HomeMy WebLinkAboutReso 114-2022 (22-368)Draft CEQA Resolution
Exhibit A: Original CEQA Findings adopted by Council Resolutions 18-2010 and 43-2013
RESOLUTION NO. 18-2010
CITY COUNCIL, CITY OF SOUTH SAN FRANCISCO STATE OF CALIFORNIA
A RESOLUTION MAKING FINDINGS AND CERTIFYING AN
ENVIIZONMENTAL IMPACT REPORT INCLUDING A
STATEMENT OF OVERRIDING CONSIDERATIONS AND
MITIGATION MONITORING AND REPORTING PROGRAM
FOR THE GATEWAY BUSINESS PARK MASTER PLAN
PROJECT
WHEREAS, Chamberlin Associates submitted an application requesting approval a General
Plan Amendment, Zoning Text Amendment, a Master Plan, a Phase 1 Precise Plan, a preliminary
Transportation Demand Management (TDM) Plan, and a Development Agreement, which would
collectively authorize the phased removal and replacement of existing buildings on the 22.6-acre
project site and construction of five to six new buildings, six stories in height, and two to four
parking structures, in five phases from 2011 to 2020, to be located at the corner of Gateway and
Oyster Point Boulevards (700, 750, 800, 850, 900, and 1000 Gateway Boulevard), in the Gateway
Redevelopment Project Area and Gateway Specific Plan Area ("Gateway Business Park Master Plan
Project" or "Project"); and
WHEREAS, the City determined that an Environmental Impact Report (EIR) was required to
evaluate the impacts of the proposed Project; and
WHEREAS, the Final EIR (FEIR) for the Project consists of the Draft EIR, Response to
Comments, and the Mitigation Monitoring and Reporting Program; and
WHEREAS, the Notice of Preparation was issued on June 16, 2008 and reissued on October
22, 2008; and
WHEREAS, the Draft EIR was prepared and circulated for 45-day public/agency review
period from October 21, 2009 through December 7, 2009; and
WHEREAS, notices of the availability of the Draft EIR were published in the San Mateo
Times, mailed to property owners within a 300-foot radius of the site, noticed to local agencies and
cities, and circulated through the State Clearinghouse; and
WHEREAS, the Planning Commission held a duly noticed meeting during the review period
on November 19, 2009 to take public testimony on the Draft EIR; and
WHEREAS, the Draft Environmental Impact Report reviewed and analyzed the following
potential environmental impacts:
Aesthetics including the visual character of the proposed Project, including lighting;
Biological Resources;
Cultural Resources;
Air Quality, including construction dust;
Geology/Soils, including ground shaking, soil stability, landslides, lateral spreading,
liquefaction and expansive soils;
Hazards/Hazardous materials;
Hydrology/Water Quality, including water quality degradation;
Land Use and Planning, including the maximum square footage of development
allowed by the General Plan;
Noise;
Population and Housing;
Transportation and Traffic, including trips generated in peak hours, impacts to
freeway segments, declines in Level of Service at nearby intersections, and
restrictions on parking to reduce congestion;
Utilities/Service Systems;
Project alternatives; and
Cumulative impacts
WHEREAS, a Final EIR was prepared, including responses to comments received on the
Draft EIR and made available to agencies and individuals from whom comments on the Draft EIR
were received; and
WHEREAS, the Planning Commission reviewed and carefully considered the information in
the Draft EIR and the Final EIR (collectively, "EIR") at a duly noticed public hearing held on
January 21, 2010, and, be resolution, unanimously recommended certification of the EIR, as an
objective and accurate document that reflects the independent judgment of the City in the
identification, discussion and mitigation of the Project's environmental impacts; and
WHEREAS, where feasible, mitigation measures have been incorporated into the Project to
reduce identified impacts to a level of less than significant; and
WHEREAS, no feasible mitigation exists for the significant and unavoidable air quality,
noise, and transportation impacts that would reduce the impacts to ales-than-significant level; and
WHEREAS, the Proj ect cannot be approved unless a Statement of Overriding Considerations
is adopted which evaluates the benefits of the proposed Project against its unavoidable impacts, and
an earlier Statement of Overriding Considerations was made by the City and also applies to the
Project as follows:
The City of South San Francisco approved an update to its General Plan and
Environmental Impact Report in October 1999. The City Council made a statement of
overriding considerations in its approval of the General Plan update, because the
measures identified to mitigate for traffic congestion along US 101 and regional air
pollution would not be sufficient to reduce the impacts to less than significant levels.
2. The Gateway Business Park Master Plan Proj ect would impact some of the same freeway
segments that were identified in the General Plan EIR and whose construction-related
noise and traffic effects could only be partially mitigated.
3 . Therefore, the Statement of Overriding Considerations that was made for approval of the
General Plan would also apply to decision-making on the Gateway Business Park Master
Plan Project by the City.
4. Additionally, the Project offers specific benefits as stated in the Statement of Overriding
Considerations for the Project (attached as Exhibit B and incorporated herein).
NOW, THEREFORE, BE IT RESOLVED that based on the entirety of the record before it, which
includes without limitation, the California Environmental Quality Act, Public Resources Code
21000, et seq. ("CEQA") and the CEQA Guidelines, l4 California Code of Regulations § 15000, et
seq.; the South San Francisco General Plan and General. Plan EIR; the South San Francisco
Municipal Code; the Project applications; the Gateway Business Park Master Plan and Phase 1
Precise Plan, as prepared by DGA Architects, Kenkay Associates, BKF Engineers, Surveyors,
Planners; the EIR, including the Draft and Final EIR prepared for the Gateway Business Park Master
Plan and appendices thereto; all site plans, and all reports, minutes, and public testimony submitted
as part of the Planning Commission's duly noticed November 19, 2009, and January 21, 2010,
meetings; and all site plans, reports, and public testimony submitted as part of the City Council and
Redevelopment Agency's duly noticed, j oint meeting of February 10, 2010; and any other evidence
within the meaning of Public Resources Code §21080(e) and §21082.2), the City Council of the
City South San Francisco hereby finds as follows:
The foregoing recitals are true and correct.
2. The EIR for the Gateway Business Park Master Plan and Phase 1 Precise Plan, as well
as the Exhibits attached to this Resolution, including the CEQA Findings (Exhibit A), the Statement
of Overriding Considerations (Exhibit B), and the Mitigation Monitoring and Reporting Program
Exhibit C), are each incorporated by reference as part of this Resolution.
3. The documents and other material constituting the record for these proceedings are
located at the Planning Division for the City of South San Francisco, 315 Maple Avenue, South San
Francisco, CA 94080, and in the custody of Chief Planner, Susy Kalkin.
4. Based on the City Council's independent judgment and analysis, the City Council
makes the findings regarding the Project's significant impacts and Project alternatives, as set forth in
Exhibit A, attached hereto and incorporated by reference.
5. Based on the City Council's independent judgment and analysis, the City Council
finds that for the reasons set forth in the Statement of Overriding Considerations, attached as Exhibit
B and incorporated herein by reference, the benefits of the Project outweigh the Project's significant
and unavoidable environmental impacts.
BE IT FURTHER RESOLVED that the City Council of the City of South San Francisco
hereby makes the CEQA findings attached as Exhibit A, and certifies EIR-08-0002, including
adoption of a Statement of Overriding Considerations, attached as Exhibit B, and Mitigation
Monitoring and Reporting Program, attached as Exhibit C.
BE IT FURTHER RESOLVED that the Resolution shall become effective immediately upon
its passage and adoption.
I hereby certify that the foregoing Resolution was regularly introduced and adopted by the
City Council of the City of South San Francisco at a regular meeting held on the 10th day of
February, 2010 by the following vote:
AYES: Councilmembers Pedro Gonzalez, Richard A. Garbarino, and Karyl Matsumoto,
Vice Mayor Kevin Mullin and Mayor Mark Addie~o
NOES:None
ABSTAIN:None
ABSENT:None
A
c;~ty
Exhibit A
CEQA Findings
Exhibit C
Mitigation Monitoring and Reporting Program
Included in Final EIR (See Exhibit X to Staff Report); Incorporated Here By Reference)
EXHIBIT A
CEQA FINDINGS
Section I: Introduction
Prior to approving a project for which an EIR has been certified, a lead agency must
make findings as to each significant impact. (Pub. Resources Code, § 21081; CEQA
Guidelines, § 15091, subd. (a).) As articulated in Section 15091(a) of the CEQA
Guidelines:
a) No public agency shall approve or carry out a project for which an
EIR has been certified which identifies one or more significant
environmental effects of the project unless the public agency makes
one or more written findings for each of those significant effects,
accompanied by a brief explanation of the rationale for each finding.
The possible findings are:
1) Changes or alterations have been required in, or
incorporated into, the project which avoid or substantially
lessen the significant environmental effect as identified in the
final EIR.
2) Such changes or alterations are within the responsibility
and jurisdiction of another public agency and not the agency
making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other
agency.
3) Specific economic, legal, social, technological, or other
considerations, including provision of employment
opportunities for highly trained workers, make infeasible the
mitigation measures or project alternatives identified in the
final EIR. (CEQA Guidelines, § 15091.)
A lead agency need not make any findings for impacts that the EIR concludes are
less than significant. (See ibid.; see also Sequoyah Hills Homeowners Assn, v. City of
Oakland (1993) 23 Cal.App.4th 704, 716.) Pursuant to these requirements, the City
hereby makes the following findings with respect to the potentially significant
impacts of the project.
Section II• General Findines
As required by CEQA, the City, in adopting these CEQA Findings and the Statement
of Overriding Considerations, also adopts a Mitigation Monitoring and Reporting
Exhibit A
CEQA Findings
Page 2 of 84
Program for the project. The City finds that the Mitigation Monitoring and Reporting
Program (MMRP), which is incorporated by reference and made a part of these
findings included as Exhibit C to the Resolution, meets the requirements of Public
Resources Code Section 21081.6 by providing for the implementation and
monitoring of measures intended to mitigate potentially significant effects of the
project. In accordance with CEQA and the CEQA Guidelines, the City adopts these
findings as part of the certification of the Final EIR for the project.
For purposes of CEQA and the findings set forth herein, the record of proceedings
for the City's decision on the project consists of, without limitation: a) matters of
common knowledge to the City, including, but not limited to, federal, State and local
laws and regulations; and b) the following documents which are in the custody of
the City, and available for review by the public at the City's Planning Department,
City Hall Annex, 400 Grand Avenue, South San Francisco, CA:
Notice of Preparation and other public notices issued by the City in
conjunction with the project;
The Public Review Draft EIR;
All written comments submitted by agencies and members of the public
during the public comment period on the Draft EIR and responses to those
comments;
The Mitigation Monitoring and Reporting Program;
All findings, statements of overriding consideration, and resolutions
adopted by the City in connection with the Project, and all documents
cited or referred therein;
All final reports, studies, memoranda, maps, correspondence, and all
planning documents prepared by the City or the consultants, or
responsible or trustee agencies with respect to: a) the City's compliance
with CEQA; b) the Project site; or c) the City's action on the Project; and
All documents submitted to the City by agencies or members of the public
in connection with the project.
Pursuant to Public Resources Code Section 21082.1(c)(3), the City also finds that the
Final EIR reflects the City's independent judgment as the lead agency for the project.
Section III• Findings Regarding Potentially Significant Impacts of the Proposed
Project
AESTHETICS
Exhibit A
CEQA Findings
Page 3 of 84
Impact IV.B-4: The proposed project would not create a new source of
substantial light orglare which would adversely affect day or nighttime views in
the area.
Implementation of the proposed project would create new sources of light from
exterior building illumination, lighted vehicle and pedestrian circulation. There are
no residential land uses on-site or within the project vicinity in the East of 101 Area
that would be adversely affected by these new light sources. Lighting would be
designed to appropriately illuminate signage and wayfinding system components to
make information clearly legible at night. The project would follow the lighting
levels as recommended by the Engineering Society of North America for all
pedestrian and vehicular circulation systems. This would maintain appropriate
levels of light at building entries, walkways, courtyards, parking lots, and private
roads at night consistent with minimum levels required by building codes.
Nighttime security lighting would not be expected to substantially increase over
current conditions.
Lighting would be directed onto the specific locations intended for illumination and
would be characteristic of existing lighting in the surrounding industrial areas.
Preparation of a Lighting Design Plan, which will establish policies required to
reduce light and glare impacts, will be required for the Precise and other
subsequent Precise Plan phases of the project. Overall, lighting would be designed to
avoid unnecessary light pollution by use of "cut-off' fixtures designed to prevent the
upward cast of light where appropriate and to consider ambient light generated by
buildings in the design of site lighting systems to help prevent over lighting.
Additional lighting would not have the potential to create "spillage" onto sensitive
land uses, as none exist within the area. As the proposed project calls for an increase
in the density and height of development, nighttime light would increase if
inappropriate levels of light are used or inappropriate lighting plans are
implemented. However, the proposed project including the Precise Plan and all
subsequent phases of the Master Plan as they are designed and constructed would
comply with the guidelines in the Design Element of the East of 101 Area Plan,
including those related to lighting, specifically Guidelines DE-29 and DE-50. Upon
implementation of Mitigation Measure listed below, impacts related to a substantial
increase in light would be less than significant.
Implementation of the proposed project could create new sources of glare from
reflective building surfaces. No residential uses are located within or near the
project site and residential uses are not permitted within the entire East of 101
Area. Land uses in the general vicinity of the project site are mostly limited to office,
R&D, commercial (including childcare facilities, fitness centers, restaurants), and
Exhibit A
CEQA Findings
Page 4 of 84
light industrial uses. However, the project site is visible from US 101. As the
proposed project calls for an increase in development at the site from one-story
buildings to more visible four- to six-story buildings, daytime glare would increase if
reflective materials were used, which could adversely affect views by distant land
uses, such as motorists traveling along US 1011ooking towards the project site to
views of the San Francisco Bay, San Bruno Mountain, and Mt. Diablo.
Mitigation Measure IU.B-4.1 Lighting
In order to reduce sources of light and glare created by project site lighting, the
applicant shall specify fixtures and lighting that maintains appropriate levels of light
at building entries, walkways, courtyards, parking lots and private roads at night
consistent with minimum levels detailed in the City's building codes. These fixtures
shall be designed to eliminate spillover, high intensity, and unshielded lighting,
thereby avoiding unnecessary light pollution.
Prior to issuance of building permits for buildings constructed for the Precise Plan
and each phase of the Master Plan, the applicant shall submit a Lighting Design Plan
for review and approval by the City of South San Francisco Planning Department for
each phase. The plan shall include, but not necessarily be limited to the following:
The Lighting Design Plan shall disclose all potential light sources with the types of
lighting and their locations.
Typical lighting shall include low mounted, downward casting and shielded lights
that do not cause spillover onto adjacent properties and the utilization of motion
detection systems where applicable. Fixture types and heights shall conform to the
following styles, as feasible:
Parking lots and roads-provide round fixtures on 22' poles on raised
concrete footings not to exceed 25' total finished height, appropriately
finished black, or approved equal.
Sidewalks, pathways, and plazas-provide round hardtop on post top
fixtures not to exceed 15'total finished height, appropriately finished black,
or approved equal.
Accent pedestrian lighting-provide bollard style fixtures, not to exceed 42"
total height, appropriately finished black, or approved equal.
o No flood lights shall be utilized.
o Lighting shall not "wash out" structures or any portions of the site.
o Lighting shall be limited to the areas that would be in operation
during nighttime hours.
o Low intensity, indirect light sources shall be encouraged.
o On-demand lighting systems shall be encouraged.
Exhibit A
CEQA Findings
Page 5 of 84
o Mercury, sodium vapor, and similar intense and bright lights shall not
be permitted except where their need is specifically approved and
their source of light is restricted.
o All light sources shall be fully shielded from off-site view.
o All buildings and structures shall consist ofnon-reflecting material or
be painted with nonreflective paint.
o Generally, light fixtures shall not be located at the periphery of the
property and should shut off automatically when the use is not
operating. Security lighting visible from the highway shall be motion-
sensoractivated.
o Use "cut-off' fixtures designed to prevent the upward cast of light and
avoid unnecessary light pollution where appropriate.
o All lighting shall be installed in accordance with the building codes
and the approved lighting plan during construction.
Mitigation Measure IV.B-4.2 Daytime Glare
In order to reduce sources of daytime glare created by reflective building materials,
the applicant shall specify exterior building materials for all proposed structures
constructed for the Precise Plan and each phase of the Master Plan that include the
use of textured or other non-reflective exterior surfaces and nonreflective glass
types, including double glazed and non-reflective vision glass. These materials
would be chosen for their non-reflective characteristics and their ability to reduce
daytime glare. All exterior glass must meet the specifications of all applicable codes
for non-reflective glass and would therefore reduce daytime glare emanating from
the project site.
Finding: Impact IV.B-4: The building design would incorporate a mixture of
materials including glass, stone, pre-cast/GFRC, and painted metal. This mixture of
materials would not create large blocks of glass or reflective materials that would
create excessive glare. Additionally, the proposed project would comply with the
guidelines in the Design Element of the East of 101 Area Plan, including those
related to building design, specifically Guidelines DE-41 and DE-42. However, to
further reduce impacts from glare, implementation of Mitigation Measure IV.B-2
listed above would reduce impacts related to daytime glare to less than significant.
Implementation of Mitigation Measures IV.B-4.1 through IV.B-4.2 identified in this
section would adequately mitigate all potential impacts related to aesthetics. These
impacts would also be reduced to a less than significant level.
