previously
covered under federal law and creates a new permitting program for activities that result in the
discharge of dredged or fill materials to any waters of the state. The new rules are adopted under
the state PCWQCA. Under the latter act, waters of the state are broadly defined as “[a]ny surface
water or groundwater, including saline waters within state boundaries,” including both natural and
certain artificial or constructed facilities. Waters of the state include both waters of the United States
and non-federal waters of the state.
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Environmental Setting, Impacts, and Mitigation
Biological Resources
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California Native Plant Protection Act
The California Native Plant Protection Act of 1977 (CNPPA) prohibits the importation of rare and
endangered plants into California, take of rare and endangered plants, and sale of rare and
endangered plants. The CESA defers to the CNPPA, ensuring that state-listed plant species are
protected when state agencies are involved in projects that are subject to CEQA. In this case, plants
that are listed as rare under the CNPPA are not protected under the CESA but rather under CEQA.
California Fish and Game Code – Fully Protected Species
Certain species are considered fully protected, meaning that the California Fish and Game Code
explicitly prohibits all take of individuals from these species, except for take permitted for scientific
research. Fully protected amphibians and reptiles, fish, birds, and mammals are listed in
Sections 5050, 5515, 3511, and 4700, respectively, of the California Fish and Game Code. It is
possible for a species to be protected under the California Fish and Game Code but not be fully
protected. For instance, the mountain lion (Puma concolor) is protected under Section 4800 et seq.
but is not a fully protected species.
California Fish and Game Code – Protection of Birds and Their Nests
Under Section 3503 of the California Fish and Game Code, it is unlawful to take, possess, or
needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any
regulation made pursuant thereto. Section 3503.5 of the California Fish and Game Code prohibits
take, possession, or destruction of any birds in the orders Falconiformes (hawks) or Strigiformes
(owls) or of their nests and eggs. Migratory non-game birds are protected under Section 3513,
whereas other specified birds are protected under Section 3800.
4.3.3.3 Local
South San Francisco General Plan
The City of South San Francisco (City) 1999 General Plan provides a vision for long-range physical
and economic development of the City, provides strategies and specific implementing actions, and
establishes a basis for judging whether specific development proposals and public projects are
consistent with the City’s plans and policy standards. The City General Plan contains an Open Space
and Conservation Element, which outlines policies relating to habitat and biological resources, water
quality, air quality, greenhouse gas emissions and historic and cultural resources conservation. The
General Plan includes the following policies applicable to biological resources:
l Policy 7.1-G-1: Protect special-status species and supporting habitats within South San Francisco,
including species that are state or federally listed as endangered, threatened, or rare.
l Policy 7.1-I-1: Cooperate with state and federal agencies to ensure that development does not
substantially affect special-status species appearing on any state or federal list for any rare,
endangered, or threatened species. Require assessments of biological resources prior to approval
of any development on sites with ecologically sensitive habitat, as depicted in Figure 7-1.
l Policy 7.2-G-1: Comply with the San Francisco Bay Regional Water Quality Control Board
regulations and standards to maintain and improve the quality of both surface water and
groundwater resources.
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l Policy 7.2-G-3: Discourage use of insecticides, herbicides, or toxic chemical substances within
the City.
l Policy 7.2-I-1: Continue working with the San Francisco Bay Regional Water Quality Control
Board in the implementation of the National Pollutant Discharge Elimination System and
continue participation in the San Mateo Countywide Stormwater Pollution Prevention Program
for the protection of surface water and groundwater quality.
South San Francisco Municipal Code
Chapter 13.30, Tree Preservation, of the South San Francisco Municipal Code concerns the preservation
of trees for the health, welfare, and quality of life of the citizens of the City. Trees preserve the scenic
beauty of the City, maintain ecological balance, prevent the erosion of topsoil, counteract air pollution
and oxygenate the air, absorb noise, maintain a climatic and microclimatic balance, help block wind,
and provide shade and color. The chapter is designed to:
l Provide standards and requirements for the protection of certain large trees (trees with a
circumference of 48 inches or greater at 54 inches above the natural grade), heritage trees, as
well as trees and stands with unique characteristics (having been so designated by the Parks
and Recreation director);
l Provide standards and requirements for the planting and maintenance of trees for new
development; and
l Establish recommended standards for the planting and maintaining of trees on property that is
already developed.
