HomeMy WebLinkAboutDEIR Appendix A - NOP and Scoping CommentsCity of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Draft Program EIR
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Appendix A:
NOP and Scoping Comments
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Draft Program EIR
FirstCarbon Solutions
A.1 - Notice of Preparation
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City of South San Francisco
Notice of Preparation of a Program Environmental Impact Report
and Notice of Public Scoping Meeting
Proposed South San Francisco General Plan Update, Zoning Code Amendments, and
Climate Action Plan
Date: January 13, 2022
To: State Clearinghouse and Interested Public Agencies, Parties, and Organizations
From: Billy Gross, Principal Planner, City of South San Francisco
Subject: Notice of Preparation of a Program Environmental Impact Report for the Proposed
South San Francisco General Plan Update, Zoning Code Amendments, and Climate
Action Plan and Notice of Public Scoping Meeting on Monday, January 31, 2022 at
1:00 p.m.
NOTICE IS HEREBY GIVEN THAT the City of South San Francisco (Lead Agency and/or City) will
prepare a Program Environmental Impact Report (Program EIR) for the proposed South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan (proposed project). The
Program EIR will address the potential physical and environmental effects of the proposed project
for each of the environmental topics outlined in the California Environmental Quality Act (CEQA).
The City will use the Program EIR when considering approval of the proposed project. Pursuant to
CEQA Guidelines Section 15082, the Project Description, location, and potential environmental
effects of the proposed project are described in the attached materials.
The original Notice of Preparation (NOP) of a Program EIR for the General Plan Update was circulated
from February 3, 2021 to March 22, 2021. This revised NOP is being circulated from January 14, 2022
to February 28, 2022 to provide the public with an opportunity to comment on changes that were
made to the Project Description related to net new housing units and net new employment
opportunities anticipated under the General Plan Update. Comments received on the NOP circulated
from February 3, 2021 to March 22, 2021 as well as comments received on the revised NOP being
circulated from January 14, 2022 to February 28, 2022 will be considered part of the administrative
record.
45-DAY NOP COMMENT PERIOD: The City is soliciting comments from public agencies,
organizations, and members of the public regarding the scope and content of the Program EIR, and
the environmental issues and alternatives to be addressed in the Program EIR. In accordance with
the time limits established by CEQA, the NOP public review period will begin on January 14, 2022,
and end on February 28, 2022. Please provide your written/typed comments (including name,
affiliation, telephone number, and contact information) to Billy Gross via email at [email protected]
or to the address shown below by 5:00 p.m., Monday, February 28, 2022. If you wish to be placed
on the notification list for this proposed project, or need additional information, please contact:
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Notice of Preparation City of South San Francisco
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Billy Gross, Principal Planner
City of South San Francisco
Planning Division
315 Maple Avenue
South San Francisco, CA 94080
Phone: 650.877.8535
Email: [email protected]
PUBLIC SCOPING MEETING: The City of South San Francisco will hold a Public Scoping Meeting to:
(1) inform the public and interested agencies about the proposed project; and (2) solicit public
comment on the scope of the environmental issues to be addressed in the Program EIR, as well as
the range of alternatives to be evaluated. The meeting will be held on Monday, January 31, 2022,
starting at 1:00 p.m. via a Zoom meeting.
Join Zoom Meeting
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Meeting ID: 833 4157 9560
Passcode: 654247
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South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco Notice of Preparation
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SOUTH SAN FRANCISCO GENERAL PLAN UPDATE, ZONING CODE
AMENDMENTS, AND CLIMATE ACTION PLAN
Project Location
The project site is located in the City of South San Francisco, in San Mateo County, California (Exhibit 1).
The City is located in a basin bounded by the San Bruno Mountains to the north, the Pacific Coast
Ranges to the west, and the San Francisco Bay to the east. The City is bordered by the City of Brisbane
to the north, Daly City, City of Pacifica, and the Town of Colma to the west, and the City of San Bruno to
the south (Exhibit 2). San Francisco International Airport is located immediately to the south but falls
within City and County of San Francisco’s jurisdictional boundaries.
Existing Conditions
The City encompasses 31 square miles, approximately 5,000 acres, and is primarily built out with
only about 3.4 percent of the land classified as vacant. Colma Creek flows in a west–east direction
through the City from its origin in the San Bruno Mountains to its terminus in the San Francisco Bay.
Regional access to the City is via highways and major roadways, including Interstate 280 (I-280), U.S.
Highway 101 (US-101), and El Camino Real. In addition, the South San Francisco Bay Area Rapid
Transit (BART) Station is also a gateway into the City, with approximately 842 passengers entering
South San Francisco via this station on an average weekday.1 Additionally, 452 passengers enter
South San Francisco from Caltrain on an average week day.2 SamTrans, a bus service that operates
throughout San Mateo County and into parts of San Francisco and Palo Alto, has three bus lines that
run through South San Francisco and serves approximately 24,077 passengers per day.3,4 The San
Francisco Bay Ferry also provides public transit service to and from the City and other locations
around the San Francisco Bay to approximately 6,027 passengers per day.5,6
1.1.1 - Unincorporated Areas
The City has two unincorporated islands within its Sphere of Influence (SOI). One island is bound by
I-280 on the west, Westborough Boulevard to the north, Orange Avenue roughly to the east, and
Ponderosa Road to the south. Most of this area is owned by the City and County of San Francisco
and is the site of the California Golf Club of San Francisco. Ponderosa Elementary School is also
situated in this unincorporated island on land owned by the South San Francisco Unified School
District (SSFUSD). The other island is roughly bound by Conmur Street to the west, Country Club
Drive to the north, Alida Way to the east, and Northwood Drive to the south, and consists primarily
1 Bay Area Rapid Transit (BART). 2021. Monthly Ridership Reports (October 1, November 1, December 1). Website: https://www.bart.gov/about/reports/ridership. Accessed January 3, 2022. 2 Caltrain. 2019. Caltrain 2019 Annual Passenger Count Key Findings. Website:
https://www.caltrain.com/Assets/Stats+and+Reports/2019+Annual+Key+Findings+Report.pdf. Accessed January 3, 2022.
3 SamTrans. 2022. Ridership. Website: https://www.samtrans.com/about/Bus_Operations_Information/Ridership.html. Accessed
January 3, 2022. 4 8,788,180 riders divided by 365 days per year. 5 San Francisco Ferry Riders. 2022. Monthly Operating Statistics Report. Website:
https://sanfranciscobayferry.com/sites/sfbf/files/opsreport/April2021.pdf. Accessed January 3, 2022.
6 2.2 million riders divided by 365 days per year.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Notice of Preparation City of South San Francisco
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of single-family residential uses and religious facilities on larger lots. Both islands are part of
unincorporated San Mateo County and within the City’s SOI.
1.1.2 - Existing Land Use
Existing land use refers to the way land is currently being used in the City, or in other words, land
uses that are currently (as of 2022) “on the ground.” Existing land uses are mapped in Exhibit 3 and
Table 1 shows the approximate acreage of each type of land use in the City. As shown in Exhibit 3
and Table 1, the most prevalent land use in the City is Residential (occupying 39.8 percent of land
area), followed by Industrial/ Research and Development (29.5 percent); Parks, Open Space, and
Common Greens (9.9 percent); and Public/Institutional (6.6 percent). There are only about 150 acres
of vacant land (3.4 percent of the City).
Table 1: Existing Land Use
Land Use Type Acres Area (%)
Within City of South San Francisco 4,226.1 94.8
Residential 1,773.5 39.8
Single-family Residential 1,506.5 33.8
Duplex/Triplex/Quadplex 66.5 1.5
Multi-family 183.4 4.1
Mobile Home Park 17.1 0.4
Commercial 250.5 5.6
Hotel 57.0 1.3
General Retail/Service 110.9 2.5
Auto Retail 43.2 1.0
Food Retail 32.9 0.7
Mixed Use (Commercial/Residential) 6.5 0.1
Industrial/Research and Development 1,313.7 29.5
Office 190.0 4.3
Biotech/Research and Development 322.1 7.2
Warehouse 639.5 14.4
Manufacturing/Processing 162.1 3.6
Parks, Open Space, and Common Greens 442.4 9.9
Public and Institutional 292.9 6.6
Vacant 153.1 3.4
Within Sphere of Influence 230.0 5.2
Single-family residential 41.4 0.9
Golf Course 183.4 4.1
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco Notice of Preparation
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Land Use Type Acres Area (%)
Public and Institutional 4.7 0.1
Vacant 0.5 0.0
Grand Total 4,456.1 100.0
Notes:
1. Totals do not include utilities and transportation infrastructure.
2. Totals may not add due to rounding
Project Description
1.1.3 - Proposed Project
The proposed project consists of the South San Francisco General Plan Update, Zoning Code
Amendments, and Climate Action Plan. The General Plan Update is a forward-looking document that
will serve as the blueprint for the City’s vision through the year 2040. The goals, policies, and actions
in the proposed General Plan Update will serve as a compass for decision-makers and will shape
future plans and actions of the City. The City's comprehensive General Plan was initially prepared in
1999. The City’s Housing Element was certified in 2015 and is valid until 2023. The process of
updating the existing Housing Element is underway and is being conducted as part of this General
Plan Update. The proposed General Plan Update would replace the 1999 General Plan.
The Proposed Land Use Map for the General Plan Update is attached as Exhibit 4. The Proposed Land
Use Map depicting only the changes from the Existing Land Use Map is attached as Exhibit 5. The
General Plan Update anticipates approximately 17,531 net new housing units and approximately
80,944 net new employment opportunities by 2040. The Climate Action Plan includes a community-
wide inventory of greenhouse gas (GHG) emissions and identifies strategies and measures to reduce
GHG emissions generated by existing and future uses in the City to achieve State-mandated targets.
The State of California requires that the General Plan contain eight mandatory elements: Land Use,
Circulation, Housing, Conservation, Open Space, Noise, Safety, and Environmental Justice. The South
San Francisco General Plan Update will include all of the State-mandated elements and three
optional elements, as described below.
• Land Use and Community Design Element—This element provides a framework for the land
use designations and the standards for density, intensity, and design, in order to maximize
opportunities for residential infill development, encourage mixed-use residential, retail, and
office uses near Caltrain and BART stations, and maintain the Downtown as the symbolic
center of the City.
• Mobility (Circulation) Element—This element focuses on enhancing the City’s existing
circulation and transportation system and contains policies and actions to provide increased
access to mobility services, including transit, bike and pedestrian networks, access between
neighborhoods, and traffic safety.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Notice of Preparation City of South San Francisco
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• Housing Element— This element adopts a comprehensive, long-term plan to address the
housing needs of the City and provide suitable, decent, and affordable housing for residents,
as well as preserve and enhance existing residential areas. The 2015-2023 Housing Element
was adopted in April 2015. The process to update the existing Housing Element for the 2023-
2031 cycle is underway and will be completed as part of this General Plan Update and will
reflect the updated Regional Housing Needs Allocation (RHNA) numbers that were finalized
December 2021.7
• Open Space and Conservation Element—This element identifies policies and actions to
address the conservation, development, and use of natural resources, protect sensitive
cultural and historic resources, improve water quality and stormwater management, address
air quality, and enhance open space areas including Colma Creek and the shoreline.
• Noise Element—This element includes policies and actions to preserve the quality of life and
reduce potential noise exposure to persons living and working in the City. The noise element
also includes goals, policies, and actions to protect sensitive land uses and historic structures
from construction-related vibration.
• Safety Element—The element establishes a framework of proactive and coordinated
programs to protect against foreseeable natural and human-caused hazards. This element also
addresses potential hazards related to sea level rise and inland flooding, as well as considering
how climate change could affect and potentially exacerbate the impacts associated with other
hazards.
• Health and Environmental Justice Element—This element includes policies celebrating the
cultural diversity of South San Francisco, access to health care and food, social equity and
environmental justice concerns, and social services.
• Social Equity Element—This element addresses engaging all residents, analyzing, and
improving policies and programs. It focuses on being a leader across jurisdictions and
departments to incorporate equity considerations into policies and programs and engaging
residents in decisions that impact their lives.
• Sustainability and Climate Action Element—This element includes an integrated policy
framework for sustainability, greenhouse gas (GHG) mitigation, and carbon sequestration. This
includes goals and policies for reducing GHG emissions, such as carbon-free energy, decarbonized
buildings, zero waste, fossil-fuel free transportation, and carbon sequestration. Given the cross-
cutting nature of these issues, there will points of integration with other policy frameworks,
including Land Use, Safety, Conservation, and Social Equity, among others.
• Public Facilities and Parks Element—This element addresses the provision of public services
and facilities, libraries, parks, and recreational facilities and includes future infrastructure
planning.
7 Association of Bay Area Governments (ABAG). 2021. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area,
2023-2031. Website: Final_RHNA_Allocation_Report_2023-2031-approved_0.pdf. Accessed January 4, 2022.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco Notice of Preparation
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• Economic Development Element—This element provides a framework to promote business
diversification, create an innovation district, retain local businesses, promote early childhood
development, and provide jobs training.
The Vision and Guiding Principles for the General Plan Update were identified through a
collaborative effort between the City and its residents and are described below.
Revised Citywide Vision Statement
South San Francisco is a place where everyone can thrive. Its high quality of life, diverse and inclusive
community, livable neighborhoods and excellent services, culture of innovation, and environmental
leadership ensure all people have an equitable opportunity to reach their full potential.
Guiding Principles
• Affordable, safe, attractive, amenity-rich neighborhoods
• High-quality and accessible services, facilities, and amenities for residents at all stages of their
lives
• A safe, convenient, and accessible transportation network that is well-connected to the region
• A resilient community
• A prosperous downtown + local economy
1.2 - Environmental Impact Report
The City, as the Lead Agency under CEQA, will prepare a Program EIR for the proposed South San
Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan (proposed
project) in accordance with CEQA, implementing the CEQA Guidelines, relevant case law, and City
procedures. The General Plan Update is considered a “project” under CEQA and is therefore subject
to CEQA review. As a policy document, the General Plan provides guidance and sets standards for
several areas of mandatory environmental review for later “projects” that would be undertaken by
local government and the private sector.
The Program EIR will evaluate potential environmental impacts associated with adoption and
implementation of the proposed project. It will discuss how the proposed policies may affect the
environment, disclose potential impacts of the proposed project, propose mitigation measures to
avoid and/or reduce impacts deemed potentially significant, identify reasonable alternatives, and
compare the environmental impacts of the alternatives to the proposed project’s impacts. Pursuant
to Section 15063(a) of the CEQA Guidelines, no Initial Study will be prepared. The Program EIR will
evaluate the full range of environmental issues contemplated under CEQA and the CEQA Guidelines,
as described below:
• Aesthetics—This section will analyze potential impacts to aesthetics, including scenic vistas,
scenic resources, visual character and quality, and light and glare within the Planning Area.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Notice of Preparation City of South San Francisco
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• Air Quality—An air quality analysis will be prepared in accordance Bay Area Air Quality
Management District (BAAQMD) requirements. A discussion of the proposed project’s
contribution to regional air quality impacts will be included.
• Biological Resources—This section will address direct and indirect impacts to regulated
waterways and wetlands, sensitive habitats and mature native trees, sensitive plants and
wildlife, and wildlife movement corridors.
• Cultural Resources/Tribal Cultural Resources—The Program EIR will examine potential
adverse impacts the proposed project would have on historical resources (or eligible historical
resources), archaeological, and tribal cultural resources.
• Energy—This section will include a discussion of the potential energy consumption and/or
impacts from implementation of the proposed project, with an emphasis on avoiding or
reducing inefficient, wasteful, or unnecessary consumption of energy.
• Geology, Soils, and Seismicity—This section will analyze potential impacts related to geology,
soils, seismicity and paleontological resources from implementation of the proposed project.
• Greenhouse Gas Emissions—The Program EIR will analyze the proposed project’s contribution
to greenhouse gas emissions and potential impacts to climate change.
• Hazards and Hazardous Materials—This section will discuss potential exposure to hazardous
substances resulting from activities within the Planning Area.
• Hydrology and Water Quality—The Program EIR will analyze impacts of the proposed project
on drainage patterns and water quality within the Planning Area.
• Land Use and Planning—This section will summarize the City’s land use characteristics,
including the overall land use pattern, and determine the potential environmental effects of
the proposed project related to Land Use and Planning.
• Noise—This section will analyze short-term impacts to noise-sensitive receptors and long-
term noise exposure.
• Population, Housing, and Employment—This section will analyze potential impacts to
population, housing, and employment that could result from implementation of the proposed
project.
• Public Services and Recreation—The Program EIR will analyze impacts on public services,
including police, fire, and schools, as well as potential impacts on recreational and open space
resources, from implementation of the proposed project.
• Transportation—The Program EIR will analyze the proposed project’s impacts on the
circulation system, including Vehicle Miles Traveled (VMT) within the Planning Area, safe
routes to schools, and all modes of transit.
• Utilities and Service Systems—This section will analyze the potential impacts associated with
water supply, wastewater services, and other utilities and service systems.
• Wildfire—This section will analyze the potential impacts to wildfire risks, adopted emergency
and evacuation plans, infrastructure, and land and drainage stability.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco Notice of Preparation
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The Program EIR will evaluate potential growth-inducing impacts and cumulative impacts of the
proposed project, including the effects of other past, present, and reasonably foreseeable projects in
the vicinity (CEQA Guidelines §§ 15126.2, 15130).
As described above, the Program EIR will also identify and examine a range of reasonable
alternatives to the proposed project, including, but not limited to, a No Project Alternative (CEQA
Guidelines §15126.6)
1.3 - Purpose
In accordance with CEQA Guidelines (14 California Code of Regulations [CCR] § 15082), the City has
prepared this NOP to inform agencies and interested parties that a Program EIR will be prepared for
the proposed South San Francisco General Plan Update, Zoning Code Amendments, and Climate
Action Plan. The purpose of an NOP is to provide sufficient information about the proposed project
to allow agencies and interested parties the opportunity to provide a meaningful response related to
the scope and content of the Program EIR, including mitigation measures that should be considered
and alternatives that should be addressed (CEQA Guidelines 14 CCR § 15082(b)).
1.4 - Environmental Review Process
Following completion of the 45-day NOP public review period, the City will incorporate relevant
information into the Program EIR, including results of public scoping and technical studies.
Subsequently, the Program EIR will be circulated for public review and comment for a 45-day public
review period.
The City requests that any potential Responsible or Trustee Agency responding to this notice do so in
a manner consistent with CEQA Guidelines Section 15082(b). All parties that have submitted their
names and email or mailing addresses will be notified throughout the CEQA review process.
A copy of the NOP (in full color) can be found on the project website at https://shapessf.com/ and on
file at the City of South San Francisco, Economic and Community Development Department, 315
Maple Avenue, South San Francisco, CA 94080.
If you wish to be placed on the mailing list or need additional information, please contact Billy Gross,
Senior Planner, Planning Division, City of South San Francisco, at 650.877.8535 or [email protected].
1.4.1 - Effects Found not to be Significant
Agriculture and Forestry
The Planning Area is located within an urban environment. No existing agriculture or forestry land use
activities occur within the Planning Area boundaries, and none of the Planning Area is designated as
relevant for agriculture or forestry resources by the City of South San Francisco or by the State of
California.8 These conditions preclude the possibility of loss of agricultural or forest resources;
therefore, this issue will not be analyzed further by the Program EIR.
8 California Important Farmland: 1984-2018. 2018. Website: https://maps.conservation.ca.gov/dlrp/ciftimeseries/. Accessed
January 3, 2022.
South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Notice of Preparation City of South San Francisco
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Mineral Resources
No activities related to mineral resources occur within the Planning Area boundaries, and none of the
Planning Area is designated as relevant for mineral resources by the City of South San Francisco
Zoning Ordinance or by the State of California.9 These conditions preclude the possibility of impacts
on mineral resources; therefore, this issue will not be analyzed further by the Program EIR.
9 California Department of Conservation, California Geological Survey Information Warehouse: Mineral Land Classification. 2015.
Website: https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc. Accessed January 3, 2022.
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50000006 • 12/2021 | 1_regional_context.cdr
Exhibit 1
Regional Context Map
CITY OF SOUTH SAN FRANCISCO
GENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLAN
NOTICE OF PREPARATION
Source: Raimi + Associates, November 2019.
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380
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Spruce A v e
S Linden AveUtah AveSSpruceAveGellertBlvd
San Bruno Creek
C o l m a C r e e k
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Terminal
San Francisco Bay
California
Golf Club
Unincorporated
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Pacifica
San Bruno
Colma
Daly City
Brisbane
San FranciscoInternational
Airport
Legend
Streams
Centennial Way Trail
Parks/Open Space
San Bruno Mountain State and County Park
BARTCaltrain
Highway
Transportation Features
ArterialLocal Street
50000006 • 12/2021 | 2_local_vicinity.mxd
Exhibit 2Local Vicinity Map
CITY OF SOUTH SAN FRANCISCOGENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLANNOTICE OF PREPARATION
3,000 0 3,0001,500
Feet
City of South San Francisco
Other City Boundaries
Jurisdictional Boundary
Sphere of Influence
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50000006 • 12/2021 | 3_existing_LU.cdr
Exhibit 3
Existing Land Use Map
CITY OF SOUTH SAN FRANCISCO
GENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLAN
NOTICE OF PREPARATION
Source: Raimi + Associates, June 2020.
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50000006 • 12/2021 | 4_proposed_LU.cdr
Exhibit 4
Proposed Land Use Map
CITY OF SOUTH SAN FRANCISCO
GENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLAN
NOTICE OF PREPARATION
Source: Raimi + Associates, October 2020.
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50000006 • 12/2021 | 5_proposed_LU_changes_only_from_existing_LU.cdr
Exhibit 5
Proposed Land Use Map - Changes Only From Existing Land Use Map
CITY OF SOUTH SAN FRANCISCO
GENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLAN
NOTICE OF PREPARATION
Source: Raimi + Associates, October 2020.
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Draft Program EIR
FirstCarbon Solutions
A.2 - Summary of EIR Scoping Comments
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City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Summary of Scoping Comments
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
State Agency
Native American
Heritage Commission
(NAHC)
Andrew Green,
Cultural Resources
Analyst
01/25/2022 • Recommends consultation with California Native American tribes
traditionally and culturally affiliated with the geographic area of the
proposed project.
