HomeMy WebLinkAboutGenentech Master Plan Update Final EIRGenentech Campus Master Plan Update
Response to Comments / Final
Environmental Impact Report
SCH # 2017052064
Lead Agency: City of South San Francisco
May 2020
Prepared for:
City of South San Francisco Planning Division
315 Maple Avenue
South San Francisco, CA 94080
Prepared by:
LAMPHIER-GREGORY
Genentech Master Plan Update, Draft EIR Page i
Table of Contents
Genentech Master Plan Update
Final EIR
Chapter Number Page
1: Introduction and Executive Summary
Purpose of the Final EIR ............................................................................................................................. 1-1
No New Significant Information .................................................................................................................. 1-2
Organization of this Final EIR ...................................................................................................................... 1-3
Uses of this Final EIR .................................................................................................................................. 1-3
Summary of Impacts, Alternatives and Mitigation Measures .................................................................... 1-6
2: Responses to Comments on the Draft EIR
Introduction ................................................................................................................................................ 2-1
Letter A and Responses, State of California, Governor’s Office of Planning and Research ........................ 2-2
Letter B and Responses, Caltrans District 4 ................................................................................................ 2-4
Letter C and Responses, California Highway Patrol ................................................................................... 2-9
Letter D and Responses, San Mateo County Department of Public Works ............................................. 2-11
Letter E and Responses, City of San Bruno .............................................................................................. 2-16
Letter F and Responses, San Francisco International Airport .................................................................. 2-20
Letter G and Responses, Rob Lau ............................................................................................................. 2-24
Letter H and Responses, Koray Ergur ....................................................................................................... 2-26
3: Revisions to the Draft EIR
Introduction ................................................................................................................................................ 3-1
Changes and Corrections to the Draft EIR -VMT ........................................................................................ 3-1
Changes and Corrections to the Draft EIR – LOS Analysis ........................................................................ 3-10
4: References
Report Preparers and Contacts ................................................................................................................... 4-1
Additional References – Final EIR ............................................................................................................... 4-2
List of Tables and Figures
Table Number Page
1-1 Summary of Project Impacts and Mitigation Measures ............................................................... 1-10
Figure Number Page
2-1 Colma Creek Flood Control Zone ................................................................................................. 2-14
2-2 South San Francisco Storm Drain System MS4 Map .................................................................. 2-15
Genentech Master Plan Update, Final EIR Page 1- 1
1
Introduction and Executive Summary
Purpose of the Final EIR
This Environmental Impact Report (EIR) is an informational document prepared by the City of South San
Francisco as Lead Agency, containing environmental analysis for public review and for City decision-makers to
use in their consideration of approvals for discretionary actions needed on the proposed Genentech Master
Plan Update Project (Project).
On November 8, 2019, the City of South San Francisco released a Draft EIR for the Project. 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 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.
This Response to Comments document, together with the Draft EIR and the Draft EIR Appendices, constitute
the Final EIR for the Project. Due to its length, the full text of the Draft EIR is not included within this
Response to Comments document, but is incorporated by reference as part of the Final EIR. The Draft EIR is
available for review at the City Planning Division offices at 315 Maple Avenue in South San Francisco, and on
the City’s website at:
http://weblink.ssf.net/weblink/0/fol/424187/Row1.aspx
Following the required 10-day agency review of this Response to Comments document, the City of South San
Francisco will hold a public hearing to consider making a recommendation to the City Council regarding
certification of the Final EIR. The City Council will then hold a separate hearing to consider the Planning
Commission’s recommendations and to determine whether to certify that the Final EIR adequately discloses
the environmental effects of the proposed Project, and that the Final EIR has been completed in
conformance with the California Environmental Quality Act (CEQA). Before the Planning Commission makes
any recommendation to the City Council as to approvals needed for the Project, and before the City Council
considers approval of discretionary actions requested as part of the Project, both the Commission and the
Council must independently review and consider the information contained in the Final EIR.
Required Contents of the Final EIR
The City of South San Francisco has prepared this document pursuant to CEQA Guidelines Section 15132,
which specifies that the Final EIR shall consist of the following:
● The Draft EIR or a revision of that Draft EIR
● A list of persons, organizations, and public agencies commenting on the Draft EIR
● Comments and recommendations received on the Draft EIR (either verbatim or in summary)
● The response of the Lead Agency to significant environmental points raised in the environmental
review process
● Any other information added by the Lead Agency as part of its environmental review of the Project
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-2
This Final EIR incorporates comments from public agencies and the public. It also contains the Lead Agency’s
response to those comments.
Areas of Public Concern
Public comments primarily concern the environmental and CEQA topics discussed below.
● The Project’s consistency with Caltrans District 4 Bike Plan, Project contributions towards access
improvements at the South San Francisco Caltrain Station, impacts related to storage capacity of
intersections near US-101, and the City of South San Francisco’s responsibility as lead agency to
ensure implementation of all required mitigation measures (Caltrans).
● Stormwater runoff from the site (particularly any runoff that may outfall into the Colma Creek flood
control channel), and compliance with Provision C.3 of the Municipal Regional Stormwater NPDES
Permit (MRP) (including requirements to incorporate post-construction stormwater control and low-
impact development measures (San Mateo County Department of Public Works)
● Water supply and demand assumptions presented in the Draft EIR as derived from the Water Supply
Assessment prepared by the California Water Service (CalWater) and provided to the City for use in
the Draft EIR, and projection of wastewater flows to the Water Quality Control Plant (WQCP) (City of
San Bruno)
● The proximity of the Project site to San Francisco International Airport (SFO), and requirements to
consider federal, State and local regulatory reviews specific to airport noise and land use
compatibility standards, Federal Aviation Administration building height restrictions, and airspace
safety criteria of the Airport Land Use Compatibility Plan (SFO)
● The Project’s potential effects on special-status species (Rob Lau)
No New Significant Information
Under section 15088.5 of the CEQA Guidelines, recirculation of an EIR is required when “significant new
information” is added to the EIR after public notice is given of the availability of the Draft EIR for public
review but prior to certification of the Final EIR. The term “information” can include changes in the project or
environmental setting, as well as additional data or other information. New information added to an EIR is
not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to
comment upon a substantial adverse environmental effect of the project, or a feasible way to mitigate or
avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to
implement.
Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or
makes insignificant modifications in an adequate EIR. The above standard is “not intend[ed] to promote
endless rounds of revision and recirculation of EIRs.” (Laurel Heights Improvement Assn. v. Regents of the
University of California (1993) 6 Cal. 4th 1112, 1132.). “Recirculation was intended to be an exception, rather
than the general rule.” (Ibid.)
CEQA case law emphasizes that “‘[t]he CEQA reporting process is not designed to freeze the ultimate
proposal in the precise mold of the initial project; indeed, new and unforeseen insights may emerge during
investigation, evoking revision of the original proposal’” (Kings County Farm Bureau v. City of Hanford (1990)
221 Cal.App.3d 692, 736-737; see also River Valley Preservation Project v. Metropolitan Transit Development
Bd. (1995) 37 Cal.App.4th 154, 168, fn. 11.). “CEQA compels an interactive process of assessment of
environmental impacts and responsive project modification which must be genuine. It must be open to the
public, premised upon a full and meaningful disclosure of the scope, purposes, and effect of a consistently
described project, with flexibility to respond to unforeseen insights that emerge from the process. In short, a
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-3
project must be open for public discussion and subject to agency modification during the CEQA process.”
(Concerned Citizens of Costa Mesa, Inc. v. 33rd Dist. Agricultural Assn. (1986) 42 Cal.3d 929, 936 (internal
citations omitted)). Here, the clarifications and information provided in this Final EIR are exactly the kind of
revisions that the case law recognizes as legitimate and proper.
This Response to Comment document includes certain clarifications of information presented in the Draft
EIR, but does not add significant new information as defined under Section 15088.5 of the CEQA Guidelines.
More specifically:
● No new significant environmental impacts have been identified.
● No substantial increase in the severity of any environmental impact that was previously identified in
the Draft EIR has been identified.
● There is no feasible alternative or mitigation measure considerably different from others previously
analyzed in the Draft EIR that would clearly lessen significant environmental impacts of the Project,
and that the Project applicant declines to adopt.
● The Draft EIR was not fundamentally inadequate or conclusory in nature such that meaningful public
review and comment were precluded.
Information presented in the Draft EIR and in this Response to Comments document supports the City’s
determination that recirculation of the Draft EIR is not required.
Organization of this Final EIR
This Response to Comments document contains responses to comments that were raised during the public
review and comment period on the Draft EIR. Following this Introduction chapter, Chapter 2 of this document
contains a copy of each letter or correspondence received by the City commenting on the Draft EIR, and
provides individual responses to CEQA-related comments raised. Chapter 2 also includes a list of all agencies,
organizations and individuals that submitted written comments on the Draft EIR during the public review and
comment period. On December 19,2019, the City of South San Francisco held a joint Planning
Commission/City Council public hearing on the Project and the Draft EIR. During that hearing, the Planning
Commission and City Council made comments and raised questions regarding the Project (e.g., issues related
to public art, the Project’s proposed Transportation Demand Management program, and the details of how
the Project’s proposed Trip Cap would be implemented, but had no comments specific to the Draft EIR. No
changes or revisions to the Draft EIR are required in response to those comments.
There are no text changes or corrections to the Draft EIR necessitated in response to comments received on
the Draft EIR.
Use of the Final EIR
Pursuant to CEQA, the Final EIR is a public information document for use by governmental agencies and the
public. The information contained in the Final EIR is subject to review and consideration by the City of South
San Francisco, prior to its decision to approve, reject or modify the Project. The South San Francisco City
Council must independently certify that they have reviewed and considered the information in the Final EIR
and that the Final EIR has been completed in conformity with the requirements of CEQA before making any
decision regarding the Project. The Final EIR identifies significant effects that would result from the
implementation of the Project.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-4
City of South San Francisco Approvals
This EIR is intended to provide the environmental review necessary for the following City of South San
Francisco approvals:
● Approval of the proposed Campus Master Plan Update
● Approval of a zoning text amendment to the Genentech Master Plan zoning district (Chapter 20.260
of the City of South San Francisco Zoning Code)
● Approval of a Development Agreement (as may be desired by both Genentech and the City)
If the City of South San Francisco does approve the Genentech Master Plan Update and each of the related
discretionary approvals, this EIR is intended to provide sufficient detail to enable the City and other
responsible governmental agencies to make informed site-specific decisions on future individual
development projects within the Campus. The City intends to use the streamlining and tiering provisions of
CEQA to the maximum feasible extent, so that future environmental review of subsequent discretionary
approvals for individual development projects within the Genentech Campus and public improvement
projects carried out in furtherance of the Campus Master Plan Update are expeditiously undertaken, without
the need for repetitive and redundant environmental review. A nonexclusive list of subsequent discretionary
and ministerial permits and approvals that may be required by the City, beyond those necessary for approval
of this Master Plan Update and zoning text amendments, and which may rely on this EIR in the event CEQA
applies to such permit or approval, includes:
● Conditional Use Permits (pursuant to Chapter 20.260.006(C), Minor Use Permits (pursuant to
Chapter 20.260.006(B), and/or Administrative Review (pursuant to Chapter 20.260.006(A)
● Design Review approvals for individual development projects within the Campus, pursuant to
Chapter 20.480 (“Design Review”) of the City of South San Francisco Zoning Code
● Approval of subdivision maps or lot line adjustments as may be necessary to create individual
development sites
● Encroachment permits for work within and close to public rights-of-way (pursuant to SSF Zoning
Code, Chapter 13.04: Excavation And Construction on Public Property - Regulated)
● Demolition permits, grading permits, and building permits – including compliance with City of South
San Francisco Municipal Code Chapter 15.08, California Building Code and California Seismic Hazards
Mapping Act
● Tree Removal Permit pursuant to South San Francisco Municipal Code 13.30, to be approved before
building permits are issued
● Waste Discharge permits from the Environmental Compliance Officer of the City of SSF
● Submittal of accepted General Construction Activity Storm Water Permit, Notice of Intent and Storm
Water Pollution Prevention Plan (SWPPP), to be submitted prior to receiving a grading or building
permit
To the extent possible, the City of South San Francisco will rely on this EIR to provide environmental review
for subsequent projects or their sites that are analyzed as part of this 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 this EIR. That
consideration will determine whether the subsequent project is exempt from CEQA, whether the subsequent
project warrants preparation of a subsequent or supplemental environmental document, or whether the
subsequent project warrants preparation of focused environmental review limited to certain site-specific
issues.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-5
Other Regulatory Agency Approvals
In addition to the City of South San Francisco, approvals and/or authorizations from a number of other
responsible agencies will or may be required to implement individual development plans pursuant to the
Campus Master Plan Update. These other agencies and their possible approvals pursuant to subsequent,
individual development projects within the Campus may include, but are not limited to the following:
Bay Area Air Quality Management District (BAAQMD)
● Permits for new stationary source of NOx and/or ROG emissions and for modifications to existing
stationary emission sources that result in increased NOx and/or ROG emissions, including the
purchase of offset credits pursuant to BAAQMD Regulation 2-2: New Source Review, Section 302
● Permits for stationary source air emissions and compliance with Regulation 2, Rule 1 for all portable
construction equipment subject to that rule
Bay Conservation and Development Commission
● Bay Plan Permits for any development activities that may occur within the 100-ft shoreline band, also
requiring compliance with biological resource protection policies of the Bay Plan as may be
incorporated into such permits
CalWater
● Granting new water service connections and meters
California Air Resources Board
● Permits for increased cap or trade of stationary source GHG emissions
SF Regional Water Quality Control Board (RWQCB) / State Water Resources Control Board (SWRCB)
● Permit for coverage under the General Construction Activity Storm Water Permit, including approval
of a Stormwater Pollution Prevention Plan (SWPPP)
● National Pollutant Discharge Elimination System (NPDES) permits for post-construction stormwater
controls and low-impact development (LID) measures, including individual Stormwater Management
Plans meeting Provision C.3 of the MRP
● Section 401 permit for discharge of dredged or fill material pursuant to Section 401 of the Clean
Water Act and the Porter-Cologne Water Quality Control Act. Although drainage channels within the
site lack many of the habitat features usually present in jurisdictional waters of the State, there is
some possibility these drainage ditches may be claimed as jurisdictional by the RWQCB. If the
RWQCB claims jurisdiction of these features, any alteration of the drainage ditches would require a
permit.
California Department of Toxic Substances
● Review and approval of any activities that may disturb existing groundwater monitoring wells or the
capped portion of the O’Brien site (in South Campus), including applicable deed restrictions and
DTSC-approved Site Management Plan and Health and Safety Plan
US Army Corp of Engineers
● Acceptance of Wetlands Delineation prior to any proposed fill or material alteration of on-site
drainage ditches
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-6
● Section 404 permit prior to the discharge of dredged or fill material into the waters of the United
States, including wetlands. Presuming subsequent Wetland Delineations )see above) find the on-site
drainage ditches are not “waters of the US”, no such federal wetlands permitting would be required
Federal Aviation Administration
● Approvals for any proposed building exceeding FAA Part 77 height criteria
Summary of Impacts, Alternatives and Mitigation Measures
Significant and Unavoidable Impacts
Based on the analysis presented in this EIR, the Project would result in the following environmental impacts
that would be considered significant and unavoidable:
Air Quality
Impact Air Quality-4: 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.