The chapter achieves these objectives in ways that support and encourage reasonable economic
enjoyment of private property, not in ways that prevent it (Ordinance 1271, Section 1 [part], 2000;
Ordinance 1060, Section 1 [part], 1989).
According to South San Francisco Municipal Code Chapter 13.30, certain trees are subject to
conditions before being removed, pruned, or otherwise materially altered. Protected trees include
heritage trees and are defined by South San Francisco Municipal Code Chapter 13.30.020 as follows:
1. Any upright, single-trunked tree of a species not considered to be a heritage tree, as defined in
Subsection 3, below, or listed in Subsection 2, below, with a circumference of 48 inches or more
when measured 54 inches above natural grade; or
2. Any upright, single-trunked tree of the following species: blue gum (Eucalyptus globulus), black
acacia (Acacia melanoxylon), myoporum (Myoporum lactum), sweetgum (Liquidambar
styraciflua), glossy privet (Lingustrum lucidum), or Lombardy poplar (Populus nigra), with a
circumference of 75 inches or more when measured 54 inches above natural grade; or
3. Any upright, single-trunked tree considered to be a heritage tree species, with a circumference
of 30 inches or more when measured at 54 inches above natural grade. A heritage tree means
any of the following: California bay (Umbellaria californica), oak (Quercus spp.), cedar (Cedrus
spp.), California buckeye (Aesculus californica), Catalina ironwood (Lyonothamnus
asplenifolium), strawberry tree (Arbutus spp.), mayten (Maytenus boaria), or little gem dwarf
southern magnolia (Magnolia grandiflora, “Little Gem”).
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Biological Resources
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4. A tree or stand of trees so designated by the director, based upon findings that it is unique and
of importance to the public due to its unusual appearance, location, historical significance, or
other factor; or
5. A stand of trees in which the director has determined each tree is dependent upon the others
for survival.
Protected trees cannot be removed or pruned without a permit from the City and must be
protected from development-related impacts such as soil compaction and underground trenching
for utilities. In addition, new developments must conform to a series of tree planting
requirements.
Gateway Specific Plan
The Gateway Specific Plan covers the portion of the East of 101 Area Plan from east of the Caltrain
tracks to the eastern boundary of the parcels along the east side of Gateway Boulevard and the
area between Oyster Point Boulevard and Grand Avenue on the northern and southern
boundaries. The Specific Plan is “intended to provide for various commercial and research and
development land uses integrated by consistent development standards.” The Gateway Specific
Plan includes the following construction standards and open space standards applicable to
biological resources:
l Construction Standard 1(f): Protection of Trees. Construction vehicles and equipment and
excavated soils shall be kept away from under the canopy of any trees on the Site which are to
be preserved.
l Construction Standard 3(a)-(f): In general, to be approved, landscaping plans ordinarily must
provide for the following:
a. Completion of landscaping on the Site contemporaneously with completion of the Building
and other Improvements on the Site;
b. Automatic underground sprinkling systems for all landscaped areas;
c. Landscaping which does not obstruct sight lines at street or driveway intersections;
d. Preservation of existing trees to the extent practical;
e. At least one (1) tree for each 2,000 square feet of area between Building lines and street
Property Lines with the exception of paved areas and parking islands;
f. Reasonable access to public and private utility lines and easements for installation and
repair.
l Open Space Standards. Open space areas shall be conserved, designed and developed to
enhance the environmental quality of the Site and to achieve safe, efficient and harmonious
development of the Site.
East of 101 Area Plan
The East of 101 Area Plan, which was adopted in 1994 and most recently amended in 2016, sets
forth specific land use policies for the East of 101 Area. The City interprets the East of 101 Area
Plan as a design-level document. Per Policy IM-5, the Gateway Specific Plan is not affected by the
land use regulations of the East of 101 Area Plan. Therefore, the policies set forth in the General
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Plan are the guiding policies and supersede all Conservation Element policies set forth in
Chapter 11 of the East of 101 Area Plan. Nonetheless, the East of 101 Area Plan contains the
following policies applicable to biological resources:
l Policy CON-4: The City shall take all feasible measures to preserve any sensitive plant and animal
species that occur in the East of 101 Area.
l Policy CON-5: Prior to receiving approval for construction activities or other disturbances on
undeveloped land in the East of 101 Area project sponsors shall conduct environmental analyses to
evaluate the site-specific status of sensitive plant and animal species.
l Policy CON-6: If sensitive plant or animal species would be unavoidably affected by a proposed
project the City shall require the project developer to implement appropriate mitigation measures.
l Policy CON-7: New development adjacent to sensitive resource areas shall be required to
incorporate the following measures into the project design:
¡ Shield lights to reduce offsite glare.
