HomeMy WebLinkAbout101 Gull_DEIR.pdf101 GULL DRIVE PROJECT
STATE CLEARINGHOUSE NUMBER 2021100227
Draft Environmental Impact Report
Lead Agency:
City of South San Francisco
Economic & Community Development Department
315 Maple Avenue
South San Francisco, CA 94083-0711
December 2021
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LAMPHIER - GREGORY
URBAN PLANNING, ENVIRONMENTAL ANALYSIS & PROJECT MANAGEMENT 1 510.535.6690
Contents
Page
Chapter 1: Introduction
Purpose of the Environmental Impact Report....................................................................................1-1
Environmental Impact Report Review Process...................................................................................1-1
Content and Organization of the Draft EIR.........................................................................................1-2
Chapter 2: Executive Summary
Introduction and Project Overview.....................................................................................................2-1
Summary of Conclusions.....................................................................................................................2-1
Issues Not Studied in Detail in the EIR..........................................................................................2-2
Significant and Unavoidable Impacts............................................................................................2-2
Potentially Significant Impacts and Mitigation Measures............................................................2-2
Summary of Alternatives..............................................................................................................2-3
Chapter 3: Project Description
ProjectApplicant................................................................................................................................. 3-1
ProjectObjectives................................................................................................................................3-1
Location and Vicinity of the Project....................................................................................................3-1
Descriptionof the Project...................................................................................................................3-3
ProjectApprovals................................................................................................................................3-4
Chapter 4: Hazards and Hazardous Materials
Introduction.........................................................................................................................................4-1
EnvironmentalSetting.........................................................................................................................4-1
RegulatorySetting...............................................................................................................................4-4
Impacts and Mitigation Measures.....................................................................................................4-12
Chapter 5: Transportation
Introduction......................................................................................................................................... 5-1
EnvironmentalSetting.........................................................................................................................5-1
RegulatorySetting...............................................................................................................................5-7
Impacts and Mitigation Measures.....................................................................................................5-12
Chapter 6: Other CEQA Topics
Introduction......................................................................................................................................... 6-1
Mandatory Findings of Significance....................................................................................................6-1
Significant Irreversible Modifications in the Environment..................................................................6-2
GrowthInducing Effects......................................................................................................................6-3
101 Gull Drive Project Draft EIR Pagel -1
Chapter 1: Introduction
Chapter 7: Alternatives
Introduction......................................................................................................................................... 7-1
ProjectObjectives................................................................................................................................7-1
Summary of Project Impacts...............................................................................................................7-2
AlternativesAnalysis...........................................................................................................................7-3
Selectionof Alternatives...............................................................................................................7-3
„No Project" Alternative...............................................................................................................7-5
„R&D Only„ Alternative.................................................................................................................7-6
„Reduced Development" Alternative...........................................................................................7-8
Environmentally Superior Alternative........................................................................................7-11
Chapter 8: Report Preparers and References
LeadAgency.........................................................................................................................................8-1
EIRPreparers.......................................................................................................................................8-1
References........................................................................................................................................... 8-1
Appendices
Appendix A: Notice of Preparation (NOP) and Comments
Appendix B: Initial Study
Appendix C: Phase I Environmental Site Assessment
Figures
Page
3.1:
Project Location............................................................................................................................3-5
3.2:
Existing Conditions and Access Easements...................................................................................3-6
3.3:
Illustrative Site Plan......................................................................................................................3-7
3.4:
Grading and Drainage Plan...........................................................................................................3-8
3.5a:
Exterior Elevations - Northeast.....................................................................................................
3-9
3.5b:
Exterior Elevations - South..........................................................................................................3-10
5.1:
Project Vicinity Roadways and Transit Facilities...........................................................................5-3
5.2:
Project Vicinity Bicycle and Pedestrian Facilities..........................................................................5-6
5.3:
Identified Vicinity Improvements to Transit & Active Transportation.......................................5-18
Tables
Page
2.1: Summary of Project Impacts and Mitigation Measures...............................................................2-4
5.1: Project Trip Generation..............................................................................................................5-13
5.2: Home -Based Work Vehicle Miles Traveled Per Employee.........................................................5-15
7.1: Summary of Impacts and Relative Comparison of Alternatives.................................................7-11
Page 1-2 101 Gull Drive Project Draft EIR
1
Introduction
Purpose of the Environmental Impact Report
The California Environmental Quality Act and the Guidelines promulgated thereunder (together "CEQA")
require an Environmental Impact Report (EIR) be prepared for any project which may have a significant
impact on the environment. An EIR is an informational document, the purposes of which, according to
CEQA are "to provide public agencies and the public in general with detailed information about the
effect which a proposed project is likely to have on the environment; to list ways in which the significant
effects of such a project might be minimized; and to indicate alternatives to such a project." The
information contained in this EIR is intended to be objective and impartial, and to enable the reader to
arrive at an independent judgment regarding the significance of the environmental impacts resulting
from the proposed project.
This EIR evaluates the potential environmental impacts that may be associated with the 101 Gull Drive
Office / Research and Development project ("project") in South San Francisco, California.
Environmental Impact Report Review Process
The City of South San Francisco distributed a Notice of Preparation (NOP) of the EIR for a 30 -day agency
and public review period starting on October 14, 2021 and ending on November 12, 2021 and a scoping
meeting was held on November 4, 2021. An Initial Study was attached to the NOP, which included initial
analysis of environmental topics to focus the EIR. As indicated in the Initial Study, substantial evidence
indicates that no significant impacts would occur to the following issue areas with the incorporation of
mitigation identified in the Initial Study: Air Quality, Cultural Resources, Geology and Soils, Tribal
Cultural Resources, and Utilities and Service Systems. The following topic areas were addressed in the
Initial Study and determined not to have significant impacts: Aesthetics, Agricultural Resources,
Biological Resources, Energy, Hydrology and Water Quality, Land Use and Planning, Mineral Resources,
Noise, Population and Housing, Public Services, Recreation, and Wildfire. The two topics of Hazards and
Hazardous Materials and Transportation were identified as those that would be addressed in the Draft
EIR.
The City received two letters in response to the NOP during the public review period and no verbal
comments. The two letters were from the Native American Heritage Commission noting required
coordination (performed during the Initial Study preparation with no responses received), and from
CalTrans outlining standard procedures for analysis and mitigation of projects (taken into consideration
in the analysis in this Draft EIR).
The Initial Study is included as Attachment A to this document. The NOP and written responses received
are presented in Appendix B.
101 Gull Drive Project Draft EIR Pagel -1
Chapter 1: Introduction
This Draft EIR, together with the Final EIR (discussed below) will constitute the EIR for the proposed
project. The EIR is intended to enable City decision makers, public agencies, and interested citizens to
evaluate the environmental issues associated with the proposed project.
In reviewing the Draft EIR, readers should focus on the sufficiency of the document in identifying and
analyzing the possible environmental impacts associated with the project. Readers are also encouraged
to review and comment on ways in which significant impacts associated with this project might be
avoided or mitigated. Comments are most helpful when the basis for the comments is explained and
they suggest additional specific alternatives or mitigation measures that would provide better ways to
avoid or mitigate significant environmental impacts.
The Draft EIR, its supporting documentation, and details relating to the project are on -file and available
for review online at: www.ssf.net/CEQAdocuments under the "101 Gull Drive" project. If you are unable
to view documents online, please use the contact below to arrange access to an alternate digital copy or
hard copy. Comments on the Draft EIR may be submitted in writing until 5:00 P.M. PST on the last day of
the public review period to:
Stephanie Skangos, Associate Planner
City of South San Francisco
Economic & Community Development Department
315 Maple Avenue
South San Francisco, CA 94083-0711
Phone: 650-877-8535
Email: [email protected]
The comments received during the public review period will be compiled and presented together with
responses to those comments in the Final EIR. Any minor revisions to the Draft EIR will also be included
in the Final EIR.
This EIR serves as an informational document for the public and City of South San Francisco decision
makers. The process includes public hearings before the Planning Commission to consider certification
of a Final EIR and approval of the proposed project. An EIR does not control the agency's ultimate
discretion on the project. However, as required under CEQA, the agency must respond to each
significant effect identified in the EIR by making findings and, if necessary, by making a statement of
overriding considerations for any significant and unavoidable impacts. In accordance with California law,
the EIR on the project must be certified before any action on the project can be taken. Once the EIR is
certified, the City of South San Francisco can then consider whether the project as proposed should be
approved, revised, or rejected.
Content and Organization of the Draft EIR
The previously issued NOP and all written responses to the NOP are presented in Appendix A. The
previously issued Initial Study is included in Appendix B.
An Executive Summary follows this introduction as Chapter 2. This summary presents an overview of the
project and the potentially significant environmental impacts that may be associated with the project,
including a listing of recommended mitigation measures and a discussion of those impacts which would
remain significant and unavoidable even following mitigation.
Page 1-2 101 Gull Drive Project Draft EIR
Chapter 1: Introduction
The Draft EIR presents a description of the project in Chapter 3.
Chapters 4 through 6 present environmental analysis of the project, focusing on the following issues:
Chapter 4: Hazards and Hazardous Materials
Chapter 5: Transportation, Circulation and Parking
Chapter 6: Other CEQA Topics
Chapter 7 presents an evaluation of the environmental effects that may be associated with the
proposed project and three alternatives evaluated: the "No Project" Alternative, the "R&D Only"
Alternative and the "Reduced Development" Alternative.
Chapter 8 lists the persons who prepared the Draft EIR, identifies those persons and organizations
contacted during the preparation of the document, and lists the reference materials used.
101 Gull Drive Project Draft EIR Page 1-3
Chapter 1: Introduction
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Page 1-4 101 Gull Drive Project Draft EIR
Executive Summary
Introduction and Project Overview
This report, together with its appendices, constitutes the Draft Environmental Impact Report (EIR)
on the proposed 101 Gull Drive project ("project"). The Lead Agency for environmental review under
the California Environmental Quality Act is the City of South San Francisco (as Lead Agency).
The project site is located at 101 Gull Drive (Assessor's Parcel Number 015-082-250), within the City
of South San Francisco's "East of 101" planning area. The 3.8 -acre project site is currently vacant.
While the site is located along Gull Drive, it is largely separated from the roadway by a grade change
and steep slope. The project site is located behind businesses fronting Eccles Avenue and Oyster
Point Boulevard and existing access easements with nearby properties would provide mutual access
to driveways on those roadways along with the new driveway on Gull Drive proposed as a part of
the project.
The project Sponsor, Sanfo Group LLC, is proposing construction and operation of a new 166,613 -
square -foot, 7 -story, office / research and development (R&D) building and an attached 4.5 -story
419 -stall parking garage. Site improvements would also include open space, landscaping, outdoor
seating areas, pedestrian walkways, and vehicular circulation elements, including the proposed
connection to Gull Drive for the mutual access easements in the vicinity.
The proposed project is consistent with the existing General Plan designation and zoning at the site.
Areas of Known Controversy
The EIR scoping process did not identify areas of known controversy for the proposed project.
Summary of Conclusions
The following Table 2.1 provides a summary of significant environmental impacts, identified
mitigation measures, and the resulting level of significance after implementation of mitigation
measures. For a more complete discussion of potential environmental impacts and mitigation
measures, please refer to individual topic area chapters of this Draft EIR and sections of the Initial
Study (Appendix A).
Impacts are categorized as follows:
Significant and Unavoidable. An impact that cannot be reduced to below the threshold level given
reasonably available and feasible mitigation measures. Such an impact requires a Statement of
Overriding Considerations to be issued if the project is approved per CEQA Guidelines Section
15093.
101 Gull Drive Project Draft EIR Page 2-1
Chapter 2: Executive Summary
Less than Significant with Mitigation. An impact that can be reduced to below the threshold level
given reasonably available and feasible mitigation measures. Such an impact requires findings under
CEQA Guidelines Section 15091.
Less than Significant. An impact that may be adverse but does not exceed the threshold levels and
does not require mitigation measures.
No Impact: The proposed project would have no effect on environmental conditions or would
reduce existing environmental problems or hazards.
Issues Not Studied in Detail in the EIR
Table 2.1 includes significant impacts from topic areas of the environmental checklist addressed in
the Initial Study (Appendix A). As indicated in the Initial Study, substantial evidence indicates that no
significant impacts would occur to the following issue areas with the incorporation of mitigation
identified in the Initial Study: Air Quality, Cultural Resources, Geology and Soils, Tribal Cultural
Resources, and Utilities and Service Systems. The following topic areas were addressed in the Initial
Study and determined not to have significant impacts: Aesthetics, Agricultural Resources, Biological
Resources, Energy, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise,
Population and Housing, Public Services, Recreation, and Wildfire. The two topics of Hazards and
Hazardous Materials and Transportation are addressed in this Draft EIR.
Significant and Unavoidable Impacts
Based on the analysis presented in this EIR, the project would result in the following environmental
impact that would be considered significant and unavoidable:
Vehicles Miles Traveled Impact (TR -2): The vehicle miles traveled per employee exceeds the City's
adopted threshold of 15 percent below the regional average under existing and future conditions.
Even with contribution toward first- and last -mile strategies to increase use of alternate modes of
travel (Mitigation Measure TR -2), this impact would remain significant and unavoidable.
Note that this impact is not unique to this project. Because the estimated vehicle miles traveled for
this project is based on averages for the entire East of 101 area, most office/R&D projects in this
area incur a significant and unavoidable impact with respect to vehicle miles traveled unless they
are located within one half mile of the Caltrain station.
Potentially Significant Impacts and Mitigation Measures
Potentially significant impacts are largely limited to construction -period disturbance, including
impacts and mitigation related to construction period dust and emissions (Mitigation Measure Air -
1); potential disturbance of unknown archaeological, paleontological, or tribal cultural resources
(Cul -1, Cul -2, Cul -3); and appropriate construction given site characteristics in a seismically -active
region (Geo -1).
Additionally, the project would contribute toward previously -identified area sewer line upgrades
(Util-1).
Page 2-2 101 Gull Drive Project Draft EIR
Chapter 2: Executive Summary
The project would be required to adhere to remediation measures in the Amended Site Closure Plan
and Post -Closure Maintenance Plan (PCMP) to address hazardous materials concerns at the site
including appropriate handling and capping of metals -impacted site soils and vapor barriers if
necessary to address methane gas migration from the nearby landfill (Haz-2).
The impacts listed in this subsection would be reduced to less than significant levels through
implementation of the identified mitigation measures. All other impacts would be less than
significant without the need for mitigation.
Summary of Alternatives
Three alternatives to the project were evaluated in Chapter 20 of this EIR, including:
The "No Project" Alternative in which the site remains vacant.
The "R&D Only" Alternative representing the same structures as proposed but constrained to
the generally lower -employee use of R&D rather than allowing office.
The "Reduced Development" Alternative representing an approximately 30% smaller
office/R&D development on the same site.
The "No Project" alternative was identified as the environmentally superior alternative, since it
would not result in any substantial changes to the site and therefore, has the lowest possible
impacts in every parameter. However, this alternative does not meet any of the project objectives
and would not prevent future development of the site consistent with the underlying land use
designation and zoning (such as the project).
The CEQA Guidelines also require that "if the environmentally superior alternative is the 'no project'
alternative, the EIR shall also identify an environmentally superior alternative among the other
alternatives" (CEQA Guidelines Section 15126.6(e)(2)). The CEQA Guidelines require a consideration
of whether alternatives "avoid or substantially lessen" significant impacts of the proposed project.
In general, the environmentally superior alternative minimizes adverse impacts to the environment,
while still achieving the basic project objectives.
Neither the "R&D Only" Alternative nor the "Reduced Development" Alternative would avoid any
significant impacts of the project or reduce the significance level of any impacts. With fewer
resultant employees at the site, both these alternatives would marginally reduce the significant and
unavoidable project impact related to vehicle miles traveled while the impact would remain
significant and unavoidable. Both these alternatives would be substantially similar though
marginally environmentally superior to the proposed project and would meet project objectives
though to a lesser degree than the project.
Because the "Reduced Development" Alternative would marginally reduce construction -related
impacts as well as operational -related impacts (without changing the need for mitigation or
significance conclusions compared to the project), the "Reduced Development" Alternative would
be the next most environmentally superior after the "No Project" Alternative. As noted above,
differences between the impacts under this alternative and the proposed project would be marginal
only.
101 Gull Drive Project Draft EIR Page 2-3
Chapter 2: Executive Summary
Table 2.1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures
Resulting Level
of Significance
Significant and Unavoidable Impacts
Impact TR -2: Vehicles Miles Traveled. The Mitigation Measure TR -2: First- and Last -Mile Strategies. The project sponsor shall Significant and
vehicle miles traveled per employee exceeds coordinate with the City for the project sponsor to implement the following off-site Unavoidable
the City's adopted threshold of 15 percent improvements to support the project's first- and last -mile and active transportation
below the regional average under existing and connections necessary to support reductions in Home -Based Work Vehicle Miles
future conditions. Traveled.
• Participation in first -/last -mile shuttle program(s) to Caltrain and BART.
Shuttles may be operated by Commute.org and/or other East of 101 shuttle
providers offering services open to the general public.
• Restriping of five crosswalks at the intersection of Oyster Point Boulevard and
Eccles Avenue, one crosswalk at the intersection of Oyster Point Boulevard,
and two crosswalks at the intersection of Oyster Point Boulevard and the 329-
333 Oyster Point Boulevard driveway with high -visibility longitudinal markings
to enhance pedestrian access to the westbound shuttle stop and nearby land
uses.
The project sponsor shall additionally coordinate with the City for the project sponsor
to pay fair -share contribution toward the following off-site improvements to support
the project's first- and last -mile and active transportation connections necessary to
support reductions in Home -Based Work Vehicle Miles Traveled.
• Modification of the existing eastbound shuttle stop at the far side of the
Oyster Point Boulevard/Eccles Avenue intersection to provide an accessible
five-foot long by eight -foot -wide landing pad and pavement markings (if such
facilities are not already fully funded or constructed by the City or SamTrans).
• Installation of a westbound shuttle stop at the far side of the Oyster Point
Boulevard/Eccles Avenue intersection including a pole, accessible five-foot
long by eight -foot -wide landing pad, pavement markings, and shelter (if such
facilities are not already fully funded or constructed by the City or SamTrans).
• Provision of eastbound and westbound Class II buffered bicycle lanes along
Eccles Avenue between Forbes Boulevard and Oyster Point Boulevard,
spanning approximately 3,000 linear feet. The improvement consists primarily
101 Gull Drive Project Draft EIR Page 2-4
Chapter 2: Executive Summary
Table 2.1: Summary of Project Impacts and Mitigation Measures
Resulting Level
Potentially Significant Impacts Regulatory Requirements / Mitigation Measures of Significance
of restriping the curbside vehicle travel lane in each direction to a Class II
buffered bicycle lane and signage. The bicycle facility will help close a gap
between the project and a planned Class I shared -use pathway between
Forbes Boulevard / Eccles Avenue and the South San Francisco Caltrain station.
Less Than Significant Impacts With Mitigation
Impact Haz-2: Accidental Release of Hazardous Mitigation Measure Haz-2: Adherence to Remediation Measures. Applicant or project Less than
Materials. Through compliance with applicable sponsor shall ensure that project design and construction shall incorporate the Significant
regulations, the proposed project would not recommended remediation measures in an Amended Site Closure Plan and Post -
create a significant hazard to the public or the Closure Maintenance Plan (PCMP) approved by the San Mateo County Department of
environment through reasonably foreseeable Environmental Health, to avoid or reduce the hazards related to the presence of
upset and accident conditions involving the hazardous materials (burn ash) and combustible vapor at this site. The remediation
release of hazardous materials into the measures are anticipated to include the following, based on the measures contained in
environment. the current PCMP:
• Placement of cap throughout the development area consistent with the final cover /
capping plan in an approved Amended PCMP.