Regulatory Requirement AQ 4 - New Source Review Offset requires Genentech to 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. Although TDM, 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 BAAQMD would exceed the
thresholds of significance. The health impacts associated with criteria pollutant emissions from the Project
are conservatively estimated and the analysis indicates that anticipated health impacts are vanishingly small
and that the actual health impacts may be zero.
Noise
Impact Noise-1: Construction activities pursuant to the Project could generate noise levels that exceed the
noise standards established in SSFMC Section 8.32.030.
Construction projects pursuant to the Project will be required to implement Mitigation Measure Noise 1A -
Construction Period BMPs for construction that is within 50 feet of an adjacent off-site property and where
construction noise may exceed the 90-dBA limit of the SSF Municipal Code, and Mitigation Measure Noise 1B
- Truck Routes (requiring that heavily loaded trucks be routed away from noise-sensitive and vibration-
sensitive uses. With implementation of Genentech Noise Attenuation and Logistics Plans, construction-period
noise effects on Genentech’s own on-Campus buildings would meet applicable OSHA requirements for safe
workspaces and other private Genentech-based noise standards for healthy workplaces. 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 include all reasonable and feasible
methods to reduce construction noise effects. However, since the details of construction activity cannot be
known in advance, this impact is conservatively considered significant and unavoidable.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-7
Transportation/Traffic
Impact Transportation-1: 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 twenty (20) of the 27 traffic study
intersections.
Regulatory requirements and/or mitigation measures have been identified that are capable of reducing these
impacts at 13 of the 20 affected intersections, but no feasible or certain improvements have been identified
as capable of reducing impacts to a less than significant level at 7 affected study intersections. Either there
are no feasible improvements capable of reducing the Project’s impacts, or implementation of mitigation
improvements are within the jurisdiction of a separate agency (Caltrans) at these seven intersections, and
impacts would remain significant and unavoidable.
Impact Transportation-3: The Project would generate more than 100 peak hour trips onto the Congestion
Management Program roadway network, resulting in conflicts with applicable plans, ordinances or
policies that establish measures for effective levels of service along two freeway segments.
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. However, 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-6: The Project would contribute to cumulative traffic levels that would result in
conflicts with applicable plans, ordinances or policies that establish measures of effectiveness for
intersection levels of service (LOS) at 22 intersections.
Mitigation measures identify improvements that could be made at 7 of the 22 affected intersections, but 4 of
these improvements do not currently have an identified funding source. No feasible improvements have
been identified as being capable of reducing impacts to less than significant levels under the Cumulative plus
Project scenario at 15 affected study intersections.
Impact Transportation-7: 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 under Cumulative plus Project conditions.
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 ramps, but impacts will remain
significant and unavoidable.
Impact Transportation-10: 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
freeway segments.
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. There are no feasible
mitigation measures for these impacts to freeway segments, due to constrained right of way on US-101.
These cumulative impacts remain significant and unavoidable.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-8
Summary of Alternatives
Two alternatives were considered in preparation of this EIR, but rejected. A “No New Development
Alternative” was rejected because the Project is a revision of the existing 2007 Genentech Campus Master
Plan, and the “no project” alternative will be rejection of the Project but continuation of the existing Master
Plan and existing zoning regulations into the future. This 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. Three alternatives are analyzed in this EIR. These alternatives are intended to
meet the CEQA requirements for the EIR to describe the no project alternative as well as a reasonable range
of alternatives to the Project that would feasibly attain most of the basic objectives of the Project, but would
avoid or substantially lessen significant effects.
● Alternative #1: No Project: Alternative #1 (or the No Project) is defined as the current 2007 Master
Plan and the existing Genentech Master Plan Zoning District remaining in place. 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 feet added as the South Campus (originally
the Britannia East Grand project) in 2013.
● Alternative 2: Reduced Project: Alternative 2 (the Reduced Project) would establish an overall growth
limit within the 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. The Reduced Project Alternative assumes that the Genentech Campus would meet
a 28% trip reduction rate, consistent with current City requirements.
● Alternative 3: Alternative Mix of Land Uses: Under Alternative #3, the overall net new development
within the Campus would be approximately 4.3 million square feet (same as the EIR Project
Description) to a buildout of 9 million square feet. However, the mix of land uses within the Campus
would have a substantially different shift from the higher trip-generating office land use assumed in
the EIR Project Description, to the lower trip-generating lab and manufacturing space uses. One of
the purposes of having an Alternative that mixes the land use composition of the future Campus
buildout is to demonstrate the flexibility of the Master Plan Update and its proposed Trip Cap to
respond to potentially changing building space demands at the Campus over time.
None of the alternatives is capable of fully avoiding an environmental effect of the Project, or changing a
significant impact of the Project to less than significant impact. Rather, the differences between the Project
and the alternatives are measured in relative magnitude. Generally, the lower development potential of
Alternative #1 (the No Project) would substantially lessen overall construction-period and operational
emission of air quality pollutants, toxic air contaminants, GHG emissions, vehicle trips and demands on
utilities as compared to the Project. Alternative #1 has a reduced development footprint, fewer identified
Opportunity Sites where new development may occur, and does not include Opportunity Sites on steeper
hillsides where mitigation measures would otherwise be required to address potential slope failure. Based on
these substantially lessened impacts, Alternative #1 (the No Project Alternative) is environmentally superior
to the Project and to all other alternatives. CEQA requires this EIR to identify another alternative that would
be considered environmentally superior in the absence of the No Project Alternative. Like the No Project
Alternative, the lower development potential of Alternative #2 would also substantially lessen overall
construction-period and operational emissions of air quality pollutants, toxic air contaminants, GHG
emissions and demands on utilities, as compared to the Project.
Alternative #2 (the Reduced Project Alternative) is the environmentally superior alternative, but Alternative
#2 (like the No Project Alternative) does not fully avoid any significant environmental effects of the Project
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-9
that cannot otherwise be substantially lessened or avoided with implementation of all feasible mitigation
measures identified in this EIR.
Summary of Impacts and Mitigation Measures
The following Table 1-1 provides a summary of potential environmental impacts, the regulatory
requirements applicable to new development within the Campus, recommended mitigation measures (as
necessary), and the resulting level of significance after implementation of all regulatory requirements and
mitigation measures. Table 1-1 incorporates all changes and additions that have been have in response to
staff-initiated changes and/or comments on the Draft EIR. For a more complete discussion of potential
environmental impacts and mitigation measures, please refer to individual topic area chapters of the Draft
EIR.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-10
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Aesthetics
Aesthetics 1: New development pursuant to the Project
would not result in a substantial adverse effect on a
scenic vista.
None needed Less than Significant
Aesthetics 2: New development pursuant to the Project
would not substantially damage scenic resources
including, but not limited to, trees, rock outcroppings or
historic buildings within a state scenic highway.
None needed Less than Significant
Aesthetics 3: New development pursuant to the Project
would not substantially degrade the visual character or
quality of the Project Area.
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.
Less than Significant
Aesthetics 4: New development pursuant to the Project
could result in new sources of increased daytime glare
and nighttime illumination.
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:
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. 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)
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-11
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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
Air Quality
AQ 1: Implementation of the Project would not conflict
with or obstruct implementation of the applicable air
quality plan
None needed Less than Significant
AQ 2: 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.
However, with implementation of Basic BMPs for all
construction projects, and Additional BMPs for those
construction projects that exceed screening criteria,
construction emissions would be unlikely to exceed
applicable thresholds.
Best Management Practices AQ 2A, Basic Construction Measures: 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.
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.
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
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g) All construction equipment shall be maintained and properly 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.
It is possible that variations in construction schedules will occur, resulting in construction
of individual buildings exceeding the assumed annual average, or that multiple buildings
may be constructed across the Campus at the same time. Therefore, the following
requirement is recommended as a Condition of Approval for the Project, to address
subsequent development-specific circumstances:
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) When 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, then a demonstration of consistency with the
results in AQ-3 would also be required.
AQ 3: 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 1
million at the maximally exposed sensitive receptor.
None needed for construction activities on each of those Opportunity Sites as indicated on
Figure 6-3 as not contributing to construction-period health risks (i.e., impacts would be
less than significant).
All construction activities pursuant to buildout of the Project may proceed on all
Opportunity Sites without further site-specific or project-specific analysis if Mitigation
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
measure AQ 3: Diesel Particulate Filters, are installed on all diesel construction equipment
(i.e., where health risk impacts would be mitigated to less than significant levels).
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 shall use off-road construction equipment installed with diesel particulate filters
capable of reducing PM10 and PM2.5 emissions by as much as 85%.
AQ 4: 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.
Regulatory Requirement AQ 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.
Significant and
Unavoidable
Although TDM,
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
exceed the
thresholds of
significance -
AQ 5: During operational activities, the Project could
expose sensitive receptors to substantial health risk from
operational-related emissions if operational sources of
TAC emissions are not limited in location and operational
parameters.
None needed for operational source of TAC emission that operate within the emission
parameters used in this analysis and located on any of those Opportunity Sites shown on
Figures 6-5 and 6-6 as not contributing to operational-period health risks – (i.e., less than
significant). Individual projects that include new sources of operational TAC emissions that
would operate outside of the operational parameters used in this EIR are subject to the
following mitigation measure:
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 this analysis (as shown in Table 6-9). For any operational
source of TAC emissions that does not operate within these parameters, a subsequent,
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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.
Individual projects that include new operational sources of TAC emissions and that are
sited at locations not shown on Figure 6-5 (for laboratories) or Figure 6-6 (for emergency
generators) are subject to the following mitigation measure:
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 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.
Biological Resources
Bio 1: 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.
Regulatory Requirement Hydro 1A, Construction General Permit and Stormwater
Pollution Prevention Plan: All qualifying construction projects pursuant to the Master Plan
Update shall 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
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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 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 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 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.
Bio-2: 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).
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 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
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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 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.
Bio 3: The Project would not cause a substantial adverse
effect, either directly or through habitat modification, on
burrowing owls. Burrowing owls are a migratory species
protected under the federal MBTA and California Fish
and Game Code, and designated as a state species of
special concern.
None required Less than Significant
Bio 4: 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.
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
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
determine the 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.
Bio 5: 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.
Regulatory Requirement Hydro 1A, Construction General Permit/Stormwater Pollution
Prevention Plan: (see additional details under Bio 1, above).
Regulatory Requirement Hydro 1B, Provision C.3 Requirements/Stormwater
Management Plan: (see additional details under Bio 1, above).
Less than Significant
Bio 6: The Project would not interfere substantially with
migratory bird corridors due to bird strikes with
buildings.
None required Less than Significant
Bio 7: 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 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.
Less than Significant
Bio 8: The Project will not have a substantial adverse
effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies,
Regulatory Requirement Hydro 1A, Construction General Permit/Stormwater Pollution
Prevention Plan: (see additional details under Bio 1, above).
Regulatory Requirement Hydro 1B, Provision C.3 Requirements/Stormwater
Management Plan: (see additional details under Bio 1, above).
Less than Significant
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Genentech Master Plan Update, Final EIR Page 1-18
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
regulations, or by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service.
Bio 9: The Project will not have a substantial adverse
effect on federally protected wetlands as defined by
Section 404 of the Clean Water Act (including, but not
limited to, marsh, vernal pool, coastal, etc.), waters of
the U.S., and waters of the state through direct removal,
filling, hydrological interruption or other means.
Regulatory Requirement Hydro 1A, Construction General Permit/Stormwater Pollution
Prevention Plan: (see additional details under Bio 1, above).
Regulatory Requirement Hydro 1B, Provision C.3 Requirements/Stormwater
Management Plan: (see additional details under Bio 1, above).
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 State, there is some possibility these drainage ditches may be claimed as
jurisdictional by the RWQCB. Prior to any proposed fill or material alteration of on-site
drainage ditches (those indicated on prior Figure 7-8), a wetlands delineation based on the
criteria of most current Corps of Engineers Wetlands Delineation Manual and any regional
supplements shall be conducted.
a) Presuming this wetland delineation finds the on-site drainage ditches are not Waters
of the US and that these delineations are accepted by the Corps, then no further
federal wetlands permitting is required.
b) If the RWQCB claims jurisdiction of these features, any alteration of the drainage
ditches would require a permit from the RWQCB and compliance with all standards
and requirements of such permit.
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.
Less than Significant
Bio 10: 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.
None required Less than Significant
Bio 11: The Project would not conflict with any local
policies or ordinances protecting biological resources,
such as a tree preservation policy or ordinance.
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
Less than Significant
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Genentech Master Plan Update, Final EIR Page 1-19
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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.
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.
Bio 12: 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.
None required Less than Significant
Cultural Resources
Cultural 1: Future development pursuant to the Project is
not anticipated to cause a substantial adverse change in
the significance of any known historical resources.
None needed Less than Significant
Cultural 2: Future development pursuant to the Project is
not anticipated to uncover or disturb a known
paleontological resource.
None needed Less than Significant
Cultural 3: During ground disturbing activities associated
within the Project Area, it is possible that currently
Mitigation Measure Cultural 3A, Cultural Resources Worker Environmental Awareness
Program: A qualified archaeologist should conduct training for all construction personnel
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-20
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
unidentified historic-period archaeological resources
could be discovered and disturbed.
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 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 #D, 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.
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
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Significance
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.
Cultural 4: 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.
Mitigation Measure Cultural 3A, Cultural Resources Worker Environmental Awareness
Program (WEAP): see above
Mitigation Measure Cultural 3B, Halt Construction Activity, Evaluate Find and Implement
Mitigation: see above
Mitigation Measure Cultural 3C, In the Event of Discovery of Human Remains: see 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 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.
Less than Significant
Geology and Soils
Geology 1: 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
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.
Less than Significant
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Genentech Master Plan Update, Final EIR Page 1-22
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
resulting from strong seismic ground-shaking and
seismic-related ground failure.
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.
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 following:
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 seismicity and unstable soils
California Building Code, which provides minimum standards for building design including
but not limited to regulations governing seismically resistant construction (Chapter 16,
Section 1613)
City of South San Francisco Municipal Code - Chapter 15.08, which includes CBC standards
as further modified by amendments, additions, and deletions adopted as the building code
of the City of South San Francisco
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
Geology 2: With implementation of all applicable
regulatory requirements, most future development
pursuant to the Project would not expose people and
structures to potentially substantial adverse effects
resulting from landslides. Future development on steep
hillside sites could pose increased risks of slope
instability and landslide potential.
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
Less than Significant
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Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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
Geology 3: 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.
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.
