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HomeMy WebLinkAboutCEQA Findings and SOC for PublicationGenentech Campus Master Plan Update – CEQA Findings page 1 CERTIFICATION OF THE EIR, CEQA FINDINGS, AND STATEMENT OF OVERRIDING CONSIDERATIONS FOR APPROVAL OF THE GENENTECH CAMPUS MASTER PLAN UPDATE PROJECT I. INTRODUCTION 1. These findings are made pursuant to the California Environmental Quality Act (CEQA) (Pub. Res. Code section 21000 et seq.) and the CEQA Guidelines (Cal. Code Regs. Title 14, section 15000 et seq.) by the City of South San Francisco, in connection with the Environmental Impact Report (EIR) prepared for the Genentech Campus Master Plan Update Project (“Project”), SCH #2017052064. 2. These CEQA Findings are attached and incorporated by reference into each and every staff report, resolution, and ordinance associated with approval of the Project, including the City’s Conditions of Approval and the Mitigation Monitoring and Reporting Program (“MMRP”) attached as Exhibit A. The City will use the MMRP to track compliance with Project mitigation measures. The MMRP will remain available for public review during the compliance period. All Exhibits are incorporated by reference into each other and into the ordinance or resolution to which the exhibit is attached. 3. These Findings are based on substantial evidence in the entire administrative record and references to specific reports and specific pages of documents are not intended to identify those sources as the exclusive basis for the Findings. These findings constitute the City’s best effort to set forth the evidentiary and policy bases for its decision to approve the Project in a manner consistent with the requirements of CEQA. To the extent that these findings conclude that various mitigation measures outlined in the EIR are feasible and have not been modified, superseded or withdrawn, the City hereby binds itself to implement such measures. These findings, in other words, are not merely informational, but rather constitute a binding set of obligations that will come into effect when the City approves the Project. II. PROJECT DESCRIPTION 4. The Genentech Campus (or “Project Area”) is approximately 207 acres in size, located in the City of South San Francisco and along the shoreline of central San Francisco Bay. It is approximately 1.5 miles north of San Francisco International Airport (SFO) and 10 miles south of downtown San Francisco. The Genentech Campus is located on a prominent hillside and hilltop location at the easterly point of the East of 101 Area of South San Francisco (East of 101), and immediately adjacent to the San Francisco Bay. It is bounded by San Francisco Bay to the northeast, east and south, and is connected to US 101 to the west by East Grand Avenue and Oyster Point /Forbes Boulevard. The Campus is located in an area known as South San Francisco’s East of 101 Area, which contains over 200 biotechnology companies and 11.5-million square feet of biotechnology space. The Genentech Campus is the largest of these biotechnology campuses. The Genentech Campus currently comprises approximately 4.7 million square feet of building space within its 207 acres, at a Campus-wide floor-area-ratio (FAR) of approximately 0.52. Genentech Campus Master Plan Update III. The Genentech Campus Master Plan Update (Project) establishes a conceptual land use and development framework to accommodate an eventual buildout of up to 9 million Genentech Campus Master Plan Update – CEQA Findings page 2 square feet of building space at the Genentech Campus (an increase of approximately 4.3 million net square feet over existing conditions), which would be consistent with the existing allowable floor-to-area ratio (FAR) of 1.0. A full and complete detailed description of the Project is set forth in EIR Chapter 3, Project Description. ENVIRONMENTAL REVIEW OF THE PROJECT 5. In 2007, the City of South San Francisco prepared a Master EIR for the 2007 Genentech Corporate Facilities Research & Development Overlay District Expansion and Master Plan. That 2007 Master EIR considered the environmental impacts that may result from development of approximately 3.2 million square feet of net new building space, to a buildout of 6 million square feet. That 2007 Master EIR (State Clearinghouse No. 2005072165) was certified by the City of South San Francisco on March 14, 2007. After certification of the 2007 Master EIR, the City Council subsequently adopted the 2007 Genentech Master Plan and amended the City’s Zoning Ordinance to allow expansion of the Genentech Research and Development Overlay (R&D) zoning district. 6. In 2012, the City updated the 2007 Master EIR in a 2012 Supplemental Master EIR (2012 SMEIR) for the Genentech Corporate Facilities Research & Development Overlay District Expansion and Master Plan Project (also SCH No. 2005072165). The 2012 SMEIR reviewed the adequacy of the 2007 Master EIR pursuant to the five-year limitations set forth in CEQA Guidelines Section 15179, and included additional environmental review to supplement the 2007 Master EIR. The 2012 SMEIR focused largely on regulatory changes that had occurred since certification of the 2007 MEIR in the areas of air quality, greenhouse gas emissions and land use/planning, and new information and changed circumstances since certification of the 2007 MEIR in the area of traffic/transportation development. 7. In 2013, Genentech requested that the City add properties known as the South Campus to the Genentech Master Plan zoning district. The City had previously certified the Britannia East Grand Project EIR in 2002 (SCH No. 2001052085), and after certification of that 2002 EIR and completion of entitlements, construction of the Britannia East Grand project was conducted to suit Genentech’s needs and became fully leased to Genentech as its South Campus. The South Campus was added to the Genentech Master Plan zoning district in 2013 with the prior CEQA review completed under the 2002 EIR. 8. Pursuant to CEQA and the CEQA Guidelines, the City determined that a new EIR would be prepared for the Project. On May 23, 2017, the City published a Notice of Preparation (NOP) to prepare an EIR for the Project, which was circulated to responsible agencies and interested groups, individuals, and to the State Clearinghouse for review and comment. The public comment period on the scope of the EIR lasted through June 23, 2017. A scoping session was held on June 8, 2017 at the Annex City Hall Conference Room at 315 Maple Avenue, South San Francisco. Notice of this scoping meeting was provided to San Mateo County, the City and County of San Francisco, and to the cities of Colma, Brisbane, Pacifica, Daly City and San Bruno. It was also provided to Responsible Agencies (any public agency that has jurisdiction by law with respect to the project) and to any agency or individual who has filed a written request for notice of such types of EIRs. A copy of the NOP and the comments thereon are included in Appendix A of the Draft EIR. 9. The City prepared a Draft EIR to analyze the Project’s potential to have a significant impact on the environment. Both written and oral comments received by the City on the NOP and scoping session were considered during preparation of the Draft EIR. The City released the Draft EIR for the Project on November 8, 2019. The 45-day public review and comment period on that Draft EIR ended on December 23, 2019. During the public review and comment period, the City of South San Francisco Genentech Campus Master Plan Update – CEQA Findings page 3 held a public hearing before the City Planning Commission on December 19, 2019. The purpose of this hearing was to inform the public about the contents of the Draft EIR and to receive oral comments on the Draft EIR about its adequacy and accuracy. 10. The City received written and oral comments on the Draft EIR. The City prepared responses to comments and, where necessary, made minor clarifications to the Draft EIR. The responses to comments, changes to the Draft EIR, and additional information were published in a Response to Comments/Final SEIR (“Final EIR) on October 15, 2020. The Draft EIR, Final EIR, and all appendices thereto constitute the “EIR” referenced in these Findings. The Final EIR was made available and noticed on October 4, 2020, more than 10 days before the duly noticed October 15, 2020 Planning Commission public hearing. The Notice of Availability and Release of the Final EIR was distributed to those state and local agencies who commented on the NOP and Draft EIR, posted at the Project site, mailed to property owners within 300 feet of the Project site, and mailed/emailed to individuals who have requested to specifically be notified of official City actions on the Project. Copies of the Draft EIR and Final EIR were also made available or distributed to those state and local agencies who commented on the Draft EIR, City officials including the Planning Commission and City Council, and made available for public review at the City offices and City’s website. Pursuant to CEQA Guidelines, responses to public agency comments on the Draft EIR have been published and made available to all commenting agencies at least 10 days prior to the public hearing to consider certification of the EIR. The City Council has had the opportunity to review all comments and responses thereto prior to consideration and certification of the EIR and prior to taking any action on the Project. IV. THE ADMINISTRATIVE RECORD 11. The record of proceedings upon which all Findings and City determinations related to the approval of the Project consists of the following documents, at a minimum, which are incorporated herein by this reference: a. The NOP and all other public notices issued by the City in conjunction with the Project; b. The EIR and all documents referenced in or relied upon by the EIR; c. All comments, documents, and correspondence submitted to the City during the public comment period on the EIR, in addition to all other timely comments on the EIR; d. All reports, studies, memoranda, maps, staff reports, or other documents relating to the Project prepared by the City, consultants to the City, or responsible or trustee agencies with respect to the City’s compliance with CEQA and with respect to City’s action on the Project; e. All information (including written evidence and testimony) provided by City staff to the South San Francisco Planning Commission and/or City Council relating to the EIR, the approvals and the Project; f. All information (including written evidence and testimony) presented to the Planning Commission and/or City Council by the environmental consultant and sub-consultants who prepared the EIR, or incorporated into reports presented to the City Council; g. All information (including written evidence and testimony) presented to the City from other public agencies relating to the Project and the EIR; h. All final applications, letters, testimony and presentations presented by the Project sponsor and its consultants to the City in connection with the Project; Genentech Campus Master Plan Update – CEQA Findings page 4 i. All final information (including written evidence and testimony) presented at any City public hearing or City workshop related to the Project and the EIR; j. For documentary and information purposes, all City-adopted land use plans and ordinances, including without limitation the General Plan, Est of 101 Area Plan, and ordinances, together with environmental review documents, findings, mitigation monitoring programs and other documentation relevant to planned growth in the area; k. All findings and resolutions and ordinances adopted by the City in connection with the Project, and all documents cited or referenced therein; l. Matters of common knowledge to the City, including but not limited to Federal, State, and local laws and regulations; m. The Conditions of Approval for the Project and the Mitigation Monitoring and Reporting Program (MMRP) for the Project; and n. All other documents composing the record pursuant to Public Resources Code section 21167.6(e). 12. The City has relied on all of the documents and materials listed above in reaching its decisions on the proposed Project even if not every document was formally presented to the City Council or City staff as part of the City files generated in connection with the Project. Without exception, any documents or materials set forth above not found in the Project files fall into one of two categories. Many of them reflect prior planning or legislative decisions of the City Council is aware in approving the Project (See City of Santa Cruz v. Local Agency Formation Commission (1978) 76 Cal.App.3d 381, 391-392; Dominey v. Department of Personnel Administration (1988) 205 Cal.App.3rd 729, 738, n. 6.) Other documents influenced the expert advice provided to City staff or consultants, who then provided advice to the Planning Commission and the City Council as final decision makers. For that reason, such documents form part of the underlying factual basis for the City’s decisions relating to approval of the Project (See Pub. Res. Code §21167.6(e)(2); Browning-Ferris Industries v. City Council of the City of San Jose (1986) 181 Cal.App.3d 852, 866; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 153, 155). 13. The custodian of the documents and other materials that constitute the record of the proceedings upon which the City’s decisions are based is the City of South San Francisco Director of Economic & Community Development, or his/her designee. Such documents and other materials are located at 315 Maple Avenue, South San Francisco, CA 94080. V. CERTIFICATION OF THE EIR 14. The City Council, after receiving a recommendation from the Planning Commission, certifies that the EIR has been completed in compliance with CEQA. The City Council has independently reviewed the record and the EIR prior to certifying the EIR and approving the Project. By these Findings, the City Council confirms, ratifies, and adopts the Findings and conclusions of the EIR as supplemented and modified by these Findings. The EIR and these Findings represent the independent judgment and analysis of the City of South San Francisco and its City Council. 15. The City Council recognizes that the EIR may contain clerical errors. The City Council reviewed the entirety of the EIR and bases its determination on the substance of the information it contains. 16. The City Council certifies that the EIR is adequate to support all actions in connection with the approval of the Project (the proposed Genentech Campus Master Plan Update), approval of Genentech Campus Master Plan Update – CEQA Findings page 5 commensurate zoning text amendments to the Genentech Master Plan zoning district (Chapter 20.260 of the City of South San Francisco Zoning Code), and approval of a Development Agreement, and taking all other actions and recommendations as described in the Staff Report to which these CEQA Findings are attached. The City Council certifies that the EIR is adequate to support approval of the Project described in the EIR, each component and phase of the Project described in the EIR, any variant of the Project described in the EIR, any minor modifications to the Project or variants described in the EIR, and the components of the Project. 17. The City of South San Francisco may rely on the EIR to provide environmental review for subsequent projects or their sites that are analyzed as part of the EIR. When individual projects contemplated under the Master Plan Update are proposed, the City will consider whether those projects’ environmental effects were fully disclosed, analyzed, and as needed, mitigated within the EIR. That consideration will also assess whether the subsequent project is exempt from CEQA and, if not, whether CEQA requires preparation of a subsequent or supplemental environmental review document. VI. ABSENCE OF SIGNIFICANT NEW INFORMATION 18. The City Council finds that the changes and modifications made to the EIR after the Draft EIR was circulated for public review and comment do not individually or collectively constitute significant new information within the meaning of Public Resources Code section 21092.1 or CEQA Guidelines section 15088.5. 19. The City Council recognizes that the Final EIR incorporates information obtained and produced after the Draft EIR was completed, and that the Final EIR contains additions, clarifications and modifications to the Draft EIR. The City Council has reviewed and considered the Final EIR and all of this information. The new information added to the EIR does not involve a new significant environmental impact, a substantial increase in the severity of an environmental impact, or a feasible mitigation measure or alternative considerably different from others previously analyzed that the project sponsor declines to adopt and that would clearly lessen the significant environmental impacts of the Project. No information indicates that the Draft EIR was inadequate or conclusory or that the public was deprived of a meaningful opportunity to review and comment on the Draft EIR or the Project. Thus, recirculation of the Draft EIR is not required. VII. CONDITIONS OF APPROVAL AND MITIGATION MONITORING AND REPORTING PROGRAM 20. Public Resources Code section 21081.6 and CEQA Guidelines section 15097 require the City to adopt a monitoring or reporting program to ensure implementation of the mitigation measures and revisions to the Project identified in the EIR. The Mitigation Monitoring and Reporting Program (“MMRP”) is attached and incorporated by reference into the Staff Report prepared for the approval of the Project, is included in the conditions of approval for the Project, and is adopted by the City Council. The MMRP satisfies the requirements of CEQA. 21. Mitigation measures set forth in the MMRP are specific and enforceable and are capable of being fully implemented by the City of South San Francisco, the applicant, and/or other identified public agencies of responsibility. As appropriate, some mitigation measures define performance standards to ensure no significant environmental impacts will result. The MMRP adequately describes implementation procedures, monitoring responsibility, reporting actions, compliance schedule, and verification of compliance in order to ensure that the Project complies with the adopted mitigation measures. Genentech Campus Master Plan Update – CEQA Findings page 6 22. The City Council will adopt and impose the feasible mitigation measures as set forth in the MMRP as enforceable conditions of approval to substantially lessen or eliminate the Project’s significant environmental effects, where feasible. The mitigation measures incorporated into and imposed upon the Project approval will not have new significant environmental impacts that were not analyzed in the EIR. 23. In the event a mitigation measure recommended in the EIR has been inadvertently omitted from the conditions of approval or the MMRP, that mitigation measure is adopted and incorporated from the EIR into the MMRP by reference, and adopted as a condition of approval. VIII. FINDINGS REGARDING IMPACTS 24. Senate Bill 743 (Steinberg, 2013) added section 20199 to the Public Resources Code (CEQA Section 20199), which directed the Governor’s Office of Planning and Research (“OPR”) to amend the CEQA Guidelines to provide an alternative to levels-of-service (LOS) based thresholds for evaluating transportation impacts. Subdivision (b)(2) of Section 20199 provides that, upon certification of the amended CEQA Guidelines, “automobile delay, as described solely by level of service or similar measures of vehicular capacity, shall not be considered a significant impact on the environment,” except as provided in the amended CEQA Guidelines. In accordance with Senate Bill 743, the CEQA Guidelines were amended and certified in December 2018 to add new CEQA Guidelines section 15064.3. Consistent with CEQA Section 20199, CEQA Guidelines section 15064.3 provides that “a project’s effect on automobile delay shall not constitute a significant effect on the environment[,]” except for roadway capacity projects. CEQA Guidelines section 15064.3 further provides that it shall apply prospectively, becoming applicable statewide on July 1, 2020, and requires lead agencies to analyze (and mitigate) transportation impacts on the basis of thresholds of significance that assess project-related vehicle miles traveled (“VMT”), rather than project-related LOS. Lead agencies are not required, however, to analyze transportation impacts under the VMT threshold methodology until July 1, 2020. Given that CEQA is currently in a period of transition away from transportation impact analyses based on LOS metrics and toward a VMT-based analytical framework, and to advance the EIR’s informational value, the EIR conservatively analyzed transportation impacts from the Project using both LOS-based and VMT-based thresholds of significance and thereby goes beyond the requirements of CEQA. With full knowledge and understanding of the transitional status of CEQA’s transportation impact analysis framework, as implemented through the CEQA Guidelines by OPR in accordance with Senate Bill 743, the City Council hereby makes Findings regarding the Project’s transportation-related impacts on basis of both LOS-based and VMT-based thresholds of significance 25. In accordance with Public Resources Code section 21081 and CEQA Guidelines sections 15091 and 15092, the City Council adopts the Findings and conclusions regarding impacts and mitigation measures that are set forth in the EIR and summarized in the MMRP. These findings do not repeat the full discussions of environmental impacts, mitigation measures and related explanations contained in the EIR. The City Council ratifies, adopts and incorporates, as though fully set forth, the analysis, explanation, findings, responses to comments and conclusions of the EIR. The City Council adopts the reasoning of the EIR, staff reports, and presentations provided by the staff and the Project sponsor as may be modified by these Findings. 26. The City Council recognizes that the environmental analysis of the Project raises environmental issues for which a range of technical and scientific opinion may exists. The City Council acknowledges that there may be differing and potentially conflicting expert and other opinions regarding the Project. The City Council has, through its review of the evidence and analysis Genentech Campus Master Plan Update – CEQA Findings page 7 presented in the record, acquired a better understanding of the breadth of this technical and scientific opinion and of the full scope of the environmental issues presented. In turn, this understanding has enabled the City Council to make fully informed, thoroughly considered decisions after taking account of the various viewpoints on these important issues and reviewing the record. These Findings are based on a full appraisal of all viewpoints expressed in the EIR and in the record, as well as other relevant information in the record of the proceedings for the Project. 27. Based upon the evidence before it, the City finds that the Project will result in one or more “significant and unavoidable” environmental impacts. Therefore, a statement of overriding considerations is required. In other words, the City must consider whether overriding economic, social, or other considerations outweigh the significant, unavoidable effects of the Project. The required statement of overriding considerations is included herein. IX. FINDINGS FOR IMPACTS FOUND TO HAVE NO IMPACT OR FOUND NOT SIGNIFICANT 28. The environmental analyses conducted and discussed in the EIR determined that the Project would have “no impact” or a less than significant impact in a number of impact areas, even without mitigation. CEQA does not require lead agencies to make findings for impacts that an EIR concludes are less than significant (Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 716-17). Although no such findings are required, in the interest of full disclosure and in the preparation of a robust administrative record, the City Council hereby makes the following findings regarding those environmental effects of the Project that would have either no impact or a less than significant impact not requiring mitigation. A. AESTHETICS 29. Impact Aesthetics 1, Scenic Vistas: New development pursuant to the Project would not result in a substantial adverse effect on a scenic vista. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Aesthetics 1): East of 101 Area Plan Policy GEO-9 identifies the Point San Bruno hill as a visually prominent landmark that should be preserved, but does not require that any individual views of the Point San Bruno Hill be protected. The Project does not propose grading that would alter the visual prominence of Point San Bruno Hill. As concluded in the EIR, the Project would not exceed CEQA thresholds for defining impacts to scenic views. 30. Impact Aesthetics 2, Scenic Resources as seen from a State Scenic Highway: New development pursuant to the Project would not result in a substantial adverse effect on scenic resources, including but not limited to trees, rock outcroppings or historic buildings, within a state scenic highway. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Aesthetics 2): The nearest designated State Scenic Highway is I-280, which is more than five miles to the west of the Project Area and views of the Project are not visible from this Scenic Highway. Views of the Project are not visible or distinguishable from other sections of the State Scenic Highway Genentech Campus Master Plan Update – CEQA Findings page 8 program, and thus the Project would have no impact on scenic resources within a scenic highway. 31. Impact Aesthetics 3, Visual Character: New development pursuant to the Project would not substantially degrade the visual character or quality of the Project Area. The Project envisions new growth and development within the Campus as being Campus-centered with substantially increased density, new buildings constructed at a larger scale, taller and larger than many of the existing buildings on Campus today, resulting in a cohesive and integrated Campus design. Regulatory Requirements: Regulatory Requirement Aesthetics 3 – Design Review: Pursuant to the City of South San Francisco’s Zoning Code (Chapter 20.480: Design Review) the City will continue to review the design of new buildings on Campus. The City’s Design review criteria will be used to ensure that new buildings promote high-quality design, are well crafted and maintained, use high-quality building materials and are attentive to the design and execution of building details and amenities. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Aesthetics 3): Pursuant to the regulatory requirements of the City’s Design Review process, subsequent development pursuant to the Project will be reviewed to ensure that each subsequent development project does not substantially degrade the existing visual character or quality of the Project Area. Compliance with this regulatory requirement would ensure that impacts to existing visual character would be reduced to less than significant. 32. Cumulative Aesthetics Effects: The Project, in combination with other past, present and reasonably foreseeable future development in the East of 101 Area, will not contribute to a cumulatively substantial adverse aesthetic effect. Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Cumulative Aesthetics Impacts): The land use and appearance of the East of 101 Area has been in transition for the last 40 years, from heavy industry and manufacturing facilities, to warehousing, and more recently to research and development (R&D) and biotechnology establishments. Although this cumulative development will substantially change the visual character of the East of 101 Area over time, this growth in the biotechnology industry has been planned for and fully anticipated pursuant to the City’s General Plan, East of 101 Area Plan and economic development strategies. This cumulative change in the visual character of the East of 101 Area is not a previously unrealized adverse effect, but rather a planned and anticipated economic development benefit to the City. B. AGRICULTURE AND FOREST RESOURCES 33. Impact Agriculture 1, Farmlands, Agricultural Zoning and Williamson Act Contracts: The Project would not convert designated farmland under the Farmland Mapping and Monitoring Program, nor would it conflict with any existing agricultural zoning or a Williamson Act contract, nor would it involve any changes to the environment that would result in the conversion of designated farmland. Mitigation Measures: None required. Genentech Campus Master Plan Update – CEQA Findings page 9 Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Impact Agriculture 1): According to the California Department of Conservation, Division of Land Resource Protection maps, the Project site is not identified as any type of farmland, but is instead identified as “Urban and Built-up.” Zoning of the Project Site is the Genentech Master Plan zoning designation, which is not intended for agricultural use. There are no Williamson Act contracts applicable to any properties within the Project Site, and there are no identified urban agricultural sites on the Project Site or vicinity. 34. Impact Agriculture 2, Forest Lands: The Project would not conflict with existing zoning for, or cause rezoning of, forestland or timberland, nor would it result in the loss of or conversion of forestland to non-forest uses. Mitigation Measures: None required. Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Impact Agriculture 2): There is no timberland or Timberland Production zoning applicable to the Project Site. None of the trees on or adjacent to the Project Site are managed for a public benefit, and even though one of the identified habitat types within the Project Area is “Ornamental Woodland”, this habitat type is not considered forestland for purposes of CEQA. The Project would not result in the loss of forestland or the conversion of forestland to non-forest use. There would be no impact with respect to forestland or timberland. 35. Cumulative Agricultural Effects: The Project would not result in a cumulatively considerable contribution to a significant cumulative impact on agricultural resources or forestland or timberland. Mitigation Measures: None required. Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Cumulative Agriculture Impacts): No other proposed, reasonably foreseeable or probable cumulative projects in the East of 101 Area are mapped as either Prime Farmland, Unique Farmland or Farmland of Statewide or Local Importance, and there are no parcels under Williamson Act contract. There is no timberland or Timberland Production zoning applicable in the East of 101 Area. C. AIR QUALITY 36. Impact Air Quality 1, Consistency with Clean Air Plan: Implementation of the Project would not conflict with or obstruct implementation of the applicable air quality plan. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Air Quality 1): Genentech is now implementing numerous initiatives that serve to decrease emissions of the air pollutants that are most harmful to Bay Area residents such as particulate matter, ozone, and toxic air contaminants; to reduce emissions of “super-GHGs” that are potent climate pollutants in the near-term; and to decrease emissions of carbon dioxide by reducing fossil fuel combustion. Genentech anticipates re-evaluation and re-assessment of its current sustainability goals for 2020, and development of successive multi-year goals and implementation strategies Genentech Campus Master Plan Update – CEQA Findings page 10 based on prior successes and challenges. The Project supports the primary goals of the 2017 Bay Area Clean Air Plan, includes applicable control measures from the 2017 CAP for air pollution, and does not disrupt or hinder implementation of any control measures of the 2017 CAP. 37. Impact Air Quality 6, Cumulative Health Risk: The Project would not contribute at a significant level to a cumulatively considerable health risk impact. Specifically, the TAC emissions generated by the Project, when added to TAC emissions from all local sources within 1,000-foot zone of influence, would not result in an excess cancer risk level of more than 100 in 1 million, a hazard index greater than 10, or a concentration greater than 0.8 μg/m3 annual average PM2.5. Mitigation Measures: None needed, beyond those identified for the Project’s individual TAC emissions under both operations and construction scenarios (see Findings for Impact Air Quality 3 and Impact Air Quality 5). Finding of Less Than Significant Impact Without Mitigation Measures (Impact Air Quality 6): The Project’s contribution to cancer risks and PM2.5 concentrations at all measured sensitive receptors, when added to other cumulative sources, do not result in exceeding a cumulatively threshold that is not already exceeded, and therefore are considered less than cumulatively significant. D. BIOLOGICAL RESOURCES 38. Impact Biology 1, Tidal Aquatic Species and Essential Fish Habitats: The Project could potentially have an indirect adverse effect on Central California Coast steelhead, green sturgeon, longfin smelt and their tidal aquatic habitat within the Bay. Project construction activities could lead to erosion of sediment into the Bay. Increases in turbidity and sediment input may stress fish because of feeding difficulties or displacement. Minor spills of petrochemicals, hydraulic fluids and solvents may occur during vehicle and equipment refueling or because of leaks, adversely affecting water quality and potentially killing or injuring fish. Regulatory Requirements: Regulatory Requirement Hydro 1A - Construction General Permit/Stormwater Pollution Prevention Plan: All new qualifying construction projects pursuant to the Master Plan Update will be required to comply with Provision C.6 of the Municipal Regional Permit (MRP), and a Notice of Intent for permit coverage under the Construction General Permit must be filed (see further details under Impact Hydrology 1). Regulatory Requirement Hydro 1B - Provision C.3 Requirements/Stormwater Management Plan: All new Regulated Projects pursuant to the Master Plan Update will be required to comply with Provision C.3 of the MRP, including requirements to incorporate post-construction stormwater control and low-impact development (LID) measures. Each individual development project must meet Provision C.3 requirements capable of reducing long-term impacts of development on stormwater quality. Some combination of post-construction stormwater controls will be required to demonstrate compliance with the hydraulic design criteria of the MRP (see further details under Impact Hydrology 1). Mitigation Measures: None required. Genentech Campus Master Plan Update – CEQA Findings page 11 Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 1): Compliance with regulatory requirements for water quality will reduce the potential for indirect impacts to Central California Coast steelhead, green sturgeon, longfin smelt and their tidal aquatic habitat within the Bay to a level of less than significant. BMPs will be incorporated into individual SWPPPs prior to approval of grading permits, providing an acceptable level of water quality protection. Implementation of the General Construction General Permit requirements will reduce potential impacts to water quality during construction activities to a less than significant level. Compliance with Provision C.3 requirements, including implementation of a Stormwater Management Plan for each subsequent regulated development project, will ensure that potential water quality impacts related to post-construction activity pursuant to the Project will be reduced to a less than significant level. 