• Installation of building combustible gas protection and monitoring features to
consist of a subfloor vapor barrier and passive venting system, and interior alarm
system, unless determined not to be necessary (due to vapor levels following
current removal of landfill materials from nearby portions of the Oyster Point
Landfill).
• Adhering to applicable provisions of the existing Risk Management Plan and Health
and Safety Plan for soil handling during excavations for utility trenches, foundations,
and other site work.
• Adherence to water conservation standards for landscaping and irrigation to reduce
or eliminate the potential for water infiltration into underlying contaminated soil
layers.
Criteria Pollutants and Dust Impact: Mitigation Measure Air -1: Basic Construction Management Practices, Measures: The Less than
Construction of the project would result in project applicant / owner / sponsor shall demonstrate proposed compliance with all Significant
emissions and fugitive dust. While the project applicable regulations and operating procedures prior to issuance of demolition,
101 Gull Drive Project Draft EIR Page 2-5
Chapter 2: Executive Summary
Table 2.1: Summary of Project Impacts and Mitigation Measures
Potentially Significant Impacts
would be below threshold levels, the Bay Area
Air Quality Management District (BAAQMD)
considers dust generated by grading and
construction activities to be a significant impact
associated with project development if
uncontrolled and recommends implementation
of construction mitigation measures to reduce
construction -related emissions and dust for all
projects, regardless of comparison to their
construction -period thresholds.
Cultural Resources Impact: There are no known
cultural or tribal cultural resources at the site.
However, given the moderate potential for
unrecorded archeological resources and Native
Regulatory Requirements / Mitigation Measures
building or grading permits, including implementation of the following BAAQMD "Basic
Construction Mitigation Measures".
i) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day.
ii) All haul trucks transporting soil, sand, or other loose material off-site shall be
covered.
iii) 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.
iv) All vehicle speeds on unpaved roads shall be limited to 15 mph.
v) 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.
vi) 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.
vii) 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.
viii) Post a publicly visible sign with the telephone number and person to contact at
the Lead Agency regarding dust complaints. This person shall respond and take
corrective action within 48 hours. The Air District's phone number shall also be
visible to ensure compliance with applicable regulations.
Mitigation Measures Cul -1: Cultural Resources Worker Environmental Awareness
Program (WEAP). A qualified archaeologist shall conduct a WEAP training for all
construction personnel on the project site prior to construction and ground -disturbing
activities. The training shall include basic information about the types of artifacts that
Resulting Level
of Significance
Less than
Significant
101 Gull Drive Project Draft EIR Page 2-6
Potentially Significant Impacts
Table 2.1: Summary of Project Impacts and Mitigation Measures
Regulatory Requirements / Mitigation Measures
Chapter 2: Executive Summary
American resources at a currently -developed might be encountered during construction activities, and procedures to follow in the
site, mitigation measures Cul -1, Cul -2, and Cul -3 event of a discovery. This training shall be provided for any personnel with the potential
shall be implemented. to be involved in activities that could disturb native soils.
Mitigation Measures Cul -2: Halt Construction Activity, Evaluate Find and Implement
Mitigation. In the event that previously unidentified paleontological, archaeological,
historical, or tribal resources are uncovered during site preparation, excavation or other
construction activity, the project applicant / owner / sponsor shall cease or ensure that
all such activity within 25 feet of the discovery are ceased until the resources have been
evaluated by a qualified professional, who shall be retained by the project applicant /
owner / sponsor, and specific measures can be implemented by the project applicant /
owner / sponsor to protect these resources in accordance with sections 21083.2 and
21084.1 of the California Public Resources Code.
Mitigation Measures Cul -3: Halt Construction Activity, Evaluate Remains and Take
Appropriate Action in Coordination with Native American Heritage Commission. In
the event that human remains are uncovered during site preparation, excavation or
other construction activity, the project applicant / owner / sponsor shall cease or
ensure that all such activity within 25 feet of the discovery are ceased until the remains
have been evaluated by the County Coroner, which evaluation shall be arranged by the
project applicant / owner / sponsor, and appropriate action taken by the project
applicant / owner / sponsor in coordination with the Native American Heritage
Commission, in accordance with section 7050.5 of the California Health and Safety Code
or, if the remains are Native American, section 5097.98 of the California Public
Resources Code.
Resulting Level
of Significance
Seismic Hazards Impact: The San Francisco Bay Mitigation Measure Geo -1: Compliance with a design -level Geotechnical Investigation Less than
Area is a seismically active region and the
report prepared by a Registered Geotechnical Engineer and with Structural Design Significant
project site includes undocumented fill and soils
Plans as prepared by a Licensed Professional Engineer. Proper foundation engineering
with low potential for expansion, liquefaction,
and construction shall be performed in accordance with the recommendations of a
and lateral spreading. To mitigate the potential
Registered Geotechnical Engineer and a Licensed Professional Engineer. The structural
for damage to structures or people, the
engineering design, with supporting Geotechnical Investigation, shall incorporate
following measure shall be implemented:
seismic parameters compliant with the California Building Code.
101 Gull Drive Project Draft EIR Page 2-7
Chapter 2: Executive Summary
Table 2.1: Summary of Project Impacts and Mitigation Measures
Mitigation Measure Util-1: Oyster Point Subtrunk Replacement. An approximately Less than
Potentially Significant Impacts
Regulatory Requirements / Mitigation Measures
Resulting Level
needs to be upsized to a 12 -inch diameter trunk sewer. This segment of sewer trunk is
Point Blvd between approximately Gull Drive
of Significance
Paleontological Resources Impact: There are no
Mitigation Measures Cul -1, Cul -2, and Cul -3 would also reduce the potential impact
Less than
known paleontological resources at the site.
related to unknown paleontological resources.
Significant
However, given the potential for unrecorded
Util-1 is consistent with the wording of the
paleontological resources at a currently -
measure in the Oyster Point Specific Plan EIR
developed site, mitigation measures Culture -1,
because this improvement is not included
2, and 3 shall be implemented.
within the Sewer Master Plan.
Tribal Cultural Impact: There are no known
Mitigation Measures Cul -1, Cul -2, and Cul -3 would require proper handling of any
Less than
tribal cultural resources at the site. However,
discoveries and also reduce the potential impact related to unknown tribal cultural
Significant
given the moderate potential for unrecorded
resources.
archeological resources and Native American
resources at a currently -developed site,
mitigation measures Cul -1, Cul -2, and Cul -3 shall
be implemented.
Sewer Capacity Impact: The Oyster Point
Mitigation Measure Util-1: Oyster Point Subtrunk Replacement. An approximately Less than
Specific Plan to the east identified required
700 -foot segment of 8 -inch diameter sewer trunk from Eccles Avenue to Gull Road Significant
upsizing of the 8 -inch gravity main in Oyster
needs to be upsized to a 12 -inch diameter trunk sewer. This segment of sewer trunk is
Point Blvd between approximately Gull Drive
not included in the Sewer Master Plan. The applicant / owner / sponsor shall either
and Eccles Avenue to a 12 -inch main. The
work with the City to include this improvement in a Sewer Master Plan update or
Oyster Point Specific Plan project requires this
directly fund their fair share of the improvement.
mitigation with reimbursement from other area
projects as appropriate. Mitigation measure
Util-1 is consistent with the wording of the
measure in the Oyster Point Specific Plan EIR
and would be required of this project as well
because this improvement is not included
within the Sewer Master Plan.
101 Gull Drive Project Draft EIR Page 2-8
3
Project Description
Note that Figures 3.1 through 3.5b are included together at the end of this chapter (pages 3-5 through
3-10).
Project Applicant
Mike Sanford
Sanfo Group LLC
3351 Greenview Drive
EI Dorado Hills, CA 96762
Project Objectives
The City of South San Francisco has identified the following objectives for the 101 Gull Drive Project in
coordination with the applicant:
1. Allow for development and productive use of a currently vacant lot.
2. Construct a flexible facility that will allow for office/research & development uses that will create
quality jobs for South San Francisco residents.
3. Build an economically viable project that will enhance property values in the City's East of 101 area
and be consistent with the goals of the South San Francisco General Plan and Zoning Ordinances.
Location and Vicinity of the Project
Project Location and Existing Uses
The project site (APN 015-082-250) is a vacant, generally triangular-shaped 3.8 -acre lot located in the
East of 101 area of the City of South San Francisco, California. The project proposes the construction and
operation of a 166,613 square foot office/research and development (R&D) building with adjoining
structured parking and a new driveway on Gull Drive along with mutual access easements with the
neighboring properties also connecting to Eccles Avenue and Oyster Point Boulevard. Figure 3.1 shows
the project location.
The site is located along Gull Drive, but is largely separated from the roadway by a grade change and
step slope. The project site is located behind businesses fronting Eccles Avenue and Oyster Point
Boulevard and existing access easements with nearby properties would provide mutual access to
driveways on those roadways and the new driveway on Gull Drive proposed as a part of this project. The
101 Gull Drive Project Draft EIR Page 3- 1
Chapter 3: Project Description
regional location of the project is shown in Figure 3.1, and the project parcel, including access
easements, is shown in Figure 3.2.
The site is relatively level, except along its south and east portions, which slope down at inclinations of
approximately 2:1 (horizontal to vertical). The maximum slope height is around 40 feet.
The site is generally underlain by about 10 to 55 feet of undocumented fill consisting of loose to medium
dense sandy soil and stiff to very stiff clayey soil with varying amounts of debris. The fill is around 10
feet thick at the northeast corner of the site and increases to the south and to the west, with the
thickest portion near the top of the existing slope. The fill is underlain by stiff to hard clay and sandy clay
over bedrock. Bedrock, consisting of sandstone and claystone of the Francisco Complex, was
encountered at depths ranging from 12 to 68 feet below ground surface. Bedrock generally becomes
deeper to the southwest.
Due to the steep slope of the native soil and bedrock underlying the site and the current site
topography, the depth to groundwater is variable. The depth to groundwater is approximately 30 feet
below ground surface, and the groundwater flow direction is to the southeast, generally toward the San
Francisco Bay.
The site is impacted by contamination from historic and adjacent uses. During the 1950s, trash was
reportedly burned on a portion of the project site and/or burn ash dumped at the site. The trash
burning/ash dumping activities were not licensed. While the burn ash located at the project site is
assumed to be associated with activity at the now -closed Oyster Point Landfill across Gull Drive from the
site, the project site was not used for disposal of municipal solid waste. The residual burn ash material
consists of ash, brick, concrete, metal fragments, and glass, and select metals concentrations were
reported at concentrations above industrial or commercial environmental screening levels, requiring
further action. Additionally, migration of landfill gas from the Oyster Point Landfill had historically been
a concern. Hazards and Hazardous Materials will be discussed in detail in the Environmental Impact
Report.
General Plan Designation / Zoning
Business and Technology Park / Business Technology Park (BTP)
Surrounding Land Uses
Uses in the project vicinity include a mix of office, warehouse, corporate, commercial, and light
industrial uses in Business Technology Park zoning. The project parcel is bounded to the north, west, and
south by office/commercial and light industrial buildings and associated parking lots. Gull Drive borders
the project parcel to the east.
Four existing businesses would directly share the access driveway(s) with the project. The existing
easements are shown on Figure 3.2. Adjacent to the north of the project site is Plenty Unlimited, Inc., a
hydroponic produce company. Two buildings, together comprising the Nickell Property, sit southwest of
the Plenty Unlimited building across the mutually -accessible 30 -foot driveway to Eccles Avenue. The
Nickell Property includes several office complexes and a wholesale business (MTC Trading Company).
Both the Nickell and Plenty Unlimited properties have direct connections from their parking lots to the
Eccles Avenue driveway.
Page 3-2 101 Gull Drive Project Draft EIR
Chapter 3: Project Description
On the other side of the Plenty Unlimited building to the east is Iron Mountain, a records storage and
document shredding facility. This property is separated from Plenty Unlimited by two parallel
approximately 30 -foot drive aisles (both owned by Plenty Unlimited, but grade separated such that they
are separate aisles), which intersect with Oyster Point Boulevard east of the signalized intersection with
Eccles Avenue and the signalized intersection with a driveway to the north.
A mutual access easement also runs along the northwest border of the project site and the USDA facility
to the southwest of the project site, allowing access around the back of the Plenty Unlimited and Iron
Mountain properties and, if the project is implemented, to Gull Drive via the proposed new driveway.
Project Description
Overview and Building Massing
The proposed project would involve construction of a new 166,613 -square -foot (sf), 7 -story, office /
research and development (R&D) building and an attached 4.5 -story 419 -stall parking garage. Site
improvements would also include open space, landscaping, outdoor seating areas, pedestrian walkways,
and vehicular circulation elements, including a connection to Gull Drive for the mutual access easements
in the vicinity (see above).
The exterior office/R&D building design would include fiber cement panels and colored glass with metal
louvers and overhangs and would reach heights of 115.5 feet tall to the top of the parapet, with
allowable rooftop elements up to 128 feet. The parking garage would reach heights of 44 feet tall.
The project site plan is shown in Figure 3.3, and the grading and drainage plan is shown in Figure 3.4.
Building elevations are shown in Figures 3.5a and 3.5b.
Access & Parking
Vehicular access to and from the project would be via three routes (all of which have mutual access
easements with nearby properties per discussion above):
• A new right-in/right-out only driveway on Gull Drive (which would require recording a new access
easement over a sliver of City -owned land).
• Along the shared drive aisle heading southwest from the site then along an existing driveway
between the Plenty Unlimited and Nickell properties to connect with Eccles Avenue at an
unsignalized intersection.
• Along one of the two adjacent 30 -foot drive aisle easements between the Plenty Unlimited and Iron
Mountain buildings to Oyster Point Boulevard. While the intersection of these driveways with
Oyster Point Boulevard is not signalized and would be limited to right -in, right -out movements by
existing medians on Oyster Point Boulevard, it is possible for vehicles to access the adjacent
signalized driveway intersection internally through the parking lot area for full turning options. Due
to the constraints of the connection to Oyster Point Boulevard at this access point, the project's on-
site circulation has been designed to discourage outbound movement along this pathway.
101 Gull Drive Project Draft EIR Page 3-3
Chapter 3: Project Description
The companies currently using the existing paved drive aisle along the northwestern boundary of the
existing parcel for access and circulation would continue to have the same access and rights to do so;
with development of the project, vehicles accessing the project site would also use the driveway and
drive aisles.
Construction
Construction is expected to span approximately 22.5 months. Site preparation would occur in the first
1.5 months, followed by 3 months of foundation work, then 18 months of building and parking garage
construction, which would overlap with 2 months for hardscape and landscaping toward the end of that
period. This active construction period would be followed by inspections and closeout. It is expected
that future tenants would engage in additional interior build out of the space to suit their needs.
Construction activities are targeted to begin in late summer 2022 with operations beginning as early as
summer of 2024.
No substantial excavation or subsurface floors / parking is proposed. Grading would involve 18,440 cubic
yards of cut across the site. Some of that would be balanced on site, with a net import of 1,780 cubic
yards and export of 16,460 cubic yards. Drilled piles are proposed for building support that would be
drilled down to bedrock (approximately 15 to 60 feet). To address the stability of the slope along the
south and east portions of the site, design -level geotechnical recommendations would include a
combination of additional rows of piles, ground improvement and/or tighter spacing of piles.
Depth to groundwater is approximately 30 feet below the ground surface (of the development portion
of the site, not the slope), and dewatering is not anticipated during foundation work.
Project Approvals
Development of the project would require the following approvals from the City of South San Francisco:
Conditional Use Permit (Parking/Loading Reduction, Incentive -Based Floor Area Ratio (FAR) Bonus,
Parking Garage Rooftop Planting), Design Review, Transportation Demand Management Program. The
project would also require the City to grant an easement for vehicular ingress and egress to Gull Drive.
Because the project is located in the San Francisco International Airport Land Use Compatibility Plan
area, the project would be subject to Airport Land Use Commission review and approval.
The project is required to comply with Municipal Regional Permit requirements related to stormwater
pollution prevention.
Page 3-4 101 Gull Drive Project Draft EIR
DOWNTOWN
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Chapter 3: Project Description
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101 Gull Drive Project Draft EIR Page 3-5
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101 Gull Drive Project Draft EIR Page 3-5
Figure 3.2: Existing Conditions and Access Easements
Source: Source: Project Plan Set, dated 10/8/2021
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Page 3-6 101 Gull Drive Project Draft EIR
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Source: Source: Project Plan Set, dated 10/8/2021
Chapter 3: Project Description
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101 Gull Drive Project Draft EIR Page 3-7
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Page 3-8 101 Gull Drive Project Draft EIR
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Source: Source: Project Plan Set, dated 10/8/2021
Chapter 3: Project Description
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101 Gull Drive Project Draft EIR Page 3-9
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Source: Source: Project Plan Set, dated 10/8/2021
Page 3-10 101 Gull Drive Project Draft EIR
V,
Hazards and Hazardous Materials
Introduction
A hazardous material is a substance or combination of substances which, because of its quantity,
concentration, or physical, chemical or infectious characteristics, may pose a substantial present or
potential hazard to human health and safety, or the environment when improperly treated, stored,
transported, disposed of, or otherwise managed.
This chapter utilizes information from the following reports prepared for this project or analysis:
Langan Engineering and Environmental (Langan) was contracted to conduct a Phase I Environmental
Site Assessment of the project site. Information is from their report dated December 22, 2020,
included as Attachment C to this document.
Environmental Setting
Site Use History
The project site is historically undeveloped land on a hillside along the western margin of the San
Francisco Bay. In the early 1900s, as part of modifications being made to the coastline of the Bay, fill
material was placed on the project site. During the 1950s, a portion of the site was used as a burn dump,
with those operations ceasing before the end of that decade. Additional fill material was placed over the
burn ash material to raise the project site to the current grades. Based on review of aerial photos, the
project site appears to have been graded to the current configuration by the 1980s. The project site has
remained undeveloped, vacant land.
Current Site Use and Potential Contamination
The top layer of soil at the site consists of undocumented fill material ranging from approximately 10 to
20 feet thick. A layer of burn ash material underlies the fill, ranging from 10 to 25 feet thick, with native
clays and silts, followed by bedrock, below that.
Soil sampling found elevated concentrations of metals in the burn ash material, including arsenic,
copper, lead, and zinc. These levels exceeded the applicable environmental screening levels (ESLs)
allowed for commercial shallow soil. Testing on the undocumented fill above the burn ash found
concentrations of arsenic and lead above the ESLs allowed for commercial shallow soil and antimony,
arsenic, chromium VI, cobalt, and lead at levels above those allowed for residential shallow soil but
below the ESLs for commercial shallow soil. The presence of lead in multiple shallow soil samples is likely
at concentrations that could potentially be classified as hazardous waste if exported from the property
for off-site disposal.
101 Gull Drive Project Draft EIR Page 4-1
Chapter 4: Hazards and Hazardous Materials
A soil vapor investigation conducted in 2006, detected methane at the site at concentrations up to 41%
by volume, exceeding the limits of 5% at the property perimeter and 1.25% within on-site structures set
by the San Mateo County Health Services Division (SMCEHD) Local Enforcement Agency (LEA) per
California Code of Regulations Title 27 (27 CCR) §20921. The highest concentrations of methane were
found in the northeastern corner of the project site, which is across Gull Drive from property identified
as formerly part of Oyster Point Landfill. Benzene and vinyl chloride were also detected in soil vapor at
concentrations above both residential and commercial vapor intrusion ESLs.