Less than Significant
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All new development pursuant to the Project will be required to comply with all applicable
regulatory requirements to address soils constraints, including but not limited to the
following:
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 unstable soils
California Building Code, Chapters 18A and 23 (or Uniform Building Code for Zone 4),
which addresses building foundations and structural support requirements, subject to
structural peer review
City of South San Francisco Municipal Code - Chapter 15.08, which includes CBC standards
as further modified by amendments, additions and deletions adopted as the Building Code
of the City of South San Francisco
East of 101 Area Plan, Chapter 10: Geotechnical Safety Element, which sets forth policies
and specific guidelines pertaining to site development and building design applicable to
soils conditions that exist in the East of 101 Area
Geology 4: 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.
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 Project. 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)
Less than Significant
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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.
Geology 5: 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.
None needed No Impact
Greenhouse Gas Emissions
GHG 1: The Project’s stationary source emissions will not
conflict with an applicable plan, policy, or regulation
adopted for the purposes of reducing the 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 Requirement GHG 1, Cap and Trade: Genentech is committed to minimizing
emissions from stationary sources and continuing participation in the Cap-and-Trade
program. Pursuant to this program, Genentech must meet the requirements by ensuring
permits (through increased cap or trade) are obtained for incremental growth in these
types of stationary source emissions. The Cap-and-Trade allowances must meet or exceed
stationary source emission levels as reported to CARB pursuant to mandatory GHG
reporting requirements. 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
Less than Significant
GHG 2: 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.
None needed. Less than Significant
GHG 3: 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. Specifically, the Project is consistent with the
City’s Qualified GHG Reduction Strategy (i.e., the SSF
Climate Action Program, or CAP). Those operational-
related GHG emissions that are fully covered under the
SSF CAP do not represent a cumulatively considerable
None needed. The Project’s indirect, operational GHG emissions attributable to mobile
sources, water use, wastewater treatment and waste disposal are fully addressed in the
City of South San Francisco’s Climate Action Plan (a Qualified GHG Reduction Strategy). 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.
Less than Significant
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contribution to global climate change, and emissions that
comply with the CAP are excluded from analysis of GHG
emissions against the numerical land use-based
threshold.
GHG 4: 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 (Project jobs) at year 2020. The Project’s land
use-based GHG emissions would not contribute
significantly to global climate change, and this impact is
considered less than cumulatively considerable.
No mitigation is required. The Project would not exceed the service-based efficiency
threshold for land use-based GHG emissions by year 2020.
Less than Significant
GHG 5: 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 2030. The Project’s land use-based
GHG emissions would not contribute significantly to
global climate change, and this impact is considered less
than cumulatively considerable.
No mitigation is required. The Project would not exceed the service-based efficiency
threshold for land use-based GHG emissions by year 2030.
Less than Significant
Hazards and Hazardous Materials
Hazards 1: Implementation of the Project would not
expose Genentech employees or the nearby public to
significant hazards due to the routine transport, use,
disposal or storage of hazardous materials (including
chemical, radioactive and biohazardous waste).
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 that the potential for worker and/or public exposure to hazardous
chemicals from improper or unsafe activities or from accidents is less than significant.
1) To reduce the potential for exposure to airborne chemicals, workers shall take
standard precautions such as working under fume hoods when using chemicals that
could present exposure hazards. The chemical fume hood is a critical health and safety
control in the laboratory setting, ensuring an adequate level of protection from
possible harmful effects of chemicals. Proper use of fume hoods keeps toxic air
contaminant levels within indoor laboratories below levels identified in guidelines of
the American Conference of Governmental Industrial Hygienists (Threshold Limit
Values) and OSHA legal limits (Permissible Exposure Levels).
Less than Significant
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2) To prevent exposure through skin contact, Genentech shall require that protective
clothing such as laboratory coats, gloves and safety glasses, be worn while handling
hazardous materials. Proper washing after handling chemicals is required. Eating,
drinking and smoking are prohibited in laboratories and other areas where hazardous
materials are used. These procedures are disclosed to all staff that work with
hazardous materials, and this training increases the safety awareness of Genentech
employees and further reduces the risks of exposure to hazardous chemicals through
inhalation, absorption, ingestion and injection. Should an accident occur that could
cause exposure of an individual to hazardous materials, required emergency
equipment (e.g., fire extinguishers, eyewashes and safety showers) are also available.
3) Cal/OSHA requires all institutions that use hazardous materials to implement a Hazard
Communication Program and to train employees that use hazardous chemicals in the
safe use of those materials. Genentech implements all safety procedures and conducts
safety programs to ensure that these OSHA safety procedures are consistently
followed. Genentech will continue to implement these (or equivalent) programs,
practices and procedures, and will expand these programs as needed. Title 8 of the
California Code of Regulations (Section 3203 of the General Industry Safety Orders)
also requires every California employer to have a written Injury and Illness Prevention
Program to provide a safe and healthful workplace. OSHA mandates methods of
documenting, investigating and controlling accidents that result in skin penetration.
Evidence presented during OSHA rule-making procedures indicates that these
programs and methods are effective in reducing the number and severity of injuries
and illness in the workplace.
Regulatory Requirements Hazards 1B, Use of Radioactive Materials: The use of
radioactive material 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 testing and conducting
decontamination and waste handling activities in accordance with applicable regulations.
1) Use of radioactive materials at Genentech is monitored to ensure consistency with
requirements of Genentech’s radioactive materials license as issued and administered
by the Radiologic Health Branch of the DHS. These licensing requirements articulate
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standards to maintain radiation exposure levels below applicable legal standards,
thereby protecting users of radioactive materials.
2) Like all hazardous materials, the effects of the routine use of radioactive materials are
limited to areas where exposure may occur and decreases substantially with distance.
For this reason, the individuals most at risk would be those specially trained in the use
of radioactive materials, thereby reducing the likelihood for accidental exposure
through improper handling techniques. All individuals who handle radioactive waste
are required to wear a personal monitor that determines their cumulative exposure to
radiation. If the monitor indicates that established safety levels might be exceeded,
the individual is prevented from being exposed to potential sources of radiation until
the monitor indicates that safety levels can be maintained.
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.
1. Occupational and public safety is protected by selecting the appropriate biological and
physical containment levels for each biological material handled. Standard
microbiological practices, such as limiting facility access, washing hands after handling,
de-contaminating work surfaces, wearing gloves and other safety equipment, using
biosafety cabinets, and proper disposal reduce risks resulting from exposure to
biohazardous materials.
2. Current state testing, monitoring and disposal regulations, and Genentech’s own
programs pertaining to the management of biohazardous materials (including
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infectious agents), further ensure that risks associated with use of biohazardous
substances remain less than significant.
3. Medical wastes are managed by Genentech as a biohazardous material, in accordance
with Section 117635 of the California Health and Safety Code and with USDHHS
guidelines and DHS regulations. Biohazardous medical waste is generally regulated in
the same manner as hazardous waste, except that special provisions apply to storage,
disinfection, containment, transportation and disposal.
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.
1. Spent hazardous materials generated on a daily basis in research, production and
maintenance facilities are placed in special containers and are kept in specially
designated and ventilated accumulation areas. These hazardous wastes are collected
and accumulated in designated and secured areas designed to prevent accidental
release to the environment. Wastes are transported off- site by licensed hazardous
waste transporters to permitted hazardous waste disposal facilities, and emergency
response procedures for all on-site storage sites are included in the Genentech
Hazardous Waste Contingency Plan. Biohazardous wastes are managed in the same
way, though separately.
2. In accordance with strict regulatory guidelines of the Department of Energy, the
Nuclear Regulatory Commission, the US EPA and the California Radiation Control Law
(California Health & Safety Code Sections 114960-114985), Genentech collects,
prepares and packages its radioactive waste. Radioactive waste is then transported by
a radioactive waste broker to a licensed radioactive waste disposal facility.
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 including driver training
and licensing, standardized hazard warning placards for vehicles, shipping manifest
requirements and standards for classifying, handling and packaging hazardous materials, as
well as 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.
Hazards 2: Implementation of the Project would not
create a significant hazard to the public or the
environment through reasonably foreseeable upset and
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.
Less than Significant
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accident conditions involving the release of hazardous
materials into the environment.
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.
Compliance with all applicable federal and state laws, as well as all Genentech programs,
practices and procedures related to the transportation of hazardous materials will
continue to reduce the likelihood and severity of accidents 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
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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 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.
Hazards 3: Although some Project area facilities are
included on the list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5,
implementation of the Project would not create a
significant hazard to the public or the environment due
to the presence of these listed facilities.
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:
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
Less than Significant
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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.
Hazards 4: 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.
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.
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
Less than Significant
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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
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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.
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.
Hazards 5: 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.
See all regulatory requirements and mitigation measures listed pursuant to the routine
transport, use, disposal or storage of hazardous materials (Hazards 1), reasonably
foreseeable upset and accident conditions involving the release of hazardous materials
into the environment (Hazards 2), known hazardous materials sites (Hazards 3), and
construction activities (Hazards 4), above
Less than Significant
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Hazards 6: 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.
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”.
Less than Significant
Hazards 7: Implementation of the Project could impair
implementation of, or physically interfere with an
adopted emergency response or emergency evacuation
plan. Implementation of mitigation measures will ensure
this impact remains less than significant.
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.
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.
Less than Significant
Hazard-8: The Project would not expose people or
structures to a significant risk of loss, injury or death
involving wildland fires.
None needed Less than Significant
Hydrology and Water Quality
Hydro 1: 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.
Regulatory Requirement Hydro 1A, Construction General Permit and Stormwater
Pollution Prevention Plan: All new qualifying construction projects pursuant to the Master
Plan Update shall 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.
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-36
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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 pollutants 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 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, general 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,
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-37
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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.
Hydro 2: Future development pursuant to the Project
will not substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
None needed Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-38
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
that the project may impeded sustainable groundwater
management of the basin.
Hydro 3: Future development pursuant to the Project
would not substantially alter the existing drainage
pattern of the site or area, including through the
alteration of the course of a stream or river, or through
the addition of impervious surfaces, in a manner that
would result in substantial erosion or siltation on- or off-
site, substantially increase the rate or amount of surface
runoff in a manner that would result in flooding on- or
off-site, or create or contribute runoff water that would
exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional
sources of polluted runoff.
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)
Less than Significant
Hydro 4: Future development pursuant to the Project
would not risk release of pollutants due to project
inundation as a result of a flood hazard, tsunami or
seiche.
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.
Less than Significant
Sea Level Rise: Most of adverse effects of mid-century
sea level rise at the Genentech Campus will likely be
confined to the 100-foot shoreline setback along the Bay.
This setback restricts Campus development adjacent to
sensitive natural areas such as tidal wetlands, which also
provide for storm surge and wave dissipation. In the
longer term (or under accelerated and/or more severe
weather conditions) adaptation to sea level rise at the
Campus may prove to be more critical.
None required. The effects that potential future sea level rise may have on the Project is
not a CEQA matter. Therefore, analysis of potential sea level rise effects is provided for
informational purposes only, but may also provide context for future City consideration of
appropriate sea level rise adaptation strategies.
Not a CEQA Impact
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-39
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Land Use
Land Use 1: The Project would not physically divide an
established community
None needed No Impact
Land Use 2: Implementation of the Project would modify
or change certain land use regulations applicable to the
Project Area, but would not cause a significant
environmental impacts due to a conflict with any land
use plan, policy, or regulation adopted for the purpose of
avoiding or mitigating an environmental effect.
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.
Mitigation Measure Geology 2 - Geotechnical Requirements for Hillside Opportunity Sites
(see above): This MM specifically requires site-specific geotechnical studies to be
conducted for each new development at hillside Opportunity Sites, with implementation of
site-specific recommendations as part of detailed plans for subsequent development.
Less than Significant
Land Use 3: The Project would not conflict with any
applicable habitat conservation plan or natural
community conservation plan.
None needed No Impact
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-40
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Noise
Noise 1: 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.
Mitigation Measure Noise 1A, Construction Period BMPs: The following mitigation
measures are recommended for construction activity within the Project Area that is within
50 feet of an adjacent off-site property (i.e., where construction noise may exceed the
90dBA limit of the SSF Municipal Code). 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
Significant and
Unavoidable
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
include all reasonable
and feasible methods
to reduce
construction noise
effects. However,
since the details of
construction activity
cannot be known in
advance, this impact
is conservatively
considered significant
and unavoidable
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-41
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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.
Genentech will also continue to prepare and implement a Noise Attenuation and Logistics
Plan for any new development that is within 50 feet of an 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.
Noise 2: Operational activities associated with the
Project would not generate a substantial permanent
increase in ambient noise levels in the vicinity of the
Project in excess of standards established in the local
general plan or noise ordinance, or applicable standards
of other agencies.
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 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.
Less than Significant
Noise 3: C 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.
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
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-42
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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.
Genentech will also continue to prepare and implement a Noise Attenuation and Logistics
Plan for any new development that is within 20 feet of an 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.
Mitigation Measure Noise 1A, Construction Period BMPs (see above)
Mitigation Measure Noise 1B, Truck Routes (see above)
Noise 4: 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.
None required Less than Significant
Noise 5: Traffic generated by the Project would result in
increased traffic volumes that would increase local
ambient traffic noise levels by greater than 3 dBA CNEL
at locations that would also meet or exceed 65 dBA
CNEL, but the Project’s increased traffic noise would not
adversely affect existing noise-sensitive receptors.
None needed. Less than Significant
Noise 6: The Project would not expose people working in
the Project Area to excessive noise levels due to
proximity to airport-related noise sources.
None needed. Less than Significant
Population, Housing and Employment
Pop/Emp. 1: The Project will result in a substantial
increase in local South San Francisco employment, but
will not result in employment growth beyond that
contemplated in the City, and will not induce population
growth beyond that contemplated in the county or the
region.
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.
Less than Significant
Pop/Emp. 2: Implementation of the Project would not
displace any existing housing that would necessitate
construction of replacement housing elsewhere.
None required Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-43
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Pop/Emp. 3: Implementation of the Project would not
displace substantial numbers of people.
None required Less than Significant
Public Services
Public Services 1: The Project would increase the
number of employees in the Project Area over time,
gradually increasing the demand for police 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 impacts related to police services would be
less than significant.
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.
Less than Significant
Public Services 2: 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 and emergency
medical services would be less than significant.
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.
Less than Significant
Public Services 3: 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
recreational open space would be less than significant.
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.
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. 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.
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-44
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Traffic and Circulation
Transp 1: 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 twenty (20) of the 27
traffic study intersections.
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:
a) Airport Boulevard/Sister Cities Boulevard/Oyster Point Boulevard (#1). Adjust the
signal timing at the intersection to allow the southbound right-turn movement to
overlap with the eastbound left turn movement. This timing adjustment would
improve intersection operations to an acceptable LOS D. (LTS)
b) Dubuque Avenue/101 NB off-ramp/Oyster Pt. Boulevard (#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.
This signal timing would reduce the queue compared to the existing conditions. The
queue would still exceed available storage space, but the Project would not further
extend queues beyond existing conditions. However, this intersection is under the
jurisdiction of Caltrans and the City cannot ensure this mitigation is implemented.