¡ Provide buffer areas of at least 100 feet between known sensitive resources and the
development area.
¡ Landscape all onsite buffer areas with native vegetation to screen habitat areas from adjacent
land uses.
¡ Restrict entry to habitat areas through devices such as fencing, landscaping, or signage.
¡ Ensure that runoff from development does not adversely affect the biotic values of adjacent
wetlands or other habitat areas.
4.3.4 Impacts and Mitigation Measures
4.3.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant biological
resources impact if it would:
l Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or
regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
l Have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, regulations or by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service;
l Have a substantial adverse effect on state or federally protected wetlands, including, but not limited
to, marsh, vernal pool, coastal areas, etc., through direct removal, filling, hydrological interruption,
or other means;
l Interfere substantially with the movement of any native resident or migratory fish or wildlife
species, or with established native resident or migratory wildlife corridors, or impede the use of
native wildlife nursery sites;
l Conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance; or
l Conflict with the provisions of an adopted habitat conservation plan, natural community
conservation plan, or other approved local, regional, or state habitat conservation plan.
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4.3.4.2 Approach to Analysis
Evaluation of the proposed project is based on a desktop review of the following sources:
l California Natural Diversity Database4 (CNDDB) species list query for a 1-mile buffer around
the project site;
l California Native Plant Society5 species list query for the U.S. Geological Survey (USGS) South
San Francisco (3712264), Hunters Point (3712263), Montara Mountain (3712254), and San
Mateo (3712253) 7.5-minute quadrangles;
l USFWS6 Information for Planning and Consultation (IPaC) query of the project site;
l Arborwell 701 Gateway Boulevard Tree Inventory and Assessment;7
l City of South San Francisco General Plan;8
l National Wetland Inventory and U.S. Environmental Protection Agency (EPA) for the
identification of waters and wetlands, using existing water/wetland inventory data;9,10 and
l Aerial imagery from Google Earth.11
4.3.4.3 Impact Evaluation
Impact BIO-1: The proposed project would not have a substantial adverse effect, either
directly or through habitat modifications, on any species identified as a candidate,
sensitive, or special-status species in local or regional plans, policies, or regulations or by
the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. (Less than
Significant with Mitigation)
The project site and surrounding area are characterized by dense urban development and are void
of natural land cover or communities. Special-status species that have the potential to occur on
the project site or in the surrounding area include the pallid bat (Antrozous pallidus) and
peregrine falcon (Falco peregrinus).
4 California Department of Fish and Wildlife. 2020. California Natural Diversity Database RareFind Records Search.
RareFind Version 5. Available: https://www.wildlife.ca.gov/Data/CNDDB/Maps-and-Data. Accessed: March 24, 2020.
5 California Native Plant Society. 2019. Online Inventory of Rare and Endangered Plants of California. Available:
http://cnps.site.aplus.net/cgi-bin/inv/inventory.cgi/Html?item=checkbox_9.htm. Accessed: March 24, 2020.
6 U.S. Fish and Wildlife Service. 2019. IPaC Species List. Available: https://ecos.fws.gov/ipac/. Accessed: March 24, 2020.
7 Arborwell. 2020. 701 Gateway Boulevard Tree Inventory and Assessment. Prepared for Alexandria Real Estate
Equities, Inc., San Francisco, CA.
8 City of South San Francisco. 1999. City of South San Francisco General Plan, Chapter 7: Open Space and
Conservation Element. Available: https://www.ssf.net/departments/economic-community-
development/planning-division/general-plan. Accessed: March 25, 2020.
9 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/data/Mapper.html. Accessed: March 25, 2020.
10 U.S. Environmental Protection Agency. 2020. WATERS GeoViewer. Available:
https://www.epa.gov/waterdata/waters-geoviewer. Accessed: March 24, 2020.
11 Google Earth Pro. 2018. Online research, 751 Gateway Boulevard, 37.660400°N and -122.397050°W. Available:
https://www.google.com/earth/versions/#earth-pro. Accessed: March 24, 2020.