Groundwater sampling conducted between 2008 and 2009 found that the shallow groundwater at the
project site appears to have been impacted with metals consistent with the presence of burn ash
material below the water table. One well also found low concentrations of petroleum hydrocarbons.
The project site (combined with the adjacent parcel at the time) was listed in the RWQCB Geotracker
database under the name "560 Eccles" with a status of "Informational Item as of 12/13/2018" and case
number T10000012436. The records available on Geotracker were related to the abandonment of the
former groundwater monitoring wells. The project site is also listed in the CalRecycle SWIS database as a
former "Nonhazardous Ash Disposal/Monofill Facility" under the name "USDA Building (41 -CR -0028)"
with an operational status of "Closed" and a regulatory status of "Unpermitted."
Other Contamination in the Vicini
Most of the nearby listings of off-site property were either closed by the regulatory agency, located in a
direction from the project site that is inferred to be hydrologically down -gradient, a significant distance
away, and/or otherwise determined in the Phase I Environmental Site Assessment (Attachment C) not to
have a potential impact on the project site. The following properties remain of environmental interest
with respect to contamination at the project site.
• The USDA building owned by SMPO ELS, LLC at 560 Eccles Avenue is the western adjoining
property and inferred to be hydrologically up- to cross- gradient. The building has a valid permit
for the storage of small quantities of diesel fuel in an aboveground storage tank for a backup
generator. There have been no violations, spills, or releases from the facility operations noted.
• The property at 336 Oyster Point Boulevard is the northern/western adjoining property and
inferred to be hydrologically up- to cross- gradient. The site is a leaking underground storage
tank (LUST) cleanup site (SWRCB Case #T0608100451) with a status of "Completed- Case Closed
as of 11/14/1995" and notes that a 2,000 -gallon diesel underground storage tank was removed
in 1987 and, while petroleum hydrocarbons were detected in groundwater, that a No Further
Action (NFA) letter was issued in 1995 indicating that no further monitoring of the groundwater
was required due to the low levels of petroleum hydrocarbons in groundwater and lack of
technically feasible remediation. Therefore, due to the NFA determination, this property is not
considered an environmental concern for the project site.
• The property at 349 Oyster Point Boulevard is approximately 350 feet northwest of the project
site and inferred to be hydrologically up- to cross- gradient. The site was formerly occupied by a
metal reclamation plant which operated between 1907 and 1987. It is a LUST cleanup site
(SWRCB Case #T0608114784) with a status of "Completed- Case Closed as of 7/17/2001" and as
a cleanup program site under the name "Wildberg Brothers" with case number T10000008176
and a status of "Completed - Case Closed as of 3/21/2018." Alternative case numbers for the
property are San Mateo County LOP case number 559014 and RWQCB case numbers 41-1115
Page 4-2 101 Gull Drive Project Draft EIR
Chapter 4: Hazards and Hazardous Materials
and 4150028. The property is also listed in the DTSC Envirostor database as a voluntary cleanup
site under the name "Wildberg Brothers (Boliden Metech)" with case number 41330049 and a
status of "Certified as of 11/30/1987." Testing over the years found relatively high
concentrations of lead in some samples from that site, leading to the removal of affected site
soils in October 1995. In November 1995, DTSC issued a NFA letter related to the lead
remediation. During construction activities in 1997, soil impacted with petroleum hydrocarbons
was encountered. Excavation activities were performed, removing additional impacted soil and
a NFA letter was issued related to the petroleum hydrocarbon contamination. Due to the NFA
determinations, this property is not considered to be an environmental concern for the project
site.
• The former Oyster Point Landfill is the eastern adjoining property across Gull Drive and inferred
hydrologically downgradient. This property is listed in the RWQCB Geotracker database as a land
disposal site under the name "Oyster Point Landfill" with case number L10009323371 and a
status of "Open as of 1/1/1965." Alternative case numbers for the property are RWQCB case
number 2 417061001. The site is also listed in the CalRecycle SWIS database as a former "Solid
Waste Disposal Site" under the name "So. San Francisco Municipal Dump/Oyster (41 -AA -0065)"
with an operational status of "Closed" and a regulatory status of "Unpermitted."
Redevelopment of the landfill is currently ongoing as part of a larger, multi -phase development
project by the City of South San Francisco and Kilroy Realty Corporation, including multiple
office/R&D buildings, infrastructure improvements, and open space areas. The current work is
subject to a Final Closure Plan (FCP) and Postclosure Monitoring and Maintenance Plan
(PCMMP), detailing procedures for closure and long-term monitoring and maintenance of the
landfill pursuant to Title 27 CCR §21190 requirements. Since the Oyster Point Landfill is
downgradient of the project site, groundwater impacts are not anticipated to be a concern.
However, due to the unknown extent of refuse potentially remaining in place beneath Gull Drive
and further west within the eastern adjoining parcel owned by the City of South San Francisco
(APN 015-190-180), and the ongoing operation, maintenance, and monitoring requirements for
the perimeter landfill gas monitoring features immediately outside the eastern project site
boundary, the Oyster Point Landfill is considered to be an environmental concern for the project
site.
Other Hazard and Hazardous Materials Issues
Schools and Daycare Facilities
CEQA establishes special requirements for certain projects near schools to ensure that potential health
impacts resulting from exposure to hazardous materials, wastes, and substances will be carefully
examined and disclosed in a negative declaration or EIR, and that the lead agency will consult with other
agencies in this regard.
There are no schools located within or near the project site, or within the entire East of 101 area. There
are four daycare centers located within the East of 101 area, including:
• Gateway Child Development Center at 559 Gateway Boulevard
• Genentech's Cabot 2nd Generation at 342 Allerton Avenue
• Genentech's 2nd Generation at 444 Allerton Avenue
101 Gull Drive Project Draft EIR Page 4-3
Chapter 4: Hazards and Hazardous Materials
• Early Years Preschool at 371 Allerton Avenue
All of these daycare centers are farther than one-quarter mile from the project site.
Airports
Aviation safety hazards can result if projects are located near airports. The public airport located nearest
to the project site is San Francisco International Airport (SFO), located approximately 2 miles south of
the project site. There are no private airstrips in the vicinity.
Wlldland Fires
The California Department of Forestry and Fire Protection (CAL FIRE) is required by law to map areas of
significant fire hazard based on fuels, terrain, weather, and other relevant factors (PRC 4201-4204 and
Govt. Code 51175-89). Factors that increase an area's susceptibility to fire hazards include slope,
vegetation type and condition, and atmospheric conditions. The CAL FIRE San Mateo County Fire Hazard
Severity Zone Map does not identify any very high or high zones of fire hazard severity in the vicinity of
the project site.
Regulatory Setting
Adoption of and development pursuant to the project is subject to government health and safety
regulations applicable to the transportation, use, and disposal of hazardous materials. This section
provides an overview of the health and safety regulatory framework that is potentially applicable to the
project.
Federal
Hazardous Materials Management
The primary federal agencies with responsibility for hazardous materials management include the
United States Environmental Protection Agency (US EPA), U.S. Department of Labor Occupational Safety
and Health Administration (OSHA), and the U.S. Department of Transportation (DOT). Federal laws,
regulations and responsible agencies are summarized below and are discussed in detail in this section.
The Emergency Planning and Community Right to Know Act of 1986 imposes requirements to ensure
that hazardous materials are properly handled, used, stored, and disposed of and to prevent or mitigate
injury to human health or the environment in the event that materials are accidently released.
Hazardous Materials Site Listings
The National Priorities List (NPL) is a compilation of over 1,200 sites for priority cleanup under the
Federal Superfund Program. The Proposed National Priorities List identifies sites considered for NPL
listing. The Comprehensive Environmental Response, Compensation and Liability Information System
(CERCLIS) system contains data on potentially hazardous waste sites that have been reported to the US
EPA by California. CERCLIS contains sites that are proposed or are on the NPL, and sites that are in the
screening and assessment phase.
Page 4-4 101 Gull Drive Project Draft EIR
Chapter 4: Hazards and Hazardous Materials
Hazardous Waste Handlin
Under the Resource Conservation and Recovery Act (RCRA), the US EPA regulates the generation,
transportation, treatment, storage and disposal of hazardous waste. The Hazardous and Solid Waste Act
amended RCRA in 1984. The amendments specifically prohibit the use of certain techniques for the
disposal of hazardous waste.
Hazardous Materials Transportation
The US Department of Transportation (DOT) has the regulatory responsibility for the safe transportation
of hazardous materials. The DOT regulations govern all means of transportation except packages
shipped by mail (49 Code of Federal Regulations (CFR)). The US Postal Service (USPS) regulations govern
the transportation of hazardous materials shipped by mail.
Occupational Safety
The Occupational Safety and Health Act of 1970 (Fed/OSHA) sets standards for safe workplaces and
work practices, including the reporting of accidents and occupational injuries (29 CFR).
Aviation Safetv and Aviation Hazards
The closest airport to the project site is the San Francisco International Airport (SFO), approximately 2
miles to the south. The Comprehensive Airport Land Use Compatibility Plan for the Environs of San
Francisco International Airport (ALUCP) is used by the City/County Association of Governments of San
Mateo County (C/CAG) to promote compatibility between SFO and surrounding land uses. The project
site is subject to Federal Aviation Regulations and the SFO ALUCP, which provides policies and
regulations pertaining to land use that may affect, or be affected by airport operations, including
restrictions for the height of structures within the ALUCP area and/or elements that may affect normal
aviation operations or that could create a safety hazard for aircraft.
State of California
Primary state agencies with jurisdiction over hazardous chemical materials management are the
Department of Toxic Substances Control (DTSC) and the Regional Water Quality Control Board (RWQCB).
Additional state agencies are also involved in hazardous materials management. These agencies include
Cal/OSHA (which is part of the Department of Industrial Relations), State Office of Emergency Services
(OES), California Air Resources Board (CARB), Bay Area Air Quality Management District (BAAQMD),
California Department of Transportation (Caltrans), California Highway Patrol (CHP), State Office of
Environmental Health Hazard Assessment (OEHHA) and the California Integrated Waste Management
Board (CIWMB).
In January 1996, the California Environmental Protection Agency (Cal EPA) adopted regulations
implementing a Unified Hazardous Waste and Hazardous Materials Management Regulatory Program
(Unified Program). The program has six elements:
• Hazardous waste generators and hazardous waste on-site treatment;
• Underground storage tanks;
• Aboveground storage tanks;
101 Gull Drive Project Draft EIR Page 4-5
Chapter 4: Hazards and Hazardous Materials
• Hazardous materials release response plans and inventories;
• Risk management and prevention programs; and
• Unified Fire Code, hazardous materials management plans, and inventories.
The Unified Program is implemented at the local level. The Certified Unified Program Agency (CUPA) is
the local agency that is responsible for the implementation of the Unified Program. In South San
Francisco, the San Mateo County Department of Environmental Health (SMCDEH) is the designated
CUPA.
Hazardous Materials Management
The California Hazardous Materials Release Response Plans and Inventory Law of 1985 (Business Plan
Act) requires that any business that handles hazardous materials prepare a business plan, which must
include the following:
• Details, including floor plans, 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
The California Hazardous Materials Incident Report System (CHMIRS) provides information regarding
spills and other incidents gathered from the California Office of Emergency Services.
Hazardous Waste Handling
The DTSC regulates the generation, transportation, treatment, storage and disposal of hazardous waste.
State and federal laws require detailed planning to ensure that hazardous materials are properly
handled, used, stored, and disposed of, and, in the event that such materials are accidentally released,
to prevent or to mitigate injury to health or the environment. Laws and regulations require hazardous
materials users to store these materials appropriately and to train employees to manage them safely.
Under the federal Resource Conservation and Recovery Act of 1976 (RCRA), individual states may
implement their own hazardous waste programs in lieu of RCRA, as long as the state program is at least
as stringent as federal RCRA requirements. In California, the DTSC regulates the generation,
transportation, treatment, storage and disposal of hazardous waste. The hazardous waste regulations
establish criteria for identifying, packaging, and labeling hazardous wastes; prescribe management of
hazardous waste; establish permit requirements for hazardous waste treatment, storage, disposal and
transportation; and identify hazardous wastes that cannot be disposed of in landfills.
Hazardous Materials Transportation
The State of California has adopted DOT regulations for the intrastate movement of hazardous
materials. State regulations are contained in Title 26 of the California Code of Regulations (CCR), which
includes requirements applicable to the transportation of hazardous waste originating in the State and
Page 4-6 101 Gull Drive Project Draft EIR
Chapter 4: Hazards and Hazardous Materials
passing through the State. The two state agencies that have primary responsibility for enforcing federal
and state regulations and responding to hazardous materials transportation emergencies are the
California Highway Patrol (CHP) and the California Department of Transportation (Caltrans).
Occupational Safety
The California Occupational Safety and Health Administration (Cal/OSHA) assumes primary responsibility
for developing and enforcing workplace safety regulations in California. Because California has a
federally approved OSHA program, it is required to adopt regulations that are at least as stringent as
those found in Title 29 of the CFR. Cal/OSHA standards are sometimes, but not always, more stringent
than federal regulations.
Cal/OSHA Title 8 regulations concerning the use of hazardous materials in the workplace require
employee safety training, safety equipment, accident and illness prevention programs, hazardous
substance exposure warnings, and emergency action and fire prevention planning. Cal/OSHA enforces
regulations for hazard communication programs, which contain training and information requirements,
including procedures for identifying and labeling hazardous substances, and communicating hazard
information relating to hazardous substances and their handling. The hazard communication program
also requires that Materials Safety Data Sheets (MSDS) be available to employees, and that employee
information and training programs be documented. These regulations also require preparation of
emergency action plans (escape and evacuation procedures, rescue and medical duties, alarm systems,
and training in emergency evacuation).
Cal/OSHA (8 CCR), like Fed/OSHA (29 CFR), includes extensive, detailed requirements for worker
protection applicable to any activity that could disturb asbestos -containing materials, including
maintenance, renovation, and demolition. These regulations are also designed to ensure that persons
working near the maintenance, renovation or demolition activity are not exposed to asbestos.
Emergency Response
California has developed an emergency response plan to coordinate emergency services provided by
federal, state and local government and private agencies. Responding to hazardous materials incidents
is one part of this plan. The plan is administered by the State Office of Emergency Services (OES), which
coordinates the responses of other agencies, including Cal EPA, CHP, CDFG, the San Francisco Bay
RWQCB and the South San Francisco Fire Department (SSFFD). The SSFFD provides first response
capabilities, if needed, for hazardous materials emergencies within the East of 101 Area.
Additional Regulatory Setting Specific to Life Sciences Facilities
While the exact tenant or tenants of the proposed building have not yet been identified, the following
regulations are listed as they are potentially applicable to R&D/life sciences types of facilities depending
on the specifics of the operations therein.
Microbiological, Biomedical and Animal Laboratories
The United States Department of Health and Human Services (USDHHS), Centers for Disease Control and
Prevention (CDC), and National Institutes of Health (NIH) prescribe containment and handling practices
for use in microbiological, biomedical, and animal laboratories. Based on the potential for transmitting
biological agents, the rate of transmission of these agents, and the quality and concentrations of
101 Gull Drive Project Draft EIR Page 4-7
Chapter 4: Hazards and Hazardous Materials
biological agents produced at a laboratory, Biosafety Levels are defined for four tiers of relative hazards.
Biosafety Level 1 (BSL -1) is for the least hazardous biological agents, and Biosafety Level 4 (BSL -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.
Federal and state laws, such as the Animal Welfare Act, specify standards for record keeping and the
registration, handling, care, treatment and transportation of animals. Such laws are enforced by the U.S.
Department of Agriculture and the California Department of Health Services (DHS).
Medical wastes must be managed as a biohazardous material, in accordance with Section 117635 of the
California Health and Safety Code. The management of biohazardous materials must comply with
USDHHS guidelines and DHS regulations pertaining to such materials. Biohazardous medical waste is
generally regulated in the same manner as hazardous waste, except that special provisions apply to
storage, disinfection, containment and transportation. The DHS Medical Waste Management Program
enforces the Medical Waste Management Act and related regulations.
Radioactive Materials Regulations
The Atomic Energy Act (42U.S.C. Sections 2011- 2259) (AEA) ensures the proper management of source,
special nuclear, and by-product material. The AEA, and the statutes that amended it, delegate the
control of nuclear energy primarily to the Department of Energy, the Nuclear Regulatory Commission
and the United States Environmental Protection Agency (US EPA). 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. The program regulates sources of ionizing radiation
and establishes procedures for performance of certain regulatory responsibilities with respect to the use
and regulation of radiation sources. 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.
Local
San Mateo County Health Department
As noted above, the San Mateo County Health Department, Environmental Health Division is the
primary local agency approved as the CUP) with responsibility for implementing federal and state laws
and regulations pertaining to hazardous materials management. The Unified Program is the
consolidation of six state environmental regulatory programs into one program under the authority of a
CUPA. This program was established under the amendments to the California Health and Safety Code
made by SB 1082 in 1994. The six consolidated programs are:
• Hazardous Materials Release Response Plan and Inventory (Business Plans)
• California Accidental Release Program (CaIARP)
• Hazardous Waste (including Tiered Permitting)
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Chapter 4: Hazards and Hazardous Materials
• Underground Storage Tanks
• Above Ground Storage Tanks, and
• Hazardous Materials Management Plan and Hazardous Materials Identification System
As the local CUPA, the San Mateo County Health Department, Environmental Health Division maintains
the records regarding location and status of hazardous materials sites in the county, and administers
programs that regulate and enforce the transport, use, storage, manufacturing and remediation of
hazardous materials. By designating a CUPA, San Mateo County has accurate and adequate information
to plan for emergencies and/or disasters, and to plan for public and firefighter safety.
A Participating Agency (PA) is a local agency that has been designated by the local CUPA to administer
one or more Unified Programs within their jurisdiction, on behalf of the CUPA. The City of South San
Francisco Fire Department maintains a special program that regulates hazardous materials through
disclosure and risk management plans, as well as referrals to the County of San Mateo for above ground
storage tanks. Thus, the City of South San Francisco Fire Department is a PA with the San Mateo County
Health Department, Environmental Health Division as the CUPA.
South San Francisco General Plan (1999
The City of South San Francisco General Plan describes goals and policies that address the patterns of
urban and industrial development in South San Francisco that may pose risks to human health and
property. The goals and policies of the General Plan Safety Element are intended to acknowledge and
mitigate the risk posed by such hazards. Pertinent Safety Element policies are listed below:
• Policy 8.3-G-2: Minimize the risk to life and property from the generation, storage and
transportation of hazardous materials and waste in South San Francisco. Comply with all
applicable regulations and provisions for the storage, use and handling of hazardous substances
as established by federal (US EPA), State (DTSC, RWQCB, Cal OSHA, Cal EPA), and local (County
of San Mateo, City of South San Francisco) regulations.
• Policy 8.3-1-2: Continue to maintain hazardous waste regulations in the City's Zoning Ordinance.
• Policy 8.3-1-3: Prepare a Geographic Information Systems (GIS) coverage for the sites included in
the Cortese List of Hazardous Waste and Substances Sites.
• Policy 8.3-1-4: Establish an ordinance specifying routes for transporting hazardous materials.
• Policy 8.4-1-3: Require site design features, fire retardant building materials, and adequate
access as conditions for approval of development or improvements to reduce the risk of fire
within the City.
• Policy 8.6-1-1: Maintain and update the City's Emergency Response Plan, as required by State
law, to minimize the risk to life and property of seismic and geologic hazards, flooding,
hazardous materials and waste, and fire.
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Chapter 4: Hazards and Hazardous Materials
• Policy 8.6-1-3: Coordinate regular emergency drills with emergency organizations, including City
and County Fire, Police, Emergency Medical Services, and Public Works; San Francisco
International Airport; and California Environmental Protection Agency.