BIOLOGICAL RESOURCES
Exhibit A
CEQA Findings
Page 6 of 84
Impact IV.D-1; The proposed project would have a substantial adverse effect,
either directly or through habitat modifications, on species identified as
candidate, sensitive, or special status species in local or regional plans, policies,
or regulations, or by the California Department of Fish and Game or U.S Fish and
Wildlife Services.
Of the thirty-five (35) special status species that have potential to occur on the
project site, as determined by habitat and the aforementioned criteria, only one (1)
has a low potential to occur, the bank swallow. This California threatened species
would not be expected to nest on site as suitable nesting habitat is not present, but it
is possible the species would be transient through the site during foraging activities;
however, the proposed project will not result in a significant impact to this species
as it would avoid construction areas during potential foraging. Project construction
activities associated with implementation of the Precise Plan and Master Plan build
out have potential to result in the destruction of active bird nests during removal of
vegetation or grading, or may potentially result in the abandonment of active nests
due to noise and increased activity. These potential impacts to nesting birds maybe
considered significant.
Mitigation Measure IV.D-1.1 Candidate, Sensitive, or Special Status Species
In order to avoid impacts to nesting birds, special-status birds and/or raptors
during Phase 1 Precise Plan and Master Plan development, the following shall be
implemented prior to commencement of each phase of the proposed project:
Project development activities (disturbances to vegetation, structures and
substrates) shall take place outside of the breeding bird season which
generally runs from March 1-August 31 (as early as February 1 for raptors)
to assist in the avoidance of take (including disturbances which would cause
abandonment of active nests containing eggs and/or young).
OR
If project activities cannot feasibly avoid the breeding bird season, weekly
bird surveys shall begin 30 days prior to disturbance of suitable nesting
habitat to detect any protected native birds in the habitat to be removed and
any other such habitat within 300 feet of the construction work area (within
500 feet for raptors) as access to adjacent property allows. The surveys shall
be conducted by a qualified biologist with experience in conducting breeding
bird surveys. The surveys shall continue on a weekly basis with the last
survey being conducted no more than three days prior to the initiation of
clearance/construction work. If a protected native bird is found, the project
proponent shall delay all clearance/construction disturbance activities in
Exhibit A
CEQA Findings
Page 7 of 84
suitable nesting habitat or within 300 feet of nesting habitat (within 500 feet
for raptor nests) until August 31 or continue the surveys in order to locate
any nests. If an active nest is located, clearing and construction within 300
feet of the nest (within 500 feet for raptor nests) or as determined by a
biological monitor shall be postponed until the nest is vacated and juveniles
have fledged and when there is no evidence of a second attempt at nesting.
Limits of construction to avoid a nest shall be established in the field with
flagging and stakes or construction fencing. Construction personnel shall be
instructed on the sensitivity of the area. The results of the recommended
protective measures described above shall be recorded to document
compliance with the Federal Migratory Bird Treaty Act and the Fish and
Game Code protecting nesting birds.
Finding Impact IV.D-1: The applicant shall require that the construction contractor
implement mitigation measure MM IV.D-1, which requires avoiding ground
disturbing activities during nesting season or conducting pre-construction bird
surveys prior to each project phase and avoiding nests during the nesting season,
thereby reducing the possibility of disturbing or destroying active bird nests. With
implementation of this mitigation measure, this potential impact will be reduced to
less-than-significant.
Impact IV.D-5: The proposed project would conflict with local policies or
ordinances protecting biological resources, such as a tree preservation policy or
ordinance.
A tree survey for the 8.91-acre Phase I Precise Plan was conducted in September
2008, and identified at least 19 treesll within landscaped areas that would be
considered protected under the South San Francisco Tree Preservation Ordinance,
Title 13, Chapter 13.3012. In particular, the popular trees along the site boundaries,
which extend from the Oyster Point access driveway behind 180 and 200 Oyster
Point Boulevard, are considered protected as their circumference would be greater
than 48 inches at 54 inches above natural grade. All of the 19 protected trees would
be removed by implementation of the Precise Plan, which would be considered a
significant impact, as it would conflict with the protected tree ordinance.
Detailed tree surveys have not yet been conducted within remaining portions of the
22.6-acre Gateway Business Park Master Plan due to the fact that trees would need
to be surveyed prior to each phase to account for tree growth. Development
activities associated with future project phases could involve "removal" or "pruning"
of additional protected trees that exceed 48 inches in circumference. Prior to the
start of construction, a qualified biologist or arborist will conduct a tree survey, for
the identification of protected trees, followed by permit application to determine
Exhibit A
CEQA Findings
Page 8 of 84
requirements for removal and replacement of such trees, thereby reducing the
impact to protected trees.
Mitigation Measure IV.D-5.1 Local Policies or Ordinances Protecting Biological
Resources
In order to minimize impacts to protected trees, the project applicant shall retain a
qualified biologist or arborist to conduct preconstruction surveys of trees within the
project site and provide a map to the applicant and the City prior to initiation of
future Master Plan phases.. Each protected tree identified that will be directly
impacted by removal or pruning shall require a Tree Pruning/Removal Permit per
Title 13, Chapter 13.30 of the South San Francisco Municipal Code (SSFMC). This
permit application shall be submitted to the City and its approval must be a
condition of issuance of any grading or building permit. The following outlines the
procedures for obtaining a tree removal permit, and procedures for the subsequent
tree replacement pursuant to the City's Protected Tree Ordinance (Municipal Code
Chapter 13.30).
Owners, or their authorized representative, of protected trees shall obtain a permit to
remove or prune a protected tree. The application shall be on a form furnished by the
department and shall state, among other things, the number and location of the
tree(s) to be removed or pruned by type and the reason for removal or pruning of each.
The application shall also include a photograph with correct botanical identification
of the subject tree(s). When removal or pruning of a protected tree is proposed as part
of or in conjunction with new development the application shall also include: (1) a site
plan showing the location of buildings, structures and proposed site disturbances; (2)
the location of all protected trees on the site; and (3) the protected trees on the site
that would be removed or pruned. An authorized representative of the department
shall make an inspection of any protected tree or site subject to this section and shall
file a written report and his recommendations to the director.
Prior to removal of trees to be conducted during Precise Plan and Master Plan
development, the required replacement of protected trees shall be determined as
set forth in SSFMC Section 13.30.080. Any protected tree that is removed shall be
replaced as follows, and the method of replacement shall be approved as part of the
protected tree removal permit process:
a) Replacement shall be three 24-inch box size or two 36-inch box minimum size
landscape trees for each tree removed as determined below. However, the director
maintains the right to dictate size and species of trees in any new developments.
Exhibit A
CEQA Findings
Page 9 of 84
b) Any protected tree removed without a valid permit shall be replaced by two 36-
inch box minimum size landscape trees for each tree so removed, as determined
below.
c) The director can waive replacement of a protected tree, if a sufficient number of
trees exist on the property to meet all other requirements of the tree preservation
ordinance.
d) If replacement trees, as designated in subsection (b) (1) or (2) of this section, as
applicable, cannot be planted on the property, payment of twice the replacement
value of the tree as determined by the International Society of Arboriculture
Standard shall be made to the City. Such payments shall be deposited in the tree
planted fund to be drawn upon for public tree. purchase and planting. (Ord 1271
Section (part), 2000:Ord 1060 Section 1 (part) 1989).
Finding Impact IV.D-5: Prior to the start of construction, a qualified biologist or
arborist will conduct a tree survey, for the identification of protected trees, followed
by permit application to determine requirements for removal and replacement of
such trees, thereby reducing the impact to protected trees. Implementation of
Mitigation Measure IV.D-2, as described further below, would reduce any significant
project-level and program-level impacts associated with Precise Plan and Master
Plan development to aless-than-significant level.
The geographic context for the analysis of cumulative biological resources impacts
consists of San Mateo County. All future development that may occur in this
geographic region would be subject to existing federal, state and local regulations.
Land uses and development consistent with the proposed project and additional
twenty cities and cumulative projects, could result in a significant loss of
populations and/or essential habitat for special-status plant and animal species, loss
of sensitive natural communities, and wildlife habitat and result in the obstruction
of wildlife movement opportunities. The proposed project does not involve the loss
of existing natural habitat and future development of such habitat in the area would
be very limited. However, the project many involve the removal of trees and/or
impacts to nesting birds, but with the implementation of Mitigation Measures IV.D-
1.1 and IV.D-5.1 these impacts will be reduced to less than significant. Therefore
cumulative biological impacts of the proposed project would be less than
significant.
CULTURAL RESOURCES
Exhibit A
CEQA Findings
Page 10 of 84
Impact IV.E-1: The proposed project would cause a substantial adverse change
in the significance of a historical resource as defined in Section 15064.5
A records search for historic resources was conducted at the Northwest Information
Center (NWIC) of the California Historical Resources Information System (CHRIS) to
determine whether the Gateway Business Park Master Plan area or environs had
been previously studied for resources or contained recorded historic resources.
Additional archival research was completed at the San Mateo County Historical
Association Archives, the archives of the City of South San Francisco's Engineering
Division in the Department of Public Works, and by utilizing other published
sources. A pedestrian surface survey of the project area was also completed.
The project area was not found to contain any recorded historic resources. This area
was not part of the historic development either of the residential/commercial
portion of the City (west of Highway 101), nor of the earliest industrial development
east of Highway 101. In addition, this area has been developed and redeveloped
more than once in the twentieth century, processes that have virtually completely
removed potential for and make the property quite unlikely to contain significant
historic resources that would be impacted by the proposed project. Although no
historic resources were found in the project area, the entire project site would be
subject to ground disturbance through various phases of the project and it is
possible that subsurface deposits may exist or that evidence of such resources has
been obscured by more recent natural or cultural factors and could be uncovered
during construction of the Precise Plan or Master Plan. Historic resources are
protected from unauthorized disturbance by State law and supervisory and
construction personnel should therefore be made aware of the possibility, however
low, of encountering historic materials in this location. Historic materials older than
45 years-bottles, artifacts, privy and disposal pits, structural remains, etc.-may also
have scientific and cultural significance and should be more readily identified.
Mitigation Measure IV.E-1.1 Unknown Historic or Cultural Resources
In order to avoid impacts to unknown historic or cultural resources, if during the
proposed construction of the Precise Plan and all subsequent phases of the Master
Plan any evidence of or cultural resources is uncovered or encountered, all
excavations within 10 meters/30 feet of the discovery shall be halted. In order to
protect these resources from damage, a qualified archaeologist approved by the City
shall determine whether this resource is a "unique archaeological resource" under
36 CFR 800, CEQA Section 15064.5, and/or Public Resources Code Section 21083.2.
If the archaeological resource is determined to be a "unique archaeological
resource," the archaeologist shall formulate a mitigation plan that satisfies the
requirements of, 36 CFR 800, CEQA Section 15064.5, and/or Public Resources Code
Exhibit A
CEQA Findings
Page 11 of 84
21083.2. Work in the vicinity of the find may resume at the completion of a
mitigation plan and/or recovery of the resource.
If the archaeologist determines that the archaeological resource is not a unique
archaeological resource, work can resume, and the archaeologist may record the site
and submit the recordation form to the California Historic Resources Information
System Northwest Information Center.
The archaeologist shall prepare a report of the results of any study prepared as part
of a mitigation plan, following accepted professional practice. Copies of the report
shall be submitted to the City and to the California Historic Resources Information
System Northwest Information Center.
Finding Impact IV.E-1: Although the potential to impact historic resources is
unlikely, mitigation measures to reduce this impact are required. The construction
contractor will halt surrounding excavation activities if evidence of historic or
cultural resources is discovered and a qualified archaeologist shall be brought to the
site to investigate further, thereby reducing the possibility of destroying historic
resources. Upon implementation of these steps as described further in Mitigation
Measure E-1.1 above, this impact would be less than significant.
Impact IV.E-2: The proposed project could cause a substantial adverse change in
the significance of an archeological resource pursuant to Section 15064.5.
A records search for archeological resources was conducted at the Northwest
Information Center (NWIC) of the California Historical Resources Information
System (CHRIS) to determine whether the Gateway Business Park Master Plan area
or environs had been previously studied for resources or contained recorded
archaeological resources. Additional archival research was completed at the San
Mateo County Historical Association Archives, the archives of the City of South San
Francisco's Engineering Division in the Department of Public Works, and by utilizing
in-house resources and other published sources. A pedestrian surface survey of the
project area was completed.
The Gateway Business Park project area was not found to contain any recorded
archaeological resources. Although no archaeological resources were found in the
project area, it is possible that subsurface deposits may exist or that evidence of
such resources has been obscured by more recent natural or cultural factors and
would be uncovered during construction of the Precise Plan or subsequent phases
of the Master Plan since ultimately the entire site would be subject to ground
disturbance. Archaeological resources are protected from unauthorized disturbance
Exhibit A
CEQA Findings
Page 12 of 84
by State law and supervisory and construction personnel should therefore be made
aware of the possibility, however low, of encountering archaeological materials in
this location. In this area, the most common and recognizable evidence of
prehistoric archaeological resources are deposits of shell and/or bones, usually in
fragments, and usually in a darker fine-grained soil (midden); chert, obsidian and
other stone flakes left from manufacturing stone tools, or the tools themselves or
ground stone (mortars, pestles, grinding slabs, arrowheads and spear points), other
artifacts (shell beads, bone tools, etc.), and human burials, often as dislocated bones.
Nevertheless, since archaeological resources could be located in the subsurface, and
impacts to these resources would be unknown until encountered during excavation,
impacts to such resources would be potentially significant.
Mitigation Measure IV.E-2.1 Unknown Archaeological Resources
If an unidentified archaeological resource is uncovered during construction of the
Precise Plan or any subsequent phases of the Master Plan, a qualified archaeologist
approved by the project applicant shall conduct further archival and field study to
identify the presence of archaeological resources in the area surrounding the
discovery. Field study may include, but is not limited to, pedestrian survey,
auguring, and monitoring construction activities as well as other common methods
used to identify the presence of archaeological resources in a fully developed urban
area. If an unidentified archaeological resource is uncovered during any phases of
construction, a qualified archaeologist approved by the project applicant shall first
determine whether this resource is a "unique archaeological resource" under 36
CFR 800, CEQA Section 15064.5, and/or Public Resources Code Section 21083.2. If
the archaeological resource is determined to be a "unique archaeological resource,"
the archaeologist shall formulate a mitigation plan that satisfies the requirements of,
36 CFR 800, CEQA Section 15064.5, and/or Public Resources Code 21083.2. Work in
the vicinity of the find may resume at the completion of a mitigation plan or
recovery of the resource. If the archaeologist determines that the archaeological
resource is not a unique archaeological resource, work will resume, and the
archaeologist may record the site and submit the recordation form to the California
Historic Resources Information System Northwest Information Center. The
archaeologist shall prepare a report of the results of any study prepared as part of a
mitigation plan, following accepted professional practice. Copies of the report shall
be submitted to the City and to the California Historic Resources Information
System Northwest Information Center.
Finding Impact IV.E-2: The construction contractor will halt surrounding
excavation activities if evidence of archaeological resources is discovered and a
qualified archaeologist shall be brought to the site to investigate further, thereby
reducing the possibility of destroying unique archaeological resources. Therefore,
Exhibit A
CEQA Findings
Page 13 of 84
upon implementation of Mitigation Measure E-2.11isted below, this impact would
be less than significant.
Impact IV.E-4: The proposed project could disturb human remains, including
those interred outside offormal cemeteries.
While there is no evidence that human remains are present on the project site, there
is still the potential that the construction phases of the Precise Plan and subsequent
phases of the Master Plan could encounter human remains, which in turn could
result in a potentially significant cultural resource impact.
Mitigation Measure IV.E-4.1 Disturbance of Human Remains
In the event of the discovery of a burial, human bone, or suspected human bone
during construction of the Precise Plan or any subsequent phases of the Master Plan,
all excavation or grading within 100 feet of the find shall halt immediately, the area
of the find shall be protected, and the project applicant immediately shall notify the
San Mateo County Coroner of the find and comply with the provisions of PRC
Section 5097 with respect to Native American involvement, burial treatment, and
re-burial, if necessary. Work may resume once the area is protected or the body is
removed.
Finding Impact IV.E-4: The construction contractor will halt ground-disturbing
activities if human remains are discovered so that the County's Medical Examiner
can investigate further, thereby reducing the possibility of destroying cultural
resources or Native American remains. Therefore, project impacts related to a
disturbance of human remains would be less than significant with implementation
of Mitigation Measure IV.E-4.1.
Impacts related to historical resources tend to be site-specific and are assessed on a
site-by-site basis. The City of South San Francisco would require the applicants of
future development subject to CEQA to assess, determine, and mitigate any potential
impacts related to historical resources that could occur as a result of development,
as necessary. Through compliance with the existing laws and the mitigation
measures listed previously, project impacts associated with historic resources,
archaeological resources, paleontological resources, unique geologic features, and
human remains would be less than significant. The occurrence of these less than
significant impacts would be limited to the project site and would not contribute to
any potentially significant cultural resources impacts that could occur at the sites of
future development subject to CEQA. As such, the proposed project would not
contribute to any potential cumulative impacts related to cultural resources.
Exhibit A
CEQA Findings
Page 14 of 84
Therefore, cumulative impacts related to cultural resources would be less than
significant. Implementation of Mitigation Measures IV.E-2.1 through IV.E-4.1
identified in this section would adequately mitigate all potential impacts related to
cultural resources. These impacts would also be reduced to aless-than-significant
level.