(conservatively SU)
c) Gateway Boulevard/East Grand Avenue (#15). Adjust the signal timing at this
intersection to convert the eastbound left turn phase from a lagging phase to a leading
phase. This timing adjustment would reduce delay to an acceptable LOS D. (LTS)
d) East Grand Avenue/Littlefield Avenue (#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. These measures would improve intersection
operations to an acceptable LOS D in the AM peak hour. (LTS)
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:
a) Oyster Point Boulevard/Eccles Avenue (#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
Significant and
Unavoidable
Regulatory
requirements and/or
mitigation measures
have been identified
that are capable of
reducing impacts at
13 of the 20 affected
intersections, but no
feasible or certain
improvements have
been identified as
capable of reducing
impacts to a less than
significant level at 7
affected study
intersections.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-45
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
would 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. This measure would result in an acceptable LOS B in
the AM peak hour. (LTS)
b) Oyster Point Boulevard/Gull Drive (#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. This measure would improve intersection
operations to an acceptable LOS D in both the AM and PM peak hours. (LTS)
c) Airport Boulevard/Grand Avenue (#12): Add a second southbound left-turn lane and
convert the southbound right-turn lane to a through/right lane. This measure would
reduce delay and improve intersection operations to an acceptable LOS D in the AM
peak hour. However, the improvements would not reduce the length of the
southbound left turn queue, and as such the queuing impact would be significant and
unavoidable. (SU)
d) East Grand Avenue/Harbor Way/Forbes Boulevard (#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. This measure would decrease delay to an acceptable LOS D in
both AM and PM peak hours. (LTS)
e) East Grand Avenue/Allerton Avenue (#17): Install a traffic signal, including a protected
southbound left-turn movement. This measure would improve intersection operations
to acceptable LOS B in the PM peak hour. (LTS)
f) East Grand Avenue/DNA Way (#18): Install a traffic signal and add an additional
eastbound left turn lane. This measure would improve intersection operations to an
acceptable LOS B in the AM peak hour and LOS C in the PM peak hour. (LTS)
g) Produce Avenue/Airport Boulevard/San Mateo Avenue (#19): Widen the westbound
approach to consist of three dedicated left turn lanes, one through lane, and one
shared through-right lane. This measure would reduce both queuing and vehicular
delay to an acceptable LOS D in both the AM and PM peak hours. (LTS)
Mitigation Measure Transportation 1: Additions to East of 101 Transportation Impact Fee
Program: The Project applicant shall pay its fair-share toward the following intersection
improvements by either; 1) fully funding the following improvement subject to fee credits
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-46
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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 (#4). Add an additional eastbound through lane,
and change the signal phasing to implement an overlap phase for the northeast-bound
right turn movement. These measures would reduce queues to levels not exceeding
existing conditions. However, this intersection is under the jurisdiction of Caltrans and
the City cannot ensure this mitigation is implemented. (conservatively SU)
b) Forbes Boulevard/Allerton Avenue (#8): Install a traffic signal with optimized signal
timing. This measure would improve intersection operations to an acceptable LOS A in
the AM and PM peak hours. (LTS with MM)
c) Gull Drive/Forbes Boulevard (#9): Adjust the existing signal timing and extend the
southbound left turn pocket to 500 feet. This measure would partially mitigate the
impact by decreasing delay, but the intersection would continue to operate at an
unacceptable LOS F during the AM peak hour. (SU)
d) Airport Boulevard/Miller Avenue/ US-101 SB Off-Ramp (#10). Adjusting the signal
timing to lengthen northbound through and eastbound right phases. This timing
adjustment would improve intersection operations to an acceptable LOS C in the PM
peak hour. However, this signal is operated by Caltrans and requests to modify signal
timing may not be approved. As such, this impact is conservatively assumed to be
significant and unavoidable. (conservatively SU)
e) South Airport Boulevard/Gateway Boulevard/Mitchell Avenue (#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 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. This
measure decreases delay to an acceptable LOS C during the AM peak hour and
acceptable LOS D during the PM peak hour, and reduces queuing to an acceptable
level. These improvements are only partially included the East of 101 Transportation
Impact Fee Program. (LTS with MM)
f) Mitchell Road/Harbor Way (#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
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-47
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
the signal timing. This measure would improve intersection operations to LOS B in the
AM peak hour and LOS A in the PM peak hour. (LTS with MM)
g) Utah Avenue/Harbor Way (#25): Add a traffic signal at this intersection and optimize
signal timing. This measure would improve intersection operations to LOS A in both
the AM and PM peak hours. (LTS with MM)
Transp 2: Although the Project would generate more
than 100 peak hour trips onto the Congestion
Management Program roadway network, it would not
resulting in conflicts with applicable plans, ordinances or
policies that establish measures for effective levels of
service at freeway ramp locations.
None needed
Consistent with C/CAG guidelines, the Project will implement a TDM program that is
consistent with, and exceeds City requirements. That TDM program will further reduce its
contribution of trips on the CMP network, including its contributions of traffic to freeway
ramps.
Less than Significant
Transp 3: The Project would generate more than 100
peak hour trips onto the Congestion Management
Program roadway network, resulting in conflicts with
applicable plans, ordinances or policies that establish
measures for effective levels of service along two
freeway segments (southbound US-101 north of Oyster
Point Boulevard and northbound US-101 south of
Produce Avenue).
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 delay.
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.
Significant and
Unavoidable
Transp 4: The Project’s on-site vehicle circulation system
would not present a design hazard.
None required Less than Significant
Transp 5: The Project would not conflict with a program,
plan, ordinance or policy addressing the circulation
system, including transit, bicycle and pedestrian facilities.
None needed. Less than Significant
Transp 6: The Project would contribute to cumulative
traffic levels that would result in conflicts with applicable
plans, ordinances or policies that establish measures of
effectiveness for intersection levels of service (LOS) at 22
intersections.
Mitigation measures identify improvements that could
be made at 7 of the 22 affected intersections, but 4 of
these improvements do not currently have an identified
funding source. No feasible improvements have been
identified as being capable of reducing impacts to less
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 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. These Existing plus Project
improvements also improve traffic conditions under the Cumulative plus Project condition,
as indicated below:
Significant and
Unavoidable
Mitigation measures
identify
improvements that
could be made at 7 of
the 22 affected
intersections, but 4
of these
improvements do not
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-48
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
than significant levels under the Cumulative plus Project
scenario at 15 affected study intersections.
a) Forbes Boulevard/Allerton Avenue (#8): Implement Regulatory Requirement
Transportation 1(d), which provides for installation of a traffic signal with optimized
signal timing. This measure would improve Cumulative intersection operations to an
acceptable LOS B in the AM and LOS C in the PM peak hour. (LTS)
b) Grand Avenue/Littlefield Avenue (#23): Implement Mitigation Measure Transportation
1(b), which provides for an adjustment to the signal timing to allow the northbound
right turn phase to overlap with the westbound left turn phase. This measure would
reduce Cumulative delay to LOS D in the AM peak hour. (LTS with MM)
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. These improvements would improve Cumulative intersection operations
to LOS D in the AM peak hour and LOS B in the PM peak hour. (LTS with MM)
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:
a) Airport Boulevard/Oyster Point Boulevard (#1): Add overlap phases for the
southbound right and northbound right movements, and optimizing signal timing. This
measure would improve intersection operations to an acceptable LOS D. However, this
mitigation measure would not reduce the length of the southbound left turn vehicle
queue to an acceptable level. There are no other feasible mitigations at this location.
(SU)
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. This measure would reduce 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. (LTS with MM,
conservatively SU)
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. These changes would decrease delay and improve 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. This
measure would also not reduce queuing to acceptable lengths. (SU)
currently have an
identified funding
source. No feasible
improvements have
been identified as
being capable of
reducing impacts to
less than significant
levels under the
Cumulative plus
Project scenario at 15
affected study
intersections.
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-49
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
d) Airport Boulevard/Miller Avenue/US-101 SB Off-Ramp (#10): Adjust the signal timing
to lengthen the westbound green time. This measure would improve cumulative
intersection operations to an acceptable LOS D in the PM peak hour. However, this
intersection is under the jurisdiction of Caltrans and the City cannot ensure this
mitigation is implemented. (SU)
e) Dubuque Avenue/Grand Avenue (#11): Adjust the signal timing to lengthen the
westbound green time. This measure would improve cumulative intersection
operations to an acceptable LOS D in the PM peak hour. (LTS with MM, conservatively
SU)
f) Produce Avenue/Airport Boulevard/San Mateo Avenue (#19). Modify the signal
timing. This measure would decrease delay but would not improve cumulative
operations to an acceptable level of service. There are no additional feasible
mitigations at this intersection. (SU)
g) South Airport Boulevard/Gateway Boulevard (#20). Update the signal timing. This
measure would decrease delay but would not improve cumulative operations to an
acceptable level of service. There are no additional feasible mitigations at this
intersection. (SU)
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. This improvement would reduce cumulative delay, but would not achieve
an acceptable level of service in the AM peak hour. In the PM peak hour, changing
configuration of the westbound approach would reduce delay to LOS D. There are no
additional feasible mitigations at this intersection. (SU)
i) Utah Avenue/Harbor Way (#25): Add a traffic signal at this intersection, and
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. This measure would improve intersection operations to LOS B in the
AM and PM peak hours.(LTS with MM, conservatively SU)
j) Westbound Ramp/South Airport Boulevard (#26). Extending cycle length and
optimizing the signal timing at this location would improve cumulative 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. (SU)
k) I-380 Eastbound Ramp/South Airport Boulevard (#27): Extend the cycle length and
optimize the signal timing at this location. This measure would improve intersection
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-50
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
operations to an acceptable LOS D in the PM peak hour. (LTS with MM, conservatively
SU)
Transp 7: 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 (US-101/Oyster Point Boulevard and US-
101/Produce Avenue).
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
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 ramps.
Significant and
Unavoidable
Transp 8: 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 at 7 freeway
segments (northbound US-101 north of Oyster Point
Boulevard; southbound US-101 north of Oyster Point
Boulevard; northbound US-101 between Oyster Point
Boulevard and Grand Avenue; southbound US-101
between Oyster Point Boulevard and Grand Avenue;
northbound US-101 between Grand Avenue and Produce
Avenue; southbound US-101 between Grand Avenue and
Produce Avenue; and northbound US-101, south of
Produce Avenue).
As there are no feasible mitigation measures for these impacts to freeway segment due to
constrained right of way on US-101.
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.
Significant and
Unavoidable
Transp 9: The Project’s calculated rate of VMT per
employee is lower than the VMT target reduction
thresholds of 15% below the regional average worker-
based VMT, the Project would not exceed the VMT
threshold, and VMT impacts of the Project would be less
than significant.
None required, other than the Project’s proposed TDM Program and Trip Cap Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-51
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
Utilities and Service Systems
Utilities 1: 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, dray and multiple dry years.
Regulatory Requirement Utilities 1, CalGreen Water Conservation Standards: All new
development pursuant to the Master Plan (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.
2) Install 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.
Less than Significant
Utilities 2: The Project would not require or result in the
relocation or construction of new or expanded water
conveyance facilities, the construction or relocation of
which could cause significant environmental effects
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.
Less than Significant
Utilities 3: The Project will not require or result in the
relocation or construction of new or expanded
wastewater treatment facilities, the construction or
relocation of which could cause significant
environmental effects.
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
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-52
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
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 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.
Utilities 4: The Project will not result in a determination
by the wastewater treatment provider (the City of South
San Francisco) that it does not have adequate capacity to
serve the Project’s wastewater treatment and disposal
demands, in addition to its existing commitments.
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.
Less than Significant
Utilities 5: The Project would not require or result in the
relocation or construction of new or expanded
wastewater collection facilities, the construction or
relocation of which could cause significant
environmental effects.
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
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-53
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
wastewater collection system will be upgraded as necessary to accommodate future
growth.
Regulatory Requirement Utilities 4, East of 101 Sewer Fees (see above)
Util-6: The Project will not require or result in the
relocation or construction of new or expanded storm
water drainage facilities, the construction or relocation
of which could cause significant environmental effects.
Regulatory Requirement Hydro 1A, Construction General Permit/Stormwater Pollution
Prevention Plan: (see further detail in the Hydrology chapter of this EIR).
Regulatory Requirement Hydro 1B, Provision C.3 Requirements/Stormwater
Management Plan: (see further detail in the Hydrology chapter of this EIR).
Less than Significant
Utilities 7: Future development pursuant to the Project
will not generate solid waste in excess of State or local
standards or in excess of the capacity of the local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals. The Project will comply with
federal, state and local management and reduction
statutes and regulations related to solid waste.
Regulatory Requirement Utilities 7A, Construction Waste Management Plan: Individual
development projects pursuant to the Project will be required to develop and implement a
Construction Waste Management Plan, pursuant to City Ordinance Chapter 15.60
Recycling and Diversion of Debris from Construction and Demolition. Pursuant to these
requirements, each new construction project must:
1) Direct one hundred percent of inert solids to reuse or recycling facilities approved by
the city, and either:
2) Take all mixed construction and demolition debris to a recycling facility and take all
sorted or crushed construction and demolition debris to approved facilities, or
3) Separate by source all non-inert materials such as cardboard and paper, wood, metals,
green waste, new gypsum wallboard, tile, porcelain fixtures, and other easily recycled
materials, and direct them to recycling facilities approved by the city, and taking the
remainder to a facility for disposal. In this option, calculations must be provided to
show that the minimum amount of debris as specified by Section 4.408 of Chapter 4 of
CALGreen has been diverted.
Regulatory Requirement Utilities 7B, Recyclable Materials: Pursuant to South San
Francisco Municipal Code, section 8.28.070, persons desiring to participate in the recycling
materials collection service program shall prepare and separate recyclable materials from
other solid waste as required by the collection contract, so as to constitute source
separated recyclable materials, and thereafter place the source separated recyclable
materials within receptacles.
1) Each type of source separated recyclable material shall be placed in the receptacle
designated for such purpose, and shall not be mixed with any other solid waste,
including any other type of recyclable material.
2) Receptacles containing recyclable materials for multiple unit residential properties,
commercial and industrial and/or institutional properties shall be of a size and
Less than Significant
Chapter 1: Introduction and Executive Summary
Genentech Master Plan Update, Final EIR Page 1-54
Table 1-1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures Resulting Level of
Significance
serviceability agreed to by the authorized recycling agent and placed at the designated
collection location.
Utilities 8: The Project would result in an incremental
increase in the demand for gas and electrical power.
However, the Project will not result in potentially
significant environmental impacts due to a wasteful,
inefficient or unnecessary consumption of energy
resources during project construction or operation, or
conflict with or obstruct a state or local plan for
renewable energy or energy efficiency.
Regulatory Requirement Utilities 8, Energy Conservation: All new development pursuant
to the Project will be required to comply with all applicable regulatory requirements
related to energy, including but not limited to the standards of Title 24 of the California
Code of Regulations and the newest California Green Building Standards Code, as
applicable, which incorporate energy-conserving design and construction requirements.