• Policy 8.7-1-1: Do not permit land uses that pose potential hazards to air navigation in the
vicinity of SFO. These land uses include the following:
1. Any use that would direct a steady or flashing light of white, red, green or amber color
towards an aircraft engaged in an initial straight climb following takeoff or toward a landing,
other than FAA -approved navigational lights;
2. Any use that would cause sunlight to be reflected toward an aircraft engaged in an initial
straight climb following takeoff or toward an aircraft engaged in a straight final approach
toward a landing;
3. Any use that would generate smoke or rising columns of air;
4. Any use that would attract large concentrations of birds within approach and climb -out
areas; and
5. Any use that would engage electrical interference that may interfere with aircraft
communications or aircraft instrumentation.
East of 101 Area Plan (adopted 1994)
The project site is also located within the East of 101 Area Plan planning area, which provides a detailed
implementation guide for the area. The East of 101 Area Plan is principally used to provide direction
related to project design and certain other facets of development in the area not otherwise covered in
the General Plan or other City plans. Some of the policies in the East of 101 Area Plan related to hazards
and hazardous concerns are listed below.
• Policy L1U9: Uses that emit loud noise or create hazardous materials, water contaminants or
other pollutants shall only be allowed in the East of 101 Area after review by the Planning
Commission. The Planning Commission must find, in addition to any other required findings,
that a proposed use would include all feasible measures to mitigate such adverse impacts and
that the use would also have mitigating benefits such as employment creation or revenue
generation.
• Policy L2U3: Maximum heights of buildings in the East of 101 Area shall not exceed the
maximum heights established by the Airport Land Use Commission based on Federal Aviation
Regulations Part 77 Criteria.
• Policy L31.111: No new above ground, bulk fuel tanks are permitted after July 25, 1994. Any above
ground fuel tanks that lawfully existed prior to July 1994 may be maintained but may not be
replaced or expanded.
• Policy G5EO: If hazardous fill such as garbage organics is encountered, it shall be appropriately
disposed by a project developer during construction. This material shall not be used for either
structural fill or grading fill. However, other uses may be possible such as landscaping around
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Chapter 4: Hazards and Hazardous Materials
vegetation if the fill has a high organic content. If no acceptable use is found on-site, the
hazardous fill should be properly disposed off-site.
South San Francisco Municipal Code
The South San Francisco Municipal Code includes regulatory requirements addressing use and disposal
of hazardous materials and hazardous waste. These regulatory requirements include the following:
Chapter 14.04 Stormwater Management and Discharge Control
• Section 14.04.320, Coordination with hazardous materials inventory and response program:
The first revision of a business plan for any facility subject to the city's hazardous materials
inventory and response program shall include a program for compliance with this chapter,
including the prohibitions on non-stormwater discharges and illicit discharges, and the
requirement to reduce stormwater pollutants to the maximum extent practicable.
Chapter 14.08 Water Quality Control
• Section 14.08.170, Reporting and recordkeeping requirements for permittee: All industrial
users discharging any substance which, if otherwise disposed of, would be a hazardous or
acutely hazardous waste under 40 CFR part 261, must comply with the notification
requirements in 40 CFR 403.12(p)(1) and (3) unless exempted under the provisions of 40 CFR
403.12(p)(2). Any written notification required by this subsection shall be provided to the city,
the EPA Regional Waste Management Division Director and state hazardous waste authorities.
The industrial user shall certify that it has a program in place to reduce the volume and toxicity
of hazardous wastes generated to the degree it has determined to be economically practical.
The city may accept a copy of a hazardous waste reduction or minimization plan otherwise
required by law, as compliance with this requirement.
• Section 14.08.210, General discharge regulations: It is unlawful to discharge or cause to be
discharged directly or indirectly, any pollutant or wastewater into any storm sewer or into any
sewage facility that will interfere with the operation or performance or pass through of the
POTW. These general prohibitions apply to all users whether or not the user is subject to
categorical pretreatment standards or any other national, state, or local pretreatment standards
or requirements. The discharge of the following is prohibited:
1. Wastes or wastewater containing any radioactive materials except in compliance with
applicable state and federal regulations;
2. Any pesticides containing algaecides, antibiotics, fungicides, herbicides, insecticides or any
similar pesticides in amounts deleterious to any sewage treatment process or to the aquatic
life of the waters receiving the effluent; and
3. Any wastewater or pollutant that results in the presence of toxic gases, vapors or fumes
within the POTW in a quantity that may cause acute worker or public health or safety
problems.
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Chapter 4: Hazards and Hazardous Materials
Impacts and Mitigation Measures
Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant hazards and
hazardous materials impact if it would do any of the following.
• Create a significant hazard to the public or the environment through the routine transport, use or
disposal of hazardous materials.
• Create a significant hazard to the public or the environment through reasonably foreseeable upset
and accident conditions involving the release of hazardous materials into the environment.
• Emit hazardous emissions, or handle hazardous or acutely hazardous materials, substances or waste
within one-quarter mile of an existing or proposed school.
• Be located on a site that is included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or
the environment.
• For a project located within an airport land use plan or, where such a plan has not been adopted,
within two miles of a public airport or public use airport, if the project results in a safety hazard or
excessive noise for people residing or working in the project area.
• Impair implementation of or physical interference with an adopted emergency response plan or
emergency evacuation plan.
• Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death
involving wildland fires.
Routine Transport, Use, Disposal or Storage of Hazardous Materials
Impact Haz-1: Routine Use of Hazardous Materials. With compliance with applicable regulations, the
project would not expose employees, the nearby public, or the environment to significant
hazards due to the routine transport, use, disposal, or storage of hazardous materials (including
chemical, radioactive and biohazardous waste). (Less than Significant)
Construction at the project site would involve small amounts of hazardous materials routinely used in
construction, such as fuels, paints, and solvents.
The proposed project would result in development and operation of an office and R&D building which
may include laboratories and other research facilities that are likely to use, store or require the
transportation and disposal of hazardous materials, depending on the particulars of the future tenant(s).
The amount and type of hazardous materials may vary over time, with changes in research and
additions to hazardous materials lists. These hazardous materials may include inorganic and organic
chemicals, chemical reagents and reaction products, solvents, mercury, lead, asbestos, radioisotopes,
biohazards, fuels, oils, paints, cleansers, and pesticides.
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Chapter 4: Hazards and Hazardous Materials
For the handling of hazardous materials during operations, the facility would be required to adhere to all
applicable state and local regulations, seek consultation with the SMCEHD, and apply for applicable
permits. In addition, registration of the materials through the SMCEHD Hazardous Material Business
Plan Program would be required to ensure safe and responsible handling. Additionally, hazardous
chemicals that are typical in office settings (e.g., toners, paints, kitchen and restroom cleaners, and
other maintenance materials) would likely also be used. Landscaping and maintenance on the project
site would require the use of a wide variety of commercial products that are formulated with hazardous
materials (e.g., fuels, cleaners and degreasers, solvents, paints, lubricants, adhesives, sealers, and
pesticides/herbicides). Such materials are considered common and are unlikely to be stored or used in
large quantities. Any spills involving these materials would be small and localized and would be cleaned
up as they occur.
The City requires that building spaces be designed to handle the intended uses, with sprinklers, alarms,
vents, and secondary containment structures, in accordance with the guidelines laid out in the City's Fire
Code. Compliance with state and local regulations would ensure that buildings are equipped with safety
measures including sprinklers, alarms, etc., to minimize potential impacts of the presence of hazardous
materials. The City further requires that upon completion of the construction of the proposed building,
occupancy is not allowed until a final inspection is made by the South San Francisco Fire Department
(SSFFD) for conformance of all building systems with the City's Fire Code and National Fire Protection
Association requirements. The inspection includes a review of the emergency evacuation plans. Finally,
compliance with the California Department of Transportation regulations would ensure that all
necessary safety precautions would be taken during transport of hazardous materials during all phases
of the project. Therefore, with compliance with applicable regulations, the proposed project would not
create a significant hazard for the public or the environment through the routine transport, use, or
disposal of hazardous materials during operation and this impact would be less than significant.
Hazardous Materials Site and Reasonably Foreseeable Upset and Accident Conditions
Impact Haz-2: Accidental Release of Hazardous Materials. Through compliance with applicable
regulations, the proposed project would not create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment. (Less than Significant with Mitigation)
Project construction and operation would involve the routine transport, use, disposal, and/or storage of
hazardous materials. Impacts related to such routine handling are addressed above.
The project site is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5, and is adjacent to the now -closed Oyster Point Landfill. Hazardous materials upset or
accident could have the potential to occur related to these hazardous materials concerns as described
below.
As detailed in the Phase I Environmental Site Investigation and summarized above, site contamination
concerns include a layer of burn ash with elevated concentrations of metals and the possible presence
of methane in the soil vapor due to migration of landfill gas from the former Oyster Point Landfill to the
east.
101 Gull Drive Project Draft EIR Page 4-13
Chapter 4: Hazards and Hazardous Materials
A closure/post-closure development plan (PCMP) is in place at the project site. The project requires
approval from the San Mateo County Department of Environmental Health, which will include an
amended PCMP to reflect the proposed development at the site.
Consistent with the current PCMP, an amended PCMP will include measures designed to minimize
potential exposure of workers and building occupants to contaminated soils and vapor during and after
site development. This is likely to be achieved generally through capping site soils with asphalt, concrete
and vegetative barriers; installation of a vapor barrier and venting system below the building foundation
to address the potential for migration onto the site of combustible vapor; and implementation of safety
measures for soil handling during construction.
Project construction activities have the potential to result in the release of contaminated soils and
project operation has the potential to bring site users into contact with contaminated soils and
combustible vapors. This impact is considered potentially significant and requires mitigation consistent
with an approved amended PCMP, and as also listed in the measure below.
Mitigation Measure Haz-2: Adherence to Remediation Measures. The applicant or the project sponsor
shall ensure that project design and construction incorporate the recommended remediation
measures in an Amended Site Closure Plan and Post -Closure Maintenance Plan (PCMP)
approved by the San Mateo County Department of Environmental Health, to avoid or reduce the
hazards related to the presence of hazardous materials (burn ash) and combustible vapor at this
site. The remediation measures are anticipated to include the following, based on measures
contained in the current PCMP:
• Placement of cap throughout the development area consistent with the final cover /
capping plan in an approved Amended PCMP.
• Installation of building combustible gas protection and monitoring features to consist of a
subfloor vapor barrier and passive venting system, and interior alarm system, unless
determined not to be necessary (due to vapor levels following current removal of landfill
materials from nearby portions of the Oyster Point Landfill).
• Adhering to applicable provisions of the existing Risk Management Plan and Health and
Safety Plan for soil handling during excavations for utility trenches, foundations, and other
site work.
• Adherence to water conservation standards for landscaping and irrigation to reduce or
eliminate the potential for water infiltration into underlying contaminated soil layers.
Consistent with conclusions under the current PCMP, compliance with an amended PCMP would result
in human health and ecological risk evaluations during both construction and operations to be
insignificant assuming implementation of identified measures into the proposed project. With
implementation of Mitigation Measure Haz-2, the impact relating to a hazardous material site and the
accidental release of hazardous materials would be less than significant.
Emissions of Hazardous Materials near a School
There are no existing schools within one-quarter mile of the project site and none within the East of 101
Area. There are no childcare facilities within one-quarter mile of the project site. The closest daycare
centers are approximately 0.5 miles from the project site, including the Cabot 2nd Generation at 342
Allerton Avenue and the 2nd Generation at 444 Allerton Avenue, as well as the private Early Years
Page 4-14 101 Gull Drive Project Draft EIR
Chapter 4: Hazards and Hazardous Materials
Preschool at 371 Allerton Avenue. The project would have no impact with respect to hazardous
materials within one-quarter mile of a school.
Hazardous Materials Site
The project site is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5. Because the contamination at the site represents potential impacts related to upset
and accident conditions during site construction, these criteria are assessed together under Impact Haz-
2 above.
Safety Hazards Related to a Public or Private Airport or Airstrip
Impact Haz-3: Development within Airport Land Use Plan Boundaries. The proposed project is located
within the Airport Land Use Plan boundaries of San Francisco International Airport (SFO), but the
project would comply with applicable regulations including required consultation with the
Federal Aviation Administration prior to construction and would not result in a safety hazard for
people residing or working at the project site. (Less than Significant)
The project site is within the boundary of the SFO ALUCP and as such, the compatibility criteria
contained within the ALUCP are applicable to development at the project site. Most of the East of 101
Area, including the project site, is located outside of the ALUCP-designated Safety Compatibility zone
that would have restricted types of uses, but within Airport Land Use Compatibility Area B, which
requires Airport Land Use Commission review of land development proposals, such as the proposed
project to confirm compatibility with airport uses and airspace safety. Development on the project site is
limited to heights between 200 and 250 feet above mean sea level according to the ALUCP but could be
modified through consultation with the Federal Aviation Administration (FAA). The proposed project
rooftop elements would reach up to 128 feet above ground level on a site that is approximately 60 feet
above mean sea level for a total height above mean sea level of approximately 188 feet. Thus, the
project would be consistent with height limitations identified in the ALUCP. Notification and
consultation with the Airport Land Use Commission would be required under CFR part 77.9 and would
ensure that the project is compatible with the SFO ALUCP. Therefore, this impact would be less than
significant.'
Impairment or Interference with an Emergency Response or Evacuation Plan
Impact Haz-4: Temporary Construction Obstructions. The proposed project would not result in
permanent changes to the roadway system or otherwise result in changes to area emergency
response or evacuation plans. No substantial construction -period roadway obstruction is
planned and any temporary construction obstructions would follow appropriate procedures.
(Less than Significant)
' City/County Association of Governments of San Mateo County, November 2012, Comprehensive Airport Land Use
Compatibility Plan for the Environs of San Francisco International Airport, including Exhibit IV -14 . Available at:
http://ccag.ca.gov/wp-content/u ploads/2014/10/Consolidated_CCAG_ALUCP_November-20121. pdf
101 Gull Drive Project Draft EIR Page 4-15
Chapter 4: Hazards and Hazardous Materials
The project would not include any changes to existing public roadways that provide emergency access to
the site or surrounding area. Vehicular access to and from the project would be via two existing mutual
access easements with nearby properties and one additional new access to Gull Drive, which would be
available via a mutual access easement to nearby properties, providing an additional point of
ingress/egress to all nearby properties. The proposed project would be designed to comply with the
California Fire Code and the City Fire Marshal's code requirements that require on site access for
emergency vehicles, a standard condition for any new project approval.
No substantial obstruction in public rights-of-way has been proposed with the project's construction
activities. However, any construction activities can result in temporary intermittent roadway
obstructions, but these would be handled through standard procedures with the City to ensure
adequate clearance is maintained.
Therefore, with compliance with applicable regulations and standard procedures, the impact with
respect to impairment or interference with an Emergency Response or Evacuation Plan would be less
than significant.
Wildland FirPc
The project site is a highly developed industrial area, and no wildlands are intermixed within this
industrial area. The closest wildlands area is San Bruno Mountain County Park located approximately
one mile away. The proposed project would not exacerbate wildfire risks of any nature, would not
substantially impair an adopted emergency evacuation plan or emergency response plan, and it not
located in or near a Local or State Responsibility area with a Very High Fire Hazard Severity Zone
designation. The project is not susceptible to significant risk of loss, injury or death involving wildland
fires and there would be no impact in this regard.'
Cumulative Hazards Risks
The project, when combined with other past, present, existing, approved, pending and reasonably
foreseeable development in the vicinity, would not result in significant cumulative hazards. With
implementation of applicable regulatory requirements, cumulative impacts related to hazards and
hazardous materials would be less than significant. Cumulative health and safety impacts could occur if
off-site hazards related to the project were to interact with or combine with similar effect of other
cumulative development within the East of 101 Area. These impacts could only occur through limited
mechanisms: air emissions, transport of hazardous materials and waste, inadvertent release of
hazardous materials to the sewer or non -hazardous waste landfill, and potential accidents that require
hazardous materials emergency response capabilities.
Because cumulative land use in the East of 101 Area relies on the same roads to be used by the project,
the project would contribute to a cumulative increase in the amount of hazardous materials transported
to and from the area. Cumulative increases in the transportation of hazardous materials and wastes
z California Department of Forestry and Fire Protection. 2007. San Mateo County Fire Hazard Severity Zones in SRA. Available:
https://osfm.fire.ca.gov/divisions/wildfire-planning-engineering/wildiand-hazards-building- codes/fire-hazard-severity-zones-
maps/.
Page 4-16 101 Gull Drive Project Draft EIR
Chapter 4: Hazards and Hazardous Materials
would not be significant because the probability of accidents is relatively low due to stringent
regulations that apply to transport, use and storage of hazardous materials. The project, in combination
with other development in the East of 101 Area would add to cumulative traffic congestion on those
roadways used for evacuation. Traffic congestion during an evacuation event is inevitable, but the
roadway system in the East of 101 Area allows for multiple possible evacuation routes in the case of an
emergency.
For these reasons, the proposed project, in combination with other past, present, and reasonably
foreseeable future projects, and with compliance with identified regulation and project -specific
mitigation, would not result in additional significant cumulative hazards or hazardous materials impacts.
101 Gull Drive Project Draft EIR Page 4-17
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5
Transportation
Introduction
This chapter of the EIR evaluates the potential impacts of the project related to transportation. It has
been prepared in coordination with Fehr & Peers.
Environmental Setting
Roadway Facilities
The project site is located on the west side of Gull Drive near Oyster Point Boulevard and Eccles Avenue
in the City of South San Francisco's East of 101 employment area. Regional access to the project site is
provided via U.S. Route 101 (U.S. 101) accessed via Oyster Point Boulevard to the north and East Grand
Avenue via Eccles Avenue or Forbes Boulevard to the south. Figure 5.1 shows the project location and
the surrounding roadway and transit system. Project site vehicular access is provided via a new two-way
driveway on Gull Drive to the east, an easement to Oyster Point Boulevard to the north (via 340 Oyster
Point Boulevard), and an easement to Eccles Avenue to the west (via 570-590 Eccles Avenue).
U.S. 101 is an eight -lane freeway and principal north -south roadway connection between San
Francisco, San Jose, and intermediate San Francisco Peninsula cities. In South San Francisco, U.S. 101
is located approximately one mile west of the project site and serves the East of 101 area with three
primary access points. Near the project site, U.S. 101 carries about 220,000 vehicles per day and
defines the East of 101 area's western edge and barrier to east -west bicycle and pedestrian
connectivity. Access points are listed below:
o Oyster Point Boulevard: Northbound on- and off -ramps intersect Dubuque Avenue at and
immediately south of Oyster Point Boulevard. Southbound on -ramps are at Dubuque Avenue,
adjacent to the northbound off -ramp. The southbound off -ramp intersects Gateway
Boulevard/Oyster Point Boulevard as the intersection's fifth leg.
o East Grand Avenue: Northbound off -ramps are at East Grand Avenue/Poletti Way and on -ramps
are to the west at Grand Avenue/Airport Boulevard. Southbound off -ramps are at Airport
Boulevard/Miller Avenue. There is no southbound freeway access at this location.
o South Airport Boulevard: Northbound on- and off -ramps are at South Airport Boulevard/
Wondercolor Lane; southbound on- and off -ramps are immediately south of the San Mateo
Avenue/Produce Avenue/South Airport Boulevard intersection.
• Gull Drive is a two-lane road connecting Oyster Point Boulevard with Forbes Boulevard and provides
direct vehicular access to the project site. It has Class II bicycle lanes and is signalized where it
connects to Oyster Point Boulevard and Forbes Boulevard.