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Pallid bat is designated as a species of special concern by CDFW. Suitable foraging habitat is open,
natural land cover such as grasslands, shrublands, woodlands, and forests. For roosting, pallid bat
prefers rocky outcrops, cliffs, and crevices with access to open habitats for foraging. Day roosts
are in caves, crevices, mines, and occasionally in hollow trees and buildings; night roosts may be
in more open sites, such as porches and open buildings. Roosts must protect bats from high
temperatures, and pallid bats are very sensitive to disturbance of roosting sites.12 Although pallid
bat may forage over the project area on occasion, the project site does not provide suitable
foraging or roosting habitat for the species. Due to the marginal roosting habitat, lack of foraging
habitat, and high level of disturbance, it is considered unlikely that pallid bat would be present at
the project site. There are no recent CNDDB occurrences of pallid bat in San Mateo County and no
CNDDB occurrences of pallid bat in nearby San Francisco County. The nearest CNDDB occurrence
for pallid bat (occurrence #294) is from 1947 and located approximately 3.2 miles south of the
project site. Therefore, impacts on pallid bat foraging habitat are not likely, and the impact on
pallid bat would be less than significant.
Peregrine falcon is designated as fully protected by CDFW. Peregrine falcons normally nest in a
scrape on a cliff ledge, but will also nest in snags or large vacant nests in trees and on structure
ledges including buildings; pigeons are often favored prey around cities.13 Although nesting
habitat onsite is marginal due to the moderate stature of the existing on-site trees and the six-
story14 existing building on the project site, the buildings and trees within and surrounding the
project site may provide suitable nesting and roosting habitat for this species. Additionally, open-
air space in and around the project site provides foraging habitat if prey is present. The nearest
CNDDB occurrence for peregrine falcon (occurrence #55) was in 2014. Although CNDDB does not
disclose the exact location of the occurrence, the size of the occurrence area is approximately 8
square miles and it includes the project site. The CNDDB occurrence indicates the nest was located
on the side of a hangar, which is a structure typically at an airport. Thus, it is presumed the
occurrence was approximately two miles south of the project site at San Francisco International
Airport. Nonetheless, if nests of this species are present on-site or in the surrounding area, and
eggs, nestlings, or nesting individuals are harmed or killed during tree removal or substantially
affected by construction noise or nighttime lighting during operation, a significant impact would
occur.
On-site buildings and landscaped areas may also provide suitable nesting habitat for resident and
migratory birds that are protected by state (California Fish and Game Code Sections 3503 and
3513) and federal (MBTA) laws. If the project is implemented during the nesting season (February
15–September 15), tree removal and construction associated with the project could impact active
nests, resulting in take (i.e., direct mortality of adult or young birds, the destruction of active
nests, disturbance of nesting adults, with associated nest abandonment and/or loss of
reproductive effort), which would be a significant impact.
12 Harris, J. 2008. Life history account for Pallid Bat. California Wildlife Habitat Relationships (CWHR) Version 9.0.
California Department of Fish and Game and California Interagency Wildlife Task Group. . Available from:
http://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=2349 Accessed: July 28, 2020. . Accessed July 28, 2020.
13 National Audubon Society, 2018. Guide to North American Birds –Peregrine Falcon (website). Available online
at: https://www.audubon.org/field-guide/bird/peregrine-falcon. Accessed July 21, 2020.
14 The six-story building within the project site is considered to be of moderate stature because peregrine falcons
have only been documented to nest on a 33-story building in the City of San Francisco.
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Implementation of Mitigation Measure BI-1, Preconstruction Nesting Bird Surveys and Buffer
Areas, would reduce potential impacts on peregrine falcon and other nesting birds covered under
the California Fish and Game Code and MBTA to less than significant with mitigation by
ensuring that project activities would not affect nesting special-status species or other resident or
migratory birds.
Mitigation Measure BI-1: Preconstuction Nesting Bird Surveys and Buffer Areas
The project sponsor shall protect nesting birds and their nests during construction by
implementation of the following measures:
a. To the extent feasible, conduct initial activities, including, but not limited to, vegetation
removal, tree trimming or removal, ground disturbance, building or parking lot
demolition, site grading, and other construction activities which may compromise
breeding birds or the success of their nests outside the nesting season (February 15–
September 15).
b. If construction occurs during the bird nesting season, a qualified wildlife biologist* shall
conduct a nesting bird preconstruction survey within 14 days prior to the start of
construction or demolition at areas that have not been previously disturbed by project
activities or after any construction breaks of 14 days or more. The survey shall be
performed within 100 feet of the applicable construction phase area in order to locate any
active nests of passerine species and within 300 feet of the applicable construction phase
area to locate any active raptor (birds of prey) nests, and this survey shall be of those
areas that constitute suitable habitat for these species.