Less than Significant
Agriculture and Forest Resources
Agriculture 1: 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.
None needed No Impact
Agriculture 2: 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.
None needed No Impact
Mineral Resources
Minerals 1: The Project would not have a significant
adverse impact on the availability of a known mineral
resource or a locally important mineral resource
recovery site.
None needed No Impact
Genentech Master Plan Update - Final EIR Page 2-1
2
Response to Comments on the Draft EIR
Introduction
This chapter includes copies of written comments received by mail or electronic mail during the public review
and comment period on the Draft EIR. Specific responses to the individual comments in each correspondence
follow each letter. Each correspondence is identified by an alphabetical designator (e.g., “A”). Specific
comments within each correspondence are identified by a numeric designator that reflects the numeric
sequence of the specific comment within the correspondence (e.g., “A-1” for the first comment in Comment
Letter A).
Responses focus on comments that pertain to the adequacy of the analysis in the Draft EIR or to other
aspects pertinent to the potential effects of the Project on the environment pursuant to CEQA. Comments
that address topics beyond the purview of this EIR or CEQA are noted as such for the public record.
List of Comment Letters
The following is a list of letters received by the City, commenting on the Draft EIR.
Public Agencies
Letter A: State of California, Governor’s Office of Planning and Research
Letter B: California Department of Transportation (Caltrans) District 4
Letter C: California Highway Control, San Francisco Area
Letter D: San Mateo County Department of Public Works
Letter E: City of San Bruno
Letter F: San Francisco International Airport (SFO)
Members of the Public
Letter G: Rob Lau
Letter H: Koray Ergur
A-1
A-2
Letter A
State of California, Governor’s Office of Planning and Research
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-3
Response to Letter A
State of California, Governor’s Office of Planning and Research
Response to Comment A-1
This comment states that the State Clearinghouse did submit the Draft EIR to selected state agencies for
review, and that comments from the responding agencies are available on the CEQA database. The OPR
CEQA database was checked for submitted comments, and two comments were submitted: one from
Caltrans District 4 (see Letter B), and one from the California Highway Patrol (see Letter C).
Response to Comment A-2
This comment acknowledges that the City has complied with the State Clearinghouse review requirements
for draft environmental documents, pursuant to the California Environmental Quality Act. No further
response to this comment is required.
B-1
Letter B
California Department of Transportation, District 4
B-4
B-2
Letter B
California Department of Transportation, District 4 (cont.)
B-3
Chapter 2: Response to Comments on the Draft EIR
Page 2-6 Genentech Master Plan Update - Final EIR
Response to Letter B
California Department of Transportation (Caltrans) District 4
Response to Comment B-1
This comment references the Caltrans District 4 Bike Plan, which identifies priority Class II/IV bikeway
improvements at the US-101/Grand Avenue and US-101/Oyster Point Boulevard interchanges, and indicates
that the Project should contribute to these improvements to promote bicycle access. The Caltrans District 4
Bike Plan Web Map shows minor interchange improvements (signage and striping) for a Class IIB facility at
the East Grand Avenue interchange, and minor interchange improvements (signage and striping) for a Class
IV bike facility at Oyster Point/Sister Cities Boulevard. 1
As indicated in the Draft EIR (page 17-61), pursuant to the South San Francisco Municipal Code, Genentech is
required to contribute to East of 101 transportation improvements in accordance with requirements of the
East of 101 Transportation Fee Program, and Transportation Impact Fees may be used by the City to fund
enhancements to bicycle and pedestrian infrastructure consistent with the Bicycle Master Plan and the
Pedestrian Master Plan. Payment of South San Francisco East of 101 Transportation Impact Fees represents
the Project’s fair-share contribution toward planned bicycle system improvements and related project
impacts would be less than significant. No mitigation is required to reduce project impacts on bicycle or
pedestrian resources to a less than significant level.
Response to Comment B-2
This comment suggests that the Project should contribute towards access improvements at the South San
Francisco Caltrain Station, including crossing improvements at the Grand Avenue/East Grand Avenue
intersection. It also suggests that the City/Project applicant should monitor the results of the upcoming
Caltrans District 4 Pedestrian Plan to determine what pedestrian improvements related to the Project should
be implemented as mitigation measures.
The Genentech Master Plan will not have any direct adverse effects on any access improvements at the South
San Francisco Caltrain Station, and no mitigation is required. The Genentech Campus (at its nearest point) is
approximately 0.8 miles from the new South San Francisco Caltrain Station site, and new development at the
Campus will not affect the new station design. Genentech employees, as well as all employees in the East of
101 Area, will benefit from improved access to transit that the new Caltrain Station will provide. As an area-
wide benefit, the City may elect to use a portion of collected East of 101 Transportation Impact Fees, and/or
may choose to amend its Transportation Impact Fee Program, to help fund enhancements to bicycle and
pedestrian infrastructure at the new station. Payment of South San Francisco East of 101 Transportation
Impact Fees (or as these fees may be amended) represents the Project’s fair-share contribution toward
planned bicycle and pedestrian system improvements to address cumulative effects.
Response to Comment B-3
This comment suggests that the Project should determine whether there is adequate storage capacity at the
US-101/Grand Avenue and US-101/Oyster Point Boulevard interchanges, and that if it is determined that
there is inadequate storage capacity, the Project should mitigate its impacts on these ramps and
intersections and/or contribute fair-share fees for these improvements. It also suggests that the Project
sponsor coordinate with Caltrans, the County Transportation Authority, and the City of South San Francisco
to implement mitigation measures for the impacted intersections owned by Caltrans.
1 Accessed 1/21/20 at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=91f1bb4eb7ff418092977b762b459d01
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-7
The Draft EIR did include an evaluation of the storage capacity of intersections at and near the US-101
interchanges at East Grand Avenue and at Oyster Point Boulevard and concluded the following under Existing
plus Project conditions:
● At the intersection at Airport Boulevard/Sister Cities Boulevard/Oyster Point Boulevard (Intersection
#1), and the intersection at Dubuque Avenue/101 NB off-ramp/101 SB on-ramp (Intersection #3), the
Project would not extend or contribute to queues beyond existing storage distances.
● At the 101 NB/Oyster Point Boulevard off-ramp (Intersection #2), the Project would cause a greater
than one percent increase in traffic volumes on the AM eastbound through movement, contributing
to queues that already exceed the available storage length. Adjusting the signal timing to provide
additional green time for the eastbound movement in the AM, and providing additional green time
for the westbound movement in the PM (Regulatory Requirement Transp-1A[b]) would reduce
vehicle queues as compared to existing conditions. The queue would still exceed available storage
space, but the Project would not further extend queues beyond existing conditions. This traffic signal
timing adjustment is already included in the East of 101 Traffic Impact Fee Program and the Project
Sponsor shall pay South San Francisco’s East of 101 Transportation Impact Fees, representing their
fair-share contribution toward this improvement.
● At the 101 SB/Gateway Boulevard/Oyster Point Boulevard off-ramp (Intersection #4), the Project
would contribute more than one percent of total volumes to the northeast-bound right turn
movement and to the shared eastbound through/right movement in the AM peak hour, causing
queues to exceed available storage space. Adding an additional eastbound through-lane and
changing the signal phasing to implement an overlap phase for the northeast-bound right turn
movement (Mitigation Measure Transp-1[a]) would reduce queues to levels not exceeding existing
conditions. To implement this mitigation measure, the Project applicant shall either fully fund the
improvement subject to fee credits, or pay updated City Transportation Impact Fees if the City
includes these improvements in its Capital Improvement Program (CIP).
● At the Airport Boulevard/Miller Avenue/101 SB off-ramp (Intersection #10), and at the East Grand
Avenue/Grand Avenue intersection (Intersection #14), the Project would not extend or contribute to
queues beyond existing storage distances.
● At the intersection of Airport Boulevard/Grand Avenue (Intersection #12), the Project would extend
queues on the southbound left turn movement in the AM hour, which already exceed storage
capacity. Adding a second southbound left-turn lane and converting the southbound right-turn lane
to a through/right lane (Regulatory Requirement Transp-1B[c]) would reduce delay and improve
intersection operations, but would not reduce the length of the southbound left turn queue. These
improvements are already included in the East of 101 Traffic Impact Fee Program and the Project
Sponsor shall pay South San Francisco’s East of 101 Transportation Impact Fees, representing their
fair-share contribution toward this improvement, but the queuing impact would remain significant
and unavoidable.
The City of South San Francisco will coordinate with Caltrans and the County Transportation Authority to seek
implementation of Transportation Impact Fee Program improvements at intersections owned by Caltrans.
Response to Comment B-4
This comment notes that the City of South San Francisco, as lead agency, is responsible for all Project
mitigation, including any needed improvements to US-101, and that the Project's fair-share contribution,
financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed
for all proposed mitigation measures.
Chapter 2: Response to Comments on the Draft EIR
Page 2-8 Genentech Master Plan Update - Final EIR
The City of South San Francisco recognizes its responsibilities as lead agency to ensure implementation of all
required mitigation measures and regulatory requirements. As required by CEQA, the City will prepare a
Mitigation Monitoring and Reporting Program (MMRP) to identify all of the mitigation measures to which the
Project will make fair-share contributions, as well as the scheduling, implementation responsibilities and lead
agency monitoring for these mitigation measures, consistent with CEQA Guidelines section 15097. As
indicated in the Draft EIR (page 17-57), the Project would increase freeway volumes by one to eight percent
over existing traffic levels, but that there are no feasible mitigation measures for the Project’s impacts to
freeway segments due to constrained right-of-way and a corresponding inability to add traffic capacity or
reduce vehicle delay. Consistent with C/CAG Agency Guidelines for implementation of the 2015 Congestion
Management Program, the Project will implement a TDM program that is consistent with, and exceeds City
requirements, and that TDM program will serve to reduce its contribution of trips on US-101 freeway
segments.
From:Correa, Cruz@CHP
To:Uhazi, Mary@CHP; OPR State Clearinghouse
Cc:Ramos, Steve@CHP; CHP-30AAdesk; Scott, Mitchell@CHP
Subject:EIR - 335 - SCH #2017052064 - No Impact
Date:Monday, December 9, 2019 1:56:50 PM
Attachments:RE 063-MHU Environmental Document Review-SCH#2017052064-DUE TO STATE CLEARINGHOUSE BY
December 23 2019.msg
I reviewed the notice of completion for SCH #2017052064, the Genentech Campus Master Plan
Update, along with the Draft Environmental Impact Report (DEIR) and Technical Appendices.
No impact on the San Francisco Area’s local operations and or public safety by SCH #2017052064
was identified. Traffic-related issues that may arise have already been addressed in the DEIR or
Technical Appendices.
Please contact me with any questions or comments about my review.
--
Cruz Correa
Administrative Sergeant
CHP – San Francisco Area (335)
455 8th Street
San Francisco, CA 94103
(415) 557-1094
C-1
Letter C
California Highway Patrol
Chapter 2: Response to Comments on the Draft EIR
Page 2-10 Genentech Master Plan Update - Final EIR
Response to Letter C
California Highway Patrol
Response to Comment C-1
This comment notes that no impacts to the San Francisco area local operations and or public safety was
identified in the Draft EIR, and that traffic-related issues that may arise have already been addressed in the
Draft EIR and/or Technical Appendices. No further response is required.
D-1
D-2
Letter D
County of San Mateo, Sept. of Public Works
Letter D
County of San Mateo, Sept. of Public Works (cont.)
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-13
Response to Letter D
San Mateo County Department of Public Works
Response to Comment D-1
The San Mateo County Flood Control District is a Countywide Special District that was created by State
legislation in order to provide a mechanism to finance flood control projects. The legislation requires that a
flood control zone be formed over an entire watershed, and a proposed funding source determined, prior to
undertaking a flood control project. There are currently three active flood control zones within the SMCFCD,
including Colma Creek. The Colma Creek Flood Control Zone was originally created in 1964 to construct flood
control facilities in Colma Creek to alleviate flooding in the City of South San Francisco, and has since
constructed numerous improvements to alleviate flooding along the Colma Creek channel.
Based on available mapping (see Figure 1) the Genentech Campus does not appear to be included in the
Colma Creek Flood Control Zone. According to the South San Francisco Storm Drain System MS4 Map (see
Figure 2),2 stormwater runoff from the Genentech Campus is directed into a series of underground
stormdrain lines (primarily below Forbes Boulevard, DNA Way, Allerton Avenue and East Grand Avenue),
which eventually drain into the San Francisco Bay, well outside of the outlet of Colma Creek. Stormwater
runoff form the site is not directed to those City stormdrain lines that ultimately do outfall into the Colma
Creek flood control channel.
Response to Comment D-2
As indicated in the Draft EIR (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.
Standard City of South San Francisco condition of project approvals include requirements that sites subject to
C.3 requirements of the MRP comply with provisions of the San Mateo Countywide Stormwater Pollution
Prevention Program Technical Guidance Manual, including source controls (such as trash management) to
limit pollution of receiving waters.
2 https://www.ssf.net/departments/public-works/water-quality-control-plant/environmental-compliance
Source: San Mateo County Flood Control District
Figure 1
Location of Project Area in relation to
Colma Creek Flood Control Zone
Colma Creek Flood Control Zone
Genentech Master Plan Boundaries
Source : https://www.ssf.net/departments/public-works/water-quality-control-plant/envi-ronmental-complianceFigure 2South San Francisco Storm Drain System MS4 Map
E-1
E-2
Letter E
City of San Bruno
E-6
E-5
E-4
E-3
Letter E
City of San Bruno (cont.)
E-6
Chapter 2: Response to Comments on the Draft EIR
Page 2-18 Genentech Master Plan Update - Final EIR
Response to Letter E
City of San Bruno
Response to Comment E-1
Information presented on Tables 18-4 and 18-6 of the Draft EIR, indicating water supply and demands under
normal years and drought conditions, were derived from the Water Supply Assessment (WSA) prepared by
the California Water Service (CalWater) in November 2017, and provided to the City for use in this EIR. These
tables also match corresponding Tables 7-2 and 7-4 of CalWater’s 2015 Urban Water Management (UWMP)
for the South San Francisco District. The comment specifically requests an explanation of why the “normal
year” water demands as presented in Table 18-4 of the Draft EIR are lower than the “drought year” water
demands is presented in Table 18-6 of the Draft EIR.
The 2015 UWMP (page 19) includes the statement that, “the balance between supply and demand totals (as
presented in Table 18-4 of the Draft EIR, and Table 7-2 of the UWMP) excludes use reductions that are not
directly a function of CalWater supplies, but are externally-imposed by other entities, such as the 2015 state-
mandated cutbacks.” City staff and our environmental consultants have interpreted this statement to mean
that the externally imposed demand reductions (such as those imposed under the 2015 State-mandated
cutbacks) are included in the basis for estimating future water demands under normal years, as presented in
Table 18-4. However, these externally imposed demand reductions are not used as the basis for estimating
future demands under drought years, as presented in Table 18-6.