39. Impact Biology 3, Burrowing Owl: The Project would not cause a substantial adverse effect, either directly or through habitat modification, on burrowing owls. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 3): This species is not expected to breed, occur regularly or occur in numbers in the Project Area, and the San Mateo County Breeding Bird Atlas indicates no evidence of breeding in the Project vicinity. New development undertaken pursuant to the Project would not result in the disturbance of breeding individuals or the loss of breeding habitat for this species, and Project impacts are not expected to affect appreciably the regional population of this species. This impact is considered less than significant. 40. Impact Biology 5, Harbor Seal and California Sea Lion: The Project could potentially have an indirect adverse effect on harbor seal and California sea lion (both protected species under the Marine Mammal Protection Act), and their tidal aquatic habitat within the Bay. The tidal aquatic habitat adjacent to the Study Area provides suitable foraging and dispersal habitat for these species. The Project has the potential to result in indirect impacts to these species and this habitat type due to adverse effects on water quality. Regulatory Requirements: Regulatory Requirement Hydro 1A - Construction General Permit/Stormwater Pollution Prevention Plan: All qualifying new construction projects pursuant to the Master Plan Update must comply with Provision C.6 of the Municipal Regional Permit (MRP). A Notice of Intent for permit coverage under the Construction General Permit must be filed, and a Stormwater Pollution Prevention Plan must be implemented (see additional details, above). Regulatory Requirement Hydro 1B - Provision C.3 Requirements/Stormwater Management Plan: All new Regulated Projects pursuant to the Master Plan Update will be required to comply with Provision C.3 of the MRP, including requirements to incorporate post-construction stormwater control and low-impact development (LID) measures. Each individual development project must meet Provision C.3 requirements capable of reducing long-term impacts of development on stormwater quality. Some combination of post-construction stormwater controls will be required to demonstrate compliance with the hydraulic design criteria of the MRP (see additional details, above). Mitigation Measures: Genentech Campus Master Plan Update – CEQA Findings page 12 None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 5): Implementation of regulatory requirements will minimize the risk for adverse impacts on water quality through implementation of best management practices and post-construction stormwater controls, that will reduce potential indirect impacts on harbor seal and sea lion to less than significant levels. 41. Impact Biology 6, Bird Strikes: The Project would not interfere substantially with migratory bird corridors due to bird strikes with buildings. Therefore, this impact is determined to be less than significant. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 6): Due to the large number of existing multi-story buildings present throughout the Project Area, and the spatial orientation of high-quality bird habitat in relation to the site, Project impacts resulting from bird collisions are not expected to rise to the CEQA standard of having a substantial adverse effect on migratory bird corridors. This would not constitute a significant impact under the CEQA. 42. Impact Biology 8, Sensitive Natural Communities: The Project will not have a substantial adverse direct 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. New development undertaken pursuant to the Project would not result in activities occurring within riparian habitat, and no direct impacts to riparian habitat would occur. Project construction activities in close proximity could result in ground disturbance, vegetation removal and mobilization of sediment that in combination could lead to erosion of sediment into the riparian habitat. Spills may occur during vehicle and equipment refueling or because of leaks that may also adversely affect riparian habitat. Regulatory Requirements: Regulatory Requirement Hydro 1A - Construction General Permit/Stormwater Pollution Prevention Plan: Qualifying new construction projects pursuant to the Master Plan Update will be required to comply with Provision C.6 of the Municipal Regional Permit (MRP). This includes filing a Notice of Intent for permit coverage under the Construction General Permit and implementation of a Stormwater Pollution Prevention Plan. Regulatory Requirement Hydro 1B - Provision C.3 Requirements/Stormwater Management Plan: All new Regulated Projects pursuant to the Master Plan Update will be required to comply with Provision C.3 of the MRP, including requirements to incorporate post-construction stormwater control and low-impact development (LID) measures. Each individual development project must meet Provision C.3 requirements capable of reducing long-term impacts of development on stormwater quality. Some combination of post-construction stormwater controls will be required to demonstrate compliance with the hydraulic design criteria of the MRP. Mitigation Measures: None required. Genentech Campus Master Plan Update – CEQA Findings page 13 Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 8): The Project would not result in the temporary or permanent loss of riparian habitat. Compliance with State regulatory requirements to control the discharge of stormwater pollutants during construction under the NPDES Construction General Permit and the RWQCB required SWPPP, and post-construction measures and design features required by the MRP, would avoid and minimize the risk for adverse impacts on water quality and potential impacts on riparian habitat to a less than significant level. 43. Impact Biology 10, Environmental Corridors: The Project will 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. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 10): All Project development activities are located in areas that are currently developed or that are surrounded by existing development or construction activities, and the Project Area consists of heavily disturbed habitats that are of little value to migrating wildlife. To the east of the biological Study Area, the Bay provides an important movement pathway for aquatic species, connecting breeding and foraging habitats, but the Project would not result in any loss of aquatic or marsh habitat. Aquatic species would continue to be able to move north to south through the Bay, independent of the Project. This impact is determined to be less than significant. 44. Impact Biology 11, Conflicts with Local Tree Protection Policies: The Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Landscaped portions of the Project Area may contain trees defined as “protected” by the South San Francisco Tree Preservation Ordinance, Title 13 Chapter 13.30. Development activities could involve removal or pruning of certain protected trees. The removal or pruning of trees protected by the City of South San Francisco Tree Preservation ordinance without required permits is considered potentially significant under CEQA. Regulatory Requirements: Regulatory Requirement Bio 11A – Tree Removal Permit: All new development pursuant to the Project will be required to comply with City of South San Francisco Municipal Code 13.30, which prohibits the removal or pruning of protected trees without a permit. Pursuant to this regulatory requirement, Genentech will be required to retain a certified arborist to conduct pre- construction surveys of trees within the Project Area, and provide a map to the applicant and the City. Each identified protected tree that will be directly impacted by removal or pruning will require a Tree Pruning/Removal Permit pursuant to the South San Francisco Municipal Code. This permit will be submitted to the City and must be approved before building permits are issued. Regulatory Requirement Bio 11B- Tree Replacement Planting: Replacement trees will be determined as set forth in Municipal Code Section 13.30.080, which provides that any protected trees that are removed shall be replaced as follows: 1) Replacement will be three 15-gallon size or two 24-inch box minimum size landscape trees for each tree removed as determined below. However, the director maintains the right to dictate size and species of trees in new developments. Genentech Campus Master Plan Update – CEQA Findings page 14 2) Any protected tree removed without a valid permit will be replaced by three 24-inch box minimum size landscape trees of a species approved by the director for each tree so removed as determined below. 3) Replacement of a protected tree can be waived by the director if a sufficient number of trees exist on the property to meet all other requirements of the tree preservation ordinance. 4) If replacement trees cannot be planted on the property, payment of the replacement value of the tree, as determined by the International Society of Arboriculture Standards, plus the costs to the city to plant an equivalent tree elsewhere in the city, will be made to the city. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 11): Implementation of the Project has the potential to result in the removal or pruning of trees protected by the City of South San Francisco Tree Preservation ordinance, but required compliance with the Municipal Code will reduce this impact to a less than significant level by prohibiting the unpermitted removal of protected trees and adequate replacement of any protected trees removed in accordance with a duly issued permit. 45. Impact Biology 12: Conflict with Habitat Conservation Plan: The Project will not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan or other habitat conservation plan approved by local, regional or state agencies. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Biology 12): The San Bruno Mountain Habitat Conservation Plan is the only Habitat Conservation Plan that has been approved in San Mateo County, but it does not cover the Project Area or the immediately surrounding vicinity. No other Natural Community Conservation Plans have been approved or are in preparation in San Mateo County. Potential impacts associated with conflicts between the Project and any adopted Habitat Conservation Plans or Natural Community Conservation Plans would be less than significant E. CULTURAL AND HISTORIC RESOURCES 46. Impact Cultural 1: Historic Resources: Future development pursuant to the Project is not anticipated to cause a substantial adverse change in the significance of any known historical resources. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Cultural 1): There are no identified historic structures located within the Project Area. No federal, State or local historic resource registers or lists identify any historic properties in the Project Area, there are no historic structures used to support Genentech operations, and the only historic structures of record within the Project Area were removed prior to 2002. No industrial buildings or sites within the East of 101 area are currently designated as historic resources. The Project would not Genentech Campus Master Plan Update – CEQA Findings page 15 require demolition or a substantial adverse change to any structure that qualifies as an historic resource, and this impact would be less than significant. 47. Impact Cultural 2, Paleontological Resources: Future development pursuant to the Project is not anticipated to uncover or disturb a known paleontological resource. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Cultural 2): The Project Area contains no record of any previously found invertebrate or vertebrate fossils. The potential to damage paleontological resources is unlikely, and considered less than significant. F. GEOLOGY AND SOILS 48. Impact Geology 1, Seismic Hazards: The Project Area is not within an Alquist-Priolo Seismic Hazard Zone, and no known active or potentially active faults traverse the Genentech Campus. New development pursuant to the Project is not subject to substantial risk of surface fault rupture. However, the Project Area is in one of the most seismically active regions in the U.S. and could be subject to violent shaking. Strong seismic ground shaking has the potential to induce seismic-related ground failure (e.g., liquefaction) and lateral spreading. Regulatory Requirements: Regulatory Requirements, General: All new development pursuant to the Project will be required to comply with all applicable regulatory requirements for seismic hazards, including but not limited to the California Seismic Hazards Mapping Act, California Building Code, City of South San Francisco Municipal Code - Chapter 15.08, and East of 101 Area Plan, Chapter 10, which sets forth policies and specific guidelines pertaining to site development and building design applicable to the unique geological hazards in the East of 101 Area, including the Project Area. Regulatory Requirement Geology 1 – Seismic Hazards: Pursuant to regulatory requirements, Genentech will be required to retain a certified licensed geotechnical engineer to prepare site- specific geotechnical studies for each new development project pursuant to the Project. 1. Required geotechnical studies shall include site-specific geotechnical recommendations demonstrating compliance with all applicable seismic-related geotechnical engineering standards. 2. Recommendations shall be incorporated into individual development project designs and construction, providing an acceptable level of protection against seismic-related hazards. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Geology 1): Compliance with the state and City building codes and policies would ensure potential impacts related to seismic hazards would be reduced to a less than significant level. With implementation of all applicable regulatory requirements, future development pursuant to the Project would not expose people and/or structures to potentially substantial adverse effects resulting from strong seismic ground shaking and seismic-related ground failure. Genentech Campus Master Plan Update – CEQA Findings page 16 49. Impact Geology 3, Differential Settlement and Unstable or Expansive Soils: The potential for soil expansion varies throughout the Project area. Areas of unsuitable soils exist particularly in the Lower Campus and South Campus, where fill soils have previously been placed over wetlands and Bay Mud. New development in these areas has the potential to result in damage to building foundations, which may compromise the stability of the overlying structure, as well as to create future liquefaction, subsidence or collapse problems leading to building settlement and utility line disruption. Regulatory Requirements: Regulatory Requirements, General: All new development pursuant to the Project will be required to comply with all applicable regulatory requirements for seismic hazards, including but not limited to the California Seismic Hazards Mapping Act, California Building Code, City of South San Francisco Municipal Code - Chapter 15.08, and East of 101 Area Plan, Chapter 10, which sets forth policies and specific guidelines pertaining to site development and building design applicable to the unique geological hazards in the East of 101 Area, including the Project Area. Regulatory Requirement Geology 3 – Soils Hazards: Pursuant to regulatory requirements, Genentech will be required to retain a certified licensed geotechnical engineer to prepare site- specific geotechnical studies for each new development project pursuant to the Project. 1. Geotechnical studies shall include site-specific geotechnical recommendations demonstrating compliance with all applicable soils-related building design requirements. 2. Site-specific recommendations may include design features (such as expansion joints, mounting foundations on concrete piles), or replacing existing soils on a project site with stable fill material such that structures can withstand soils expansion. Building pad substrates may also be applicable on soils subject to expansive potential, and weak soils may require re-engineering specifically for stability. Soil treatment programs (replacement, grouting, compaction, drainage control, etc.) may be included in excavation and construction plans, and/or piling supports that conform to implementation criteria described in the CBC, Chapters 16, 18, and A33 may need to be designed and implemented. 3. All recommendations shall be incorporated into individual development project designs and construction, providing an acceptable level of protection against soils-related hazards. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Geology 3): Compliance with regulations and project-specific recommendations will ensure that individual development project designs and construction of foundations and structures provide adequate protection against soils-related hazards. With implementation of all applicable regulatory requirements, future development pursuant to the Project that may be located on a geologic unit or soil that is unstable or that could become unstable because of development, and future development that may be on expansive soil, will not create a substantial risk to life or property. Adherence to the City's Codes and policies, including any project-specific recommendations to demonstrate full compliance, would ensure the maximum practicable protection available for soils hazards, and would result in a less than significant impact. 50. Impact Geology 4, Substantial Soil Erosion or Loss of Topsoil: New development pursuant to the Project could potentially generate soil erosion, primarily from site preparation activities for new Genentech Campus Master Plan Update – CEQA Findings page 17 development. Construction-period earth-disturbing activities would be temporary, and erosion effects would depend largely on the areas excavated, the quantity of excavation and the length of time soils are subject to conditions that would be affected by erosion processes. Substantial erosion is unlikely to occur on an operational basis, and is not considered significant. Regulatory Requirements: Regulatory Requirement Geology 4 – Grading Regulations: Pursuant to regulatory requirements, Genentech will be required to retain a certified licensed geotechnical engineer to prepare site- specific geotechnical studies for each new development project pursuant to the Master Plan Update. Geotechnical studies shall include site-specific geotechnical recommendations demonstrating compliance with all applicable erosion control requirements, including but not limited to the following: 1. California Building Code, Chapter 18 (which regulates excavation activities and the construction of foundations and retaining walls) and Chapter 33 (which regulates grading activities, including drainage and erosion control) 2. Bay Area Air Quality Management District Rules regarding fugitive dust, which would stabilize soils and prevent erosion through the reduction of dust generation by up to 85 percent 3. All new qualifying construction projects pursuant to the Master Plan Update will be required to comply with Provision C.6 of the Municipal Regional Permit (MRP), including filing a Notice of Intent for permit coverage under the Construction General Permit, and preparation of a Stormwater Pollution Prevention Plan (SWPPP) that demonstrates compliance with the City’s Grading Ordinances and other local requirements (see further details in Regulatory Requirement Hydro 1A in the Hydrology chapter of this EIR) 4. The evaluation of potential erosion of steeper slopes is also required as part of new development design in accordance with East of 101 Area Plan Geotechnical Safety Element policies. These policy requirements specify that slopes be graded and compacted during construction to reduce the likelihood of surface slumping or erosion, and that vegetative cover be applied to protect the slope from soil erosion. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Geology 4): All regulatory requirements will be incorporated into individual development projects to ensure that erosion is controlled to the maximum extent feasible. These regulations and policies include those outlined in the East of 101 Area Plan and the California Building Code, as well as the applicable NPDES General Construction Permit requirements for construction activities. With implementation of all applicable regulatory requirements, future development pursuant to the Project would not result in substantial soil erosion or the loss of topsoil. Adherence to these codes and regulatory requirements would result in a less than significant erosion impact. 51. Impact Geology 5, Septic Tanks: Future development pursuant to the Project would be served by the existing municipal sewer system. No septic tanks or alternate waste disposal systems are proposed for development. Genentech Campus Master Plan Update – CEQA Findings page 18 Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Geology 5): Existing infrastructure is located throughout the Project Area, and any new development would connect to or expand the existing wastewater lines. No septic tanks or alternative wastewater systems are proposed, and there would be no impact. G. GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE 52. Impact GHG 1, Stationary Source Emissions Subject to Cap-and-Trade: The Project will result in a net increase in the types of stationary sources of GHG emissions that are specifically covered under the CARB Cap-and-Trade program (miscellaneous natural gas use, a combined heat and power plant and four new natural gas-fired boilers). Per Table 10-2 of the EIR, these stationary sources are projected to emit approximately 72,885 MTCO2e/year. These Project-related stationary source emissions will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of GHGs. Specifically, the Project will comply with the CARB Cap-and-Trade program, which is a method to achieve statewide reduction goals as set forth in AB 32. Regulatory Requirements: Regulatory Requirement GHG 1 – Cap and Trade: Pursuant to Genentech’s participation in the Cap-and-Trade Program, Genentech must meet its requirements by ensuring permits (through increased cap or trade) are obtained for incremental growth stationary source GHG emissions. The Cap-and-Trade allowances must meet or exceed stationary source emission levels as reported to CARB pursuant to mandatory GHG reporting requirements. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact GHG 1): Reliance on the Cap-and-Trade program to address these specific types of stationary source emissions is consistent with the City’s Climate Action Plan (CAP), which indicates that emissions from such stationary sources are most effectively addressed and regulated by the BAAQMD, or by federal and state programs. The volume of emissions resulting from energy use at Genentech facilities subject to the Cap-and-Trade program was specifically excluded from the City’s GHG inventory and forecast. Compliance with the Cap-and-Trade program can be verified through publicly accessible data maintained by the California Air Resources Board, which includes statewide and facility-specific information on emissions reporting, offsets and allocations, and facility compliance with the Cap and Trade Program. 53. Impact GHG 2, Permitted Stationary Source Emissions: The Project’s stationary source emissions that are not otherwise addressed under the Cap-and-Trade program will not exceed 10,000 MT of CO2e per year, and thus will not contribute to global climate change at a level that is considered cumulatively considerable. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact GHG 2): Based on the detailed calculation presented in the GHG Appendix to the EIR and summarized in EIR Genentech Campus Master Plan Update – CEQA Findings page 19 Table 10-3, the estimated GHG emissions attributed to non-Cap-and-Trade sources (as many as 52 new emergency generators) is estimated at approximately 2,200 MTCO2e/yr., substantially less than the stationary source emissions threshold of 10,000 MTCO2e/yr. 54. Impact GHG 3, Operational Emissions Fully Covered under the SSF CAP: The Project’s operational emissions will not conflict with an applicable plan, policy or regulation adopted for the purposes of reducing the emissions of GHGs. Operational GHG emissions that comply with a Qualified GHG Reduction Strategy (i.e., the South San Francisco Climate Action Plan, or CAP) are deemed less than significant under CEQA. GHG emission sources of the Project that are covered by, and in compliance with the CAP include the Project’s traffic-related mobile source emissions, indirect GHG emissions from water use and wastewater treatment, and GHG emissions from solid waste disposal. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact GHG 3): The Project’s indirect operational GHG emissions attributable to mobile sources, water use, wastewater treatment and waste disposal (estimated in Table 10-4 of the EIR to total approximately 25,849 MTCO2e/yr) are fully addressed in the City of South San Francisco’s Climate Action Plan. The CAP allows the City to determine that future development projects will have a less than significant impact on CAP-related GHG emissions if they comply with CAP GHG reduction measures. The Project’s TDM program is in full compliance with (and exceeds) the GHG emission reduction strategies of the SSF CAP, the Project’s water conservation and water recycling programs are in full compliance with the GHG emission reduction strategies of the SSF CAP, and the Project’s waste diversion programs are in full compliance with the GHG emission reduction strategies of the SSF CAP. Therefore, these GHG emission sources of the Project that are covered by, and in compliance with the CAP, will not conflict with an applicable plan, policy or regulation adopted for the purposes of reducing the emissions of GHGs. 55. Impact GHG 4, Other Operational GHG Emissions by Year 2020: The Project will not generate land use-based GHG emissions, other than those emissions addressed pursuant to the City CAP, that exceed the efficiency threshold of 4.6 MT of CO2e per year per service population at year 2020. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact GHG 4): As shown on EIR Table 10-6, the net new GHG emission attributable to construction activity through buildout, plus indirect electricity use, HFC gas use and process CO2 gas use is calculated to be approximately 17,678 MTCO2e/yr. Dividing those annual emissions by the Project’s anticipated service population of 15,070 net new jobs yields a ratio of 1.17 MTCO2e per service population, well below the 2020 threshold of 4.60 MTCO2e/yr/service population. Thus, the Project would not exceed the service-based efficiency threshold for land use-based GHG emissions by year 2020. 56. Impact GHG 5, Other Operational GHG Emissions by Year 2030: The Project will not generate land use-based GHG emissions, other than those emissions addressed pursuant to the City CAP, that exceed the efficiency threshold of 2.7 MT of CO2e per year per service population at year 2020 Mitigation Measures: None required. Genentech Campus Master Plan Update – CEQA Findings page 20 Finding of Less Than Significant Impact Without Mitigation Measures (Impact GHG 4): As shown on EIR Table 10-6, the net new GHG emission attributable to construction activity through buildout, plus indirect electricity use, HFC gas use and process CO2 gas use is calculated to be approximately 17,678 MTCO2e/yr. Dividing those annual emissions by the Project’s anticipated service population of 15,070 net new jobs yields a ratio of 1.17 MTCO2e per service population, well below the 2030 threshold of 2.7 MTCO2e/yr/service population. Thus, the Project would not exceed the service-based efficiency threshold for land use-based GHG emissions by year 2030. 57. Cumulative GHG Emissions: Analysis of the Project’s climate change impacts in the EIR assess the Project’s contribution to cumulatively significant global climate change resulting from the Project’s individual emission of GHGs. The cumulative impacts of the Project with respect to the issue of climate change are therefore captured in the project-level analysis. H. HAZARDS AND HAZARDOUS MATERIALS 58. Impact Hazards 1, Routine Transport, Use, Disposal or Storage of Hazardous Materials: Implementation of the Project will result in development of additional laboratories and other research facilities that are likely to use, store or require the transportation and disposal of hazardous materials. The Project would also result in an increase in the number of people that work and visit the Project area, increasing the number of individuals potentially exposed to hazardous materials. Off-site hazardous materials exposure could occur through limited circumstances, such as accidental spills or release during transport or use. Regulatory Requirements: Genentech must comply with the safety procedures mandated by applicable federal, state and local laws and regulations pertaining to the routine use of hazardous materials and disposal of hazardous wastes. Genentech has established programs, practices and procedures, and safety standards in compliance with these regulations. These safety programs will reduce the risk of exposure to biohazardous and chemical hazardous materials through established protocols. Genentech ensures that their facilities comply with the California Code of Regulations and the conditions of its radioactive materials license. Radiation use authorizations and ongoing training regarding radiation safety also reduce the risks from radiation-related use or disposal on-site. Federal and state laws, as well as all Genentech procedures for handling hazardous wastes, will be extended to all new facilities developed under the Project, as applicable. Regulatory Requirements Hazards 1A - Use of Chemical Materials: Genentech shall comply with all State, federal and local regulations, and Genentech programs, practices and procedures that ensure the potential for worker and/or public exposure to hazardous chemicals from improper or unsafe activities or from accidents is less than significant. Regulatory Requirements Hazards 1B - Use of Radioactive Materials: The use of radioactive materials at the Genentech site is specifically subject to the conditions of a radioactive materials license issued and administered by the Radiologic Health Branch of the DHS. Genentech administers and monitors facility compliance with license requirements. Radioactive materials licensing requirements include routine inspection and monitoring of areas where radioactive materials are used, to ensure that surfaces are not contaminated with radioactivity above background levels. Under the radioactive materials license, renovation or demolition of facilities using radioactive material requires decommissioning of the facilities. This involves radiation Genentech Campus Master Plan Update – CEQA Findings page 21 testing and conducting decontamination and waste handling activities in accordance with applicable regulations. Regulatory Requirements Hazards 1C - Use of Biohazardous Materials: Genentech complies with guidelines promulgated by the United States Department of Health and Human Services (USDHHS), Centers for Disease Control and Prevention, and National Institutes of Health that determine the level of safety precautions that must be used for four tiers of relative hazards. Biosafety Level 1 is for the least hazardous biological agents, and Biosafety Level 4 is for the most hazardous biological agents. Biosafety Levels for infectious agents are based on the characteristics of the agent (virulence, ability to cause disease, routes of exposure, biological stability and communicability), the quantity and concentration of the agent, the procedures to be followed in the laboratory, and the availability of therapeutic measures and vaccines. Biosafety Level 1 agents pose minimal or no known potential hazards to individuals and the environment. Biosafety Level 2 agents are considered to be of ordinary potential hazard and may produce varying degrees of disease through accidental inoculation, but may be effectively contained by ordinary laboratory techniques and specific laboratory equipment. Biosafety Level 3 agents pose a more substantial risk, and work with these agents must be conducted in contained facilities for which airflow is directed into the laboratory and access is controlled separately from public areas. Regulatory Requirements Hazards 1D - Disposal of Hazardous Materials: Genentech disposes of hazardous wastes in compliance with Titles 8, 14, 17 and 22 of the California Code of Regulations. Regulatory Requirements Hazards 1E – Hazardous Materials Transport: The CHP and US DOT strictly regulate the transportation of hazardous materials to and from the site. Procedures mandated by federal and state laws and regulations include driver training and licensing, standardized hazard warning placards for vehicles, shipping manifest requirements and standards for classifying, handling and packaging hazardous materials. Continuation of existing (or equivalent) Genentech programs, practices and procedures, will ensure that the use, transport or disposal of hazardous materials does not expose employees, visitors or the nearby public to significant health or safety risks. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 1): Mandatory compliance with all applicable federal, State and local regulations pertaining to the safe use, storage, transport and disposal of hazardous materials (including chemical, radioactive, and biohazardous waste used at Genentech facilities) will ensure that the expose of Genentech employees or the nearby public will be reduced to levels determined by these regulations to be less than significant. 