c. If active nests are located during the preconstruction nesting bird survey, a qualified
biologist shall determine if the schedule of construction activities could affect the active
nests; if so, the following measures would apply:
1. If the qualified biologist determines that construction is not likely to affect an active
nest, construction may proceed without restriction; however, a qualified biologist
shall regularly monitor the nest at a frequency determined appropriate for the
surrounding construction activity to confirm there is no adverse effect. Spot-check
monitoring frequency would be determined on a nest-by-nest basis, considering the
particular construction activity, duration, proximity to the nest, and physical barriers
that may screen activity from the nest.
2. If it is determined that construction may cause abandonment of an active nest, the
qualified biologist shall establish a no-disturbance buffer around the nest(s), and all
project work shall halt within the buffer to avoid disturbance or destruction until a
qualified biologist determines that the nest is no longer active. Typically, buffer
distances are 100 feet for passerines and 300 feet for raptors; however. the buffers
may be shortened if an obstruction, such as a building, is within line-of-sight between
the nest and construction.
3. Modifying nest buffer distances, allowing certain construction activities within the
buffer, and/or modifying construction methods in proximity to active nests shall be
approved by the qualified biologist and in coordination with the Planning Division. To
the extent necessary to remove or relocate an active nest, such removal or relocation
shall be coordinated with the Planning Division, and the removal or relocation shall be
in compliance with the California Fish and Game Code and other applicable laws.
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4. Any work that must occur within established no-disturbance buffers around active
nests shall be monitored by a qualified biologist. If adverse effects in response to
project work within the buffer are observed and could compromise the nest, work
within the no-disturbance buffer(s) shall halt until the nest occupants have fledged.
5. Any birds that begin nesting within the project area and survey buffers amid
construction activities are assumed to be habituated to construction-related or similar
noise and disturbance levels. Work may proceed around these active nests subject to
Measure c.2 above.
* The experience requirements for a “qualified biologist” shall include a minimum of 4 years
of academic training and professional experience in biological sciences and related
resource management activities, and a minimum of 2 years of experience conducting
surveys for each species that may be present within the project area.
Impact BIO-2: The proposed project would not have a substantial adverse effect on any
riparian habitat or other sensitive natural community identified in local or regional plans,
policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and
Wildlife Service. (No Impact)
The project site and surrounding area are completely developed, composed entirely of
commercial and office buildings that are interspersed with turf areas and landscaping as well as
paved parking lots, sidewalks, and surface streets. No riparian habitat or other sensitive natural
community is present on the project site or in the immediate vicinity. The existing on-site
ornamental vegetation is not a sensitive natural community. Colma Creek, located approximately
0.7 mile southwest of the project site, is concrete lined and has little to no riparian habitat. The
proposed Project would not result in any impacts to this feature. The closest areas with potential
for sensitive natural communities include the shoreline of San Francisco Bay and San Bruno
Mountain State and County Park, approximately 0.2 mile northeast and 0.3 mile northwest of the
project site, respectively. The proposed project would have no effect on these areas because of
their respective distances from the project site. Therefore, the project would have no impact. No
mitigation is required.
Impact BIO-3: The proposed project would not have a substantial adverse effect on state or
federally protected wetlands, including, but not limited to, marsh, vernal pool, coastal
areas, etc., through direct removal, filling, hydrological interruption, or other means. (No
Impact)
No federally protected wetlands or other jurisdictional waters are present on the project site or in
the immediate vicinity. The nearest federally protected wetlands in proximity to the project site
are the riverine habitat located approximately 0.2 mile north of the project site, along the east side
of U.S. 101, and the estuarine and marine deep-water habitat located approximately 0.2 mile
northeast of the project site, which is associated with San Francisco Bay.15 The project site is
separated from these features by dense urban development, including multiple paved roads.
Therefore, the proposed project would have no impact on state or federally protected wetlands.
No mitigation is required.