Under either of the water supply and demand scenarios presented in the Draft EIR, the higher water
demands as presented in Table 18-6 of the Draft EIR represent the greatest demand as compared to supply,
and demonstrate that the ‘worst-case’ (i.e., highest demands) have been assessed against ‘worst case’ (i.e.,
drought year) supply, and these impacts have been fully addressed in the Draft EIR.
Response to Comment E-2
As indicated in the Draft EIR (page 18-17), “Table 18-4 shows the projected supply and demand totals for the
three Peninsula Districts for a normal water year. In normal years, the full amount of Cal Water’s Individual
Supply Guarantee (ISG) of 39,967 AF is available, and the total of SFPUC-purchased water, SSF District
groundwater and the Bear Gulch District surface supplies meets the combined demands of the three Districts
through year 2040. Future demands are estimated as the product of future services and expected water use
per service.” As suggested by Table 18-4, although the full ISG of SFPUC water is available, CalWater’s
purchases would seek to match demands. For example, the year 2020 supply would include 1,535 AF of
groundwater supplies, 1,260 AF of Bear Gulch District surface supplies, and purchase of 37,430 AF of the total
39,967 AF of CalWater’s ISG, such that water supply would meet expected demand. As demands increase
over time, CalWater would purchase more of their SFPUC ISG supplies to meet growing demands.
Response to Comment E-3
A detailed discussion of groundwater supplies and groundwater management planning efforts since 2003 is
provided in the CalWater WSA (Appendix 18 to the Draft EIR). That information details the Sustainable
Groundwater Management Act, as amended in 2015 (SB 13, SB 226 and AB 1390), as well as the
Groundwater Storage and Recovery Agreement between SFPUC, Daly City, San Bruno and CalWater (June
2016). That Agreement requires agencies to limit groundwater extraction from the Westside Basin to allow
for storage recovery. In exchange, SFPUC supplies in-lieu water to affected agencies. The status of operating
groundwater wells is evaluated annually, and restrictions are expected to continue through 2020.
As noted in the CalWater WSA, a Westside Basin Model (HydroFocus, May 2011) indicated that the
sustainable municipal pumping rate of the Westside Basin is 6.9 mgd, and CalWater, Daly City, and San Bruno
intend to coordinate their respective pumping rates so that 6.9 mgd is not exceeded on an annual basis. Cal
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-19
Water plans to limit its production of groundwater from the Westside Basin to 1.37 mgd (1,535 AFY), which is
consistent with current pumping capacity and historical pumping rates. As indicated in Response to Comment
C-2, the water supplies indicated in Table 18-4 include this same 1,535 AF of groundwater supplies.
Response to Comment E-4
As noted on page 18-3 of the Draft EIR, “South San Francisco and San Bruno jointly own the South San
Francisco Water Quality Control Plant (WQCP).” This joint ownership is pursuant to a Joint Powers Agreement
(JPA) between the two cities, under which the City of South San Francisco operates the Plant. Consistent with
the JPA, the City of San Bruno will be advised and consulted on any projects to expand or modify the Plant
and/or outfalls, which may including future joint efforts with Genentech to consider innovative strategies to
increase opportunities for water recycling.
Response to Comment E-5
The year 2040 projection of 10.3 MGD of wastewater flows to the WQCP is the Final South San Francisco/San
Bruno Water Quality Control Plant Facility Plan Update (Corollo Engineers, April 2011), and as specifically
shown on Figure 1.3 of that document.
The Draft EIR also cites the same Facility Plan Update to conclude that, “the treatment capacity of 13 mgd is
adequate for a 30-year period, with an available reserve capacity of about 2.6 mgd.” The Draft EIR indicates
that the Project’s estimated net new wastewater flows of approximately 0.3 mgd represent approximately 19
percent of the cumulative increase in average dry weather flows assumed in the Facility Plan Update by year
2040 and would not result in a cumulatively significant increase in treatment capacity demand at the WQCP.
The Draft EIR does not suggest an allocation of the available 2.6 mgd capacity between SSF and San Bruno.
Response to Comment E-6
As noted on page 18-15 of the Draft EIR, the water demand factors used in Table 18-3 are, “derived from
Genentech’s 2016 CalWater utility bills for the Project Area, disaggregated by building and by land use type.
These water demand factors account for all of the prior water conservation strategies and initiatives that
Genentech has implemented since 2007.”
As also indicated on page 18-15 of the Draft EIR, “By using water demand factors that already account for
these prior water conservation and reduction efforts, Genentech is committing (at a minimum) to maintain
these already reduced water use factors, and to extend comparable water conservation and reduction levels
to all new development pursuant to the Project.”
F-1
F-2
Letter F
San Francisco International Airport
F-4
F-3
Letter F
San Francisco International Airport (cont.)
F-5
F-6
Chapter 2: Response to Comments on the Draft EIR
Page 2-22 Genentech Master Plan Update - Final EIR
Response to Letter F
San Francisco International Airport (SFO)
Response to Comment F-1
This comment acknowledges that the Draft EIR recognizes the proximity of the Genentech Campus to SFO,
and the requirements to consider federal, State, and local regulatory reviews specific to airport noise and
land use compatibility standards, Federal Aviation Administration (FAA) Part 77 height restrictions, and
airspace safety criteria of the Airport Land Use Compatibility Plan (ALUCP). 3 This comment also encourages
the City of South San Francisco to work closely with the C/CAG Board to determine project consistency with
the ALUCP and other regulatory review procedures. The City intends to work collaboratively with the C/CAG
Board for matters under their jurisdiction to ensure consistency with the ALUCP and other regulatory review
procedures.
Response to Comment F-2
The Draft EIR (page 13-4) recognizes that the Project Area is entirely within the SFO Airport Influence Area
(AIA). As such, the compatibility criteria specific to noise, safety, and airspace protection as contained within
the ALUCP are applicable to the Project, and the C/CAG Board will exercise its statutory duties to review the
Project. An assessment of the Project’s consistency with ALUCP compatibility criteria specific to noise, safety,
and airspace protection is provided in the Draft EIR (beginning at page 13-4), identifying no inconsistencies.
Response to Comment F-3
As shown on Figure 13-1 of the Draft EIR, the Project Area is located outside of the area subject to airport
operations-related noise contours of 65 dBA CNEL, in an area where commercial and industrial land use and
related structures (such as the Project) are compatible, without restrictions. The Genentech Campus Master
Plan Update does not propose any noise sensitive uses that would requires future evaluation.
To the extent that Genentech Campus properties are required to include a real estate disclosure regarding
airport impacts, such disclosures would be included in any future real estate transactions of Genentech-
owned property within the Campus.
Response to Comment F-4
The Draft EIR (at page 13-6 and as shown on Figure 13-2) fully discloses that the Project site is located within
the FAA Part 77 Conical Surface for airport operations and that the FAA requires notification of proposed
construction for any project that may have a potential effect on air navigation facilities. A “Determination of
No Hazard” from the FAA is included as a requirement of individual projects pursuant to the Master Plan
Update, as required per Mitigation Measure Land Use 2 - Building Height Limits.
Response to Comment F-5
This comment concurs with Response to Comment F-3 (above) with respect to noise compatibility, agreeing
that the Project Site is located outside of the projected 2020 CNEL 65 dB noise contour, where the noise
compatibility policies of the ALUCP do not apply.
3 As found in Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport
(ALUCP), City/County Association of Governments of San Mateo County (C/CAG), 2012
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-23
Response to Comment F-6
The Noise chapter of the Draft EIR does indicate that childcare centers and preschools in the East of 101 Area
are considered noise sensitive areas, but that noise impacts attributable to aircraft overflight would not
adversely affect these uses (i.e., would not exceed 65 dBA CNEL) based on the noise contours as published in
the ALUCP.
G-1
G-2
Letter G
Rob Lau
Chapter 2: Response to Comments on the Draft EIR
Genentech Master Plan Update - Final EIR Page 2-25
Response to Letter G
Rob Lau
Response to Comment G-1
The Biology chapter of the Draft EIR (Chapter 7) provides a comprehensive analysis of the Project’s potential
effects on special-status species. The analysis is organized by sub-topics and species type. Nine special-status
animal species are known to breed or could potentially breed in the Study Area or its vicinity, to occur
commonly as non-breeders in the Study Area (and thus could potentially be substantially affected by
activities that occur under the Project), and/or are of particular concern to regulatory agencies. These species
include the Central California Coast steelhead, green sturgeon and longfin smelt, California Ridgway’s rail,
burrowing owl, San Francisco common yellowthroat and Alameda song sparrow, and harbor seal and sea lion.
Potential impacts resulting from implementation of the Project on each of these species, as well as potential
impacts to sensitive natural communities, migratory birds, and impacts pertaining to invasion of non-native
plant species, are fully analyzed in the Draft EIR and mitigation measures are identified, where necessary to
reduce these potential impacts to less than significant levels.
Response to Comment G-2
The remainder of this comment letter addresses issues related to rent prices, tax revenue, and reinvestment
by Genentech and other large companies back into the community. These comments pertain to the relative
economic merits of the Project, but are not pertinent to environmental effects or CEQA. Pursuant to CEQA
Guidelines section 15131, “economic or social effects of a project shall not be treated as significant effects on
the environment. No response to these matters is required or provided in this EIR.
From: Koray Ergur <[email protected]> To: "Rozzi, Tony" <[email protected]> Cc: "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "'Kevin Fuller'" <[email protected]>, "Andres Claure ([email protected])" <[email protected]>, Koray Ergur <[email protected]>
Subject: RE: Genentech Master Plan EIR
12/23/2019
Mr. Rozzi,
First, Thank you for sharing this information very promptly. By the time I realized
existence of this proposal, I was already missed public hearing date by one day. When I
contact you shared this valuable info you did email me information very rapidly. Thank
You again, Now let’s get to the main points,
1. Oyster Point Island is about 1Mile square area approximately
about 650 Acre “World BIO+TECH Headquarter City” (Area is
Guesstimate Not Exact)
2. Genentech Master Plan Update 2019 Covering 207 Acres (Nearly
Half of the Island)
3. UrbanX, Inc, Our company has a long term recorded ground lease
next 99 years APN 015-200-190-5 About 108.75 Acre. Which is
located front of Genentech land mass must have a access thru
Genentech Campuses. (See attached flyer)
4. As we know shorelines being under sea levels are rising well
known threats, Next era cities will be building on waters/oceans
but, first project will be starting as a test/pilot projects in San
Francisco Bay see attached “Seasteating” website Wikipedia page
dated today! For make it easier you are reading, I already attached
to this email and highlighted page #3 FYI!
5. I already personally shared with Genentech/City of SSF principals
our Vision/Master Plan as well. (See Attached Meeting Notes and
Discussions)
6. Based on what I have outlined 1-5 I have major vested
interest/concern in Genentech Master Plan 2019. Make sure this
master plan by 800-pound gorilla a/k/a “Genentech” does not kill
our future vision/project. I do believe I have enough past bad
experiences with City of SSF + Genentech, in order to be
concerned, which they are;
a. City of SSF currently has a fraudulent title on one of Ergur’s
stolen property located at 938 Linden Avenue. As we speak
H-1
Letter H
Koray Ergur
there is a currently on-going lawsuit at SF Court Case #
CGC-16-550825
b. When City of SSF/Genentech build Bay Trail they build it
100% on our property (None on Genentech land) without
even notifying property owner. (illegally)
c. These are just a few others also exist.
7. Plus, I’m including Genentech parties as well as shared vision
documents into this email. Our true intention is making sure both
projects are dealt with together same studies, Last thing we don’t
want to be bulldoze by both of you, Based on outlines above until
we meet and discuss sone sort of win-win solution road map.
Our position is strongly opposing this study at this point. Until we meet and reach
some sort of understanding how we can solve it beneficial to all parties. Please make a
proper registration with system our current position.
Decision will be up to you guys, Are we going forward to war or work with harmony
together! Choice is yours. Our choice is #2.
Sincerely
Koray Ergur
Chapter 2: Response to Comments on the Draft EIR
Page 2-28 Genentech Master Plan Update - Final EIR
Response to Letter H
Koray Ergur
This letter and its attached materials do not raise any issues related to the Draft EIR or the environmental
impacts of the Genentech Master Plan Update Project. Rather, it suggests plans for a separate project on
approximately 108 acres within the San Francisco Bay (APN 015-200-190-5) adjacent to the Genentech
Campus, and suggests that this separate project requires access through the Genentech Campus.
This response provides no comment as to the legitimacy of any assertions made in the letter, other than to
note that the City has no official application on file for such a project, and that such a project is not indicated
in the South San Francisco General Plan. Thus, this separate project is not included in the cumulative baseline
as used in the Draft EIR.
This letter does reference the threats associated with rising sea levels. The Draft EIR (page 10-2) notes that
“the over-abundance of GHGs in the atmosphere has led to an unexpected warming of the earth and has
already started affecting the Earth’s climate system”, including effects related to sea level rise. Chapter 10 of
the Draft EIR analyzes the Project’s contributions to GHG emissions, concluding that the Project effects would
be less than significant with implementation of all regulatory requirements. Sea level rise is also addressed in
the Hydrology chapter of the EIR (Chapter 12). The Hydrology chapter of the EIR includes (at page 12-24) a
non-CEQA analysis of the effects that potential future sea level rise scenarios may have on the Genentech
Campus site.
Sid Commons Final EIR Page 3-1
3
Revisions to the Draft EIR
Introduction
The following chapter presents corrections and modifications to text as presented in the Draft EIR. These
changes and corrections have been initiated by City of South San Francisco staff (as Lead Agency), specific to
the topic of Vehicle Miles Travelled. No changes to the Draft EIR have been made, or are necessary in
response to public comments received on the Draft EIR. Those comments on the Draft EIR received during
the public comment period are fully addressed in Chapter 2 of this Final EIR, and no revisions to the Draft EIR
were necessary to address those comments.
As indicated in the Introduction to this document, this Response to Comments document, together with the
Draft EIR and the Draft EIR Appendices, constitute the Final EIR for the Genentech Master Plan Update
Project. Thus, changes to the Draft EIR presented below supersede the corresponding original text of the
Draft EIR. Throughout this chapter, newly added text is shown in double underline format, and deleted text is
shown in strikeout format. Changes are listed in the order in which they appeared in the Draft EIR.
Changes and Corrections to the Draft EIR - VMT
Draft EIR Approach to Vehicle Miles Travelled (VMT)
Chapter 17 of the Draft EIR presented an evaluation of the potential impacts of the Master Plan Update (the
Project) related to transportation. This chapter described the existing conditions in and near the Project Area,
evaluated the extent to which transportation and traffic conditions may be affected by implementation of
the Project, and identified mitigation measures, where needed, to address these potential impacts.