59. Impact Hazards 2, Reasonably Foreseeable Upset and Accident Conditions: Implementation of the Project will result in increased shipments of hazardous waste. The transportation of hazardous materials can result in accidental spills, leaks, toxic releases, fire or explosion. The movement of hazardous materials also occurs within buildings at the Genentech facility, where accidents could occur. The consequences of an on-site spill depend on whether hazardous materials are released, the specific hazards associated with the material, the facility design and the availability of emergency response equipment. Genentech Campus Master Plan Update – CEQA Findings page 22 Regulatory Requirements: Regulatory Requirements Hazards 2A - Off-Site Transportation of Hazardous Materials: The USDOT Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials, as described in Title 49 of the Code of Federal Regulations, and implemented by Title 13 of the California Code of Regulations. Transportation of hazardous materials along any City or state roadways within or near Genentech is also subject to all hazardous materials transportation regulations established by the California Highway Patrol pursuant to the California Vehicle Code and the South San Francisco Fire Department (SSFFD). 1. In compliance with these regulations, Genentech’s programs, practices and procedures specifically govern receipt of hazardous materials. Licensed vendors bring hazardous materials to and from the facility, and manifests are completed and maintained by Genentech for all hazardous waste that is transported. The DTSC maintains copies of Genentech's waste manifests. In conformance with additional legal requirements, incoming radioactive material is monitored and recorded for each acquisition. Genentech processes and delivers all incoming radioactive materials to end users. 2. Section 31303 of the California Code of Regulations requires that when hazardous materials are transported on state or interstate highways, the highways that offer the shortest overall transit time possible shall be used. As required by federal and state laws, all other hazardous materials transportation regulations must be followed, including USDOT regulations for packaging and handling hazardous materials to prevent accidental spills of hazardous materials during transit. Regulatory Requirements Hazards 2B - Hazardous Materials Use, Storage and On-Site Transportation: Management of risk and minimizing the potential for upset and accident conditions involving the release of hazardous materials is regulated by numerous federal, State and local laws and regulations. 1. The Cal EPA’s regulations pursuant to the Unified Hazardous Waste and Hazardous Materials Management Regulatory Program addresses (among other matters) a number of programs specifically designed to minimize such risks. These programs require all businesses that handle hazardous materials to prepare a Hazardous Materials Release Response Plan and inventory, a Risk Management and Prevention program, and compliance with Unified Fire Code requirements. These programs are implemented at the local level, and in South San Francisco, the San Mateo County Department of Environmental Health (SMCDEH) is the designated Certified Unified Program Agency (CUPA) responsible for implementation of these programs. 2. The California Hazardous Materials Release Response Plans and Inventory Law of 1985 (Business Plan Act) requires that any business that handles hazardous materials prepare a Business Plan. That Business Plan must include details of the facility and business conducted at the site, an inventory of hazardous materials that are handled or stored on site, an emergency response plan and a training program for safety and emergency response for new employees, with annual refresher courses. 3. The USDHHS, CDC, NIH and DHS all prescribe containment and handling practices for use in microbiological, biomedical and animal laboratories. Medical wastes must be managed as a biohazardous material, in accordance with Section 117635 of the California Health and Genentech Campus Master Plan Update – CEQA Findings page 23 Safety Code, and the management of biohazardous materials must comply with USDHHS guidelines and DHS regulations. 4. The Atomic Energy Act ensures the proper management of source, special nuclear, and by- product material. The California Radiation Control Law California Health & Safety Code Sections 114960-114985) is a regulatory program designed to provide for compatibility with the standards and regulatory programs of the federal government and integrate an effective system of regulation within the state. These laws and regulations govern the receipt, storage, use, transportation and disposal of sources of ionizing radiation (radioactive material), and protect the users of these materials and the public from radiation hazards. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 2): Genentech complies with all of these applicable federal, State and local laws and regulations via Genentech programs, practices and procedures related to the storage and use of hazardous materials. Safe storage of hazardous materials will continue to be implemented to maximize containment through safe handling and storage practices. Genentech will also continue to comply with federal and state laws and existing Genentech programs, practices and procedures to eliminate or reduce the consequence of hazardous materials accidents, should they occur. Genentech will also continue to implement all applicable federal and State laws and existing Genentech programs, practices and procedures to prevent against the risks of accidental spills or releases of hazardous materials during internal transfers and movement of these materials, and the cleanup of hazardous materials in the event of an accidental release. Continued compliance with all applicable federal, state and local laws and regulations pertaining to the transport, use, disposal, and handling of hazardous waste, as well as implementation of Genentech’s programs, practices and procedures, will ensure that impacts related to accidental spills and upset involving hazardous materials remains less than significant. 60. Impact Hazards 3, Cortese List Sites: Most Cortese listed sites within the Campus consist of registered facilities that generate, transport, store, treat and/or dispose of hazardous waste, registered active or inactive underground storage tanks (USTs), and registered hazardous materials storage locations, rather than contaminated sites (e.g., soil or groundwater). There is one open (or active) contaminated site within the Project Area where an investigation and/or remediation is in progress and where a regulatory agency is still actively involved. This site is the O'Brien Corporation site located at 450 East Grand Avenue on the South Campus. This site is designated by the DTSC as a “Closed Case” but with Corrective Action, and is also designated by the SWRCB as a Cleanup Program Site with cleanup status “Open – Inactive”. Future development of any site that has a documented release of hazardous materials and that is listed in a regulatory database (such as any additional work within the bounds of the O’Brien site) is subject to site clean-up regulations as required by the lead regulatory agency. Regulatory Requirements: Regulatory Requirement Hazards 3 – DTSC Deed Restrictions and Enforcement Plan: The O’Brien site is still subject to deed restrictions and the Agreement for Operations and Maintenance (which includes a requirement to comply with the Land Use Covenant Implementation Enforcement Plan). As a result, the following regulatory controls remain applicable to this site: Genentech Campus Master Plan Update – CEQA Findings page 24 1. Activities that may disturb existing groundwater monitoring wells shall not be permitted without prior review and approval by DTSC. 2. The capped portion of the site may be variously occupied by buildings, paved with either concrete or asphalt or covered with landscaping or other vegetative cover, clean soil imported from an off-site location, or with other suitable cover to mitigate direct exposure. 3. Engineering controls such as wind erosion control and dust suppression must be implemented during construction activities to minimize or mitigate potential exposure of contaminated soil. 4. Any contaminated soils that may be brought to the surface by future grading, excavation, trenching, backfilling or other activity shall be managed in accordance with all applicable provisions of state and federal laws and regulations, including the DTSC-approved Site Management Plan and Health and Safety Plan. 5. The Site Management Plan includes administrative controls for construction workers (including designation of regulated areas, employee training and personal hygiene practices). Controls include personal protective respiratory equipment for construction workers, air monitoring to verify the effectiveness of hazard controls and to document emissions, training of construction employees or persons who may handle or come in contact with potentially hazardous materials, and collection and analysis of surface soil samples from areas not covered with structures or a paved surface to verify the integrity of a clean soil cap. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 3): Implementation of regulatory requirements will ensure that any impacts that may result from future disturbance of the soil cap at the Cortese-listed O’Brien site will be mitigated to less than significant levels. 61. Impact Hazards 5, Emissions of Hazardous Materials near a School: The Project will not emit hazardous emissions nor handle hazardous or acutely hazardous materials, substances or waste within one-quarter mile of an existing or proposed school, but may handle such substances within one-quarter mile of a childcare facility. The Project Area is located within an area zoned for industrial uses, only. Thus, no school can be proposed within one-quarter mile of the Project Area. However, there are three childcare facilities operating at or within one-quarter mile of the Project Area. New construction activities pursuant to the Project could expose children and workers at these childcare centers to hazards, and potential exposure to hazards related to the routine transport, use, disposal or storage of hazardous materials. Regulatory Requirements: Regulatory Requirements: During any construction activities near childcare facilities, all regulatory requirements pertaining to known hazardous materials sites (see Findings under Impact Hazards 3, above) will apply. Additionally, all regulatory requirements pursuant to construction activities that could expose the public to a significant hazard from hazardous materials through the renovation or demolition of buildings, or relocation of underground utilities (see Findings under Impact Hazards 4, above) will also apply. All of the regulatory requirements listed pursuant to the routine transport, use, disposal or storage of hazardous Genentech Campus Master Plan Update – CEQA Findings page 25 materials (see Findings under Impact Hazards 1, above), and all of the regulatory requirements listed pursuant to reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment (see Findings under Impact Hazards 2, above) will also apply to operational activities near childcare facilities. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 5): Continued compliance with applicable regulations will ensure that the potential for impacts related to use or discovery of hazardous materials near childcare facilities will be reduced to levels determined by these regulations to be less than significant. 62. Impact Hazards 6, Safety Hazards Related to a Public or Private Airport or Airstrip: The Project is located within the Airport Land Use Plan boundaries of San Francisco International Airport (SFO), but the Project would not result in a safety hazard for people residing or working in the Project area. The Project is not located near a private airstrip. The Project Area is entirely within the SFO Airport Influence Area (AIA) and as such, the compatibility criteria contained within the SFO ALUCP are applicable to development within the Project Area. The Project is consistent with the noise, land use safety and building height criteria of the ALUCP, and would not conflict with plans and policies intended to protect and promote airport operations safety and/or airspace protection. Regulatory Requirements: Regulatory Requirement Hazards 6: FAA Building Height Criteria: Pursuant to the Project, the maximum heights of new buildings within the Project Area shall comply with the height regulations and restrictions as established by FAA criteria. 1. Pursuant to these height regulations, new buildings exceeding the FAA Part 77 “imaginary surface” height limits will be subject to FAA review and may be required to provide marking and/or lighting, or may not be found acceptable to the FAA if determined to have impacts to the safety or efficiency of operations at SFO. 2. No new structures will exceed heights that penetrate “critical aeronautical surfaces”. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 6): Compliance with FAA building height regulations would ensure that the Project does not result in new buildings that exceed applicable ALUCP building height limits, and thus will be protective of public health, safety and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures. 63. Impact Hazards 8, Wildland Fires: The Project would not expose people or structures to a significant risk of loss, injury or death involving wildland fires. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hazards 8): The Project Area is a highly developed industrial area, and no wildlands are intermixed within this industrial area. The Project Area is bordered by developed industrial lands to the north, east and Genentech Campus Master Plan Update – CEQA Findings page 26 south, San Francisco Bay is to the east and no wildlands are adjacent to the Project area. The Project would not exacerbate wildfire risks of any nature, would not substantially impair and adopted emergency evacuation plan or emergency response plan, and it not located in or near a Local or State Responsibility area with a Very High Fire Hazard Severity Zone designation. The Project is not susceptible to significant risk of loss, injury or death involving wildland fires. I. HYDROLOGY AND WATER QUALITY 64. Impact Hydrology 1, Water Quality: Future development pursuant to the Project could result in a violation of water quality standards or waste discharge requirements or otherwise substantially degrade water quality. Typical construction activities can result in degradation of water quality and violation of water quality and waste discharge standards as construction activities may loosen soils, increase erosion and downstream siltation, potentially intercept contaminated groundwater during dewatering, and may result in accidental spill or release of construction-related chemicals that may contact surface waters. After construction, new development pursuant to the Project would create or replace impervious surfaces, resulting in increased runoff and the potential for that runoff to carry pollutants to receiving waters, including the Bay. Regulatory Requirements: Regulatory Requirement Hydro 1A - Construction General Permit/Stormwater Pollution Prevention Plan: All new qualifying construction projects pursuant to the Master Plan Update will be required to comply with Provision C.6 of the Municipal Regional Permit (MRP), including filing a Notice of Intent for permit coverage under the Construction General Permit. 1. To obtain Construction General Permit coverage, construction projects must include a Stormwater Pollution Prevention Plan (SWPPP) that demonstrates compliance with the City’s Grading Ordinances and other local requirements. 2. The SWPPP must demonstrate implementation of seasonally appropriate and effective best management practices (BMPs) to prevent construction site discharges of pollutants into the storm drains, before approval and issuance of local grading permits. 3. Such construction projects are required to implement the stormwater BMPs identified by the San Mateo Countywide Stormwater Pollution Prevention Program, including plans to address materials and waste management, equipment management and spill control, grading and earthmoving to prevent erosion, paving and asphalt work, concrete and mortar applications, painting and paint removal, landscaping and dewatering. Regulatory Requirement Hydrology 1B - Permitting Requirements for Dewatering Discharges: Depending on volume and pollutant loads of non-stormwater discharges associated with an individual construction dewatering activity, and the dewatering methodology to be applied, different regulatory requirements apply. For non-stormwater dewatering discharges, each individual construction project shall obtain coverage either under the Construction General Permit, Statewide Low-Threat Discharge Waste Discharge Requirements (WDR) or a site-specific NPDES permit. Typical dewatering methods permitted pursuant to these regulatory requirements include: 1. Discharge to a Stormdrain. Authorized non-stormwater may be discharged to a storm drain under the Construction General Permit. A permit from the local sewer agency must be obtained prior to such discharge. This approach is generally appropriate for water that contains some sediment and/or pollutants, but sediment may require pre-treatment and Genentech Campus Master Plan Update – CEQA Findings page 27 acceptable pollutants and pollutant levels are defined by the sewerage agency. Such permits typically include provisions for fees, requirements for pre-discharge testing and reporting, and establishment of acceptable discharge limitations/prohibitions typically pertaining to the chemical quality of the water, discharge flow rates and quantities. 2. Managing Water within the Project Site: Accumulated non-stormwater may be retained and managed on the construction site, generally pursuant to statewide low-threat discharge Waste Discharge Requirements (WDRs). Retained water is evaporated, infiltrated into the soil, or is used onsite for dust control, irrigation or other construction-related purposes. This approach is generally appropriate for water that is free of pollutants, other than sediment. 3. Off-Site Treatment: This option is typically appropriate for water with toxic pollutants that cannot be discharged elsewhere. Under this approach, water is hauled off-site for treatment, typically involving a licensed commercial contractor who can remove, transport and dispose (or treat and recycle) polluted water. General requirements of this approach include acceptance of a NOI for coverage under the Construction General Permit, plus chemical testing of water quality and management of the water as hazardous waste, with applicable regulatory agency (typically RWQCB) oversight (see also Mitigation Measure Hazards-4: Site Assessment in the Hazards and Hazardous Waste chapter of this EIR). 4. Site-Specific NPDES Dewatering Permits: For those dewatering activities that cannot obtain permission to discharge to the local sanitary sewer and where the discharge cannot be regulated under the Construction General Permit or the statewide low-threat discharge WDRs, site-specific NPDES Dewatering Permits may be sought. General requirements for site-specific NPDES dewatering permits include monitoring and reporting as required by the Regional Board, and discharge and receiving water requirements (including water quality objectives, discharge prohibitions and TMDLs) as defined in the Basin Plan and specific NPDES permit obligations. Regulatory Requirement Hydro 1C - Provision C.3 Requirements/Stormwater Management Plan: All new Regulated Projects pursuant to the Master Plan Update will be required to comply with Provision C.3 of the MRP, including requirements to incorporate post-construction stormwater control and low-impact development (LID) measures. Each individual development project must meet Provision C.3 requirements capable of reducing long-term impacts of development on stormwater quality. Some combination of the following post-construction stormwater controls will be required to demonstrate compliance with the hydraulic design criteria of the MRP: 1. Site design may include minimizing impervious surfaces that are directly connected to the storm drain system, or using landscaping as a drainage feature. 2. Source control measures may include roofed trash enclosures, berms that control runoff from a pollutant source, use of indoor mats/equipment wash racks that are connected to the sanitary sewer (where allowed under separate sewer discharge permits), and regular inspection and cleaning of storm drain inlets. 3. Stormwater treatments may be met by a combination of measures that may include, but are not limited to bioretention areas, flow-through planter boxes, infiltration trenches, extended detention basins, green roofs, pervious paving and grid pavements, rainwater harvesting and subsurface infiltration systems. Mitigation Measures: None required Genentech Campus Master Plan Update – CEQA Findings page 28 Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hydrology 1): Subsequent development pursuant to the Project will comply with the State, regional, countywide and City regulations as outlined in the Municipal Regional Stormwater NPDES Permit (MRP) issued by SFRWQCB in November 2015, as may be subsequently updated or amended. These regulations ensure that potential water quality impacts related to construction and post-construction activity pursuant to the Project will be reduced to a less than significant level through implementation of stormwater treatment and design and regulatory oversight. 65. Impact Hydrology 2, Groundwater (Project-specific and Cumulative): Future development pursuant to the Project will not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impeded sustainable groundwater management of the basin. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hydrology 2): New development pursuant to the Project may result in slight interference with groundwater recharge, but this impact would be less than significant. California Water Service Company (Cal Water) supplies water to the Project Area, and new development pursuant to the Project would not individually draw down or otherwise substantially reduce the underlying groundwater resource. Based on information contained in the WSA report, the Project’s water demands will not cause Cal Water to extract groundwater at a rate that would substantially deplete groundwater supplies or interfere substantially with groundwater recharge. Further, the Project’s water demands will not contribute to cumulative water demands that would cause a net deficit in aquifer volume or a lowering of the local groundwater table level. Groundwater resource depletion is therefore not a significant direct or indirect effect of the Project. 66. Impact Hydrology 3, Drainage Patterns and Runoff (Project-specific and Cumulative): Colma Creek is the City’s main natural drainage system. Development pursuant to the Project will not alter the course of Colma Creek, will not result in substantial erosion or siltation to Colma Creek and will not increase the rate or amount of runoff into Colma Creek in a manner that would result in flooding. The total area of impervious surface created by the Project will not be substantially greater than the existing conditions, and thus redevelopment of existing impervious area will generally not increase runoff or demand substantial increases in stormdrain capacity, and no expansion of the onsite stormdrain facilities is anticipated. Because the Project Area’s stormdrain system drains directly into the Bay, no downstream drainage facilities are affected or influenced by runoff from the Project Area. Three surface drainage ditches are located within the Project Area. New development pursuant to the Project may result in the need or desire to alter the alignment, culvert or bridge over these drainage ditches, to develop or gain access to certain Opportunity Sites. Regulatory Requirements: Regulatory Requirement Hydro 1A - Construction General Permit/Stormwater Pollution Prevention Plan (see above) Regulatory Requirement Hydro 1B - Provision C.3 Requirements/Stormwater Management Plan (see above) Mitigation Measures: None required. Genentech Campus Master Plan Update – CEQA Findings page 29 Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hydrology 3): All new Regulated Projects pursuant to the Master Plan Update will be required to comply with State, regional, countywide and City regulations, including those outlined in the Municipal Regional Stormwater NPDES Permit (MRP). Compliance with these regulations will ensure that potential Project-specific and cumulative alterations to existing drainage patterns do not result in substantial erosion or siltation or adverse effects to water quality, and maintain the functionality of existing on-site drainage channels. The volume of stormwater runoff generated by the Project is not expected to substantially increase above existing conditions, and no substantial improvements or expansions to the existing stormdrain system is anticipated. The entire East of 101 Area, including the Project Area, is not within the Hydromodification Management Control Area Boundary, and thus not subject to hydromodification management (i.e., is not required to minimize the change in the rate and flow of runoff as compared to the pre-development conditions). Future development pursuant to the Project would not substantially alter existing drainage patterns in a manner that would result in substantial cumulative erosion or siltation, or that would increase the rate or amount of cumulative surface runoff in a manner that would result in flooding. Development pursuant to the Project will not contribute to potential cumulative effects that might alter the course of Colma Creek, will not contribute to cumulative siltation effects in Colma Creek, and will not increase the rate or amount of cumulative runoff that contributes to Colma Creek. 67. Impact Hydrology 4, Flood Hazards: Future development pursuant to the Project could risk release of pollutants due to project inundation as a result of a flood hazard, tsunami or seiche. The Genentech Campus is located immediately adjacent to the Bay, with Bay shoreline along its entire eastern boundary. Although the majority of the Project Area is not within a 100-year flood hazard zone, the immediate shoreline and the inlet at the southern portion of the Project Area are within the 100-year flood hazard zone as mapped by FEMA. Coastal flooding and wave action during a 100- year storm would inundate certain portions of the immediate shoreline bordering the Project Area. New development pursuant to the Project would not include housing, and no new structures would be placed on the shoreline that would be subject to or impede flows within the 100-year flood hazard zone. Certain potential Opportunity Sites identified in the Master Plan Update are near the shoreline, and subsequent and more detailed development plans for these sites will need to demonstrate compliance with regulatory requirements, including building pads that are elevated above the 100-year flood elevation. Regulatory Requirements: Regulatory Requirement Hydro 4A: National Flood Insurance Program: Executive Order 11988 is a federal regulation that requires the prevention of uneconomic, hazardous or incompatible use of floodplains; protection and preservation of the natural and beneficial floodplain values; and consistency with the standards and criteria of the National Flood Insurance Program. Regulatory Requirement Hydro 4B: South San Francisco Municipal Code: Chapter 15.56, Section 15.56.140 of the South San Francisco Municipal Code identifies standards specific to construction in coastal high hazard areas. Developments shall be elevated above the flood level, anchored and constructed of materials resistant to flood damage. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Hydrology 4): All new development pursuant to the Project will be required to adhere to applicable codes and Genentech Campus Master Plan Update – CEQA Findings page 30 regulatory measures that ensure potential flood hazards are reduced to the maximum extent feasible. With compliance with these regulatory requirements, development pursuant to the Project would not expose people or structures to substantial risks involving flooding, nor would the Project risk release of pollutants due to project inundation as a result of a flood hazard, tsunami or seiche. 68. Cumulative Hydrology Effects: The Project’s potential contribution to cumulative impacts to hydrology and water quality is evaluated in the context of past, present, and reasonably foreseeable probable future development that may affect similar water resources in the same watershed. Cumulative runoff (both construction-period and post construction) from the Project and other past, current and reasonably foreseeable future cumulative development in the East of 101 Area could have adverse cumulative effects on hydrology and water quality, including increased stormwater runoff and pollutant loading to the Bay. Finding of Less Than Cumulatively Significant Impact With Mitigation Measures or Regulatory Requirements: All present and reasonably foreseeable future development projects are required to comply with regulatory requirements that control the discharge of stormwater pollutants. Those regulatory requirements that apply to all cumulative construction projects include compliance with the Construction General Permit, and preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) pursuant to Provision C.6 of the Municipal Regional Permit (MRP). All regulated cumulative development projects are required to design and implement Stormwater Management Plans that comply with applicable C.3 provisions of the MRP, including requirements to incorporate post-construction stormwater controls and low- impact development (LID) measures. These regulations are designed to protect water quality from all new cumulative construction and development, including the Project. With implementation of applicable regulatory requirements, cumulative impacts to hydrology and water quality would be less than significant, and the Project would not result in a cumulatively considerable contribution to a significant cumulative hydrology or water quality impact. J. LAND USE 69. Impact Land Use 1, Physically Divide an Established Community/Residential or Business Displacement: The Project would not physically divide an established community. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Land Use 1): Existing and future uses within the Project Area include commercial, manufacturing, and research and development activities. These uses are consistent with existing land uses in the surrounding area. There are no residential structures within the Project Area, and residential use is not permitted in the East of 101 Area. No existing business or residential community would be displaced by the proposed Project. Therefore, there would be no impact. 70. Impact Land Use 2, Conflict with Policies or Regulations Adopted to Avoid or Mitigate an Environmental Effect: Implementation of the Project would modify or change certain land use regulations applicable to the Project Area, but would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Genentech Campus Master Plan Update – CEQA Findings page 31 Mitigation Measures None required. However, to clarify the City’s position regarding consistency with ALUCP criteria, the following mitigation measure is recommended: MM Land Use 2 - Building Height Limits: Any proposed building within the Project Area that would exceed FAA notification heights shall file a Notice of Proposed Construction or Alteration with the FAA. a) Any structure that exceeds the Horizontal Surface Plane of 163.2 feet above mean sea level, that otherwise exceeds applicable FAA Part 77 criteria, or which exceed 200 feet above the ground level of its site shall be required to comply with the findings of an FAA aeronautical study. Structures subject to such FAA review shall comply with any FAA-recommended alterations in the building design and/or height, and any recommended marking and lighting of the structure as may be necessary to be found by the FAA as not posing a hazard to air navigation. b) The maximum height of new buildings within the Project area shall be the lower of the height shown on the SFO Critical Aeronautical Surfaces Map, or the maximum height determined by the FAA as being “not a hazard to air navigation” based on an aeronautical study. c) The Project proponent shall provide documentation to the City Planning Division demonstrating that the FAA has issued a ‘Determination of No Hazard to Air Navigation” when such determination is applicable. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Land Use 2): The Project does not fundamentally conflict with plans or policies adopted for the purposes of avoiding or mitigating an environmental effect, including those of the South San Francisco General Plan, the East of 101 Area Plan, City zoning regulations, the BCDC Bay Plan or the SFO ALUCP. Where certain conflicts have been identified (e.g., East of 101 Area Plan policies pertaining to steep slopes), alternative regulations or mitigation measures are identified that provide more specific and precise standards, such that potential environmental impacts would not be significant, and potential conflict with plans and policies would not result in significant environmental effects not otherwise addressed by comparable of more effective mitigation. 71. Impact Land Use 3, Conflicts with Applicable Habitat Conservation Plan: The Project would not conflict with any applicable habitat conservation plan or natural community conservation plan. Mitigation Measures None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Land Use 3): The Project site is not included in any natural community conservation plan or applicable habitat conservation plan. Therefore, the Project has no impact related to potential conflicts with such plans or programs. 72. Cumulative Land Use Effects: The Project would contribute to overall changes in land use in the East of 101 Area. Development pursuant to the Master Plan Update, in combination with other cumulative development in East of 101 will increase the density of the employment-generating land use in the East of 101 Area. Genentech Campus Master Plan Update – CEQA Findings page 32 Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Cumulative Land Use Impacts): Cumulative development in the East of 1010 is anticipated to be consistent with buildout expectations of the SSF General Plan and East of 101 Area Plan. The City encourages redevelopment of underutilized sites with high-quality campus-style biotechnology, technology and research and development uses. Other office/R&D uses anticipated under cumulative conditions are anticipated to be consistent with land use plans and policies in effect at the time. The Project, in combination with other cumulative development in East of 101 will not contribute to a physical division of the established business community. For these reasons, the Project in combination with past, present and reasonably foreseeable future projects in the East of 101 Area will have a less than significant cumulative land use impact. The Project will not make a cumulatively considerable contribution to a significant cumulative land use impact, and no mitigation measures are necessary. K. MINERAL RESOURCES 73. Impact Minerals 1, Availability of Mineral Resources (Project-specific and Cumulative): The Project would not have a significant adverse impact, individually or cumulatively, on the availability of a known mineral resource or a locally important mineral resource recovery site. Mitigation Measures: None required. Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Impact Minerals): The Project Site is urbanized and located in an urbanized, industrial area in the East of 101 portion of South San Francisco. The Project Site is classified under the Mineral Lands Classification system as an area where available information is inadequate for assignment to any other mineral classification zone, and not designated as an area of significant mineral deposits, and the Project Site has not been delineated as a locally important mineral recovery site in the General Plan. There are no mining activities on the Project Site, and no mining activities are known to have occurred there. Portions of the Project Site are located over Bay fill, where no subsurface mineral resources would be expected. There are no designated mineral resource recovery sites in the vicinity, whose operations or accesses would be adversely affected by the Project. No other proposed, reasonably foreseeable or probable cumulative projects in the East of 101 Area are mapped as containing mineral resources or resource recovery sites. There are no local, state or federal ordinances or policies related to mineral resources that are applicable to the Project. Mineral resource impacts are evaluated based on the California Department of Conservation, Division of Mines and Geology Mineral Lands Classification system. L. NOISE 74. Impact Noise 4, Operational Ground-Borne Vibration: Operational activities pursuant to the Project would not generate excessive ground-borne vibration, and would not adversely affect vibration- sensitive equipment or persons within the Project Area. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Noise 4): Upon completion of construction, no operational uses associated with the Project would generate a permanent source of ground-borne vibration. Implementation of the Project would not expose Genentech Campus Master Plan Update – CEQA Findings page 33 persons within the Project vicinity to excessive ground-borne vibration levels. The impact would be less than significant. 75. Impact Noise 5, Substantial Permanent Increase in Ambient Traffic Noise: Traffic generated by the Project would increase local ambient traffic noise, but the Project’s increased traffic noise would not adversely affect existing noise-sensitive receptors. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Noise 5): Table 14-12 of the EIR shows the increase in Project-generated traffic noise at those few noise- sensitive land uses (childcare centers and preschools) in the East of 101 Area. These existing noise-sensitive land uses are currently exposed to traffic noise exceeding 60 dBA, and the increased traffic noise attributable to the Project would not increase the existing noise levels at these sensitive receptors by 3 dBA or more. The Project’s increase in traffic noise would not adversely affect any noise-sensitive land use (i.e., residences, schools, churches or hospitals), and the impact is considered less than significant. 76. Impact Noise 6, Excessive Noise Due to Location within an Airport Land Use Plan: The Project would not expose people working in the Project Area to excessive noise levels due to proximity to airport-related noise sources. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Noise 6): The Project Area is not located within any of the ALUCP-identified noise impact areas. The ALUCP’s noise exposure criteria do not apply to the Project and would not restrict proposed land uses, and the Project is consistent with the ALUCP noise criteria. No impact would occur. 77. Impact Noise 7, Cumulative Traffic Noise: The Project, in combination with other current and foreseeable future cumulative development in the East of 101 Area will result in increased local traffic volumes that would increase ambient noise levels in the East of 101 area by greater than 3 dBA CNEL. However, there are few noise-sensitive land uses identified along these roadways that would be adversely affected by the cumulative increase in traffic noise. Of the four existing childcare and pre-school facilities within the East of 101 Area, only one of these facilities (which is located on Gateway Boulevard between Oyster Point Boulevard and East Grand Avenue) would experience a cumulative traffic noise increase of more than 3 dBA. The Project’s contribution to traffic noise in this location is approximately 0.5 dBA, less than the 1 dBA threshold for making a significant contribution to cumulative traffic noise. The other three existing noise-sensitive childcare and pre- school facilities are located along Allerton Avenue, where cumulative noise levels are not predicted to increase by more than 3 dBA and where the Project’s contribution to cumulative traffic noise would not be significant. Mitigation Measures: None required. Finding of Less Than Significant Cumulative Impact Without Mitigation Measures (Impact Noise 7): The Project would not generate a significant contribution to cumulative traffic noise throughout most of the East of 101 Area, with the exceptions of Oyster Point Boulevard, Gull Genentech Campus Master Plan Update – CEQA Findings page 34 Drive and East Grand Avenue. There are no identified noise-sensitive land uses along these specific roadways. Thus, cumulative traffic noise impacts on noise-sensitive land uses are considered less than significant. M. POPULATION, EMPLOYMENT AND HOUSING 78. Impact Population/Housing 1, Induce Substantial Population and Employment Growth (Project- specific and Cumulative): The Project will result in an increase in local South San Francisco employment by as much as 12,550 new employees, to 24,970 total employees at Project buildout. This employment growth will not exceed the cumulative growth in employment beyond that contemplated in the City General Plan, and will not induce cumulative population growth beyond that contemplated in the county or the region. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Population/Housing 1): The Project’s proposed increase to 9 million square feet of building space represents an increase of less than 10% of all projected cumulative employment- generating land uses in the East of 101 Area. The Project’s estimated employment growth is within the range of expected cumulative citywide employment growth, and the Project’s potential indirect housing demand represents a small share of projected cumulative household growth within the Bay Area region. The Project will not include any physical improvement that would induce growth beyond that needed to support its own needs, or that is in addition to City growth plans for the area. 79. Impact Population/Housing 2, Displace Substantial Numbers of Existing Housing Units: Implementation of the Project would not displace any existing housing that would necessitate construction of replacement housing elsewhere. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Population/Housing 2): The Project Area is composed entirely of the existing Genentech Campus and contains no housing of any type. As no residential uses exist in the Project Area, implementation of the Project would not displace existing housing. Therefore, there would be no impact. 80. Impact Population/Housing 3, Displace Substantial Numbers of People: Implementation of the Project would not displace substantial numbers of people. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Population/Housing 3):The Project consists of intensification of existing uses within the existing Genentech Campus, on properties owned or controlled by Genentech. There are three properties not owned or leased by Genentech, and the presence and ongoing operation of these out-parcels does not affect implementation of the Project or Genentech’s on-going operations, nor does the Project fundamentally affect or displace the ownership or use of these out-parcels. Genentech Campus Master Plan Update – CEQA Findings page 35 The Project’s direct employment growth can be accommodated on the Campus without displacing any businesses or people. 81. Cumulative Housing and Population Growth: The Project’s indirect housing demand can be accommodated on a regional basis within the Bay Area region’s expected household growth, without displacing any people. Genentech is able to draw employees from across the entire Bay Area region due, in large part, to its effective TDM Plan that provides employees with transportation options for commuting to the Campus from regionally dispersed locations. On a regional basis, the Project’s demand for new housing is not a significant share of the total projected regional household growth. Regulatory Requirements: Regulatory Requirement Pop /Emp. 1: Affordable Housing Commercial Linkage Fees: Each new development project within the Genentech Campus will be required to pay the City’s established commercial linkage fee to mitigate impacts on affordable housing in the City. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Cumulative population and Housing Impact): The City has found that there is a reasonable relationship between the commercial linkage fee and new commercial development because of the additional demands on housing (specifically affordable housing) that is generated by new development. The proceeds collected from these fees are used to address and mitigate the indirect impacts on housing created by commercial development projects. Project compliance with this regulatory requirement will ensure that this impact is less than significant without mitigation. N. PUBLIC SERVICES 82. Impact Public Services 1, Police Service (Project-specific and Cumulative): The Project would increase the number of employees in the Project Area over time, gradually increasing the demand for police service within the Project Area. However, the Project is and will continue to be adequately served with police service from existing facilities or new facilities to be constructed per citywide efforts, and Project-specific impacts related to police services would be less than significant. Cumulatively, a replacement police station is expected as part of the City’s Community Civic Campus project, which is intended to improve broader citywide (or cumulative) public services, including police services, to the City. Regulatory Requirements: Regulatory Requirement Services 1: Public Safety Impact Fees: Genentech will be required to pay the City of South San Francisco’s Public Safety Impact Fees as applicable at the time of new construction. Mitigation Measures: Finding of Less Than Significant Impact Without Mitigation Measures (Impact Public Services 1): Based on information presented in the EIR, the Project would generate a limited service demand of approximately 1 additional call every 4 days, and the Project would not individually generate demand for a new police station. The Project would have a less than significant individual impact related to police services because no new police facilities (other than those already planned at the Community Civic Campus Project) would be required. Required Genentech Campus Master Plan Update – CEQA Findings page 36 contributions to the City’s Public Safety Impact Fees represent the Project’s fair share of costs to provide citywide police services, and address cumulative impacts. 83. Impact Public Services 2, Fire and Emergency Medical Services (Project-specific and Cumulative): The Project would increase the number of employees in the Project Area over time, gradually increasing the demand for fire and emergency medical services within the Project Area. However, the Project is and will continue to be adequately served with fire and emergency medical service from existing facilities or new facilities to be constructed per citywide efforts, and impacts related to fire protection and emergency medical services would be less than significant. Cumulative development in the East of 101 Area (including the Project) is expected to necessitate relocation of Fire Station #62 to provide better response times to the entire East of 101 Area. Regulatory Requirements: Regulatory Requirement Services 2A - Compliance with Fire Code: Individual projects pursuant to the Master Plan Update will be required to comply with the City’s Fire Code (Chapter 15.24 of the Municipal Code), and the City Fire Marshall’s code requirements regarding on-site access for emergency vehicles. Regulatory Requirement Services 1 - Public Safety Impact Fees: Genentech will be required to pay the City of South San Francisco’s Public Safety Impact Fees as applicable at the time of new construction. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Public Services 2): Based on information presented in the EIR, the Project’s limited increase in fire and emergency service demand would not individually generate the need for a new fire station to serve the Project. Additionally, Genentech’s private First Alert Team provides supplemental fire response services for emergencies (including medical, chemical and fire emergencies) within the Genentech Campus. Required contributions to the City’s Public Safety Impact Fees represent the Project’s fair share of costs to provide citywide police services, and address cumulative impacts. The need for a new or relocated fire station to improve fire protection service and provide better response times to serve cumulative development throughout the entire East of 101 Area is unlikely to result in either direct or indirect environmental effects. The limiting factors involved in developing a new or relocated fire station are primarily economic. Under the current development impact fee structure, the City of South San Francisco’s Public Safety Impact Fees do not provide present-day funds in a timely manner to offset the near-term costs of a new fire station. To provide needed funds for a new and/or relocated fire station, it is anticipated that the City will need to enact a special property tax to be levied on those properties in the East of 101 Area benefitting from a new or relocated fire station or an updated and increased Public Safety Impact Fee applicable to the East of 101 Area (or potential in-lieu contributions associated with property dedication) to offset costs associated with construction and on-going fire protection and emergency response services needed to serve new cumulative development. 84. Impact Public Services 3, Recreation (Project-specific and Cumulative): The Project would increase the number of employees in the Project Area over time, gradually increasing the demand for recreational space within or near the Project Area. However, the existing Campus contains substantial public and private open space areas, and the Project includes plans for increasing open spaces with plazas, pathways, and common open space to serve new employees. Impacts related to Genentech Campus Master Plan Update – CEQA Findings page 37 recreational open space would be less than significant. Genentech and the Bay Conservation and Development Commission (BCDC) have entered into several permits that support on-going use of the Bay Trail by the public, on property within the Genentech Campus but subject to BCDC jurisdiction. These Bay Trail amenities provide benefits to Genentech employees, but also to the general public seeking open space and nature-based recreation. Any changes or additions to the Bay Trail improvements within the Genentech Campus will be subject to BCDC consideration and approval of amended permit conditions. Regulatory Requirements: Regulatory Requirement Services 3 - Parkland Acquisition and Construction Fees: Genentech will be required to pay Parkland Acquisition and Construction fees pursuant to Chapter 8.67 of the SSF Municipal Code. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Public Services 3): The Parkland Acquisition and Construction fees are intended to offset the financial effects related to increased demand for parks and recreational facilities resulting from cumulative development. Through on-site provision of recreational opportunities, payment of in-lieu fees to support off-site recreational opportunities as required by SSF Municipal Code, and required BCDC jurisdictional permit approval processes, the Project will not result in significant environmental impacts related to parks or recreation facilities. O. TRANSPORTATION 85. Impact Transportation 1A, Vehicle Miles Travelled: in addition to analyzing Project transportation impacts using LOS based thresholds of significance, the EIR also analyzed Project transportation impacts using VMT based thresholds suggested in OPR’s Revised Proposal on Updates to the CEQA Guidelines on Evaluating Transportation Impacts in CEQA (January 2016). Specifically, the Project would not exceed an average daily VMT per-employee (worker) rate that is 15% lower than the regional average daily VMT rate, or 15% lower than the City’s average daily VMT rate. Mitigation Measures None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Transportation 1A [VMT]): For purposes of the EIR’s VMT analysis, Project-generated VMT per employee was measured relative to baseline data provided by the Metropolitan Transportation Commission through their Travel Demand Model. Based on the VMT thresholds used in the EIR’s analysis, the target VMT rates are 19.3 VMT per employee in year 2015 (or 15% below the 2105 rate of 22.7 VMT per employee), and 17.3 VMT per employee in year 2040 (or 15% below the 2040 VMT per employee rate of 20.3 VMT per employee). The Project (the Master Plan Update) includes a goal of achieving a 50 percent alternative mode share for Campus arrivals by buildout. The updated Genentech TDM program continues those existing TDM strategies that Genentech provides, and includes a menu of additional strategies that Genentech may use to refine or add to the existing gRide program as may be needed to meet future demands and TDM commitments. In tandem with its TDM goal, the Project also provides a maximum development envelope (defined in terms of both maximum square feet of Genentech Campus Master Plan Update – CEQA Findings page 38 new building space and a “Trip Cap”) which governs the maximum amount of development which may occur within the Project area. To achieve this Trip Cap, the Project would implement TDM programs for all of its employees at levels that can reduce drive-alone trips such that the Trip Cap is not exceeded. It is estimated that the effectiveness of this TDM program will need to increase commensurate with new development, and will need to expand to at least an approximately 47% drive-alone trip reduction rate for Campus arrivals by the time of the 9 million square foot buildout. To achieve Genentech’s Trip Cap commitments, the TDM Program will continue those existing TDM strategies that Genentech currently provides, and may implement strategies from a menu of additional programs to refine or add to the existing gRide program. The TDM program will be operated to maintain the drive-alone trip reductions necessary to remain below the Trip Cap of 5,216 AM peak hour drive-alone trips, on a continuous basis throughout buildout. Both the Master Plan Update and the EIR’s MMRP include monitoring procedures to ensure that both the TDM performance rate and the Trip Cap are implemented over time. Taking into account the Project’s proposed TDM trip reductions (i.e., a 47 percent reduction in AM peak hour drive-alone trips to the Campus as necessary to maintain the Trip Cap), the Project would have calculated rates of 17.1 VMT per employee (year 2015) and 15.6 VMT per employee (year 2040), which are lower than the VMT target reduction thresholds of 15% below the regional average worker-based VMT for both year 2015 and year 2040. Thus, the Project’s transportation impacts assessed using VMT based thresholds of significance would be less than significant without mitigation. 86. Impact Transportation 2, Freeway Ramps (Existing plus Project): The Project would not result in conflicts with applicable plans, ordinances or policies that establish measures for effective levels of service at freeway ramp locations. Mitigation Measures None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Transportation 2): Consistent with C/CAG guidelines, the Project will implement a Transportation Demand Management (“TDM”) program that is consistent with, and exceeds City requirements. The TDM program will further reduce its contribution of trips on the CMP network, including its contributions of traffic to freeway ramps. The Project would not result in conflicts with applicable plans, ordinances or policies that establish measures for effective levels of service at freeway ramp locations, and this impact would be less than significant. 87. Impact Transportation 4, Roadway Design Hazard/Internal Vehicle Circulation (Existing plus Project; Cumulative plus Project): The Project’s on-site vehicle circulation system would not present a design hazard under Existing plus Project or Cumulative plus Project conditions. Mitigation Measures None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Transportation 4): Existing Project Area roadways provide sufficient vehicular circulation to serve the Project’s circulation needs and no additional streets or street improvements are necessary, and no design hazards would occur. The Project includes driveway and loading dock designs and parking location strategies that promote a safe internal pedestrian environment. With implementation Genentech Campus Master Plan Update – CEQA Findings page 39 of these Project designs and locational strategies, the Project’s on-site vehicular circulation system will not present a design hazard, and this impact would be less than significant. 88. Impact Transportation 5, Conflict with a Transit, Bicycle or Pedestrian System Program or Policy (Existing plus Project; Cumulative plus Project): The Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, bicycle and pedestrian facilities, under Existing plus Project and Cumulative plus Project conditions. Mitigation Measures None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Transportation 5): Pursuant to Section 20.260.006 of Chapter 20.260 of the South San Francisco Municipal Code, the Project is required to contribute to East of 101 transportation improvements in accordance with requirements of the East 101 Traffic Fee Program. Payment of this impact fee represents the Project’s fair-share contribution toward planned bicycle improvements that accommodate additional bicycle demand and reduce traffic impacts by paying for on- and off- site bicycle improvements designed to encourage bicycle use instead of car use. The Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, bicycle and pedestrian facilities, under Existing plus Project and Cumulative plus Project conditions, and this impact would be less than significant. P. UTILITIES 89. Impact Utilities 1, Water Supply (Project and Cumulative): New development pursuant to the Project would result in an estimated net new average daily water demand of approximately 295,000 gallons per day, for a total average daily water demand at buildout of approximately 1,135,000 gallons. This water demand is derived from Genentech’s 2016 CalWater utility bills, and considers all of the water conservation strategies and initiatives that Genentech currently implements throughout its Campus. The Project’s water demands would not exceed water supplies available to serve the Project, and there is sufficient water supplies to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. Regulatory Measures: Regulatory Requirement Utilities 1- CalGreen Water Conservation Standards: All new development pursuant to the Master Plan Update (the Project) are subject to the water conservation requirements of the 2016 California Green Building Standards Code, Nonresidential (CalGreen, 2016), or as may be amended. These requirements, as pertaining to water conservation, include: 1. Installation of separate sub-meters or metering devices for each individual leased, rented, or other tenant space within the building projected to consume more than 100 gal/day, including, but not limited to spaces used for laboratories, and for water supplied to sub-systems used for make-up water for cooling towers, evaporative coolers, and steam and hot-water boilers. The intent of this code requirement is to reduce potable water use in new or altered buildings by making building owners and/or tenants aware of their daily potable water consumption to encourage voluntary reduction. Genentech Campus Master Plan Update – CEQA Findings page 40 2. Installation of water conserving plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) that meet maximum allowable flow rates. The intent of this code regulation is to reduce the overall use of potable water within the building. 3. Compliance with mandatory Model Water Efficiency Landscape Ordinance (MWELO) measures for outdoor water use in landscape areas, or a local water efficient landscape ordinance that is at least as effective in conserving water. The intent of this code requirement is to reduce the overall outdoor water used for irrigation for both new landscaping areas and rehabilitated landscape projects. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Utilities 1): The CalWater SB 610 Water Supply Assessment included in the EIR as Appendix 18A indicated that the SSF District of Cal Water will be able to provide adequate water supplies to meet existing and projected customer demands, including full development of the Project, for normal water year conditions. During single dry year conditions, Cal Water may need to implement demand reduction measures on all customers including the Project, or, depending on when the next single dry year occurs, additional supply sources may have been developed and be available to offset any reductions in existing supply sources. For multiple dry year conditions, Cal Water will determine what additional demand reduction measures will be needed to reduce demand to match available supplies. This is expected to result in an adequate water supply for all three Cal Water Peninsula Districts for the years 2020 to 2040. Therefore, the impact (Project-specific and cumulative) would be less than significant. 90. Impact Utilities 2, Water Supply Infrastructure: Based on a programmatic and system-wide assessment of the Project Area’s water delivery system, the existing water system within the Project Area is capable of accommodating the Project’s increase in water demand. The looped water system within the Project Area is designed to convey fire flow requirements, which are substantially higher in terms of gallon per minute demands and velocities than the average domestic water demands associated with new buildings. Regulatory Requirements: Regulatory Requirements, General: As new development occurs within the Project Area, Cal Water will furnish and install any needed piping, meters and meter boxes necessary to provide service, and Genentech will be responsible for connecting new buildings to the Cal Water service connection. Cal Water will also ensure that all required water facilities are designed consistent with the proposed Project, and will coordinate with Genentech, the City of South San Francisco and the California Division of Drinking Water in the design, construction and operation of the proposed water distribution system. Water supply and pressure requirements for each new building will be established pursuant to applicable Fire Codes. Regulatory Requirement Utilities 2 – Water Service Connections: Genentech will be responsible for connecting new buildings pursuant to the Project to existing or new Cal Water service connections. All such water service connections will be required to adhere to applicable Code requirements, and these requirements will be incorporated into individual development project designs and construction. Mitigation Measures: Genentech Campus Master Plan Update – CEQA Findings page 41 None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Utilities 2): Adherence to applicable codes and regulatory measures would ensure less than significant impacts. These water service connections will occur within the street right-of-way and within individual development sites, and will not result in any unique or peculiar on-site or off-site environmental effects. 91. Impact Utilities 3, Exceedances of Wastewater Discharge Requirements (Project-specific and Cumulative): The cities of South San Francisco and San Bruno jointly own and operate the South San Francisco and San Bruno Water Quality Control Plant (WQCP) located in the East of 101 Area of South San Francisco, and its wastewater collection system. The WQCP provides secondary wastewater treatment for the cities of South San Francisco, San Bruno and Colma, along with the de-chlorination treatment of chlorinated effluent for the cities of Burlingame, Millbrae and the San Francisco International Airport, prior to discharging the treated wastewater into San Francisco Bay. Discharges from the WQCP have the potential to violate wastewater treatment requirements of the applicable NPDES permit if the treatment system is not able to adequately remove pollutants contained in the discharge, or if pollutants damage or disrupt operations of the WQCP. Industrial discharges to publicly operated treatment plants have historically been a significant source of pollutants, and certain industrial discharges can interfere with operation of the WQCP, leading to the discharge of untreated or inadequately treated wastewater into the Bay. Some pollutants are not compatible with biological wastewater treatment, and may pass through the treatment plant untreated. The pass-through of such pollutants could adversely affect the surrounding environment. Regulatory Requirements Regulatory Requirements, General: The State Water Resources Control Board (SWRCB) requires all public wastewater collection systems agencies in California with greater than one mile of sewers (including the WQCP) to be regulated under the Statewide General Waste Discharge Requirements (WDR). Additionally, the discharge of treated effluent from the WQCP to the San Francisco Bay is subject to further waste discharge requirements as set forth by the California Regional Water Quality Control Board, San Francisco Bay Region (RWQCB) through a National Pollutant Discharge Elimination System (NPDES) permit. The SSF WQCP operates pursuant to a Sewer System Management Plan (SSMP), which demonstrates that its operations meet the requirements of both the RWQCB and WDR). The SSMP sets forth requirements for direct and indirect contributors to the WQCP, established through waste discharge permits, that enable compliance with all applicable State of California laws and federal laws required by the Clean Water Act, and General Pretreatment Regulations (40 CRF, Part 403). It is unlawful to discharge wastewater into the WQCP system without such a permit. New development pursuant to the Project may include wastewater-generating industrial uses that will need to be individually assessed for appropriate waste discharge permits and pollutant reduction plans to ensure compliance with waste discharge requirements. Regulatory Requirement Utilities 3 - Wastewater Discharge Permit: New development pursuant to the Project will be required to obtain a wastewater discharge permit from the Environmental Compliance Supervisor of the City of South San Francisco. Each new project shall comply with all requirements or limitations of that permit as cited in the City's Wastewater Discharge Ordinance, Municipal Code, Environmental Compliance Program or any applicable State and federal laws. New development projects pursuant to the Project will be classified as institutional, commercial, or industrial users, depending on the types of discharge from the facility. New industrial uses will be further classified as either Categorical Industrial User (an Genentech Campus Master Plan Update – CEQA Findings page 42 industrial user subject to categorical pretreatment standards or categorical standards), or as a Significant Industrial User (designated as such because the industrial use has a reasonable potential for adversely affecting operation of the treatment plant or to violate pretreatment standard or requirements). 1. New uses designated by the City of South San Francisco as Categorical Industrial Users will be required to develop and implement a plan designed to reduce the amount of pollutants of concern (copper, cyanide, selenium, mercury, perchloroethylene and tributyltin) discharged into the sanitary and the storm water sewer systems. Certain industrial uses within the Project Area may also require a pH neutralization system for pretreatment of industrial process wastewater discharge. 2. New uses designated by the City of South San Francisco as Significant Industrial Users will be subject to additional requirements or limitations as may be cited in the City's Wastewater Discharge Ordinance, Municipal Code, Environmental Compliance Program or any applicable State and federal Laws. Effluent sampling and monitoring is required to verify compliance with applicable regulations and limitations. Mitigation Measures: None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Utilities 3:): Obtaining required regulatory permits, implementing any required pollutant reduction plans and/or pH neutralization system, and compliance with any additional requirements or limitations (including sampling and monitoring) as may be required for new Significant Industrial User discharge permits will reduce impacts related to exceeding the wastewater treatment requirements of the RWQCB to less than significant levels on a Project-specific and cumulative basis. 