15 U.S. Fish and Wildlife Service. 2019. National Wetland Inventory. October 8. Available:
https://www.fws.gov/wetlands/Data/Data-Download.html/. Accessed: March 25, 2020.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Biological Resources
751 Gateway Boulevard Project 4.3-12 September 2020
ICF 0662.19
Impact BIO-4: The proposed project would not interfere substantially with the movement
of any native resident or migratory fish or wildlife species, or with established native
resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
(Less than Significant with Mitigation)
No wetlands or running waters are present in the vicinity of the project site; therefore, the project
would have no impact on the movement of fish species. As discussed above under Impact BIO-1,
existing structures and trees on the project site could provide nesting habitat for resident and
migratory birds, therefore, the project has the potential to affect a native wildlife nursery site, which
would be a significant impact. Implementation of Mitigation Measure BI-1, Preconstruction Nesting
Bird Surveys and Buffer Areas would reduce this impact to less than significant with mitigation by
ensuring that project activities would not impede the use of native wildlife nursery sites.
Wildlife corridors are described as pathways or habitat linkages that connect discrete areas of
natural open space that would otherwise be separated or fragmented by topography, changes in
vegetation, or natural or man-made obstacles, such as urbanization. Because the project site and
surrounding area are developed, it does not connect directly to areas of natural open space. Any
common urban-adapted species that currently move through the project site would continue to be
able to do so following project construction. Nonetheless, the likelihood exists for trees on the
project site to be used by migratory birds because of the site’s location along the Pacific Flyway
and proximity to San Bruno Mountain and San Francisco Bay. A potentially significant impact
would occur if a substantial number of nesting migratory birds were injured or killed during
construction or operation of the project. Implementation of Mitigation Measure BI-1,
Preconstruction Nesting Bird Surveys and Buffer Areas would reduce potential impacts on nesting
migratory birds covered under the California Fish and Game Code and MBTA to less than significant
with mitigation by ensuring that project activities would not affect nesting migratory birds.
Operation of the proposed project would include the use of new lighting and a new 148-foot-tall,
seven-story building with potentially reflective surfaces. The new lighting and new surfaces could
misdirect or confuse migratory birds, resulting in disruption of natural behavioral patterns and
possible injury or death from exhaustion or collisions with buildings, which would be a
significant impact. The potential for these types of impacts could be heightened because of the
project site’s proximity to San Bruno Mountain and San Francisco Bay. Implementation of
Mitigation Measures BI-3, Lighting Measures to Reduce Impacts on Birds, and BI-4b, Building
Design Measures to Minimize Bird Strike Risk would reduce impacts on the movement of native
resident or migratory wildlife species to less than significant with mitigation by ensuring that
project activities would not affect migratory birds.
Mitigation Measure BI-2: Lighting Measures to Reduce Impacts on Birds
During design, the project sponsor shall ensure that a qualified biologist experienced with bird
strikes and building/lighting design issues shall identify lighting-related measures to minimize
the effects of the building’s lighting on birds. The project sponsor shall incorporate such
measures, which may include the following and/or other measures, into the building’s design
and operation.
a. Use strobe or flashing lights in place of continuously burning lights for obstruction lighting.
Use flashing white lights rather than continuous light, red light, or rotating beams.
b. Install shields onto light sources not necessary for air traffic to direct light towards the
ground.
City of South San Francisco
Environmental Setting, Impacts, and Mitigation
Biological Resources
751 Gateway Boulevard Project 4.3-13 September 2020
ICF 0662.19
c. Extinguish all exterior lighting (i.e., rooftop floods, perimeter spots) not required for public
safety.
d. When interior or exterior lights must be left on at night, the operator of the buildings shall
examine and adopt alternatives to bright, all-night, floor-wide lighting, which may include
installing motion-sensitive lighting, using desk lamps and task lighting, reprogramming
timers, or using lower-intensity lighting.
e. Windows or window treatments that reduce transmission of light out of the building shall
be implemented to the extent feasible.
Mitigation Measure BI-3: Building Design Measures to Minimize Bird Strike Risk
During design, the project sponsor shall ensure that a qualified biologist experienced with bird
strikes and building/lighting design issues shall identify measures related to the external
appearance of the building to minimize the risk of bird strikes. The project sponsor shall
incorporate such measures, which may include the following and/or other measures, into the
building’s design.
a. Minimize the extent of glazing.
b. Use low-reflective glass and/or patterned or fritted glass.
c. Use window films, mullions, blinds, or other internal or external features to “break up”
reflective surfaces rather than having large, uninterrupted areas of surfaces that reflect, and
thus to a bird may not appear noticeably different from, vegetation or the sky.