GEOLOGY AND SOILS
Impact IV.F-Z: The proposed project would expose people or structures to
potential substantial adverse effects, including the risk of loss, injury or death
involving exposure to strong seismicground shaking.
The proposed project is located in the seismically active San Francisco Bay Area and
there is a high probability that the proposed development would be subjected to
strong to violent ground shaking from an earthquake during its design life. Strong
seismic ground shaking is considered a potentially significant impact.
Mitigation Measure IV.F-2.1 California Building Code Requirements
The project applicant shall ensure that the project development during all phases of
the Precise and Master Plan meets requirements of the California Building Code Vol.
1 and 2, 2007 Edition, including the California Building Standards, 2007 Edition,
published by the International Conference of Building Officials, and as modified by
the amendments, additions and deletions as adopted by the City of South San
Francisco, California to reduce impacts from strong seismic ground shaking. As new
development occurs over the project site from the Precise Plan and subsequent
phases of the Master Plan, this development would meet the current requirements
existing at each phase of the project. Incorporation of seismic construction
standards would reduce the potential for catastrophic effects of ground shaking,
such as complete structural failure, but will not completely eliminate the hazard of
seismically induced ground shaking.
Mitigation Measure IV.F-2.2 Foundation Engineering and Construction
The project applicant shall ensure that proper foundation engineering and
construction shall be performed during all phases of the Precise and Master Plan in
accordance with the recommendations of a Registered Geotechnical Engineer or
Civil Engineer experienced in geotechnical design and a Registered Structural
Engineer or Civil Engineer experienced in structural design to reduce impacts from
strong seismic ground shaking. As new development is proposed over the project
site from the Precise Plan and subsequent phases of the Master Plan, each
Exhibit A
CEQA Findings
Page 15 of 84
development would require geotechnical evaluation and the preparation of specific
recommendations for each phase of the project based on the site specific location
and proposed building design. The structural engineering design shall incorporate
seismic parameters as outlined in the 2007 California Building Code. The project
Geotechnical Investigation shall establish the seismic design parameters, as
determined by the geotechnical engineer in accordance with requirements of the
2007 California Building Code.
Mitigation Measure IV.F-2.3 Seismic Design Criteria
The project applicant shall obtain building permits during all phases of the Precise
and Master Plan through the City of South San Francisco Building Division. Final
Design Review of planned buildings and structures shall be completed by a licensed
structural engineer for adherence to the seismic design criteria for planned
commercial and industrial sites in the East of 101 Area of the City of South San
Francisco to reduce impacts from strong seismic ground shaking. Buildings shall be
designed in accordance with the East of 101 Area Plan Geotechnical Safety Element
polices, which state that buildings shall be designed to resist earthquakes so that
they not be subject to catastrophic collapse under foreseeable seismic events, and
will allow egress of occupants in the event of damage following a strong earthquake.
As new development is proposed over the project site from the Precise Plan and
subsequent phases of the Master Plan, each development shall require Final Design
Review of planned buildings and structures completed by a licensed structural
engineer for each phase of the project based.
Finding Impact IV.F-2: The project applicant shall require that construction of
buildings on the project site adhere to the requirements of building code provisions
and current foundation-engineering principles designed to minimize earthquake-
induced impacts to safety and the structural integrity of buildings. Implementation
of these requirements as described in Mitigation Measures IV.F-2.1 through 2.3
would ensure proper foundation and structural design, thereby decreasing this
impact to a level of less than significant.
Impact IV.F-4: The proposed project would be subject to seismic-related ground
failure, including liquefaction and landslides or be located on a geologic unit or
soil that is unstable and subject to landslide.
No landslides are mapped across the property. The project site has a naturally
gentle slope, which has been graded to a nearly level pad for the currently existing
development. Due to this grading there is an approximately 1.5:1 (horizontal:
vertical) cut slope along the southeastern border of the project site. There are also
approximately 2:1 (h: v) slopes (likely fill) along Gateway Boulevard. More cuts may
Exhibit A
CEQA Findings
Page 16 of 84
be necessary, requiring construction of retaining walls, which could fail if
improperly designed. The impact of landslides is potentially significant.
Mitigation Measure IU.F-4.1 Landsliding
The project applicant shall ensure all phases of the Precise and Master Plan that
proper foundation engineering and retaining wall design shall be performed under
the direction and guidance of the geotechnical engineer of record and in accordance
with the recommendations of the Geotechnical Investigation. Geotechnical
Investigations for each phase of the Precise and Master Plan shall be reviewed and
approved by the City's Geotechnical Consultant and by the City Engineer for
compliance with the recommendations of the Geotechnical Investigation. As new
development is proposed over the project site from the Precise Plan and subsequent
phases of the Master Plan, each development shall require proper foundation
engineering and retaining wall design in accordance with the recommendations of
the Geotechnical Investigation and reviewed and approved by the City's
Geotechnical Consultant and by the City Engineer for each phase of the project
based.
Finding Impact IV.F-4: Implementation of Mitigation Measure IV.F-4.1 would
ensure proper design of retaining walls and foundations, thereby reducing the
impact of Landsliding to a level of less than significant.
Impact IV.F-5: The proposed project would result in soil erosion.
All phases of the project would involve mass grading in a sensitive area near the San
Francisco Bay. During construction, grading would disturb soil and displace any
topsoil that could potentially impact vicinity drainages, and would eventually
impact Colma Creek and the Bay. This would be a potentially significant impact
during and following site construction activities. The project applicant will ensure
that dust, erosion, and pollution control measures including soil stabilization
techniques and other best management practices will be followed during
construction activities to reduce the potential for loose soils impacting nearby
drainages.
Mitigation Measure IV.F-5.1 Soil Erosion
The project applicant shall complete an Erosion Control Plan to be submitted to the
City in conjunction with the Grading Permit Application for the Precise Plan and
subsequent phases of the Master Plan. The Plan shall include winterization, dust,
erosion and pollution control measures conforming to the ABAG Manual of
Exhibit A
CEQA Findings
Page 17 of 84
Standards for Erosion and Sediment Control Measures, with sediment basin design
calculations. The Erosion Control Plan shall describe the "best management
practices" (BMPs) to be used during and after construction to control pollution
resulting from both storm and construction water runoff. The Plan shall include
locations of vehicle and equipment staging, portable restrooms, mobilization areas,
and planned access routes. Recommended soil stabilization techniques include
placement of straw wattles, silt fences, berms, and gravel construction entrance
areas or other control to prevent tracking sediment onto city streets and into storm
drains. Public works staff or representatives shall visit the site during grading and
construction to ensure compliance with the grading ordinance and plans, and note
any violations, which shall be corrected immediately.
Mitigation Measure IV.F-5.2 Soil Erosion
In accordance with the Clean Water Act and the State Water Resources Control
Board (SWRCB), thecproject applicant shall file a Storm Water Pollution Prevention
Plan (SWPPP) prior to the start of construction of the Precise Plan and all
subsequent phases of the Master Plan. The SWPPP shall include specific best
management practices to reduce soil erosion. This is required to obtain coverage
under the General Permit for Discharges of Storm Water Associated with
Construction Activity (Construction General Permit, 99-08-DWQ).
Finding IV.F-S: The project applicant will ensure that dust, erosion, and pollution
control measures including soil stabilization techniques and other best management
practices will be followed during construction activities to reduce the potential for
loose soils impacting nearby drainages. Implementation of these practices as
described in Mitigation Measures IV.F-S.1 and 5.2 would ensure that soils disturbed
during construction would not be mobilized by either storm- or construction-
related runoff and therefore reduce the impact of soil erosion to a level of less than
significant.
Impact IV.F-6: The proposed project would be located on expansive soils.
The geotechnical investigation performed by Treadwell and Rollo did not identify
expansive material in the sand and sand with clay native site soils. However, some
of the near surface fill materials consist of sandy clay that may have expansive
properties. This impact would be mitigated through adherence to foundation,
pavement and slabs on grade design recommendations put forth in the Geotechnical
Reports prepared for each phase of the project. Recommendations include: over
excavation of materials two feet below foundations and replacement with
engineered fill compacted to 95 percent relative to maximum dry density under
Exhibit A
CEQA Findings
Page 18 of 84
building footprints; floor slabs underneath garages 1 and 2 shall be underlain by 6
inches of
Class II aggregate base compacted to 95 percent relative to maximum dry density;
and the upper 6 inches of soil under pavement areas shall be compacted to 95
percent relative to maximum dry density.
Mitigation Measure (not numbered): Measures as specified in the Geotechnical
Report.
Finding Impact IV.F-6: Incorporation of the measures as specified in the
Geotechnical Report would reduce the impact of expansive soils to a level of less
than significant. Likewise, Geotechnical impacts related to future development in
the East of 101 Area of the City of South San Francisco would involve hazards
associated with site-specific soil conditions, erosion, and groundshaking during
earthquakes. The impacts on each site would be specific to that site and its users
and would not be common or contribute to (or be shared with, in an additive sense)
the impacts on other sites. In addition, development on each site would be subject to
uniform site development and construction standards that are designed to protect
public safety. Therefore, cumulative geology and soils impacts would be less than
significant. Implementation of Mitigation Measures IV.F-2.1 through IV.F-2.3, IV.F-
4.1, IV.F-5.1, and IV.F-5.2 identified in this section would adequately mitigate all
potential impacts related to geology and soils. These impacts would also be reduced
to a less than significant level.
HAZARDOUS MATERIALS
Impact IV.G-1: The proposed project would create a significant hazard to the
public or the environment through the routine transport, use, or disposal of
hazardous materials.
The proposed project could include construction of office uses, and Class-A office
and laboratory buildings for both the Precise Plan and all subsequent phases of the
Master Plan. Class A refers to a research laboratory, not merely an instructional
laboratory. Depending upon the nature of research planned at the proposed
facilities, for which detailed information has not yet been provided, there are likely
to be both hazardous and potentially hazardous materials stored and used on the
site that would eventually require disposal. This could include both biohazards, as
well as chemical hazards. There would also likely be transportation of hazardous
Exhibit A
CEQA Findings
Page 19 of 84
materials to and from the site, probably traveling along Highway 101, Gateway
Boulevard and Oyster Point Boulevard. The impact of routine transport, use, or
disposal of hazardous materials is potentially significant.
Mitigation Measure IV.G-1.1 Hazardous Materials Business Plan
Businesses occupying the project site through all phases of the Precise Plan and
subsequent phases of the Master Plan must complete a Hazardous Materials
Business Plan for the safe storage and use of chemicals. The Business Plan must
include the type and quantity of hazardous materials, a site map showing storage
locations of hazardous materials and where they maybe used and transported from,
risks of using these materials, included in material safety data sheets for each
material, a spill prevention plan, an emergency response plan, employee training
consistent with OSHA guidelines, and emergency contact information. Businesses
qualify for the program if they store a hazardous material equal to or greater than
the minimum reportable quantities. These quantities are 55 gallons for liquids, 500
pounds for solids and 200 cubic feet (at standard temperature and pressure) for
compressed gases. Exemptions include businesses selling only pre-packaged
consumer goods; medical professionals who store oxygen, nitrogen, and/or nitrous
oxide in quantities not more than 1,000 cubic feet for each material, and whom store
or use no other hazardous materials; or facilities that store no more than 55 gallons
of a specific type of lubricating oil, and for which the total quantity of lubricating oil
not exceed 275 gallons for all types of lubricating oil. These exemptions are not
expected to apply to Class A laboratory facilities. Businesses occupying and/or
operating at the proposed project site through all phases of the Precise Plan and
subsequent phases of the Master Plan must submit a business plan prior to the start
of operations, and must review and update the entire Business Plan at least once
every two years, or within 30 days of any significant change. Some of these changes
are new emergency contact information, major increases or decreases in hazardous
materials storage and/or changes in location of hazardous materials. Plans shall be
submitted to the San Mateo County Environmental Health Business Plan Program,
which maybe contacted at (650) 363-4305 for more information. The San Mateo
County Environmental Health Department (SMCEHD) shall inspect the business at
least once a year to ensure the Business Plan is complete and accurate.
Mitigation Measure IV.G-1.2 South San Francisco Municipal Code
Building space thorough all phases of the project must be designed to handle the
intended office and laboratory use, with sprinklers, alarms, vents, and secondary
containment structures, in accordance with the guidelines laid out in Chapter 15.24
Fire Code) of the South San Francisco Municipal Code. Requirements include the
following:
Exhibit A
CEQA Findings
Page 20 of 84
All occupancies and buildings shall be protected throughout by an automatic
sprinkler system installed in accordance with UBC Standard 9-1.
An automatic fire sprinkler system shall be installed in all garbage
compartments, dumb waiter shafts, and storage rooms when located in all
occupancies except Group R, Division 3, detached carports, greenhouses and
Group U occupancies less than 200 square feet. An accessible indicating shut
off valve shall also be installed.
An approved audible anal visual sprinkler flow alarm shall be provided on the
exterior of the building in an approved location. A single approved sprinkler
flow alarm shall be provided on the interior of the building in a normally
occupied location.
For buildings more than four stories in height, the following additional
requirements must be met:
o Products of combustion detectors shall be provided in all mechanical
equipment, electrical, transformer, telephone equipment, elevator
machine or similar rooms.
o Detector(s) shall be located in the air conditioning system. Activation
of any detector shall initiate the fire alarm system and place into
operation all equipment necessary to prevent the recirculation of
smoke.
A smoke control system meeting the requirements of Chapter 9
and Section 1005.3.3.7 of the Uniform Building Code shall be
provided.
A manual fire alarm system shall be provided that will alarm
both audibly/visually throughout the building if activated and
also alert: the Fire Department via an approved monitoring
station. The fire alarm system shall be provided with a public
address system and an outside remote annunciator.
Standby power shall be provided and must conform to Section
403.8 of the California Building Code. These systems must pass
plan review through the City of South San Francisco Planning,
Building, and Fire Departments for the Precise Plan and each
subsequent phase of the Master Plan.
Mitigation Measure IV.G-1.3 Sprinkler System
During construction of the Precise Plan and each subsequent phase of the Master
Plan, the utilities including sprinkler systems shall pass pressure and flush tests to
make sure they perform as designed. At the end of construction of each building
constructed under the Precise Plan and each subsequent phase of the Master Plan,
occupancy shall not be allowed until a final inspection is made by the Fire
Department for conformance of all building systems with the Fire Code and National
Fire Protection Agency Requirements. The inspection shall include testing of
sprinklers systems, alarm systems, ventilation and airflow systems, and secondary
containment systems. The inspection shall include a review of the emergency
Exhibit A
CEQA Findings
Page 21 of 84
evacuation plans. These plans shall be modified as deemed necessary to ensure that
they ensure safety to building occupants.
Mitigation Measure IV,G-1.4 Hazardous Materials Transportation
All transportation of hazardous materials and hazardous waste to and from the site
will be in accordance with Title 49 of the Code of Federal Regulations, US
Department of Transportation (DOT), State of California, and local laws, ordinances
and procedures including placards, signs and other identifying information. These
regulations shall be followed for the Precise Plan and each subsequent phase of the
Master Plan to ensure the safe transport of hazardous materials and waste to and
from the site.
Finding Impact IV G-1: The proposed project would include Class A research
laboratories, which require the use, storage, and transport of hazardous materials.
As described above, registration in the San Mateo County Environmental Health
Hazardous Material Business Plan Program would help to ensure safe and
responsible handling of hazardous materials by site tenants. Construction
inspection for adherence to fire codes would ensure that buildings are equipped
with safety measures including sprinklers, alarms, etc, to minimize potential
impacts of the presence of hazardous materials. Finally, compliance with DOT
regulations would ensure that all necessary safety precautions would betaken
during transport of hazardous materials during all phases of the project. Therefore,
upon implementation of Mitigation Measures IV.G-1.1 through IV.G-1.41isted below,
this impact would be less than significant.
Impact IV.G-2: The proposed project would create a significant hazard to the
public or the
environment through reasonably foreseeable upset and accident conditions
involving the release of hazardous materials into the environment.
Existing buildings potentially contain hazardous materials including waste oil,
asbestos, lead paint, halogenated and non-halogenated solvents, organic
compounds, and petroleum products. Underlying site soils may contain hazardous
materials including motor oil, gasoline, diesel, other chemicals and toxic heavy
metals related to the history of heavy industry in the area. The historic railroad
grade along the southeast edge of the project site may be a source of additional
hazardous materials, including arsenic, chromium, creosote, zinc chloride, or other
wood preservatives. During demolition operations required for the Precise Plan and
subsequent phases of the Master Plan hazardous materials could be released from
structures at the site or from the underlying soils. Following construction,
Exhibit A
CEQA Findings
Page 22 of 84
operations at the proposed facilities are expected to represent a continuing threat to
the environment through accidental release of hazardous materials since the site is
proposed to include Class A laboratory facilities, where hazardous materials are
likely to be stored, used, and ultimately require disposal. This represents a
potentially significant impact. However, implementation of all of the below
mitigation measures would reduce risks from hazardous materials on the project
site. The project site has a history of hazardous material use, and residual
contamination may remain in the surface soils, and in buildings on-site through all
phases of the Precise Plan and the Master Plan. A demolition plan will ensure any
hazardous materials remaining in buildings or building materials will be properly
disposed of. Site soil testing and a soil management plan will ensure that residual
contamination is not mobilized by site grading activities. The development of risk
management plans through the CaIARPP and compliance with BAAQMD and OSHA
standards through all phases of the project would reduce risk of hazardous material
releases related to post construction land uses. Therefore, upon implementation of
Mitigation Measures IV.G-2.1 through IV.G- 2.51isted below, this impact would be
less than significant.