As noted in the Draft EIR (beginning at page 17-100), pursuant to Senate Bill 743, the Governor’s Office of
Planning and Research (OPR) released proposed changes to the state’s CEQA Guidelines in 2016 that amend
the way transportation impacts are analyzed. Specifically, SB 743 (Public Resources Code Section 21099)
required OPR to amend CEQA Guidelines to provide an alternative to Level of Service (LOS) methodology for
evaluating transportation impacts. These changes to CEQA Guidelines result in significant changes in how
transportation impacts are evaluated, and also result in significant changes in how mitigation is imposed
through the CEQA process. Mitigation may include measures that seek to reduce or avoid impacts related to
vehicle miles travelled (VMT) and/or trip generation, rather than improvements to increase levels of service
(LOS) to accommodate increased traffic demands.
The Draft EIR also noted that the new CEQA Guidelines pertaining to transportation impacts that were
created to implement SB 743 do not go into full effect statewide until July 2020. South San Francisco has yet
to officially determine how these CEQA changes will be implemented, but they will become effective in the
relatively near term. The Draft EIR provided an analysis of the Project’s impacts related to VMT, indicating
that this analysis was for informational purposes only and was not considered a CEQA topic. However, the
Draft EIR did indicate that its VMT analysis may provide a context for future City consideration of appropriate
new VMT thresholds and mitigation strategies, as well as alternative investment programs for how the City
uses its development impact fees.
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-2
Reconsideration of the VMT Approach
The City of South San Francisco released the Draft EIR for the Project on November 8, 2019, and the 45-day
public review and comment period on that Draft EIR ended on December 23, 2019. At that time, the July
2020 date for statewide implementation of the new CEQA Guidelines related to VMT was more than six
months in the future. The City of South San Francisco has embarked on an effort to determine how these
changes in transportation impact analyses will be implemented within the City, but no official action had yet
been taken. As of the date of publication of this Response to Comment / Final EIR document the City has not
adopted an official VMT methodology or related CEQA thresholds, although these are important
considerations being deliberated pursuant to the City’s current General Plan Update effort.
The Genentech Master Plan Update EIR is a programmatic document that evaluates the physical
environmental and land use changes that may result from future development that could occur pursuant to
adoption and implementation of the Genentech Campus Master Plan Update. These future developments
and changes on the Genentech Campus will occur after the July 1, 2020 statewide mandate for VMT analysis.
An important purpose of this Program EIR is to simplify the task of preparing subsequent project-level
environmental documents for these future projects, and to use the streamlining and tiering provisions of
CEQA to the maximum feasible extent. To achieve this purpose, specifically as it pertains to transportation
impacts, the City has decided to elevate the VMT analysis as presented in the Draft EIR to a full CEQA topic,
and not just presented for informational purposes.
● Elevating the VMT analysis as presented in the Draft EIR to a CEQA topic does not constitute “new
information” as defined by CEQA Guidelines Section 15188.5, and does not require recirculation of
the Draft EIR. Other than now establishing the relative significance of this information pursuant to
CEQA, all of the VMT-related analysis presented in the Draft EIR remains as-is. No additions or
subtractions of that information (thresholds, methodologies or conclusions) are suggested (see
detailed Changes to the Draft EIR, below).
● Elevating the VMT analysis as presented in the Draft EIR to a CEQA topic does not constitute “a new
significant environmental impact” as defined by CEQA Guidelines Section 15188.5 (1). The VMT
analysis presented in the Draft EIR concludes that, if assessed as a CEQA topic, the VMT impacts of
the Project would be less than significant. This conclusion demonstrates that the Project’s VMT
impacts are a less than significant effect (not a new significant effect), and recirculation of the Draft
EIR is not required.
● In the absence of a City-preferred VMT threshold for CEQA analysis, the Draft EIR relied on guidance
provided by the California Office of Planning and Research (OPR) in its “Revised Proposal on Updates
to the CEQA Guidelines on Evaluating Transportation Impacts in CEQA” (January 2016). This guidance
document, which has been updated per the OPR “Technical Advisory on Evaluating Transportation
Impacts In CEQA” (December 2018), suggests thresholds by which to assess VMT-based
transportation impacts. These thresholds include:
o A proposed residential project exceeding a level of 15 percent below existing VMT per capita
may indicate a significant transportation impact. Existing VMT per capita may be measured
as regional VMT per capita or as city VMT per capita, whichever is higher.
o A proposed office project exceeding a level of 15 percent below existing regional VMT per
employee may indicate a significant transportation impact.
o A net increase in total VMT for a retail project may indicate a significant transportation
impact.
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-3
These are the same, or very similar thresholds that have been adopted by other cities that have
chosen to be early-adopters of VMT as a CEQA topic.1 Use of these thresholds for this EIR is
appropriate pursuant to CEQA, but does not preclude the City from ultimately adopting different
thresholds in the future.
● Similarly, the methodology used in the Draft EIR to calculate VMT also relies on OPR’s
recommendations, but does not preclude the City from adopting or using a different methodology in
the future.
Changes to the Draft EIR
The following represent the specific changes to the Draft EIR (starting at page 17-100) that are needed to
make the VMT analysis that was included in the Draft EIR into a full CEQA topic.
Changes to Draft EIR beginning at Page 17-28 et.seq.:
Thresholds of Significance
City of South San Francisco and San Mateo County C/CAG guidelines, as well as changes to the state’s
CEQA Guidelines initiated by the Governor’s Office of Planning and Research (OPR) pursuant to SB 743,
were used to identify thresholds of significance to determine whether implementation of the Project
would result in significant environmental impacts. The Project would have a significant transportation or
circulation impact if it were to:
1. Exceed 100 net new peak hour trips on the Congestion Management Program roadway system
(C/CAG criteria)
2. Conflict with applicable plans, ordinances or policies establishing measures of effectiveness for the
performance of the circulation system. These thresholds are specifically defined as:
3. If signalized intersection operations and all-way-stop operations would deteriorate from operating at
an acceptable LOS (LOS D or better) to an unacceptable operation (LOS E or F) with the addition of
project traffic
a. If uncontrolled turn movements or side-street stop-controlled approach operations at
intersections would deteriorate from operating at LOS E or better to LOS F and total volumes
passing through the intersection would increase by at least one percent if at least one leg is
connected to a Caltrans ramp, and two percent otherwise. Side street stop criteria are applicable
only for approaches with more than 25 trips during any peak traffic hour
b. If the Project would increase the total traffic volume passing through an intersection by two
percent or more, at an intersection with signalized or all-way stop operations already at a
baseline LOS E or F, or when a side street stop controlled approach is at a baseline LOS F. Side
street stop criteria are applicable only for approaches with more than 25 trips during any peak
traffic hour
c. If Project traffic would increase baseline volumes at an unsignalized intersection to meet peak
hour volume signal warrant criteria levels, or to meet pedestrian/school crossing signal warrant
criteria levels
1 City of San Francisco Planning Department, Transportation Impact Analysis Guidelines, February 2019, page 15; City of
Oakland, Interim Update to Transportation CEQA Thresholds and Guidelines, October 2016; City of San Jose, Transportation
Analysis Handbook, April 2018, page 17
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-4
d. If the Project would increase traffic entering an unsignalized intersection by two percent or
more, at an intersection with baseline traffic levels already exceeding peak hour volume signal
warrant criteria levels
e. Increase volumes on a given traffic movement downstream of Caltrans facilities by one percent
or more, and in doing so would either cause vehicle queues to exceed existing storage space for
that movement, or would contribute to existing vehicle queues that exceed storage space for
that movement
f. Degrade operation of the US 101 freeway or freeway ramps from LOS E to LOS F with at least a
one percent increase in volumes, or increase volumes by more than one percent on a freeway
segment or a freeway ramp with baseline LOS F operation, or make a considerable contribution
to a cumulative degradation of the US 101 freeway or freeway ramps operations, according to
the same criteria
4. Substantially increase transportation hazards due to a geometric design feature or incompatible
uses, or result in inadequate emergency access.
5. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit,
bicycle and pedestrian facilities.
6. If the project would make a considerable contribution to a cumulative impact, based on the same
criteria
7. 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 (whichever is higher)
The above significance criteria primarily relate to vehicular delay and traffic congestion. However,
statewide legislation will render impacts based on vehicular delay no longer a significant impact under
CEQA in the near future. Senate Bill (SB) 743 changes CEQA transportation impact analysis significance
criteria to eliminate auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as a
basis for determining significant impacts under CEQA (although a jurisdiction may choose to maintain
these measures under its General Plan). The proposed changes in CEQA Guidelines to implement SB 743
present Vehicle Miles Traveled (VMT) as an appropriate measure of transportation impacts. At present,
Although the City of South San Francisco has not officially adopted VMT as a transportation impact
criteria or established local VMT significance thresholds, As a result, a VMT analysis is not included as
part of this EIR, as a CEQA analysis, based on OPR guidelines and recommendations. , but is presented for
informational purposes toward the end of this chapter.
Changes to Draft EIR beginning at Page 17-89 et.seq.:
Vehicle Miles Travelled (VMT)
Impact Transportation 9: The Project’s calculated rate of VMT per employee is lower than the VMT
target reduction thresholds of 15% below the regional average worker-based VMT, the Project
would not exceed the VMT threshold, and VMT impacts of the Project would be less than
significant. (Less than Significant)
Pursuant to Senate Bill 743, the Governor’s Office of Planning and Research (OPR) released proposed
changes to the state’s CEQA Guidelines in 2016 that will amend the way transportation impacts are
analyzed. Specifically, SB 743 (Public Resources Code Section 21099) required OPR to amend CEQA
Guidelines to provide an alternative to Level of Service (LOS) methodology for evaluating transportation
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-5
impacts.2 The new CEQA Guidelines sections created by SB 743 do not go into full effect statewide until
July 2020, and South San Francisco has yet to determine how these changes will be implemented within
the City. Therefore, the following analysis is provided for informational purposes only, and is not
considered a CEQA topic.
These changes to CEQA Guidelines will result in significant changes in how transportation impacts are
evaluated pursuant to CEQA. These analytic changes may also result in significant changes in how
mitigation is imposed through the CEQA process, potentially including measures that seek to reduce or
avoid impacts related to VMT and/or trip generation, rather than improvements to increase levels of
service (LOS) to accommodate increased traffic demands. These changes are not effective in South San
Francisco yet, but they will likely become effective in the relatively near term. The analysis provided in
this section of the EIR is for informational purposes only, and provides for a CEQA assessment of Project-
related VMT-based impacts, and may provide a context for future City consideration of appropriate VMT
thresholds, mitigation strategies and alternative investment programs for how the City uses its
development impact fees.
Criteria Used for this Analysis
In the absence of a City-preferred methodology or threshold, this analysis relies on OPR’s Revised
Proposal on Updates to the CEQA Guidelines on Evaluating Transportation Impacts in CEQA (January
2016), which suggests several alternative means by which to assess transportation impacts, including the
following: 3
1. Would the project achieve 15 percent lower per capita or per employee VMT than existing
development?
2. Would the project achieve an average daily VMT per employee (worker) that is 15% lower than the
regional average daily VMT rate or 15% lower than the City’s average daily VMT rate, whichever is
higher?
The OPR’s Revised Proposal on Updates to the CEQA Guidelines on Evaluating Transportation Impacts in
CEQA finds (absent any more project-specific information to the contrary) that per capita or per
employee VMT fifteen percent below the existing regional average daily per employee VMT rate, or 15%
lower than the City’s average daily per employee VMT rate that of existing development may be used as
a reasonable threshold, for the reasons described below:
● SB 743 states that the criteria for determining significance must promote the reduction in
greenhouse gas emissions. SB 743 also states the Legislature’s intent that the analysis of
transportation in CEQA should better promote the state’s goals of reducing greenhouse gas
emissions. It cites in particular the reduction goals in the Global Warming Solutions Act and the
Sustainable Communities and Climate Protection Act, both of which call for substantial reductions.
The California Air Resources Board established long-term GHG reduction targets for the largest
regions in the state that ranged from 13 to 16 percent.
2 Implementation of SB 743 must “promote the reduction of greenhouse gas emissions, the development of multimodal
transportation networks and a diversity of land uses.” (New Public Resources Code Section 21099(b)(1).) Measurements of
transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates,
or automobile trips generated.” Once the new CEQA Guidelines take effect state-wide, are amended to include those alternative
criteria, auto delay will no longer be considered a significant impact under CEQA.
3 Governor’s Office of Planning and Research, Revised Proposal on Updates to the CEQA Guidelines on Evaluating
Transportation Impacts in CEQA, Implementing Senate Bill 743 (Steinberg, 2013), January 20, 2016
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-6
● Caltrans has developed a statewide VMT reduction target in its Strategic Management Plan.
Specifically, it calls for a 15 percent reduction in per capita VMT compared to 2010 levels, by 2020.
● The First Update to the AB 32 Scoping Plan states, "Recognizing the important role local
governments play in the successful implementation of AB 32, the initial Scoping Plan called for local
governments to set municipal and communitywide GHG reduction targets of 15 percent below then-
current levels by 2020, to coincide with the statewide limit."
Achieving 15 percent lower per capita or per employee VMT than existing development is, therefore,
both reasonably ambitious and generally achievable.4 If the Project were to result in VMT rates that
exceed a 15% reduction threshold, the Project’s transportation effects could would be considered
inconsistent with pending statewide and local environmental and transportation policies, and a
significant effect. Use of OPR’s recommended VMT thresholds for this informational analysis does not
preclude the City from ultimately adopting another methodology or alternative significance threshold in
the future.
Methodology
For purposes of this analysis, Project-generated VMT per employee was measured relative to baseline
data provided by the Metropolitan Transportation Commission (MTC) through their Travel Demand
Model (“Travel Model One”).5 General components of the Travel Model One model include a wide array
of analytical approaches including various transportation mode-choice models, activity duration models,
time-use models and models of individual micro-simulations, etc. Ultimately, the combination of these
datasets is designed to realistically represent travel behavior, adequately replicate observed activity-
travel patterns and ensure model sensitivity to infrastructure and policies.
MTC’s Travel Model One contains 1,454 regional Traffic Analysis Zones (TAZs) that span across the San
Francisco Bay Area. The model includes nine TAZs that represent the City of South San Francisco (TAZ #s
209 through 215, and 230 and 231). The Project Area is located in TAZ #212, which represents all of the
East of 101 Area, as well as large portions of the industrialized areas south of Downtown along Spruce
and Linden Avenues (see Figure 17-13). Several steps were taken to analyze the potential effects of the
Project relative to VMT. These steps include:
• Identifying the baseline VMT and potential target thresholds on a per-employee basis
• Calculating the Project’s VMT per employee by applying VMT reductions resulting from Genentech’s
proposed Transportation Demand Management (TDM) program, as well as daily VMT reductions
based on other factors that influence daily travel behavior (i.e., on-Campus amenities, the DNA
shuttle vans, etc.), and
• Comparing the Project’s resulting per employee VMT rate to existing conditions, to a 15 percent
lower per-employee VMT than existing development, and to a 15 percent reduction in the City of
South San Francisco and the San Francisco Bay Area regional per employee VMT (for both existing -
2015, and future – 2040), to determine if the Project would exceed these alternative thresholds
4 Note: Lead agencies may apply more stringent thresholds at their discretion (Section 21099)
5 The Metropolitan Transportation Commission (MTC), Travel Demand Model (“Travel Model One”) transportation model is
an activity-based (or tour-based) travel demand model for the nine-county San Francisco Bay Area, and widely used by counties
and communities throughout the San Francisco Bay Area. The development methodology, datasets and metrics provided in the
Model are often used by city and county agencies to develop their own travel demand models, and the data is regularly
validated for consistency among all nine counties.