92. Impact Utilities 4, Wastewater Treatment and Disposal Capacity (Project-specific and Cumulative): New development pursuant to the Project is conservatively estimated to generate net new wastewater flows of approximately 0.294 mgd. Added to baseline wastewater flows from the Genentech Campus of approximately 0.774 mgd, the total wastewater flows generated at buildout of the Project Area would amount to approximately 1.07 mgd. According to the City of South San Francisco’s Water Quality Control Plant Facility Plan of April of 2011, the dry weather flow capacity of the WQCP has a remaining treatment and disposal capacity of approximately 4 mgd. The Project’s estimated net new wastewater flows of approximately 0.3 mgd would not result in exceeding currently available treatment capacity at the WQCP, nor disposal capacity at the NBSU outfall. Regulatory Requirements: Regulatory Requirement Utilities 4 - East of 101 Sewer Fees: New development within the Project Area will contribute to East of 101 sewer improvements in accordance with existing requirements of the East of 101 Sewer Fee contribution formula, established by Resolution 97- 2002 (or as that resolution may be amended). These fees represent “fair-share” payments towards the availability of sewer collection, treatment and disposal capacity for the Project, and apply to all discretionary land use approvals, including Administrative Review, Minor Use Permits and Conditional Use Permits. Mitigation Measures: Genentech Campus Master Plan Update – CEQA Findings page 43 None required. Finding of Less Than Significant Impact Without Mitigation Measures (Impact Utilities 4): The Project will be required (see Regulatory Requirement Utilities 3 - Wastewater Discharge Permit) to obtain appropriate wastewater discharge permits and comply with limitations of those permit designed to ensure compliance with the NBSU effluent and receiving water limitations of the RWQCB NBSU permit. The WQCP has adequate capacity to absorb the additional wastewater treatment and disposal demands generated by the Project, in addition to other projected cumulative wastewater flows. The Project’s impact on wastewater treatment and disposal capacity, including compliance with waste discharge requirements, would be less than significant. X. FINDINGS FOR IMPACTS THAT CAN BE REDUCED TO LESS THAN SIGNIFICANT LEVELS WITH MITIGATION MEASURES 93. The EIR determined that the Project has potentially significant environmental impacts in the areas discussed below. The EIR identified feasible mitigation measures and/or applicable regulatory requirements that would avoid or substantially reduce some or all of the environmental impacts in these areas. Based on the information and analyses set forth in the EIR and the entirety of the Record before it, including without limitation the Mitigation Monitoring and Reporting Program (“MMRP”), the City finds that for each of the following Project impacts, changes or alterations have been required in, or incorporated into the Project, which mitigate or avoid the significant effects on the environment. As described in further detail below and in the EIR, the following impacts will be less than significant with identified feasible mitigation measures and/or compliance with applicable regulatory requirements. 94. Pursuant to CEQA Guidelines § 15091, the following mitigation measures have also been included in the MMRP that is to be adopted concurrently with these Findings. A. AESTHETICS 95. Impact Aesthetics 4, Light and Glare: New development pursuant to the Project could result in new sources of increased daytime glare and nighttime illumination. Implementation of the Project will include construction of new buildings throughout the Project Area, and these new buildings could create new sources of glare from reflective building surfaces. If new buildings were to be constructed with reflective materials, glare from these new buildings could adversely affect views. Mitigation Measures and Regulatory Requirements: Regulatory Requirement Aesthetics 4 – Design Review for Light and Glare: Consistent with South San Francisco Municipal Code, section 20.480.006, new development pursuant to the Master Plan Update will be required to comply with the following design considerations relative to light and glare (underline added): 1. Open space, pedestrian walks, signs, illumination, and landscaping (including irrigation) shall be designed and developed to enhance the environmental quality of the site, achieve a safe, efficient, and harmonious development, and accomplish the objectives set forth in the precise plan of design and design criteria (Municipal Code section 20.480.006.6) 2. Electrical and mechanical equipment or works, and fixtures and trash storage areas, shall be designed and constructed so as not to detract from the environmental quality of the site. Genentech Campus Master Plan Update – CEQA Findings page 44 Electrical and mechanical equipment or works and fixtures and trash storage areas shall be concealed by an appropriate architectural structure that uses colors and materials harmonious with the principal structure, unless a reasonable alternative is identified (Municipal Code section 20.480.006.7) 3. Components considered in design review shall include but not be limited to exterior design, materials, textures, colors, means of illumination, landscaping, irrigation, height, shadow patterns, parking, access, security, safety, and other usual on-site development elements (Municipal Code section 20.480.006.8) Mitigation Measure Aesthetics 4A - Night Lighting: Maintain appropriate levels of night lighting at building entries, walkways, courtyards, parking lots and private roads, consistent with minimum levels detailed in Genentech’s Security Plan and City building codes. Mitigation Measure Aesthetics 4B - Non-Reflective Glass and Surfaces: Design for new structures within the Project Area shall include the use of textured or other non-reflective exterior surfaces and non-reflective glass types, including double-glazed and non-reflective vision glass, while achieving the requisite performance for energy conservation, internal comfort and glare control. All exterior glass must meet the specifications of all applicable building codes Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Aesthetics 4): Implementation of Mitigation Measure Aesthetics 4A would reduce impacts from nighttime lighting by maintaining appropriate light levels and reducing potential light spillage beyond areas where light is needed for security and safety. Implementation of Mitigation Measure Aesthetics 4B would eliminate or minimize increased glare through use of non-reflective glass and non-reflective textured surfaces. With implementation of these mitigation measures, as demonstrated through compliance with Regulatory Requirement Aesthetics 4 – Design Review for Light and Glare, impacts related to light and glare would be reduced to levels of less than significant. B. AIR QUALITY 96. Impact Air Quality 2, Construction-Period Emissions of Criteria Pollutants (Project-specific and Cumulative): Throughout buildout of the Project, construction activities would result in emissions of criteria pollutants for which the region is non-attainment, including releasing emissions of ozone precursors and particulates. Mitigation Measures: Mitigation Measure Air Quality 2, Best Management Practices: Consistent with BAAQMD recommendations, the following BMPs shall be implemented by all construction projects, regardless of itemized construction emission levels: a) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. b) All haul trucks transporting soil, sand, or other loose material off-site shall be covered. c) All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. d) All vehicle speeds on unpaved roads shall be limited to 15 mph. Genentech Campus Master Plan Update – CEQA Findings page 45 e) All roadways, driveways and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. f) Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. g) All construction equipment shall be maintained and tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. h) Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations. Mitigation Measure/Recommendation AQ 2: Project-Specific Construction Emission Analysis: A project-specific construction emissions analysis is required for all projects that exceed the assumptions of this analysis, including: a) Annual construction exceeding 215,000 square feet a year b) Construction projects that individually exceed 227,000 square feet in size (the lower of BAAQMD screening sizes for either office parks or industrial parks) c) two or more simultaneously occurring construction projects would exceed this screening size, or construction projects include more than two simultaneously occurring construction phases d) Construction projects that would include demolition, that would involve extensive site preparation (i.e., greater than default assumptions used by the URBEMIS model), or that involve extensive material transport (in amounts greater than 10,000 cubic yards of soil import/export) e) If a project-specific emission analysis exceeds the per-day construction emissions thresholds presented in Table 6-2 of the EIR, then a demonstration of consistency with the results of Mitigation Measure AQ-3 would also be required. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Air Quality 2); With implementation of Basic Best Management Practices (BMPs) for all construction projects, construction emissions would be unlikely to exceed applicable thresholds, and construction-period criteria pollutant emission would be reduced to levels of less than significant. For any construction project that exceeds the assumptions of the EIR analysis as outlined in Recommendation AQ 2, a project-specific construction emissions analysis is required, demonstrating that construction-period emission of criteria pollutant would be reduce to below threshold levels. All construction-period emissions would combine with emissions from other cumulative construction project and other cumulative operational emissions to affect regional air quality. With implementation of Basic BMPs at all of the Project’s construction activities and additional BMPs for those construction projects that exceed screening criteria, the Project’s construction emissions would be unlikely to exceed applicable thresholds, and thus not considered cumulatively significant. Genentech Campus Master Plan Update – CEQA Findings page 46 97. Impact Air Quality 3, Construction-Period Health Risk: During construction activities, the Project could expose sensitive receptors to substantial pollutant concentrations from construction-related emissions. Specifically, the Project’s construction emissions could cause an excess cancer risk level exceeding 10 in one million at the maximally exposed sensitive receptor. Mitigation Measures: Mitigation Measure AQ 3 - Diesel Particulate Filters: Construction activity that occurs in proximity to the Genentech daycare center or the Early Years preschool on Allerton Avenue (as indicated in Figure 6-3 of the EIR) shall use off-road construction equipment installed with diesel particulate filters capable of reducing PM10 and PM2.5 emissions by as much as 85%. Finding of Less Than Significant Impact With Mitigation Measures (Impact Air Quality 3): If all construction activity that occurs in proximity to the Genentech daycare center or the Early Years preschool on Allerton Avenue uses off-road equipment installed with diesel particulate engines as defined in Mitigation Measure AQ 3, construction activities occurring throughout the entire Project Area would not exceed any health risk-based thresholds, and health-related impacts caused by substantial pollutant concentrations from construction-related emissions would be reduced to a level of less than significant. 98. Impact Air Quality 5, Operational Health Risks: During operational activities, the Project could expose sensitive receptors to substantial health risks from operational-related emissions if operational sources of TAC emissions are not limited in location and operational parameters. Sensitive receptors evaluated include daycare receptors, residential receptors to the north (houseboats in the Oyster Point Marina) and recreational receptors on the San Francisco Bay Trail. A significant air quality impact is defined as exposing sensitive receptors to substantial pollutant concentrations, expressed as excess cancer risk exceeding 10 in 1 million, hazard index greater than 1.0 or annual PM2.5 concentrations that exceed 0.3 µg/m3 at sensitive receptor locations. Mitigation Measures: Mitigation Measure AQ 5A - Parameters for Operational Emissions: New operational sources of TAC emissions (i.e., emergency generators, laboratories with emissions stacks, or natural gas combustion at the Miura boilers or potential CHP) shall operate within the operational parameters as used in the EIR analysis (as shown in EIR Table 6-9). For any operational source of TAC emissions that does not operate within these parameters, a subsequent, project-specific health risk analysis shall be performed. Any such subsequent, project-specific health risk analysis must be able to demonstrate that the proposed operational source of TAC emissions would not contribute to new or substantially more significant health risks to sensitive receptors than those health risks presented in this EIR. This conclusion may account for any additional project-specific measures to reduce TAC emissions included as part of such an emission source. Mitigation Measure AQ 5B - Locational Restrictions on Future Operational Emission Sources: Emergency generators and laboratories with emissions stacks shall be limited to those locations as shown on EIR Figure 6-5 (for laboratories) or Figure 6-6 (for emergency generators), where their operations have been demonstrated to not exceed health risk thresholds. For any operational source of TAC emissions that are located outside of these locations, a subsequent project-specific health risk analysis shall be performed. Any such subsequent, project-specific health risk analysis must be able to demonstrate that the proposed location would not contribute to new or substantially more significant health risks to sensitive receptors than those health risks presented in this EIR. This conclusion may account for any additional project-specific measures to reduce TAC emissions included as part of such an emission source. Genentech Campus Master Plan Update – CEQA Findings page 47 Finding of Less Than Significant Impact With Mitigation Measures (Impact Air Quality 5): Operational source of TAC emission that operate within the emission parameters used in the EIR analysis can be located on any of those Opportunity Sites shown on EIR Figures 6-5 and 6-6 without contributing to operational-period health risks. Individual projects that include new sources of operational TAC emissions that would operate outside of the operational parameters used in this EIR may only be initiated after preparation of a subsequent project-specific health risk analysis which demonstrates that such projects do not contribute to a new or more significant health risk to sensitive receptors. Individual projects that include new operational sources of TAC emissions and that are sited at locations shown on EIR Figure 6-5 or Figure 6-6 as potentially contributing to operational-period health risks may only be initiated after preparation of a subsequent project-specific health risk analysis which demonstrates that such projects do not contribute to a new or more significant health risk to sensitive receptors. Health risk impacts resulting from emission sources at these locations would also be less than significant, pending affirmative conclusions of subsequent project-specific health risk analyses. C. BIOLOGICAL RESOURCES 99. Impact Biology 2: California Ridgway’s Rail: The Project may cause a substantial adverse effect, both directly and through habitat modification, on California Ridgway’s rail (federally and state listed as endangered and designated as a state fully protected species). The tidal salt marshes/coastal salt marshes within the Biology Study Area for this EIR are extremely limited in extent and are highly disturbed. The salt marsh in the northerly portion of the Study Area is small, highly disturbed and isolated, and it is unlikely that rails would nest or forage there. However, there is some (albeit low) potential for individuals to forage in the tidal wetland/coastal salt marsh along the southeastern edge of the Study Area at San Bruno Channel, and it is possible that a pair of California Ridgeway Rails could breed in this marsh. Mitigation Measures and Regulatory Requirements: The CDFW has jurisdiction over the California Ridgway’s rail under the State ESA. Therefore, the CDFW will require that avoidance measures be implemented to avoid take of individual California Ridgway’s Rails. The following mitigation measures shall be implemented, consistent with CDFW requirements, to avoid take of individual California Ridgway’s rails. Mitigation Measure Bio 2A - Seasonal Avoidance: To avoid causing the abandonment of an active California Ridgway’s rail nest, construction activities within 750 feet of the coastal salt marsh habitat in the southeastern corner of the site (see prior Figure 7-9) shall be avoided during the rail breeding season (from February 1 through August 31). If avoidance is not possible, protocol-level surveys (see Mitigation Measure Bio 2, below) shall be conducted by a qualified biologist to determine rail locations and territories. Mitigation Measure Bio 2B - Protocol-Level Surveys and Buffers around Calling Centers: Prior to any construction activity near the coastal salt marsh along the southeastern edge of the biological Study Area, a protocol-level survey, which involves a series of site visits between mid- January (beginning no later than January 31) and late March, shall be conducted by a qualified biologist. The survey needs to be approved by the USFWS and CDFW in advance. If breeding rails are determined to be present, construction activities shall not occur within 750 feet of an identified calling center during the breeding season. Mitigation Measure Bio 2C - Initiate Work during the Non-Breeding Season: Regular, ongoing disturbance within a work area that begins prior to the start of the nesting season or nest Genentech Campus Master Plan Update – CEQA Findings page 48 establishment in an area may deter California Ridgway’s rails from nesting near construction activities. If construction activities need to occur within 750 feet of suitable California Ridgway’s rail nesting habitat, such activities shall be initiated and shall reach peak levels of disturbance prior to the onset of the nesting season. Peak levels of disturbance is defined as construction noise in the vicinity of the suitable habitat reaching maximum levels, and construction activities that occur as near to the suitable habitat as required for the project. If an active nest is identified subsequent to construction activities reaching a peak level of disturbance, a buffer of 750 feet shall be established between Project activities and the nest. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Biology 2): Implementation of Mitigation Measures Bio 2A through 2C above would avoid take of individuals as is required by the CDFW due to this species’ designation as fully protected, would avoid impacts to nesting pairs, and Project activities will not adversely affect this species’ potential habitat. Therefore, impacts on the California Ridgway’s rail will be reduced to a level of less than significant. 100. Impact Biology 4, San Francisco Common Yellowthroat, Alameda Song Sparrow and other Native Nesting Birds: The Project may cause a substantial adverse effect, either directly or through habitat modification, on Alameda song sparrow, San Francisco common yellowthroat (both California species of special concern) and other native bird species protected by the MBTA and California Fish and Game Code. Project construction activities that occur during the nesting season (February 1 through August 31) could result in the incidental loss of eggs or nestlings, either through destruction or disturbance of active nests, or indirectly by causing the abandonment of nests. This is considered a potentially significant impact. Mitigation Measures and Regulatory Requirements: The Alameda song sparrow, San Francisco common yellowthroat and other native birds are protected under the federal MBTA and Sections 3503 and 3800 of the California Fish and Game Code. The Project will be required to implement measures to ensure that Project activities comply with the MBTA and California Fish and Game Code. Therefore, the following avoidance mitigation measures shall be implemented, consistent with the MBTA and California Fish and Game Code: Mitigation Measure Bio 4A - Seasonal Avoidance: To the extent feasible, construction activities should be scheduled to avoid the nesting season. If construction activities are scheduled to take place outside the nesting season, all impacts on nesting birds protected under the MBTA and California Fish and Game Code will be avoided. The nesting season for most birds in San Mateo County extends from February 1 through August 31. Mitigation Measure Bio 4B - Pre-construction/Pre-disturbance Surveys: If it is not possible to schedule construction activities between September 1 and January 31, then a pre-construction survey for nesting birds shall be conducted by a qualified ornithologist to ensure that no nests will be disturbed during Project implementation. These surveys should be conducted no more than seven days prior to the initiation of any construction activities. During this survey, the ornithologist shall inspect all trees and other potential nesting habitats (e.g., trees, shrubs, ruderal grasslands, buildings) in and immediately adjacent to the impact area, as well as a construction zone of up to 300 feet from the edge of the construction zone into the southerly coastal salt marsh habitat (if applicable), for nests. Mitigation Measure Bio 4C - Buffers: If an active nest is found sufficiently close to work areas such that it would be disturbed by construction activities, the ornithologist shall determine the Genentech Campus Master Plan Update – CEQA Findings page 49 extent of a construction-free buffer zone to be established around the nest (typically 300 feet for raptors and 100 feet for other species). Any active nests shall be monitored by the ornithologists to determine when the young fledge, and construction within the buffer zone can resume. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Biology 4): Based on the limited extent and low quality of habitat conditions observed, as well as the Project’s avoidance of wetland habitats, Project development activities are expected to have only limited impacts on a small number of individuals of these species, and would not result in a substantial impact on regional populations. Implementation of Mitigation Measures 4A through 4C would ensure compliance with the MBTA and California and Fish and Game Code, and reduce potential impacts to a level considered less than significant. 101. Impact Biology 7, Invasive Species: The Project could potentially result in adverse effects on coastal salt marsh and other sensitive habitat due to the spread of invasive and non-native plant species. Mitigation Measures: Mitigation Measure Bio 7 - Invasive Weed Control: Prior to ground disturbing activities, the Project work areas shall be surveyed by a qualified biologist/botanist for the presence of pampas grass, fennel and other highly invasive plant species from the California Invasive Plant Council list. a) Any invasive plants found within the area that is to be disturbed by development shall be removed and disposed of in a sanitary landfill. Alternatively, invasive plants may be disposed of in a high-temperature composting facility that can compost using methods known to kill weed seeds, taking care to prevent any seed dispersal during the process by bagging material or covering trucks transporting such material from the site. b) Cut soils from areas infested by weeds such as pampas grass and fennel that will be reused as fill elsewhere in the Project Area will be buried under hardscape or placed in areas to be managed with landscaping. c) During construction activities, all seeds and straw materials used on site shall be weed-free, and all gravel and fill material shall be certified weed-free. d) Construction vehicles and all equipment will be washed (including wheels, undercarriages and bumpers) before entering the Project Area. Vehicles will be cleaned at existing construction yards or car washes. Genentech will document that all vehicles have been washed prior to commencing work. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Biology 7): Implementation of Mitigation Measure Bio 7 will control the spread of invasive and non-native plant species and will reduce impacts from invasive weeds to a less than significant level through the proper disposal or removal of invasive plans, weed management, and proper equipment washing and cleaning. 102. Impact Biology 9, Wetlands and Other Waters: The Project would not result in either temporary or permanent loss of wetland habitats, as these areas are not identified in Opportunity Sites for new development. However, tidal aquatic and wetland habitats may be indirectly affected due to increased hardscape in upland habitats that can lead to an increase in runoff, a decrease in Genentech Campus Master Plan Update – CEQA Findings page 50 infiltration and groundwater recharge, and possible introduction of anthropogenic contaminants. Project-related construction activities such as grading, paving, vegetation removal and other soil disturbances can increase the potential for soil erosion. The on-site drainage ditches are unlikely to be claimed as waters of the U.S. by the US Army Corps of Engineers under Section 404 or 401 of the Clean Water Act, or to constitute waters of the State pursuant to Section 1600 of the California Fish and Game Code. Mitigation Measures and Regulatory Requirements: Whereas the EIR consulting biologist’s opinion is that the on-site drainage ditches do not constitute waters of the State and are unlikely to be claimed as waters of the U.S. by the US Army Corps of Engineers, this determination will ultimately need to be made by the USACE and/or the RWQCB. The following mitigation measure clarifies the requirement for verification of wetlands delineations for these on-site drainage ditches. Mitigation Measure Bio 9 – Drainage Channel Wetland Delineation: Although drainage channels within the site lack many of the habitat features usually present in jurisdictional waters of the U.S. or the State, there is some possibility these drainage ditches may be claimed as jurisdictional. Prior to any proposed fill or material alteration of on-site drainage ditches (those indicated on prior Figure 7-8), a preliminary wetlands delineation based on the criteria of most current Corps of Engineers Wetlands Delineation Manual and any regional supplements shall be conducted and submitted to USACE and RWQCB prior to issuance of any grading permits. a) Presuming these preliminary wetland delineations find the on-site drainage ditches are not Waters of the US or of the State, and that these delineations are accepted by the respective permitting agencies, then no further federal wetlands permitting is required. b) If the USACE and/or the RWQCB claim jurisdiction of these features, any alteration of the drainage ditches would require applicable permits and compliance with all standards and requirements of such permits. c) The RWQCB is likely to consider these drainage ditches as required parts of the overall Campus’ Stormwater Management Plan, and pursuant to subsequent Statewide General Construction Permits will likely require that the storm drainage functions of these features be replaced if they are affected. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Biology 9): Potential biological effects on drainage ditches, should they be claimed as jurisdictional waters by either the USACE or the RWQCB (which is considered to be not likely), would be reduced to a level of less than significant through implementation of regulatory requirements of these respective agencies, if found applicable pursuant to subsequent preliminary wetland delineations. 103. Cumulative Biological Resource Effects: The Project will not result in a cumulatively considerable contribution to significant cumulative impacts on biological resources. Finding of Less Than Significant Cumulative Impact With Mitigation Measures and Regulatory Requirements (Biological Resource): Biological resource impacts are largely location-specific and dependent on site-specific habitat. With implementation of applicable regulatory requirements and appropriate mitigation measures, cumulative impacts to biological resources would be less than significant, and the Project would not result in a cumulatively considerable contribution to a significant cumulative biological resources impact. Genentech Campus Master Plan Update – CEQA Findings page 51 D. CULTURAL AND HISTORIC RESOURCES 104. Impact Cultural 3, Archaeological Resources: During ground disturbing activities associated within the Project Area, it is possible that currently unidentified historic-period archaeological resources could be discovered and disturbed. Given the extent of historic-era development during the late 1800s and early 1900s in the Project Area (including paint manufacturing, meat packing plants and other industrial development), there is a high potential for unrecorded archaeological resources associated with these industrial periods to be present within the Project Area. Construction associated with the Project could result in ground disturbance associated with grading, excavating and trenching, which could damage or destroy previously unidentified, significant archaeological resources, and may uncover previously unknown and buried human remains. Mitigation Measures: Mitigation Measure Cultural 3A - Cultural Resources Worker Environmental Awareness Program (WEAP): A qualified archaeologist should conduct a WEAP training for all construction personnel prior to Project-related construction and ground-disturbing activities. The training should include basic information about the types of artifacts that might be encountered during construction activities, and procedures to follow in the event of a discovery. Mitigation Measure Cultural 3B - Halt Construction Activity, Evaluate Find and Implement Mitigation: In the unlikely event of discovery of paleontological or historical archaeological resources during site preparation, excavation or other construction activity, all such activity within 25 feet of the discovery shall cease until the resources have been evaluated by a qualified professional. Historic-period archaeological resources may include stone or adobe foundations or walls, structures and remains with square nails, and refuse deposits or bottle dumps. a) If the qualified archaeologist determines the find is not significant and that there is no potential for the find to be a tribal cultural resource, then proper recordation and identification will ensue, and the project construction activity may continue without further delay. b) If the qualified archaeologist determines the find may potentially be a tribal cultural resource, a tribal representative shall be consulted to determine whether it is in fact a tribal cultural resource (see MM Cultural 4B, below). c) If the qualified archaeologist determines an archaeological find is significant, then the archaeologist will excavate the find in compliance with state law and keeping project delays to a minimum, and shall implement specific mitigation measures to protect these resources in accordance with sections 21083.2 and 21084.1 of the California Public Resources Code. d) If it is determined that avoidance of the resource is not feasible, then a mitigation plan (including monitoring and data recovery) shall be prepared, with specific steps and timeframe identified. Work near the find may only resume upon completion of a mitigation plan or recovery of the resource. Mitigation Measure Cultural 3C - In the Event of Discovery of Human Remains: In the event of a discovery of buried human remains or suspected human remains, all construction activity within 50 feet shall cease until the remains have been evaluated by the County Coroner. a) If the County Coroner determines that an investigation into the cause of death is required, or that the remains are Native American, all work shall cease within 50 feet of the remains until appropriate arrangements are made. Genentech Campus Master Plan Update – CEQA Findings page 52 b) In the event that the remains are Native American, the City shall contact the California Native American Heritage Commission (NAHC), pursuant to subdivision (c) of section 7050.5 of the California Health and Safety Code to identify the Most Likely Descendant. The Most Likely Descendant shall be consulted as to means for treating or re-interring the human remains and any associated grave goods, with appropriate dignity. Finding of Less Than Significant Impact With Mitigation Measures (Impact Cultural 3): In conjunction with regulatory requirements for discoveries of archaeological resources, implementation of Mitigation Measures Cultural 3A through 3C will reduce the impacts associated with possible disturbance or discovery of archaeological resources or unidentified human remains to a level of less than significant through implementation of training programs, monitoring, avoidance, consultation, and recommended treatment measures. 105. Impact Cultural 4, Tribal Cultural Resources: During ground disturbing activities associated within the Project Area, it is possible that currently unidentified or non-located tribal cultural resources could be discovered and disturbed. The Project Area lies within an area once occupied by the Costanoan, or Ohlone group of Native Americans. Previously discovered tribal resources in this area of San Mateo County tend to be situated near the historic margin of Bay, in tidal marshland and along creeks that drain upland terrain bordering the Bayshore plain. Similar conditions are found within the Project Area in the South and Lower Campuses. Based on an evaluation of the environmental setting and a review of features associated with known tribal resource discovery sites, there is high possibility that unrecorded tribal cultural resources exist in the Project Area, and may be discovered during Project-related construction activities in these areas. Mitigation Measures: Mitigation Measure Cultural 3A - Cultural Resources Worker Environmental Awareness Program (see details above). Mitigation Measure Cultural 3B - Halt Construction Activity, Evaluate Find and Implement Mitigation (see details above). Mitigation Measure Cultural 3C - In the Event of Discovery of Human Remains (see details above). Mitigation Measure Cultural 4A - Cultural Resources Monitoring: A qualified archaeologist shall monitor all construction-related activity expected to involve excavating, drilling or trenching at depths that may reach native sediment in those areas where tribal cultural resources are likely present (i.e., along the Project’s shoreline areas within the South and Lower Campus). Monitoring will continue for the duration of such activity or until culturally sterile sediments are reached (e.g., bedrock). The qualified archaeologist may determine to decrease or increase the monitoring efforts based on sediments observed, findings or the number of large ground- disturbing machines in operation. Mitigation Measure Cultural 4B - In the Event of Discovery of a Tribal Resource: If a Tribal cultural resource is uncovered during construction, work should be halted within 25 feet of the discovered materials and workers shall avoid altering the materials and their context until a qualified professional archaeologist has evaluated the situation and provided appropriate recommendations. Project personnel should not collect cultural resources. Native American resources include chert or obsidian flakes, projectile points, mortars, and pestles; and dark friable soil containing shell and bone dietary debris, heat-affected rock, or human burials. A tribal representative shall be consulted to determine an appropriate mitigation plan (including Genentech Campus Master Plan Update – CEQA Findings page 53 monitoring and data recovery), with specific steps and timeframe to be stipulated. Work near the found tribal cultural resource may only resume upon completion of a mitigation plan and/or recovery of the tribal cultural resource. Finding of Less Than Significant Impact With Mitigation Measures (Impact Cultural 4): In conjunction with the regulatory requirements for discoveries of archaeological resources, implementation of Mitigation Measures Cultural 3A through 3CE and Mitigation Measures 4A and 4B will reduce the impacts associated with possible disturbance or discovery of tribal cultural resources to a level of less than significant through implementation of training programs, monitoring, avoidance, consultation, and recommended treatment measures. 