Mitigation Measure IV.G-2,1 Demolition Plans
Demolition plans with permit applications shall be submitted to the City of South
San Francisco Building Department for approval prior to demolition of buildings for
the Precise Plan and subsequent phases of the Master Plan. The Demolition Plans for
safe demolition of existing structures shall include dust control and shall
incorporate measures for the potential release of asbestos or lead and
recommendations from the site surveys for the presence of potentially hazardous
building materials, as well as additional surveys when required by the City. The
Demolition Plans shall address both on-site Worker Protection and offsite resident
protection from both chemical and physical hazards. All contaminated building
materials shall be tested for contaminant concentrations and shall be disposed of to
appropriate licensed landfill facilities. Prior to building demolition, hazardous
building materials such as peeling, chipping and friable lead based paint and
asbestos containing building materials shall be removed in accordance with all
applicable guidelines, laws, anal ordinances. The Demolition Plans shall include a
program of air monitoring for dust particulates and attached contaminants. Dust
control and suspension of work during dry windy days shall be addressed in the
plan. Prior to obtaining a demolition permit from the Bay Area Air Quality
Management District (BAAQMD), an asbestos demolition survey shall be conducted
in accordance with the requirements of BAAQMD Regulation 11, Rule 2.
Additionally, any soil removal plans shall be submitted to the San Mateo County
Groundwater Protection Program (SMGPP).
Mitigation Measure IV.G-2.2 Soil Sampling
Exhibit A
CEQA Findings
Page 23 of 84
Prior to site grading activities for all phases of the project, the applicant shall retain
a licensed Civil Engineer or Professional Geologist to complete additional surface
and subsurface soil sampling to determine if elevated levels of toxic metals,
herbicides, motor oil, other petroleum products, or wood preservatives are present
in site soils for the specific area that would be redeveloped under that phase of the
project. These tests shall take place within the entirety of the project site for that
phase. Results of testing shall be submitted to SMGPP prior to implementation of
any soil removal plans. If contamination exceeding commercial/industrial
guidelines such as the Regional Water Quality Control Board Environmental
Screening Levels for commercial/industrial Sites, USEPA Preliminary Remediation
Goals for commercial/industrial sites, or the California Department of Toxic
Substances Control Human Health Screening Levels is detected, then a Site Soil
Management Plan and Health and Safety Plan shall be prepared and implemented.
Mitigation Measure IV.G-2.3 Contaminated Soils
If contamination of site soils is detected for the Precise Plan or any subsequent
phase of the Master Plan, then results shall be reported to the Department of Toxic
Substance Control (DTSC) and a Site Soil Management Plan shall be prepared in
accordance with recommendations of the environmental consultant and established
procedures for safe removal. Specific mitigation measures designed to protect
human health and the environment will be provided in the Plan. At a minimum the
Plan shall include, but not be limited to the following:
Documentation of the extent of previous environmental investigation and
remediation at the site.
Requirements for site specific Health and Safety Plans (HASPs) to be
prepared by all contractors at the project site. This includes a HASP for all
demolition, grading and excavation on the site, as well as for future
subsurface maintenance work. The HASP shall include appropriate training,
any required personal protective equipment, and monitoring of
contaminants to determine exposure. The HASP will be reviewed and
approved by a Certified Industrial Hygienist.
Description of protocols for the investigation and evaluation of previously
unidentified hazardous materials that could be encountered during project
development, including engineering controls that maybe required to reduce
exposure to construction workers and future users of the site.
Requirements for site-specific construction techniques that would minimize
exposure to any subsurface contamination found to occur. This shall include
treatment and disposal. measures for any contaminated groundwater
removed from excavations, trenches, and dewatering systems in accordance
with San Francisco Bay Regional Water Quality Control Board guidelines.
Sampling and testing plan for excavated soils to determine suitability for
reuse or acceptability for disposal at a state licensed landfill facility.
Exhibit A
CEQA Findings
Page 24 of 84
Restrictions (if any) limiting future excavation or development of the
subsurface by residents and visitors to the proposed development.
The plan shall be reviewed and approved by the responsible jurisdiction
prior to issuance of any demolition, grading and construction permits for the
project.
Mitigation Measure IV.G-2,4 Compliance with Local and State Hazardous
Materials Regulations
Future businesses at the development as a result of the Precise Plan and subsequent
phases of the Master Plan shall check the state and federal lists of regulated
substances available from the San Mateo County Environmental Health Department
SMCEHD). Chemicals on the list are chemicals that pose a major threat to public
health and safety or the environment because they are highly toxic, flammable or
explosive. Businesses shall determine which list to use in consultation with the
SMCEHD. Should businesses qualify for the program they shall complete a CaIARP
registration form and submit it to the SMCEHD. Following registration, they shall
submit a Risk Management Plan (RMP). RMPs are designed to handle accidental
releases and ensure that businesses have the proper information to provide to
emergency response teams if an accidental release occurs. All businesses on the site
as a result of the Precise Plan and subsequent phases of the Master Plan that store
or handle more than a threshold quantity (TQ) of a regulated substance must
develop a RMP and follow it.
Risk Management Plans describe impacts to public health and the environment if a
regulated substance is released near schools, residential areas, hospitals and
childcare facilities. RMPs must: include procedures for: keeping employees and
customers safe, handling regulated substances, training staff, maintaining
equipment, checking that substances are stored safely, and responding to an
accidental release.
Mitigation Measure IV.G-2.5 Compliance with BAAQMD Regulations
Each independent R&D facility operating on the property shall obtain necessary
permits and comply with monitoring and inspection requirements of the BAAQMD.
Future operations shall comply with all local, state and federal requirements for
emissions. Each facility shall also meet OSHA and California OSHA standards for
R&D facilities. This includes plan review by the City of South San Francisco to
examine if the proposed development plans meet the same standards as for other
similar facilities. Engineering controls, such as exhaust hoods, filtration systems,
spill kits, fire extinguishers, and other controls, shall be incorporated into laboratory
facilities to meet OSHA and California OSHA requirements. These standards are
Exhibit A
CEQA Findings
Page 25 of 84
primarily designed to maintain. worker safety, but also function to reduce the risk of
accidental upset and limit potential hazardous emissions.
Finding Impact IV.G-2: Implementation of all of the above mitigation measures
would reduce risks from hazardous materials on the project site. The project site
has a history of hazardous material use, and residual contamination may remain in
the surface soils, and in buildings on-site through all phases of the Precise Plan and
the Master Plan. A demolition plan will ensure any hazardous materials remaining
in buildings or building materials will be properly disposed of. Site soil testing and a
soil management plan will ensure that residual contamination is not mobilized by
site grading activities. The development of risk management plans through the
CaIARPP and compliance with BAAQMD and OSHA standards through all phases of
the project would reduce risk of hazardous material releases related to post
construction land uses. Therefore, upon implementation of Mitigation Measures
IV.G-2.1 through IV.G- 2.5 listed below, this impact would be less than significant.
Impact IV.G-3: The proposed project could emit hazardous emissions or handle
hazardous or acutely hazardous materials, substances or waste within one-
quartermile of an existing or proposed school.
The nearest school or childcare site to the project is the YMCA of San Francisco
Gateway Childcare center located at 559 Gateway Boulevard, less than aquarter-
mile southwest of the project site. The project site itself also houses Genentech's
Second Generation, a childcare facility serving Genentech's employees that would be
in operation through Phase 1a of the Precise Plan. The project currently contains
hazardous materials that could be released during demolition and site grading
activities thorough all phases of the project. Implementation of the mitigation
measures previously discussed would incorporate management and testing
procedures relating to hazardous materials during the construction and operation
phases of the project, thereby minimizing the potential for the emission of
hazardous materials to nearby school facilities. Therefore, upon implementation of
Mitigation Measures IV.G-3.1 through IV.G-3.71isted below, this impact would be
less than significant.
Mitigation Measure IV.G-3.1 Hazardous Materials Business Plan
Businesses occupying the development through all phases of the Precise Plan and
subsequent phases of the. Master Plan must complete a Hazardous Materials
Business Plan for the safe storage and use of chemicals. The Business Plan must
include the type and quantity of hazardous materials, a site map showing storage
locations of hazardous materials and where they maybe used and transported from,
risks of using these materials, included in material safety data sheets for each
Exhibit A
CEQA Findings
Page 26 of 84
material, a spill prevention plan, an emergency response plan, employee training
consistent with OSHA guidelines, and emergency contact information. Businesses
qualify for the program if they store a hazardous material equal to or greater than
the minimum reportable quantities. These quantities are 55 gallons for liquids, 500
pounds for solids and 200 cubic feet (at standard temperature and pressure) for
compressed gases.
Exemptions include businesses selling only pre-packaged consumer goods; medical
professionals who Store oxygen, nitrogen, and/or nitrous oxide in quantities not
more than 1,000 cubic feet for each material, and whom store or use no other
hazardous materials; or facilities that store no more than 55 gallons of a specific
type of lubricating oil, and for which the total quantity of lubricating oil not exceed
275 gallons for all types of lubricating oil. These exemptions are not expected to
apply to Class A laboratory facilities. Businesses occupying and/or operating at the
proposed development must submit a business plan prior to The start of operations,
and must review and update the entire Business Plan at least once every two years,
or within 30 days of any significant change. Some of these changes are new
emergency contact information, major increases or decreases in hazardous
materials storage and/or changes in location of hazardous materials. Plans shall be
submitted to the San Mateo County Environmental Health Business Plan Program,
which maybe contacted at (650) 363-4305 for more information. The San Mateo
County Environmental Health Department (SMCEHD) shall inspect the business at
least once a year to ensure the Business Plan is complete and accurate.
Mitigation Measure IV.G-3.2 Hazardous Materials Transportation
All transportation of hazardous materials and hazardous waste to and from the site
will be in accordance with Title 49 of the Code of Federal Regulations, US
Department of Transportation (DOT), State of California, and local laws, ordinances
and procedures including placards, signs and other identifying information. These
regulations shall be followed for the Precise Plan and each subsequent phase of the
Master Plan to ensure the safe transport of hazardous materials and waste to and
from the site.
Mitigation Measure IV.G-3.3 Demolition Plans
Demolition plans with permit applications shall be submitted to the City of South
San Francisco Building Department for approval prior to demolition of buildings for
the Precise Plan and subsequent phases of the Master Plan. The Demolition Plans for
safe demolition of existing structures shall include dust control and shall
incorporate measures for the potential release of asbestos or lead and
recommendations from the site surveys for the presence of potentially hazardous
Exhibit A
CEQA Findings
Page 27 of 84
building materials, as well as additional surveys when required by the City. The
Demolition Plans shall address both on-site Worker Protection and offsite resident
protection from both chemical and physical hazards. All contaminated building
materials shall be tested for contaminant concentrations and shall be disposed of to
appropriate licensed landfill facilities. Prior to building demolition, hazardous
building materials such as peeling, chipping and friable lead based paint and
asbestos containing building materials shall be removed in accordance with all
applicable guidelines, laws, and ordinances. The Demolition Plans shall include a
program of air monitoring for dust particulates and attached contaminants. Dust
control and suspension of work during dry windy days shall be addressed in the
plan. Prior to obtaining a demolition permit from the Bay Area Air Quality
Management District (BAAQMD), an asbestos demolition survey shall be conducted
in accordance with the requirements of BAAQMD Regulation 11, Rule 2.
Additionally, any soil removal plans shall be submitted to the San Mateo County
Groundwater Protection Program (SMGPP).
Mitigation Measure IV.G-3.4 Soil Sampling
Prior to site grading activities for all phases of the project, the applicant shall retain
a licensed Civil Engineer or Prc-fessional Geologist to complete additional surface
and subsurface soil sampling to determine if elevated levels of toxic metals,
herbicides, motor oil, other petroleum products, or wood preservatives are present
in site soils for the specific area that would be redeveloped under that phase of the
project. These tests shall take place within the entirety of the project site for that
phase. Results of testing shall be submitted to SMGPP prior to implementation of
any soil removal plans. If contamination exceeding commercial/industrial
guidelines such as the Regional Water Quality Control Board Environmental
Screening Levels for commercial/industrial Sites, USEPA Preliminary Remediation
Goals for commercial/industrial sites, or the California Department of Toxic
Substances Control Human Health Screening Levels is detected, then a Site Soil
Management Plan and Health and Safety Plan shall be prepared and implemented.
Mitigation Measure IV.G-3.5 Contaminated Soils
If contamination of site soils is detected for the Precise Plan or any subsequent
phase of the Master Plan, then results shall be reported to the Department of Toxic
Substance Control (DTSC) and a Site Soil Management Plan shall be prepared in
accordance with recommendations of the environmental consultant and established
procedures for safe removal. Specific mitigation measures designed to protect
human health and the environment will be provided in the Plan. At a minimum the
Plan shall include, but not be limited to the following:
Documentation of the extent of previous environmental investigation and
remediation at the site,.
Exhibit A
CEQA Findings
Page 28 of 84
Requirements for site specific Health and Safety Plans (HASPs) to be
prepared by all contractors at the project site. This includes a HASP for all
demolition, grading and excavation on the site, as well as for future
subsurface maintenance work. The HASP shall include appropriate training,
any required personal protective equipment, and monitoring of
contaminants to determine exposure. The HASP will be reviewed and
approved by a Certified Industrial Hygienist.
Description of protocols for the investigation and evaluation of previously
unidentified hazardous materials that could be encountered during project
development, including engineering controls that maybe required to reduce
exposure to construction workers and future users of the site.
Requirements for site-specific construction techniques that would minimize
exposure to any subsurface contamination found to occur. This shall include
treatment and disposal measures for any contaminated groundwater
removed from excavations, trenches, and dewatering systems in accordance
with San Francisco Bay Regional Water Quality Control Board guidelines.
Sampling and testing plan for excavated soils to determine suitability for
reuse or acceptability for disposal at a state licensed landfill facility.
Restrictions (if any) limiting future excavation or development of the
subsurface by residents and visitors to the proposed development.
The plan shall be reviewed and approved by the responsible jurisdiction
prior to issuance of any demolition, grading and construction permits for the
project.
Mitigation Measure IV.G-3.6 Compliance with Local and State Hazardous
Materials Regulations
Future businesses at the development as a result of the Precise Plan and subsequent
phases of the Master Plan shall check the state and federal lists of regulated
substances available from the San Mateo County Environmental Health Department
SMCEHD). Chemicals on the list are chemicals that pose a major threat to public
health and safety or the environment because they are highly toxic, flammable or
explosive. Businesses shall determine which list to use in consultation with the
SMCEHD. Should businesses qualify for the program they shall complete a CaIARP
registration form and submit it to the SMCEHD. Following registration, they shall
submit a Risk Management Plan (RMP). RMPs are designed to handle accidental
releases and ensure that businesses have the proper information to provide to
emergency response teams if an accidental release occurs. All businesses on the site
as a result of the Precise Plan and subsequent phases of the Master Plan that store
or handle more than a threshold quantity (TQ) of a regulated substance must
develop a RMP and follow it. Risk Management Plans describe impacts to public
health and the environment if a regulated substance is released near schools,
residential areas, hospitals and childcare facilities. RMPs must include procedures
for: keeping employees and customers safe, handling regulated substances, training
Exhibit A
CEQA Findings
Page 29 of 84
staff, maintaining equipment, checking that substances are stored safely, and
responding to an accidental release.
Mitigation Measure IV.G-3.7 Compliance with BAAQMD Regulations
Each independent R&D facility operating on the property shall obtain necessary
permits and comply with monitoring and inspection requirements of the BAAQMD.
Future operations shall comply with all local, state and federal requirements for
emissions. Each facility shall also meet OSHA and California OSHA standards for
R&D facilities. This includes plan review by the City of South San Francisco to
examine if the proposed development plans meet the same standards as for other
similar facilities. Engineering controls, such as exhaust hoods, filtration systems,
spill kits, fire extinguishers, and other controls, shall be incorporated into laboratory
facilities to meet OSHA and California OSHA requirements. These standards are
primarily designed to maintain worker safety, but also function to reduce the risk of
accidental upset and limit potential hazardous emissions.
The project site is located within 1/4 mile of an existing school and has a history of
hazardous material use. Residual contamination may remain in the surface soils and
in buildings on-site. A demolition plan will ensure any hazardous materials
remaining in buildings or building materials will be properly disposed of. Site soil
testing and a soil management plan will ensure that residual contamination is not
mobilized by site grading activities. The development of risk management plans
through the CaIARPP and compliance with BAAQMD and OSHA standards would
reduce risk of hazardous material releases related to post construction land uses to
a level of less than significant.
Finding Impact IU.G-3: ImpleYnentation of the mitigation measures would
incorporate management and testing procedures relating to hazardous materials
during the construction and operation phases of the project, thereby minimizing the
potential for the emission of hazardous materials to nearby school facilities.
Therefore, upon implementation of Mitigation Measures IV.G-3.1 through IV.G-3.7
listed above, this impact would be less than significant.
Impact IV.G-4: The proposed project would be located on a site which is included
on a list of
hazardous materials sites compiled pursuant to Government Code Section
65962.5 and, as a result, it would create a significant hazard to the public or the
environment.