Impact BIO-5: The proposed project would not conflict with any local policies or ordinances
protecting biological resources, such as a tree preservation policy or ordinance. (Less than
Significant)
Local policies and ordinaces for protecting biological resources include the Tree Preservation
Ordinance (Chapter 13.30) in the City of South San Francisco Municipal Code. A tree inventory and
assessment of the project site was performed by Arborwell in January 2020. A total of 227 trees were
documented on the project site, 35 of which are protected under this ordinance. The proposed project
would require the removal of 175 trees on the project site, including four protected trees. The project
sponsor would be required to abide by all conditions specified in the City Municipal Code which
requires that the project sponsor obtain permits to remove protected trees and to compensate for
their removal by planting replacement trees of certain sizes and species as specified in the City
Municipal Code and by the Parks and Recreation director. Therefore, the project would comply with
local policies and ordinances for protecting biological resources, such as a tree preservation policy or
ordinance, ensuring that project activities would not result in an unauthorized impact on a protected
tree. This impact would be less than significant.
Impact BIO-6: The proposed project would not conflict with the provisions of an adopted
habitat conservation plan, natural community conservation plan, or other approved local,
regional, or state habitat conservation plan. (No Impact)
The project site is not part of an existing habitat conservation plan or natural community conservation
plan or any other local, regional, or state habitat conservation plan. Therefore, the project would have
no impact on the provisions of an adopted habitat conservation plan, natural community conservation
plan, or other approved local, regional, or state habitat. No mitigation is required.
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Environmental Setting, Impacts, and Mitigation
Biological Resources
751 Gateway Boulevard Project 4.3-14 September 2020
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4.3.4.4 Cumulative Impacts
Impact C-BIO-1: The proposed project would not result in a cumulatively considerable
contribution to significant cumulative impacts on biological resources. (Less than Significant
with Mitigation)
The proposed project would not modify any natural habitat and would have no impact on sensitive
natural communities, including riparian habitat; protected wetlands; the movement of native resident
or migratory fish species; or an approved conservation plan. The cumulative geographic context for
biological resources is the immediate vicinity of the project site, which is the area where construction
activities, including tree removal, could affect biological resources including nesting special-status and
migratory bird species, and protected trees that may be present on or near the site. The cumulative
projects located within approximately 0.5 mile of the project site are described in Section 4.1.5,
Approach to Cumulative Impact Analysis, of this draft EIR and shown in Figure 4.1-1.
Similar to the project site, the majority of the sites for cumulative projects contain development with
ornamental landscaping and ruderal vegetation; therefore, habitat for candidate, sensitive, or special-
status species is marginal. Most of the future projects would involve primarily the construction of new
buildings or modifications to existing buildings or infrastructure, and associated tree removals.
Therefore, as with the proposed project, such development could have an impact on nesting special-
status and migratory bird species, the movement of native resident or migratory wildlife species,
established native resident or migratory wildlife corridors, the use of native wildlife nursery sites, and
local policies or ordinances for protecting biological resources. Cumulative impacts on these biological
resources could be significant because reasonably foreseeable projects would affect or remove
additional structures and trees and erect new structures. Structures and trees provide roosting and
nesting habitat for special-status and migratory birds and act as potential nursery sites; new
structures could affect the movement of species. However, these future projects would also be subject
to the requirements of the wildlife protection laws, including CESA, MBTA, and the California Fish and
Game Code, as well as wildlife protection policies and provisions in the City General Plan and the City
Municipal Code, Chapter 13.30. Nonetheless, cumulative impacts on these biological resources would
be significant because reasonably foreseeable projects could affect or remove a substantial number of
structures and trees and erect new structures.
The project would remove 175 trees on the project site and construct a new 148-foot-tall, seven-story
building. Implementation of Mitigation Measure BI-1, Preconstruction Nesting Bird Surveys and Buffer
Areas; Mitigation Measure BI-2, Lighting Measures to Reduce Impacts on Birds; and Mitigation
Measure BI-3, Building Design Measures to Minimize Bird Strike Risk, would require pre-construction
surveys for nesting birds, and building design measures to minimize lighting effects on birds and bird
strike risk. Implementation of these mitigation measures would ensure that the proposed project’s
contribution to cumulative impacts on nesting special-status and migratory bird species, the
movement of native resident or migratory wildlife species, established native resident or migratory
wildlife corridors, the use of native wildlife nursery sites, and local policies or ordinances for
protecting biological resources would be less than cumulatively considerable.