106. Cumulative Cultural Resource Effects: The Project, in combination with other past, present and future reasonably foreseeable projects could result in cumulatively significant cumulative impacts on archaeological and/or tribal cultural resources. Finding of Less Than Significant Impact With Mitigation Measures or Regulatory Requirements (Cumulative Cultural Impacts): Compliance with regulatory requirements and mitigation measures identified for the Project would ensure the Project would not make a cumulatively considerable contribution to cumulative cultural resource impacts. The Project will have no impact on historic architectural resources or paleontological resources, and thus will not contribute to cumulative effects on such resources. With implementation of applicable regulatory requirements and mitigation measures, the Project in combination with other past, present, and future reasonably foreseeable projects would not result in significant cumulative impacts on archaeological or tribal cultural resources, and the Project would not make a cumulatively considerable contribution to significant cumulative cultural resource impacts. E. GEOLOGY AND SOILS 107. Impact Geology 2, Landslides: Most future development pursuant to the Project would not expose people and structures to potentially substantial adverse effects resulting from landslides. However, future development on steep hillside sites could pose increased risks of slope instability and landslide potential. New development may occur on Opportunity Sites that are located along the base of the existing steep hillsides may require deep cuts into the hillside, potentially exacerbating slope failure and/or resulting in landslide conditions if not conducted in a safe manner and consistent with applicable excavation design and slope stability standards. Impacts related to the risk of landslides and slope instability on these identified hillside Opportunity Sites pursuant to the Project is considered potentially significant. Mitigation Measures and Regulatory Requirements: Regulatory Requirements, General: All new development pursuant to the Project on non-steep Hillside Opportunity sites will be required to comply with applicable regulatory requirements for slope stability and landslide prevention. These requirements include, but are not limited to the California Seismic Hazards Mapping Act, which enables the City of South San Francisco to withhold development permits until geologic or soils investigations are conducted for specific sites and mitigation measures are incorporated into plans to reduce hazards associated with seismically induced landslides and slope instability. All new development pursuant to the Project on non-step Hillside Opportunity Sites will also be required to adhere to policies of the East of 101 Area Plan Geotechnical Safety Element, which sets forth policies and specific guidelines pertaining to site development and building design applicable to the unique geological hazards in the East of 101 Area. Genentech Campus Master Plan Update – CEQA Findings page 54 Regulatory Requirement Geology 2 – Landslide Hazards: Pursuant to regulatory requirements, Genentech will be required to retain a certified licensed geotechnical engineer to prepare site- specific geotechnical studies for each new development project pursuant to the Project. 1. Required geotechnical studies shall include site-specific geotechnical recommendations demonstrating compliance with all applicable excavation design and slope stability standards. The East of 101 Area Plan Geotechnical Safety Element policies (specifically Policy Geo-7 through Geo-9) are designed specifically to mitigate impacts associated with landsliding and unstable slope conditions. 2. Recommendations shall be incorporated into individual development project designs and construction, providing an acceptable level of protection against landslide hazards. Mitigation Measure Geology 2 - Geotechnical Requirements for Hillside Opportunity Sites: Site- specific geotechnical studies required for each new development at hillside Opportunity Sites (sites with slopes of 30 percent or greater) shall including site-specific geotechnical recommendations to address the stability of existing and proposed slopes, as well as the stability of all proposed excavations. These investigations and recommendations may include, but are not limited to the following: a) A geologic evaluation of the bedding properties of the underlying bedrock to determine if joints or fractures may project out of the proposed excavation during construction b) Recommendations for appropriate shoring systems to be used when making vertical cuts, including evaluation of the stability of the excavation as well as job-site safety considerations c) Evaluation of the drainage and infiltration properties of the existing slope bank d) Installation of horizontal drains to remove seepage e) Construction of a buttress wall at the base of the slope to reduce the risk of damage in the case of an accidental slope failure Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Geology 2): Continued adherence to the City’s codes and policies would ensure the maximum practicable protection available to minimize the risks associated with landsliding at those Opportunity Sites not located on steep hillsides. These codes and policies reduce potential impacts at non-hillside sites to a level of less than significant. Compliance with applicable state and local regulations, and implementation of additional site-specific mitigation measures to be implemented at steeply sloped hillside Opportunity Sites would minimize the risk of landslide and slope failure, and potential impacts would be reduced to a less than significant level. 108. Cumulative Geologic Effects: The geographic context for the analysis of impacts resulting from geologic hazards is generally site-specific rather than cumulative in nature. Each development site has a different set of geologic considerations that would be subject to specific site development and construction standards. As such, the potential for cumulative geologic impacts to occur is limited. Finding of Less Than Cumulatively Significant Impact With Mitigation Measures and Regulatory Requirements (Cumulative Geology Effect): All cumulative development is required to be constructed in conformance with the provisions of applicable federal, State, county and city laws and ordinances, including but limited to the California Building Code, the East of 101 Area Plan Geotechnical Safety Element, and City building codes. With adherence to all relevant Genentech Campus Master Plan Update – CEQA Findings page 55 plans, codes and regulations pertaining to building design and construction, cumulative development would provide adequate levels of safety, cumulative geologic impacts would be less than significant, and the Project would not present a cumulatively considerable contribution to cumulative geologic impacts. F. HAZARDS AND HAZARDOUS MATERIALS 109. Impact Hazards 4, Construction-Related Hazardous Materials: New construction activities pursuant to the Project could expose construction workers or Genentech employees to a significant hazard through the renovation or demolition of buildings, or relocation of underground utilities that contain hazardous materials. It is possible that currently unknown or non-listed underground storage tanks or sites with contaminated soil and/or groundwater could be encountered during construction. Naturally occurring asbestos in serpentine rock is known to be present in the central portions of the Project area, and may be present in other locations as well. It is also possible that contamination could exist in localized areas as the result of pesticide or herbicide use during routine landscape/turf maintenance practices, or in association with the removal or disturbance of older underground utilities or unidentified buried debris. If required during construction activities, dewatering could result in the withdrawal of contaminated groundwater. If the groundwater contains contaminants above regulatory levels, the water could present a hazard to people or the environment unless managed properly. Demolition of existing structures within the Project Area may expose construction workers, the public or the environment to hazardous materials such as lead-based paint, asbestos and PCBs unless proper precautions are taken. Mitigation Measures and Regulatory Requirements: Potential exposure to hazardous building materials would be reduced through appropriate identification, removal and disposal according to applicable regulations. Regulatory Requirement Hazards 4A – Discovery of Underground Storage Tanks: All known on- site storage tanks are above ground and conform to applicable federal, state and local regulations and are registered and permitted by the South San Francisco Fire Department. In the event that previously unknown USTs are uncovered or disturbed, they will be properly closed in place or removed. While removal could pose health and safety risks, such as the exposure of workers and the public to tank contents or vapors, these potential risks will be reduced by managing the tank closure process according to established regulatory guidelines for investigation and closure of USTs, and for cleanup of sites contaminated by leaking USTs. These regulatory guidelines are established pursuant to the California EPA’s adopted Unified Hazardous Waste and Hazardous Materials Management Regulatory Program, as implemented at the local level by the San Mateo County Department of Environmental Health. Regulatory Requirement Hazards 4B – Asbestos: Asbestos-containing materials are regulated both as a hazardous air pollutant under the Clean Air Act and as a potential worker safety hazard under the authority of Cal-OSHA. Any asbestos-containing materials in structures slated for demolition must be abated in accordance with State and federal regulations, prior to the start of demolition or renovation activities. 1 Section 19827.5 of the California Health and Safety Code requires that local agencies not issue demolition or alteration permits until an applicant has demonstrated compliance with notification requirements under applicable federal regulations regarding hazardous air pollutants, including asbestos. Genentech Campus Master Plan Update – CEQA Findings page 56 2. The BAAQMD is vested by the California legislature with authority to regulate airborne pollutants, including asbestos, through both inspection and law enforcement, and is to be notified 10 days in advance of any proposed demolition or abatement work. 3. State regulations contained in 8 CCR 1529 and 8 CCR 341.6 through 341.14 must be followed where there is asbestos-related work involving 100 square feet or more of asbestos- containing material. Asbestos removal contractors must be certified as such by the Contractors Licensing Board of the State of California. 4. The owner of the property where abatement is to occur must have a hazardous waste generator number assigned by and registered with the DTSC. The site owner or responsible party and the transporter of the waste are required to file a hazardous waste manifest that details the transportation of the material from the site and its disposal. Regulatory Requirement Hazards 4C – Lead-Based Paint: Both the federal OSHA and Cal-OSHA regulate worker exposure during construction activities that may disturb lead-based paint. The Interim Final Rule found in 29 CFR 1926.62 covers construction work in which employees may be exposed to lead during such activities as demolition, removal, surface preparation for repainting, renovation, cleanup and routine maintenance. The OSHA-specified compliance includes respiratory protection, protective clothing, housekeeping, special high-efficiency filtered vacuums, hygiene facilities, medical surveillance and training. No minimum level of lead is specified to activate the provisions of this regulation. Regulatory Requirement Hazards 4D- PCBs: Fluorescent lighting ballasts manufactured prior to 1978, and electrical transformers, capacitors and generators manufactured prior to 1977 may contain PCBs. In accordance with the Toxic Substances Control Act and other federal and state regulations, construction or demolition activities that may involve such materials must properly handle and dispose of electrical equipment and lighting ballasts that contain PCBs. Regulatory Requirement Hazards 4E – Construction Dewatering: Pursuant to Section 13263 of the California Water Code, the Regional Water Quality Control Board issues Waste Discharge Requirements to control discharges (including dewatering during construction) to land or water. Pursuant to these requirements, permits require contractors to implement best management practices during construction dewatering to avoid exposure of employees or construction workers to potentially contaminated groundwater. These BMPs may include, but are not limited to groundwater testing, containment of contaminated groundwater in storage tanks for subsequent treatment and/or disposal, and the provision of release response information. In the unlikely event that contaminated groundwater is discovered during construction activities, Genentech’s contractors will follow specific procedures to reduce the risk of exposure. Regulatory Requirement Hazards 4F – Building Demolition: Buildings demolished during construction activities could have contained biohazardous materials, including medical wastes, prior to demolition. Genentech's programs, practices and procedures, and current state testing, monitoring and disposal regulations pertaining to the management of biohazardous materials (including medical waste) will eliminate or reduce the potential for biohazardous substances to be present in fixtures or building materials removed during demolition. Genentech’s radioactive materials license requires testing and implementation of decontamination and waste handling activities in accordance with applicable regulations when facilities using radioactive materials are decommissioned for purposes of renovation or demolition. Genentech Campus Master Plan Update – CEQA Findings page 57 Because the presence of hazardous materials at any particular location is not always known, the following mitigation measure shall be implemented prior to initiation of ground-disturbing grading activities or construction activities associated with the Project: Mitigation Measure Hazards 4: Site Assessment: If previously unknown contamination, underground tanks, containers or stained or odorous soils are discovered during construction activities, the construction contractor(s) shall stop work and appropriate investigation, sampling and comparison of data collected with health-based screening levels and/or consultation with a regulatory oversight agency shall be conducted to determine if the discovered materials pose a significant risk to the public or construction workers. a) If any such materials are discovered that exceed human health screening levels as noted in DTSC’s HERO HHRA Note 3 criteria for California Human Health Screening Levels (CHHSLs) and/or Environmental Screening Levels (ESLs), a remediation plan shall be prepared and submitted to the appropriate regulatory agency in compliance with all applicable legal requirements, and to ensure the proper handling and management. b) Soil remediation methods may include, but are not limited to excavation and on-site treatment, excavation and off-site treatment, or disposal and/or treatment without excavation. c) Remediation alternatives for cleanup of contaminated groundwater could include, but are not limited to on-site treatment, extraction and off-site treatment, and/or disposal. d) Construction schedules may need to be modified or delayed to ensure that construction will not inhibit remediation activities and will not expose the public or construction workers to significant risks associated with hazardous conditions. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Hazards 4): Continued compliance with federal and state health and safety laws and regulations, as well as existing (or equivalent) Genentech programs, practices and procedures would ensure that potential exposure to known hazardous building materials would be reduced to levels of less than significant. Individual site assessments for construction activities that may encounter currently unknown soil or groundwater contamination pursuant to the mitigation measure identified above would also ensure that potential exposure of construction workers, employees and the public are reduced to a level of less than significant. 110. Impact Hazards 7, Impairment or Interference with an Emergency Response or Evacuation Plan: Implementation of the Project could impair implementation of, or physically interfere with an adopted emergency response or emergency evacuation plan. It is possible that construction and certain operational activities associated with the Project could potentially affect emergency response or evacuation plans due to temporary construction barricades or other roadway obstructions that could impede emergency access on-site. Mitigation Measures: Mitigation Measure Hazards 7A – Adequate Roadway Access: To the extent feasible, the Project applicant shall maintain at least one unobstructed lane in both directions on the site's roadways. At any time only a single lane is available, Genentech shall provide a temporary flag-person or other appropriate traffic control to allow travel in both directions. If construction activities require the complete closure of a roadway segment, Genentech shall provide appropriate signage indicating alternative routes. Genentech Campus Master Plan Update – CEQA Findings page 58 Mitigation Measure Hazards 7B – Lane Closure Request: To ensure adequate access for emergency vehicles when construction projects may result in temporary lane or roadway closures, Genentech shall consult with the South San Francisco Police and Fire Departments to disclose any such temporary lane or roadway closures and to identify appropriate alternative travel routes. Finding of Less Than Significant Impact With Mitigation Measures (Impact Hazards 7): Coordinated planning between Genentech, the San Mateo County DEH and the South San Francisco Fire Department, as provided for in Mitigation Measures Hazards 7A and 7B will ensure that the Project will not impair or interfere with coordinated emergency response and evacuation planning. On-going coordination between Genentech and local agencies pursuant to the mitigation measures identified above would also ensure that roadway or travel lane closures are coordinated with emergency response personnel. This coordination will ensure that individual development projects pursuant to the Project will not impair implementation of, or physically interfere with emergency response and evacuation efforts, and the impact will be reduced to a level of less than significant. 111. Cumulative Hazards Risks: Cumulative health and safety impacts could occur if off-site hazards related to the Project were to interact with, or combine with similar effect of other cumulative development within the East of 101 Area. Cumulative increases in the transportation of hazardous materials and wastes would not be significant because the probability of accidents is relatively low due to stringent regulations that apply to all transport, use and storage of hazardous materials. Fire response capabilities and hazardous materials emergency response capabilities are currently available and sufficient for all cumulative projects. Substantive hazardous accidents within the vicinity of the Project site are expected to be rare, and if such incidents were to occur, only one such incident would be expected at any one time. The Project, as well as other future development in the East of 101 Area are subject to the all regulatory requirements regarding the use, transport, and disposal of hazardous substances, which provide for the transport of hazardous materials safely to and from the entire East of 101 Area. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Cumulative Hazards Risks): With implementation of applicable regulatory and mitigation requirements, cumulative impacts related to hazards and hazardous materials would be less than significant, and the Project would not result in a cumulatively considerable contribution to a significant cumulative hazard or hazardous materials impact. G. NOISE 112. Impact Noise 2, Operational Noise: Operational activities associated with the Project could potentially generate a substantial permanent increase in ambient noise levels in the vicinity, in excess of standards established in the local General Plan or Noise Ordinance. The maximum L50 noise standards for the land uses within and adjacent to the Project site vary depending on their location relative to roadway noises, industrial operations and other existing noise sources. Mitigation Measures: Mitigation Measure Noise 2: Mechanical and Industrial Equipment Noise Reduction Requirements: The project applicant shall analyze or provide documentation of future exterior mechanical or industrial equipment to determine if the equipment would exceed applicable operational noise standards. If so, noise control measures must be provided to meet the City’s requirements. Typical noise control measures include barriers, enclosures, silencers and Genentech Campus Master Plan Update – CEQA Findings page 59 acoustical louvers at vent openings. Prior to issuance of any building permits, the project applicant shall submit a report verifying that noise levels generated by project mechanical equipment are no greater than applicable noise standards at receiving properties. Finding of Less Than Significant Impact With Mitigation Measures (Impact Noise 3): With the implementation of Mitigation Measure Noise-2, new industrial or mechanical operational noise that would exceed applicable operational noise standards must be reduced to meet the City’s requirements, and impacts associated with the Project would be reduced to a less than significant level. 113. Impact Noise 3, Construction-Period Ground-Borne Vibration: Construction activities pursuant to the Project would not generate excessive ground-borne vibration, but could adversely affect vibration-sensitive equipment and persons within the Project Area. The most intensely vibratory pieces of construction equipment (vibratory rollers) would not exceed the building damage threshold of 0.5 inches per second unless it was operating as close as 14 feet from another building. No off-Campus, non-Genentech buildings are expected to be as close as 14 feet from a substantial vibratory construction operation, and no off-site impacts related to building damage are anticipated. Mitigation Measures: Mitigation Measure Noise 3A - Pre-Construction Survey: Prior to the commencement of ground clearing activities, the project applicant shall verify that: a) no heavy construction activity that may generate a PPV of more than 0.10 inches/second at 25 feet would occur within 10 feet of an adjacent, non-Genentech building, and that b) no heavy construction activity that may generate a PPV of more than 0.20 inches/second at 25 feet would occur within 20 feet of an adjacent, non-Genentech building c) If no such construction activity would occur within these specified distances from an adjacent, off-site building, then construction activities would not exceed the building damage threshold, and construction may begin with no further action required for vibration effects. Mitigation Measure 3B – Changes to Construction Plans: If heavy construction activity is proposed at distances closer to an adjacent, non-Genentech building than those distances prescribed in Mitigation Measure Noise 3A, such that vibration impacts may result in damage to and adjacent building, the project applicant shall adjust the construction plan such that it would not generate vibration levels at the adjacent building that exceed the building damage threshold of 0.50 inches per second PPV. Mitigation Measure Noise 1A - Construction Period BMPs (see above) Mitigation Measure Noise 1B - Truck Routes (see above) Finding of Less Than Significant Impact With Mitigation Measures (Impact Noise 3): With implementation of these mitigation measures, potentially significant damage to adjacent buildings would be reduced to a less-than-significant level. Genentech will continue to prepare and implement Noise Attenuation and Logistics Plans for new development that is in close proximity to another existing Genentech building, demonstrating consistency with all applicable OSHA requirements for safe workspaces, and any other private Genentech-based noise standards for a healthy workplace. Genentech Campus Master Plan Update – CEQA Findings page 60 H. UTILITIES 114. Impact Utilities 5, Wastewater Collection Infrastructure (Project-specific and Cumulative): Based on a programmatic, system-wide assessment of the Project Area’s wastewater collection system, the existing wastewater system will generally have adequate collection pipe capacity to accommodate buildout of the Project, but may have certain capacity constraints particularly within those sewer mains along Forbes Avenue and Allerton Way that flow to Pump Station #8. The Project would contribute additional sewer flows in the system, but these flows would be distributed throughout the Campus, and existing system capacity deficiencies are not driven by the additional flows attributed to the Project. Mitigation Measures and Regulatory Requirements Regulatory Requirement Utilities 4 - East of 101 Sewer Fees: These fees represent “fair-share” payments towards the availability of sewer collection, as well as treatment and disposal capacity for the Project, and apply to all discretionary land use approvals, including Administrative Review, Minor Use Permits and Conditional Use Permits. Regulatory Requirement Utilities 5 - Sewer Lateral Construction: Pursuant to South San Francisco Municipal Code, Chapter 14.14 Sewer Lateral Construction, Maintenance and Inspection, as new development occurs within the Project Area, Genentech will be responsible for constructing, operating and maintaining all individual building sanitary sewer laterals from the building to the City sanitary sewer main. Mitigation Measure Utilities 5 – Detailed Hydraulic Analysis and System Upgrades: Subsequent detailed hydraulic analysis will ultimately be needed pursuant to individual development projects that rely on the segment of sewer line contributing to Pump Station #8. The results of this detailed analysis will determine whether and when the capacity of these wastewater collection facilities may need to be increased to meet demand. The wastewater collection system will be upgraded as necessary to accommodate future growth, consistent with City Municipal Code requirements and responsibilities. Finding of Less Than Significant Impact With Mitigation Measures and Regulatory Requirements (Impact Utilities 5): Wastewater service connections and potential capacity improvements will occur within the street right-of-way and within individual development sites, and will not result in any unique or peculiar on-site or off-site environmental effects. Cumulative development occurring in the East of 101 Area may require that the City undertake improvements to the main sewer collection system and/or treatment facilities, beyond those improvements already assumed in the City’s Capital Improvement Program. These potential sewer system improvements provide citywide benefits, and would be financed (if needed), through issuance of sewer revenue bonds. XI. FINDINGS FOR SIGNIFICANT AND UNAVOIDABLE IMPACTS 115. The California Environmental Quality Act (“CEQA”), Public Resources Code §21000 et seq., states that if a project would result in significant environmental impacts, it may be approved if feasible mitigation measures or feasible alternatives are proposed which avoid or substantially lessen the impact, or if there are specific economic, social, or other considerations which justify approval notwithstanding unmitigated impacts. When an environmental impact report (“EIR”) identifies one or more potentially significant or significant environmental impacts, the approving agency must make one or more of the following findings for each identified significant impact: Genentech Campus Master Plan Update – CEQA Findings page 61  Changes or alternatives which avoid or substantially lessen the significant environmental effects as identified in the EIR have been required or incorporated into the project; or  Such changes or alternatives are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency; or  Specific economic, social or other consideration make infeasible the mitigation measures or project alternatives identified in the EIR. (Pub. Res. Code § 21081). 116. The following significant impacts would remain significant and unavoidable, notwithstanding the imposition of all feasible mitigation measures, as set forth below. No mitigation is feasible that would mitigate these impacts to a level of less than significant. The City has determined that the impacts identified below are acceptable because of overriding economic, social, or other considerations, as described in the Statement of Overriding Considerations adopted concurrently with these findings. (Pub. Res. Code §§ 21081, 21081.5; CEQA Guidelines § 15093). A. AIR QUALITY 117. Impact Air Quality 4, Operational Criteria Pollutant Emissions (Project-specific): During operations, the Project would result in a cumulatively considerable net increase of criteria pollutants for which the region is non-attainment, including emissions that exceed quantitative thresholds for ozone precursors. Specifically, the Project’s average daily operational emissions are projected to exceed 54 pound per day of reactive organic gas (ROG) and nitrogen oxides. Operational sources of criteria air pollutants include stationary sources (diesel-fired emergency generators, permit-exempt natural gas-fired boilers, the potential construction of a Combined Heat and Power Plant and four new Miura boilers), plus additional area sources and mobile sources. The combined emissions from each of these sources would exceed applicable criteria air pollutant emissions thresholds. Mitigation Measures and Regulatory Requirements: Regulatory Requirements: Stationary sources that are subject to permitting by the BAAQMD are required to be offset per BAAQMD Regulation 2-2: New Source Review, Section 302: Offset Requirements, if the facility emits or is permitted to emit greater than 35 tons per year of NOx and ROGs. Genentech is permitted to emit greater than 35 tons per year of both NOx and ROG, and is therefore required to submit emissions offsets for every new permitted source or emissions modification that results in increased emissions. Offsets are established at a 1.15 to 1.0 ratio. Regulatory Requirement Air Quality 4 - New Source Review Offset: Genentech shall purchase offset credits pursuant to BAAQMD Regulation 2-2: New Source Review, Section 302: Offset Requirements for each new permitted stationary source of NOx and/or ROG emissions, and for any modifications to existing stationary emission sources that result in increased NOx and/or ROG emissions. The BAAQMD's offset program is intended to ensure a no net increase of NOx and ROG emissions in the San Francisco Bay Area. The purchase and retirement to the BAAQMD of offsets ensures that new emissions are balanced by federally enforced emission reductions or emissions source removals. Mitigation Measures: No additional measures are available or feasible. Finding of Significant and Unavoidable Impact (Impact Air Quality 4): The BAAQMD offset program (RR AQ-4) will ensure a no net increase of NOx and ROG emissions from stationary Genentech Campus Master Plan Update – CEQA Findings page 62 sources. Additionally, the Project incorporates numerous design features (e.g., TDM measures and energy efficient features) that will serve to reduce operational emissions of criteria pollutants. Although these TDM measures, energy efficiency features and regulatory requirements are incorporated into the Project, total emissions of criteria pollutants from mobile sources and other sources not requiring separate permits form BAAQMD would still exceed the thresholds of significance. There are no additional quantifiable and feasible mitigation measures (other than those BMPs identified under Impact Air Quality 2, Construction-Period Emissions of Criteria Pollutants) capable of further reducing these emissions, and this impact would remain significant and unavoidable. A separate analysis was conducted as part of the EIR to estimate the potential health impacts of criteria pollutants, specifically oxides of nitrogen (NOx), volatile organic compounds (VOC), ozone, particulate matter smaller than 2.5 microns in diameter (PM2.5), and oxides of sulfur (SOx). The results of that analysis indicate that anticipated health impacts are vanishingly small (less than significant). 