Exhibit A
CEQA Findings
Page 30 of 84
The site is included on the "Cortese List". Portions of the project site are listed on the
following governmental databases: FINDS, RCRA -SQG, RCRA-LQG, RCRA non-gen,
HAZNET, LUST, Cortese, SWEEPS, and San Mateo County Hazardous Materials
Business Plan. Hazardous materials onsite include batteries, lamps, pesticides,
thermostats, Silver, chlorobenzene, chloroform, potassium cyanide, liquids with
halogenated organic compounds, other organic compounds, halogenated and
nonhalogenated solvents, and waste oil. Additionally, Leaking Underground Storage
Tanks at the Federal Express facility and adjacent parcels have affected
groundwater, and there contamination due to herbicides and wood preservatives
associated with the railroad grade at the southeastern edge of the project site. This
represents a potentially significant impact.
Mitigation Measure IV.G-4.1 Demolition Plans
Demolition plans with permit applications shall be submitted to the City of South
San Francisco Building Department for approval prior to demolition of buildings for
the Precise Plan and subsequent phases of the Master Plan. The Demolition Plans for
safe demolition of existing structures shall include dust control and shall
incorporate measures for the potential release of asbestos or lead and
recommendations from the site surveys for the presence of potentially hazardous
building materials, as well as additional surveys when required by the City. The
Demolition Plans shall address both on-site Worker Protection and offsite resident
protection from both chemical and physical hazards. All contaminated building
materials shall be tested for contaminant concentrations and shall be disposed of to
appropriate licensed landfill facilities. Prior to building demolition, hazardous
building materials such as peeling, chipping and friable lead based paint and
asbestos containing building materials shall be removed in accordance with all
applicable guidelines, laws, and ordinances. The Demolition Plans shall include a
program of air monitoring for dust particulates and attached contaminants. Dust
control and suspension of work during dry windy days shall be addressed in the
plan. Prior to obtaining a demolition permit from the Bay Area Air Quality
Management District (BAAQMD), an asbestos demolition survey shall be conducted
in accordance with the requirements of BAAQMD Regulation 11, Rule 2.
Additionally, any soil removal plans shall be submitted to the San Mateo County
Groundwater Protection Program (SMGPP).
Mitigation Measure IV.G-4.2 Soil Sampling
Prior to site grading activities for all phases of the project, the applicant shall retain
a licensed Civil Engineer or Professional Geologist to complete additional surface
and subsurface soil sampling to determine if elevated levels of toxic metals,
herbicides, motor oil, other petroleum products, or wood preservatives are present
in site soils for the specific area that would be redeveloped under that phase of the
Exhibit A
CEQA Findings
Page 31 of 84
project. These tests shall take place within the entirety of the project site for that
phase. Results of testing shall be submitted to SMGPP prior to implementation of
any soil removal plans. If contamination exceeding commercial/industrial
guidelines such as the Regional Water Quality Control Board Environmental
Screening Levels for commercial/industrial Sites, USEPA Preliminary Remediation
Goals for commercial/industrial sites, or the California Department of Toxic
Substances Control Human Health Screening Levels is detected, then a Site Soil
Management Plan and Health and Safety Plan shall be prepared and implemented.
Mitigation Measure IV,G-4.3 Contaminated Soils
If contamination of site soils is detected for the Precise Plan or any subsequent
phase of the Master Plan, then results shall be reported to the Department of Toxic
Substance Control (DTSC) and a Site Soil Management Plan shall be prepared in
accordance with recommendations of the environmental consultant and established
procedures for safe removal. Specific mitigation measures designed to protect
human health and the environment will be provided in the Plan. At a minimum the
Plan shall include, but not be limited to the following:
Documentation of the extent of previous environmental investigation and
remediation at the site.
Requirements for site specific Health and Safety Plans (HASPs) to be
prepared by all contractors at the project site. This includes a HASP for all
demolition, grading and excavation on the site, as well as for future
subsurface maintenance work. The HASP shall include appropriate training,
any required personal protective equipment, and monitoring of
contaminants to determine exposure. The HASP will be reviewed and
approved by a Certified. Industrial Hygienist.
Description of protocols for the investigation and evaluation of previously
unidentified hazardous materials that could be encountered during project
development, including engineering controls that maybe required to reduce
exposure to construction workers and future users of the site.
Requirements for site-specific construction techniques that would minimize
exposure to any subsurface contamination found to occur. This shall include
treatment and disposal measures for any contaminated groundwater
removed from excavations, trenches, and dewatering Water Quality Control
Board guidelines.
Sampling and testing plan for excavated soils to determine suitability for
reuse or acceptability for disposal at a state licensed landfill facility.
Restrictions (if any) limiting future excavation or development of the
subsurface by residents and visitors to the proposed development.
The plan shall be reviewed and approved by the responsible jurisdiction
prior to issuance of any demolition, grading and construction permits for the
project.
Exhibit A
CEQA Findings
Page 32 of 84
Finding Impact IV.G-4: The subject property is listed on numerous government
hazardous material lists as a result of storage and disposal of hazardous materials
including, but not limited to: hE~avy metals, batteries, halogenated and non-
halogenated solvents, organic compounds and motor oil. There may also be residual
contamination related to the removal of leaking underground storage tanks.
Demolition plans would be submitted for the Precise Plan and each subsequent
phase of the Master Plan. The demolition plans would ensure any hazardous
materials remaining in buildings or building materials would be properly disposed
of. Site soil testing and a soil management plan would ensure that residual
contamination is not mobilized. by site grading activities. Implementation of a site
health and safety plan would ensure worker protection, decreasing Impact IV.G-4 to
a level of less than significant.. Therefore, upon implementation of Mitigation
Measures IV.G-4.1 through IV.G-4.31isted below, this impact would be less than
significant.
HYDROLOGY
Impact IV.H-1: The proposed project would violate water quality standards or
waste discharge requirements.
The project will involve an intensification of land-use through the gradual increase
in development on the site through construction of the Precise Plan and subsequent
phases of the Master Plan. Development of these phases would result in the
incremental increase in floor area and number of occupants. This increased use may
increase non-point source pollution to receiving waters. Non-point source
pollutants (NPS) are washed by rainwater from roofs, landscape areas, and streets
and parking areas into the drainage network. Typical industrial NPS pollutants for
various industrial activities are listed in Table IV.H-1 in the EIR. Development of the
proposed project would contribute to the levels of NPS pollutants and litter entering
downstream waters, including San Francisco Bay. An increase in NPS pollutants
could have adverse effects on wildlife, vegetation, and human health. NPS pollutants
could also infiltrate into groundwater and degrade the quality of potential
groundwater drinking sources.
Mitigation Measure IV.H-1.1 SWPPP
Pursuant to NPDES requirements, the project applicant shall develop a SWPPP for
the Precise Plan and each subsequent phase of the Master Plan to protect water
quality during and after construction of each phase. The project SWPPP shall
include, but is not limited, to the following mitigation measures for the construction
period:
Exhibit A
CEQA Findings
Page 33 of 84
Erosion control/soil stabilization techniques such as straw mulching, erosion
control blankets, erosion control matting, and hydro-seeding, shall be
utilized, in accordance with the regulations outlined in the ABAG Manual of
Standards for Erosion and Sediment Control Measures. Silt fences shall be
installed down slope of all graded slopes. Hay bales shall be installed in the
flow path of graded areas receiving concentrated flows and around storm
drain inlets.
Best management practices" (BMPs) for preventing the discharge of other
construction related NPDES pollutants beside sediment (i.e. paint, concrete,
etc) to dovvnstream wat:ers.
After construction is completed, all drainage facilities shall be inspected for
accumulated sediment, and these drainage structures shall be cleared of
debris and sediment. Long-term mitigation measures to be included in the
project SWPPP shall include, but are not limited to, he following:
o Description of potential sources of erosion and sediment at the
project site. Industrial activities and significant materials and
chemicals that could be used at the proposed project site should be
described. This will include a thorough assessment of existing and
potential pollutant sources.
o Identification of BMPs to be implemented at the project site based on
identified industrial activities and potential pollutant sources.
Emphasis shall be placed on source control BMPs, with treatment
controls used as needed.
o Development of a monitoring and implementation plan. Maintenance
requirements and frequency shall be carefully described including
vector control, clearing of clogged or obstructed inlet or outlet
structures, vegetation/landscape maintenance, replacement of media
filters, regular sweeping of parking lots and other paced areas, etc.
Wastes removed from BMPs maybe hazardous, therefore,
maintenance costs should be budgeted to include disposal at a proper
site.
o The monitoring and maintenance program shall be conducted at the
frequency agreed upon by the RWQCB and/or City of South San
Francisco. Monitoring and maintenance shall be recorded and
submitted annually to the SWRCB. The SWPPP shall be adjusted, as
necessary, to address any inadequacies of the BMPs.
o The applicant shall prepare informational literature and guidance on
industrial and commercial BMPs to minimize pollutant contributions
from the proposed development. This information shall be distributed
to all employees at the project site. At a minimum the information
shall cover: a) proper disposal of commercial cleaning chemicals; b)
proper use of landscaping chemicals; c) clean-up and appropriate
disposal of hazardous materials and chemicals; and d) prohibition of
any washing and dumping of materials and chemicals into storm
drains.
Exhibit A
CEQA Findings
Page 34 of 84
Mitigation Measure IV.H-1.2 Erosion Control Plans
The applicant shall complete Erosion Control Plans to be submitted to the City of
South San Francisco in conjunction with the Grading Permit Application for the
Precise Plan and each subsequent phase of the Master Plan. The Erosion Control
Plans shall include controls for winterization, dust, erosion, and pollution in
accordance with the ABAG Manual of Standards for Erosion and Sediment Control
Measures. The Plans shall also describe the BMPs to be used during and following
construction to control pollution resulting from both storm and construction water
runoff. The Plans shall include locations of vehicle and equipment staging, portable
restrooms, mobilization areas, and planned access routes. Public works staff or
representatives shall visit the site during grading and construction of the Precise
Plan and all subsequent phases of the project to ensure compliance with the grading
ordinance and plans, and note any violations, which shall be corrected immediately.
Finding Impact IV.H-1: Implementation of this mitigation measure will be required
and enforced through the MMRP. The implementation of Water Quality BMPs for
stormwater runoff from the loading and trash area, would reduce the level of
potential pollutants that may enter the San Francisco Bay. Implementation of a
SWPPP including BMPs to control erosion and siltation during the construction
phase of the project will reduce erosion and siltation on and off the project site. The
long-term mitigation measures in the SWPPP are important to mitigate the
potentially increased non-point source pollution due to the intensified land-use. The
short- and long-term mitigations and BMPs outlined above will serve to reduce the
potentially significant impacts of increased non-point source pollution and
increased sedimentation to receiving waters during construction activities to a level
of less than significant.
NOISE
Finding Noise-2: Implementation of this mitigation measure will be required and
enforced through the MMRP. 7'he use of best management practices, identified in the
mitigation measure, would ensure that construction-related noise impacts do not
exceed the City-established thresholds. Accordingly, the mitigation measure would
reduce this impact to a level ofless-than-significant.
Impact IV.J-1: The proposed project could result in exposure of persons to or
generation of noise in excess of standards established in the local general plan
or noise ordinance, or applicable standards of other agencies. Operational noise
Exhibit A
CEQA Findings
Page 35 of 84
at the site, such as that created by HVAC equipment, would exceed the noise
generation standards set forth in the City's Municipal Code.
The heating, ventilation and air-conditioning (HVAC) equipment for the project
buildings will likely be located on the roof-tops of the buildings. At this time the
details of the HVAC system are not known and therefore, precise predictions can not
be made regarding the noise levvels at the nearby land uses. It is possible that HVAC
noise levels could exceed the limits of the Municipal Code at adjacent noise sensitive
land uses such as the Larkspur Landing Hotel. This is considered to be a potentially
significant impact.
Mitigation Measure IV.J-1.1 Operational Noise
As the proposed project moves forward an analysis of the noise generated by the
project's mechanical equipment should be conducted to assess the proposed
equipment with respect to the standards of 60 dBA at the property line between the
hours of 10 p.m. and 7 a.m. and 65 dBA at the property line between the hours of 7
a.m. and 10 p.m. The analysis should specify the noise control measures required to
meet these noise levels. Specific measures can not be specified at this time because
of the lack of detailed information on the HVAC equipment design and location.
Typical measures include barriers or enclosures around rooftop equipment. Other
measures include duct silencers and acoustical louvers at the ventilation openings.
Once the noise control measures are included in the design a letter should be
submitted to the City Building Division should require a letter from the designer
stating that the project has been designed to meet the City's Standards.
Finding Impact IV.J-1: Implementation of Mitigation Measure IV.J-1.1 would reduce
this impact to a less than significant level by requiring the project's HVAC design to
include noise control measures adequate to meet the City's Noise Standards.
Impact IV.J-2: The proposed project could result in exposure of persons to or
generation of noise in excess of standards established in the local general plan
or noise ordinance, or applicable standards of other agencies. The proposed
project could expose persons to traffic-related noise levels greater than the
upper limit of satisfactory noise levels for commercial land use of CNEL 70 dBA.
In the future, the proposed project buildings will be exposed to a CNEL of up to 76
dBA due to traffic along Oyster Point Boulevard and Gateway Boulevard. The city
will require that an analysis of noise reduction requirements be conducted and
noise insulation features be included, as needed, in the design. This is considered to
be a potentially significant impact.
Exhibit A
CEQA Findings
Page 36 of 84
Mitigation Measure IV.J-2.1 Future Traffic Noise
Prior to the approval of any precise plan for the project site, an acoustical analysis
shall be prepared by a qualified acoustical consultant in order to determine the
measures required to achieve acceptable interior noise levels for the buildings
included as part of the precise plan. The East of 101 Area Plan contains interior
noise level goal of Leq 45 dBA. 'This will require a noise reduction of up to 30 dBA.
This analysis can not be made at this time because of the lack of detailed
information on the glazing typE~ and exterior facade construction. Typical measures
include sound-rated windows and special exterior wall construction.
Finding Impact IV.J-2: Implementation of Mitigation Measure IV.J-2.1 will reduce
this impact to a less than significant level by requiring sound-rated windows and
special exterior wall construction as necessary to meet the East of 101 Area Plan
interior noise level goal.
Impact IV.J-5: The proposed project could result in exposure of persons to or
generation of excessive groundbornevfbration orgroundborne noise levels.
Construction equipment could generate noticeable vibration at adjacent buildings
on and off the site. The greatest potential for vibration generation would be during
the excavation and foundation construction activities. Pile driving often generates
the highest vibration levels at a construction site, however, pile driving would not be
required for the project. Table IV.J-6 shows the vibration levels for different
construction equipment at their closest approach to the Larkspur Landing South San
Francisco Hotel and commercial buildings both on and off the site. As the equipment
moves farther away, the vibration level drops rapidly, due to absorption from the
ground through which the vibration propagates. Construction activities would result
in vibration levels that are generally within the FTA's impact levels of 80 VdB for
residences and hotels and 83 VdB for offices. The vibration level from a vibratory
roller could slightly exceed thE~ impact criteria (by 1 VdB), but only briefly when it is
at its closest point.
Since the project would be constructed in phases, it is possible that onsite office
buildings could be still be occupied and, therefore, potentially affected during the
construction of a project building. There is also the potential for nearby buildings to
contain vibration sensitive research equipment such as electron microscopes. This
equipment could be affected at lower levels that those discussed above. Therefore,
groundborne vibration is considered a potentially significant impact.
Mitigation Measure IV.J-5.1 Groundborne Vibration
Exhibit A
CEQA Findings
Page 37 of 84
Prior to the commencement of ground clearing activities, the project applicant shall
conduct a
preconstruction survey to determine whether the construction project's activities
would impact vibration sensitive equipment located in adjacent buildings within
100 feet of the construction acl:ivity. If it is determined that no impact would occur
then construction activities shall begin and no further action need be taken. If the
project applicant determines that vibration sensitive equipment has the potential to
be affected, it shall implement .a construction schedule to ensure that construction
activities would occur during tames when vibration sensitive equipment would not
be in use.
Finding Impact IV.J-S: Implementation of Mitigation Measure IV.J-5.1 would reduce
the impact of groundborne vibration to a less than significant level by minimizing
the potential for vibration to interfere with vibration sensitive equipment which
maybe located nearby.
Impact IV.J-6: The proposed project could result in exposure of people residing
or working at the project site to excessive noise levels from a project located
within an airport land use plan or, where such a plan has not been adopted,
within two miles of a public or public use airport.
The proposed project site is located within two miles of the San Francisco
International Airport. Noise contours prepared for the airport indicate that the
project site is located 2,700 feet outside the CNEL 60 dBA contour. Therefore, the
proposed office buildings would be exposed to an aircraft generated CNEL below 60
dBA which is considered satisfactory for commercial development by the policies of
the South San Francisco General Plan and the San Mateo County Airport Land Use
Commission. The policies of the East of 101 Area Plan indicate that office and retail
buildings located in the project area are required to provide a minimum exterior-to-
interior noise attenuation of 2'7 dBA to reduce indoor maximum instantaneous noise
levels (Lmax) from aircraft to the goal of 60 dBA (Policy NO-2). Therefore, airport
noise is a less than significant :impact with respect to the City and County criteria but
mitigation is required to be consistent with the local land use plan (East of 101 Area
Plan). Implementation of Mitigation Measure IV.J-6.1 would ensure that impacts
remain less than significant.