101 Gull Drive Project Draft EIR Page 5-1
Chapter 5: Transportation
• Eccles Avenue is a two-lane roadway connecting Oyster Point Boulevard on the north and Forbes
Boulevard on the south. Signalized at both Oyster Point Boulevard and Forbes Boulevard, Eccles
Avenue has no street parking. The project site can be accessed from Eccles Avenue via an easement
driveway.
• Oyster Point Boulevard is an east -west arterial street that connects U.S. 101 with the Oyster Point
Marina. It has mostly four travel lanes between Gull Drive and U.S. 101. The project site could be
accessed from Oyster Point Boulevard via an easement driveway.
• Forbes Boulevard is a four -lane street extending north from East Grand Avenue, then running east
into the Genentech campus, terminating at DNA Way. East of Allerton Avenue, Forbes Boulevard has
two lanes and Class II buffered bicycle lanes. There is not direct driveway access from the project
site to Forbes Boulevard.
• East Grand Avenue is an east -west arterial street. It has six travel lanes west of Gateway Boulevard,
four travel lanes east of Gateway Boulevard, and two travel lanes east of Haskins Way. U.S. 101
freeway ramps at East Grand Avenue enable project site access from the south.
Transit Facilities and Service
Transit services are not located along the project's frontage, but there are transit options within walking
distance of the project site. The South San Francisco Ferry Terminal is located approximately 0.6 miles
from the project site (a 10 to 15 minute walk). The South San Francisco Caltrain station and South San
Francisco BART Station are farther away (approximately 1.5 miles and 4.1 miles, respectively) and no
SamTrans bus service currently serves the east of U.S. 101 area in South San Francisco near the project
site. The project site therefore relies on supplementary public shuttle services to connect employees
with regional transit. Shuttles to BART and Caltrain operated by the Peninsula Traffic Congestion Relief
Alliance (Commute.org) stop about 0.2 miles from the project site on Oyster Point Boulevard. Existing
transit services are shown in Figure 5.1.
Regional Transit Service
The following transit services operate within South San Francisco and are accessible from the project
site, primarily via Commute.org shuttles. Descriptions provided in this section reflect conditions prior to
the COVID-19 pandemic, which has resulted in atypical travel behavior and changes to transit services.
• BART provides regional rail service between the East Bay, San Francisco, and San Mateo County,
connecting between San Francisco International Airport and Millbrae Intermodal Station to the
south, San Francisco to the north, and Oakland, Richmond, Pittsburgh/Bay Point, Dublin/Pleasanton
and Fremont in the East Bay. Two BART lines serve South San Francisco Station: the Yellow Line
connecting Antioch with San Francisco International Airport, and the Red Line connecting Richmond
and Millbrae. Each BART line operates every 15 -minutes throughout the day.
• Caltrain provides passenger rail service on the Peninsula between San Francisco and San Jose, and
limited service to Morgan Hill and Gilroy during weekday commute periods. The South San Francisco
Caltrain Station serves local and limited trains, with 23 northbound and 23 southbound weekday
trains. The South San Francisco Caltrain Station provides weekday service from around 5:30 A.M. to
12:00 A.M., with approximately 30 -minute headways during peak times and 60 -minute headways
during off-peak times. In 2022, Caltrain plans to relocate the South San Francisco Caltrain station
Page 5-2 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
caltrain Station and A gnment F ] Project site
—C).- Cornmute,n g Shitit1k,. Rniitps and Sines - - - - FasPmPntt
— Samirar.s Routes
South San rrarc:sco ferry erminal
Figure 5.1: Project Vicinity Roadways and Transit Facilities
Source: Fehr & Peers
IE
AL
101 Gull Drive Project Draft EIR Page 5-3
Chapter 5: Transportation
several hundred feet to the south near the East Grand Avenue/Airport Boulevard intersection and
provide more direct pedestrian and shuttle access to the East of 101 area via a tunnel with access at
East Grand Avenue and Poletti Way. By 2024, Caltrain plans to complete its electrification project to
support the operation of faster and more frequent rail service on the Peninsula.
• The Water Emergency Transportation Authority (WETA) provides weekday commuter ferry service
between the Oakland/Alameda ferry terminals and the South San Francisco Ferry Terminal at Oyster
Point. There are three morning departures from Oakland/Alameda to South San Francisco, and three
evening departures from South San Francisco to Oakland/Alameda.
• SamTrans provides bus service in San Mateo County but does not serve the East of 101 employment
area near the project site. Draft recommendations from the Reimagine SamTrans project call for
extending Route 130 from its current terminus in downtown South San Francisco into the East of
101 area via East Grand Avenue, Gateway Boulevard, and Oyster Point Boulevard by Fall 2022;
however, these recommendations have not yet been adopted.
East of 101 Commuter Shuttle Service
Commute.org provides weekday commute period first/last mile shuttles connecting employers with
BART, Caltrain, and the ferry. Three shuttle routes serve the Oyster Point Boulevard corridor connecting
to the South San Francisco BART station, the South San Francisco Caltrain Station, and the South San
Francisco Ferry Terminal. Shuttles have timed connections to Caltrain and ferry service, while BART
shuttles meet every other peak period trains. While the closest eastbound shuttle stop to the project
site is located about 0.2 mile away near the intersection of Oyster Point and Eccles Avenue, there is no
corresponding westbound shuttle stop.
Pedestrian Facilities
Pedestrian facilities include sidewalks, crosswalks, trails, and pedestrian signals. Pedestrian facilities
near the project site tend to serve walking trips connecting to shuttle stops, the ferry terminal, and
nearby offices and businesses. The following pedestrian facilities exist near the project site:
Gull Drive has a continuous sidewalk along the east side of the street connecting Oyster Point
Boulevard to Forbes Boulevard. A partial sidewalk on the west side of the street also connects the
project site to Oyster Point Boulevard, but this sidewalk does not continue to Forbes Boulevard due
to steep grades and a drainage culvert.
Oyster Point Boulevard has a continuous sidewalk on the southern side of the street but does not
have a sidewalk on the northern side between Gull Drive and Eccles Avenue. Oyster Point Boulevard
may be accessed from the project site via the western sidewalk along Gull Drive or via the western
easement driveway through 340 Oyster Point Boulevard. At the intersection of Oyster Point
Boulevard and Gull Drive, marked crosswalks exist on the south and east legs of the intersection.
Oyster Point Boulevard provides the primary pedestrian connection to shuttle services as well as the
South San Francisco Ferry Terminal.
• Eccles Avenue has a continuous sidewalk on the western side of the street but lacks a sidewalk on
the eastern side of the street. Eccles Avenue may be accessed from the project site via the western
easement driveway along 570-590 Eccles Avenue.
Page 5-4 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
• Forbes Boulevard has a sidewalk on the north side of the street that connects to the sidewalk on the
western side of Gull Drive. Forbes Boulevard provides pedestrian access to the northern end of the
Genentech campus.
• A segment of the San Francisco Bay Trail runs along the shoreline in the East of 101 area, providing a
continuous off-street shared -use trail connection between Brisbane's Sierra Point to the north and
South Airport Boulevard at the San Bruno Canal to the south.
Gaps in sidewalks near the project site are shown on Figure 5.2.
Bicycle Facilities
Bicycle facilities consist of separated bikeways, bicycle lanes, routes, trails, and paths, as well as bicycle
parking, bicycle lockers, and showers for cyclists. The California Department of Transportation (Caltrans)
recognizes four classifications of bicycle facilities as described below.
Class I—Shared-Use Pathway: Provides a completely separated right-of-way for the exclusive use of
cyclists and pedestrians with crossflow minimized (e.g., off-street
bicycle paths).
Class II—Bicycle Lanes: Provides a striped lane for one-way travel on a street or highway. May
include a "buffer" zone consisting of a striped portion of roadway
between the bicycle lane and the nearest vehicle travel lane.
Class III—Bicycle Route: Provides for shared use with motor vehicle traffic; however, are often
signed or include a striped bicycle lane.
Class IV—Separated Bikeway: Provides a right-of-way designated exclusively for bicycle travel adjacent
to a roadway and which are protected from vehicular traffic. Types of
separation include, but are not limited to, grade separation, flexible
posts, inflexible physical barriers, or on -street parking.
Current bicycle facilities in the project vicinity, as designated by the City's Bicycle Master Plan and the
draft Active South City: Bicycle and Pedestrian Master Plan (ongoing), are shown in Figure 5.2 and
discussed below.
• Gull Drive has Class II bicycle lanes between Oyster Point Boulevard and Forbes Boulevard and
provides bicycle connectivity between the project site to Forbes Boulevard and Oyster Point
Boulevard.
• Forbes Boulevard has Class II bicycle lanes between Allerton Avenue and DNA Way. An extension of
bike lanes between Eccles Avenue and Allerton Avenue is planned.
• Oyster Point Boulevard has Class II bicycle lanes between Gull Drive and Gateway Boulevard.
• The Bay Trail is a Class I mixed-use trail along the San Francisco Bay shoreline.
101 Gull Drive Project Draft EIR Page 5-5
Chapter 5: Transportation
OOWNT� l
i
fx"sting Class I Shared Path "•'•' Plarned Class I Sha ed Patl South San rrancisco fer•y Ter sinal
Ex sting Class 11 Bicyc a Lane •"'" Plar-ied Class 11 Bicycle Lane A
South San Francisco Caltra'n Statior
Ex sting Class III Bicy� e Route •••••• Plarned Class III Bicycle Route
Fu ct'nq Class IV SFgaratPd RikPway ...... Plar-ied Class IV Separated Bikeway Project Site
Miss -ng Sidewalk- Easements
Figure 5.2: Project Vicinity Bicycle and Pedestrian Facilities
Source: Fehr & Peers
Page 5-6 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
Bicyclists primarily access the project site from Oyster Point Boulevard and Forbes Boulevard via Gull
Drive and Eccles Avenue. While the City continues to expand its bicycle network, the East of 101 area
has historically experienced low volumes of bicyclists due to commute lengths, lack of continuous low
stress bicycle facilities, lack of network connectivity to residences and transit stations, and topography.
The reconstructed South San Francisco Caltrain station (currently under construction, with completion
expected in 2022) features a bicycle and pedestrian undercrossing that will connect the East of 101 area
to residents and transit facilities west of U.S. 101. The undercrossing represents the first non -motorized
connection spanning the Caltrain and U.S. 101 corridors, which represent substantial barriers to east -
west bicycle and pedestrian travel.
Emergency Vehicle Access
Emergency vehicles typically use major streets through the study area when heading to and from an
emergency and/or an emergency facility. Arterial roadways allow emergency vehicles to travel at higher
speeds and provide enough clearance space to permit other traffic to maneuver out of the path of the
emergency vehicle and yield the right-of-way. The nearest fire station to the project is Fire Station 62
located at 249 Harbor Way, approximately 1.4 miles south of the project site. Emergency vehicle access
to the project site presently occurs via easements at 570-590 Eccles Avenue and 340 Oyster Point
Boulevard.
Regulatory Setting
Summary
The City of South San Francisco has jurisdiction over all local City streets and City -operated traffic signals
within the study area. Several regional agencies, including the San Mateo City/County Association of
Governments (C/CAG), the Congestion Management Agency in San Mateo County, and the Metropolitan
Transportation Commission (MTC), coordinate and establish funding priorities for intra -regional
transportation improvement programs. Freeways serving South San Francisco (US 101, 1-380 and 1-280),
associated local freeway ramps and local surface highway segments are under the jurisdiction of the
State of California Department of Transportation (Caltrans). Transit service providers such as BART,
Caltrain, SamTrans, and WETA (ferry service), have jurisdiction over their respective services.
State
California Department of Transportation
Caltrans has authority over the state highway system, including freeways, interchanges, and arterial
routes. Caltrans operates and maintains state highways in the project site vicinity. The Guide for the
Preparation of Traffic Impact Studies (Caltrans 2001) provides information that Caltrans uses to review
impacts on state highway facilities, including freeway segments. This guidance was updated by the Local
Development — Intergovernmental Review Program Interim Guidance published in November 2016 for
consistency with Senate Bill (SB) 743, described below.
101 Gull Drive Project Draft EIR Page 5-7
Chapter 5: Transportation
Assembly Bill 32 and Senate Bill 375
With the passage of Assembly Bill (AB) 32, the Global Warming Solutions Act of 2006, the state
committed itself to reducing greenhouse gas (GHG) emissions to 1990 levels by 2020. The California Air
Resources Board (CARE) is coordinating a response to comply with AB 32. In 2008, CARB defined its 1990
baseline level of emissions. On December 11, 2008, CARB adopted its Proposed Scoping Plan for AB 32.
This scoping plan included approval of SB 375 as the means for achieving regional transportation -related
GHG targets. In 2011, CARB completed its major rulemaking for reducing GHG emissions. Rules on
emissions, as well as market-based mechanisms such as the cap -and -trade program, took effect on
January 1, 2012.
SB 375 provides guidance regarding curbing emissions from cars and light-duty trucks to help the state
comply with AB 32. There are four major components to SB 375. First, SB 375 requires regional GHG
emissions targets. CARB's Regional Targets Advisory Committee guides the adoption of targets to be met
by 2020 and 2035 for each Metropolitan Planning Organization (MPO) in the state. These targets, which
MPOs may propose themselves, must be updated every eight years in conjunction with the revision
schedule of the housing and transportation elements of local general plans. Second, MPOs are required
to create a Sustainable Communities Strategy (SCS) that provides a plan for meeting regional targets.
The SCS and the Regional Transportation Plan (RTP) must be consistent, including action items and
financing decisions. If the SCS does not meet the regional target, the MPO must produce an alternative
planning strategy that details an alternative plan for meeting the target. Third, SB 375 requires regional
housing elements and transportation plans to be synchronized on eight-year schedules. In addition,
Regional Housing Needs Assessment allocation numbers must conform to the SCS. If local jurisdictions
are required to rezone land as a result of changes in the housing element, rezoning must take place
within three years of adoption of the housing element. Finally, MPOs must use transportation and air
emissions modeling techniques that are consistent with the guidelines prepared by the California
Transportation Commission. Regional transportation planning agencies, cities, and counties are
encouraged, but not required, to use travel demand models that are consistent with California
Transportation Commission guidelines. The adopted RTP, per SB 375 (Plan Bay Area 2040), is discussed
below.
Complete Streets (AB 1358)
Assembly Bill (AB) 1358, also known as the California Complete Streets Act of 2008, requires cities and
counties to include "complete street" policies in their general plans. These policies address issues
regarding the safe accommodation of all users, including bicyclists, pedestrians, motorists, public transit
vehicles and riders, children, the elderly, and persons with disabilities. These policies can apply to new
streets as well as the redesign of transportation corridors.
Senate Bill 743
Senate Bill (SB) 743, was signed into law in 2013 and is codified in Section 21099 of the California Public
Resources Code with the intent to better align CEQA transportation impact analysis practices and
mitigation outcomes with the State's goals to reduce greenhouse gas (GHG) emissions, encourage infill
development, and improve public health through more active transportation. SB 743 created several key
statewide changes to CEQA, as described in the EIR sections referenced above. This discussion focusses
on changes related to the assessment of transportation and parking impacts under CEQA.
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Chapter 5: Transportation
As required by SB 743, the Office of Planning and Research (OPR) amended CEQA Guidelines Section
15064.3 to provide an alternative to automobile delay, as described by level of service (LOS) or similar
measures of vehicular capacity or traffic congestion, for evaluating traffic impacts of proposed projects.
The new metric, vehicle miles traveled (VMT), measures the total number of miles traveled by vehicles
daily on the roadway network and thereby the impacts on the environment from those miles traveled
(e.g., through GHG emissions). In other words, SB 743 changes the focus of transportation impact
analysis in CEQA from measuring impacts on drivers to measuring the impact of driving on the
environment, particularly as it relates to GHG emissions. Land use projects with one or more of the
following characteristics would generally have lesser VMT impacts relative to projects without these
characteristics:
• A mix of project uses;
• Support for a citywide jobs/housing balance;
• Proximity to high-quality transit service; and
• Locations in highly walkable or bikeable areas.
Additionally, CEQA Guidelines Section 15064.3 (b)(1) states that lead agencies generally should presume
that projects within 0.5 mile of an existing major transit stop or an existing stop along a high-quality
transit corridor will have a less -than -significant impact on VMT. This presumption would not apply,
however, if project -specific or location -specific information indicates that the project will still generate
significant levels of VMT. For transportation infrastructure projects, such as a street extension, projects
that reduce or have no impact on VMT are presumed to have a less -than -significant impact on VMT.
This shift in transportation impact criteria is expected to align transportation impact analysis and
mitigation outcomes with state goals to reduce GHG emissions, encourage infill development, and
improve public health through more active transportation. Although OPR provides recommendations for
adopting new VMT analysis guidelines, lead agencies retain discretion in designing their methodology.
Lead agencies must select their preferred method for estimating and forecasting VMT, their preferred
significance thresholds for baseline and cumulative conditions, and the mitigation strategies they
consider feasible. Lead agencies must prove that their selected analysis methodology aligns with SB
743's goals to promote infill development, reduce GHGs, and reduce VMT. To aid in SB 743
implementation, the following state guidance has been published:
• OPR's Technical Advisory on Evaluating Transportation Impacts in CEQA
California Air Resources Board's (CARB's) 2017 Scoping Plan -Identified VMT Reductions and
Relationship to State Climate Goals
California Department of Transportation's (Caltrans') Local Development—Intergovernmental Review
Program Interim Guidance, Implementing Caltrans Strategic Management Plan 2015-2020
Consistent with SB 743
On June 10, 2020, the City of South San Francisco adopted Resolution 77-2020 establishing VMT
thresholds and methodology effective July 1, 2020. The VMT thresholds applied in this analysis are
further described in the Significance Criteria section below.
101 Gull Drive Project Draft EIR Page 5-9
Chapter 5: Transportation
Regional
San Mateo Citv/County Association of Governments
The San Mateo City/County Association of Governments (C/CAG) is the Congestion Management Agency
(CMA) for San Mateo County and is authorized to set State and federal funding priorities for
improvements affecting the San Mateo County Congestion Management Program (CMP) roadway
system. The C/CAG-designated CMP roadway system in South San Francisco near the project site
includes U.S. 101 and Interstate 380.
C/CAG has adopted guidelines to reduce the number of net new vehicle trips generated by new land
development. These guidelines apply to all developments that generate 100 or more net new peak hour
vehicular trips on the CMP network and are subject to CEQA review. The goal of these guidelines is that
developers and/or tenants will reduce demand for all new peak hour trips (including the first 100 trips)
projected to be generated by a development.
C/CAG has adopted guidelines as a part of its CMP, which are intended to reduce the regional traffic
impacts of substantive new developments. The guidelines apply to all projects in San Mateo County that
will generate 100 or more net new peak hour trips on the CMP network and are subject to CEQA review.
C/CAG calls for projects that meet the criteria to determine if a combination of acceptable measures is
possible that has the capacity to "fully reduce," through the use of a trip credit system, the demand for
net new trips that the project is anticipated to generate on the CMP roadway network (including the
first 100 trips). C/CAG has published a list of mitigation options in a memorandum. South San Francisco's
Transportation Demand Management (TDM) ordinance is consistent with CCAG's ordinance, so by
adhering to the City's ordinance, the proposed project would also be compliant with CCAG's guidelines.