118. Cumulative Air Quality Effects, Ambient Air Quality Standards: The San Francisco Bay Area Air Basin is currently designated as non-attainment for ozone, PM10 and PM2.5. Since the Project’s emissions of criteria pollutants (i.e., PM10, PM2.5, and the ozone precursors NOx and ROG) from construction and operation of the Project exceeds threshold levels, impacts of the Project due to the emission of non-attainment pollutants is considered cumulatively considerable. Mitigation Measures: There are no quantifiable and feasible mitigation measures capable of further reducing these emissions. Finding of Significant and Unavoidable Impact (Cumulative Air Quality): The Project incorporates numerous features in its design that will serve to reduce operational emissions of criteria pollutants, including a TDM program that exceeds local requirements and implementation of energy efficiency features in future building designs. The Project’s participation in the BAAQMD offset program will also ensure a no net increase of NOx and ROG emissions from stationary sources. Although these TDM measures, energy efficiency features and regulatory requirements are incorporated into the Project, total emissions of criteria pollutants from mobile sources and other sources not requiring separate permits from the BAAQMD would still exceed the thresholds of significance, and the Project would make a substantial contribution to cumulatively significant and unavoidable air quality impacts. B. NOISE 119. Impact Noise 1, Construction Noise: Construction activities pursuant to the Project could generate a substantial temporary increase in ambient noise levels in the vicinity of the project in excess of noise levels that exceed the noise standards established in SSFMC Section 8.32.030. Certain types of construction activity (e.g., concrete mixer trucks, excavators and graders, jackhammers, etc.) could generate noise that exceeds 90 dB at a distance of 25 feet or could potentially exceed 90 dB at a nearby property line. Depending on the precise location of new development relative to property lines, construction noise at these select Opportunity Sites could potentially exceed 90 dB at an adjacent property line. These types of construction-period noise impacts would be considered significant. Genentech Campus Master Plan Update – CEQA Findings page 63 Mitigation Measures and Regulatory Requirements: Regulatory Requirement Noise 1 -Compliance with SSF Municipal Code. All noise-generating construction activities pursuant to the Project would comply with limits on weekday and weekend hours, as set forth in the SSF Municipal Code Section 8.32.050. Additionally, the following mitigation measures are recommended for construction activity within the Project Area that is within 50 feet of an adjacent off-site property, and where construction noise may exceed the 90-dB limit of the SSF Municipal Code. Mitigation Measure Noise 1A - Construction Period BMPs: The Project applicant shall require, by contract specifications, that best management practices (BMPs) for construction activity be implemented by contractors to reduce construction noise levels: a) Two weeks prior to the commencement of construction, notification must be provided to surrounding land uses disclosing the construction schedule, including the various types of activities that would be occurring throughout the duration of the construction period. b) Maintain all construction equipment to minimize noise emissions. All construction equipment shall be equipped with mufflers and sound control devices (e.g., intake silencers and noise shrouds) that are in good condition and appropriate for the equipment. c) Place stationary noise- and vibration-generating construction equipment away from sensitive uses where feasible. d) Construction staging areas and operation of earthmoving and or other noise-generating or vibration-generating equipment should be located as far away from noise sensitive sites as possible. e) Unnecessary idling of internal combustion engines should be strictly prohibited. f) Schedule high noise-producing activities during times when they would be least likely to interfere with the noise-sensitive activities of the adjacent land uses, when possible. g) For any new development pursuant to the Project that may require deep foundations, consider the use of augured-cast-in-place piles or drilled shafts, rather than use of impact or vibratory pile drivers. h) Implement noise attenuation measures to the extent feasible, which many include, but are not limited to, noise barriers or noise blankets i) The construction contractor shall provide the name and telephone number of an on-site construction liaison. If construction noise is found to be intrusive to surrounding properties (i.e., if complaints are received), the construction liaison shall investigate the source of the noise and require that reasonable measures be implemented to correct the problem. Mitigation Measure Noise 1B - Truck Routes: The Project applicant shall require, by contract specifications, that heavily loaded trucks used during construction be routed away from noise- sensitive and vibration-sensitive uses to the extent possible. Finding of Significant and Unavoidable Impact (Impact Noise 1): With implementation of construction-period BMPs per Mitigation Measures Noise 1A and 1B, most adverse effects on adjacent and separately-owned properties resulting from construction activity pursuant to the Project would be reduced to a level of less than significant. However, certain future Opportunity Sites are near adjacent properties, and where details about the placement of new structures and associated construction activities are not currently known. It is possible that construction Genentech Campus Master Plan Update – CEQA Findings page 64 noise generated at these locations, near adjacent property lines, could exceed the 90-dB limits of the SSF Noise Ordinance. Even with implementation of construction-period BMPs, these noise levels could temporarily exceed 90 dB at the property line. The details of such future construction projects are not and cannot be known at this time, and the effectiveness of construction-period BMPs cannot be demonstrated with certainty without such details. Construction noise is typically not considered significant if its duration is for a period of less than one year. Construction noise is temporary and episodic in nature, and mitigation measures presented above include all reasonable and feasible methods to reduce construction noise effects. However, since the details of such construction activity at each Opportunity Site cannot be known in advance, this impact is conservatively considered significant and unavoidable. C. TRANSPORTATION 120. Impact Transportation 1, Local Intersection Level of Service/Queuing (Existing plus Project): Under Existing plus Project conditions, the Project would contribute traffic to intersections in the Project vicinity that would result in conflicts with applicable plans, ordinances or policies that establish measures of effectiveness for intersection levels of service (“LOS”) or queuing at 20 of the 27 traffic study intersections. Mitigation Measures and Regulatory Requirements: Regulatory Requirement Transportation 1A - Assumed Signal Timing Adjustments: The Project sponsor shall pay South San Francisco’s East of 101 Transportation Impact Fees, representing their fair-share contribution toward the following traffic signal timing adjustments already included in the East of 101 Traffic Impact Fee Program: 1. Airport Boulevard/Sister Cities Boulevard/Oyster Point Boulevard (Intersection #1): Adjust the signal timing at the intersection to allow the southbound right-turn movement to overlap with the eastbound left turn movement. 2. Dubuque Avenue/101 NB off-ramp/Oyster Pt. Boulevard (Intersection #2). Adjust the signal timing at the intersection to provide additional green time for the eastbound movement in the AM, and to provide additional green time for the westbound movement in the PM. 3. Gateway Boulevard/East Grand Avenue (Intersection #15): Adjust the signal timing at this intersection to convert the eastbound left turn phase from a lagging phase to a leading phase. 4. East Grand Avenue/Littlefield Avenue (Intersection #23): Optimize the signal timing, allowing the northbound right-turn movement to overlap with the westbound left-turn movement, and change the existing northbound through/left-turn lane to allow northbound through/left/right turn movements. Regulatory Requirement Transportation 1B - East of 101 Transportation Impact Fee Improvements: The Project sponsor shall pay South San Francisco’s East of 101 Transportation Impact Fees, representing their fair-share contribution toward the following intersection improvements already included in the East of 101 Traffic Impact Fee Program: 1. Oyster Point Boulevard/Eccles Avenue (Intersection #6): Add an eastbound right-turn lane and provide a northbound configuration that includes a northbound right-turn lane, a northbound left-turn lane and a 100-foot northbound left-turn pocket, in conjunction with optimized signal timing. Because the addition of an eastbound right-turn lane would Genentech Campus Master Plan Update – CEQA Findings page 65 lengthen pedestrian crossing distances and overlap with an existing bike lane, a pedestrian refuge in the median and expanded green bike lane (conflict zone) markings should also be included. 2. Oyster Point Boulevard/Gull Drive (Intersection #7): Extend the double northbound left-turn lanes to approximately 200 feet, add an eastbound right-turn pocket, add a second northbound left-turn lane, and adjust the signal timing to allow the eastbound right and northbound left movements to overlap. 3. Airport Boulevard/Grand Avenue (Intersection #12): Add a second southbound left-turn lane and convert the southbound right-turn lane to a through/right lane. 4. East Grand Avenue/Harbor Way/Forbes Boulevard (Intersection #16): Add a westbound through lane, an eastbound right-turn lane, an eastbound through lane, and time-of-day geometry changes for northbound and southbound approaches. Because these improvements would lengthen crosswalk distances and exacerbate conflicts with bicyclists along East Grand Avenue and Forbes Boulevard, the mitigation should incorporate pedestrian refuge islands, bicycle conflict zone markings and consider the removal of slip lanes. 5. East Grand Avenue/Allerton Avenue (Intersection #17): Install a traffic signal, including a protected southbound left-turn movement. 6. East Grand Avenue/DNA Way (Intersection #18): Install a traffic signal and add an additional eastbound left turn lane. 7. Produce Avenue/Airport Boulevard/San Mateo Avenue (Intersection #19): Widen the westbound approach to consist of three dedicated left turn lanes, one through lane, and one shared through-right lane. MM Transportation 1 - Additions to East of 101 Transportation Impact Fee Program: The Project sponsor shall pay its fair-share toward the following intersection improvements by either; 1) fully funding the following improvement subject to fee credits if the improvement is subsequently included in the City’s CIP update; or 2) paying the City’s Transportation Impact Fees if the City has included these improvements in its Capital Improvement Program (CIP) prior to issuance of building permits for development that triggers these mitigation improvements: a) 101 SB/Oyster Pt. Boulevard off Ramp (Intersection #4). Add an additional eastbound through lane, and change the signal phasing to implement an overlap phase for the northeast-bound right turn movement. b) Forbes Boulevard/Allerton Avenue (Intersection #8): Install a traffic signal with optimized signal timing. c) Gull Drive/Forbes Boulevard (Intersection #9): Adjust the existing signal timing and extend the southbound left turn pocket to 500 feet. d) Airport Boulevard/Miller Avenue/ US-101 SB Off-Ramp (Intersection #10). Adjusting the signal timing to lengthen northbound through and eastbound right phases e) South Airport Boulevard/Gateway Boulevard/Mitchell Avenue (Intersection #20): Separate the existing shared northbound through/right lane into one northbound through lane and a northbound right turn lane, add one westbound through lanes, one eastbound right turn lane, one eastbound left turn lane and one southbound right turn lane. These improvements Genentech Campus Master Plan Update – CEQA Findings page 66 would lengthen crosswalk distances and exacerbate conflicts with bicyclists along Airport Boulevard and Gateway Boulevard; consequently, median pedestrian refuges and green bicycle conflict zone markings should be added. f) Mitchell Road/Harbor Way (Intersection #24): Install a traffic signal at this intersection, add a 250-foot eastbound left turn lane and a 100-foot northbound left turn lane and optimize the signal timing. g) Utah Avenue/Harbor Way (Intersection #25): Add a traffic signal at this intersection and optimize signal timing. Finding of Less Than Significant Impact With Mitigation (Impact Transportation 1): With implementation of Regulatory Requirements Transportation 1A and 1B and Mitigation Measure Transportation 1, the Project’s impacts at the following 13 intersections would be reduced to a less than significant level: i. At Airport Boulevard/Oyster Point Boulevard (Intersection #1), the signal timing adjustment per RR Transp 1A-1 would improve intersection operations to an acceptable LOS D ii. At Gateway Boulevard/East Grand Avenue (Intersection #15), the signal timing adjustment per RR Transp 1A-3 would reduce delay to an acceptable LOS D. iii. At East Grand Avenue/Littlefield Avenue (Intersection #23) the signal timing adjustment per RR Transp 1A-4 would improve intersection operations to an acceptable LOS D in the AM peak hour iv. At Oyster Point Boulevard/Eccles Avenue (Intersection #6), the identified improvements per RR Transp 1B-1 would result improve operations to an acceptable LOS B in the AM peak hour. v. At Oyster Point Boulevard/Gull Drive (Intersection #7), the identified improvements per RR Transp 1B-2 would result improve operations to an acceptable LOS D in both the AM and PM peak hours. vi. At East Grand Avenue/Harbor Way/Forbes Boulevard (Intersection #16), the identified improvements per RR Transp 1B-4 would result in improved operations to an acceptable LOS D in both AM and PM peak hours. vii. At East Grand Avenue/Allerton Avenue (Intersection #17), the identified improvements per RR Transp 1B-5 would improve intersection operations to acceptable LOS B in the PM peak hour. viii. At East Grand Avenue/DNA Way (Intersection #18), the identified improvements per RR Transp 1B-6 would improve intersection operations to acceptable LOS B in the AM peak hour and LOS C in the PM peak hour. ix. At Produce Avenue/Airport Boulevard/San Mateo Avenue (Intersection #19), the identified improvements per RR Transp 1B-7 would reduce both queuing and vehicular delay to an acceptable LOS D in both the AM and PM peak hours. x. At Forbes Boulevard/Allerton Avenue (Intersection #8), the identified improvements per MM Transp 1b would improve intersection operations to an acceptable LOS A in the AM and PM peak hours. Genentech Campus Master Plan Update – CEQA Findings page 67 xi. At South Airport Boulevard/Gateway Boulevard/Mitchell Avenue (Intersection #20), the identified improvements in MM Transp 1e would decrease delay to an acceptable LOS C during the AM peak hour and acceptable LOS D during the PM peak hour, and reduce queuing to an acceptable level. xii. At Mitchell Road/Harbor Way (Intersection #24), the improvements identified in MM Transp 1f would improve intersection operations to LOS B in the AM peak hour and LOS A in the PM peak hour. xiii. At Utah Avenue/Harbor Way (Intersection #25), the improvements identified in MM Transp 1g would improve intersection operations to LOS A in both the AM and PM peak hours Finding of Significant and Unavoidable Impacts (Impact Transportation 1): Even with implementation of Regulatory Requirements Transportation 1A and 1B, and Mitigation Measure Transportation 1, the Project’s impacts at the following 7 intersections could not be reduced to a less than significant level: i. At Dubuque Avenue/101 NB off-ramp/Oyster Pt. Boulevard (Intersection #2), the signal timing improvements identified in RR Transp 1A-2 would reduce the queue compared to the existing conditions, but the intersection is under the jurisdiction of Caltrans and the City cannot ensure that improvements can be made. ii. At 101 SB/Oyster Pt. Boulevard off Ramp (Intersection #4), the intersection improvements identified in MM Transp 1a would reduce the queue compared to existing conditions, but the intersection is under the jurisdiction of Caltrans and the City cannot ensure that improvements can be made. iii. At Gull Drive/Forbes Boulevard (Intersection #9), even with improvements identified under Mitigation Measure Transp 1C, the intersection would continue to operate at an unacceptable LOS F during the AM peak hour and no further mitigation is available due to restricted right-of-way. iv. At Airport Boulevard/Miller Avenue/ US-101 SB Off-Ramp (Intersection #10), the intersection improvements identified in MM Transp 1D would improve intersection operations to an acceptable LOS C in the PM peak hour, but the intersection is under the jurisdiction of Caltrans and the City cannot ensure that improvements can be made. v. At Airport Boulevard/Grand Avenue (Intersection #12), the improvements identified in Mitigation Measure Transp-1B would reduce vehicle delay and LOS to a less than significant level, but these improvements cannot reduce the length of the southbound left turn queue to which the Project contributes, and no further mitigation is available due to restricted right-of-way. vi. At South Airport Boulevard/US-101 On- and Off-Ramps/ Wondercolor Drive (Intersection #21), no improvements have been identified due to restricted right-of- way. vii. At South Airport Boulevard/I-380 Westbound ramp (Intersection #26), no improvements have been identified due to restricted right-of-way. 121. Impact Transportation 3, Freeway Segments (Existing plus Project): The Project would generate more than 100 peak hour trips onto the Congestion Management Program roadway network, Genentech Campus Master Plan Update – CEQA Findings page 68 resulting in conflicts with applicable plans, ordinances or policies that establish measures for effective levels of service along two freeway segments. Mitigation Measures (MMs) No mitigation is available. Finding of Significant and Unavoidable Impact (Impact Transportation 3): As there are no feasible mitigation measures for these impacts to freeway segments due to constrained right-of- way and a corresponding inability to add traffic capacity or reduce vehicular delays, Impact Transportation 3 will remain significant and unavoidable. The C/CAG Agency Guidelines for implementation of the 2015 Congestion Management Program specifies that local jurisdictions must ensure that project sponsors mitigate traffic impacts during the peak hour on the CMP network. These C/CAG Guidelines apply to developments that generate more than 100 peak- hour trips on the CMP roadway network. Consistent with C/CAG guidelines, the Project will implement a TDM program that is consistent with, and exceeds, City requirements. That TDM program will serve to reduce its otherwise greater contribution of trips on the CMP network, including increased traffic on US-101 freeway segments. 122. Impact Transportation 6, Local Intersection Level of Service/Queuing (Cumulative plus Project): Based on the analysis of cumulative traffic operations at study intersections, the Project would individually contribute traffic at levels considered cumulatively significant (i.e., that would result in conflicts with applicable plans, ordinances or policies that establish measures of effectiveness for intersection levels of service or queuing) at 22 of the 27 study area intersections. Mitigation Measures and Regulatory Requirements: Mitigation Measure Transportation 6A: Implement Existing plus Project Measures. Pursuant to regulatory requirements and mitigation measures identified under Existing plus Project conditions, the Project applicant shall pay its fair-share toward intersection improvements by either; 1) fully funding the following improvement subject to fee credits if the improvement is subsequently included in the City’s CIP update; or 2) paying the City’s Transportation Impact Fees if the City has included these improvements in its Capital Improvement Program (CIP) prior to issuance of building permits for development that triggers these mitigation improvements. These Existing plus Project improvements also improve traffic conditions under the Cumulative plus Project condition, as indicated below: a) Forbes Boulevard/Allerton Avenue (#8): Implement Mitigation Measure Transportation 1(b), which provides for installation of a traffic signal with optimized signal timing. b) Grand Avenue/Littlefield Avenue (#23): Implement Regulatory Requirement Transportation 1A (d), which provides for an adjustment to the signal timing to allow the northbound right turn phase to overlap with the westbound left turn phase. c) Mitchell Road/Harbor Way (#24): Implement Mitigation Measure Transportation 1(f), which provides for installation of a traffic signal at this intersection, and adding an additional 250- foot eastbound left turn pocket as well as a 100-foot northbound left turn pocket. Mitigation Measure Transportation 6B: Additions to East of 101 Transportation Impact Fee Program: If the City includes the following improvements in its East of 101 Transportation Impact Fee Program and Capital Improvement Program (CIP), the Project applicant shall pay its fair-share toward these intersection improvements by paying the City’s Transportation Impact Fees: Genentech Campus Master Plan Update – CEQA Findings page 69 a) Airport Boulevard/Oyster Point Boulevard (#1): Add overlap phases for the southbound right and northbound right movements, and optimizing signal timing. b) Dubuque Avenue/US-101 Ramps (#3): Change the eastbound through-right lane to a left- through-right lane, introduce an overlap phase for the southbound right turn movement and optimize the signal timing. c) Oyster Point Boulevard/Gateway Boulevard (#4): Increase cycle length to 160 seconds, providing an overlap phase for the northeast-bound right turn movement, and optimizing timing splits. d) Airport Boulevard/Miller Avenue/US-101 SB Off-Ramp (#10): Adjust the signal timing to lengthen the westbound green time. e) Dubuque Avenue/Grand Avenue (#11): Adjust the signal timing to lengthen the westbound green time. f) Produce Avenue/Airport Boulevard/San Mateo Avenue (#19). Modify the signal timing. g) South Airport Boulevard/Gateway Boulevard (#20). Update the signal timing. h) South Airport Boulevard/Utah Avenue (#22): Separate the westbound left turn lane into one westbound left and one westbound through lane, and adjust the signal timing to allow the northbound right and westbound left movements to overlap in the AM peak hour. i) Utah Avenue/Harbor Way (#25): Implement Mitigation Measure Transportation 1(g), which provides for installation of a traffic signal at this intersection. Additionally, reconfigure the approaches to add one eastbound left turn pocket and one westbound left-turn pocket, and convert the existing shared westbound through-right lane to a right turn lane. j) Westbound Ramp/South Airport Boulevard (#26). Extending cycle length and optimizing the signal timing at this location. k) I-380 Eastbound Ramp/South Airport Boulevard (#27): Extending the cycle length and optimizing the signal timing at this location. Finding of Less Than Significant Impact With Mitigation (Impact Transportation 6): With implementation of Mitigation Measures Transportation 6A, the Project’s cumulative impacts at the following 3 intersections would be reduced to a less than significant level: i. At Forbes Boulevard/Allerton Avenue (Intersection #8), the improvements identified in MM Transp 6A(a) would improve Cumulative intersection operations to an acceptable LOS B in the AM and LOS C in the PM peak hour. ii. At Grand Avenue/Littlefield Avenue (Intersection #23), the improvements identified under MM Transp 6A(b) would reduce Cumulative delay to LOS D in the AM peak hour. iii. At Mitchell Avenue/Harbor Way (Intersection #24), the improvements identified under MM Transp 6A(c) would improve Cumulative intersection operations to LOS D in the AM peak hour and LOS B in the PM peak hour. Finding of Significant and Unavoidable Impacts (Impact Transportation 6): Even with implementation of Mitigation Measures Transportation 6A and 6B, the Project’s impacts at the following 19 intersections could not be reduced to a less than significant level. None of the improvements identified in MM Transportation 6B are currently included under the City’s East Genentech Campus Master Plan Update – CEQA Findings page 70 of 101 Transportation Impact Fee Program or in the City’s Capital Improvement Program (CIP). Updating the City’s Transportation Impact Fee Program and CIP to include these additional improvements is a separate discretionary action that may or may not be taken by the City. If a fair-share funding mechanism were to be established by the City to provide for fair-share payments toward improvements needed to address cumulative traffic congestion, traffic impacts at the following intersections could be reduced to less than cumulatively significant at the following intersection: i. At Utah Avenue/Harbor Way (Intersection #25), the measures identified under MM Transp 6B(i) would improve cumulative intersection operations to LOS B in the AM and PM peak hours. However, these improvements do not have an identified funding source, and implementation of this mitigation cannot be ensured. If a funding mechanism were to be established by the City to provide for fair-share payments toward improvements needed to address cumulative traffic congestion at the following intersections, the City cannot ensure that traffic impacts would be reduced to less than cumulatively significant because these intersections are under the jurisdiction of Caltrans and the City cannot ensure that improvements can be made: ii. At Dubuque Avenue/US-101 Ramps (Intersection #3), the measures identified under MM Transp 6B(b) would reduce cumulative delay to achieve LOS D during the AM and PM peak hour, and would reduce eastbound left/through queue length to an acceptable level in the PM peak hour. However, there is no identified funding source for this cumulative mitigation, and this intersection is under the jurisdiction of Caltrans and the City cannot ensure this mitigation could be implemented. iii. At Dubuque Avenue/Grand Avenue (Intersection #11), the measures identified under MM Transp 6B(e) would measure would improve Cumulative intersection operations to an acceptable LOS D in the PM peak hour. However, there is no identified funding source for this cumulative mitigation, and this intersection is under the jurisdiction of Caltrans and the City cannot ensure this mitigation could be implemented. iv. At I-380 Eastbound Ramp/South Airport Boulevard (#27), the measures identified under MM Transp 6B(k) would improve cumulative intersection operations to an acceptable LOS D in the PM peak hour. However, these improvements do not have an identified funding source, and this intersection is under the jurisdiction of Caltrans and the City cannot ensure this mitigation could be implemented. Even if a fair-share funding mechanism were to be established by the City to provide for fair- share payments toward improvements needed to address cumulative traffic congestion, traffic impacts at the following intersections could not be reduced to less than cumulatively significant at the following intersections: v. At Airport Boulevard/Sister Cities Boulevard/Oyster Point Boulevard (Intersection #1), the measures identified under MM Transp 6B(a) would improve cumulative intersection operations to an acceptable LOS D, but would not reduce the length of the southbound left turn or southbound right turn vehicle queues to an acceptable level. There is no identified funding source for this cumulative mitigation, and there no other feasible mitigations at this location due to restricted right-of-way. Genentech Campus Master Plan Update – CEQA Findings page 71 vi. At Dubuque Avenue/Oyster Point Boulevard (Intersection #2), there are no feasible mitigation measures for this location due to constrained right of way. vii. At Oyster Point Boulevard/Gateway Boulevard (Intersection #4), the measures identified under MM Transp 6B(c) would decrease delay and improve cumulative operations to an acceptable level of service in the AM peak hour, but would not improve Cumulative operations to an acceptable level of service in the PM peak hour and would not reduce cumulative queuing to acceptable lengths. There is no identified funding source for this cumulative mitigation, and this intersection is under the jurisdiction of Caltrans and the City cannot ensure this mitigation could be implemented. viii. At Oyster Point Boulevard/Veterans Boulevard (Intersection #5), there are no identified feasible mitigations at this intersection due to constrained right-of way. ix. At Oyster Point Boulevard/Eccles Avenue (Intersection #6), there are no identified feasible mitigations at this intersection due to constrained right-of way. x. At Gull Drive/Forbes Boulevard (Intersection #9), there are no identified feasible mitigations at this intersection due to constrained right-of way. xi. At Airport Boulevard/Miller Avenue/US-101 SB Off-Ramp (Intersection #10), the measures identified under MM Transp 6B(d) would improve Cumulative intersection operations to an acceptable LOS D in the PM peak hour. However, there is no identified funding source for this cumulative mitigation, and this intersection is under the jurisdiction of Caltrans and the City cannot ensure this mitigation could be implemented. xii. At Airport Boulevard/Grand Avenue (Intersection #12), there are no feasible mitigations at this intersection because any changes to Grand Avenue or Airport Boulevard to add vehicle capacity would be inconsistent with the Pedestrian Priority Zone identified in the South San Francisco Station Area Specific Plan. xiii. At East Grand Avenue/Gateway Boulevard (Intersection #15), there are no viable mitigations at this intersection because additional roadway widening would conflict with the City of South San Francisco’s Complete Streets Policy by further lengthening pedestrian crossing distances in an area with a high expected pedestrian demand. xiv. At East Grand Avenue/Harbor Way/Forbes Boulevard (Intersection #16), there are no identified feasible mitigations at this intersection due to constrained right-of way. xv. At Produce Avenue/Airport Boulevard/San Mateo Avenue (Intersection #19), the measures identified under MM Transp 6B(f) would decrease delay but would not improve cumulative operations to an acceptable level of service. There are no additional feasible mitigations at this intersection due to constrained right-of way. xvi. At South Airport Boulevard/Gateway Boulevard (Intersection #20), the measures identified under MM Transp 6B(g) would not improve Cumulative operations to an acceptable level of service, and there are no additional feasible mitigations at this intersection due to constrained right-of way. Genentech Campus Master Plan Update – CEQA Findings page 72 xvii. At South Airport Boulevard/US-101 On- and Off-Ramps (Intersection #21), there are no feasible mitigations at this intersection due to constrained roadway right-of-way. xviii. At South Airport Boulevard/Utah Avenue (#22), the measures identified under MM Transp 6B(h) would not achieve an acceptable level of service in the AM peak hour, and there are no additional feasible mitigations at this intersection due to constrained right-of way. xix. At Westbound Ramp/South Airport Boulevard (#26), the measures identified under MM Transp 6B(j) would improve intersection operations to an acceptable LOS D in the PM peak hour, but would not result in decreased queue lengths on the southbound right turn movement. There are no additional feasible mitigations at this intersection due to constrained right-of way. 123. Impact Transportation 7, Freeway Ramps (Cumulative plus Project): The Project would generate more than 100 peak hour trips onto the Congestion Management Program roadway network, contributing to cumulative traffic levels that would conflict with applicable plans, ordinances or policies that establish measures for effective levels of service at two nearby freeway interchanges. Based on the analysis of cumulative traffic operations at freeway ramps near the study area, the Project would individually contribute traffic at levels considered cumulatively significant at each of the two nearby freeway interchanges.  US-101/Oyster Point Boulevard Interchange: The Project would contribute more than one percent of the cumulative PM peak hour traffic to the northbound on-ramp, which is already expected to operate at LOS F condition in the Cumulative/No Project scenario.  US-101/Produce Avenue Interchange: The Project would contribute more than one percent of the cumulative AM peak hour traffic to the northbound off-ramp, causing the off-ramp to decline from LOS E in the Cumulative/No Project scenario to LOS F condition. Mitigation Measures No mitigation measures are available due to constrained rights-of-way and inability to add capacity. Finding of Significant and Unavoidable Impact (Impact Transportation 7): There are no feasible mitigation measures for these impacts to freeway interchanges. The northbound freeway on-ramp at Oyster Point Boulevard has a constrained right-of-way, and the Produce Avenue northbound off-ramp also has constrained right-of-way and a lack of capacity on surface roadways to accommodate more exiting vehicles. These freeway segments are under the jurisdiction of Caltrans, and even if improvements were feasible, the City could not ensure their implementation. These impacts remain significant and unavoidable. Consistent with C/CAG guidelines, the Project will implement a TDM program that is consistent with, and exceeds City requirements. That TDM program will serve to reduce its otherwise greater contribution of trips on the CMP network, including its contributions of traffic to freeway interchanges. 124. Impact Transportation 8, Freeway Segments (Cumulative plus Project): The Project would generate more than 100 peak hour trips onto the Congestion Management Program roadway network, contributing to cumulative traffic levels that would conflict with applicable plans, ordinances or policies that establish measures for effective levels of service on the freeway. No feasible improvements have been identified as capable of reducing impacts to less than significant levels. The impact of Project-generated traffic at each of the adversely affected freeway segments is described below. Genentech Campus Master Plan Update – CEQA Findings page 73  Northbound US-101, north of Oyster Point Boulevard: This northbound freeway segment is projected to operate at LOS F conditions during both the AM and PM peak hours under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during both peak hours.  Southbound US-101, north of Oyster Point Boulevard: This southbound freeway segment is projected to operate at LOS F conditions during the AM peak hour under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the AM peak hour.  