Mitigation Measure IV,J-6.1 Aircraft Noise
Prior to approval of submittal of the first building permit, an aircraft sound
attenuation study must be prepared that indicates what measures will be
implemented to achieve the minimum exterior-to-interior noise attenuation of 27
Exhibit A
CEQA Findings
Page 38 of 84
dBA from aircraft overflights. The study should review the exterior window/wall
and roof/ceiling construction and specify, if necessary, measures such as sound-
ratedwindows and acoustical treatments to the fresh air ventilation system.
Finding Impact IV.J-6: Airport noise is a less than significant impact with respect to
the City and County criteria bui: mitigation is required to be consistent with the local
land use plan (East of 101 Area Plan). Implementation of Mitigation Measure IV.J-6.1
would ensure that impacts remain less than significant.
Implementation of Mitigation Measures IV.J-1.1, IV.J-2.1, IV.J-5.1, and IV.J-6.1
identified in this section would adequately mitigate potential impacts related to
operational noise, future traffic: noise, construction noise impacts to office uses,
groundborne vibration, and aircraft noise. These impacts would also be reduced to a
less than significant level. Ho~Never, construction noise impacts to noise sensitive
uses
TRANSPORTATION AND CIRCULATION
Impact IV.M-1: Project Trip Generation Exceeds 100 Trips During Peak Hours
The half-developed project would generate more than 100 net new trips during the
AM and PM peak hours (412 t~vo-way [inbound + outbound] trips during the AM
peak hour and 357 two-way trips during the PM peak hour [see Table IV.M-21]).
The San Mateo City/County Association of Governments (C/CAG) Agency Guidelines
for the implementation of the 2003 Draft Congestion Management Program ("C/CAG
Guidelines") specifies that local jurisdictions must ensure that the developer and/or
tenants will mitigate all new peak hour trips (including the first 100 trips) projected
to be generated by the development. This would be a significant impact.
Mitigation Measure IU.M-1 Transportation Demand Management Program
The project sponsors shall implement a Transportation Demand Management
TDM) program consistent with the City of South San Francisco Zoning Ordinance
Chapter 20.120 Transportation Demand Management, and acceptable to C/CAG.
These programs, once implemented, must be ongoing for the occupied life of the
development. The C/CAG guidelines specify the number of trips that maybe
credited for each TDM measure. The project's TDM program is included in Appendix
H to the EIR and will generate trip credits to offset the 412 total AM peak hour and
Exhibit A
CEQA Findings
Page 39 of 84
357 PM peak hour net new trips generated by the project by the year 2015. Impact
reduced to a less than significant level.
Finding Impact IV.M-1: Implementation of this mitigation measure would address
the City's Transportation Demand Management program goals. The project's TDM
program is included in Appendix H of the EIR and will generate trip credits to offset
the 412 total AM peak hour and 357 PM peak hour net new trips generated by the
project by the year 2015. The impact is reduced to a less than significant level.
Impact IV.M-ZA: Oyster Point Boulevard /Gateway Boulevard / U.S. 101
Southbound Off-Ramp Flyover
AM Peak Hour: The project would increase volumes by 5.0 percent at a location with
unacceptable LOS F Base Case operation. PM Peak Hour: The project would increase
volumes by 5.2 percent at a location with unacceptable LOS F Base Case operation.
This would be a significant impact.
Mitigation Measure IvM-2A ?015 Intersection Level of Service at Oyster Point
Boulevard /Gateway Boulevard / U.S.101 Southbound Off-Ramp Flyover
Intersection (see Figure IV.M-•20 and Table IV.M-24)
The project should provide a fair share contribution as determined by the City
Engineer to the following measures.
Add a fourth through lane on the westbound Oyster Point Boulevard
approach. In conjunction with this measure, provide an additional
westbound departure lane, which should extend to the Dubuque Avenue /
U.S.101 Northbound On-Ramp intersection.
Restripe the right turn lane on the U.S.101 Southbound Flyover Off-Ramp
intersection approach to also allow through movements. In conjunction with
this measure, provide a third eastbound departure lane.
Resultant Operation: AM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS F-
195 seconds control delay, which is better than Base Case operation (LOS F-
206 seconds control delay) PM Peak Hour: The proposed mitigation will
provide additional capacity and reduce delay, which will improve operation
to LOS E-65.9 seconds control delay, which is better than Base Case
operation (LOS F-104 seconds control delay) Impact reduced to a less than
significant level.
Exhibit A
CEQA Findings
Page 40 of 84
Finding Impact IV.M-2A: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS F-195
seconds control delay, which is better than Base Case operation (LOS F-206 seconds
control delay) PM Peak Hour: The proposed mitigation will provide additional
capacity and reduce delay, which will improve operation to LOS E-65.9 seconds
control delay, which is better than Base Case operation (LOS F-104 seconds control
delay). Thus, this impact will be reduced to a less than significant level.
Impact IV.M-2B: Oyster Point Boulevard /Veterans Boulevard /Project Entrance
AM Peak Hour: The project would increase volumes by 7.9 percent at a location
where unacceptable LOS D Base Case operation would be degraded to unacceptable
LOS E operation.
PM Peak Hour: The project would increase volumes by 9.9 percent at a location with
unacceptable LOS F Base Case operation.
This would be a significant impact.
Mitigation Measure IV.M-2B '1015 Intersection Level of Service at Oyster Point
Boulevard /Veterans Boulevard /Project Driveway Intersection (see Figure
IV.M-20 and Table IV.M-24)
The project should provide a fair share contribution as determined by the City
Engineer to the following measures.
Add one additional through lane on the westbound Oyster Point Boulevard
approach (and continuE~ to the Dubuque Avenue intersection).
Restripe the northbound two-lane driveway approach to provide a left turn
lane and acombined lei=t/through/right turn lane.
Add an exclusive right turn lane on the eastbound Oyster Point Boulevard
approach.
Resultant Operation: AM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS C-
29.1 seconds control delay, which is acceptable operation PM Peak Hour: The
proposed mitigation will provide additional capacity and reduce delay, which
will improve operation to LOS E-67.6 seconds control delay, which is better
than Base Case operation (LOS F-104 seconds delay)
Impact reduced to a less than significant level.
Finding Impact IV.M-2B: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS C-29.1
seconds control delay, which is acceptable operation PM Peak Hour: The proposed
Exhibit A
CEQA Findings
Page 41 of 84
mitigation will provide additional capacity and reduce delay, which will improve
operation to LOS E-67.6 seconds control delay, which is better than Base Case
operation (LOS F-104 seconds delay). Thus the Impact will be reduced to a less than
significant level.
Impact IV.M-2C: Gateway Boulevard /So. Airport Boulevard /Mitchell Avenue
PM Peak Hour: The project would increase volumes by 2.1 percent at a location with
unacceptable LOS F Base Case operation. This would be a significant impact.
Mitigation Measure IV.M-2C 2015 Intersection Level of Service at Gateway
Boulevard /S. Airport Boulevard /Mitchell Avenue Intersection (see Figure
IV.M-20 and Table IV.M-24)
The project should provide a fair share contribution as determined by the City
Engineer to the following measures.
Provide a second right turn lane on the southbound Gateway Boulevard
approach.
Resultant Operation: PM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS E-
59.1 seconds control delay, which is better than Base Case operation (LOS F-
108 seconds delay)
Impact reduced to a less than significant level.
Finding Impact IV.M-2C: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS E-59.1
seconds control delay, which is better than Base Case operation (LOS F-108 seconds
delay). Thus, the impact will be reduced to a less than significant level.
Impact IV.M-ZD: Oyster Poini: Boulevard /Dubuque Avenue / U.S. 101
Northbound On-Ramp
PM Peak Hour: The project would increase volumes by 4.5 percent at a location with
unacceptable LOS F Base Case operation. This would be a significant impact.
Mitigation Measure IV.M-ZD 2015 Intersection Level of Service Oyster Point
Boulevard/DubuqueAvenue/U.S.101 Northbound On-Ramplntersection (see
Figure IV.M-20 and Table IV.M-24)
Exhibit A
CEQA Findings
Page 42 of 84
The project should provide a fair share contribution as determined by the City
Engineer to the following measures.
Add a second right turn lane on the westbound Oyster Point Boulevard
intersection approach.
Resultant Operation: PM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS F-
87.3 seconds control delay, which is better than Base Case operation (LOS F-
271 seconds control delay)
Impact reduced to a less than significant level.
Finding Impact IV.M-2D: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS F-87.3
seconds control delay, which is; better than Base Case operation (LOS F-271 seconds
control delay). Thus, this impact will be reduced to a less than significant level.
Impact IV.M-3A; Oyster Point Boulevard /Dubuque Avenue / U.S.101
Northbound On-Ramp
AM Peak Hour: The project would increase volumes by 4.9 percent in the through
lanes on the eastbound Oyster Point intersection approach where Base Case
volumes would already be exceeding available storage. PM Peak Hour: The project
would increase volumes by 8.3 percent and 8.2 percent in the westbound Oyster
Point Boulevard approach left and right turn lanes, where Base Case volumes would
already be exceeding available storage. This would be a significant impact.
Mitigation Measure IV.M-3A ~.~015 Vehicle Queuing - Synchro Evaluation at
Oyster Point Boulevard /Dubuque Avenue/ U.S.101 Northbound On-Ramp
Intersection-Eastbound Approach (see Figure IV.M-ZO)
See Mitigation Measure IV.M-2D
Resultant Operation: AM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will reduce 95th percentile
vehicle queuing in the eastbound approach through lanes to 268 feet, which
would be better than B<~se Case queuing of 282 feet. PM Peak Hour: The
proposed mitigation will provide additional capacity and reduce delay, which
will reduce 95th percentile queuing in the westbound approach right turn
lane to 1,418 feet, which would be better than Base Case queuing of 2,855
feet, and 95th percentile queuing in the westbound approach left turn lane
would be 1,192 feet, which would be better than Base Case queuing of 1,250
feet.
Impact reduced to a less than significant level.
Exhibit A
CEQA Findings
Page 43 of 84
Finding Impact IV.M-3A: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will reduce 95th percentile vehicle
queuing in the eastbound approach through lanes to 268 feet, which would be
better than Base Case queuing •of 282 feet. PM Peak Hour: The proposed mitigation
will provide additional capacity and reduce delay, which will reduce 95th percentile
queuing in the westbound approach right turn lane to 1,418 feet, which would be
better than Base Case queuing ~of 2,855 feet, and 95th percentile queuing in the
westbound approach left turn lane would be 1,192 feet, which would be better than
Base Case queuing of 1,250 feet. Thus, this impact will be reduced to a less than
significant level.
Impact IV.M-3B: Oyster Point Boulevard /Gateway Boulevard / U.S.101
Southbound Flyover Off- Ramp
AM Peak Hour: The project would increase volumes by 7.1 percent in the Oyster
Point Boulevard eastbound approach through lanes, where Base Case volumes
would already be exceeding available storage. This would be a significant impact.
Mitigation Measure IV.M-3B 2015 Vehicle Queuing - Synchro Evaluation (see
Figure IV.M-ZO) at Oyster Point Boulevard /Gateway Boulevard / U.S.101
Southbound Off-Ramp Flyover Intersection-Off-Ramp Right Turn Lane
See Mitigation Measure IV.M-2A.
Resultant Operation: AM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will reduce 95th percentile
queuing in the Oyster Point Boulevard eastbound approach through lanes to
1,271 feet, which would be better than Base Case queuing of 1,280 feet.
Impact reduced to a less than significant level.
Finding Impact IV.M-3B: Implementation of this mitigation measure will provide
additional capacity and reducE~ delay, which will reduce 95th percentile queuing in
the Oyster Point Boulevard eastbound approach through lanes to 1,271 feet, which
would be better than Base Case queuing of 1,280 feet. Thus, this impact will be
reduced to a less than significant level.
Impact IV.M-5C: U.S.101 Northbound Off-Ramp to East Grand Avenue/Executive
Drive Intersection
Exhibit A
CEQA Findings
Page 44 of 84
AM Peak Hour: The project would increase off-ramp volumes by 6.2 percent (from
2,151 up to 2,284 vehicles) at a location where the two-lane off-ramp diverge
capacity would be 2,300 vehicles per hour. This would be a significant impact.
Mitigation Measure IV.M-50015 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Northbound Off-Ramp to East Grand Avenue/Executive Drive
Intersection
Provide a second off-ramp lane connection to the U.S. 101 freeway mainline. The
required improvements are contemplated in and funded in the City's East of 101
traffic program, and by paying the City's East of 101 traffic fee, the project
proponent will be funding its fair share of the required improvements. Planned
provision of a second off-ramp would increase diverge capacity to 2,200 to 2,300
vehicles per hour. This could accommodate the project off-ramp volume of about
2,284 vehicles per hour.
Finding Impact IV.M-5C: Impllementation of this mitigation measure could
accommodate the projected ofF-ramp volume of about 2,284 vehicles per hour. Thus
the impact would be reduced to a less than significant level.
Impact IV.M-8: Project Trip Generation Exceeds 100 Trips During Peak Hours
The totally developed project ~NOUId generate more than 100 net new trips during
the AM and PM peak hours (7Ei4 two-way (inbound + outbound) trips during the AM
peak hour and 780 two-way trips during the PM peak hour (see Table IV.M-22)).
The San Mateo City/County Association of Governments (C/CAG) Agency Guidelines
for the implementation of the ;Z003 Draft Congestion Management Program ("C/CAG
Guidelines") specifies that local jurisdictions must ensure that the developer and/or
tenants will mitigate all new peak hour trips (including the first 100 trips) projected
to be generated by the development. This would be a significant impact.
Mitigation Measure IV.M-8 Transportation Demand Management Program
The project sponsors shall implement a Transportation Demand Management
TDM) program consistent wi1:h the City of South San Francisco Zoning Ordinance
Chapter 20.120 Transportation Demand Management, and acceptable to C/CAG.
These programs, once implemented, must be ongoing for the occupied life of the
development. The C/CAG guidelines specify the number of trips that maybe
credited for each TDM measure. The project's TDM program is included in Appendix
H to the EIR and will generate trip credits to offset the 764 total AM peak hour and
780 PM peak hour net new trips generated by the project by the year 2035.
Exhibit A
CEQA Findings
Page 45 of 84
Impact reduced to a less than significant level.
Finding Impact IY.M-8: The p:roject's TDM program is included in Appendix H to
the EIR and will generate trip credits to offset the 764 total AM peak hour and 780
PM peak hour net new trips generated by the project by the year 2035.
Implementation of this mitigation measure would reduce the impact to a less than
significant level.
Impact IV.M-9A: Airport Boulevard /Sister Cities Boulevard /Oyster Point
Boulevard
PM Peak Hour: The project would increase volumes by 3.4 percent at a location with
unacceptable LOS E Base Case operation. This would be a significant impact.
Mitigation Measure IV.M-9A 2035 Intersection Level of Service at Airport
Boulevard /Sister Cities Boulevard /Oyster Point Boulevard Intersection (see
Figure IV.M-22 and Table IV.M-25)
Add a second right turn lane on the Airport Boulevard Southbound approach
to the Oyster Point Boulevard/Sister Cities Boulevard intersection. The
applicant should pay a fair share contribution towards this measure (see
Figure IV.M-22).
Resultant Operation: PM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS D-
50.0 seconds control delay, which is acceptable operation.
Impact reduced to a less than significant level.
Finding Impact IV.M-9A: The proposed mitigation will provide additional capacity
and reduce delay, which will improve operation to LOS D-50.0 seconds control
delay, which is acceptable operation. Impact reduced to a less than significant
level.
Impact IV.M-9B: Oyster Point Boulevard /Gateway Boulevard / U.S. 101
Southbound Off-Ramp Flyover
AM Peak Hour: The project would increase volumes by 6.2 percent at a location with
unacceptable LOS F Base Case operation. PM Peak Hour: The project would increase
volumes by 7.7 percent at a location with unacceptable LOS F Base Case operation.
This would be a significant irripact.
Exhibit A
CEQA Findings
Page 46 of 84
Mitigation Measure IV.M-9B 2035 Intersection Level of Service at Oyster Point
Boulevard /Gateway Boulevard / U.S.101 Southbound Off-Ramp Flyover
Intersection (see Figure IV.M-22 and Table IV.M-25)
Same mitigations as for 2015.
Resultant Operation: AM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS F-
318 seconds control delay, which is better than Base Case operation (LOS F-
381 seconds control delay) PM Peak Hour: The proposed mitigation will
provide additional capacity and reduce delay, which will improve operation
to LOS F-138 seconds control delay, which is better than Base Case operation
LOS F-142 seconds control delay)
Impact reduced to a less than significant level.
Finding Impact IV.M-9B: will improve operation to LOS F-318 seconds control
delay, which is better than Base Case operation (LOS F- 381 seconds control delay)
PM Peak Hour: The proposed mitigation will provide additional capacity and reduce
delay, which will improve operation to LOS F-138 seconds control delay, which is
better than Base Case operation (LOS F-142 seconds control delay) Impact reduced
to a less. than significant level.
Impact IV.M-9C: Oyster Point Boulevard /Veterans Boulevard /Project Entrance
AM Peak Hour: The project traffic would increase volumes by 5.7 percent at a
location with unacceptable LOS F Base Case operation. PM Peak Hour: The project
would increase volumes by 7.2. percent at a location with unacceptable LOS F Base
Case operation. This would be a significant impact.
Mitigation Measure IV.M-9C 2035 Intersection Level of Service at Oyster Point
Boulevard /Veterans Boulevard /Project Entrance Intersection (see Figure
IV.M-22 and Table IV.M-25)
Same mitigation as for ;2015.