• Outlines Assembly Bill (AB) 52 and Senate Bill (SB) 18 tribal
consultation provisions.
• Provides recommendations for Cultural Resources Assessments.
• Section 3.4, Cultural and Tribal
Cultural Resources
NAHC Nancy Gonzalez-Lopez,
Cultural Resources
Analyst
02/08/2021 • Recommends consultation with California Native American tribes
traditionally and culturally affiliated with the geographic area of the
proposed project.
• Outlines AB 52 and SB 18 tribal consultation provisions.
• Provides recommendations for Cultural Resources Assessments.
• Section 3.4, Cultural and Tribal
Cultural Resources
California Department
of Fish and Wildlife
(CDFW)
Erin Chappell, Regional
Manager, Bay Delta
Region
02/22/2022 • Recommends providing as much information related to anticipated
future activities as possible in the project description.
• Recommends creating a procedure or checklist for evaluating
subsequent project impacts on biological resources.
• Recommends that the Draft Program EIR provides baseline habitat
assessments for special-status species plant, fish, and wildlife species
located and potentially located within the project area and
surrounding lands.
• Recommends that surveys be conducted for special-status plant and
wildlife species prior to project implementation.
• Recommends that the Draft Program EIR describe aquatic habitats,
such as wetlands and/or waters of the United States or State, and
any sensitive natural communities or riparian habitat in the project
area.
• Recommends that the Draft Program EIR include the reasonably
foreseeable direct and indirect changes (temporary and permanent)
to biological resources, including cumulative impacts.
• Recommends implementation of avoidance and minimization
measures for special-status species.
• Recommends that the proposed project avoid or minimize the use of artificial lighting to reduce nighttime light pollution.
• Chapter 2, Project Description
• Section 3.1, Aesthetics, Light,
and Glare
• Section 3.3, Biological
Resources
• Section 3.9, Hydrology and
Water Quality
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
• Recommends that the proposed project incorporate visual signals or
cues to exterior windows to prevent bird collisions.
• Recommends that the proposed project avoid increases in
stormwater runoff to streams that can cause hydromodification and
erosion.
• States that if fencing is built, the proposed project use wildlife
friendly fencing.
• Includes recommended mitigation measures to be included in the
Draft Program EIR to protect nesting birds.
California Department of Fish and Wildlife (CDFW)
Gregg Erickson, Regional Manager, Bay Delta Region
03/10/2021 • Recommends providing as much information related to anticipated
future activities as possible in the project description.
• Recommends creating a procedure or checklist for evaluating
subsequent project impacts on biological resources.
• Recommends that the Draft Program EIR provides baseline habitat
assessments for special-status species plant, fish, and wildlife species
located and potentially located within the project area and
surrounding lands.
• Recommends that surveys be conducted for special-status plant and
wildlife species prior to project implementation.
• Recommends that the Draft Program EIR describe aquatic habitats,
such as wetlands and/or waters of the United States or State, and
any sensitive natural communities or riparian habitat in the project
area.
• Recommends that the Draft Program EIR include the reasonably foreseeable direct and indirect changes (temporary and permanent)
to biological resources, including cumulative impacts.
• Recommends implementation of avoidance and minimization
measures for special-status species.
• Recommends that the proposed project avoid or minimize the use of
artificial lighting to reduce nighttime light pollution.
• Recommends that the proposed project incorporate visual signals or
cues to exterior windows to prevent bird collisions.
• Includes recommended mitigation measures to be included in the
Draft Program EIR to protect State fully protected species, special-
status species, nesting birds, and bat species.
• Chapter 2, Project Description
• Section 3.1, Aesthetics, Light,
and Glare
• Section 3.3, Biological
Resources
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
San Francisco
International Airport
(SFO)
Nupur Sinha, Director,
Planning and
Environmental Affairs
02/28/2022 • States that the Airport maintains the comments on the proposed
project contained in the March 22, 2021, letter.
• Section 3.8, Hazards and
Hazardous Materials
• Section 3.10, Land Use and
Planning
• Section 3.11, Noise
San Francisco
International Airport
(SFO)
Nupur Sinha, Acting
Planning Director,
Planning and
Environmental Affairs
03/22/2021 • Expresses concern that portions of the proposed mixed-use
residential areas east of U.S. Highway 101 (US-101) are within the
airport’s runway safety zone boundaries and 65 decibel Community
Noise Equivalent Level (CNEL) noise contour.
• Requests that the Program EIR evaluate project consistency with all
comprehensive Airport Land Use Compatibility Plan (ALUCP) for the
environs of San Francisco International Airport (SFO) regulatory requirements and policies.
• Expresses concern that any residential developments east of US-101
could reduce the efficacy of the Nighttime Preferential Runway Use
program that protects residents of South San Francisco, Daly City,
and Pacifica by maximizing flights over water and industrial areas
between 1:00 a.m. and 6:00 a.m.
• Recommends that noise impacts on sensitive receptors and any
necessary mitigation measures should be fully evaluated in the
Program EIR, and the EIR should describe the proposed project’s
consistency with noise policies described in ALUCP, including Noise
Policies NP-1 through NP-4.
• States that the southern portions of the General Plan area are within
various runway end safety zones, including the Inner
Approach/Departure Zone, Inner Turning Zone, and Outer
Approach/Departure Zone and requests that the Program EIR
describe and evaluate the proposed project’s consistency with land
use criteria within these runway end safety zones, as described in ALUCP SP-1 through SP-3.
• Requests that the Program EIR evaluate impacts of the new vehicular bridge between Oyster Point and North Access Road on airport
property.
• Section 3.8, Hazards and
Hazardous Materials
• Section 3.10, Land Use and Planning
• Section 3.11, Noise
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
California Department
of Transportation
(Caltrans)
Mark Leong, District
Branch Chief
02/25/2022 • States that current and future land use projects proposed near and
adjacent to the State Transportation Network shall be assessed, in
part, through Caltrans’ Transportation Impact Study Guide.
• Recommends a sufficient allocation of fair share contributions
toward multimodal and regional transit improvements to fully
mitigate cumulative impacts to regional transportation.
• States that Lead Agency is responsible for all impact mitigation,
including any needed improvements to the State Transportation
Network.
• States that if any Caltrans facilities are impacted by the proposed
project, those facilities must meet Americans with Disabilities Act
(ADA) Standards after project completion and maintain bicycle and pedestrian access during construction.
• Section 3.14, Transportation
California Department
of Transportation (Caltrans)
Mark Leong, District
Branch Chief
03/22/2021 • Recommends that a detailed Vehicle Miles Traveled (VMT) analysis
be included in the Draft Program EIR for projects that do not meet
the screening criteria.
• Recommends that the Draft Program EIR include a robust
Transportation Demand Management (TDM) Program and provides a
list of measures to reduce VMT and greenhouse gas (GHG)
emissions.
• Recommends that TDM programs be documented with annual
monitoring reports by a TDM coordinator.
• States that Lead Agency is responsible for all impact mitigation,
including any needed improvements to the State Transportation
Network.
• Section 3.7, Greenhouse Gas
Emissions
• Section 3.14, Transportation
San Mateo County
Local Agency Formation Commission (LAFCo)
Rob Bartoli, Interim
Executive Director
02/28/2022 • Supports inclusion of unincorporated islands within the sphere of
influence of South San Francisco within the General Plan study area.
• Recommends that the Draft Program EIR evaluate land uses and
infrastructure within the two unincorporated islands, including sewer
and right-of-way improvements.
• Recommends that the City explore how to allow for annexations of
the unincorporated areas, through individual annexations, a phased
approach, or annexation of the whole area.
• Section 3.10, Land Use and
Planning
• Section 3.9, Hydrology and
Water Quality
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
California Geological
Survey
Dr. Erik Frost, Senior
Engineering Geologist,
Seismic Hazards Program
03/15/2021 • Recommends that the Draft Program EIR address liquefaction,
landslide, faulting, and ground shaking geologic hazards.
• States that new Zones of Required Investigation for liquefaction and
earthquake-induced landslides will be released for the planning area.
• States that Holocene-active strands of the San Andreas fault zone
traverse the planning area.
• States that new Tsunami Hazard Area maps for San Mateo County
and new Tsunami Regulatory Zones will be released.
• States that Oyster Point Harbor and Oyster Cove Marina are susceptible to tsunami hazards.
• Recommends that the Draft Program EIR discuss the geologic history and rock types in the planning area.
• Recommends that the Draft Program EIR discuss soil types and
particular soil characteristics pertinent to development.
• Section 3.6, Geology, Soils, and
Seismicity
• Section 3.9, Hydrology and
Water Quality
Bay Area Air Quality
Management District
(BAAQMD)
Greg Nudd, Deputy Air
Pollution Control
Officer
03/18/2021 • Recommends that the Draft Program EIR estimate and evaluate
potential health risks to existing and future sensitive populations
within the planning area from Toxic Air Contaminants (TACs) and
particulate matter, including dust, 2.5 micrometers or less in
diameter (PM2.5).
• Recommends that the greenhouse gas (GHG) impact analysis include
an evaluation of the General Plan’s consistency with the most recent
AB 32 Scoping Plan and the State’s 2030 and 2050 climate goals.
• Recommends that the Draft Program EIR evaluate all feasible
measures, both on-site and offsite, to minimize air quality and GHG impacts.
• Recommends that the Draft Program EIR evaluate the General Plan’s consistency with the Air District’s 2017 Clean Air Plan, the South San
Francisco Climate Action Plan (2014), and the San Mateo County’s
Sea Level Rise Vulnerability Assessment (2018).
• States that certain aspects of the General Plan may require a permit
from the Air District (for example, back-up diesel generators).
• Section 3.2, Air Quality
• Section 3.7, Greenhouse Gas
Emissions
• Section 3.9, Hydrology and
Water Quality
San Francisco Public
Utilities Commission
(SFPUC)
Joanne Wilson, Senior
Land and Resources
Planner, Natural
03/18/2021 • Recommends that the Draft Program EIR identify the SFPUC as an
agency that may provide approval for future projects or activities
under the General Plan and include information about the SFPUC’s
project review process.
• Chapter 2, Project Description
• Section 3.10, Land Use and
Planning
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
Resources and Lands
Management Division • Recommends that the Draft Program EIR analyze the General Plan’s
consistency with applicable SFPUC adopted plans, policies, and
guidelines in the land use analysis.
• Requests the Draft Program EIR to disclose and analyze potential
land use conflicts from proposed housing sites, accessory housing
land uses, or residential zoning included in the updated Housing
Element that might conflict with established plans and policies of
other agencies, including the SFPUC.
• Cites SFPUC’s policies regarding right-of-way.
• Section 2.15 Utilities and
Service Systems
City/County
Association of
Governments of San
Mateo County (C/CAG)
Katherine Kalkin, ALUC
Staff
03/22/2021 • Recommends the Draft Program EIR discuss how the proposed policies in the General Plan Update will ensure Airport/Land Use Compatibility with noise, height/airspace protection, safety and
overflight compatibility criteria and policies in the 2012 SFO ALUCP.
• Section 3.8, Hazards and Hazardous Materials
• Section 3.10, Land Use and Planning
• Section 3.11, Noise
Individuals
N/A Liliana Rivera 03/22/2021 • Highlights disparate pollution, health, and noise impacts on
communities of color in South San Francisco resulting from industry
on the east side and discriminatory housing policies.
• Requests that the City prioritize health services and green space,
particularly for non-English speakers and undocumented residents.
• States that the General Plan should prioritize well-being of diverse
community that already lives in the City.
• Attach exhibits illustrating pollution and demographic data in the City
as well as information on the causes of pollution in these areas.
• Section 3.2, Air Quality
N/A Marcela Rivera • Requests that the General Plan include more affordable housing,
parks, and green space on the east side and neighborhoods like
sunshine gardens.
• Requests that the City create more routes for the free shuttle,
especially to and from the Bay Area Rapid Transit (BART) station.
• Requests that the City provide more services for Spanish speaking
families and find a way to better communicate with all its residents.
• Requests that City evaluate impacts of the biotechnology industry
and water levels at Oyster Point.
• Chapter 2, Project Description
• Section 3.9, Hydrology and
Water Quality
• Section 3.12, Population,
Housing, and Employment
• Section 3.13, Public Services
and Recreation
• Section 3.14, Transportation
City of South San Francisco– General Plan Update, Zoning Code Amendments, and Climate Action Plan
Administrative Draft Program EIR Appendix A-2
FirstCarbon Solutions
Agency/Organization Author Date Comment Summary Coverage in Draft Program EIR
N/A Olga Perez 03/22/2021 • Suggests consideration of local residents in providing affordable
housing should be a driving force in meeting citizen needs and
Regional Housing Needs Assessment (RHNA) mandates (as opposed
to serving the housing needs of growing biotech employees).
• States that housing/mixed-use (retail) near BART would help mitigate
climate change/improve air quality by discouraging vehicle use.
• Suggests the City provide art and recreational programs in Old Town
area where majority of Latinx population exists.
• Suggests multi-language resources and outreach materials as well as
interpreter services for agency meetings to provide equal access to
participation.
• States that Old Town, Downtown, Pecks Lots, and Cypress Park areas
need more parks and park improvements for infants, young children,
teens and seniors.
• Suggests creation of volunteer-based community gardens throughout
the City.
• Suggests affordable and free internet for low-income communities.
• Suggests mandate for inspection of Pacific and Gas Company (PG&E)
underground natural gas lines throughout the City.
• Expresses concern regarding health impacts of housing near US-101.
• Chapter 2, Project Description
• Section 3.2, Air Quality
• Section 3.7, Greenhouse Gas
Emissions
• Section 3.13, Public Services
and Recreation
• Section 3.14, Transportation
• Section 3.15, Utilities and
Service Systems
Individuals (Verbal Comments Received During EIR Scoping Meeting)
San Francisco
International Airport
(SFO)
David Kim, Senior
Environmental Planner
01/31/2022 • States that much of the land slated to be changed to residential uses is close to the airport runways.
• Recommends that the City submit the General Plan Update to the ALUC for review and approval.
• Recommends that residential uses be discouraged within the 65
decibel CNEL noise contour.
• States that the southern portions of the General Plan area are within
safety zones, and requests that the Program EIR describe and evaluate the proposed project’s consistency within these safety
zones.
• Requests that the Program EIR evaluate impacts of the new vehicular
bridge between Oyster Point and North Access Road on airport
property.
• Section 3.8, Hazards and Hazardous Materials
• Section 3.10, Land Use and Planning
• Section 3.11, Noise
Source: Compiled by FirstCarbon Solutions (FCS) 2022.
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Draft Program EIR
FirstCarbon Solutions
A.3 - EIR Scoping Comment Letters
THIS PAGE INTENTIONALLY LEFT BLANK
STATE OF CALIFORNIA Gavin Newsom, Governor
NATIVE AMERICAN HERITAGE COMMI SSION
Page 1 of 5
January 25, 2022
Billy Gross
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
Re: 2021020064, South San Francisco General Plan Update, Zoning Code Amendments, and
Climate Action Plan Project, San Mateo County
Dear Mr. Gross:
The Native American Heritage Commission (NAHC) has received the Notice of Preparation
(NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project
referenced above. The California Environmental Quality Act (CEQA) (Pub. Resources Code
§21000 et seq.), specifically Public Resources Code §21084.1, states that a project that may
cause a substantial adverse change in the significance of a historical resource, is a project that
may have a significant effect on the environment. (Pub. Resources Code § 21084.1; Cal. Code
Regs., tit.14, §15064.5 (b) (CEQA Guidelines §15064.5 (b)). If there is substantial evidence, in
light of the whole record before a lead agency, that a project may have a significant effect on
the environment, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources
Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)(1) (CEQA Guidelines §15064 (a)(1)).
In order to determine whether a project will cause a substantial adverse change in the
significance of a historical resource, a lead agency will need to determine whether there are
historical resources within the area of potential effect (APE).
CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of
2014) (AB 52) amended CEQA to create a separate category of cultural resources, “tribal
cultural resources” (Pub. Resources Code §21074) and provides that a project with an effect
that may cause a substantial adverse change in the significance of a tribal cultural resource is
a project that may have a significant effect on the environment. (Pub. Resources Code
§21084.2). Public agencies shall, when feasible, avoid damaging effects to any tribal cultural
resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice
of preparation, a notice of negative declaration, or a mitigated negative declaration is filed on
or after July 1, 2015. If your project involves the adoption of or amendment to a general plan or
a specific plan, or the designation or proposed designation of open space, on or after March 1,
2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).
Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the
federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal
consultation requirements of Section 106 of the National Historic Preservation Act of 1966 (154
U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.
The NAHC recommends consultation with California Native American tribes that are
traditionally and culturally affiliated with the geographic area of your proposed project as early
as possible in order to avoid inadvertent discoveries of Native American human remains and
best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as
well as the NAHC’s recommendations for conducting cultural resources assessments.
Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with
any other applicable laws.
CHAIRPERSON
Laura Miranda Luiseño
VICE CHAIRPERSON
Reginald Pagaling Chumash
PARLIAMENTARIAN
Russell Attebery
Karuk
COMMISSIONER William Mungary
Paiute/White Mountain
Apache
COMMISSIONER Isaac Bojorquez
Ohlone-Costanoan
COMMISSIONER Sara Dutschke Miwok
COMMISSIONER
Buffy McQuillen
Yokayo Pomo, Yuki, Nomlaki
COMMISSIONER
Wayne Nelson
Luiseño
COMMISSIONER
Stanley Rodriguez
Kumeyaay
EXECUTIVE SECRETARY Christina Snider
Pomo
NAHC HEADQUARTERS
1550 Harbor Boulevard Suite 100
West Sacramento,
California 95691
(916) 373-3710
[email protected] NAHC.ca.gov
Page 2 of 5
AB 52
AB 52 has added to CEQA the additional requirements listed below, along with many other requirements:
1. Fourteen Day Period to Provide Notice of Completion of an Application/Decision to Undertake a Project:
Within fourteen (14) days of determining that an application for a project is complete or of a decision by a public
agency to undertake a project, a lead agency shall provide formal notification to a designated contact of, or
tribal representative of, traditionally and culturally affiliated California Native American tribes that have
requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.
Resources Code §21080.3.1 (d)).
d. A “California Native American tribe” is defined as a Native American tribe located in California that is
on the contact list maintained by the NAHC for the purposes of Chapter 905 of Statutes of 2004 (SB 18).
(Pub. Resources Code §21073).
2. Begin Consultation Within 30 Days of Receiving a Tribe’s Request for Consultation and Before Releasing a
Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report: A lead agency shall
begin the consultation process within 30 days of receiving a request for consultation from a California Native
American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.
(Pub. Resources Code §21080.3.1, subds. (d) and (e)) and prior to the release of a negative declaration,
mitigated negative declaration or Environmental Impact Report. (Pub. Resources Code §21080.3.1(b)).
a. For purposes of AB 52, “consultation shall have the same meaning as provided in Gov. Code §65352.4
(SB 18). (Pub. Resources Code §21080.3.1 (b)).
3. Mandatory Topics of Consultation If Requested by a Tribe: The following topics of consultation, if a tribe
requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
c. Significant effects. (Pub. Resources Code §21080.3.2 (a)).
4. Discretionary Topics of Consultation: The following topics are discretionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project’s impacts on tribal cultural resources.
d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe
may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).
5. Confidentiality of Information Submitted by a Tribe During the Environmental Review Process: With some
exceptions, any information, including but not limited to, the location, description, and use of tribal cultural
resources submitted by a California Native American tribe during the environmental review process shall not be
included in the environmental document or otherwise disclosed by the lead agency or any other public agency
to the public, consistent with Government Code §6254 (r) and §6254.10. Any information submitted by a
California Native American tribe during the consultation or environmental review process shall be published in a
confidential appendix to the environmental document unless the tribe that provided the information consents, in
writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3 (c)(1)).
6. Discussion of Impacts to Tribal Cultural Resources in the Environmental Document: If a project may have a
significant impact on a tribal cultural resource, the lead agency’s environmental document shall discuss both of
the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource.
b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed
to pursuant to Public Resources Code §21082.3, subdivision (a), avoid or substantially lessen the impact on
the identified tribal cultural resource. (Pub. Resources Code §21082.3 (b)).
Page 3 of 5
7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the
following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on
a tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot
be reached. (Pub. Resources Code §21080.3.2 (b)).
8. Recommending Mitigation Measures Agreed Upon in Consultation in the Environmental Document: Any
mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code §21080.3.2
shall be recommended for inclusion in the environmental document and in an adopted mitigation monitoring
and reporting program, if determined to avoid or lessen the impact pursuant to Public Resources Code §21082.3,
subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §21082.3 (a)).
9. Required Consideration of Feasible Mitigation: If mitigation measures recommended by the staff of the lead
agency as a result of the consultation process are not included in the environmental document or if there are no
agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if
substantial evidence demonstrates that a project will cause a significant effect to a tribal cultural resource, the
lead agency shall consider feasible mitigation pursuant to Public Resources Code §21084.3 (b). (Pub. Resources
Code §21082.3 (e)).
10. Examples of Mitigation Measures That, If Feasible, May Be Considered to Avoid or Minimize Significant Adverse
Impacts to Tribal Cultural Resources:
a. Avoidance and preservation of the resources in place, including, but not limited to:
i. Planning and construction to avoid the resources and protect the cultural and natural
context.
ii. Planning greenspace, parks, or other open space, to incorporate the resources with culturally
appropriate protection and management criteria.
b. Treating the resource with culturally appropriate dignity, taking into account the tribal cultural values
and meaning of the resource, including, but not limited to, the following:
i. Protecting the cultural character and integrity of the resource.
ii. Protecting the traditional use of the resource.
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easements or other interests in real property, with culturally appropriate
management criteria for the purposes of preserving or utilizing the resources or places.
d. Protecting the resource. (Pub. Resource Code §21084.3 (b)).
e. Please note that a federally recognized California Native American tribe or a non-federally
recognized California Native American tribe that is on the contact list maintained by the NAHC to protect
a California prehistoric, archaeological, cultural, spiritual, or ceremonial place may acquire and hold
conservation easements if the conservation easement is voluntarily conveyed. (Civ. Code §815.3 (c)).
f. Please note that it is the policy of the state that Native American remains and associated grave
artifacts shall be repatriated. (Pub. Resources Code §5097.991).