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-7
VMT Baseline and Targeted VMT Reductions
Based on Travel Model One data, the most current (year 2015) VMT rate for TAZ #212 (the TAZ in which
the Project is located) is 26.3 VMT per employee. The most current citywide average VMT rate (2015) is
25.9 23.9 VMT per employee, and the projected 2040 citywide average VMT rate is 23.3 25.9 VMT per
employee. The higher per employee VMT rate for TAZ #212 as compared to the City average reflects the
broader commute-shed for many of the tech and biotech companies located within this TAZ, where
employees from across the region, travelling longer distances, commute to the East of 101 Area for
highly desirable jobs. The latest data from Plan Bay Area also provides a current (year 2015) worker-
based VMT for the region at 22.7 VMT per employee, and a projected year 2040 worker-based VMT for
the region of 20.3 VMT per employee.
Based on the thresholds used in this EIR, analysis, the target thresholds for VMT reductions are 15%
below the 2015 and 2040 worker-based regional VMT rates. This represent a target rate of 19.3 VMT per
employee (or 15% below the 2015 rate of 22.7 VMT per employee) in year 2015, and a target rate of 17.3
VMT per employee (or 15% below the 2040 rate of 20.3 VMT per employee) in year 2040. Note that this
threshold conservatively compares the Project against the lower regional average VMT rates instead of
the higher citywide average VMT rates, whereas OPR guidance allows comparison to whichever VMT rate
is higher.
Estimating the Project’s VMT
Based on standard Institute of Transportation Engineers (ITE) trip generation rates as applied to the
Project’s net new land uses, the Project would generate approximately 32,200 daily trips.6 This is a
baseline number of daily trips that does not account for any application of the Project’s TDM measures.
● The Project’s proposed TDM reductions (i.e., a 47 percent reduction in AM peak hour drive alone
trips to the Campus as necessary to maintain the Trip Cap) are applied to all AM peak period trips to
the Campus, all PM peak period trips from the Campus and partial application to mid-day trips to
mirror the existing GenenBus schedules. This results in a 31% overall reduction in daily trips as
compared to standard ITE rates, or approximately 22,200 total daily trips.7
● Conservatively assuming an additional 5% reduction for internalized trips (i.e., daily trip reductions
attributable to the availability of on-Campus amenities (e.g., cafeterias, personal services and
daycare facilities), access to on-Campus DNA shuttles, and bicycle and pedestrian amenities, results
in approximately 21,000 daily trips attributable to the Project.
● Multiplying these 21,000 daily trips by an average trip length of 10.2 miles per trip (a weighted
average of home-based work trips and non-home-based trips for TAZ #212) for year 2015,8 the
Project would generate approximately 214,200 total vehicle miles travelled.
● Multiplying these 21,000 daily trips by an average trip length of 9.3 miles per trip (the same weighted
average of home-based work trips and non-home-based trips for TAZ #212) for year 2040, the
Project would generate approximately 194,900 daily total vehicle miles travelled.
● Dividing these total daily vehicle miles travelled by the total number of new employees pursuant to
the Project (12,500) yields an average of 17.1 VMT per employee for year 2015, and an average of
15.6 VMT per employee for year 2040.
6 Fehr & Peers (EIR Transportation consultant), personal communication, October 2018
7 This is the number of daily trips (conservatively) used in the air quality and greenhouse gas emissions analysis as included in
this EIR.
8 Derived from the MTC Travel Model One data
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-8
This calculation of these Project-specific VMT rates per employee, and a comparison to calculated VMT
based on standard ITE rates (i.e., without the Project’s Trip Cap and associated TDM) is shown below in
Table 17-25.
Table 17-25: Calculation of Project VMT per Employee
Project Project, Based on Standard ITE Rates
For Year 2015
Project Daily Trips 21,000 32,200
Average Trip Length x 10.2 x 10.2
Total VMT 214,200 328,440
Project Employees ÷ 12,500 ÷ 12,500
Per Capita VMT 17.1 26.3
Regional Average Worker-Based VMT vs. 22.7 vs. 22.7
Percent Below/Above Regional Average Target -25% + 116%
For Year 2040
Project Daily Trips 21,000 32,200
Average Trip Length x 9.3 x 9.3
Total VMT 194,880 298,816
Project Employees ÷ 12,500 ÷12,500
Per Capita VMT 15.6 23.9
Regional Average Worker-Based VMT vs. 20.3 vs. 20.3
Percent Below/Above Regional Average -23% + 117%
Source: Correspondence with Fehr & Peers, 2019
Mitigation Measures Comparison against Thresholds
None required. As indicated in Table 17-25, the Project’s calculated rate of 17.1 VMT per employee (year
2015) and 15.6 VMT per employee (year 2040) is lower than the VMT target reduction thresholds of 15%
below the regional average worker-based VMT for both year 2015 and year 2040.
The Project does would not exceed the VMT thresholds, used in this analysis. If assessed as a CEQA topic,
and the VMT impacts of the Project would be less than significant. If the City of South San Francisco were
to rely on the VMT thresholds used in this analysis for assessment of transportation impacts and
mitigation measures under CEQA, then n No mitigation measures beyond the Project’s proposed Trip Cap
and corresponding TDM trip reductions (i.e., 47 percent reduction in drive-alone trips) are would be
required.
Possible Implications for Future Project Analysis and Mitigation Measures
Even if project-specific VMT impacts were to be determined less than significant, The City of South San
Francisco could still requires projects, particularly those in the East of 101 Area, to pay traffic fees and/or
implement roadway improvements. Existing General Plan policies address these Traffic Impact Fee
requirements (i.e., General Plan Policy 4.2-I-6 regarding needed intersection and roadway improvements
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-9
to enhance mobility in the East of 101 Area, and Policy 4.2-G-12 providing for a fair and equitable means
for paying for future street improvements via development impact fees). However, the focus of CEQA
analysis and applicable mitigation of traffic impacts has shifted would shift in a direction more consistent
with General Plan Policy 4.2-G-10, which calls for making “efficient use of existing transportation
facilities, improved alternate travel modes and enhanced integration of transportation systems serving
South San Francisco to reduce vehicle-miles traveled.” 9
The Project’s VMT analysis presented above demonstrates the relative importance of an effective TDM
program as a VMT reduction and overall trip reduction strategy. Alternatively, the cumulative traffic analysis
presented under Impacts Transp 8, 9 and 10 above demonstrate that, even with implementation of all
feasible LOS-based mitigation measures, traffic congestion will continue to be significant and unavoidable
throughout many parts of the East of 101 Area, at freeway ramps and on the freeway. By reducing the
number of cars from the overall transportation system with increased TDM performance, a more sustainable
transportation system may be achievable, rather than increasing the capacity of roadways and intersections
to accommodate increased vehicle demand levels.
Genentech will be able to achieve its Campus-wide TDM goal of 50% TDM trip reductions for Campus arrivals
by increasing its current TDM program capacity commensurate with new employee growth, and by increasing
its overall non-single occupant mode share split by an additional approximately 10 percent. Additionally,
Genentech expects to continue its flexible work arrangement initiatives. Assuming that these initiatives
maintain the current average of 13 percent of the Genentech workforce choosing a flexible work option, this
would further reduce the number of AM peak hour Campus arrivals, resulting in a total trip reduction rate of
approximately 57 percent - far exceeding the 47 percent trip reduction rate needed to achieve the Trip Cap.
Genentech is able to attain these drive-alone trip reductions in part because of the scale of the Genentech
Campus and employment base, the substantial capital investments already made in buses, ferries and
shuttles, and the commitment to on-going financial assistance to off-set the transit/alternative travel mode
costs of its employees. Not all developments within the East of 101 Area will have the resources and
capabilities of Genentech to be able to achieve such a highly efficient TDM program on an independent basis.
The City of South San Francisco could assist in helping to achieve higher TDM trip reduction rates across the
entire East of 101 Area by reconsidering its investment strategy in East of 101 transportation improvements.
Rather than investing its accrued and future cumulative development Transportation Impact Fees solely on
intersection and roadway improvements that increase vehicle capacity, the City may consider alternative
investments of these fees. Alternative investments might include projects and programs that make the most
efficient use of existing transportation facilities, improve alternate travel modes, and enhance the transit
systems serving the East of 101 Area, thereby reducing the total vehicle trips generated and commensurate
VMT. Such investments could include measures to make TDM more efficient, available and desirable for the
East of 101 employers and employees, consistent with the recommendations of the City’s recent Mobility
20/20 Report, including but not limited to:
• Capital investments in buses and shuttle vans to provide “last-mile service” between regional transit
stations (i.e., the relocated Caltrain station and the South San Francisco BART station) and
employment centers in East of 101
• Designs and improvements at the relocated Caltrain station to improve circulation efficiency for TDM
shuttles and buses that pick-up and drop-off employees at the station
• Establishing Bus Rapid Transit (BRT) lanes on East Grand Avenue and potentially on Oyster Point
Boulevard
9 South San Francisco, General Plan Transportation Element
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-10
• BRT improvements may include dedicated bus or transit lanes with signal priority, queue jumps, and
median or curb improvements at bus stop locations
• Increasing the frequency and origin/destination of ferry service at the Oyster Point ferry landing
• Increasing bicycle and pedestrian use by filling gaps in the existing bike and pedestrian network and
increasing bike and pedestrian routes, especially along abandoned rail alignments within the East of
101 area, and
• Establishment of a special Transit Management Agency (TMA) and/or a Community Facilities District
(CFD), whereby employers in the East of 101 area could pool their resources and TDM needs,
thereby creating efficiencies of scale similar to those achieved by Genentech.
Changes and Corrections to the Draft EIR – LOS Analysis
Changes to Local Intersection Level of Service/Queuing (Existing plus Project)
Page 2-48: Executive Summary
Transp 10 Transp 8: 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 at 7 freeway segments (northbound US-101 north of Oyster Point Boulevard;
southbound US-101 north of Oyster Point Boulevard; northbound US-101 between Oyster Point
Boulevard and Grand Avenue; southbound US-101 between Oyster Point Boulevard and Grand
Avenue; northbound US-101 between Grand Avenue and Produce Avenue; southbound US-101
between Grand Avenue and Produce Avenue; and northbound US-101, south of Produce Avenue).
Page 17-55: Resulting Level of Significance
Airport Boulevard/Grand Avenue (#12): Although the improvements identified in Regulatory
Requirement Mitigation Measure Transp-1B would reduce vehicle delay and LOS to a less than
significant level, these improvements cannot reduce the length of the southbound left turn queue to
which the Project contributes. Further 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, and queuing impacts would remain significant and unavoidable.
(SU)
Page 17-81: Resulting Level of Significance
Produce Avenue/Airport Boulevard/San Mateo Avenue (#19): The identified mitigation measure
would decrease delay at this intersection but would not improve operations to an acceptable level of
service. There are no additional feasible mitigations at this intersection due to constrained roadway
right-of-way.
South Airport Boulevard/Gateway Boulevard (#20): The identified mitigation measure would
decrease delay at this intersection but would not improve operations to an acceptable level of
service. There are no additional feasible mitigations at this intersection, as any further roadway
capacity improvements would lengthen crosswalk distances and further exacerbate conflicts with
bicyclists along Airport Boulevard and Gateway Boulevard.
Chapter 3: Revisions to the Draft EIR
Genentech Master Plan Update, Final EIR Page 3-11
South Airport Boulevard/Utah Avenue (#22): The identified mitigation measure would decrease
delay at this intersection to an acceptable level of service in the PM, but would not improve
operations to an acceptable level of service in the AM peak hour. There are no additional feasible
mitigations at this intersection due to constrained roadway right-of-way.
I-380 Westbound Ramp/South Airport Boulevard (#26): The identified mitigation measure would
decrease delay at this intersection to an acceptable level of service, but would not decrease queue
lengths on the southbound right turn movement. There are no additional feasible mitigations at this
intersection due to constrained right-of-way and downstream queuing on the I-380 Westbound
ramp.
Genentech Master Plan Update, Final EIR Page 4-1
4
EIR Preparers and References
EIR Preparers
Lead Agency
City of South San Francisco
Department of Economic & Community Development, Planning Division
315 Maple Avenue
South San Francisco, CA - 94080
Alex Greenwood, Director
Sailesh Mehra, Planning Manager
Tony Rozzi, Principal Planner
City Peer Review Consultants
Raney Planning & Management
Nick Pappani, Vice President
Crane Transportation Group
Mark Crane, Principal
EIR Preparers
Lamphier-Gregory (Primary Report Preparers)
1944 Embarcadero
Oakland, CA - 94606
510-535-6690
Scott Gregory, President
Rebecca Auld, Senior Planner
Sharon Wright, Planner
Fehr & Peers (Traffic and Transportation)
332 Pine Street, 4th Floor
San Francisco, CA - 94104-3222
Daniel Jacobson, Associate
H. T. Harvey & Associates (Biological Resources)
983 University Avenue, Building D
Los Gatos, CA – 95032
Ginger Bolen, Associate Wildlife Ecologist
Élan Alford, Ph.D., Plant Ecologist
EIR Preparers and References
Page 4-2 Genentech Master Plan Update, Final EIR
JRDV Urban, International (Aesthetics, Urban Design)
The Cathedral Building, 1615 Broadway, 6th Floor
Oakland, California 94612
Edward McFarlan, Principal
Daniel Dolan, Associate Architect
Nelson\Nygaard (TDM and Parking)
116 New Montgomery Street, #500
San Francisco, CA - 94105
Magnus Barber, Associate
Ramboll (Air Quality and GHG)
201 California Street, Suite 1200
San Francisco, CA – 94111
Douglas Daugherty, Director
David Kim, Senior Manager
RGD Acoustics, Inc. (Noise and Acoustics)
1100 Larkspur Landing Circle #354
Larkspur, CA - 94939
Harold S. Goldberg, P.E., LEED Green Associate, Principal
Wilsey Ham (Civil Engineering)
3130 La Selva Street, Suite 100
San Mateo, CA – 94403
Jeff Peterson, P.E., Principal
Final EIR – Additional References
California, State of, Caltrans District 4, Bike Plan Web Map, accessed at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=91f1bb4eb7ff418092977b
762b459d01
California Office of Planning and Research (OPR), Technical Advisory on Evaluating Transportation
Impacts In CEQA, December 2018
San Mateo County Flood Control District, Colma Creek Flood Control Zone
South San Francisco, City of, South San Francisco Storm Drain System MS4 Map, accessed at:
https://www.ssf.net/departments/public-works/water-quality-control-plant/environmental-
compliance