Resultant Operation: A1vI Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS F-
130 seconds control delay, which is better than Base Case operation (LOS F-
150 seconds control delay) PM Peak Hour: The proposed mitigation will
provide additional capacity and reduce delay, which will improve operation
to LOS F-186 seconds control delay, which is better than Base Case operation
LOS F- 289 seconds control delay)
Exhibit A
CEQA Findings
Page 47 of 84
Impact reduced to a less than significant level.
Finding Impact IV.M-9C: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS F-130
seconds control delay, which is better than Base Case operation (LOS F- 150 seconds
control delay) PM Peak Hour: T'he proposed mitigation will provide additional
capacity and reduce delay, which will improve operation to LOS F-186 seconds
control delay, which is better than Base Case operation (LOS F- 289 seconds control
delay). Thus, the impact would be reduced to a less than significant level.
Impact IV.M-9D: Gateway Boulevard /So. Airport Boulevard /Mitchell Avenue
PM Peak Hour: The project would increase volumes by 4.5 percent at a location with
unacceptable LOS F Base Case operation. This would be a significant impact.
Mitigation Measure IV.M-9D ~,~035 Intersection Level of Service at Gateway
Boulevard / S. Airport Boulevard /Mitchell Avenue Intersection (see Figure
IV.M-22 and Table IV.M-25)
Same mitigation as for x'.015 and adjust signal timing.
Resultant Operation: PM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS D-
39.6 seconds control delay. Operation is improved to an acceptable level.
Impact reduced to a less than significant level.
Finding Impact IV.M-9D: Implementation of this mitigation measure will provide
additional capacity and reduces delay, which will improve operation to LOS D-39.6
seconds control delay. Operation is improved to an acceptable level. Thus, the
impact would be reduced to a :less than significant level.
Impact IV.M-9E: Airport Boulevard /San Mateo Avenue /Produce Avenue
PM Peak Hour: The project would increase volumes by 3.2 percent at a location
where unacceptable LOS E Base Case operation would be degraded to unacceptable
LOS F operation.
This would be a significant impact.
Exhibit A
CEQA Findings
Page 48 of 84
Mitigation Measure IV.M-9E 2035 Intersection Level of Service at Airport
Boulevard /San Mateo Avenue /Produce Avenue Intersection (see Figure IV.M-
22 and Table IV.M-25)
Restripe the Airport Boulevard right turn on the southbound approach to the
Produce Avenue/San Mateo Avenue intersection to allow through
movements. Funding for this measure would be the full responsibility of the
Project sponsor.
Resultant Operation: PM Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS D-
54.9 seconds control delay, which is better than Base Case operation (LOS F-
141 seconds control delay)
Impact reduced to a less than significant level.
Finding Impact IV.M-9E: Imp:lementation of this mitigation measure will provide
additional capacity and reduce delay, which will improve operation to LOS D-54.9
seconds control delay, which i;> better than Base Case operation (LOS F-141 seconds
control delay). Thus the impact would be reduced to a less than significant level.
Impact IV.M-9G: Dubuque Avenue/ U.S.101 Northbound Off-Ramp-Southbound
On-Ramp
Intersection
PM Peak Hour: Project traffic would degrade acceptable LOS D Base Case operation
to unacceptable LOS E operation.
Mitigation Measure IV.M-9G 2035 Intersection Level of Service at Dubuque
Avenue / U.S.101
Northbound Off-Ramp-Southbound On-Ramp Intersection (see Figure IV.M-22
and Table IV.M-25)
Adjust signal timing.
Resultant Operation: P1VI Peak Hour: The proposed mitigation will provide
additional capacity and reduce delay, which will improve operation to LOS C-
30.9 seconds control delay
Impact reduced to a less than significant level.
Exhibit A
CEQA Findings
Page 49 of 84
Finding Impact IV.M-9G: The proposed mitigation will provide additional capacity
and reduce delay, which will improve operation to LOS C-30.9 seconds control
delay. Thus the impact would be reduced to a less than significant level.
Impact IV.M-10B: Oyster Point Boulevard /Gateway Boulevard / U.S.101
Southbound Flyover Off- Rarr,~p Intersection
AM Peak Hour: The project would increase volumes by 5.7 percent in the eastbound
Oyster Point Boulevard approach through lanes, where Base Case 95th percentile
queues would already be exceeding available storage. This would be a significant
impact.
Mitigation Measure IV.M-10B 2035 Vehicle Queuing - Synchro Evaluation at
Oyster Point Boulevard /Gateway Boulevard / U.S.101 Southbound Flyover Off-
Ramp Intersection (see Figure IV.M-22)
Same mitigation as for ]level of service (Mitigation Measure IV.M-9B).
Resultant Operation: A1VI Peak Hour: Oyster Point Boulevard Eastbound
Through Lanes: The proposed mitigation will provide additional capacity and
reduce delay, which would reduce 95th percentile queue to 1,633 feet, which
would be better than Base Case queuing of 1,650 feet.
Impact reduced to a less than significant level.
Finding Impact IV.M-10B: Implementation of this mitigation measure will provide
additional capacity and reducE~ delay, which would reduce 95th percentile queue to
1,633 feet, which would be better than Base Case queuing of 1,650 feet. Thus the
impact will be reduced to a less than significant level.
Impact IV.M-10C: Airport Boulevard /Sister Cities Boulevard /Oyster Point
Boulevard Intersection
PM Peak Hour: The project would increase volumes by 2.9 percent in the left turn
lane and by 10.6 percent in the through lanes on the westbound Oyster Point
Boulevard intersection approach where Base Case 95th percentile queues would
already be exceeding availablE~ storage.
This would be a significant irripact.
Exhibit A
CEQA Findings
Page 50 of 84
Mitigation Measure IV.M-10C'2035 Vehicle Queuing - Synchro Evaluation at
Airport Boulevard /Sister Cities Boulevard /Oyster Point Boulevard
Intersection
Same mitigation as for level of service (Mitigation Measure IV.M-9A)
PM Peak Hour: Oyster F'oint Boulevard Westbound Through Lanes: The
proposed mitigation will provide additional capacity and reduce delay, which
would reduce 95th pert;entile queuing to 701 feet, which would be better
than Base Case queuing; of 738 feet. Oyster Point Boulevard Westbound Left
Turn: The proposed mittigation will provide additional capacity and reduce
delay, which would reduce 95th percentile queuing to 411 feet, which would
be better than Base Case queuing of 486 feet.
Impact reduced to a less than significant level.
Finding Impact IV.M-10-C: Implementation of this mitigation measure will provide
additional capacity and reduce delay, which would reduce 95th percentile queuing
to 701 feet, which would be butter than Base Case queuing of 738 feet. Oyster Point
Boulevard Westbound Left Turn: The proposed mitigation will provide additional
capacity and reduce delay, which would reduce 95th percentile queuing to 411 feet,
which would be better than Base Case queuing of 486 feet, thus will reduce the
impact to a less than significant level.
Impact IV.M-16: Pedestrian Circulation
A wide variety of pedestrian walkways are proposed as part of the project. They
would include:
A central pedestrian spine, which would be the major thoroughfare for
pedestrian movements through the campus. It would be wide enough to also
serve as an emergency vehicle route.
A secondary network of walkways connecting to the central spine.
Direct connections bet<Neen the parking structures and the central spine.
Direct connections bet~Neen the street and the internal campus.
Anew public sidewalk along the project's Gateway Boulevard and Oyster
Point Boulevard frontages that will connect to the existing sidewalk system
along Gateway Boulevard at the south end of the campus and to the sidewalk
system to be provided lby the 180 and 200 Oyster Point buildings. The
project's new street frontage sidewalk will be utilized to provide access to
two additional shuttle stops, which are being proposed along the site
frontage (one along Oyster Point Boulevard and one near the north end of
Gateway Boulevard).
Exhibit A
CEQA Findings
Page 51 of 84
An existing walkway about 30 feet from Gateway Boulevard (called the
perimeter walk) that is located between hedges of Poplar trees and will be
maintained and utilized. primarily by employees.
While the proposed walkway system will provide acceptable pedestrian circulation
within the majority of the campus, all drivers using any of the four large parking
structures along the east edge of the campus will be required to cross the main
internal circulation road to access any of the project buildings. At full buildout, from
200 to 500 vehicles per hour maybe on various segments of the internal street
providing access to the garages. While speed table and pedestrian crossings of
materials other than asphalt are being considered to slow traffic and highlight
locations with significant pedestrian crossings, the proposed location of the main
internal road (on the west rather than the east side of the garages) could lead to
significant pedestrian/auto conflicts. This would be a significant impact.
Mitigation Measure IV.M-16 Aedestrian Circulation
Consider relocating the internal roadway running along the west side of the parking
garages to the east side of the garages along the project boundary. This will
eliminate thousands of pedestrian crossings of a busy internal roadway as
employees walk between the €;arages and the office buildings. An emergency access
roadway may still be required between the garages and offices to meet fire
department requirements. Impact reduced to a less than significant level.
Finding Impact IV.M-16: Implementation of this mitigation measure will eliminate
thousands of pedestrian crossings of a busy internal roadway as employees walk
between the garages and the office buildings. An emergency access roadway may
still be required between the garages and offices to meet fire department
requirements. Impact reduced to a less than significant level.
Impact IV.M-17: Site Access and Internal Vehicle Circulation
Primary project vehicle access; would be provided via an existing signalized
intersection along Oyster Point Boulevard (about 850 feet south of Oyster Point
Boulevard and now being used for access to the project site) as well as via the south
leg of the existing signalized Oyster Point Boulevard /Veterans Boulevard
intersection. The south leg of t:he Veterans Boulevard intersection would also be
used for access to the 180 and 200 Oyster Point Boulevard buildings, which are
about to be completed but are not part of the Gateway project. Both major entrances
would connect to an access lane, which would run along the west side of the
project's proposed four parking garages. Two secondary signalized entrances would
Exhibit A
CEQA Findings
Page 52 of 84
also be provided to the site. One would be located along Oyster Point Boulevard at
the easterly project boundary, opposite the entrance to the 333 Oyster Point
Boulevard development and in the location of the existing FedEx driveway. The
other would be located along Gateway Boulevard at the south end of the project
frontage at an existing signal. Both secondary entrances would also connect to the
access lane running adjacent to the project's four garages. Supplemental (right turn
in/right turn out) access points would also be provided along the project's Oyster
Point Boulevard frontage (one supplemental access) and Gateway Boulevard
frontage (one supplemental access). These would provide limited pick up/drop off
access to buildings not adjacent to the internal access lane as well as access to
subsurface parking for the Gateway building on the corner of the Oyster Point
Boulevard /Gateway Boulevard intersection. Speed tables are being considered
along all internal streets at major pedestrian crossings in order to slow speeds.
Paving would also be interrupted with contrasting materials at pedestrian crossings
and internal intersections to increase pedestrian safety.
Overall, the proposed project circulation system appears that it will function
acceptably for employees, wha~ will quickly learn which is the most convenient
driveway to use for their assigned parking garage. However, given the size of the
project, its numerous buildings and garages as well as the variety of driveway
connections to Gateway and Olympic boulevards, unless frequent, large and clear
signing is provided, visitors m<~y experience confusion in regards to finding
appropriate parking closest to their final destination. This would be a significant
impact.
Mitigation Measure IV.M-17~~ccess and Internal Vehicle Circulation
Provide building addresses that can be read easily by drivers on Gateway Boulevard
and Oyster Point Boulevard. Provide easy-to-follow directions for visitors from the
access driveway intersections along Gateway Boulevard or Oyster Point Boulevard
and along the internal driveways to the specific garage associated with each office
building. Impact reduced to a less than significant level,
Finding Impact IV.M-17: Implementation of this mitigation measure will provide
easy-to-follow directions for visitors from the access driveway intersections along
Gateway Boulevard or Oyster Point Boulevard and along the internal driveways to
the specific garage associated with each office building. Impact reduced to a less
than significant level.
UTILITIES/SERVICE SYSTEMS
Exhibit A
CEQA Findings
Page 53 of 84
Impact IV.N-1: The proposed project would create or contribute runoff water which
would exceed the capacity of e:~isting or planned stormwater drainage systems or
provide substantial additional ;sources of polluted runoff. Surface and stormwater
runoff in the project area is collected by the City's storm drainage system and is
discharged to San Francisco Bay east of the project area. The existing storm
drainage system in the project area is designed to accommodate flows from office
development and the amount of existing impervious surfaces in the area. The
proposed project would remove existing buildings on the site and redevelop the
area with similar uses. The project consists of the phased removal and replacement
of existing buildings on the 22.6 acre project site and construction of five to six new
office buildings and two to four parking structures. As a result of increased traffic,
increased stormwater pollutants, such as copper and zinc from break pads23 or oil
from leaking engines, may result in a potentially significant change in storm water
quality.
To comply with the Clean WatE~r Act (CWA), STOPPP was formed. STOPPP holds a
joint municipal NPDES permit from the San Francisco Bay RWQCB. The permit
includes a comprehensive plan to reduce the discharge of pollutants to creeks, San
Francisco Bay, and the ocean to the maximum extent possible. The San Mateo
Countywide STOPPP has a Site Design Standards Checklist to evaluate proposed
projects against guidelines intended to reduce stormwater pollution. These
guidelines are regulated by the SSFMC, General Plan, or other best management
practices guidelines. The project site is divided into three separate sub-drainage
areas: North (Portion of Building 1000), Central (Portion of Buildings 800 and 1000)
and South (Buildings 700, 750,, 850, 900 and a portion of Building 800). The on-site
storm drainage system varies :in size from 12-inch to 30-inch in diameter. The three
sub-drainage areas discharge 1:o the City's public storm drainage system as follows:
North Sub- Drainage Area, Central Sub-Drainage Area, and South Sub-Drainage Area.
The North sub-drainage area discharges to the existing 18-inch to 24-inch public
storm drainage system on Oyster Point Boulevard. The Oyster Point Boulevard
storm drainage system outfalls to the San Francisco Bay at the Oyster Cove
Marina (north of the Master Plan Area) via a 24 by 30-inch box storm drain line. The
Central subdrainage area discharges to the existing 18-inch public storm drainage
line on Gateway Boulevard. The existing 18-inch Gateway Boulevard line connects
to the Oyster Point Boulevard public storm drainage system at the intersection of
Oyster Point and Gateway Boulevard. The South sub-drainage area discharges to the
existing 30-inch public storm drain line on Gateway Boulevard. The Gateway
Boulevard public storm drainage system collects and conveys storm runoff from the
site and outfalls south of the sate to Colma Creek. The outfall is located east of the
intersection of Harbor Way anal Mitchell Avenue. The Gateway Boulevard public
system varies in size from 30-inch to 72-inch.
Exhibit A
CEQA Findings
Page 54 of 84
Mitigation Measure IV.N-1.1 l)perational SWPPP
The project applicant shall develop an operational SWPPP for all drainage to the
Central and South Sub-Drainage areas prior to construction of the Precise Plan and
for the North Sub-Drainage area prior to construction of the subsequent phases of
the Master Plan to protect water quality after construction. These project SWPPPs
shall include, but not be limited to, the following measures for project operation:
Description of potential sources of erosion and sediment at the project site
for each phase of the
Master Plan. Industrial activities and significant materials and chemicals that
could be used for each phase of the Master Plan at the proposed project site
shall be described. This shall include a thorough assessment of existing and
potential pollutant sources.
Identification of BMPs to be implemented for the Precise Plan and for each
phase of the Master Plan at the project site based on identified industrial
activities and potential pollutant sources.
Emphasis shall be placed on source control BMPs, with treatment controls
uses as needed.
Development of a monitoring and implementation plan for the Precise Plan
and for each phase of the Master Plan. Maintenance requirements and
frequency shall be careirully described including vector control, clearing of
clogged or obstructed inlet or outlet structures, vegetation/landscape
maintenance, replacement of media filters, regular sweeping of parking lots
and other paced areas, •etc. Wastes removed from BMPs maybe hazardous;
therefore, maintenance costs shall be budgeted to include disposal at a
proper site. Parking lot areas shall be cleared on a daily basis of debris that
may enter the storm drain system.
The monitoring and maintenance program shall be conducted at the
frequency agreed upon by the RWQCB and/or City of South San Francisco.
Monitoring and maintenance shall be recorded and submitted annually in
coordination with the S'~TOPPP. The SWPPP shall be adjusted, as necessary, to
address any inadequaciies of the BMPs.
The project applicant shhall prepare informational literature and guidance on
industrial and commercial BMPs for the Precise Plan and each phase of the
Master Plan to minimize pollutant contributions from the proposed
development. This information shall be distributed to all employees at the
project site. At a minimum, the information shall cover: (1) proper disposal
of commercial cleaning chemicals; (2) proper use of landscaping chemicals;
3) clean-up and appropriate disposal of hazardous materials and chemicals;
and (4) prohibition of any washing and dumping of materials and chemicals
into storm drains.
Mitigation Measure IV.N-1.2 ,Storm Drain Interceptors
Exhibit A
CEQA Findings
Page 55 of 84
The project applicant shall install a storm drain interceptor (also known as an
oil/water or oil/grit separator)I on-site to remove oils and heavy particulates from
stormwater at appropriate storm drains for the Precise Plan and each phase of the
Master Plan. Appropriate sizinl; of the unit relative to the impervious surface
drainage area is important and should be taken into consideration when choosing
the interceptor unit model and size.