11. Prerequisites for Certifying an Environmental Impact Report or Adopting a Mitigated Negative Declaration or
Negative Declaration with a Significant Impact on an Identified Tribal Cultural Resource: An Environmental
Impact Report may not be certified, nor may a mitigated negative declaration or a negative declaration be
adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public
Resources Code §21080.3.1 and §21080.3.2 and concluded pursuant to Public Resources Code
§21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise
failed to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources
Code §21080.3.1 (d) and the tribe failed to request consultation within 30 days. (Pub. Resources Code
§21082.3 (d)).
Page 4 of 5
The NAHC’s PowerPoint presentation titled, “Tribal Consultation Under AB 52: Requirements and Best Practices” may
be found online at: http://nahc.ca.gov/wp-content/uploads/2015/10/AB52TribalConsultation_CalEPAPDF.pdf
SB 18
SB 18 applies to local governments and requires local governments to contact, provide notice to, refer plans to, and
consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of
open space. (Gov. Code §65352.3). Local governments should consult the Governor’s Office of Planning and
Research’s “Tribal Consultation Guidelines,” which can be found online at:
https://www.opr.ca.gov/docs/09_14_05_Updated_Guidelines_922.pdf.
Some of SB 18’s provisions include:
1. Tribal Consultation: If a local government considers a proposal to adopt or amend a general plan or a
specific plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC
by requesting a “Tribal Consultation List.” If a tribe, once contacted, requests consultation the local government
must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification to
request consultation unless a shorter timeframe has been agreed to by the tribe. (Gov. Code §65352.3
(a)(2)).
2. No Statutory Time Limit on SB 18 Tribal Consultation. There is no statutory time limit on SB 18 tribal consultation.
3. Confidentiality: Consistent with the guidelines developed and adopted by the Office of Planning and
Research pursuant to Gov. Code §65040.2, the city or county shall protect the confidentiality of the information
concerning the specific identity, location, character, and use of places, features and objects described in Public
Resources Code §5097.9 and §5097.993 that are within the city’s or county’s jurisdiction. (Gov. Code §65352.3
(b)).
4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures
for preservation or mitigation; or
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes
that mutual agreement cannot be reached concerning the appropriate measures of preservation or
mitigation. (Tribal Consultation Guidelines, Governor’s Office of Planning and Research (2005) at p. 18).
Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initiating tribal consultation with
tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in AB 52 and
SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and “Sacred Lands
File” searches from the NAHC. The request forms can be found online at: http://nahc.ca.gov/resources/forms/.
NAHC Recommendations for Cultural Resources Assessments
To adequately assess the existence and significance of tribal cultural resources and plan for avoidance, preservation
in place, or barring both, mitigation of project-related impacts to tribal cultural resources, the NAHC recommends
the following actions:
1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center
(http://ohp.parks.ca.gov/?page_id=1068) for an archaeological records search. The records search will
determine:
a. If part or all of the APE has been previously surveyed for cultural resources.
b. If any known cultural resources have already been recorded on or adjacent to the APE.
c. If the probability is low, moderate, or high that cultural resources are located in the APE.
d. If a survey is required to determine whether previously unrecorded cultural resources are present.
2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report
detailing the findings and recommendations of the records search and field survey.
a. The final report containing site forms, site significance, and mitigation measures should be submitted
immediately to the planning department. All information regarding site locations, Native American
human remains, and associated funerary objects should be in a separate confidential addendum and
not be made available for public disclosure.
Page 5 of 5
b. The final written report should be submitted within 3 months after work has been completed to the
appropriate regional CHRIS center.
3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the
Sacred Lands File, nor are they required to do so. A Sacred Lands File search is not a substitute for
consultation with tribes that are traditionally and culturally affiliated with the geographic area of the
project’s APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the
project site and to assist in planning for avoidance, preservation in place, or, failing both, mitigation
measures.
4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources)
does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for
the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code
Regs., tit. 14, §15064.5(f) (CEQA Guidelines §15064.5(f)). In areas of identified archaeological sensitivity, a
certified archaeologist and a culturally affiliated Native American with knowledge of cultural resources
should monitor all ground-disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the disposition of recovered cultural items that are not burial associated in consultation with culturally
affiliated Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the treatment and disposition of inadvertently discovered Native American human remains. Health
and Safety Code §7050.5, Public Resources Code §5097.98, and Cal. Code Regs., tit. 14, §15064.5,
subdivisions (d) and (e) (CEQA Guidelines §15064.5, subds. (d) and (e)) address the processes to be
followed in the event of an inadvertent discovery of any Native American human remains and
associated grave goods in a location other than a dedicated cemetery.
If you have any questions or need additional information, please contact me at my email address:
[email protected].
Sincerely,
Andrew Green
Cultural Resources Analyst
cc: State Clearinghouse
State of California – Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director
Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
February 22, 2022
Mr. Billy Gross
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
[email protected]
Subject: South San Francisco General Plan Update, Zoning Code Amendments, and
Climate Action Plan, Notice of Preparation of a Draft Environmental Impact
Report, SCH No. 2021020064, City of South San Francisco, San Mateo County
Dear Mr. Gross:
The California Department of Fish and Wildlife (CDFW) reviewed the Notice of
Preparation (NOP) of a draft Environmental Impact Report (EIR) prepared by the City of
South San Francisco for the South San Francisco General Plan Update, Zoning Code
Amendments, and Climate Action Plan (Project). CDFW is submitting comments on the
NOP regarding potentially significant impacts to biological resources associated with the
Project.
CDFW ROLE
CDFW is a Trustee Agency with responsibility under the California Environmental
Quality Act (CEQA) for commenting on projects that could impact fish, plant, and wildlife
resources (Pub. Resources Code, § 21000 et seq.; Cal. Code Regs., tit. 14, § 15386).
CDFW is also considered a Responsible Agency if a project would require discretionary
approval, such as a California Endangered Species Act (CESA) Incidental Take Permit
(ITP), a Native Plant Protection Act (NPPA) Permit, a Lake and Streambed Alteration
(LSA) Agreement, or approval under other provisions of the Fish and Game Code that
afford protection to the state’s fish and wildlife trust resources. Pursuant to our authority,
CDFW has the following concerns, comments, and recommendations regarding the
Project.
California Endangered Species Act
Please be advised that a CESA ITP must be obtained if the Project has the potential to
result in take1 of plants or animals listed under CESA, either during construction or over
the life of the Project. Issuance of a CESA Permit is subject to CEQA documentation;
1 Take is defined in Fish and Game Code section 86 as hunt, pursue, catch, capture, or kill, or attempt
any of those activities.
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the CEQA document must specify impacts, mitigation measures, and a mitigation
monitoring and reporting program. If the Project will impact CESA listed species, early
consultation is encouraged, as significant modification to the Project and mitigation
measures may be required to obtain a CESA ITP.
CEQA requires a Mandatory Finding of Significance if a project is likely to substantially
restrict the range or reduce the population of a threatened or endangered species (Pub.
Resources Code, §§ 21001, subd. (c), 21083; CEQA Guidelines, §§ 15380, 15064, and
15065). Impacts must be avoided or mitigated to less-than-significant levels unless the
CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).
The Lead Agency’s FOC does not eliminate the project proponent’s obligation to comply
with CESA.
Lake and Streambed Alteration Agreement
CDFW requires an LSA Notification, pursuant to Fish and Game Code section 1600 et
seq., for Project activities affecting lakes or streams and associated riparian habitat.
Notification is required for any activity that may substantially divert or obstruct the
natural flow; change or use material from the bed, channel, or bank including associated
riparian or wetland resources; or deposit or dispose of material where it may pass into a
river, lake, or stream. Work within ephemeral streams, washes, watercourses with a
subsurface flow, and floodplains are subject to notification requirements. CDFW, as a
Responsible Agency, will consider the CEQA document for the Project and may issue
an LSA Agreement. CDFW may not execute the final LSA Agreement until it has
complied with CEQA as a Responsible Agency.
Migratory Birds and Raptors
CDFW has authority over actions that may disturb or destroy active nest sites or take
birds. Fish and Game Code sections 3503, 3503.5, and 3513 protect birds, their eggs,
and nests. Fully protected species may not be taken or possessed at any time (Fish and
Game Code, § 3511). Migratory birds are also protected under the federal Migratory
Bird Treaty Act.
PROJECT LOCATION
The Project is located in the City of South San Francisco, in San Mateo County,
California. The City is located in a basin bounded by the San Bruno Mountains to the
north, the Pacific Coast Ranges to the west, and the San Francisco Bay to the east. The
City is bordered by the City of Brisbane to the north, Daly City, City of Pacifica, and the
Town of Colma to the west, and the City of San Bruno to the south. San Francisco
International Airport is located immediately to the south but falls within City and County
of San Francisco’s jurisdictional boundaries.
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PROJECT DESCRIPTION
The proposed Project consists of the South San Francisco General Plan Update,
Zoning Code Amendments, and Climate Action Plan. The General Plan Update is a
forward-looking document that will serve as the blueprint for the City’s vision through the
year 2040. The goals, policies, and actions in the proposed General Plan Update will
serve as a compass for decision-makers and will shape future plans and actions of the
City. The City's comprehensive General Plan was initially prepared in 1999. The City’s
Housing Element was certified in 2015 and is valid until 2023. The process of updating
the existing Housing Element is underway and is being conducted as part of this
General Plan Update. The proposed General Plan Update would replace the 1999
General Plan.
The General Plan Update anticipates approximately 17,531 net new housing units and
approximately 80,944 net new employment opportunities by 2040. The Climate Action
Plan includes a community-wide inventory of greenhouse gas (GHG) emissions and
identifies strategies and measures to reduce GHG emissions generated by existing and
future uses in the City to achieve State-mandated targets.
The CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.) require that the draft
EIR incorporate a full project description, including reasonably foreseeable future phases
of the Project, that contains sufficient information to evaluate and review the Project’s
environmental impact (CEQA Guidelines, §§ 15124 and 15378). Please include a
complete description of the following Project components in the project description:
Footprints of permanent Project features and temporarily impacted areas, such
as staging areas and access routes.
Plans and dimensions for any proposed buildings/structures, ground disturbing
activities, fencing, paving, stationary machinery, landscaping, and stormwater
systems.
Operational features of the Project, including level of anticipated human
presence (describe seasonal or daily peaks in activity, if relevant), artificial
lighting/light reflection, noise, traffic generation, and other features.
Construction schedule, activities, equipment, and crew sizes.
ENVIRONMENTAL SETTING
The draft EIR should provide sufficient information regarding the environmental setting
(“baseline”) to understand the project’s, and its alternative’s (if applicable), potentially
significant impacts on the environment (CEQA Guidelines, §§ 15125 and 15360).
CDFW recommends that the draft EIR provide baseline habitat assessments for
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special-status plant, fish, and wildlife species located and potentially located within the
Project area and surrounding lands, including but not limited to all rare, threatened, or
endangered species (CEQA Guidelines, § 15380). The draft EIR should describe
aquatic habitats, such as wetlands and/or waters of the U.S. or State, and any sensitive
natural communities or riparian habitat occurring on or adjacent to the Project site.
The special-status species that have the potential to occur in or near the Project site,
include, but are not limited to:
Common Name Scientific Name Status
San Francisco gartersnake Thamnophis sirtalis tetrataenia FE, SE, SP
California Ridgway’s rail Rallus obsoletus obsoletus FE, SE
San Francisco common yellowthroat Geothlypic trichas SSC
American peregrine falcon Falco peregrines anatum SP
Point Reyes horkelia Horkelia marinensis SR
California red-legged frog Rana draytonii FT
Mission blue butterfly Icaricia icarioides missionensis FE
Callippe silverspot butterfly Speyeria callippe callippe FE
Longfin smelt Spirinchus thaleichtys FC, ST
Nesting birds
Bats
Plants
Aquatic species
Terrestrial species
Notes:
FT= federally threatened under ESA; FE = federally endangered under ESA; FC = federal
candidate for federal listing under ESA; SE = state endangered under CESA; ST = state
threatened under CESA; SSC = state species of special concern; SP = state listed as fully
protected; SR = state rare under the Native Plant Protection Act
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Habitat descriptions, and the potential for species occurrence, should include
information from multiple sources: aerial imagery; historical and recent survey data; field
reconnaissance; scientific literature and reports; the U.S. Fish and Wildlife Service’s
(USFWS) Information, Planning, and Consultation System; and findings from positive
occurrence databases such as California Natural Diversity Database (CNDDB). Based
on the data and information from the habitat assessment, the draft EIR should
adequately assess which special-status species are likely to occur on or near the
Project site, and whether they could be impacted by the Project.
CDFW recommends that prior to Project implementation, surveys be conducted for
special-status species with potential to occur, following recommended survey protocols
if available. Survey and monitoring protocols and guidelines are available at:
https://wildlife.ca.gov/Conservation/Survey-Protocols.
Botanical surveys for special-status plant species, including those listed by the
California Native Plant Society (http://www.cnps.org/cnps/rareplants/inventory/), must
be conducted during the blooming period for all species potentially impacted by the
Project within the Project area and adjacent habitats that may be indirectly impacted by,
for example, changes to hydrology, and require the identification of reference
populations. Please refer to CDFW protocols for surveying and evaluating impacts to
rare plants, and survey report requirements, available at:
https://wildlife.ca.gov/Conservation/Plants.
IMPACT ANALYSIS AND MITIGATION MEASURES
The draft EIR should include the reasonably foreseeable direct and indirect changes
(temporary and permanent) that may occur with implementation of the Project (CEQA
Guidelines, §§ 15126, 15126.2, and 15358). This includes evaluating and describing
impacts such as:
Encroachments into riparian habitats, wetlands, or other sensitive areas;
Potential for impacts to special-status species;
Loss or modification of breeding, nesting, dispersal and foraging habitat,
including vegetation removal, alteration of soils and hydrology, and removal of
habitat structural features (e.g., snags, rock outcrops, overhanging banks);
Permanent and temporary habitat disturbances associated with ground
disturbance, noise, lighting, reflection, air pollution, traffic, or human presence;
and
Obstruction of movement corridors, fish passage, or access to water sources and
other core habitat features.
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The draft EIR should also identify reasonably foreseeable future projects in the Project
vicinity, disclose any cumulative impacts associated with these projects, determine the
significance of each cumulative impact, and assess the significance of the Project’s
contribution to the impact (CEQA Guidelines, § 15355). Although a project’s impacts
may be less-than-significant individually, its contributions to a cumulative impact may be
considerable; a contribution to a significant cumulative impact, e.g., reduction of habitat
for a special-status species should be considered cumulatively considerable.
Based on the comprehensive analysis of the direct, indirect, and cumulative impacts of
the Project, the CEQA Guidelines direct the Lead Agency to consider and describe all
feasible mitigation measures to avoid potentially significant impacts in the draft EIR and
mitigate potentially significant impacts of the Project on the environment (CEQA
Guidelines, §§ 15021, 15063, 15071, 15126.4, and 15370). This includes a discussion
of impact avoidance and minimization measures for special-status species, which are
recommended to be developed in early consultation with CDFW, the USFWS, and the
National Marine Fisheries Service. These measures should be incorporated as
enforceable Project conditions to reduce impacts to biological resources to less-than-
significant levels.
Fully protected species such as San Francisco garter snake and American peregrine
falcon may not be taken or possessed at any time (Fish and Game Code, § 3511, 4700,
5050, and 5515). Therefore, the draft EIR should include measures to ensure complete
avoidance of these species.
CDFW COMMENTS AND RECOMMENDATIONS
COMMENT 1: Artificial Lighting
Issue: The Project could increase artificial lighting. Artificial lighting often results in light
pollution, which has the potential to significantly and adversely affect biological
resources.
Evidence the impact would be significant: Night lighting can disrupt the circadian
rhythms of many wildlife species. Many species use photoperiod cues for
communication (e.g., bird song; Miller 2006), determining when to begin foraging (Stone
et al. 2009), behavior thermoregulation (Beiswenger 1977), and migration (Longcore
and Rich 2004). Aquatic species can also be affected, for example, salmonids migration
can be slowed or stopped by the presence of artificial lighting (Tabor et al. 2004,
Nightingale et al. 2006).
Recommendations to minimize significant impacts: CDFW recommends eliminating all
non-essential artificial lighting. If artificial lighting is necessary, CDFW recommends
avoiding or limiting the use of artificial lights during the hours of dawn and dusk, when
many wildlife species are most active. CDFW also recommends that outdoor lighting be
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shielded, cast downward, and does not spill over onto other properties or upwards into
the night sky (see the International Dark-Sky Association standards at
http://darksky.org/).
COMMENT 2: Exterior Windows
Issue: The glass used for exterior building windows could result in bird collisions, which
can cause bird injury and mortality.
Evidence the impact would be significant: Birds, typically, do not see clear or reflective
glass, and can collide with glass (e.g., windows) that reflect surrounding landscape
and/or habitat features (Klem and Saenger 2013, Sheppard 2019). When birds collide
with glass, they can be injured or killed. In the United States, the estimated annual bird
mortality is between 365-988 million birds (Loss et al. 2014).
Recommendations to minimize significant impacts: CDFW recommends incorporating
visual signals or cues to exterior windows to prevent bird collisions. Visual signals or
cues include, but are not limited to, patterns to break up reflective areas, external
window films and coverings, ultraviolet patterned glass, and screens. For best practices
on how to reduce bird collisions with windows, please go to USFWS’s website for
Buildings and Glass (https://www.fws.gov/birds/bird-enthusiasts/threats-
tobirds/collisions/buildings-and-glass.php).
COMMENT 3: Stream Hydromodification
Issue: The Project could increase impervious surfaces within the Project area.
Impervious surfaces, stormwater systems, and storm drain outfalls have the potential to
significantly affect fish and wildlife resources by altering runoff hydrograph and natural
streamflow patterns and causing erosion.
Evidence the impact would be significant: Urbanization (e.g., impervious surfaces,
stormwater systems, storm drain outfalls) can modify natural streamflow patterns by
increasing the magnitude and frequency of high flow events and storm flows (Hollis
1975, Konrad and Booth 2005).
Recommendations to minimize significant impacts: CDFW recommends the Project
avoid increases in stormwater runoff to streams that can cause hydromodification and
erosion. Low impact designs should be incorporated into the Project such as permeable
surfaces throughout the Project area to allow stormwater to percolate in the ground and
other methods that can disperse rather than concentrate stormwater to drainage outfalls.
COMMENT 4: Fencing
Issue: The Project has the potential to build temporary and/or permanent fences.
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Evidence the impact would be significant: Fencing can be a hazard to wildlife causing
entanglement and mortality (van der Ree 1999, Stuart et al. 2001, Harrington and
Conover 2006). Recommendation to minimize significant impacts: CDFW recommends
that if fencing is built, the Project use wildlife friendly fencing.
COMMENT 5: Nesting Birds
Issue: Project construction could result in disturbance of nesting birds.
Evidence the impact would be significant: Noise can impact bird behavior by masking
signals used for bird communication, mating, and hunting (Bottalico et al. 2015). Birds
hearing can also be damaged from noise and impair the ability of birds to find or attract
a mate and prevent parents from hearing calling young (Ortega 2012).
Recommendations to minimize significant impacts: If ground-disturbing or vegetation-
disturbing activities occur during the bird breeding season (February through early-
September), the Project applicant is responsible for ensuring that implementation of the
Project does not result in violation of Fish and Game Code.
To evaluate and avoid for potential impacts to nesting bird species, CDFW recommends
incorporating the following mitigation measures into the Project’s draft EIR, and that
these measures be made conditions of approval for the Project.
Recommended Mitigation Measure 1: Nesting Bird Surveys
If ground-disturbing or vegetation-disturbing activities occur during the bird breeding
season, CDFW recommends that a qualified avian biologist conduct pre-Project activity
nesting bird surveys no more than seven (7) days prior to the start of ground or
vegetation disturbance and if there is a four day or more lapse in ground or vegetation
disturbance. CDFW recommends that nesting bird surveys cover a sufficient area
around the Project area to identify nests and determine their status. A sufficient area
means any area potentially affected by the Project.
During nesting bird surveys, CDFW recommends that a qualified avian biologist
establish behavioral baseline of all identified nests. During Project activities, CDFW
recommends having the qualified avian biologist continuously monitor nests to detect
behavioral changes resulting from Project activities. If behavioral changes occur, CDFW
recommends stopping the activity, that is causing the behavioral change, and consulting
with a qualified avian biologist on additional avoidance and minimization measures.
Recommended Mitigation Measure 2: Nesting Bird Buffers
During Project activities, if continuous monitoring of nests by a qualified avian biologist
is not feasible, CDFW recommends a minimum no-disturbance buffer of 250 feet
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around active nests of non-listed bird species and a 1,000-foot no-disturbance buffer
around active nests of non-listed raptors. These buffers are advised to remain in place
until the breeding season has ended or until a qualified avian biologist has determined
that the birds have fledged and are no longer reliant upon the nest or on-site parental
care for survival. Variance from these no-disturbance buffers is possible when there is
compelling biological or ecological reason to do so, such as when the Project area
would be concealed from a nest site by topography. CDFW recommends that a qualified
avian biologist advise and support any variance from these buffers.
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and
negative declarations be incorporated into a database which may be used to make
subsequent or supplemental environmental determinations. [Pub. Resources Code, §
21003, subd. (e)]. Accordingly, please report any special-status species and natural
communities detected during Project surveys to CNDDB. The CNNDB online field
survey form and other methods for submitting data can be found at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported
to CNDDB can be found at the following link: https://wildlife.ca.gov/Data/CNDDB/Plants-
and-Animals.
FILING FEES
CDFW anticipates that the Project will have an impact on fish and/or wildlife, and
assessment of filing fees is necessary (Fish and Game Code, § 711.4; Pub. Resources
Code, § 21089). Fees are payable upon filing of the Notice of Determination by the
Lead Agency and serve to help defray the cost of environmental review by CDFW.
If you have any questions, please contact Mr. Will Kanz, Environmental Scientist, at
[email protected]; or Mr. Wesley Stokes, Senior Environmental Scientist
(Supervisor), at [email protected].
Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
cc: State Clearinghouse, SCH No. 2021020064
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REFERENCES
Beiswenger, R. E. 1977. Diet patterns of aggregative behavior in tadpoles of Bufo
americanus, in relation to light and temperature. Ecology 58:98–108.