Northbound US-101, between Oyster Point Boulevard and Grand Avenue: This northbound freeway segment is projected to operate at LOS F conditions during both the AM and PM peak hours under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the PM peak hour.  Southbound US-101, between Oyster Point Boulevard and Grand Avenue: This southbound freeway segment is projected to operate at LOS F conditions during the PM peak hour under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the PM peak hour.  Northbound US-101, between Grand Avenue and Produce Avenue: This northbound freeway segment is projected to operate at LOS F conditions during the AM peak hour under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the AM peak hour.  Southbound US-101, between Grand Avenue and Produce Avenue: This southbound freeway segment is projected to operate at LOS F conditions during the PM peak hour under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the PM peak hour.  Northbound US-101, south of Produce Avenue: This northbound freeway segment is projected to operate at LOS F conditions during the AM peak hour under Cumulative/No Project conditions, and the Project would contribute more than 1 percent of the cumulative traffic on this freeway segment during the AM peak hour. Mitigation Measures No mitigation measures are available. Finding of Significant and Unavoidable Impact (Impact Transportation 8): There are no feasible mitigation measures for these impacts to freeway segment due to constrained right of way on US-101. These freeway segments are under the jurisdiction of Caltrans, and even if improvements were feasible, the City could not ensure their implementation. These cumulative impacts remain significant and unavoidable. Consistent with C/CAG guidelines, the Project will implement a TDM program that is consistent with, and exceeds City requirements. That TDM program will serve to reduce its otherwise greater contribution to cumulative trips on the CMP network, including increased traffic on US-101 freeway segments. XII. FINDINGS REGARDING ALTERNATIVES 125. CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur. The concept of “feasibility” encompasses the question of whether a particular alternative or mitigation Genentech Campus Master Plan Update – CEQA Findings page 74 measure promotes the underlying goals and objectives of the a project (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417 (City of Del Mar); Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, 1506-1509 [court upholds CEQA findings rejecting alternatives in reliance on applicant’s project objectives]; see also California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001 (CNPS) [“An alternative ‘may be found infeasible on the ground that is inconsistent with the Project objectives as long as the finding is supported by substantial evidence in the record’”] (quoting Kostka & Zischke, Practice Under the Cal. Environmental Quality Act [Cont.Ed.Bar 2d ed. 2009] (Kostka), § 17.39, p. 825); In re Bay-Delta Programmatic Environmental Impact Report Coordinated Proceedings (2008) 43 Cal.4th 1143, 1165-1166 (Bay Delta) [“In the CALFED program, feasibility is strongly linked to achievement of each of the primary objectives”; “A lead agency may structure its EIR alternative analysis around a reasonable definition of underlying purpose and need not study alternatives that cannot achieve that basic goal”].) Moreover, “‘feasibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, legal, and technological factors.” (City of Del Mar, supra, 133 Cal.App.3rd at 417; see also CNPS, supra, 177 Cal.App.4th at 1001 [“An alternative that ‘is impracticable or undesirable from a policy standpoint’ may be rejected as infeasible”] (quoting Kostka, supra, § 17.29, p. 824]; San Diego Citizenry Group v. County of San Diego (2013) 219 Cal.App.4th 1, 17.) 126. The City Council finds that specific economic, social, environmental, technological, legal or other considerations make infeasible the alternatives to the Project as analyzed in the EIR despite the remaining impacts, as more fully set forth in the Statement of Overriding Considerations below. The only significant unavoidable impacts of the Project that cannot be fully mitigated through the mitigation measures regulatory requirements described in the EIR are certain air quality, noise and traffic impacts, as described in these Findings. 127. The City Council adopts the EIR's analysis and conclusions, eliminating from further consideration both the No New Development Alternative and the Alternative Site Location. The EIR does not analyze nor does it foresee any “no build” scenario under which there is no new development beyond what exists at the Campus under the current baseline condition. There is no information to suggest that development of up to approximately 4.3 million square feet of Genentech operational facilities at any identified off-site locations would avoid or substantially lessen any significant effects of the Project, but instead would likely transfer those effects from one place to another. 128. The EIR evaluated a reasonable range of alternatives to the Project. The EIR identified two alternatives to the Project, in addition to the No Project alternative required by CEQA. These alternatives represent a reasonable range of potentially feasible alternatives that reduce one or more significant impacts of the Project. These alternatives include Alternative #1: No Project, Alternative 2: Reduced Project, and Alternative 3: Alternative Mix of Land Uses. 129. The three CEQA alternatives proposed and evaluated in the EIR are rejected for the following reasons. Each individual reason presented below constitutes a separate and independent basis to reject the alternative as being infeasible. No Project Alternative: Under the No Project Alternative, the current 2007 Master Plan and the existing Genentech Master Plan Zoning District (Chapter 20.260 of the City of South San Francisco Zoning Code) would remain in place as the guiding land use policies and regulations for the Campus. Consistent with growth projections as analyzed in the prior 2007 Master EIR and 2012 Supplemental Master EIR, new development within the Campus would remain limited to a maximum buildout of up to 6 million square feet of building space, plus the 821,000 square Genentech Campus Master Plan Update – CEQA Findings page 75 feet added as the South Campus (originally the Britannia East Grand project) in 2013. Buildout of the No Project Alternative #1 would be limited to a maximum of 2.1 million square feet of net new development on the Campus, over the current baseline of approximately 4.7 million square feet, for a total of approximately 6.8 million square feet. This building space would be further regulated by land use type and by sub-campus location as indicated in the 2007 Campus Master Plan. The No Project Alternative is rejected as infeasible because: (a) it would not achieve any of the Project sponsor’s objectives for the Project; (b) although certain environmental effects would be reduced under the No Project Alternative as compared to the Project, these reductions are either not fully capable of reducing impacts to less than significant levels, or are not necessary to reduce any significant impacts of the Project that are not otherwise reduced through implementation of regulatory requirements or mitigation measures; (c) the No Project Alternative continues limitations on growth and development within the Genentech Campus that were originally established pursuant to Chapter 20.260 of the City of South San Francisco Zoning Code as being temporary, through the year 2017 only, and (d) the No Project alternative continues limitations on growth and development within the Genentech Campus that are more restrictive (i.e., a lower effective FAR) than other properties throughout the East of 101 Area. In addition, the No Project Alternative is rejected as infeasible because it development restrictions would ensure that this alternative would not promote the City’s goals and policies regarding future use of the Project site, as described in the East of 101 Area Plan, to the same extent as the Project. For example, by restricting net new development of the Project site with new office and administrative facilities, research and development uses, biotechnology manufacturing, and warehouse and distribution facilities, the No Project Alternative would not promote or advance the City’s goals of encouraging development that enhances net revenues to the City, of promoting development that creates quality jobs for the City, and of encouraging use of the East of 101 planning area as a commercial center, to the same extent as would the larger Project. For the same reason, the No Project Alternative would not promote or advance the City’s policies of evaluating development proposals on the basis of the net benefits they would provide to the City, and the City’s policy that new development in the East of 101 area reflect market conditions, enhance property values and property tax revenues, and be constructed at densities and intensities that are similar to surrounding development. Further, the No Project Alternative 2 is rejected as infeasible due to inconsistencies with the City’s Economic Development Element of the General Plan, which provides a policy framework for ensuring South San Francisco’s long-term business competitiveness in the region. Policy 6-I-6 of the Economic Development Element seeks "the creation of campus environments in the East of 101 area", and promotes the area as "a high amenity growth-based industrial activity center". This policy identifies the biotech/R&D industry as, "South San Francisco’s largest industrial cluster, and the General Plan permits a doubling of current employment at buildout. It is vital for the City to strive to create an environment that is beneficial in realizing this development potential to maintain the City’s competitive edge in this industry." The Project would not only, "enhance the prestige of South San Francisco as the biotech/R&D capital", but would also "promote the City as a high amenity location for these activities." The Project is precisely the type of development promoted pursuant to this Economic Development policy. Genentech is a biotechnology leader and is firmly established in the East of 101 Area with an already well- defined campus. The Project provides for new growth and development within the Genentech Campus, and provides for continuation of high-level landscaping and design, a unified signage Genentech Campus Master Plan Update – CEQA Findings page 76 and wayfinding system, orchestrated streetscapes, nearby services including child-care programs, and access to park land or open space. The No Project Alternative does not provide for the extent of growth and development in the biotech/R&D industry that the City recognizes as essential to enhance and maintain South San Francisco's prestige as the region's biotech/R&D capital. Alternative 2: Reduced Project: Alternative 2 would establish an overall growth limit within the Genentech Campus boundaries of up to 7.9 million square feet, or an overall floor area ratio (FAR) of 0.88 times the total area of the approximately 208-acre Campus. A 7.9 million square- foot buildout potential represents a mid-point between the 6.8 million square-foot buildout of the currently effective 2007 Master Plan, and the 9 million square-foot buildout potential of the proposed Project. Alternative 2 would enable construction of approximately 3.2 million square feet of net new building space. Buildout of up to 7.9 million square feet would exceed the 6 million square-foot building space cap on the original 2007 Master Plan, and modifications to the existing Genentech Master Plan Zoning District would be necessary to accommodate this increase in building space. Alternative 2 is rejected as infeasible because: (a) it would not achieve most of the Project sponsor’s objectives for the Project; (b) although certain environmental effects would be reduced under the Alternative 2 as compared to the Project, these reductions are either not fully capable of reducing impacts to less than significant levels, or are not necessary to reduce any significant impacts of the Project that are not otherwise reduced through implementation of regulatory requirements or mitigation measures; (c) Alternative 2 places limitations on growth and development within the Genentech Campus that are more restrictive (i.e., a lower effective FAR) than other properties throughout the East of 101 Area; and (d), it is uncertain whether Genentech would propose to include the same Trip Cap and commensurate TDM program under Alternative 2 as is proposed under the Project. Rather, it is assumed that Genentech would instead meet the trip reduction rate consistent with current City requirements. Pursuant to SSF Municipal Code section 20.400.003, whereby projects within the Business and Technology Park land use designation and with a FAR of between 0.8 and 1.0 are required to achieve a minimum trip reduction rate of 35 percent, substantially lower than the 50% TDM goal and Trip Cap as would be achieved under the Project. In addition, the Alternative 2 is rejected as infeasible because it development restrictions would ensure that this alternative would not promote or advance the City’s goals and policies regarding future use of the Project site, as described in the East of 101 Area Plan, to the same extent as the Project. For example, by restricting net new development of the Project site with new office and administrative facilities, research and development uses, biotechnology manufacturing, and warehouse and distribution facilities, Alternative 2 would not promote or advance the City’s goals of encouraging development that enhances net revenues to the City, of promoting development that creates quality jobs for the City, and of encouraging use of the East of 101 planning area as a commercial center, to the same extent as would the larger Project. For the same reason, Alternative 2 would not promote or advance the City’s policies of evaluating development proposals on the basis of the net benefits they would provide to the City, and the City’s policy that new development in the East of 101 area reflect market conditions, enhance property values and property tax revenues, and be constructed at densities and intensities that are similar to surrounding development. Likewise, Alternative 2 would not encourage or support transportation modes other than single-occupancy automobiles including Genentech Campus Master Plan Update – CEQA Findings page 77 ridesharing, bicycling, walking and transit, as compared to the Project, as it would result in more AM peak hour trips as compared to the Project. Further, Alternative 2 is rejected as infeasible due to inconsistencies with the City’s Economic Development Element of the General Plan, which provides a policy framework for ensuring South San Francisco’s long-term business competitiveness in the region. Policy 6-I-6 of the Economic Development Element seeks "the creation of campus environments in the East of 101 area", and promotes the area as "a high amenity growth-based industrial activity center". This policy identifies the biotech/R&D industry as, "South San Francisco’s largest industrial cluster, and the General Plan permits a doubling of current employment at buildout. It is vital for the City to strive to create an environment that is beneficial in realizing this development potential to maintain the City’s competitive edge in this industry." The Project would not only, "enhance the prestige of South San Francisco as the biotech/R&D capital", but would also "promote the City as a high amenity location for these activities." The Project is precisely the type of development promoted pursuant to this Economic Development policy. Genentech is a biotechnology leader and is firmly established in the East of 101 Area with an already well- defined campus. The Project provides for new growth and development within the Genentech Campus, and provides for continuation of high-level landscaping and design, a unified signage and wayfinding system, orchestrated streetscapes, nearby services including child-care programs, and access to park land or open space. Alternative 2 does not provide for the extent of growth and development in the biotech/R&D industry that the City recognizes as essential to enhance and maintain South San Francisco's prestige as the region's biotech/R&D capital. Alternative 3: Alternative Mix of Land Uses: To maximize flexibility, the Project allows the land use mix within the Campus to evolve over time, depending upon Genentech’s future needs. To provide detail and specificity for the EIR, the Project Description provides one potential detailed buildout scenario that meets the goals of the Master Plan Update, and is used in this EIR for qualitative and quantitative analytical purposes. Under Alternative 3, the overall net new development within the Campus would be retained at approximately 4.3 million square feet (the same as the Project), but the mix of land uses within the Campus would be fixed (rather than flexible), and with a substantially different mix of land use types, as follows: 1.7 million square feet of net new office space, 2 million square feet of net new lab space, 300,00 square feet of net new manufacturing space and 300,00 square feet of new employee amenity space. Alternative 3 presents a scenario as to how the Project Area may develop over time, but with an established, or “fixed” composition of future land uses that is substantially different than the EIR Project Description, representing a shift from higher trip-generating office land use to lower trip- generating lab and manufacturing space uses. One of the purposes of this Alternative 3 was to determine whether such a different land use mix may result in reduced environmental effects as compared to the Project. Alternative 3 is rejected as infeasible because: (a) it would not achieve the Project sponsor’s objectives for a Master Plan that provides flexibility to meet building space needs that can adapt to changes and advancement in science and technology – a core element of the Project sponsors business; (b) the potential environmental effects under Alternative 3 are, in most respects, the same as the Project, resulting from the same buildout potential of 9 million square feet of total building space occurring on the same Opportunity Sites, and with employment growth and new land uses of the same office, lab and amenity space types as those of the Project; (c) the increased emphasis on new lab space as compared to office space would likely result in a greater demand on water supply than the Project; (d) the increased emphasis on new Genentech Campus Master Plan Update – CEQA Findings page 78 lab space as compared to office space would likely result in air quality operational health risks that would be relatively more substantial than the proposed project; and (e) Alternative 3 places limitations on growth and development within the Genentech Campus that are more restrictive (i.e., a lower effective FAR) than other properties throughout the East of 101 Area and thus would not promote or advance the City’s East of 101 Area Plan policy that new development in the East of 101 area reflect market conditions and be constructed at densities and intensities that are similar to surrounding development. 130. As presented in the EIR, the alternatives were described and compared with each other and with the proposed Project. Alternative 1: No Project Alternative is the environmentally superior alternative based on order of magnitude effects. Because the No Project Alternative has been identified as the environmentally superior alternative, CEQA requires the lead agency to identify another alternative that would be considered environmentally superior in the absence of the No Project Alternative. Excluding the No Project Alternative, Alternative 2: Reduced Project is the environmentally superior alternative based on order of magnitude effects. However, none of the alternatives, even the environmentally superior alternative, is capable of changing a significant impact of the Project to less than significant, or is capable of fully avoiding an environmental effect of the Project. Rather, the differences between the Project and the alternatives are measured in relative magnitude. 131. The City Council certifies that it has independently reviewed and considered the information on alternatives provided in the EIR and in the record. The EIR reflects the City Council's independent judgment as to alternatives. The City Council finds that the Project provides the best balance between the project sponsor's objectives, the City's goals and objectives, the Project's benefits as described below in the Statement of Overriding Considerations, and mitigation of environmental impacts to the extent feasible. XIII. STATEMENT OF OVERRIDING CONSIDERATIONS 132. CEQA requires a public agency to balance the benefits of a proposed project against its significant unavoidable adverse impacts in determining whether to approve a project. The Project will result in environmental effects, which, although mitigated to the extent feasible by the implementation of mitigation measures required for the Project, will remain significant and unavoidable, as discussed in the EIR and these Findings. 133. The City Council finds that each of the specific economic, legal, social, technological, environmental, and other considerations and benefits of the Project separately and independently outweigh the Project’s significant, adverse impacts, and each overriding consideration independently warrants Project approval, so that if a court were to set aside the determination that any particular benefit or consideration will occur and justifies project approval, this City Council determines that it would stand by its determination that the remaining benefit(s) and consideration(s) is or are sufficient to warrant Project approval. The remaining significant adverse impacts identified above are acceptable in light of each of these overriding considerations. 134. The Project helps advance South San Francisco’s economic development goals of enhancing the competitiveness of the local economy, and maintaining a strong and diverse revenue and job base. One of the City’s main economic development goals is to support the growth and sustainability of the biotechnology industry cluster in the East of 101 Area, home to more than 200 of the most innovative biotechnology companies in the world. Genentech is the largest of these companies, the principal employer in the City, and the largest single biotechnology research facility in the world. The Genentech Campus Master Plan Update – CEQA Findings page 79 City has been, and continues to be purposeful about planning for growth of the biotechnology industry by providing city services and infrastructure, enabling this industry to expand and to attract more biotechnology companies to the area.1 The Genentech Master Plan Update (the Project) will result in new state-of-the-art facilities that will enhance the overall marketability of the East of 101 Area as a high-technology and biotechnology center, further strengthening the City’s fiscal base. 135. The Project is specifically intended to help facilitate Genentech’s ability to advance their research, development and manufacture of biological medicines designed to treat serious or life- threatening medical conditions. The Project will also provide additional building space that may enable the discovery of new medicines that may prove effective in the fight against neurological disorders and disease. 136. The Project will generate substantial regional economic and employment benefits from Genentech spending and employment, as money spent by Genentech and its employees is cycled through the economy. 2 Genentech currently has approximately 12,000 workers employed on Campus in South San Francisco. The annual labor income and compensation for Genentech workers totals approximately $2.2 billion. Of the total $2.2 billion in annual compensation, $106 million goes to workers residing in South San Francisco, and $876 million goes to workers living in San Mateo County. The Project is expected to accommodate an additional approximately 12,000 new workers employed on Campus in South San Francisco, with a corresponding increase in annual labor income and compensation. Genentech’s South San Francisco Campus also creates substantial employment and earnings for South San Francisco, San Mateo County, and beyond, as the company’s earnings and its own employees generate multiplier effects through payments to suppliers and worker household expenditures. Currently, Genentech is estimated to account for 13,200 direct and indirect jobs in South San Francisco, with worker compensation totaling $2.4 billion annually. For San Mateo County, Genentech currently provides or supports 22,700 jobs with total compensation valued at 3.6 billion annually. At buildout of the Project, this would increase to 54,600 estimated jobs and $8.5 billion in annual compensation for countywide workers. Genentech’s total annual average construction impacts over an assumed 30-year buildout period are also significant, including approximately 2,300 construction-related jobs in South San Francisco, 2,700 construction-related jobs throughout San Mateo County. Total annual labor income generated by Genentech construction is anticipated to be $230 million for jobs in South San Francisco and $273 million in San Mateo County. 137. The Project will generate additional construction-related benefits, including economic and fiscal benefits related to new construction.3 Based on Genentech’s current construction cost estimates, Genentech will spend approximately $12.8 million on hard construction costs for projects at the South San Francisco campus over the next 30 years, including almost $6.1 million to construct new buildings and $6.8 million for ongoing 1 City of South San Francisco, https://www.ssf.net/our-city/biotech/biotech-in-ssf 2 BAE Urban Economics, Economic and Fiscal Benefits of Genentech’s South San Francisco Campus, April 29, 2019 3 Ibid Genentech Campus Master Plan Update – CEQA Findings page 80 capital improvements to existing facilities, averaging an estimated $428 million per year on hard construction costs in South San Francisco. These expenditures have both economic impacts by generating jobs and labor income as well as generating local tax revenue The Project will generate revenues to the City of South San Francisco from impact fees and capital facilities charges that the City assesses on new construction, and will also generate construction use taxes that accrue to the City of South San Francisco and the County of San Mateo. Additionally, Genentech’s development program would generate additional indirect economic output as the dollars spent on construction circulate through the local and regional economies. On an annual average basis, this additional possible benefit is estimated at $11 million in South San Francisco and $114 million in San Mateo County. 138. The Project will generate fiscal benefits to South San Francisco and San Mateo County due to taxes and other revenue sources from Genentech operations. 4 With the Project, Genentech will generate a larger positive net fiscal impact on the City of South San Francisco and County of San Mateo. With full buildout of the Project, Genentech’s South San Francisco campus will generate an estimated $18.8 million in total annual operating revenue to the City of South San Francisco General Fund in the form of property taxes, property tax in-lieu of Vehicle License Fees, sales taxes, transit occupancy taxes and business license fees. With full buildout of the Project, Genentech’s South San Francisco campus will also generate an estimated $22.3 million to the County of San Mateo General Fund in the form of property taxes, property tax in-lieu of Vehicle License Fees and sales taxes. The annual net fiscal impact on the City of South San Francisco is projected to total $9.9 million in revenue to the City net of service costs. The annual net fiscal impact on the County of San Mateo is projected to total $7.6 million in revenue to the County net of service costs. The City and County will be able to use these revenues for a range of purposes, such as police and fire protection, infrastructure projects, affordable housing, public health initiatives, and recreational opportunities. 139. In addition to the economic and fiscal benefits described above, Genentech provides a range of other economic and community benefits through the company’s charitable giving. Important examples of Genentech’s programs “for Good” include the following: Genentech invests in science education through the Futurelab program, a partnership between Genentech and the South San Francisco Unified School District to bring hands-on STEM education to the South San Francisco public schools at every grade level. Futurelab gets students excited to learn about science, improves their college readiness, and inspires them to pursue careers in science. Since its launch in 2015, Futurelab represents an investment by Genentech of more than $25 million in support of science education in the South San Francisco Unified School District, including over 61,000 employee volunteer hours providing science education for more than 8,000 students, professional development for SSFUSD science teachers, scholarships for students to study STEM, computer and iPad donations, mentoring, on-Campus tours and biotech lab coursework.5 Through the Genentech Foundation, Genentech has provided a $10.5 million grant over five years to San Francisco State University to support 100 under-represented and low-income students per year along their academic journey, expanding on a decade of support to SFSU through scholarships to the 4 Ibid Genentech Campus Master Plan Update – CEQA Findings page 81 College of Science & Engineering. The Genentech Foundation is also helping to dismantle barriers for under-represented students interested in science and medicine through grants to the University of California, Davis and the American Chemical Society. The Project includes a commitment to continue this community giving by establishing and implementing a grant program pursuant to which Genentech will make individual community benefit grants directly to a variety of community organizations, community events, or community programs operating within the City, with the total grant awards to total at least $100,000.00 per year over a minimum of fifteen years. 140. The Project will further implement Genentech’s demonstrated history of incorporating environmentally sustainable practices into its everyday operations and major initiatives, with the goal of achieving increasingly high standards that exceed regulatory requirements and CEQA thresholds. Genentech reduces the environmental impact of its South San Francisco Campus through a range of transportation demand management initiatives. Genentech offers bus transportation for employees and financially encourages employees to commute via carpool or vanpool, significantly reducing the number of single-driver car trips, and reimburses employees for any out-of-pocket transit expenses to encourage commuting by public transit. Overall, 42 percent of employees who commute to South San Francisco arrive via a mode other than single-occupant vehicles. Combined with its flexible work initiate, approximately 50 percent of Genentech employees at the South San Francisco Campus participate in some form of alternative Transportation Demand Management (TDM) program. The Project’s includes a commitment to further increase this TDM participation rate, coupled with a Trip Cap that places a matching limit on the number of single occupant vehicles that can arrive at the Campus. In advance of those commitments, Genentech launched a company ferry service for employees and the first fully electric double-decker buses in 2018. Genentech continues to achieve increasingly high standards of environmental sustainability as the company develops new buildings and renovates existing buildings on the South San Francisco campus. Genentech partnered with the Department of Energy’s FLEXLAB at the Lawrence Berkeley National Laboratory to design Building 35, which opened in 2015 and has earned a LEED Gold certification. FLEXLAB created a full mock-up of the building shell and interior to test lighting controls, window coverings, and other design and construction elements, modeling the energy use for the entire building under real-world conditions to optimize energy efficiency. Due largely to this science-based effort, Building 35 consumes 80 percent less energy per person than other similar buildings at Genentech’s South San Francisco campus. In addition, water-efficiency features in Building 35 have lessened water use by 35 percent. During construction, 98 percent of the construction debris from Building 35 was diverted from landfills. Genentech has subsequently opened Building 34, which achieved LEED Gold certification and is expected to achieve WELL certification, and a new Childcare Center which achieved LEED Platinum certification and is the South San Francisco campus’ first zero net energy building. In 2015, Genentech’s Sustainability Program launched a new set of sustainability goals for the South San Francisco Campus, to be achieved by year 2020. The year 20202 energy goal was to reduce CO2 emissions from on-site energy use by 30% compared to 2010. As of 2018, Genentech had exceed that goal, with 34% lower CO2 emissions since 2010 as a result of continued reduction in energy use, a new onsite solar installation and an increase in the use of clean energy. The year 2020 water use goal to was reduce total water use by 20% compared to 2010. In 2018, Genentech used 20 million gallons less water (or a 12% decrease compared to 2010), partially driven by a large increase in use of internally recycled water. Genentech continues to research and development new means by Genentech Campus Master Plan Update – CEQA Findings page 82 which to lower it water use in manufacturing, the biggest contributor to total water use. The year 2020 waste diversion goal was to achieve an 80% reduction in waste to landfill per employee compared to 2010. Despite a significant shift in the international plastics recycling market, Genentech succeeded in reducing waste to landfill per employee by almost 50% by 2018, successfully diverting 4 million pounds of compostable material and 4.5 million pounds of recyclables.6 141. The Project will provide publically accessible open space to be improved with at least $10,000,000.00 worth of active and passive recreational improvements. The Project will also provide publically accessible public art works for each 200,000 square feet of new office, lab, and manufacturing building space. 3569308.1