Local
City of South San Francisco General Plan
The 1999 South San Francisco General Plan (General Plan) provides a vision for long-range physical and
economic development of the City, provides strategies and specific implementing actions, and
establishes a basis for judging whether specific development proposals and public projects are
consistent with the City's plans and policy standards. The General Plan contains a Transportation
Element, which includes policies, programs, and standards to enhance capacity and provide new
linkages to provide "Complete Streets" that are safe, comfortable, and convenient routes for walking,
bicycling, and public transportation to increase use of these modes of transportation, enable active
travel as part of daily activities, reduce pollution, help reduce transportation demand, and meet the
needs of all users of the streets, including bicyclists, children, persons with disabilities, pedestrians,
users of public transportation, seniors, youth, and families, while continuing to maintain a safe and
effective transportation system for motorists and movers of commercial goods. The general plan
includes the following policies that are applicable to transportation and circulation.
• Guiding Principle 4.2-G-1: Undertake efforts to enhance transportation capacity, especially in
growth and emerging employment areas such as in the East of 101 area.
Guiding Principle 4.2-G-2: Improve connections between different parts of the city. These would
help integrate different parts of the city. Connections between areas west and east of U.S. 101
(currently limited to streets that provide freeway access) would also free -up capacity along streets
Page 5-10 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
Grand Avenue and Oyster Point Boulevard that provide access to U.S. 101. (Amended by Resolution
26-2014, adopted February 12, 2014)
• Guiding Principle 4.2-G-8: Use the Bicycle Master Plan to identify, schedule, and implement roadway
improvements that enhance bicycle access. (Amended by Resolution 26-2014, adopted February 12,
2014)
• Guiding Principle 4.2-G-9: Use the Pedestrian Master Plan to identify, schedule, and implement
roadway improvements that enhance pedestrian access. (Amended by Resolution 26-2014, adopted
February 12, 2014)
• Guiding Principle 4.2-G-10: Make efficient use of existing transportation facilities and, through the
arrangement of land uses, improved alternate modes, and enhanced integration of various
transportation systems serving South San Francisco, strive to reduce the total vehicle -miles traveled.
• Guiding Principle 4.2-G-13: Integrate Complete Streets infrastructure and design features into street
design and construction to create safe and inviting environments for people to walk, bicycle, and use
public transportation. (Amended by Resolution 136-2014, adopted December 10, 2014)
• Guiding Principle 4.2-G-14: Make Complete Streets practice a routine part of South San Francisco's
everyday operations. (Amended by Resolution 136-2014, adopted December 10, 2014)
• Guiding Policy 4.3-G-3: In partnership with employers, continue efforts to expand shuttle operations.
• Guiding Policy 4.3-G-4: In partnership with the local business community, develop a transportation
systems management plan with identified trip -reduction goals, while continuing to maintain a
positive and supportive business environment.
• Implementing Policy 4.3-1-4: Require provision of secure covered bicycle parking at all existing and
future multifamily residential, commercial, industrial, and office/ institutional uses.
• Implementing Policy 4.3-1-11: As part of any development in Lindenville or East of 101, require
project proponents to provide sidewalks and street trees as part of frontage improvements for new
development and redevelopment projects.
• Implementing Policy 4.3-1-16: Favor Transportation Systems Management programs that limit vehicle
use over those that extend the commute hour.
• Implementing Policy 4.4-1-4: Encourage SamTrans to increase the shuttle or bus -service to the East of
101 area to better serve the area's growing employment base.
The City of South San Francisco is presently updating its General Plan but has not yet adopted new
transportation policies.
South San Francisco Bicycle Master Plan and Pedestrian Master Plan
The City's Bicycle Master Plan identifies and prioritizes street improvements to enhance bicycle access.
The plan analyzes bicycle demand and gaps in bicycle facilities and recommends improvements and
programs for implementation as described in the policy below.
101 Gull Drive Project Draft EIR Page 5-11
Chapter 5: Transportation
Policy 3.2-1: All development projects shall be required to conform to the Bicycle Transportation
Plan goals, policies and implementation measures.
The City's Pedestrian Master Plan identifies and prioritizes street improvements to enhance pedestrian
access. The plan analyzes pedestrian demand and gaps in pedestrian facilities and recommends
improvements and programs for implementation. The Pedestrian Master Plan establishes the following
policy related to the project:
• Policy 3.2: Pedestrian facilities and amenities should be provided at schools, parks, and transit stops,
and shall be required to be provided at private developments, including places of work, commercial
shopping establishments, parks, community facilities and other pedestrian destinations.
The City is currently updating both the Bicycle Master Plan and Pedestrian Master Plan via the Active
South City: Bicycle and Pedestrian Master Plan.
South San Francisco Transportation Demand Management Ordinance
The City's Transportation Demand Management (TDM) Ordinance, which is specified in Title 20 of the
City's Municipal Code in Chapter 20.400, Transportation Demand Management, seeks to reduce the
amount of traffic generated by nonresidential development and minimize drive -alone commute trips.
The ordinance establishes a performance target of 28 percent minimum alternative mode share for all
nonresidential projects resulting in more than 100 average daily trips and identifies higher thresholds for
projects requesting a floor area ratio (FAR) bonus.
Per the ordinance, all projects are required to submit annual mode share surveys. Project sponsors
seeking an FAR bonus are required to submit triennial reports assessing project compliance with the
required alternative mode share target. Where targets are not achieved, the report must include
program modification recommendations and City officials may impose administrative penalties should
subsequent triennial reports indicate mode share targets remain unachieved.
Impacts and Mitigation Measures
Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a transportation and
circulation impact if it would do any of the following:
• Conflict with a program, plan, ordinance, or policy addressing the circulation system, including
transit, roadway, bicycle, and pedestrian facilities;
• Generate per -employee VMT greater than the City's adopted threshold of 15 percent below the
regional average, pursuant to CEQA Guidelines Section 15064.3, subdivision (b) and City of
South San Francisco Resolution 77-2020 related to VMT;
• Substantially increase hazards due to a geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible land uses; or
• Result in inadequate emergency access.
Page 5-12 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
Project Trip Characterization
While congestion -based analysis is no longer used for assessment of CEQA impacts per SB 743 and City
of South San Francisco Resolution 77-2020, the project's trip generation is still useful in conveying an
understanding of the project and to better assess circulation on and around the site.
Proposed project traffic added to the surrounding roadway system was estimated using data collected in
Fall 2019 from three sample office and research and development (R&D) campus sites in the East of 101
area. Local travel demand data were used instead of national averages because of the unique
transportation and land use conditions in the East of 101 area, including peak period spreading, mix of
employers, and higher rates of participation in TDM programs. In contrast, national trip generation data
such as the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th edition are
generally collected at suburban sites with limited non -auto access and less congestion.
The project trip generation rate was derived from the sample site data and multiplied by the size of the
proposed project (gross square feet) to determine average weekday, AM peak hour, and PM peak hour
vehicle trip generation volume, shown in Table 15.1.
Table 5.1: Project Trip Generation
Land Use
Size (KSF)
Daily
Total
AM Peak Hour
In Out Total
PM Peak Hour
In Out Total
Project
166.6
933
147 18 165
24 150 175
Source: Fehr & Peers 2021.
Notes: KSF = thousand square feet.
Trip generation rates based on 2019 driveway count data collected at similar sites in South San Francisco's East of 101 area and reflect a
daily rate of 5.6, A.M. Peak Hour rate of 0.99, and P.M. Peak Hour rate of 1.05. Rates are reported in trips per thousand square feet.
According to this trip generation analysis, the new 166,600 square foot office building would generate
933 new daily trips, 165 new AM peak hour trips (147 inbound and 18 outbound), and 175 new PM peak
hour trips (24 inbound and 150 outbound). As noted previously, the project site is currently vacant and
therefore no trips were discounted from the total trip generation estimate.
Project traffic would exit the site primarily via driveways on Gull Drive and Eccles Avenue, while exiting
via Oyster Point Boulevard would be discouraged via site design and signage.
The project would generate non -auto trips, including trips walking and bicycling to and from nearby
destinations as well as accessing regional transit. Approximately 60 to 80 walking and bicycle trips would
be generated during each peak hour, with most trips occurring via walking to and from nearby shuttle
stops and the ferry terminal.
Conflict with a Transit, Bicycle or Pedestrian System Program or Policy
Impact TR -1: Increased Demand for Transit, Bicycle, and Pedestrian Facilities. The proposed project
would not produce a detrimental impact to existing bicycle, pedestrian, or transit facilities, or
conflict with adopted plans and programs. (Less than Significant)
101 Gull Drive Project Draft EIR Page 5-13
Chapter 5: Transportation
Construction
Construction activities could potentially interfere with programs, plans, ordinances, or policies if
temporary closures impede roadways, shuttle stops, bikeways, or pedestrian paths in a way that
prohibits the achievement of identified goals. Similarly, construction activities could have a detrimental
impact on existing bicycle, pedestrian, or transit facilities if temporary closures impede the use of these
facilities. However, while temporary sidewalk and bike lane rerouting on Gull Drive is expected and
roadway traffic control would be used as needed during construction, detours would be temporary in
nature and would not fully impede movement or have a sustained detrimental impact on existing bicycle
and pedestrian facilities. In the event of a temporary construction closure, the project would be
required to prepare a traffic control plan that would document how temporary facilities, detour routes,
and/or signage would be provided consistent with guidance from the California Manual on Uniform
Traffic Control Devices (CA-MUTCD). Therefore, the project would not produce a detrimental impact on
existing bicycle and pedestrian facilities during construction and construction -related conflicts with
programs, plans, ordinances, or policies addressing the circulation system would be less than significant.
No mitigation is required.
Operation
The project would not produce a detrimental impact to existing bicycle or pedestrian facilities or conflict
with adopted policies in adopted City plans summarized in the Regulatory Setting section earlier in this
chapter. The project would generate additional vehicle trips to existing sidewalks, bikeways, and shuttle
routes along streets such as Oyster Point Boulevard and Gull Drive, and would also generate
approximately 60 to 80 walking and bicycling trips on such streets during each peak hour. However, by
adding approximately three vehicles per minute to the surrounding street network, the project would
not adversely affect existing or planned bicycle or pedestrian facilities or substantially lengthen travel
times by existing shuttle services. Although the project would add a new driveway across existing bike
lanes on Gull Drive, the bike lanes would be marked per applicable design standards to minimize
potential conflicts with vehicles.
Therefore, the project's impacts to walking, bicycling, and transit facilities would be less than significant.
In addition, project -related conflicts with programs, plans, ordinances, or policies addressing the
circulation system would be less than significant. No mitigation is required.
Vehicle Miles Travelled
Impact TR -2: Vehicles Miles Traveled. The vehicle miles traveled per employee exceeds the City's
adopted threshold of 15 percent below the regional average under existing and future
conditions. (Significant and Unavoidable with Mitigation)
On June 10, 2020, the City of South San Francisco adopted Resolution 77-2020 establishing VMT
thresholds and methodology effective July 1, 2020. The adopted VMT threshold for land use projects
determines that a project would have a significant transportation impact if the VMT for the project
would be 15 percent below the applicable baseline VMT.
The project was analyzed based on home-based work (HBW) VMT per employee as shown in Table 5.2.
HBW VMT per employee was derived from the C/CAG Travel Demand Model. This metric follows City
Page 5-14 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
and OPR guidance for measuring office project VMT and helps compare the project's relative
transportation efficiency to the regional average baseline.
Based on these factors, a significant impact would occur if existing HBW VMT per employee in the
transportation analysis zone (TAZ) results in greater than 15 percent below the existing regional
average. Based on the City's analysis using the C/CAG Model, this threshold would be set at 12.1 HBW
VMT per employee for office and R&D projects, which represents 15 percent below the existing regional
average of 14.2 HBW VMT per employee as shown in Table 5 2. This threshold of 12.1 HBW VMT per
employee also applies to cumulative conditions.
The project's effect on VMT describes changes in VMT generation from neighboring land uses by
comparing area VMT for "no Project" and "Project" scenarios. Project -generated HBW VMT per
employee is calculated based on the average HBW VMT generated by employees working in the C/CAG
Model transportation analysis zone (TAZ) where the project is located divided by the number of jobs
within the TAZ. A TAZ is the smallest resolution available in the C/CAG Model. Each TAZ included in the
model contains information related to the existing and proposed land uses and transportation options
for zone. Therefore, the transportation properties of the project's TAZ are an appropriate proxy for
transportation properties of the project itself.
Per City requirements, the project is required to implement a TDM Plan. The proposed project would
include a TDM Plan to achieve an alternative mode use goal of 35 percent to help manage commuting
via driving alone. The effects of the project's TDM Plan are included in the calculation of HBW VMT.
Additional potential reductions to VMT based on implementation of the project's TDM Plan are
uncertain for several reasons. First, mode share targets do not necessarily correlate with trip generation
and trip length; although many East of 101 employers meet their non -drive alone mode share targets,
vehicle trip generation and trip lengths remain comparable to regional averages. Second, alternative
mode share targets include passenger vehicle -based modes such as vanpools and carpools, which may
dilute its effectiveness of VMT reductions. Third, VMT is a measure of daily activity for all trips, whereas
accounting for non -drive alone mode share targets focuses only on commute trips. Therefore, additional
VMT adjustments based on the project's TDM Plan are not applicable.
Table 5.2: Home -Based Work Vehicle Miles Traveled Per Employee
Location
Estimated HBW VMT
Estimated
Estimated HBW VMT
per Employee
Employees
Bay Area Region (Existing)
14.2
4,461,700
63,336,200
VMT Reduction Factor
(15%)
HBW VMT Per Employee Threshold
12.1
Project (Existing)
16.2
550
8,900
Above threshold
Yes
Project (2040 Cumulative)
12.9
550
7,100
Above threshold
Yes
Source: Fehr & Peers 2021; C/CAG-VTA Bi -County Transportation Demand Model, 2021.
Notes: HBW = home-based work; VMT = vehicle miles traveled.
Project estimated employees are based on employment density of 1 employee per 300 square feet.
101 Gull Drive Project Draft EIR Page 5-15
Chapter 5: Transportation
Based on this methodology, the project would generate 16.2 HBW VMT per employee under existing
conditions and 12.9 HBW VMT per employee under future cumulative conditions. The above -threshold
HBW VMT is due to above-average trip lengths and auto mode shares. As transit, first/last mile, and
housing projects envisioned in the South San Francisco General Plan are built out, HBW VMT is expected
to decline over time but would remain above the threshold of significance under cumulative conditions.
Note that this impact is not unique to the project. Since VMT is analyzed based on HBW VMT per
employee averages for the entire East of 101 area, most office/R&D projects in this area incur a
significant and unavoidable impact to VMT unless they are located within one half mile of the Caltrain
station.
Mitigation Measure TR -2: First- and Last -Mile Strategies. The project sponsor shall coordinate with the
City for the project sponsor to implement the following off-site improvements to support the
project's first- and last -mile and active transportation connections necessary to support
reductions in Home -Based Work Vehicle Miles Traveled.
• Participation in first -/last -mile shuttle program(s) to Caltrain and BART. Shuttles may be
operated by Commute.org and/or other East of 101 shuttle providers offering services open
to the general public.
• Restriping of five crosswalks at the intersection of Oyster Point Boulevard and Eccles
Avenue, one crosswalk at the intersection of Oyster Point Boulevard, and two crosswalks at
the intersection of Oyster Point Boulevard and the 329-333 Oyster Point Boulevard driveway
with high -visibility longitudinal markings to enhance pedestrian access to the westbound
shuttle stop and nearby land uses.
The project sponsor shall additionally coordinate with the City for the project sponsor to pay
fair -share contribution toward the following off-site improvements to support the project's first -
and last -mile and active transportation connections necessary to support reductions in Home -
Based Work Vehicle Miles Traveled.
Modification of the existing eastbound shuttle stop at the far side of the Oyster Point
Boulevard/Eccles Avenue intersection to provide an accessible five-foot long by eight -foot
wide landing pad and pavement markings (if such facilities are not already fully funded or
constructed by the City or SamTrans).
Installation of a westbound shuttle stop at the far side of the Oyster Point Boulevard/Eccles
Avenue intersection including a pole, accessible five-foot long by eight -foot wide landing
pad, pavement markings, and shelter (if such facilities are not already fully funded or
constructed by the City or SamTrans).
Provision of eastbound and westbound Class II buffered bicycle lanes along Eccles Avenue
between Forbes Boulevard and Oyster Point Boulevard, spanning approximately 3,000 linear
feet. The improvement consists primarily of restriping the curbside vehicle travel lane in
each direction to a Class II buffered bicycle lane and signage. The bicycle facility will help
close a gap between the project and a planned Class I shared -use pathway between Forbes
Boulevard / Eccles Avenue and the South San Francisco Caltrain station.
Page 5-16 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
First- and last -mile transit connections and active transportation improvements are likely to produce the
greatest project VMT reductions. Mitigation Measure TR -2, First- and Last -Mile Strategies, would help
enhance first- and last -mile and active transportation connections, supporting decreased use of single -
occupancy vehicles. The components of Mitigation Measure TR -2 are shown in Figure 5.3. The
effectiveness of Mitigation Measure TR -2 is uncertain and cannot be guaranteed to fully reduce VMT
under the threshold of significance under existing or cumulative conditions. Therefore, this impact
would be significant and unavoidable with mitigation.
Note that this impact is not unique to the project. Since VMT is analyzed based on HBW VMT per
employee averages for the entire East of 101 area, most office/R&D projects in this area incur a
significant and unavoidable impact to VMT unless they are located within one half mile of the Caltrain
station.
For the off-site improvements, the City would collect payment from the project sponsor and would
allocate those funds for the specific improvements identified. Specific details of the contributions would
be addressed in the project's conditions of approval, but in any case, would comply with the Mitigation
Fee Act. The potential environmental impacts of these pedestrian and bicycle improvements would be
analyzed under the CEQA review prepared for the Active South City: Bicycle and Pedestrian Master Plan.
Any impacts associated with the construction of these projects would be temporary and minor in nature
(e.g., short-term construction impacts related to air quality and noise) and would not result in a
substantial adverse impact on the environment. The participation in first- and last -mile shuttle
program(s), would not result in long-term air quality, greenhouse gas, or noise impacts. Thus, no
adverse secondary impacts on the environment would occur with implementation of Mitigation
Measure TR -2.
Transportation Hazards
Impact TR -3: New Project Meeting Safety Standards. The proposed project would not substantially
increase hazards due to a geometric design feature or incompatible uses. (Less than Significant)
The proposed project would not worsen any existing geometric design features or cause new design
hazards. The project would rely on two existing driveways accessed via 340 Oyster Point Boulevard and
570-590 Eccles Avenue and would provide a new unsignalized driveway providing a direct connection to
Gull Drive. Existing driveways would be appropriate to handle expected vehicle traffic in and out of the
buildings constructed pursuant to the project. Although the driveway between 340 Oyster Point
Boulevard and 570-590 Eccles Avenue includes a circuitous connection for vehicles exiting to the traffic
signal at the intersection of Oyster Point Boulevard/329-333 Oyster Point Boulevard driveway, the
project would include signage directing vehicles to exit via Eccles Avenue instead and include driveway
geometry to encourage target circulation.
The new driveway on Gull Drive would not change the geometry of the adjacent roadways. Based on an
assessment of the site, the sight distance at the proposed driveway location is expected to be adequate
for drivers exiting the project site and for pedestrians crossing the driveways. The hill north of the
driveway would be graded to ensure sight distance is met, and any future vegetation or signage located
in the sight triangles at the driveway would be maintained to prevent restricting drivers' sight distance
when exiting the driveway.