Bottalico, Pasquale & Spoglianti, Dorina & Bertetti, Carlo & Falossi, Marco. 2015. Effect
of noise generated by construction sites on birds, paper presented at Internoise
2015, International Congress and Exposition on Noise Control Engineering.
Harrington, J. L., and M. R. Conover. 2006. Characteristics of ungulate behavior and
mortality associated with fences. Wildlife Society Bulletin 34:1295–1305.
Hollis, G. 1975. The effect of urbanization on floods of different recurrence interval.
Water Resources Research 11:431-435.
Klem, D. and P. G. Saenger. 2013. Evaluating the Effectiveness of Select Visual
Signals to Prevent Bird-window Collisions. The Wilson Journal of Ornithology
125(2):406-411.
Konrad, C.P. and D.B. Booth. 2005. Hydrologic changes in urban streams and their
ecological significance, paper presented at American Fisheries Society
Symposium, American Fisheries Society.
Longcore, T., and C. Rich. 2004. Ecological light pollution - Review. Frontiers in Ecology
and the Environment 2:191–198.
Loss, S.R., T. Will, S.S. Loss, and P.P. Marra. 2014. Bird-building collisions in the
United States: estimates of annual mortality and species vulnerability. Condor
116: 8-23.
Miller, M. W. 2006. Apparent effects of light pollution on singing behavior of American
robins. The Condor 108:130–139.
Ortega, C. P. 2012. Chapter 2: Effects of noise pollution on birds: A brief review of our
knowledge. Ornithological Monographs 47: 6-22.
Stuart, J. N., M. L. Watson, T. L. Brown, and C. Eustice. 2001. Plastic netting: An
entanglement hazard to snakes and other wildlife. Herpetological Review
32:162–164.
Sheppard, C. D. 2019. Evaluating the relative effectiveness of patterns on glass as
deterrents of bird collisions with glass. Global Ecology and Conservation
20:e00795.
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Stone, E. L., G. Jones, and S. Harris. 2009. Street lighting disturbs commuting bats.
Current Biology 19:1123–1127. Elsevier Ltd.
Tabor, R. A., G. S. Brown, and V. T. Luiting. 2004. The effect of light intensity on
sockeye salmon fry migratory behavior and predation by cottids in the Cedar
River, Washington. North American Journal of Fisheries Management 24:128–
145.,
Van der Ree, R. 1999. Barbed wire fencing as a hazard for wildlife. The Victorian
Naturalist 116:210–217.
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“Provide a safe and reliable transportation network that serves all people and respects the environment”
DISTRICT 4 OFFICE OF TRANSIT AND COMMUNITY PLANNING P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660 www.dot.ca.gov
February 25, 2022 SCH #: 2021020064
GTS #: 04-SM-2021-00415
GTS ID: 21933
Co/Rt/Pm: SM/101/22
Billy Gross, Principal Planner
City of South San Francisco
315 Maple Avenue South San Francisco, CA 94080
Re: South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan Notice of Preparation (NOP)
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the South San Francisco General Plan Update,
Zoning Code Amendments, and Climate Action Plan (project). We are committed to
ensuring that impacts to the State’s multimodal transportation system and to our
natural environment are identified and mitigated to support a safe, sustainable,
integrated and efficient transportation system. The following comments are based on
our review of the revised January 2022 NOP.
Project Understanding
The project includes the update of the South San Francisco General Plan;
amendments to the Zoning Code; and the update of the Climate Action Plan. In
addition, the City of South San Francisco (City) will prepare a Draft Program
Environmental Impact Report (DEIR) for the project. The DEIR will evaluate potential
environmental impacts associated with adoption and implementation of the project.
The project encompasses the entire City and is located along segments of State Route
(SR)-82 (El Camino Real), Interstate (I)-280, and United States Route (US)-101.
Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient
development patterns, innovative travel demand reduction strategies, and
multimodal improvements. For more information on how Caltrans assesses
Transportation Impact Studies, please review Caltrans’ Transportation Impact Study
Guide (link). Please note that current and future land use projects proposed near and
Billy Gross, Principal Planner
February 25, 2022
Page 2
“Provide a safe and reliable transportation network that serves all people and respects the environment”
adjacent to the State Transportation Network (STN) shall be assessed, in part, through
the TISG.
Transportation Impact Fees
We encourage a sufficient allocation of fair share contributions toward multimodal
and regional transit improvements to fully mitigate cumulative impacts to regional
transportation. We also strongly support measures to increase sustainable mode
shares, thereby reducing VMT. Caltrans welcomes the opportunity to work with the
City and local partners to secure the funding for needed mitigation. Traffic mitigation-
or cooperative agreements are examples of such measures.
Lead Agency
As the Lead Agency, the City of South San Francisco is responsible for all project
mitigation, including any needed improvements to the State Transportation Network
(STN). The project’s fair share contribution, financing, scheduling, implementation
responsibilities and lead agency monitoring should be fully discussed for all proposed
mitigation measures.
Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet
American Disabilities Act (ADA) Standards after project completion. As well, the
project must maintain bicycle and pedestrian access during construction. These
access considerations support Caltrans’ equity mission to provide a safe, sustainable,
and equitable transportation network for all users.
Thank you again for including Caltrans in the environmental review process. Should
you have any questions regarding this letter, or for future notifications and requests for
review of new projects, please email [email protected].
Sincerely,
MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
COMMISSIONERS: MIKE O’NEILL, CHAIR, CITY ▪ ANN DRAPER, VICE CHAIR, PUBLIC ▪ HARVEY RARBACK, CITY ▪ DON HORSLEY, COUNTY
▪ WARREN SLOCUM, COUNTY ▪ JOSHUA COSGROVE, SPECIAL DISTRICT ▪ RIC LOHMAN, SPECIAL DISTRICT
ALTERNATES: KATI MARTIN, SPECIAL DISTRICT ▪ DIANA REDDY, CITY ▪ JAMES O’NEILL, PUBLIC ▪ DAVE PINE, COUNTY
STAFF: ROB BARTOLI, INTERIM EXECUTIVE OFFICER ▪ TIM FOX, LEGAL COUNSEL▪ ANGELA MONTES, CLERK
February 28, 2022
Sent Via Email
Mr. Billy Gross
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for the Proposed
South San Francisco General Plan Update, Zoning Code Amendments, and Climate
Action Plan
Mr. Billy Gross,
Thank you for the opportunity to comment on the Notice of Preparation for a Program
Environmental Impact Report for the Proposed South San Francisco General Plan Update,
Zoning Code Amendments, and Climate Action Plan.
The Local Agency Formation Commission (LAFCo) is a state mandated local agency established
in every county to oversee and regulate the boundaries of cities and special districts. San Mateo
LAFCo has jurisdiction over the boundaries of the 20 cities, 22 independent special districts, and
many of the 33 active county and city governed special districts serving San Mateo County.
The Existing Conditions section of the NOP identifies two unincorporated islands within the
Sphere of Influence of South San Francisco. The first is the California Golf Club area which
consists of the golf course, Ponderosa Elementary School, portions of Westborough Boulevard,
and a several parcels to the north of Westborough Boulevard. The second is the largely
residential area known as Country Club Park roughly bound by Conmur Street to the west,
Country Club Drive to the north, Alida Way to the east, and Northwood Drive to the south.
LAFCo supports the inclusion of these unincorporated areas within the General Plan study area.
LAFCo has the following comments regarding the NOP:
As part of the CEQA review and General Plan Update, the City should evaluate land uses and
infrastructure within the two unincorporated islands. While some properties are served by the
City’s public wastewater system, the majority of properties within the unincorporated area are
still served by on-site septic systems. In recent years, requests for properties to connect to the
City’s wastewater system have increased due to either failing septic systems or limitations of
February 28, 2022
Page 2
septic systems to support construction of additions to existing structures or the redevelopment
of these properties. The City’s current General Plan does not permit the City to annex individual
parcels in the Country Club Park area. The Plan states that no portion of the area should be
annexed unless the entire area is annexed.
LAFCo encourages the City to explore how to allow for annexations of the unincorporated
areas, through individual annexations, a phased approach, or annexation of the whole area. The
General Plan and CEQA documents should evaluate infrastructure needs, including sewer and
right-of-way improvements, of the unincorporated areas as well. The General Plan should
include the development of policies that support the creation of master plan for the
unincorporated areas that address infrastructure improvements, identifies funding for these
improvements, and assesses different approaches to annexation of the areas. LAFCo staff is
available for discussions with the City about the annexation process and the infrastructure
needs in the unincorporated areas of South San Francisco.
San Mateo LAFCo looks forward to reviewing all future environmental and planning documents
related to the General Plan Update.
Sincerely,
Rob Bartoli
Interim Executive Officer
February 28, 2022
Billy Gross, Principal Planner TRANSMITTED VIA E-MAIL and U.S. MAIL
City of South San Francisco [email protected]
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for Proposed South San
Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a
Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update (the
Proposed Project). We appreciate this opportunity to coordinate with the City of South San Francisco (the City) in
considering potential land use compatibility issues that the Proposed Project may pose and should address.
As described in the Notice of Preparation (NOP), the original NOP of a Program EIR for the General Plan Update was
circulated from February 3, 2021 to March 22, 2021. The Airport provided comments on the original NOP in a letter
dated March 22, 2021. Those original comments are included as an attachment to this letter. This revised NOP is being
circulated to provide the public with an opportunity to comment on changes that were made to the Project Description
related to net new housing units (from 14,324 to 17,531) and net new employment opportunities (from 13,352 to
80,944) to be incorporated into the General Plan Update. The proposed land use map (Exhibit 5 of the revised NOP)
does not appear to be changed from the original NOP. The revised NOP states that comments received on the original
NOP as well as comments received on the revised NOP will be considered part of the administrative record. As such,
the Airport maintains that the comments on the Proposed Project contained in the March 22, 2021 letter (attached)
remain valid. The main points from that letter include: 1) concerns that portions of proposed mixed-use residential
zones are within the Airport’s runway safety zone boundaries and the 65 decibel Community Noise Equivalent Level
noise contour, 2) concerns that proposed mixed-use residential zones East of Highway 101 could reduce the efficacy of
nighttime Airport departure procedures protecting residents, and 3) keeping the Airport apprised of any developments
regarding the proposal for a new vehicular bridge between Oyster Point and North Access Road.
The Airport appreciates your consideration of these comments. We look forward to reviewing the Draft Environmental
Impact Report when made public. If I can be of assistance as the City considers airport land use compatibility as they
relate to the General Plan update, Program EIR, or any future projects, please do not hesitate to contact me at (650) 821-
6678 or at [email protected].
Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
P.O. Box 8097
San Francisco, California 94128
Attachment
cc: Susy Kalkin, ALUC
Sean Charpentier, C/CAG
Audrey Park, SFO
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ATTACHMENT
Comment Letter from SFO to City of South San Francisco re: Notice of Preparation of a Program
Environmental Impact Report for Proposed South San Francisco General Plan Update (March 22, 2021)
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March 22, 2021
Billy Gross TRANSMITTED VIA EMAIL
Senior Planner [email protected]
City of South San Francisco
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for Proposed South San
Francisco General Plan Update
Dear Mr. Gross,
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a
Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update
(the project). We appreciate this opportunity to coordinate with the City of South San Francisco (the City) in
considering and evaluating potential land use compatibility issues that the project may pose and should address.
As described in the Notice of Preparation (NOP), the project site is the geographic limits of the City, in San
Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with, City and
County of San Francisco/SFO property boundaries. The City is primarily residential, with this use occupying
approximately 40% of its land area, followed by industrial/research and development (RD) at approximately 30%,
and parks/open space/common greens at approximately 10%. The NOP notes that presently there are about 150
acres of vacant land remaining in the City, which amounts to 3.4% of the City. This project will serve as a
blueprint for the City’s vision through the year 2040 and will replace the 1999 General Plan and inform updates to
the City’s Zoning Ordinance.
The City’s proposed changes are highlighted in Proposed Land Use Maps and, specifically, the Land Use Map
depicting the changes from the existing map (see Figure 1). This map highlights the concentration in change along
the U.S. Highway 101 (U.S. 101) corridor, the “East of 101” precinct including Oyster Point, and transit nodes
such as the San Bruno Bay Area Rapid Transit (BART) and South San Francisco BART and Caltrain stations,
which have been targeted for zoning intensification. The NOP notes that the project permits approximately 14,324
net new housing units and approximately 13,352 net new employment opportunities by 2040. This map highlights
that much of this change will come from intensifying land uses which were previously exclusively office/RD or
industrial under the 1999 General Plan to include mixed use or high-density mixed use, which would allow for
residential uses.
The Airport is concerned that much of the land slated for this change is closer to the Airport than the previous
General Plan’s housing element, and portions of the proposed mixed-use residential zones are within the Airport’s
runway safety zone boundaries and 65 decibel (dB) Community Noise Equivalent Level (CNEL) noise contour.
In the 1999 General Plan, the City acknowledged the significance of and retained areas east of U.S. 101 for cargo
handling and freight forwarder uses that support the cargo operations at SFO. The Airport appreciates that in the
intervening years, the City has successfully maintained these land uses east of U.S. 101, which enhance and
support the relationship among the City, its residents, and the Airport. These existing compatible land uses east of
U.S. 101 include industrial, warehousing, hotels, and office/RD. The Airport cautions against the project’s
proposed departure from this successful practice.
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Mr. Billy Gross March 22, 2021 Page 2 of 5
The close proximity of these areas to SFO would require developments to undergo federal, state, and local
regulatory review processes specific to airport noise, airspace safety, and other land use compatibility standards,
including 14 Code of Federal Regulations Part 77 regulations for the safety, efficient use, and preservation of
navigable airspaces. Airport staff encourages the City to work closely with the Airport Land Use Commission
(ALUC)1 to determine project consistency with the Comprehensive Airport Land Use Compatibility Plan for the
Environs of SFO (ALUCP)2 and other regulatory review procedures. The Program EIR should evaluate the
project for consistency with all ALUCP regulatory requirements and policies.
Figure 1: Proposed Changes from Existing Land Use Map (NOP of Program EIR Exhibit 5)
The ALUCP establishes policies, to ensure compatibility between the Airport and surrounding land uses and to
protect local residents and workers from adverse effects of airport operations. All three topics are based on
research into actual effects of airport operations on human health and safety.3
Noise: Reduce the potential number of future residents who could be exposed to noise effects from airport
and aircraft operations.
Safety: Minimize the potential number of future residents and land use occupants exposed to hazards
related to aircraft operations and/or catastrophic incidents.
Elevation/Height: Protect the navigable airspace around the Airport for the safe and efficient operation
of aircraft in flight.
1 State law requires an ALUC for every county with an airport in its jurisdiction. See Cal. Pub. Util. Code §§ 21670-21679.5.
In San Mateo County, the City/County Association of Governments of San Mateo County (C/CAG) board serves as the
ALUC.
2 State law requires the preparation of an ALUCP. See id. In 2012, C/CAG, in consultation with the Airport and surrounding
communities, adopted the current ALUCP, which addresses issues related to compatibility between airport operations and
surrounding proposed land use development, considering noise impacts, safety of persons on the ground and in flight, height
restrictions/airspace protection, and overflight notification.
3 California Department of Transportation (Caltrans) Division of Aeronautics, California Airport Land Use Planning
Handbook, October 2011.
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Most of the City, and all of the areas of proposed land use intensification around and to the east of U.S. 101, are
located within the ALUCP Airport Influence Areas A and B (see Figure 2). The ALUCP requires all residential
development within Area A, which is the entirety of San Mateo County, to provide real estate disclosures, a copy
of which can be found at ALUCP Appendix G-7. Additionally, within the more restrictive Area B, “the ALUC
[the C/CAG Board] shall exercise its statutory duties to review proposed land use policy actions, including new
general plans, specific plans, zoning ordinances, plan amendments and rezoning, and land development
proposals.”4 The City must accordingly submit the proposed general plan update to the ALUC for review.
Figure 2: ALUCP-defined boundaries affecting South San Francisco (ALUCP Exhibit IV-3)
With respect to noise compatibility, portions of the project are situated within the Airport’s 65 dB CNEL noise
contour, and some even within the 70 dB contour. The ALUCP policies for noise are to protect the comfort and
quality of life of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher
contours. To the extent that the project would allow such uses, the Program EIR must disclose and evaluate any
inconsistency with the ALUCP. The ALUCP requires the grant of an avigation easement to the City and County
of San Francisco, as the proprietor of SFO, as a condition of allowing residential development within the 65 dB
contour.5 While avigation easements are an important mitigation tool, they do not replace the imperative to avoid
introducing incompatible uses into a noise-affected area in the first place. As shown in ALUCP Table IV-1,
residential uses are not compatible within the 70 dB contour and higher, and the Program EIR should evaluate
them as such.
Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap or Oyster
Point, including one procedure, the Shoreline Departure visual procedure, which is a noise abatement procedure
designed specifically to keep aircraft over the industrial areas of the City east of U.S. 101 and away from its
traditional residential areas. Any residential developments east of U.S. 101 could reduce the efficacy of the
Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to protect residents
of South San Francisco, Daly City, and Pacifica by maximizing flights over water and industrial areas between
4 ALUCP IP-2 (Airport Influence Area B – Policy/Project Referral Area), p. IV-11.
5 ALUCP NP-3.
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Mr. Billy Gross March 22, 2021 Page 4 of 5
1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise
disturbances from aircraft departures. The Program EIR should evaluate these potential environmental impacts of
the project. The Airport also urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the project as it relates to the existing and long-established
aircraft noise abatement procedures to the City and adjacent cities.
Any proposed residential uses outside of the 65 dB contour should still meet the interior noise requirements of the
California Building Code. Noise impacts on sensitive receptors and any necessary mitigation measures should be
fully evaluated in the Program EIR, and the EIR should describe the project’s consistency with noise policies
described in ALUCP, including noise policies NP-1 through NP-4.
The Airport understands and supports the City’s efforts to address the region’s housing supply shortage with its
General Plan update. SFO has felt the effects of the housing crisis firsthand, with many people who work at the
Airport forced to finding housing 60 miles away, or farther. This places a considerable hardship on the
employees, Airport, neighboring communities, and the regional surface transportation system, and we would
welcome affordable, transit-oriented housing closer to the Airport. However, subjecting new residents to
excessive aircraft noise is not an equitable solution. SFO requests that the City revise its proposals for residential
and mixed uses away from the 65 dB CNEL contour, including the southern portions of Highway 101 and San
Bruno BART station. Any upzoning proposed along the City’s commercial core along Grand Avenue or higher
density around South San Francisco BART station would be outside of the critical 65 dB CNEL contour and
would not pose these concerns.
Figure 3: SFO runway safety compatibility zones around South San Francisco (ALUCP Exhibit IV-8)
With respect to safety, the southern portions of the General Plan area are within various runway end safety zones,
including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer Approach/Departure Zone (see
Figure 3). Each of these zones carry restrictions on what may be located there, based on the safety compatibility
criteria and guidelines from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already recognizes the
intense level of existing development in the vicinity of SFO, and the Airport recommends against overriding these
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Mr. Billy Gross March 22, 2021 Page 5 of 5
restrictions. The Program EIR should also describe and evaluate the project’s consistency with land use criteria
within these runway end safety zones, as described in ALUCP SP-1 through SP-3.
With respect to elevation, the Airport appreciates the City’s commitment to protecting the critical airspace
surfaces defined in the ALUCP, as these surfaces protect the safety and economic vitality of the Airport and the
City. The Airport has observed several points of confusion regarding airspace surfaces and requests that the City
work with SFO staff to ensure the accuracy of the guidance provided in the General Plan Update.
For example, all critical airspace surfaces are based on elevation above mean sea level (AMSL) – not height
above ground level (AGL). Therefore, if the General Plan Update establishes height restrictions, it should note
them in AMSL rather than AGL and incorporate by reference the most recently adopted version of the ALUCP. It
should also note that the finished height of any proposed development must be maintained below these clearance
limits, including architectural parapets, machine rooms, antennas, etc. The Airport suggests that any exhibits
included in the General Plan Update should include prominent notes which address these common concerns.
Finally, the General Plan Update also proposes a new vehicular bridge between Oyster Point, likely around the
southern end of Haskins Way, and North Access Road on Airport property. While we understand this may be
highly notional, if the City does intend to pursue the concept, the Program EIR should fully evaluate it. We also
request that the City keep the Airport apprised of any developments regarding this proposal, which would require
close coordination with the Airport. For example, the Airport would need to understand vehicular movements and
how the bridge could increase or redistribute traffic on the Airport’s roadways and intersection with Interstate 380
in deciding whether to support the project.
The Airport appreciates your consideration of these comments. If I can be of assistance as the City considers
airport land use compatibility as they relate to the General Plan update, Program EIR, or any future projects,
please do not hesitate to contact me at (650) 821-9464 or at [email protected].
Sincerely,
Nupur Sinha
Acting Planning Director
Planning and Environmental Affairs
cc: Susy Kalkin, Airport Land Use Committee
Sandy Wong, C/CAG
Audrey Park, SFO, Acting Environmental Affairs Manager
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State of California – Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director
Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
March 10, 2021
Mr. Billy Gross
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
[email protected]
Subject: South San Francisco General Plan Update, Notice of Preparation of a
Program Environmental Impact Report, SCH No. 2021020064, City of South
San Francisco, San Mateo County
Dear Mr. Gross:
The California Department of Fish and Wildlife (CDFW) reviewed the Notice of
Preparation (NOP) of a draft Program Environmental Impact Report (EIR) for the City of
South San Francisco General Plan Update (Project).
CDFW is a Trustee Agency with responsibility under the California Environmental
Quality Act (CEQA) for commenting on projects that could impact fish, plant, and wildlife
resources (Pub. Resources Code, § 21000 et seq.; Cal. Code Regs., tit. 14, § 15386).
CDFW is also considered a Responsible Agency if a project would require discretionary
approval, such as a California Endangered Species Act (CESA) Incidental Take Permit
(ITP), a Native Plant Protection Act (NPPA) Permit, a Lake and Streambed Alteration
(LSA) Agreement, or approval under other provisions of the Fish and Game Code that
afford protection to the state’s fish and wildlife trust resources. Pursuant to our authority,
CDFW has the following concerns, comments, and recommendations regarding the
Project.
PROJECT LOCATION AND DESCRIPTION
The Project is located in the City of South San Francisco (City), San Mateo County,
California. The City is located in a basin bounded by the San Bruno Mountains to the
north, the Pacific Coast Ranges to the west, and the San Francisco Bay to the east. The
City is bordered by the City of Brisbane to the north, Daly City, City of Pacifica, and the
Town of Coloma to the west, and the City of San Bruno to the south. The City
encompasses 31 square miles, approximately 5,000 acres, and is primarily built out with
only about 3.4 percent of the land classified as vacant.
The Project includes an update to the City’s General Plan. The General Plan Update will
serve as the blueprint for the City’s vision throughout the year 2040. The goals, priorities,
and actions in the proposed General Plan Update will serve as a compass for decision-
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City of South San Francisco
March 10, 2021
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makers and will shape future plans and actions for the City. This revised document will
replace the 1999 General Plan and will inform updates to the City’s Zoning Ordinance.
The General Plan Update anticipates approximately 14,324 new housing units.
COMMENTS AND RECOMMENDATIONS
COMMENT 1: Project Description
The CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.) require that the draft
EIR incorporate a full Project description, including reasonably foreseeable future phases
of the Project, that contains sufficient information to evaluate and review the Project’s
environmental impact (CEQA Guidelines, §§ 15124 and 15378). Please include a
complete description of the following Project components in the project description:
Footprints of permanent Project features and temporarily impacted areas, such
as staging areas and access routes.
Plans and dimensions for any proposed buildings/structures, ground disturbing
activities, fencing, paving, stationary machinery, landscaping, and stormwater
systems.
Operational features of the Project, including level of anticipated human
presence (describe seasonal or daily peaks in activity, if relevant), artificial
lighting/light reflection, noise, traffic generation, and other features.
Construction schedule, activities, equipment, and crew sizes.
The draft EIR is identified as a program EIR. While program EIRs have a necessarily
broad scope, CDFW recommends providing as much information related to anticipated
future activities as possible. CDFW recognizes that, pursuant to CEQA Guidelines
section 15152, subdivision (c), if a Lead Agency is using the tiering process in
connection with an EIR or large-scale planning approval, the development of detailed,
site-specific information may not be feasible and can be deferred, in many instances,
until such time as the Lead Agency prepares a future environmental document. This
future environmental document would cover a project of a more limited geographical
scale and is appropriate if the deferred information does not prevent adequate
identification of significant effects of the planning approval at hand. Based on CEQA
Guidelines section 15183.3 and associated Appendix N Checklist, and consistent with
other program EIRs, CDFW recommends creating a procedure or checklist for
evaluating subsequent project impacts on biological resources to determine if they are
within the scope of the program EIR or if an additional environmental document is
warranted. This checklist should be included as an attachment to the draft EIR. Future
analysis should include all special-status species including but not limited to species
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City of South San Francisco
March 10, 2021
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considered rare, threatened, or endangered species pursuant to CEQA Guidelines,
section 15380. The checklist should cite the specific portions of the draft EIR, including
page and section references, include an analysis of the subsequent project activities’
potentially significant effects, and incorporate all applicable mitigation measures from
the draft EIR.
COMMENT 2: Environmental Setting
The draft EIR should provide sufficient information regarding the environmental setting
(“baseline”) to understand the project’s, and its alternative’s (if applicable), potentially
significant impacts on the environment (CEQA Guidelines, §§ 15125 and 15360).
CDFW recommends that the draft EIR provide baseline habitat assessments for
special-status plant, fish, and wildlife species located and potentially located within the
Project area and surrounding lands, including but not limited to all rare, threatened, or
endangered species (CEQA Guidelines, § 15380). The draft EIR should describe
aquatic habitats, such as wetlands and/or waters of the U.S. or State, and any sensitive
natural communities or riparian habitat occurring on or adjacent to the Project sites.
Fully protected, threatened or endangered, and other special-status species that are
known to occur, or have the potential to occur in or near the Project sites, include, but
are not limited to:
American peregrine falcon (Falco peregrinus anatum), SFP
Alameda song sparrow (Melospiza melodia pusillula), SSC
California Ridgeway’s rail (Rallus obsoletus obsoletus), FE, SE, SFP
San Francisco garter snake (Thamnophis sirtalis tetrataenia), FE, SE
Longfin smelt (Spirinchus thaleichthys), FC, ST
San Francisco owl’s clover (Triphysaria floribunda), 1B.2
Congested-headed hayfield tarplant (Hemizonia congesta ssp. congesta), 1B.2
Robust spineflower (Chorizanthe robusta var. robusta), FE, 1B.1
Point Reyes horkelia (Horkelia marinensis), 1B.2
Kellogg’s horkelia (Horkelia cuneata var. sericea), 1B.1
Two-fork clover (Trifolium amoenum), FE, 1B.1
Western bumble bee (Bombus occidentalis), ICP
Mission blue butterfly (Plebejus icarioides missionensis), FE
Callippe silverspot butterfly (Speyeria callippe callippe), FE
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City of South San Francisco
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Nesting and migratory birds
Bat species
FE = Federally Endangered; FT = Federally Threatened; FC= Federal Candidate; SE = State
Endangered; SFP = State Fully Protected; SSC = State Species of Special Concern; ICP= California
Terrestrial and Vernal Pool Invertebrate of Conservation Priority
CNPS Plant Ranks
1B = Rare, Threatened, or Endangered in California and Elsewhere
2A = Presumed Extirpated in California, But Common Elsewhere
2B = Rare, Threatened, or Endangered in California, But More Common
Elsewhere
CNPS Threat Ranks
0.1-Seriously threatened in California (over 80% of occurrences threatened/high
degree and immediacy of threat)
0.2-Moderately threatened in California (20-80% occurrences
threatened/moderate degree and immediacy of threat)
0.3 Not very threatened in California (less than 20% of occurrences
threatened/low degree and immediacy of threat or no current threats known)
Habitat descriptions, and the potential for species occurrence, should include
information from multiple sources: aerial imagery; historical and recent survey data; field
reconnaissance; scientific literature and reports; the U.S. Fish and Wildlife Service’s
(USFWS) Information, Planning, and Consultation System; and findings from positive
occurrence databases such as California Natural Diversity Database (CNDDB). Based
on the data and information from the habitat assessment, the draft EIR should
adequately assess which special-status species are likely to occur on or near the
Project site, and whether they could be impacted by the Project.
CDFW recommends that prior to Project implementation, surveys be conducted for
special-status species with potential to occur, following recommended survey protocols
if available. Survey and monitoring protocols and guidelines are available at:
https://wildlife.ca.gov/Conservation/Survey-Protocols.
Botanical surveys for special-status plant species, including those with a California Rare
Plant Rank (http://www.cnps.org/cnps/rareplants/inventory/), must be conducted during
the blooming period for all species potentially impacted by the Project within the Project
area and adjacent habitats that may be indirectly impacted by, for example, changes to
hydrology, and require the identification of reference populations. Please refer to CDFW
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City of South San Francisco
March 10, 2021
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protocols for surveying and evaluating impacts to rare plants, and survey report
requirements, available at: https://wildlife.ca.gov/Conservation/Plants.
COMMENT 3: Impact Analysis and Mitigation Measures
The draft EIR should include the reasonably foreseeable direct and indirect changes
(temporary and permanent) that may occur with implementation of the Project (CEQA
Guidelines, §§ 15126, 15126.2, and 15358). This includes evaluating and describing
impacts such as:
Encroachments into riparian habitats, wetlands, or other sensitive areas;
Potential for impacts to special-status species;
Loss or modification of breeding, nesting, dispersal and foraging habitat,
including vegetation removal, alteration of soils and hydrology, and removal of
habitat structural features (e.g., snags, rock outcrops, overhanging banks);
Permanent and temporary habitat disturbances associated with ground
disturbance, noise, lighting, reflection, air pollution, traffic, or human presence;
and
Obstruction of movement corridors, fish passage, or access to water sources and
other core habitat features.
The draft EIR should also identify reasonably foreseeable future projects in the Project
vicinity, disclose any cumulative impacts associated with these projects, determine the
significance of each cumulative impact, and assess the significance of the Project’s
contribution to the impact (CEQA Guidelines, § 15355). Although a project’s impacts
may be less-than-significant individually, its contributions to a cumulative impact may be
considerable; a contribution to a significant cumulative impact, e.g., reduction of habitat
for a special-status species should be considered cumulatively considerable.
Based on the comprehensive analysis of the direct, indirect, and cumulative impacts of
the Project, the CEQA Guidelines direct the Lead Agency to consider and describe all
feasible mitigation measures to avoid potentially significant impacts in the draft EIR and
mitigate potentially significant impacts of the Project on the environment (CEQA
Guidelines, §§ 15021, 15063, 15071, 15126.4, and 15370). This includes a discussion
of impact avoidance and minimization measures for special-status species, which are
recommended to be developed in early consultation with CDFW, the USFWS, and the
National Marine Fisheries Service. These measures should be incorporated as
enforceable Project conditions to reduce impacts to biological resources to less-than-
significant levels.
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Fully protected species, such as American peregrine falcon and California Ridgeway’s
rail, may not be taken or possessed at any time (Fish and Game Code, § 3511, 4700,
5050, and 5515). Therefore, the draft EIR should include measures to ensure complete
avoidance of these species.
COMMENT 4: Artificial Lighting
Issue: The Project may increase artificial lighting. Artificial lighting often results in light
pollution, which has the potential to significantly and adversely affect biological
resources. Night lighting can disrupt the circadian rhythms of many wildlife species.
Many species use photoperiod cues for communication (e.g., bird song), determining
when to begin foraging (Stone et al. 2009), behavior thermoregulation (Beiswenger
1977), and migration (Longcore and Rich 2004).
Recommendations to minimize significant impacts: CDFW recommends eliminating
all non-essential artificial lighting. If artificial lighting is necessary, CDFW recommends
avoiding or limiting the use of artificial lights during the hours of dawn and dusk, when
many wildlife species are most active. CDFW also recommends that outdoor lighting be
shielded, cast downward, and does not spill over onto other properties or upwards into
the night sky. In addition, lights can be motion-activated, or turned off or dimmed during
critical times of the year (e.g., migration) or during times of night that have the most
significant impact on wildlife (i.e., dawn and dusk) (Gaston et al., 2012, 2013). Lights
with wildlife-friendly spectral composition (i.e., minimize light avoidance/attraction) can
also be used (Gaston et al. 2012, 2013). LED lights are well suited for operating at
variable brightness and being switched off or dimmed during certain times of the year or
during times of low demand, as they operate at full efficiency and have no “warm-up”
time (Gaston et al., 2012, 2013). Vegetation may also be used to shield sensitive areas
against light, and light-absorbent surfaces can be used in in place of reflective surfaces
(Gaston et al., 2012, 2013). See the International Dark-Sky Association standards at
http://darksky.org/.
COMMENT 5: Exterior Windows
Issue: The glass used for exterior building windows could result in bird collisions, which
can cause bird injury and mortality. Birds typically do not see clear or reflective glass,
and can collide with glass (e.g., windows) that reflect surrounding landscape and/or
habitat features (Klem and Saenger 2013, Sheppard 2019). When birds collide with
glass, they can be injured or killed. In the United States, the estimated annual bird
mortality is between 365-988 million birds (Loss et al. 2014).
Recommendations to minimize significant impacts: CDFW recommends
incorporating visual signals or cues to exterior windows to prevent bird collisions. Visual
signals or cues include, but are not limited to, patterns to break up reflective areas,
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external window films and coverings, ultraviolet patterned glass, and screens. For best
practices on how to reduce bird collisions with windows, please go to the USFWS’
website for Buildings and Glass (https://www.fws.gov/birds/bird-enthusiasts/threats-to-
birds/collisions/buildings-and-glass.php).
COMMENT 6: State Fully Protected Species
State fully protected species may occur within the Project area. CDFW has jurisdiction
over fully protected species of birds, mammals, amphibians, reptiles, and fish pursuant
to Fish and Game Code §§ 3511, 4700, 5050, and 5515. Take, as defined by Fish and
Game Code § 86 is to “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue,
catch, capture, or kill”, take of any fully protected species is prohibited and CDFW
cannot authorize their incidental take.
Without appropriate avoidance and minimization measures, Project activities may cause
potentially significant impacts to fully protected species including, but not limited to the
following: inadvertent entrapment, reduced reproductive success, reduced health and
vigor, nest abandonment, loss of nest trees, and/or loss of foraging habitat that would
reduce nesting success (loss or reduced health or vigor of eggs or young), and direct
mortality.
To evaluate and avoid potential impacts to fully protected species, CDFW recommends
incorporating the following mitigation measures into the Project’s draft EIR, and that
these measures be made conditions of approval for the Project.
Recommended Mitigation Measures:
Fully Protected Species Surveys
To avoid impacts to fully protected species, CDFW recommends that a qualified
biologist conduct species-specific surveys (using standard protocol or methodology, if
available) of the Project site before Project implementation. If Project activities will take
place when fully protected species are active or are breeding, CDFW recommends that
additional pre-activity surveys for active nests or individuals be conducted by a qualified
biologist no more than seven (7) days prior to the start or restart of Project construction
and every 14 days during Project construction.
Fully Protected Species Avoidance
In the event a fully protected species is found within or adjacent to the Project site,
CDFW recommends that a qualified wildlife biologist develops an appropriate no-
disturbance buffer to be implemented. The qualified biologist should also be on-site
during all Project activities to ensure that the fully protect species is not being disturbed
by Project activities.
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COMMENT 7: Special-Status Species Surveys
Special-status species may occur in the Project area. Without appropriate mitigation
measures, the Project could potentially have a significant impact on these species.
CDFW recommends that before future project implementation, special-status species
surveys be conducted for species that have the potential to occur or will be impacted by
the project implementation. CDFW recommends, if available, using established species
survey protocols. Survey and monitoring protocols and guidelines are available at:
https://wildlife.ca.gov/Conservation/Survey-Protocols.
COMMENT 8: Nesting Birds
Issue: CDFW encourages that Project implementation occur during the bird non-nesting
season; however, if ground-disturbing or vegetation-disturbing activities must occur
during the breeding season (February through early-September), the Project applicant
is responsible for ensuring that implementation of the Project does not result in violation
of the Migratory Bird Treaty Act or Fish and Game Codes.
To evaluate and avoid for potential impacts to nesting bird species, CDFW recommends
incorporating the following mitigation measures into the Project’s draft EIR, and that
these measures be made conditions of approval for the Project.
Recommended Mitigation Measures:
Nesting Bird Surveys
CDFW recommends that a qualified avian biologist conduct pre-Project activity nesting
bird surveys no more than seven (7) days prior to the start of ground or vegetation
disturbance, and every fourteen (14) days during Project activities to maximize the
probability that nests are detected. CDFW recommends that nesting bird surveys cover
a sufficient area around the Project area to identify nests and determine their status. A
sufficient area means any area potentially affected by the Project.
During nesting bird surveys, CDFW recommends that a qualified avian biologist
establish behavioral baseline of all identified nests. During Project activities, CDFW
recommends having the qualified avian biologist continuously monitor nests to detect
behavioral changes resulting from Project activities. If behavioral changes occur, CDFW
recommends stopping the activity, that is causing the behavioral change, and consulting
with a qualified avian biologist on additional avoidance and minimization measures.
Nesting Bird Buffers
During Project activities, if continuous monitoring of nests by a qualified avian biologist
is not feasible, CDFW recommends a minimum no-disturbance buffer of 250 feet
around active nests of non-listed bird species and a 1,000-foot no-disturbance buffer
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around active nests of non-listed raptors. These buffers are advised to remain in place
until the breeding season has ended or until a qualified avian biologist has determined
that the birds have fledged and are no longer reliant upon the nest or on-site parental
care for survival. Variance from these no-disturbance buffers is possible when there is
compelling biological or ecological reason to do so, such as when the Project area
would be concealed from a nest site by topography. CDFW recommends that a qualified
avian biologist advise and support any variance from these buffers.
COMMENT 9: Bats
Bat species may occur within and surrounding the project site, including in buildings. To
evaluate and avoid potential impacts to bat species, CDFW recommends incorporating
the following mitigation measures into the Project’s draft EIR, and that these measures
be made conditions of approval for the Project.
Bat Habitat Assessment
To evaluate Project impacts to bats, a qualified bat biologist should conduct a habitat
assessment for bats at work sites seven (7) days prior to the start of Project activities
and every fourteen (14) days during Project activities. The habitat assessment shall
include a visual inspection of features within 50 feet of the work area for potential
roosting features (bats need not be present). Habitat features found during the survey
shall be flagged or marked.
Bat Habitat Monitoring
If any habitat features identified in the habitat assessment will be altered or disturbed by
Project construction, the qualified bat biologist should monitor the feature daily to
ensure bats are not disturbed, impacted, or fatalities are caused by the Project.
Bat Project Avoidance
If bat colonies are observed at the Project site, at any time, all Project activities should
stop until the qualified bat biologist develops a bat avoidance plan to be implement at
the Project site. Once the plan is implemented, Project activities may recommence.
REGULATORY REQUIREMENTS
California Endangered Species Act
Please be advised that a CESA ITP must be obtained if the Project has the potential to
result in take1 of plants or animals listed under CESA, either during construction or over
the life of the Project. Issuance of a CESA Permit is subject to CEQA documentation;
1 Take is defined in Fish and Game Code section 86 as hunt, pursue, catch, capture, or kill, or attempt
any of those activities.
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the CEQA document must specify impacts, mitigation measures, and a mitigation
monitoring and reporting program. If the Project will impact CESA listed species, early
consultation is encouraged, as significant modification to the Project and mitigation
measures may be required to obtain a CESA ITP.
CEQA requires a Mandatory Finding of Significance if a project is likely to substantially
restrict the range or reduce the population of a threatened or endangered species (Pub.
Resources Code, §§ 21001, subd. (c), 21083; CEQA Guidelines, §§ 15380, 15064, and
15065). Impacts must be avoided or mitigated to less-than-significant levels unless the
CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).
The Lead Agency’s FOC does not eliminate the project proponent’s obligation to comply
with CESA.
Lake and Streambed Alteration Agreement
CDFW requires an LSA Notification, pursuant to Fish and Game Code section 1600 et
seq., for Project activities affecting lakes or streams and associated riparian habitat.
Notification is required for any activity that may substantially divert or obstruct the
natural flow; change or use material from the bed, channel, or bank including associated
riparian or wetland resources; or deposit or dispose of material where it may pass into a
river, lake, or stream. Work within ephemeral streams, washes, watercourses with a
subsurface flow, and floodplains are subject to notification requirements. CDFW, as a
Responsible Agency, will consider the CEQA document for the Project and may issue
an LSA Agreement. CDFW may not execute the final LSA Agreement until it has
complied with CEQA as a Responsible Agency.
Migratory Birds and Raptors
CDFW also has authority over actions that may disturb or destroy active nest sites or
take birds. Fish and Game Code sections 3503, 3503.5, and 3513 protect birds, their
eggs, and nests. Fully protected species may not be taken or possessed at any time
(Fish and Game Code, § 3511). Migratory birds are also protected under the federal
Migratory Bird Treaty Act.
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and
negative declarations be incorporated into a database which may be used to make
subsequent or supplemental environmental determinations. [Pub. Resources Code, §
21003, subd. (e)]. Accordingly, please report any special-status species and natural
communities detected during Project surveys to CNDDB. The CNNDB online field
survey form and other methods for submitting data can be found at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported
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to CNDDB can be found at the following link: https://wildlife.ca.gov/Data/CNDDB/Plants-
and-Animals.
FILING FEES
CDFW anticipates that the Project will have an impact on fish and/or wildlife, and
assessment of filing fees is necessary (Fish and Game Code, § 711.4; Pub. Resources
Code, § 21089). Fees are payable upon filing of the Notice of Determination by the
Lead Agency and serve to help defray the cost of environmental review by CDFW.
If you have any questions, please contact Ms. Stephanie Holstege, Environmental
Scientist, at [email protected]; or Mr. Wes Stokes, Senior
Environmental Scientist (Supervisory), at [email protected].
Sincerely,
Gregg Erickson
Regional Manager
Bay Delta Region
cc: State Clearinghouse (SCH No. 2021020064)
REFERENCES
Beiswenger, R. E. (1977). Diet patterns of aggregative behavior in tadpoles of Bufo
americanus, in relation to light and temperature. Ecology 58:98–108.
Bottalico, Pasquale & Spoglianti, Dorina & Bertetti, Carlo & Falossi, Marco. 2015. Effect
of noise generated by construction sites on birds, paper presented at Internoise
2015, International Congress and Exposition on Noise Control Engineering
Gaston, K. J., Davies, T. W., Bennie, J., & Hopkins, J. (2012). Reducing the ecological
consequences of night‐time light pollution: options and developments. Journal of
Applied Ecology, 49(6), 1256-1266.
Gaston, K. J., Bennie, J., Davies, T. W., & Hopkins, J. (2013). The ecological impacts of
nighttime light pollution: a mechanistic appraisal. Biological reviews, 88(4), 912-
927.
Klem, D. and P. G. Saenger. 2013. Evaluating the Effectiveness of Select Visual
Signals to Prevent Bird-window Collisions. The Wilson Journal of Ornithology
125(2):406-411
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Kyba, C. C., & Hölker, F. (2013). Do artificially illuminated skies affect biodiversity in
nocturnal landscapes?.
Longcore, T., & Rich, C. (2004). Ecological light pollution. Frontiers in Ecology and the
Environment, 2(4), 191-198.
Loss, S.R., T. Will, S.S. Loss, and P.P. Marra. 2014. Bird-building collisions in the
United States: estimates of annual mortality and species vulnerability. Condor
116: 8-23.
Ortega, C. P. 2012. Chapter 2: Effects of noise pollution on birds: A brief review of our
knowledge. Ornithological Monographs 47: 6-22
Sheppard, C. D. 2019. Evaluating the relative effectiveness of patterns on glass as
deterrents of bird collisions with glass. Global Ecology and Conservation
20:e00795
Stone, E. L., G. Jones, and S. Harris (2009). Street lighting disturbs commuting bats.
Current Biology 19:1123–1127. Elsevier Ltd.