101 Gull Drive Project Draft EIR Page 5-17
Chapter 5: Transportation
Provide westbound
shuttle stop with a
pole, accessible 5-footRestripe Ecrojsswal)ks
long by 8 -toot wide `++'
landing pad, pavement
markings, and shelter Restripe 2 crosswalks
Provide accessible
5 -foot long by 8 -foot
wide landing pad and
pavement markings
Provideeastbound
westbound Class fl
buffered biryrle lanes
1
C7
Prosect Site
Ea<_emerts
Figure 5.3: Identified Vicinity Improvements to Transit & Active Transportation
Source: Fehr & Peers
EAST OF
101
F1
Page 5-18 101 Gull Drive Project Draft EIR
Chapter 5: Transportation
The project would not include any uses that are incompatible with the surrounding land use or the
existing roadway system; trips generated by office/R&D uses are consistent with the surrounding mix of
office/R&D and light industrial land uses..
Therefore, the project is not expected to result in a substantial increase to hazards, and the project's
impacts to hazards would be less than significant under existing plus project conditions and less than
significant under cumulative plus project conditions. No mitigation is required.
Emergency Access
Impact TR -4: Adequate Emergency Access. The proposed project would not result in inadequate
emergency access. (Less than Significant)
Vehicle trips generated by the project would represent a small percentage of overall daily and peak hour
traffic on roadways and freeways in the study area. The project would generate about three vehicle trips
per minute on average during peak hours, which is not expected to introduce or exacerbate conflicts for
emergency vehicles traveling near the project. The project would not include features that would alter
emergency vehicle access routes or roadway facilities; fire and police vehicles would continue to have
access to all facilities around the entire City. Emergency vehicles would have full access to the project
site via three driveways connecting to adjacent streets; each driveway would be equipped to handle all
types of emergency vehicles. Therefore, the project would result in adequate emergency access, and the
project's impacts to emergency access would be less than significant under existing plus project
conditions and less than significant under cumulative plus project conditions. No mitigation is required.
Cumulative Impacts
Cumulative conditions include transportation demand resulting from reasonably foreseeable land use
changes and conditions associated with funded transportation projects.
As indicated in the analysis above, the vehicle miles traveled analysis was performed for both existing
and future cumulative conditions with the same conclusions. There would be no difference in the
impacts or conclusions related to conflict with programs, transportation hazards, or emergency access,
as the conclusion that the project would comply with applicable programs and, safety standards, and
provide adequate emergency access are not affected by changes in future cumulative analysis
conditions. There are no additional cumulative impacts or mitigation required beyond the cumulative
vehicle miles traveled impact identified above.
101 Gull Drive Project Draft EIR Page 5-19
Chapter 5: Transportation
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Page 5-20 101 Gull Drive Project Draft EIR
Other CEQA Topics
Introduction
This chapter of the Draft EIR contains discussion of the following additional CEQA considerations:
• Mandatory Findings of Significance
• Significant Irreversible Modifications in the Environment
• Growth Inducing Impacts
The environmental effects of the proposed project, proposed mitigation measures, and alternatives are
summarized in Chapter 2: Executive Summary.
Mandatory Findings of Significance
Appendix G of the CEQA Guidelines (Environmental Checklist) contains a list of mandatory findings of
significance that may be considered significant impacts if any of the following occur:
1. Does the project have the potential to substantially degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to
drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a rare or endangered plant or animal or eliminate
important examples of California history or prehistory?
2. Does the project have impacts that are individually limited, but cumulatively considerable?
3. Does the project have environmental effects which will cause substantial adverse effects on human
beings either directly or indirectly?
Quality of the Environment
With compliance with regulatory requirements and implementation of mitigation measures identified in
this document, the project would not degrade the quality of the environment, substantially reduce the
habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining
levels, or threaten to eliminate a plant or animal community. The project site is in an urbanized area, is
generally consistent with surrounding development, and the site does not contain biological or cultural
resources.
101 Gull Drive Project Draft EIR Page 6-1
Chapter 6: Other CEQA Topics
Cumulative Impacts
The immediate vicinity of the project site is largely already developed. The cumulative context for
analysis in this EIR includes the existing development as well as continued redevelopment, especially in
the surrounding East of 101 area.
As detailed in this EIR and the attached Initial Study, impacts of the project are considered to be less
than significant or reaching that level with mitigation for all topic areas except transportation, and the
same would therefore be true for cumulative impacts given the cumulative scenario for this site.
The project would result in a significant impact with respect to vehicles miles traveled per employee,
which is over target rates at this site. While overall vehicles miles traveled per employee is expected to
go down over time in all areas including at the project site, the analysis in this Draft EIR determined that
the site continue to have vehicles miles traveled per employee rates above future cumulative threshold
levels as well.
Adverse Effects on Human Beings
Potential impacts of the project on human beings include exposure to emissions, site soils and seismic
activity, disturbance of site contamination during construction, potential presence of methane gas in soil
vapor, and routine hazardous materials use; however, these impacts are less than significant with
compliance with regulatory requirements and identified mitigation as detailed in this Draft EIR and the
attached Initial Study. The project would not have environmental effects that would cause substantial
adverse effects on human beings, either directly or indirectly.
Significant Irreversible Modifications in the Environment
An EIR must identify any significant irreversible environmental changes that could be caused by a
project. These may include current or future uses of non-renewable resources, and secondary or
growth -inducing impacts that commit future generations to similar uses. Irretrievable commitments of
resources should be evaluated to assure that such current consumption is justified. The CEQA Guidelines
describe three distinct categories of significant irreversible changes:
1. Changes in land use which would commit future generations to specific uses;
2. Irreversible damage; and
3. Commitment of Resources.
Changes in Land Use which Would Commit Future Generations
The project proposes office and R&D development on a site zoned for such use in the City's General
Plan. The type of use is consistent with plans and policies for development of the site and would not
constitute a change in land use.
Irreversible Damage
While currently vacant, the site is not in a "natural" state, and development of this site in an urbanized
area would not represent damage to an otherwise natural resource. While accident involving routine
Page 6-2 101 Gull Drive Project Draft EIR
Chapter 6: Other CEQA Topics
use of hazardous materials or site contamination during construction can never be fully discounted,
compliance with regulatory requirements, standard procedures, and mitigation measures identified in
the Draft EIR and attached Initial Study would result in non-significant risk of occurrence. Similarly, while
air quality and greenhouse gas emissions would contribute to regional pollutant levels and global
climate change, through compliance with applicable regulatory requirements, local greenhouse gas
reduction measures, and mitigation measures identified in this Draft EIR and attached Initial Study, the
project would comply with emissions reduction targets and would result in non-significant contribution
to emissions -related environmental damage.
Commitment of Resources
Consumption of nonrenewable resources can include increased energy consumption, conversion of
agricultural lands, and lost access to mining reserves. The project would not result in the loss of
agricultural lands or mining reserves, as these are not located at or near the site. Development of the
project area as proposed could result in the commitment of nonrenewable resources (e.g., gravel and
petroleum products) and slowly renewable resources (e.g., wood products) used in construction. The
operation of the proposed use would also require commitment of water and energy resources (e.g.,
petroleum products for vehicle operations, natural gas and electricity for lighting, heating, and cooling).
As a project on a vacant site that is consistent with the General Plan and zoning designation for the site,
it can be concluded that the project is consistent with City plans for area development and, therefore,
that energy consumption for construction and operations would not be considered unnecessary. The
project incorporates energy and energy-related efficiency measures meeting all applicable
requirements, including water and waste efficiency. The project is not required to prepare a separate
Water Supply Assessment under Senate Bill 610 because the project has less than 1,000 employees and
is less than 250,000 square feet (the threshold for a commercial office building) and can instead rely
upon the planning within the current UWMP, which indicates available supply for the proposed project,
which is within development assumptions for the site. The project would be required to comply with all
standards of Title 24 of the California Code of Regulations and the California Green Building Standards
Code (CALGREEN), as applicable, aimed at the incorporation of energy -conserving design and
construction. The project would also implement a Transportation Demand Management Plan to reduce
employee trips, thereby reducing energy consumption for transportation for the employees. The project
is also consistent with regional and local climate actions plans, as currently applicable, which include
measures related to energy consumption.
Growth -Inducing Effects
Typical growth inducement concerns of CEQA include actions such as the extension of roadways or
expansion of infrastructure capacity that would otherwise preclude new development or that would
induce growth beyond what is otherwise planned. Proposed project improvements are limited to the
project site or contribution to already -planned improvements such as for the vicinity sewer line and area
transit and bicycle facilities.
The project is on an infill site in the East of 101 section of the city which consists almost entirely of
similar employment centers. While neither housing nor population are directly created as a result of this
project, employment opportunities can indirectly increase population and the demand for housing.
Based on an average office/R&D project employment density of 300 gross square footage per employee,
the project is estimated to introduce 555 new jobs to the City of South San Francisco. The current South
Page 6-3 101 Gull Drive Project Draft EIR
Chapter 6: Other CEQA Topics
San Francisco General Plan was released in 1999 and does not have relevant employee estimates and
the updated General Plan, while being prepared during the preparation of this document, is not yet
available. That being said, the project would be consistent with the land use and zoning designations for
the site, and, therefore, should be within current and updated General Plan projections of future
employees.
Plan Bay Area 2050 is the current regional long-range plan charting the course for the future of the nine -
county San Francisco Bay Area. Plan Bay Area 2050 focuses on four key issues — the economy, the
environment, housing, and transportation. Plan Bay Area 2050 estimates a total addition of 1,403,000
total jobs to the Bay Area between 2015 and 2050.1 The project's addition of 555 employees would
increase jobs in the City and region incrementally. Compared to the total jobs projection for the entire
Bay Area, the addition of 555 jobs would not be substantial. Based on consistency with land use and
zoning designations of the site, project implementation would be within the expected growth of City
employment and projected employment growth of the Bay Area and the impact with respect to indirect
population growth would be less than significant.
The project will not include physical improvements that would induce growth beyond what is otherwise
planned. Proposed project improvements are limited to the project site or contribution to already -
planned improvements such as for the vicinity sewer line and area transit and bicycle facilities.
1 Metropolitan Transportation Commission and Association of Bay Area Governments, adopted October 21, 2021, Plan Bay Area
2050, Table 6-4. Available at: https://www.planbayarea.org/finalplan2050.
Page 6-4 101 Gull Drive Project Draft EIR
Alternatives
Introduction
CEQA Guidelines require an analysis of a reasonable range of alternatives for any project subject to an
EIR. The purpose of the alternatives analysis is to provide decision -makers and the public with a
discussion of alternatives to the project or its location that are capable of avoiding or substantially
lessening any significant effects of the project, even if these alternatives would impede to some degree
the attainment of the project objectives, or would be more costly. Evaluation of alternatives should
present the proposed action and all the alternatives in comparative form, to define the issues and
provide a clear basis for choice among the alternatives.
CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to
substantially lessen or avoid significant environmental impacts that would otherwise occur. Where a
lead agency has determined that even after adoption of all feasible mitigation measures, a project as
proposed would still result in significant environmental effects that cannot be substantially lessened or
avoided, the agency must first determine whether any alternatives are both environmentally superior
and feasible. CEQA provides the following guidelines for discussing project alternatives:
• An EIR need not consider every conceivable alternative to a project. Rather, it must consider a
reasonable range of potentially feasible alternatives that will foster informed decision-making
and public participation (§15126.6(a)).
• An EIR is not required to consider alternatives which are infeasible (§15126.6(a)).
• The discussion of alternatives shall focus on alternatives to the project or its location that are
capable of avoiding or substantially lessening any significant effects of the project (§15126.6(b)).
• The range of potential alternatives to the proposed project shall include those that could
feasibly accomplish most of the basic objectives of the project and could avoid or substantially
lessen one or more of the significant effects (§15126.6(c)).
• The EIR shall include sufficient information about each alternative to allow meaningful
evaluation, analysis and comparison with the proposed project (§15126.6(d)).
Project Objectives
CEQA requires the analysis of alternatives that would feasibly attain "most of the basic objectives of the
project but would avoid or substantially lessen any of the significant effects of the project" (15126.6 (a)).
Therefore, the stated objectives can be used as a metric against which an alternative can be measured
when determining overall feasibility. Additionally, CEQA requires the evaluation of a proposed project
101 Gull Drive Project Draft EIR PAGE 7-1
Chapter 7: Alternatives
to address only impacts to the physical environment; economic and social effects can be analyzed only
as one link in a chain of cause and effect from a proposed decision (e.g., physical changes caused, in
turn, by economic and social changes) (15131). However, economic viability can be considered when
determining the feasibility of a project alternative.
The following objectives have been identified for the project. Alternatives are evaluated in part based on
their ability to meet these objectives.
1. Allow for development and productive use of a currently vacant lot.
2. Construct a flexible facility that will allow for office/research & development uses that will create
quality jobs for South San Francisco residents.
3. Build an economically viable project that will enhance property values in the City's East of 101 area
and be consistent with the goals of the South San Francisco General Plan and Zoning Ordinances.
Summary of Project Impacts
Significant and Unavoidable Impacts
Based on the analysis presented in this EIR, the project would result in the following environmental
impact that would be considered significant and unavoidable:
Vehicles Miles Traveled Impact (TR -2): The vehicle miles traveled per employee exceeds the City's
adopted threshold of 15 percent below the regional average under existing and future conditions. Even
with contribution toward first- and last -mile strategies to increase use of alternate modes of travel
(Mitigation Measure TR -2), this impact would remain significant and unavoidable.
Note that this impact is not unique to this project. Because the estimated vehicle miles traveled for this
project is based on averages for the entire East of 101 area, most office/R&D projects in this area incur a
significant and unavoidable impact with respect to vehicle miles traveled unless they are located within
one half mile of the Caltrain station.
Potentially Significant Impacts and Mitigation Measures
Potentially significant impacts are largely limited to construction -period disturbance, including impacts
and mitigation related to construction period dust and emissions (Mitigation Measure Air -1); potential
disturbance of unknown archaeological, paleontological, or tribal cultural resources (Cul -1, Cul -2, Cul -3);
and appropriate construction given site characteristics in a seismically -active region (Geo -1).
Additionally, the project would contribute toward area sewer line upgrades (Util-1).
The project would be required to adhere to remediation measures in the Amended Site Closure Plan and
Post -Closure Maintenance Plan (PCMP) to address hazardous materials concerns at the site including
appropriate handling and capping of metals -impacted site soils and vapor barriers if necessary to
address methane gas migration from the nearby landfill (Haz-2).
Page 7-2 101 Gull Drive Project Draft EIR
Chapter 7: Alternatives
The impacts listed in this subsection would be reduced to less than significant levels through
implementation of the identified mitigation measures. All other impacts would be less than significant
without the need for mitigation.
A comparison of the impacts of the alternatives to the impacts of the project is included in Table 7.1 at
the end of this chapter.
Alternatives Analysis
The alternatives analysis is presented as a comparative analysis to the proposed project. A project may
have the potential to generate significant impacts, but changes to certain features may also afford the
opportunity to avoid or reduce such impacts. The following alternatives analysis compares the potential
significant environmental impacts of the alternatives with those of the proposed project. This analysis
focuses on potentially significant impacts with other topics grouped together.
Selection of Alternatives
The three alternatives analyzed in this EIR are listed below. These alternatives are intended to meet the
CEQA requirements for the EIR to describe the no project alternative as well as a range of reasonable
alternatives to the project that would feasibly attain most of the basic objectives of the project, but
would avoid or substantially lessen significant effects.
• No Project
• R&D Only
• Reduced Development
Each of the alternatives is more fully described below, and their potential environmental effects are
compared to those of the project. As permitted by CEQA (CEQA Guidelines Section 15126.6[d]), the
effects of the alternatives are discussed in less detail than the impact discussions of the project.
However, the alternatives analysis is conducted at a sufficient level of detail to provide the public, other
public agencies, and City decision -makers adequate information to evaluate the alternatives as
compared to the project. For each of the alternatives, the significance of each impact is compared to
applicable thresholds. These significance conclusions assume implementation of those same regulatory
requirements and mitigation measures as applied to the project (if necessary).
Alternatives Resected From Further Consideration
Section 15126.6(c) of the CEQA Guidelines requires an EIR to identify any alternatives that were
considered by the lead agency but were rejected as infeasible during the scoping process and briefly
explain the reasons underlying the lead agency's determination.
No Project — Allowable Site Development
The CEQA Guidelines state that, "where failure to proceed with the project will not result in
preservation of existing environmental conditions, the analysis should identify the practical result of the
project's non -approval" (15126.6(e)(3)(B)). The project site is currently vacant, but other than project
approvals, there is nothing otherwise preventing development of this vacant site according to existing
101 Gull Drive Project Draft EIR Page 7-3
Chapter 7: Alternatives
rules and regulations. It can therefore be assumed that if this project did not proceed, the site would not
be "preserved" as a vacant site, but rather another development proposal would likely be brought forth
at this location. As development consistent with the existing General Plan land use designation and
underlying zoning at the site, the proposed project itself represents a project that could be proposed at
the site under such a "no project" condition. Therefore, since the proposed project already represents
allowable site development, an alternative to represent allowable site development would not need to
be different than the proposed project.
For these reasons, a "no project" alternative that looks at allowable site development was eliminated
from further consideration in this EIR.
Alternative Site Location
In considering the range of alternatives to be analyzed in an EIR, the CEQA Guidelines state that an
alternative site location should be considered when, "...any of the significant effects of the project would
be avoided or substantially lessened by putting the project in another location" (15126.6(f)(2)(A)).
The current proposal is specific to the project site and consistent with the land use designation and
zoning for the site. While the applicant may own other sites suitable for office/R&D development, the
development of one site does not preclude them from proposing development on any other sites. If this
developer did not propose this project at this site at this time, it could be proposed in the same or
similar details at any later date. Therefore, because the proposed type of development is not unique
such that consideration of development on a different site would mean it was no longer considered at
this site, consideration of an alternative site location would not effectively avoid or substantially lessen
significant effects of the project and therefore, an off-site alternative was determined not to provide a
useful discussion for this analysis.
For these reasons, an alternative site location was eliminated from further consideration in this EIR.
Incorporation of Residential Uses
An alternative that would incorporate residential uses at the project site either as a wholly -residential
project or a mixed-use project with a residential component was considered. A residential alternative
could help address regional housing shortages and would have the potential to reduce the average HBW
VMT per employee by locating residential uses in an area predominantly occupied by employment uses,
providing more opportunities for employees in the East of 101 area to live closer to their place of work.
The project site is identified as Business Technology Park in the General Plan and is zoned Business and
Technology Park under the City's zoning ordinance. Neither of these designations permit residential
uses, nor would residential uses be consistent with existing land uses in the vicinity of the project site
and potentially result in conflicts by introducing emissions and noise sensitive receptors to a commercial
area. Residential development at this site would not be consistent with current General Plan direction
and policies to preserve land East of 101 for employment uses. As part of the City's Shape SSF 2040
General Plan update process currently underway, the City is considering residential uses in portions of
the East of 101 area, potentially including high-density mixed-use residential uses in areas adjacent to
and within 0.5 miles to the Caltrain station. The areas that are under consideration for residential uses
are within 0.5 mile of the Caltrain station, which does not include the project site. The City does not
anticipate that the Shape SSF 2040 General Plan will consider residential uses for the project site.
Furthermore, a residential alternative would be inconsistent with virtually all of the project objectives.
Page 7-4 101 Gull Drive Project Draft EIR
Chapter 7: Alternatives
Therefore, this alternative was rejected based on its infeasibility and inability to meet the basic project
objectives.
Other Alternatives Considerations
Obviously, not every possible alternative to the project can be fully evaluated. Alternatives A through C
satisfy the requirement to consider and discuss "a range of reasonable alternatives to the project"
pursuant to CEQA Guidelines section 15126.6. As discussed in this chapter, these alternatives were
chosen as reasonable alternatives at this site and no additional alternatives were identified that would
substantially contribute to a meaningful evaluation, analysis, and comparison of the project to possible
alternatives.