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From: Frost, Erik@DOC <[email protected]>
Sent: Monday, March 15, 2021 10:04 AM
To: Gross, Billy <[email protected]>
Cc: [email protected]; OLRA@DOC <[email protected]>
Subject: Comments ‐ NOP for South San Francisco General Plan update (SCH 2021020064)
Dear Mr. Gross,
The California Geological Survey (CGS) has received the Notice of Preparation of a Program Environmental
Impact Report (EIR) for the City of South San Francisco General Plan Update. This letter conveys the following
suggestions and recommendations from CGS concerning geologic and soils issues related to the planning area:
1. Geologic Hazards
Several potential geologic hazards exist within the planning area. Each of the hazards listed below
should be addressed in the General Plan update.
a. Liquefaction and Landslide Hazards
The California Geological Survey is releasing new Zones of Required Investigation (ZORIs) under the
Seismic Hazard Mapping Act (SHMA) for both liquefaction and earthquake‐induced landslides for
the San Francisco South 7.5‐minute quadrangle, in which the City of South San Francisco is
located. The mapping indicates that these hazards potentially exist within the planning area as
your previous general plan indicates. CGS released the preliminary map for review and comment
by the impacted lead agencies on February 18, 2021.
The soon‐to‐be published map and report also include updated landslide mapping, a new geologic
map compilation of both Quaternary and Bedrock geology, and the latest ground motion
estimates. CGS used geotechnical reports collected from the cities and San Mateo County within
the San Francisco South 7.5‐minute quadrangle to determine geotechnical characteristics of
surficial geologic units. CGS used groundwater data from the California State GAMA database and
geotechnical borings to determine depth to historical high shallow ground water. This information
was used to define the ZORIs. The preliminary maps are subject to a 3‐month public review period
and a 3‐month revision period based on any comments received, after which the maps will be
finalized and become official.
The SHMA of 1990 (Public Resources Code, Chapter 7.8, Section 2690‐2699.6) directs the
Department of Conservation, California Geological Survey to identify and map areas prone to
earthquake hazards of liquefaction, earthquake‐induced landslides and amplified ground shaking.
The purpose of the SHMA is to reduce the threat to public safety and to minimize the loss of life
and property by identifying and mitigating these seismic hazards. The SHMA was passed by the
legislature following the 1989 Loma Prieta earthquake.
The SHMA requires the State Geologist to establish regulatory zones (Earthquake Zones of
Required Investigation) and to issue appropriate maps (Seismic Hazard Zone maps). These maps
are distributed to all affected cities, counties, and state agencies for their use in planning and
controlling construction and development. Single family frame dwellings up to two stories not part
of a development of four or more units are exempt from the state requirements. However, local
agencies can be more restrictive than state law requires. Additional information can be found at
the following website: https://www.conservation.ca.gov/cgs/shma.
b. Faulting Hazards
CGS has established Earthquake Fault Zones within and nearby the planning area. Specifically,
Holocene‐active strands of the San Andreas fault zone traverse the planning area. Digital versions
of these maps (PDF and Shapefiles) and associated reports can be downloaded from the CGS
Information Warehouse, here:
https://maps.conservation.ca.gov/cgs/informationwarehouse/regulatorymaps/.
c. Ground Shaking Hazards
The planning area is located near a number of active faults capable of producing severe ground
shaking during an earthquake. The EIR should include a discussion of nearby active faults and the
relative likelihood of the planning area to experience strong ground shaking. The earthquake
shaking potential for various regions of California can be viewed at the following website:
https://www.conservation.ca.gov/cgs/psha.
d. New Tsunami Hazard Area maps, future Tsunami Regulatory Zones, and Maritime Tsunami
Hazards
CGS is planning to release new Tsunami Hazard Area maps for San Mateo County on 23 March
2021. These maps will replace the 2009 Tsunami Inundation Maps for Emergency Planning and are
for evacuation planning purposes only.
In addition, in the next 4‐6 months, CGS is planning to release new Tsunami Regulatory Zones
under SHMA. These maps will require investigations in planned Tsunami Regulatory Engineering
Subzones and evacuation planning measures in both the larger Tsunami Regulatory Zone and the
Engineering Subzone. Guidance and supporting products will be provided on the SHMA website
for community and project‐level officials.
Harbors and marinas are the most prone to tsunami hazards because they are on the
water. Oyster Point Harbor and Oyster Cove Marina are both susceptible to tsunami
hazards. Harbor structures, infrastructure, and vessels are all vulnerable to damage and people in
and around the harbors could be injured. The following website has been developed to provide
guidance and products for maritime communities with regard to tsunami hazards:
https://sites.google.com/view/tsunami‐maritime‐guidance/home.
2. Regional and Site‐Specific Geology
The Program EIR should include a brief discussion of the geologic history of the area and a description
of the rock types in the planning area.
3. Soils
The Program EIR should consider including a summary of the types of soils present in the planning
area, as well as a discussion of the soils characteristics pertinent to development, such as source
material, geographic setting, drainage characteristics, permeability, and the risk of erosion and soil
expansion. The National Resources Conservation Service has an interactive soil map available at the
following website: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx
Please let me know if you have any questions or concerns with the comments in this letter.
Sincerely,
Erik Frost
Dr. Erik Frost
Senior Engineering Geologist | Seismic Hazards Program
California Geological Survey
801 K Street, MS 12-31, Sacramento, CA 95814
(916) 205-8255
[email protected]
375 BEALE STREET, SUITE 600 • SAN FRANCISCO CA • 94105 • 415.771.6000 • www.baaqmd.gov
March 18, 2021
Mr. Billy Gross
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
RE: City of South San Francisco General Plan Update – Notice of Preparation
Dear Mr. Gross,
Bay Area Air Quality Management District (Air District) staff has reviewed the
Notice of Preparation (NOP) for the City of South San Francisco General Plan
Update (General Plan) Draft Program Environmental Impact Report (Program
DEIR). The General Plan will serve as the blueprint for the City through the year
2040. The goals, policies, and actions in the proposed General Plan will serve as a
compass for decision-makers and will shape the City’s future plans and actions.
This revised document will replace the 1999 General Plan and will inform updates
to the City’s Zoning Ordinance.
Air District staff commends the City for its work to increase density, housing, and
new employment opportunities by 2040 through the General Plan. Air District staff
also applaud the City for its inclusion of affordable neighborhoods and a
convenient, accessible transportation network in the General Plan’s guiding
principles. Having transportation options, such as bicycle and pedestrian support,
as well as public transit, supports the Air District’s climate and air quality goals by
reducing vehicle miles traveled.
Air District staff recommends the Program DEIR include the following information
and analyses:
• The DEIR should estimate and evaluate the potential health risk to
existing and future sensitive populations within the Plan area from Toxic
Air Contaminants (TACs) and fine particulate matter (PM2.5) because of
construction and operations anticipated under the Plan. The General Plan
includes new land uses in areas previously zoned for industrial use.
Changing Industrial Zones to High Density Mixed Use Zones, which includes
housing and other uses for sensitive receptors, may result in new
exposures of sensitive receptors to TACs and PM2.5. Thus, Air District staff
recommends that the DEIR evaluate potential cumulative health risk
impacts of TACs and PM2.5 emissions on sensitive receptors within the Plan
area.
ALAMEDA COUNTY John J. Bauters (Secretary) Pauline Russo Cutter David Haubert Nate Miley CONTRA COSTA COUNTY John Gioia David Hudson Karen Mitchoff (Vice Chair) Mark Ross MARIN COUNTY Katie Rice NAPA COUNTY Brad Wagenknecht SAN FRANCISCO COUNTY Myrna Melgar Shamann Walton Tyrone Jue (SF Mayor’s Appointee) SAN MATEO COUNTY David J. Canepa Carole Groom Davina Hurt SANTA CLARA COUNTY Margaret Abe-Koga Cindy Chavez (Chair) Rich Constantine Rob Rennie SOLANO COUNTY Erin Hannigan Lori Wilson SONOMA COUNTY Teresa Barrett Lynda Hopkins Jack P. Broadbent EXECUTIVE OFFICER/APCO
City of South San Francisco March 18, 2021 Page 2 ____________________________________________________________________
• The greenhouse gas (GHG) impact analysis should include an evaluation of
the Plan’s consistency with the most recent AB 32 Scoping Plan by the
California Air Resources Board (CARB) and with the State's 2030 and 2050
climate goals. The Air District's current recommended GHG thresholds in
our CEQA Guidelines are based on the State's 2020 GHG targets which are
now superseded by the 2030 GHG targets established in SB 32. The EIR
should demonstrate how the Project will be consistent with the Scoping
Plan.
• The DEIR should evaluate all feasible measures, both onsite and offsite, to
minimize air quality and GHG impacts. The DEIR should prioritize onsite
mitigation measures, followed by offsite mitigation measures, within the
Plan area. Examples of potential emission and exposure reduction measures
that should be evaluated and considered include, but are not limited to:
o Prohibiting or minimizing the use of diesel fuel, consistent with the
Air District’s Diesel Free By ’33 initiative
(http://dieselfree33.baaqmd.gov/);
o Implementing green infrastructure and fossil fuel alternatives in the
Plan, such as solar photovoltaic (PV) panels, renewable diesel,
electric heat pump water heaters, and solar PV back-up generators
with battery storage capacity;
o Implementing a building decarbonization goal or policy in the Plan
(https://www.buildingdecarb.org/compass.html);
o Requiring construction vehicles to operate with the highest tier
engines commercially available;
o Providing funding for zero- and low-emission transportation projects,
including a neighborhood electric vehicle program, community
shuttle/van services and car sharing, and enhancement of active
transportation initiatives, among others;
o Providing funding for expanding and improving bicycle and
pedestrian infrastructure and projects that improve bicycle and
pedestrian access to transit, employment, and major activity centers;
o Implementing a zero-waste program consistent with SB 1383 organic
waste disposal reduction targets including the recovery of edible
food for human consumption; and
o Include air filtration for new and existing buildings that may be
exposed to air pollution, such as MERV 13 filters, as well as
vegetative buffers between new and existing buildings, and sources
of pollution. For more emissions and exposure reduction best
practices, see the Air District’s Planning Healthy Places guidance,
Appendices A and B, here:
https://www.baaqmd.gov/~/media/files/planning-and-
research/planning-healthy-places/php_may20_2016-pdf.pdf
City of South San Francisco March 18, 2021 Page 3 ____________________________________________________________________
• The DEIR should evaluate the Plan’s consistency with the Air District’s 2017
Clean Air Plan (2017 CAP). The DEIR should discuss 2017 CAP measures
relevant to the Plan and show the Plan’s consistency with the measures. The
2017 CAP can be found on the Air District’s website:
http://www.baaqmd.gov/plans-and-climate/air-quality-plans/current-plans.
• The DEIR should evaluate the Plan’s consistency with the City of South San
Francisco’s Climate Action Plan (2014), as well as San Mateo County’s Sea
Level Rise Vulnerability Assessment (2018.) The DEIR should analyze the
Plan’s consistency with the City of South San Francisco’s most recently
adopted Climate Action Plan and consider any updates from San Mateo
County’s more recent work on Sea Level Rise Vulnerability Assessments.
• The Air District’s CEQA website contains several tools and resources to
assist lead agencies in analyzing air quality and GHG impacts. These tools
include guidance on quantifying local emissions and exposure impacts. The
tools can be found on the Air District’s website:
http://www.baaqmd.gov/plans-and-climate/california-environmental-
quality-act-ceqa/ceqa-tools. If the Plan requires a site-specific analysis,
please contact Air District staff to obtain more recent data.
• Certain aspects of the Plan may require a permit from the Air District (for
example, back-up diesel generators). Please contact Barry Young, Senior
Advanced Projects Advisor, at (415) 749-4721 or [email protected] to
discuss permit requirements. Any applicable permit requirements should be
discussed in the EIR.
We encourage the City to contact Air District staff with any questions and/or to
request assistance during the environmental review process. If you have any
questions regarding these comments, please contact Kelly Malinowski, Senior
Environmental Planner, (415) 749-8673, [email protected].
Sincerely,
Greg Nudd
Deputy Air Pollution Control Officer
cc: BAAQMD Director David J. Canepa
BAAQMD Director Carole Groom
BAAQMD Director Davina Hurt
From: Wilson, Joanne <[email protected]>
Sent: Thursday, March 18, 2021 6:38 PM
To: Gross, Billy <[email protected]>
Cc: Natesan, Ellen <[email protected]>; Rando, Casey <[email protected]>; Read, Emily
<[email protected]>; Wong, Christopher J <[email protected]>; Rodgers, Heather
<[email protected]>; Feng, Stacie <[email protected]>
Subject: NOP for Proposed South San Francisco General Plan Update DEIR
Dear Mr. Gross:
Thank you for providing the SFPUC with the Notice of Preparation of a Draft Environmental Impact
Report (DEIR) for the proposed South San Francisco General Plan Update (Plan). The City and County of
San Francisco, through its San Francisco Public Utilities Commission (SFPUC), is submitting the following
comments to the City of South San Francisco related to the SFPUC’s right‐of‐way (ROW) property
interests and infrastructure located within the proposed project site.
The SFPUC operates and manages land and water system infrastructure that is part of the Hetch Hetchy
Regional Water System that provides drinking water to 2.7 million people in the San Francisco Bay Area,
including to the City of South San Francisco. The SFPUC has several water transmission pipelines that
traverse the City of South San Francisco, generally in a north‐south direction within right‐of‐way lands
(ROW) that are typically 80‐feet wide (see attached map). In some cases, the ROW is owned in fee by
the City and County of San Francisco (CCSF) and operated and managed by the SFPUC (SFPUC Fee). In
other cases, the CCSF and SFPUC have acquired a ROW easement or the pipelines are within a public
ROW. These pipelines include the SFPUC’s San Andreas Pipeline Nos. 1, 2 and 3; the Sunset Supply Line;
the Baden‐Merced Pipeline; and the Crystal Springs Pipeline Nos. 1 and 2. In addition, the SFPUC Fee
includes undeveloped ROW land, valve lots, and groundwater facilities (including five well sites).
Land Use Element Analysis
Land use and planning analyses under the California Environmental Quality Act (CEQA) generally consider
the compatibility of a project with neighboring areas, change to or displacement of existing uses, and
consistency of a project with relevant local land use policies. The magnitude of land use conflicts or
compatibility issues depends on the extent to which a project physically divides an established community
or conflicts with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating
an environmental effect such that an adverse impact on the environmental occurs. The SFPUC has
adopted guidelines to help inform how and in which instances its ROW lands can serve the needs of
public agencies, private parties, nonprofit organizations, and developers, while maintaining the safety and
security of the SFPUC pipelines. SFPUC guidelines pertain to land use and structures, recreational use,
utilities, vegetation, and water efficiency. The easements also are subject to terms and restrictions
regarding use of land contained in the original deeds granting the easements to the SFPUC.
Please include a discussion of the SFPUC’s adopted policies in the DEIR land use analysis. For example, in
the discussion of agency approvals required for the implementation of the Plan, the DEIR could
state: Development under the updated South San Francisco General Plan may require the following
approvals from other agencies, as determined on a project‐by‐project basis:
San Francisco Public Utilities Commission
Determination of consistency with applicable SFPUC adopted plans, polices, and guidelines.
Housing Element Analysis
The SFPUC previously provided comments on the update to the City of South San Francisco’s Housing
Element (attached). As stated in the letter, some potential housing sites identified in the updated
Housing Element are not compatible with SFPUC land use policies which do not allow structures to be
built on top of its water transmission pipelines or within its ROW lands in order to protect SFPUC
infrastructure and the SFPUC’s ability to operate, maintain, repair its pipelines, and construct water
utility improvements. The DEIR should disclose and analyze potential land use conflicts that any
proposed housing site, accessory housing land use, or residential zoning included in the updated
Housing Element might create with established plans and policies of other agencies, including the
SFPUC.
Project Review Process
The DEIR should include information about the SFPUC’s Project Review Process. All proposed projects
and activities on SFPUC lands must be reviewed by the SFPUC’s Project Review Committee (committee)
to determine whether a proposal is compatible with SFPUC adopted plans and policies prior to obtaining
written authorization from the SFPUC. During Project Review, the committee may require modifications
to the proposal and/or require implementation of avoidance and minimization measures to reduce
negative impacts and to ensure that the proposal conforms to applicable plans and policies. Therefore, it
is important to schedule projects for review at the earliest opportunity to address any potential project
issues. To initiate the Project Review process, please visit www.sfwater.org/projectreview to download
the Project Review application. Once the application is completed, please email your application and
supporting attachments (project description, maps, drawings and/or plans) to
[email protected]. Completed applications with required attachments are scheduled for the
next available Project Review Committee meeting date.
Right of Way Policies
For your reference, attached are the following two SFPUC ROW policies:
Interim Water Pipeline ROW Use Policy – specifies uses allowed or prohibited within the SFPUC
ROW (ex. land use, structures, utilities, etc.). Note: An applicant may not use SFPUC property to
fulfill an open space, setback, emergency access, parking or other permitting/entitlement
requirement; and
Integrated Vegetation Management Policy – see section 12.005 for vegetation height
specifications allowed within the SFPUC ROW.
The main design guideline (restriction) comes from the Interim Water Pipeline ROW Use Policy (no
structures within 20‐feet of the edges of the water transmission pipelines; and no pads/footings deeper
than 6‐inches). Projects on SFPUC property or near SFPUC infrastructure must be consistent with SFPUC‐
adopted policies and the SFPUC’s primary mission as a water utility. This includes planning for SFPUC
scheduled or emergency engineering, operations, or maintenance requirements/needs. The proposed
DEIR must analyze the plan for consistency with SFPUC adopted plans and policies.
Please mail any hard copies of notices to the following address:
San Francisco Public Utilities Commission
Real Estate Services
525 Golden Gate Avenue, 10th Floor
San Francisco, CA 94102
Thanks for your time and attention. If you have any questions or need further information, please
contact me.
Regards,
Joanne Wilson
Joanne Wilson
Senior Land and Resources Planner
Natural Resources and Lands Management Division
Water Enterprise
1657 Rollilns Road
Burlingame, CA 94010
Please consider the environment before printing this email.
Hetch Hetchy Regional Water System
Operated by San Francisco Water, Power and Sewer | Services of the San Francisco Public
Utilities Commission
SFPUC Water Transmission Pipeline Right-of-Way in
South San Francisco
The City does not guarantee that the information on this site is accurate or
complete. The City is not responsible for any damages arising from the use of
information on this site. Users should verify the information before making
project commitments.
50,932
Date Created
1.6
1:
NAD_1983_StatePlane_California_III_FIPS_0403_Feet
Miles1.60
Notes
Legend
0.80
03/17/2021
Treatment Plants
Transmission Lines
Penstock
Pipeline
Siphon
Tunnel
SFPUC Parcels / Right of Way
Other / Uncertain
Easement
Fee-owned
Raker Act
Major Roads
<all other values>
Interstate
US Highway
State Highway
Major Road
SFPUC Reservoirs
Cities
SFPUC Interim Water Pipeline Right of Way Use Policy
for San Mateo, Santa Clara, and Alameda Counties
Approved January 13, 2015
by
SFPUC Resolution No. 15-0014
as an amendment to the SFPUC Real Estate Guidelines
SFPUC Water Pipeline Right of Way Use Policy for
San Mateo, Santa Clara, and Alameda Counties
As part of its utility system, the San Francisco Public Utilities Commission (SFPUC) operates
and maintains hundreds of miles of water pipelines. The SFPUC provides for public use on its
water pipeline property or right of way (ROW) throughout Alameda, Santa Clara, and San Mateo
counties consistent with our existing plans and policies. The following controls will help inform
how and in which instances the ROW can serve the needs of third parties—including public
agencies, private parties, nonprofit organizations, and developers—seeking to provide
recreational and other use opportunities to local communities.
Primarily, SFPUC land is used to deliver high quality, efficient and reliable water, power, and
sewer services in a manner that is inclusive of environmental and community interests, and that
sustains the resources entrusted to our care. The SFPUC’s utmost priority is maintaining the
safety and security of the pipelines that run underneath the ROW.
Through our formal Project Review and Land Use Application and Project Review process, we
may permit a secondary use on the ROW if it benefits the SFPUC, is consistent with our mission
and policies, and does not in any way interfere with, endanger, or damage the SFPUC’s current
or future operations, security or facilities.1 No secondary use of SFPUC land is permitted without
the SFPUC’s consent.
These controls rely on and reference several existing SFPUC policies, which should be read
when noted in the document. Being mindful of these policies while planning a proposed use and
submitting an application will ease the process for both the applicant and the SFPUC. These
controls are subject to change over time and additional requirements and restrictions may apply
depending on the project.
The SFPUC typically issues five-year revocable licenses for use of our property, with a form of
rent and insurance required upon signing.2
Note: The project proponent is referred to as the “Applicant” until the license agreement is signed, at
which point the project proponent is referred to as the “Licensee.”
1 SFPUC Guidelines for the Real Estate Services Division, Section 2.0.
2 SFPUC Guidelines for the Real Estate Services Division, Section 3.3.
I. Land Use, Structures, and Compliance with Law
The following tenets govern the specifics of land use, structures, and accessibility for a
project. Each proposal will still be subject to SFPUC approval on a case-by-case basis.
A. SFPUC Policies. The Applicant’s proposed use must conform to policies approved
by the SFPUC’s Commission, such as the SFPUC’s Land Use Framework
(http://sfwater.org/index.aspx?page=586).
B. Americans with Disabilities Act Compliance. The Applicant must demonstrate that a
Certified Access Specialist (CASp) has reviewed and approved its design and plans
to confirm that they meet all applicable accessibility requirements.
C. Environmental Regulations. The SFPUC’s issuance of a revocable license for use of
the ROW is subject to compliance with the California Environmental Quality Act
(CEQA). The Applicant is responsible for assessing the potential environmental
impacts under CEQA of its proposed use of the ROW. The SFPUC must be named
as a Responsible Agency on any CEQA document prepared for the License Area. In
addition, the Applicant shall provide to SFPUC a copy of the approved CEQA
document prepared by the Applicant, the certification date, and documentation of the
formal approval and adoption of CEQA findings by the CEQA lead agency. The
SFPUC will not issue a license for the use of the ROW until CEQA review and
approval is complete.
D. Crossover and Other Reserved Rights. For a ROW parcel that bisects a third party’s
land, the Applicant’s proposed use must not inhibit that party’s ability to cross the
ROW. The Applicant must demonstrate any adjoining owner with crossover or other
reserved rights approves of the proposed recreational use and that the use does not
impinge on any reserved rights.
E. Width. The License Area must span the entire width of the ROW.
For example, the SFPUC will not allow a 10-foot wide trail license on a ROW
parcel that is 60 feet wide.
F. Structures. Structures on the ROW are generally prohibited. The Licensee shall not
construct or place any structure or improvement in, on, under or about the entire
License Area that requires excavation, bored footings or concrete pads that are
greater than six inches deep.
i. Structures such as benches and picnic tables that require shallow (four to six
inches deep) cement pads or footings are generally permitted on the ROW.
No such structure may be placed directly on top of a pipeline or within 20 feet
of the edge of a pipeline.
ii. The SFPUC will determine the permitted weight of structures on a case-by-
case basis.
When the SFPUC performs maintenance on its pipelines, structures
of significant weight and/or those that require footings deeper than six
inches are very difficult and time-consuming to move and can pose a
safety hazard to the pipelines. The longer it takes the SFPUC to reach
the pipeline in an emergency, the more damage that can occur.
G. Paving Materials. Permitted trails or walkways should be paved with materials that
both reduce erosion and stormwater runoff (e.g., permeable pavers).
H. License Area Boundary Marking. The License Area’s boundaries should be clearly
marked by landscaping or fencing, with the aim to prevent encroachments.
I. Fences and Gates. Any fence along the ROW boundary must be of chain-link or
wooden construction with viewing access to the ROW. The fence must include a
gate that allows SFPUC access to the ROW.3 Any gate must be of chain-link
construction and at least 12 feet wide with a minimum 6-foot vertical clearance.
II. Types of Recreational Use
Based on our past experience and research, the SFPUC will allow simple parks without
play structures, community gardens and limited trails.
A. Fulfilling an Open Space Requirement. An applicant may not use the ROW to fulfill a
development’s open space, setback, emergency access or other requirements.4 In
cases where a public agency has received consideration for use of SFPUC land from
a third party, such as a developer, the SFPUC may allow such recreational use if the
public agency applicant pays full Fair Market Rent.
B. Trail Segments. At this time, the SFPUC will consider trail proposals when a multi-
jurisdictional entity presents a plan to incorporate specific ROW parcels into a fully
connected trail. Licensed trail segments next to unlicensed parcels may create a trail
corridor that poses liability to the SFPUC. The SFPUC will only consider trail
proposals where the trail would not continue onto, or encourage entry onto, another
ROW parcel without a trail and the trail otherwise meet all SFPUC license
requirements.
III. Utilities
A. Costs. The Licensee is responsible for all costs associated with use of utilities on the
License Area.
3 SFPUC Right of Way Requirements.
4 SFPUC Guidelines for the Real Estate Services Division, Section 2.0.
B. Placement. No utilities may be installed on the ROW running parallel to the SFPUC’s
pipelines, above or below grade.5 With SFPUC approval, utilities may run
perpendicular to the pipelines.
C. Lights. The Licensee shall not install any light fixtures on the ROW that require
electrical conduits running parallel to the pipelines. With SFPUC approval, conduits
may run perpendicular to and/or across the pipelines.
Any lighting shall have shielding to prevent spill over onto adjacent
properties.
D. Electricity. Licensees shall purchase all electricity from the SFPUC at the SFPUC’s
prevailing rates for comparable types of electrical load, so long as such electricity is
reasonably available for the Licensee’s needs.
IV. Vegetation
A. The Applicant shall refer to the SFPUC Integrated Vegetation Management Policy for
the minimum requirements concerning types of vegetation and planting.
(http://www.sfwater.org/index.aspx?page=431.) The Licensee is responsible for all
vegetation maintenance and removal.
B. The Applicant shall submit a Planting Plan as part of its application.
(Community garden applicants should refer to Section VII.C for separate
instructions.)
i. The Planting Plan should include a layout of vegetation placement (grouped
by hydrozone) and sources of irrigation, as well as a list of intended types of
vegetation. The SFPUC will provide an area drawing including pipelines and
facilities upon request.
ii. The Applicant shall also identify the nursery(ies) supplying plant stock and
provide evidence that each nursery supplier uses techniques to reduce the
risk of plant pathogens, such as Phytophthora ramorum.
V. Measures to Promote Water Efficiency6
A. The Licensee shall maintain landscaping to ensure water use efficiency.
B. The Licensee shall choose and arrange plants in a manner best suited to the site’s
climate, soil, sun exposure, wildfire susceptibility and other factors. Plants with
similar water needs must be grouped within an area controlled by a single irrigation
valve
5 SFPUC Land Engineering Requirements.
6 SFPUC Rules and Regulations Governing Water Service to Customers, Section F.
C. Turf is not allowed on slopes greater than 25 percent.
D. The SFPUC encourages the use of local native plant species in order to reduce
water use and promote wildlife habitat.
E. Recycled Water. Irrigation systems shall use recycled water if recycled water
meeting all public health codes and standards is available and will be available for
the foreseeable future.
F. Irrigation Water Runoff Prevention. For landscaped areas of any size, water runoff
leaving the landscaped area due to low head drainage, overspray, broken irrigation
hardware, or other similar conditions where water flows onto adjacent property,
walks, roadways, parking lots, structures, or non-irrigated areas, is prohibited.
VI. Other Requirements
A. Financial Stability. The SFPUC requires municipalities or other established
organizations with a stable fiscal history as Licensees.
i. Applicants must also demonstrate sufficient financial backing to pay rent,
maintain the License Area, and fulfill other license obligations over the license
term.
B. Smaller, community-based organizations without 501(c)(3) classifications must
partner with a 501(c)(3) classified organization or any other entity through which it
can secure funding for the License Area over the license term. Maintenance. The
Licensee must maintain the License Area in a clean and sightly condition at its sole
cost.7 Maintenance includes, but is not limited to, regular weed abatement, mowing,
and removing graffiti, dumping, and trash.
C. Mitigation and Restoration. The Licensee will be responsible, at its sole cost, for
removing and replacing any recreational improvements in order to accommodate
planned or emergency maintenance, repairs, replacements, or projects done by or
on behalf of the SFPUC. If the Licensee refuses to remove its improvements,
SFPUC will remove the improvements l at the Licensee’s sole expense without any
obligation to replace them.
D. Encroachments. The Licensee will be solely responsible for removing any
encroachments on the License Area. An encroachment is any improvement on
SFPUC property not approved by the SFPUC. Please read the SFPUC ROW
Encroachment Policy for specific requirements. If the Licensee fails to remove
encroachments, the SFPUC will remove them at Licensee’s sole expense. The
Licensee must regularly patrol the License Area to spot encroachments and remove
them at an early stage.
7 SFPUC Framework for Land Management and Use.
E. Point of Contact. The Licensee will identify a point of contact (name, position title,
phone number, and address) to serve as the liaison between the Licensee, the local
community, and the SFPUC regarding the License Agreement and the License Area.
In the event that the point of contact changes, the Licensee shall immediately
provide the SFPUC with the new contact information. Once the License Term
commences, the point of contact shall inform local community members to direct any
maintenance requests to him or her. In the event that local community members
contact the SFPUC with such requests, the SFPUC will redirect any requests or
complaints to the point of contact.
F. Community Outreach.
i. Following an initial intake conversation with the SFPUC, the Applicant shall
provide a Community Outreach Plan for SFPUC approval. This Plan shall
include the following information:
1. Identification of key stakeholders to whom the Applicant will contact
and/or ask for input, along with their contact information;
2. A description of the Applicant’s outreach strategy, tactics, and
materials
3. A timeline of outreach (emails/letters mailing date, meetings, etc.);
and
4. A description of how the Applicant will incorporate feedback into its
proposal.
ii. The Applicant shall conduct outreach for the project at its sole cost and shall
keep the SFPUC apprised of any issues arising during outreach.
iii. During outreach, the Applicant shall indicate that it in no way represents the
SFPUC.
G. Signage. The SFPUC will provide, at Licensee’s cost, a small sign featuring the
SFPUC logo and text indicating SFPUC ownership of the License Area at each
entrance. In addition, the Licensee will install, at its sole cost, an accompanying sign
at each entrance to the License Area notifying visitors to contact the organization’s
point of contact and provide a current telephone number in case the visitors have
any issues. The SFPUC must approve the design and placement of the Licensee’s
sign.
VII. Community Gardens
The following requirements also apply to community garden sites. As with all projects,
the details of the operation of a particular community garden are approved on a case-by-
case basis.
A. The Applicant must demonstrate stable funding. The Applicant must provide
information about grants received, pending grants, and any ongoing foundational
support.
B. The Applicant must have an established history and experience in managing urban
agriculture or community gardening projects. Alternatively, the Applicant may
demonstrate a formal partnership with an organization or agency with an established
history and experience in managing urban agriculture or community gardening
projects
C. During the Project Review process, the Applicant shall submit a Community Garden
Planting Plan that depicts the proposed License Area with individual plot and planter
box placements, landscaping, and a general list of crops that may be grown in the
garden.
D. The Applicant shall designate a Garden Manager to oversee day-to-day needs and
serve as a liaison between the SFPUC and garden plot holders. The Garden
Manager may be distinct from the point of contact, see Section VI.E.
E. The Licensee must ensure that the Garden Manager informs plot holders about the
potential for and responsibilities related to SFPUC repairs or emergency
maintenance on the License Area. In such circumstances, the SFPUC is not liable
for the removal and replacement of any features on the License Area or the costs
associated with such removal and replacement.
F. The Licensee must conduct all gardening within planter boxes with attached bottoms
that allow for easy removal without damaging the crops.
AMENDMENT TO THE
RIGHT OF WAY INTEGRATED VEGETATION MANAGEMENT POLICY
Approved January 13, 2015
by
SFPUC Resolution No. 15-0014
12.000 RIGHT OF WAY INTEGRATED VEGETATION MANAGEMENT POLICY
12.001 General
The San Francisco Public Utilities Commission (“SFPUC”) is responsible for the delivery of potable water
and the collection and treatment of wastewater for some 800,000 customers within the City of San
Francisco; it is also responsible for the delivery of potable water to 26 other water retailers with a
customer base of 1.8 million. The following policy is established to manage vegetation on the
transmission, distribution and collection systems within the SFPUC Right of Way (“ROW”) so that it
does not pose a threat or hazard to the system’s integrity and infrastructure or impede utility
maintenance and operations.
The existence of large woody vegetation1, hereinafter referred to as vegetation, and water transmission
lines within the ROW are not compatible and, in fact, are mutually exclusive uses of the same space.
Roots can impact transmission pipelines by causing corrosion. The existence of trees and other
vegetation directly adjacent to pipelines makes emergency and annual maintenance very difficult,
hazardous, and expensive, and increases concerns for public safety. The risk of fire within the ROW is
always a concern and the reduction of fire ladder fuels within these corridors is another reason to
modify the vegetation mosaic. In addition to managing vegetation in a timely manner to prevent any
disruption in utility service, the SFPUC also manages vegetation on its ROW to comply with local fire
ordinances enacted to protect public safety.
One of the other objectives of this policy is to reduce and eliminate as much as practicable the use of
herbicides on vegetation within the ROW and to implement integrated pest management (IPM).
12.002 Woody Vegetation Management
1.0 Vegetation of any size or species will not be allowed to grow within certain critical portions of the
ROW, pumping stations or other facilities as determined by a SFPUC qualified professional, and generally
in accordance with the following guidelines.
1.1 Emergency Removal
SFPUC Management reserves the right to remove any vegetation without prior public notification that
has been assessed by a SFPUC qualified professional as an immediate threat to transmission lines or
other utility infrastructure, human life and property due to acts of God, insects, disease, or natural
mortality.
1.2 Priority Removal
Vegetation that is within 15 feet of the edge of any pipe will be removed and the vegetative debris will
be cut into short lengths and chipped whenever possible. Chips will be spread upon the site where the
vegetation was removed. Material that cannot be chipped will be hauled away to a proper disposal site.
1 Woody vegetation is defined as all brush, tree and ornamental shrub species planted in (or naturally occurring in)
the native soil having a woody stem that at maturity exceeds 3 inches in diameter.
If vegetation along the ROW is grouped in contiguous stands2, or populations, a systematic and
staggered removal of that vegetation will be undertaken to replicate a natural appearance. Initial
removal3 will be vegetation immediately above or within 15 feet of the pipeline edges; secondary
vegetation4 within 15 to 25 feet from pipelines will then be removed.
1.3 Standard Removal
Vegetation that is more than 25 feet from the edge of a pipeline and up to the boundary of the ROW will
be assessed by a SFPUC qualified professional for its age and condition, fire risk, and potential impact to
the pipelines. Based on this assessment, the vegetation will be removed or retained.
1.4 Removal Standards
Each Operating Division will develop its own set of guidelines or follow established requirements in
accordance with local needs.
2.0 All stems of vegetation will be cut flush with the ground and where deemed necessary or
appropriate, roots will be removed. All trees identified for removal will be clearly marked with paint
and/or a numbered aluminum tag.
3.0 Sprouting species of vegetation will be treated with herbicides where practicable, adhering to
provisions of Chapter 3 of the San Francisco Environment Code.
4.0 Erosion control measures, where needed, will be completed before the work crew or contractors
leave the work site or before October 15 of the calendar year.
5.0 Department personnel will remove in a timely manner any and all material that has been cut for
maintenance purposes within any stream channel.
6.0 All vegetation removal work and consultation on vegetation retention will be reviewed and
supervised by a SFPUC qualified professional. All vegetation removal work and/or treatment will be
made on a case-by-case basis by a SFPUC qualified professional.
7.0 Notification process for areas of significant resource impact that are beyond regular and ongoing
maintenance:
7.1 County/City Notification – The individual Operating Division will have sent to the affected
county/city a map showing the sections of the ROW which will be worked, a written description of the
work to be done, the appropriate removal time for the work crews, and a contact person for more
information. This should be done approximately 10 days prior to start of work. Each Operating Division
will develop its own set of guidelines in accordance with local need.
2 A stand is defined as a community of trees possessing sufficient uniformity in composition, structure, age,
arrangement, or condition to be distinguishable from adjacent forest communities to form a management unit. 3 Initial removal is defined as the vegetation removed during the base year or first year of cutting. 4 Secondary vegetation is defined as the vegetative growth during the second year following the base year for
cutting.
7.2 Public Notification – The Operating Division will have notices posted at areas where the vegetation is
to be removed with the same information as above also approximately 10 days prior to removal. Notices
will also be sent to all property owners within 300 feet of the removal site. Posted notices will be 11- by
17-inches in size on colored paper and will be put up at each end of the project area and at crossover
points through the ROW. Questions and complaints from the public will be handled through a
designated contact person. Each Operating Division will develop its own set of guidelines in accordance
with local needs.
12.003 Annual Grass and Weed Management
Annual grasses and weeds will be mowed, disked, sprayed or mulched along the ROW as appropriate to
reduce vegetation and potential fire danger annually. This treatment should be completed before July
30 of each year. This date is targeted to allow the grasses, forbs and weeds to reach maturity and
facilitate control for the season.
12.004 Segments of ROW that are covered by Agricultural deed rights
The only vegetation that may be planted within the ROW on those segments where an adjacent owner
has Deeded Agricultural Rights will be: non-woody herbaceous plants such as grasses, flowers, bulbs, or
vegetables.
12.005 Segments of ROW that are managed and maintained under a Lease or License
Special allowance may be made for these types of areas, as the vegetation will be maintained by the
licensed user as per agreement with the City, and not allowed to grow unchecked. Only shallow rooted
plants may be planted directly above the pipelines.
Within the above segments, the cost of vegetation maintenance and removal will be borne by the
tenant or licensee exclusively. In a like fashion, when new vegetative encroachments are discovered
they will be assessed by a SFPUC qualified professional on a case-by-case basis and either be permitted
or proposed for removal.
The following is a guideline for the size at maturity of plants (small trees, shrubs, and groundcover) that
may be permitted to be used as landscape materials. Note: All distance measurements are for mature
trees and plants measured from the edge of the drip-line to the edge of the pipeline.
• Plants that may be permitted to be planted directly above existing and future pipelines: shallow
rooted plants such as ground cover, grasses, flowers, and very low growing plants that grow to a
maximum of one foot in height at maturity.
• Plants that may be permitted to be planted 15–25 feet from the edge of existing and future
pipelines: shrubs and plants that grow to a maximum of five feet in height at maturity.
• Plants that may be permitted to be planted 25 feet or more from the edge of existing and future
pipelines: small trees or shrubs that grow to a maximum of twenty feet in height and fifteen feet
in canopy width.
Trees and plants that exceed the maximum height and size limit (described above) may be permitted
within a leased or licensed area provided they are in containers and are above ground. Container load
and placement location(s) are subject to review and approval by the SFPUC.
Low water use plant species are encouraged and invasive plant species are not allowed.
All appurtenances, vaults, and facility infrastructure must remain visible and accessible at all times. All
determinations of species acceptability will be made by a SFPUC qualified professional.
The above policy is for general application and for internal administration purposes only and may not
be relied upon by any third party for any reason whatsoever. The SFPUC reserves the right at its sole
discretion, to establish stricter policies in any particular situation and to revise and update the above
policy at any time.
Natural Resources and Lands Management Division
525 Golden Gate Avenue, 10th Floor
San Francisco, CA 94102
T 415.554.3265
F 415.934.5770
March 19, 2015
Tony Rozzi, AICP, Senior Planner
City of South San Francisco
Economic and Community Development Department
315 Maple Avenue
South San Francisco, CA 94080
RE: City of South San Francisco 2015-2023 Housing Element Update
Initial Study/Negative Declaration
Dear Mr. Tony Rozzi:
Thank you for the opportunity to review and comment on the Initial
Study/Negative Declaration for the South San Francisco 2015-2023 Housing
Element Update.
The City and County of San Francisco, through its San Francisco Public
Utilities Commission (SFPUC), owns land in-fee and holds land easements in
the City of South San Francisco to operate its water system infrastructure as
part of the Hetch Hetchy Regional Water System. The Hetch Hetchy Regional
Water System has multiple pipelines crossing the City of South San Francisco
which provides drinking water to 2.6 million people in the San Francisco Bay
Area.
Below are our comments relating to the Initial Study/Negative Declaration.
Section 3.10 Land Use and Planning
The City of South San Francisco, in its 2015-2023 Housing Element Update
(Chapter 5 - Housing Resources - Transit Village Sites), identified parcels
between El Camino Real and the BART Right of Way (ROW) as potential
residential sites. These sites are currently zoned as "El Camino Real/Chestnut
Mixed Use High Density." There are SFPUC pipelines located on four of these
parcels along El Camino Real. The SFPUC holds an easement for its Sunset
Supply water transmission pipelines on the parcels identified in the Housing
Element Update. These potential housing sites are not compatible with
SFPUC land use policies (see attached SFPUC ROW Use Policy). There is no
discussion in the draft Initial Study/Negative Declaration of the SFPUC
easements, infrastructure or policies relating to the identified sites.
Services of the San Francisco Public Utilities Commission
San Francisco
Water Power Sewer
Operator of the Hetch Hetchy Regional Water System
Edwin M. Lee
Mayor
Ann Moller Caen
President
Francesca Vietor
Vice President
Vince Courtney
Commissioner
Anson Moran
Commissioner
Ike Kwon
Commissioner
Harlan L. Kelly, Jr.
General Manager
SFPUC Response to City of South San Francisco 2015-2023 Housing Element Update
Initial Study/Negative Declaration
The SFPUC understands that the purpose of the housing element update is to
identify potential housing sites as part of state requirements. Currently, the
discussion for Section 3.10 states that "future housing projects will continue to
be reviewed through the City's entitlement process and CEQA to ensure
consistency with local, state, and federal regulations and all General Plan
goals, objectives and policies intended to protect established communities and
land uses." The City of South San Francisco should consider and discuss the
SFPUC infrastructure located on these parcels and the potential land use
conflict that the proposed housing sites on El Camino Real may create with
SFPUC easement land rights and the established SFPUC plans and policies
for managing its water utility ROW. This land use conflict could potentially limit
the suitability of using these sites for future residential projects.
To assist you in your planning efforts, below you will find the Assessor Parcel
Numbers (APNs) for the areas identified as potential housing sites that may
have a land use conflict with SFPUC land easements.
Housing Element Update Site APN SFPUC Parcel
2 010-292-130 49-D
2 010-292-280 49-C
2 010-292-270 49-B
5 011-326-030 49-E
As specified in the attached ROW Policy, the SFPUC must retain the ability to
access its property to maintain, repair, replace, or install water transmission
pipelines. The SFPUC does not allow any structures on its ROW and limits
vegetation on its property because repair or maintenance of our water utility
infrastructure may result in damage or demolition of built improvements and/or
landscaping. Project sponsors of any proposed project over or near SFPUC
easements should be made aware of the SFPUC's ROW requirements.
If a residential development project is proposed to the City of South San
Francisco adjacent to SFPUC fee-owned property or easement areas, the
SFPUC requests notification and sufficient time to comment on the proposed
project. If a residential development project is proposed on SFPUC fee-owned
propertv or easement areas, the SFPUC requires that the project proponent
participate in the SFPUC's Project Review process to comply with all applicable
SFPUC plans and policies. For more information about our Project Review
process and for instructions of how to participate, please visit our website at
http://www.sfwater.orq/index.aspx?paqe=450.
As noted in the Initial Study, the water department serving the City of South
San Francisco purchases much of its drinking water from the SFPUC. The
ongoing operation and maintenance of the Hetch Hetchy Regional Water
System in a safe and reliable manner is a shared priority for both your
community and the SFPUC. If you have any questions or require further
Page 2 of 3
SFPUC Response to City of South San Francisco 2015-2023 Housing Element Update
Initial Study/Negative Declaration
information, please contact Jonathan Mendoza, Planner, at
[email protected] or (650) 652-3215.
For your reference, I am enclosing the SFPUC Right of Way Use Policy and
the Right of Way Integrated Vegetation Management Policy.