"No Project" Alternative
Alternative Description
CEQA Guidelines Section 15126.6(e) requires that a "no project" alternative be evaluated, along with its
impacts. Alternative A is a "no project" alternative. It assumes the proposed project is not approved and
the site remains vacant.
While the CEQA Guidelines allow the no project alternative to assess development under the
continuation of the existing plan, policy, or operation into the future, the proposed project already
represents development per existing plans and policies. Therefore, Alternative A presumes the site
would remain in its current state.
Impact Comparison
Impact Summary
Under the "No Project" Alternative, the project site would remain as it is today with no substantial
construction activities and no development at the site. Therefore, the potential for all of the less than
significant impacts and need for mitigation would be avoided.
While continuance of the vacant state would not be considered an impact under CEQA, the "No Project"
Alternative also would not develop the site consistent with the General Plan land use designation and
zoning.
Hazards and Hazardous Materials
The "No Project" Alternative represents no substantial construction activities or operations at the site
and, therefore, no potential for hazards and hazardous materials impacts.
Transportation
The "No Project" Alternative represents no construction or operations at the site and, therefore, no
potential for transportation impacts.
101 Gull Drive Project Draft EIR Page 7-5
Chapter 7: Alternatives
Other Topics
Because the assessed "No Project" alternative would not change the conditions at the site or involve
construction activities, there would be no actions that could be considered to result in environmental
impacts under CEQA.
Ability to Accomplish Project Objectives and Feasibility
The "No Project" Alternative would have the following ability to meet project objectives:
1. The "No Project" Alternative would not meet the objective to allow for development and productive
use of a currently vacant lot. This alternative would not result in development of the site.
2. The "No Project" Alternative would not meet the objective to construct a flexible facility that will
allow for office/research & development uses that will create quality jobs for South San Francisco
residents. This alternative would not result in any development of the site.
3. The "No Project" Alternative would not meet the objective to build an economically viable project
that will enhance property values in the City's East of 101 area and be consistent with the goals of
the South San Francisco General Plan and Zoning Ordinances. This alternative would not result in
any development of the site.
The "No Project" Alternative would not meet any of the Project Objectives.
This alternative represents the possibility that no project is approved on this site at this time. It would
not preclude application for development of the site at a later point.
"R&D Only" Alternative
Alternative Description
This alternative would have generally the same building and parking garage structures as the proposed
project on the same site and footprint. The only difference is that the use would be constrained to R&D
uses. Office uses (except as part of an R&D use) would not be allowed.
The proposed project would allow for any mix of office and R&D uses to be determined through
identification of future tenants. Office uses have generally more employees while R&D uses have more
daily trips reflecting more supporting services. Because the one significant and unavoidable impact of
the project is related to the vehicle miles traveled per employee, a project with a lower number of
employees would have a marginally lower impact in this respect.
R&D uses usually have employee densities of 300 to 350 square feet of building space per employee,
whereas strictly office uses can have employment densities of 150 to 250 square feet per employee.
Therefore, a 100% R&D project would have approximately 40% less employees than a 100% office
project. While the project as proposed could be any mix of R&D and office uses and the analysis in the
Initial Study and EIR made applicable assumptions for reasonable worst-case assessment of impacts, this
alternative is intended to present the difference if the project were constrained to R&D uses only.
Page 7-6 101 Gull Drive Project Draft EIR
Chapter 7: Alternatives
Impact Comparison
Impact Summary
Impacts under the "R&D Only" Alternative would be the same or marginally reduced compared to the
project. No impacts would be avoided or substantially reduced by the "R&D Only" Alternative.
Because the "R&D Only" Alternative would result in fewer employees at the site than the proposed
project, there would be a marginal reduction in the project's one significant and unavoidable impact.
Because the threshold is based on the vehicle miles traveled per employee and not on the number of
employees, and the per -employee rate would remain the same for a project of this type at this site, the
impact would remain above threshold levels and significant and unavoidable. That being said, adding
fewer employees at higher -than -threshold -level vehicle miles traveled per employee rates would
contribute less to region -wide rates of vehicle miles traveled above target levels. This could be
considered a marginal reduction in this impact with no change in significance or the required mitigation.
With the same structure and construction required, all construction -related impacts would remain the
same under the "R&D Only" Alternative, as would the need to contribute to area -wide sewer
improvements and the same mitigation would be required.
Hazards and Hazardous Materials
The "R&D Only" Alternative would require generally the same site construction as under the proposed
project and would also be required to adhere to remediation measures in the Amended Site Closure
Plan and Post -Closure Maintenance Plan (PCMP) to address hazardous materials concerns at the site.
As under the proposed project, compliance with applicable regulations and procedures related to
routine use of hazardous materials would result in less than significant impacts related to routine
handling of such materials for an R&D use.
There would be no change to hazards and hazardous materials impacts under the "R&D Only"
Alternative.
Transportation
The "R&D Only" Alternative would result in fewer employees at the site than the proposed project,
which could be any mix of office and R&D uses. The project's one significant and unavoidable impact
was that the vehicle miles traveled per employee exceeds threshold levels. The vehicle miles traveled
per employee is mostly based on location for office or R&D uses and, therefore, would not change given
a change in the mix of those uses at the same site. The impact with respect to vehicle miles traveled for
the "R&D Only" Alternative would therefore remain above threshold levels and significant and
unavoidable. That being said, adding fewer employees at higher -than -threshold -level vehicle miles
traveled per employee rates would contribute less to overall exceedances of vehicle miles traveled
targets in the region. The impact of the "R&D Only" project would therefore be marginally reduced
compared to the project.
Other Topics
Because site construction would be generally the same as under the proposed project, there would be
no substantial change in construction -related impacts and mitigation measures including for
101 Gull Drive Project Draft EIR Page 7-7
Chapter 7: Alternatives
construction emissions and dust; potential disturbance of unknown archaeological, paleontological, or
tribal cultural resources; and appropriate construction given site characteristics in a seismically -active
region. Contribution toward area sewer line upgrades would also still be required under the "R&D Only"
Alternative. There would be no substantial change to other impacts.
Ability to Accomplish Project Objectives and Feasibility
The "R&D Only" Alternative would have the following ability to meet project objectives:
1. The "R&D Only" Alternative would meet to the same degree the objective to allow for development
and productive use of a currently vacant lot.
2. The "R&D Only" Alternative would meet to a lesser degree the objective to construct a flexible
facility that will allow for office/research & development uses that will create quality jobs for South
San Francisco residents. This alternative would result in an R&D use to create quality jobs in South
San Francisco but would not provide flexibly to allow office use.
3. The "R&D Only" Alternative would meet to the same degree the objective to build an economically
viable project that will enhance property values in the City's East of 101 area and be consistent with
the goals of the South San Francisco General Plan and Zoning Ordinances.
The "R&D Only" Alternative would meet two of the three Project Objectives to the same degree as the
project. The third objective would be met to a lesser degree as the "R&D Only" Alternative would not
allow for flexible use of the development.
"Reduced Development" Alternative
Alternative Description
This alternative represents a reduced intensity alternative to demonstrate how impacts may be different
if the project were smaller. An approximately 30% reduction in both building space and parking area was
chosen, which would be consistent with a building about two floors lower (five stories), though it would
likely also include a somewhat reduced footprint. The building square footage would be approximately
133,300. As with the project, any mix of office and/or R&D would be allowed.
Impact Comparison
Impact Summary
Impacts under the "Reduced Development" Alternative would be the same or marginally reduced
compared to the project. No impacts would be avoided or substantially reduced by the "Reduced
Development" Alternative.
Because the "Reduced Development" Alternative would result in fewer employees at the site than the
proposed project, there would be a marginal reduction in the project's one significant and unavoidable
impact. Because the threshold is based on the vehicle miles traveled per employee and not on the
number of employees, and the per -employee rate would remain the same for a project of this type at
this site, the impact would remain above threshold levels and significant and unavoidable. That being
said, adding fewer employees at higher -than -threshold -level vehicle miles traveled per employee rates
Page 7-8 101 Gull Drive Project Draft EIR
Chapter 7: Alternatives
would contribute less to region -wide rates of vehicle miles traveled above target levels. This could be
considered a marginal reduction in this impact with no change in significance or the required mitigation.
While the building construction activities would be reduced in scope under the "Reduced Development"
Alternative with potentially even a smaller building footprint, the entire site would still be developed
(open space/landscaping and circulation elements would fill areas not developed with structures) and
require site preparation generally the same as under the proposed project. Site -disturbance related
impacts and mitigation measures including for construction dust; potential disturbance of unknown
archaeological, paleontological, or tribal cultural resources; and also the need for appropriate
construction given site characteristics in a seismically -active region would not change under the
"Reduced Development" Alternative.
Building construction itself would be reduced. However, impacts related to building construction were
already below significance levels so would remain less than significant under the project or the
"Reduced Development" Alternative.
While a reduced project would contribute less demand to the sewer line in need of an upgrade, this is
an identified area -wide improvement and as such, the need for the improvement would not be affected
by reduction in the development intensity at this site and the impact and mitigation would remain
substantially the same under the "Reduced Development" Alternative.
Hazards and Hazardous Materials
While the construction activities would be reduced in scope under the "Reduced Development"
Alternative with potentially even a smaller building footprint, the entire site would still be developed
(open space/landscaping and circulation elements would fill areas not developed with structures) and
require site preparation generally the same as under the proposed project. As under the project, the
"Reduced Development" Alternative would be required to adhere to remediation measures in the
Amended Site Closure Plan and Post -Closure Maintenance Plan (PCMP) to address hazardous materials
concerns at the site and would be required to comply with applicable regulations and procedures
related to routine use of hazardous materials.
There would be no substantial change to hazards and hazardous materials impacts under the "Reduced
Development" Alternative.
Transportation
The "Reduced Development" Alternative would result in approximately 30% fewer employees at the site
than the proposed project. The project's one significant and unavoidable impact was that the vehicle
miles traveled per employee exceeds threshold levels. The vehicle miles traveled per employee is mostly
based on location for office or R&D uses and, therefore, would not change given reduced project size at
the same site. The impact with respect to vehicle miles traveled for the "Reduced Development"
Alternative would therefore remain above threshold levels and significant and unavoidable. That being
said, adding fewer employees at higher -than -threshold -level vehicle miles traveled per employee rates
would contribute less to overall exceedances of vehicle miles traveled targets in the region. The impact
of the "Reduced Development" project would therefore be marginally reduced compared to the project.
101 Gull Drive Project Draft EIR Page 7-9
Chapter 7: Alternatives
Other Topics
While building construction would be reduced under the "Reduced Development" Alternative, the
entire site would still be disturbed for development. There would be no substantial change in site -
disturbance -related impacts and mitigation measures including for construction dust; potential
disturbance of unknown archaeological, paleontological, or tribal cultural resources; and also the need
for appropriate construction given site characteristics in a seismically -active region.
With a smaller building, there would be a reduction in construction -related noise, traffic, and energy
use. Compliance with applicable regulations and procedures would result in project impacts below
threshold levels in these topics for the project and, therefore, reductions in impacts under the "Reduced
Project" Alternative would be marginal. Less building construction activities would also result in less
construction -related emissions, which were already below threshold levels and further lowered by
Mitigation Measure Air -1. This would again be a marginal reduction in the impact without changing
significance conclusions.
Similarly, with fewer employees and a smaller building at the site, there would be marginal reductions in
operational -related air quality and greenhouse gas emissions, hazardous materials handling, noise,
population, demand for public services and utility and energy use. Other than sewer capacity discussed
below, compliance with applicable regulations and procedures would result in project impacts below
threshold levels in these topics for the project and, therefore, reductions in impacts under the "Reduced
Project" Alternative would be marginal.
Contribution toward area sewer line upgrades would also still be required for all area projects including
the "Reduced Development" Alternative. While a reduced project would contribute less demand to the
sewer line, this is an identified area -wide improvement and as such, the need for the improvement
would not be affected by reduction in the development intensity at this site.
There would be no substantial change to other impacts.
Ability to Accomplish Project Objectives and Feasibility
The "Reduced Development" Alternative would have the following ability to meet project objectives:
The "Reduced Development" Alternative would meet to the same degree the objective to allow for
development and productive use of a currently vacant lot.
2. The "Reduced Development" Alternative would meet to a lesser degree the objective to construct a
flexible facility that will allow for office/research & development uses that will create quality jobs for
South San Francisco residents. This alternative would result in a flexible office/R&D use to create
quality jobs in South San Francisco but would be a smaller project with relatively fewer jobs created.
3. The "Reduced Development" Alternative would meet to the same degree the objective to build an
economically viable project that will enhance property values in the City's East of 101 area and be
consistent with the goals of the South San Francisco General Plan and Zoning Ordinances.
The "Reduced Development" Alternative would meet two of the three Project Objectives to the same
degree as the project. The third objective would be met to a lesser degree as the "Reduced
Development" Alternative would result in a smaller project with fewer jobs.
Page 7-10 101 Gull Drive Project Draft EIR
Chapter 7: Alternatives
Environmentally Superior Alternative
CEQA requires the identification of the environmentally superior alternative in an EIR. Where a no
project alternative has been identified as the environmentally superior alternative, CEQA requires the
EIR to identify another alternative that would be considered environmentally superior in the absence of
the no project alternative.
Table 7.1 provides a summary comparison of the impacts of each of these alternatives relative to those
of the project. This table focuses on potentially significant impacts with other topics grouped into
construction -related and operational -related.
Because the differences between the project and the alternatives are often marginal only — meaning
that small changes could occur in the magnitude of an impact without changing the significance
conclusion - Table 7.1 also indicated when there are marginal differences (with an arrow symbol).
Table 7.1: Summary of Impacts and Relative Comparison of Alternatives
"Reduced
"No Proiect"
"R&D OnIV"
Development"
Environmental Topic
Project
Alternative
Alternative
Alternative
Transportation (TR -2)
SU with MM
NI
SU with MM 4,
SU with MM J,
Hazardous Materials (Haz-2)
LTS with MM
NI
LTS with MM
LTS with MM
Construction Emissions (Air -
1)
LTS with MM
NI
LTS with MM
LTS with MM �L
Cultural/Tribal Cultural
LTS with MM
NI
LTS with MM
LTS with MM
(Cul -1, Cul -2, Cul -3)
Geology and Soils (Geo -1)
LTS with MM
NI
LTS with MM
LTS with MM
Utilities (Util-1)
LTS with MM
NI
LTS with MM
LTS with MM
Other Topics
(construction -related)
LTS
NI
LTS
LTS y
Other Topics
(operational -related)
LTS
NI
LTS y
LTS y
NI = no impact
LTS = less than significant
SU = significant and unavoidable
with MM = with implementation of mitigation measures
4, = marginal reduction in impacts of the same significance level
Environmentally Superior Alternative
In addition to the discussion and comparison of impacts of the proposed project and the alternatives,
Section 15126.6 of the CEQA Guidelines requires that an "environmentally superior" alternative be
101 Gull Drive Project Draft EIR Page 7-11
Chapter 7: Alternatives
selected and the reasons for such a selection disclosed. In general, the environmentally superior
alternative is the alternative that would be expected to generate the least amount of significant impacts.
Table 7.1 above provides a summary comparison of the environmental impacts of the alternatives
compared to the proposed project.
The "No Project' Alternative would not result in any substantial changes to the site and therefore, has
the lowest possible impacts in every parameter. The "No Project" Alternative would be the
environmentally superior alternative. However, the "No Project' Alternative does not meet any of the
project objectives.
The CEQA Guidelines also require that "if the environmentally superior alternative is the 'no project'
alternative, the EIR shall also identify an environmentally superior alternative among the other
alternatives" (CEQA Guidelines Section 15126.6(e)(2)). The CEQA Guidelines require a consideration of
whether alternatives "avoid or substantially lessen" significant impacts of the proposed project. In
general, the environmentally superior alternative minimizes adverse impacts to the environment, while
still achieving the basic project objectives.
Neither the "R&D Only" Alternative nor the "Reduced Development" Alternative would avoid any
significant impacts of the project or reduce the significance level of any impacts. With fewer resultant
employees at the site, both these alternatives would marginally reduce the significant and unavoidable
project impact related to vehicle miles traveled while the impact would remain significant and
unavoidable. Both these alternatives would be substantially similar though marginally environmentally
superior to the proposed project and would meet project objectives though to a lesser degree than the
project.
Because the "Reduced Development" Alternative would marginally reduce construction -related impacts
as well as operational -related impacts (without changing the need for mitigation or significance
conclusions compared to the project), the "Reduced Development" Alternative would be the next most
environmentally superior after the "No Project" Alternative. As noted above, differences between the
impacts under this alternative and the proposed project would be marginal only.
Page 7-12 101 Gull Drive Project Draft EIR
EIR Preparers and References
Lead Agency
Citv of South San Francisco
Department of Economic & Community Development, Planning Division
315 Maple Avenue
South San Francisco, CA 94080
Stephanie Skangos, Associate Planner
Tony Rozzi, Principal Planner
EIR Preparers
Lamphier-Gregory (Primary Report Preparers)
4100 Redwood Road, STE 20A - #601
Oakland, CA 94619
510-535-6690
Rebecca Auld, Vice President
Jenna Sunderlin, Planner
Fehr & Peers (Transportation)
332 Pine Street, 4th Floor
San Francisco, CA 94104-3222
Daniel Jacobson, Associate
Ashley Hong, Transportation Planner III
References
California Department of Forestry and Fire Protection, 2007, San Mateo County Fire Hazard Severity
Zones in SRA. Available at: https://osfm.fire.ca.gov/divisions/wildfire-planning-
engineering/wildland-hazards-building- codes/fire-hazard-severitv-zones-maps/
California Air Resources Board, January 2019, 2017 Scoping Plan -Identified VMT Reductions and
Relationship to State Climate Goals. Available
at: https://ww2.arb.ca.gov/sites/default/files/2019-01/2017 sp vmt reductions ianl9.pdf
California Department of Transportation (Caltrans), July 2020, Interim Land Development and
Intergovernmental Review (LDIGR) Safety Review Practitcioners Guidance. Available
at: https://dot.ca.gov/-/media/dot-media/programs/transportation-
planning/documents/sb-743/2020-07-01-interim-Idigr-safety-guidance-allv.pdf
101 Gull Drive Project Draft EIR Page 8-1
Chapter 8: EIR Preparers and References
City/County Association of Governments of San Mateo County, November 2012, Comprehensive
Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport,
including Exhibit IV -14. Available at: http://ccag.ca.gov/wp-
content/uploads/2014/10/Consolidated CCAG ALUCP November-20121.pdf
City of South San Francisco, accessed November 2021, Active South City Bicycle and Pedestrian
Master Plan. Available: https://activesouthcity.com/
City of South San Francisco, 2011, South San Francisco Pedestrian Master Plan. Available
at: https://www.ssf.net/home/showpublisheddocument/1304/636334624142770000
City of South San Francisco, prepared by Alta Planning + Design, February 9, 2011, Bicycle Master
Plan. Available
at: https://www.ssf.net/home/showpublisheddocument/760/636319456492130000
Langan Engineering and Environmental, December 22, 2020, Phase I Environmental Site Assessment.
Metropolitan Transportation Commission and Association of Bay Area Governments, adopted
October 21, 2021, Plan Bay Area 2050. Available
at: https://www.planbayarea.org/finalplan205O.
State of California Governor's Office of Planning and Research, December 2018, Technical Advisory
on Evaluating Transportation Impacts in CEQA. Available
at: https://opr.ca.gov/docs/20190122-743 Technical Advisory.pdf
Page 8-2 101 Gull Drive Project Draft EIR