Sincerely,
Tim Ramirez
Division Manager
Natural Resources and Lands Management Division (NRLMD)
Enclosures: SFPUC Right of Way Use Policy
Right of Way Integrated Vegetation Management Policy
CC: Rosanna Russell, Director, SFPUC Real Estate Services
Ellen Natesan, Planning and Compliance Manager, SFPUC-NRLMD
Joanne Wilson, Senior Planner, SFPUC-NRLMD
Craig Freeman, Utility Specialist, SFPUC-BEM
Jonathan Mendoza, Planner, SFPUC-NRLMD
Page 3 of 3
March 22, 2021
Billy Gross TRANSMITTED VIA EMAIL
Senior Planner [email protected]
City of South San Francisco
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for Proposed South San
Francisco General Plan Update
Dear Mr. Gross,
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a
Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update
(the project). We appreciate this opportunity to coordinate with the City of South San Francisco (the City) in
considering and evaluating potential land use compatibility issues that the project may pose and should address.
As described in the Notice of Preparation (NOP), the project site is the geographic limits of the City, in San
Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with, City and
County of San Francisco/SFO property boundaries. The City is primarily residential, with this use occupying
approximately 40% of its land area, followed by industrial/research and development (RD) at approximately 30%,
and parks/open space/common greens at approximately 10%. The NOP notes that presently there are about 150
acres of vacant land remaining in the City, which amounts to 3.4% of the City. This project will serve as a
blueprint for the City’s vision through the year 2040 and will replace the 1999 General Plan and inform updates to
the City’s Zoning Ordinance.
The City’s proposed changes are highlighted in Proposed Land Use Maps and, specifically, the Land Use Map
depicting the changes from the existing map (see Figure 1). This map highlights the concentration in change along
the U.S. Highway 101 (U.S. 101) corridor, the “East of 101” precinct including Oyster Point, and transit nodes
such as the San Bruno Bay Area Rapid Transit (BART) and South San Francisco BART and Caltrain stations,
which have been targeted for zoning intensification. The NOP notes that the project permits approximately 14,324
net new housing units and approximately 13,352 net new employment opportunities by 2040. This map highlights
that much of this change will come from intensifying land uses which were previously exclusively office/RD or
industrial under the 1999 General Plan to include mixed use or high-density mixed use, which would allow for
residential uses.
The Airport is concerned that much of the land slated for this change is closer to the Airport than the previous
General Plan’s housing element, and portions of the proposed mixed-use residential zones are within the Airport’s
runway safety zone boundaries and 65 decibel (dB) Community Noise Equivalent Level (CNEL) noise contour.
In the 1999 General Plan, the City acknowledged the significance of and retained areas east of U.S. 101 for cargo
handling and freight forwarder uses that support the cargo operations at SFO. The Airport appreciates that in the
intervening years, the City has successfully maintained these land uses east of U.S. 101, which enhance and
support the relationship among the City, its residents, and the Airport. These existing compatible land uses east of
U.S. 101 include industrial, warehousing, hotels, and office/RD. The Airport cautions against the project’s
proposed departure from this successful practice.
Mr. Billy Gross March 22, 2021 Page 2 of 5
The close proximity of these areas to SFO would require developments to undergo federal, state, and local
regulatory review processes specific to airport noise, airspace safety, and other land use compatibility standards,
including 14 Code of Federal Regulations Part 77 regulations for the safety, efficient use, and preservation of
navigable airspaces. Airport staff encourages the City to work closely with the Airport Land Use Commission
(ALUC)1 to determine project consistency with the Comprehensive Airport Land Use Compatibility Plan for the
Environs of SFO (ALUCP)2 and other regulatory review procedures. The Program EIR should evaluate the
project for consistency with all ALUCP regulatory requirements and policies.
Figure 1: Proposed Changes from Existing Land Use Map (NOP of Program EIR Exhibit 5)
The ALUCP establishes policies, to ensure compatibility between the Airport and surrounding land uses and to
protect local residents and workers from adverse effects of airport operations. All three topics are based on
research into actual effects of airport operations on human health and safety.3
x Noise: Reduce the potential number of future residents who could be exposed to noise effects from airport
and aircraft operations.
x Safety: Minimize the potential number of future residents and land use occupants exposed to hazards
related to aircraft operations and/or catastrophic incidents.
x Elevation/Height: Protect the navigable airspace around the Airport for the safe and efficient operation
of aircraft in flight.
1 State law requires an ALUC for every county with an airport in its jurisdiction. See Cal. Pub. Util. Code §§ 21670-21679.5.
In San Mateo County, the City/County Association of Governments of San Mateo County (C/CAG) board serves as the
ALUC.
2 State law requires the preparation of an ALUCP. See id. In 2012, C/CAG, in consultation with the Airport and surrounding
communities, adopted the current ALUCP, which addresses issues related to compatibility between airport operations and
surrounding proposed land use development, considering noise impacts, safety of persons on the ground and in flight, height
restrictions/airspace protection, and overflight notification.
3 California Department of Transportation (Caltrans) Division of Aeronautics, California Airport Land Use Planning
Handbook, October 2011.
Mr. Billy Gross March 22, 2021 Page 3 of 5
Most of the City, and all of the areas of proposed land use intensification around and to the east of U.S. 101, are
located within the ALUCP Airport Influence Areas A and B (see Figure 2). The ALUCP requires all residential
development within Area A, which is the entirety of San Mateo County, to provide real estate disclosures, a copy
of which can be found at ALUCP Appendix G-7. Additionally, within the more restrictive Area B, “the ALUC
[the C/CAG Board] shall exercise its statutory duties to review proposed land use policy actions, including new
general plans, specific plans, zoning ordinances, plan amendments and rezoning, and land development
proposals.”4 The City must accordingly submit the proposed general plan update to the ALUC for review.
Figure 2: ALUCP-defined boundaries affecting South San Francisco (ALUCP Exhibit IV-3)
With respect to noise compatibility, portions of the project are situated within the Airport’s 65 dB CNEL noise
contour, and some even within the 70 dB contour. The ALUCP policies for noise are to protect the comfort and
quality of life of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher
contours. To the extent that the project would allow such uses, the Program EIR must disclose and evaluate any
inconsistency with the ALUCP. The ALUCP requires the grant of an avigation easement to the City and County
of San Francisco, as the proprietor of SFO, as a condition of allowing residential development within the 65 dB
contour.5 While avigation easements are an important mitigation tool, they do not replace the imperative to avoid
introducing incompatible uses into a noise-affected area in the first place. As shown in ALUCP Table IV-1,
residential uses are not compatible within the 70 dB contour and higher, and the Program EIR should evaluate
them as such.
Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap or Oyster
Point, including one procedure, the Shoreline Departure visual procedure, which is a noise abatement procedure
designed specifically to keep aircraft over the industrial areas of the City east of U.S. 101 and away from its
traditional residential areas. Any residential developments east of U.S. 101 could reduce the efficacy of the
Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to protect residents
of South San Francisco, Daly City, and Pacifica by maximizing flights over water and industrial areas between
4 ALUCP IP-2 (Airport Influence Area B – Policy/Project Referral Area), p. IV-11.
5 ALUCP NP-3.
Mr. Billy Gross March 22, 2021 Page 4 of 5
1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise
disturbances from aircraft departures. The Program EIR should evaluate these potential environmental impacts of
the project. The Airport also urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the project as it relates to the existing and long-established
aircraft noise abatement procedures to the City and adjacent cities.
Any proposed residential uses outside of the 65 dB contour should still meet the interior noise requirements of the
California Building Code. Noise impacts on sensitive receptors and any necessary mitigation measures should be
fully evaluated in the Program EIR, and the EIR should describe the project’s consistency with noise policies
described in ALUCP, including noise policies NP-1 through NP-4.
The Airport understands and supports the City’s efforts to address the region’s housing supply shortage with its
General Plan update. SFO has felt the effects of the housing crisis firsthand, with many people who work at the
Airport forced to finding housing 60 miles away, or farther. This places a considerable hardship on the
employees, Airport, neighboring communities, and the regional surface transportation system, and we would
welcome affordable, transit-oriented housing closer to the Airport. However, subjecting new residents to
excessive aircraft noise is not an equitable solution. SFO requests that the City revise its proposals for residential
and mixed uses away from the 65 dB CNEL contour, including the southern portions of Highway 101 and San
Bruno BART station. Any upzoning proposed along the City’s commercial core along Grand Avenue or higher
density around South San Francisco BART station would be outside of the critical 65 dB CNEL contour and
would not pose these concerns.
Figure 3: SFO runway safety compatibility zones around South San Francisco (ALUCP Exhibit IV-8)
With respect to safety, the southern portions of the General Plan area are within various runway end safety zones,
including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer Approach/Departure Zone (see
Figure 3). Each of these zones carry restrictions on what may be located there, based on the safety compatibility
criteria and guidelines from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already recognizes the
intense level of existing development in the vicinity of SFO, and the Airport recommends against overriding these
Mr. Billy Gross March 22, 2021 Page 5 of 5
restrictions. The Program EIR should also describe and evaluate the project’s consistency with land use criteria
within these runway end safety zones, as described in ALUCP SP-1 through SP-3.
With respect to elevation, the Airport appreciates the City’s commitment to protecting the critical airspace
surfaces defined in the ALUCP, as these surfaces protect the safety and economic vitality of the Airport and the
City. The Airport has observed several points of confusion regarding airspace surfaces and requests that the City
work with SFO staff to ensure the accuracy of the guidance provided in the General Plan Update.
For example, all critical airspace surfaces are based on elevation above mean sea level (AMSL) – not height
above ground level (AGL). Therefore, if the General Plan Update establishes height restrictions, it should note
them in AMSL rather than AGL and incorporate by reference the most recently adopted version of the ALUCP. It
should also note that the finished height of any proposed development must be maintained below these clearance
limits, including architectural parapets, machine rooms, antennas, etc. The Airport suggests that any exhibits
included in the General Plan Update should include prominent notes which address these common concerns.
Finally, the General Plan Update also proposes a new vehicular bridge between Oyster Point, likely around the
southern end of Haskins Way, and North Access Road on Airport property. While we understand this may be
highly notional, if the City does intend to pursue the concept, the Program EIR should fully evaluate it. We also
request that the City keep the Airport apprised of any developments regarding this proposal, which would require
close coordination with the Airport. For example, the Airport would need to understand vehicular movements and
how the bridge could increase or redistribute traffic on the Airport’s roadways and intersection with Interstate 380
in deciding whether to support the project.
The Airport appreciates your consideration of these comments. If I can be of assistance as the City considers
airport land use compatibility as they relate to the General Plan update, Program EIR, or any future projects,
please do not hesitate to contact me at (650) 821-9464 or at [email protected].
Sincerely,
Nupur Sinha
Acting Planning Director
Planning and Environmental Affairs
cc: Susy Kalkin, Airport Land Use Committee
Sandy Wong, C/CAG
Audrey Park, SFO, Acting Environmental Affairs Manager
555 County Center, 5th Floor, Redwood City, CA 94063 PHONE: 650.599.1406 www.ccag.ca.gov
C/CAG
CITY/COUNTY ASSOCIATION OF GOVERNMENTS
OF SAN MATEO COUNTY
Atherton • Belmont • Brisbane • Burlingame • Colma • Daly City • East Palo Alto • Foster City • Half Moon Bay • Hillsborough • Menlo Park • Millbrae • Pacifica • Portola Valley • Redwood City • San Bruno • San Carlos • San Mateo • San Mateo County •South San Francisco • Woodside
March 22, 2021 Billy Gross, Senior Planner City of South San Francisco Planning Division 315 Maple Avenue South San Francisco, CA 94080 RE: C/CAG Airport Land Use Committee Staff Comments - Notice of Prep. for South San Francisco General Plan Update Dear Mr. Gross, In response to your notice on the above matter, C/CAG Airport Land Use Committee staff offers the following input for your consideration: The City of South San Francisco lies within both Airport Influence Area (AIA) A (the Real Estate Disclosure Area) and B (the Policy/Project Referral Area) for San Francisco International Airport. Accordingly, the DEIR should discuss how the proposed policies in the General Plan Update will ensure Airport/Land Use Compatibility by addressing the noise, height/airspace protection, safety and overflight compatibility criteria and policies contained in the 2012 Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP), available on the C/CAG website at https://ccag.ca.gov/programs/airport-land-use/ Further, please note that this General Plan update will require formal review by the C/CAG Airport Land Use Committee and C/CAG, acting as the Airport Land Use Commission, for a determination of consistency with the SFO ALUCP prior to local agency action on the project. Thank you for the opportunity to review and comment on this NOP. If you have any questions, please contact me at [email protected]. Sincerely, ____________________________ Susy Kalkin ALUC Staff
“Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
STATE OF CALIFORNIA—CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF TRANSPORTATION DISTRICT 4
OFFICE OF TRANSIT AND COMMUNITY PLANNING
P.O. BOX 23660, MS-10D OAKLAND, CA 94623-0660
PHONE (510) 286-5528
TTY 711
www.dot.ca.gov
Making Conservation
a California Way of Life.
March 22, 2021 SCH #: 2021010203 GTS #: 04-SM-2021-00349
GTS ID: 21933
Co/Rt/Pm: SM/101/22.022
Billy Gross, Senior Planner
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94083
Re: South San Francisco General Plan Update + Notice of Preparation (NOP) of an Environmental Impact Report
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the South San Francisco General Plan
Update Project. We are committed to ensuring that impacts to the State’s
multimodal transportation system and to our natural environment are identified and mitigated to support a safe, sustainable, integrated and efficient
transportation system. The following comments are based on our review of the
January 2021 NOP.
Project Understanding The proposed project will update the goals, policies, and actions in the
proposed General Plan Update and will serve as a compass for decision-makers
and will shape future plans and actions of the City. This revised document will replace the 1999 General Plan and will inform updates to the City’s Zoning
Ordinance. The proposed South San Francisco General Plan Update has a
temporal horizon of 2040. The proposed plan update includes new housing and employment opportunities by the year 2040.
Travel Demand Analysis With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing
efficient development patterns, innovative travel demand reduction strategies,
and multimodal improvements. For more information on how Caltrans assesses
Billy Gross, Senior Planner
March 22, 2021
Page 2
“Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
Transportation Impact Studies, please review Caltrans’ Transportation Impact
Study Guide. If the project meets the screening criteria established in the City’s adopted
Vehicle Miles Traveled (VMT) policy to be presumed to have a less-than-
significant VMT impact and exempt from detailed VMT analysis, please provide justification to support the exempt status in align with the City’s VMT policy.
Projects that do not meet the screening criteria should include a detailed VMT
analysis in the DEIR, which should include the following:
• VMT analysis pursuant to the City’s guidelines; if the City has not adopted
guidelines at this point, please use the Office of Planning and Research’s
(OPR) guidelines. Projects that result in automobile VMT per capita above the threshold of significance for existing (i.e. baseline) city-wide or regional values
for similar land use types may indicate a significant impact. If necessary,
mitigation for increasing VMT should be identified. Mitigation should support
the use of transit and active transportation modes. Potential mitigation
measures that include the requirements of other agencies such as Caltrans
are fully enforceable through permit conditions, agreements, or other legally-
binding instruments under the control of the City.
• A schematic illustration of walking, biking and auto conditions at the project
site and study area roadways. Potential safety issues for all road users should be identified and fully mitigated.
• The project’s primary and secondary effects on pedestrians, bicycles,
travelers with disabilities and transit performance should be evaluated, including countermeasures and trade-offs resulting from mitigating VMT
increases. Access to pedestrians, bicycle, and transit facilities must be
maintained.
• Clarification of the intensity of events/receptions to be held at the location
and how the associated travel demand and VMT will be mitigated.
Mitigation Strategies
Location efficiency factors, including community design and regional accessibility, influence a project’s impact on the environment. Using Caltrans’
Smart Mobility 2010: A Call to Action for the New Decade, the proposed project
site is identified as a Close-In Compact Community where community design is moderate and regional accessibility is strong.
Billy Gross, Senior Planner
March 22, 2021
Page 3
“Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
Given the place, type and size of the project, the DEIR should include a robust
Transportation Demand Management (TDM) Program to reduce VMT and greenhouse gas emissions from future development in this area. The measures
listed below have been quantified by California Air Pollution Control Officers
Association (CAPCOA) and shown to have different efficiencies reducing regional VMT:
• Increase in number of affordable housing units in project;
• Orientation of project towards non-auto corridor;
• Pedestrian network improvements;
• Transit access supporting infrastructure (including bus shelter improvements
and sidewalk/ crosswalk safety facilities);
• Bicycle network improvements or Fair Share contribution to such measures;
• Traffic calming measures;
• Implementation of a neighborhood electric vehicle (EV) network, including
designated parking spaces for EVs;
• Limiting parking supply;
• Unbundled parking from property costs;
• Transit and trip planning resources such as a commute information kiosk;
• Real-time transit information system;
• Transit access supporting infrastructure (including bus shelter improvements and sidewalk/ crosswalk safety facilities);
• VMT Banking and/or Exchange program;
Using a combination of strategies appropriate to the project and the site can
reduce VMT, along with related impacts on the environment and State facilities.
TDM programs should be documented with annual monitoring reports by a TDM coordinator to demonstrate effectiveness. If the project does not achieve the
VMT reduction goals, the reports should also include next steps to take in order
to achieve those targets.
Please reach out to Caltrans for further information about TDM measures and a toolbox for implementing these measures in land use projects. Additionally,
Federal Highway Administration’s Integrating Demand Management into the
Transportation Planning Process: A Desk Reference (Chapter 8). The reference is available online at:
http://www.ops.fhwa.dot.gov/publications/fhwahop12035/fhwahop12035.pdf.
Billy Gross, Senior Planner
March 22, 2021
Page 4
“Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
Lead Agency
As the Lead Agency, South San Francisco is responsible for all impact mitigation, including any needed improvements to the State Transportation Network (STN).
The project’s fair share contribution, financing, scheduling, implementation
responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures.
Thank you again for including Caltrans in the environmental review process.
Should you have any questions regarding this letter, please contact Laurel Sears at [email protected]. Additionally, for future notifications and requests for
review of new projects, please contact [email protected].
Sincerely,
MARK LEONG
District Branch Chief
Local Development - Intergovernmental Review
c: State Clearinghouse
From: Liliana Rivera <[email protected]>
Sent: Monday, March 22, 2021 4:26 PM
To: Gross, Billy <[email protected]>
Subject: General Plan Project EIR
Hello,
I am writing with my concerns regarding the General Plan environmental impact. First and
foremost, I believe that the plans for the future must center and attempt to remedy the harm that
has been done in the past.
The air quality and pollution on the east side is placing harm disproportionately on communities
of color. This census tract is one of the most pollution burdened areas in the entire state. The
history of industry combined with racist housing policies have led to the present situation where
kids have higher rates of asthma, low birth weight, etc.
There should be an environmental racism tax on the industries that polluted our city, and on the
freeway that adds both particulate matter and noise pollution into the area as well. There needs to
be a focus on health services and investing in green space on the east side to try to mitigate some
of the health impacts that people have suffered. These services should also be accessible to those
who don’t speak English and those who are undocumented, as these groups are already facing
the least amount of protection in our city.
I implore you to prioritize human health and well being over private profit. The city needs to stop
trying to attract a younger, wealthier, whiter demographic and realize that our diverse
community is what makes us stronger. Please focus on creating a better environment for those
families that already live here, and center this racial equity during all of these conversations.
Thank you.
Liliana Rivera
-
From: Marcela Rivera <[email protected]>
Sent: Monday, March 22, 2021 4:10 PM
To: Gross, Billy <[email protected]>
Subject: General Plan EIR
To whom it may concern:
I am writing today to discuss what I would like to see from the General Plan. Looking at land use and planning, I
would like to see more affordable housing. I think the amount of affordable housing currently is no where near
enough. I want to see more parks and green spaces not only in the east side but also in neighborhoods like sunshine
gardens. I think the city needs to create more routes for the free shuttle especially to and from the BART station so
that residents can be less dependent on cars for transportation. I want to see more services for Spanish speaking
families and the city to find a way to better communicate with all its residents. I would also like the city to look
more into the environmental impact of the biotechnology industry and the water levels at oyster point.
Thank you.
‐‐‐‐‐Original Message‐‐‐‐‐
From: O Perez <[email protected]>
Sent: Monday, March 22, 2021 4:58 PM
To: Gross, Billy <[email protected]>
Subject: General Plan EIR
Mr. Gross,
Hope this email finds you well. Please excuse any grammatical errors, as this was hurriedly prepared last
minute.
Below are comments for consideration and inclusion in General Plan EIR review.
SSF General Plan Project
Affordable Housing/Transportation
High rise buildings along Airport Boulevard have been designated to serve the housing needs of ever
growing biotech employees. Consideration for local residents in providing affordable housing should
also be a driving force in both meeting citizen needs and RHNA mandates.
Housing/mixed use (retail) near BART would help mitigate climate change/improve air quality by
discouraging vehicle use.
Cultural Resources/Language Barriers/Public Services Cultural awareness through acceptability and
appreciation would be beneficial through art and recreational programs, in particular Old Town area,
where there exists a majority of Latinx population.
Accessible resources and outreach materials in languages other than English would be very beneficial for
non‐English speakers. Accessibility, interpreter services and ease in participation of agency meetings is
another factor for consideration, to be able to provide equal access to residents to voice concerns.
Parks/Education
Equitable accessibility and outreach in Old Town/Downtown/Pecks Lots areas of recreational and
educational programs for youth. Residents have received several pamphlets and communication about
proven benefits of recreation programs and parks; however, some neighborhoods lack playgrounds for
infants, youth children and teens. Cypress Park has been very beneficial to families; however in need of
infant swings and full‐size basketball court, as well as trees (shade/climate change).
Seniors, in particular Old Town area, have been equally underserved of services and recreational
opportunities. Seniors face need of an art garden with benches to combat loneliness and provide
recreational opportunities. A cultural benefit would be a kiosk on Pine/Linden to serve seniors as well as
memorial garden for community healing.
Sustainability
Sustainable food sources through free community gardens (volunteer based) would be beneficial to
different neighborhoods throughout SSF. It would also promote pride and unity in community, as well as
help in mitigating climate change.
Utilities/Service Systems/Hazards
Affordable and/or free internet services for low income communities is a necessity in 2021 for
educational/school purposes for youth and for those working from home throughout SSF.
Regular inspection of PG&E underground natural gas lines throughout SSF should be mandated and be
available for public view, in particular older areas of SSF.
Housing near Highway 101 is very concerning due to human health issues due to proximity to freeway.
Thank you.
Olga Perez
650‐869‐5942