Mitigation Measure IV.N-1.3
Impervious Area Drainage Retention Devices The project applicant shall incorporate
alternative drainage solutions around surface parking lots and near large areas of
impervious surfaces such as public plazas to increase pervious surfaces on the site
and increase infiltration. This shall be done for the Precise Plan and each phase of
the Master Plan. Such solutions may include, but are not limited to, vegetated
swales, bioretention areas, planter/tree boxes, and ponds.
Mitigation Measure IV.N-1.4 Rooftop Retention Devices
The project applicant shall incorporate rooftop or downspout retention into all
building plans proposed by the Precise Plan and each phase of the Master Plan to
capture all roof runoff.
Finding Impact IY.N-1: ConstY•uction impacts to water quality are mitigated through
soil stabilization and erosion control techniques as described in Mitigation Measure
IV.H-1.1 and IV.H-1.2 in Section IV.H (Hydrology/Water Quality) of this Draft EIR.
However, operation of the proposed project could contribute to polluted
stormwater runoff. This would be a potentially significant impact. However, as
described above, mitigation measures, such as incorporating rooftop downspouts
and the installation of a storm drain interceptor to capture oil and heavy
particulates before entering stormwater drainage systems, would minimize
pollutant contributions to stormwater drainage systems. Therefore, implementation
of Mitigation Measure IV.N-1.9~ would reduce operation impacts associated with
polluted runoff to aless-than-significant level.
Impact IV.N-2: The proposed :project would require or result in the construction of
new water treatment, distribution, or conveyance facilities or expansion of existing
facilities, the construction of which could cause significant environmental effects.
Mitigation Measure IV.N-2.1 Fire Flow Analysis Report
Exhibit A
CEQA Findings
Page 56 of 84
In order to assure that the water system has the ability to serve peak flow demands
including for fire flow, prior to first building permit for all buildings constructed for
the Precise Plan and each phase of the Master Plan, the project applicant shall
consult a NCEES certified Fire Protection Engineer to prepare an analysis of the
proposed project and determir.~e the required design fire flow and fire duration. A
certified report shall be submitted to the South San Francisco Fire Department for
review and comment to ensures that all required design fire flow and fire duration
requirements are met.
Mitigation Measure IV.N-2.2 Fire Flow Testing
In order to assure that the water system has the ability to serve peak flow demands
including for fire flow, prior to receiving a building permit for all buildings
constructed for the Precise Plan and each phase of the Master Plan, the project
applicant shall perform fire flow tests for all hydrants within 500 feet of the project
site pursuant to American Water Works Association filed testing standards25 to
verify if adequate fire flows defined in Mitigation Measure N-5 are achieved. Any
deficiency measured shall be corrected and retested prior occupancy.
Mitigation Measure IV.N-2.3 Fire Protection Water Supply
In order to assure that the water system has the ability to provide water supply for
fire protection, prior to occupancy of all buildings constructed for the Precise Plan
and each phase of the Master Flan, California Water Service Company shall certify
that reservoir storage, beyond their operational and emergency allotments,
required for adequate protection identified in Mitigation Measure IV.N-2.1 will be
maintained at all times.
Finding Impact IV.N-2: The proposed project could have a potentially significant
impact on the water system that delivers the required fire flows. Water for fire flow
would be provided in 12 inch mains that would be constructed with the Precise Plan
and each phase of the project. The water distribution system is owned and operated
by CWSC. The water system consists of a network of 12-and 10-inch lines which
should be adequate to serve tl-ie required flows.24 .To avoid impacts to the water
system's ability to serve peak :flow demands, fire flow testing as well as analysis and
certification by fire protection personnel as described in Mitigation Measure IV.N-
2.1 above would reduce the impacts associated with increased fire flow demands to
a less than significant level.
Impact IV.N-4: The proposed. project would have sufficient water supplies available
to serve the project from existing entitlements and resources and no new or
Exhibit A
CEQA Findings
Page 57 of 84
expanded entitlements are needed. While this is aconsidered aless-than-significant
impact, implementation of Mitigation Measure IV.N-4.1 would further minimize the
impact and ensure that it remains less-than-significant.
Mitigation Measure IV.N-4.1 {Water Conservation
In order to reduce water demands of all phases of the project, the project applicant
shall include methods of water conservation in the proposed project's buildings and
landscaping for the Precise Plan and each phase of the Master Plan. These methods
shall include, but not be limited, to the following:
Install water-conservin;; dishwashers and washing machines, and water-
efficient centralized coaling systems in all new buildings (this method would
not apply to process development or
research development laboratory equipment);
nstall water-conserving; irrigation systems (e.g., drip irrigation and
evaportranspiration-based irrigation controllers);
Design landscaping with drought-resistant and other low-water-use plants;
and
Install water-saving devices such as water-efficient toilets, faucets, and
showerheads.
Finding Impact IV.N-4: The W~SA was prepared using the assumptions that
approximately 40 percent of the proposed new building space will be used for
offices and the remaining 60 percent of space for biotechnology research and
development laboratories. R&]D uses typically consume more water than office uses.
Therefore, the estimated increase in water demand due to the proposed project of
49,411 gpd is more conservative than what would be demanded under full buildout
of the Precise Plan and all sub<.~equent phases of the Master Plan. The project would
employ a Leadership in Energy and Environmental Design (LEED)-equivalent
standard for the design of the new buildings and would use water consumption. In
addition, Cal Water concluded that for the next 20 years, the SSF District will have
adequate water supplies to mE~et projected demands associated with the proposed
project along with those of all existing customers and all other anticipated future
users for normal, single dry year and multiple dry year conditions. Therefore, the
impact would be less than significant and no mitigation measures are required.
While the proposed project's effect on water supply is not a significant effect under
CEQA, the proposed measures, addressing the installation ofwater-conserving
appliances including dishwasl-iers, washing machines, toilets, and faucets and the
use of drought-resistant plants in landscaping, would minimize the project site's
water demand. Therefore, Mitigation Measure IV.4.1 above would reduce the
Exhibit A
CEQA Findings
Page 58 of 84
proposed project's contribution to the total water demand, ensuring that the less-
than-significant impact remains so.
Section IV: Findings Regardine Alternatives
The EIR evaluates the environmental impacts of three alternatives to the project. All
alternatives are located on the project site. Differences between the build
alternatives include square footage of development, land uses allowed on the site,
total employees, and the number of parking spaces.
Alternative A: No Project/Buildout Under Existing General Plan. Alternative A
assumes the Applicant's proposal is not approved, but would allow for
redevelopment of the project site under the existing General Plan and zoning
regulations, including at a maximum FAR of 1.0. This alternative assumes that
development on the site could be phased but that total buildout would occur by
2020. Buildout on the site would be a combination of Office and R&D uses (50
percent each). This alternative would result in the construction of approximately
492,225 sf of office uses and 492,225 sf of R&D uses, for a total of 984,500 sf of
development. Buildout under Alternative A would result in approximately 2,406
employees on the project site. Parking would be provided at a ratio of 2.83 spaces
per 1,000 sf of development for a total of 2,835 spaces.
Alternative B: Reduced ProjE:ct Alternative. Alternative B would allow
redevelopment of the project site at an FAR of 1.25, but developed with Research &
Development (R&D) uses only resulting in a reduced project due to the reduction of
employees on site. This alternative assumes that development on the site could be
phased but that total buildout would occur by 2020. Under Alternative B, buildout
on the site would result in the construction of approximately 1,230,570 sf of R&D
uses. Buildout under Alternative B would result in approximately 2,735 employees
on the project site. Parking would be provided at a ratio of 2.83 spaces per 1,000 sf
of development for a total of 3,544 spaces.
Alternative C: Reduced Parking Alternative. Alternative C would develop the site
with Office and R&D uses at ari FAR of 1.25. This alternative assumes that
development on the site could be phased but that total buildout would occur by
2020. Buildout on the site would be a combination of Office and R&D uses (50
percent each). Alternative C would result in the construction of approximately
1,230,570 sf of development and approximately 3,009 employees on the site. Under
Exhibit A
CEQA Findings
Page 59 of 84
Alternative C, parking would bf~ provided at a reduced ratio of 2.3 spaces per 1,000
sf resulting in a total of 2,264 parking spaces on the site.
The City Council hereby concludes that the EIR sets forth a reasonable range of
alternatives to the Project, so as to foster informed public participation and informed
decision making. The City Council finds that the alternatives identified and described in
the EIR were considered and further finds them to be infeasible for the specific
economic, social, or other considerations set forth below pursuant to CEQA section
21081(c).
ALTERNATIVE A: NO-PROJECT
Alternative A - No Project/ Buildout Under Existing General Plan Alternative
As required by CEQA, this subsection analyzes a "No Project" Alternative
Alternative A). CEQA requires the evaluation of a "No Project" alternative, which
assumes "the existing conditions, as well as what would reasonably be expected to
occur in the foreseeable future if the project were not approved, based on current
plans and consistent with available infrastructure and community services" (CEQA
Guidelines, Section 15126.6[e] [2]). Evaluation of this alternative allows the City to
compare the impact of approving the proposed project with the impacts of not
approving the proposed project.
Alternative A assumes that they proposed project would not be approved, but the
Alternative would still allow for the redevelopment of the project site under the
existing General Plan and zoning regulations, including development to a FAR of 1.0.
This Alternative assumes that development on the site could be phased but that
total buildout would occur by 2020. Buildout on the site would be a combination of
Office and R&D uses (50 percent each). This alternative would result in the
construction of approximately 492,225 sf of office uses and 492,225 sf of R&D uses,
for a total of 984,500 sf of development. Buildout under Alternative A would result
in approximately 2,406 employees on the project site. Parking would be provided at
a ratio of 2.83 spaces per 1,OOiD sf of development for a total of 2,835 spaces.
Aesthetics
Exhibit A
CEQA Findings
Page 60 of 84
The project site is currently developed as a business park. Under Alternative A, a
business park housing Office and R & D uses would be developed on the site. Similar
to the project, no public views Ito scenic vistas would be blocked and impacts to
scenic vistas would be less than significant. Additionally, similar to the project there
would be no impact to state scenic highways. The site is currently developed at an
FAR of 0.29. Alternative A would result in development of the site at an FAR of 1.0, a
higher density. Similar to the project, this increase in FAR could be accomplished
primarily by increasing the height of the buildings on the site, thereby increasing the
amount of open space on the site, which would minimize the feeling of density on
the site. Therefore, similar to the project, Alternative A would result in
improvements to the visual quality of the site by increasing open space and
pedestrian-oriented areas and creating a cohesive pedestrian-oriented
environment. Lighting and building materials on the site under Alternative A would
similar to the project and would be subject to the same City standards as the project.
Therefore, impacts to visual character and light and glare under Alternative A would
be less than significant and tree same as under the project. Overall impacts to visual
resources would be the same a.s under the project.
Air Quality
Similar to the project, Alternative A would involve the demolition of the existing
structures on the site. Under Alternative A, the project site would be developed with
approximately 984,500 squarE~ feet of Office and R & D uses. Alternative A would be
consistent with the City's General Plan FAR of 1.0. Therefore, unlike the project,
Alternative A would not create a significant unavoidable impact due to
inconsistency with the BAAQN[D's Clean Air Plan. Alternative A would implement
the same construction mitigation measures as the project and this impact would be
less than significant and similar to the project. Alternative A would result in
operational emissions primarily from increased vehicular trips to and from the
commercial development. Altriough Alternative A would result in an approximately
20 percent decrease in square footage of development and proposes 50 percent
R&D uses (which would generate fewer employees), this decrease would not be
enough to reduce the project's significant unavoidable PM10 emissions. Therefore,
air quality impacts PM10 emissions from under Alternative A (both project and
cumulative) would remain significant and unavoidable, similar to the project.
Local CO concentrations would be reduced incrementally, however, impacts would
remain less than significant acid the same as under the project. Assuming that
Alternative A would be constructed in a phased manner and therefore the childcare
facility could remain on site during some phases of the project, the impacts from
TACs would remain the same .as under the project and less than significant. Similar
to the project, there would be less than significant impacts from objectionable odors
under Alternative A and it would not conflict with the State goals in AB 32. Overall
impacts to air quality under Alternative A, although incrementally less than under
the project, would be the same as under the project and remain significant and
unavoidable.
Exhibit A
CEQA Findings
Page 61 of 84
Biological Resources
The project site is currently developed as a business park and the only biological
resources on the site are mature landscaping. Alternative A could potentially
remove fewer trees on the site during construction of new buildings due to the
decrease in FAR on the site. However, under Alternative A, project construction
activities could result in the destruction of active bird nests during removal of
vegetation or grading or could potentially result in the abandonment of active nests
due to noise and increased activity. As with the project, mitigation measures would
reduce this impact to less than significant. Similar to the project, Alternative A
would have no impact to riparian habitat, wetlands, or to migratory corridors.
Regarding the removal of trees,, impacts to tree removal and conflict with existing
codes or plans protecting biological resources would be less than significant and
the same under Alternative A ais the project.
Cultural Resources
The project site has been develloped and redeveloped several times in the twentieth
century. These processes have almost completely removed potential for, and make
the property quite unlikely to contain, significant cultural resources that could be
impacted by development that: could occur under Alternative A. Similar to the
proposed project, the potential for disturbance of subsurface resources, including
fossilbearing soils and rock formations, paleontological resources, and archeological
sites and sites of cultural signi:Ficance to Native Americans, during ground disturbing
activities still exists under this alternative. Mitigation measures would be expected
to be developed for any future construction at the site, and possible impacts to
historical resources would be ;avoided to the extent feasible. Under Alternative A,
impacts to cultural resources ~NOUId remain less than significant, and similar to the
proposed project.
Geology and Soils
Development of the site under the existing General Plan FAR of 1.0 would result in
slightly less
development (984,500 sf opposed to 1,230,570 sf). Similar to the project, there
would be no impact due to they lack of an Alquist-Priolo Fault Zone on the site.
Geologic hazards such as seismic ground shaking would still exist under this
alternative. However, impacts would be lessened due to decreased development
which would directly result in fewer people exposed to ground shaking at the site.
Site specific hazards related to erosion, loss of top soil, subsidence, expansive soils,
and landslides would be the same as under the project as this alternative would
Exhibit A
CEQA Findings
Page 62 of 84
result in grading and construction over the entire site. Collectively, impacts would
be less than significant, and less than the proposed project due to the presence of
fewer buildings and people on the site.
Hazards and Hazardous Materials
Implementation of Alternative A, as with the proposed project, would likely result in
development of additional labc-ratories and other research facilities that would use,
store, or require the transport and disposal of hazardous materials. However, fewer
of these uses would be constructed under Alternative A. As with the proposed
project, compliance with safety procedures mandated by applicable federal, state,
and local laws and regulations would ensure the risks associated with the routine
use of hazardous materials and disposal of hazardous wastes remain less than
significant. However, impacts would be incrementally less due to the reduced
development on the site.
Similar to the proposed project, existing buildings at the site would be demolished
in order to make room for new' development. These buildings potentially contain
hazardous materials including waste oil, asbestos, lead paint, halogenated and non-
halogenated solvents, organic compounds, and petroleum products. During
demolition operations hazardous materials could be released from structures at the
site or from the underlying soils. Portions of the project site would still be included
on government lists of sites containing hazardous materials, and development at the
site could create a significant hazard to the public or the environment. However, as
projects are reviewed on a situ-by-site basis, mitigation measures would be
identified to reduce these impacts to a less than significant level. Impacts associated
with the release of hazards and hazardous materials under this alternative would be
incrementally less due to the smaller amount of development and remain less than
significant. Under this alternative, potential impacts to nearby schools would also
remain the same, and it is expE~cted That mitigation measures would be identified to
ensure impacts remain less than significant.
Hydrology and Water Qualit~~
Buildout under Alternative A would result in development of 984,456 sf of Office
and R&D uses at the site. Typical industrial non-point source (NPS) pollutants
associated with industrial activities would still be present at the site. Development
of this alternative would contribute to the levels of NPS pollutants and Litter
entering downstream waters, including San Francisco Bay. An increase in NPS
pollutants could have adverse effects on wildlife, vegetation, and human health. NPS
pollutants could also infiltrate into groundwater and degrade the quality of
potential groundwater drinking sources. However, mitigation measures would
Exhibit A
CEQA Findings
Page 63 of 84
reduce impacts to a less than significant level and this impact would be the same as
under the project.
Alternative A could result in a reduction of impervious surfaces. Approximately 70
percent of the project site is currently covered in impervious surfaces.
Implementation of the project would decrease impervious surfaces from 70 percent
to 61 percent of the project site. Under Alternative A, fewer buildings would be
developed and it is likely, although unknown if, Alternative A would result in a
greater percentage of pervious surfaces. Mitigation measures would be expected to
be developed on a site by site basis, as individual projects are proposed and
reviewed. Therefore, it is anticipated that under this alternative, impacts would be
less than significant, but not less than the proposed project. Redevelopment at the
project site under Alternative A would involve demolition of existing structures and
paved areas, as well as grading, activities. Construction operations associated with
this alternative would present a threat of soil erosion from soil disturbance by
subjecting unprotected bare soil areas to the erosional forces of runoff during
construction. However, mitigal:ion measures would reduce these impacts to a less
than significant level. Collectively, impacts related to hydrology and water quality
would, similar to the project, be less than significant under Alternative A.
Land Use and Planning
Under Alternative A, the project site would be redeveloped with business park uses.
These uses would be consistent with existing land uses in the surrounding area
which include industrial, warehouse, commercial and research and development
activities. Similar to the project, Alternative A would redevelop the project site and
there would be no division or displacement and therefore no impact to existing
residential communities.
Under Alternative A, a General. Plan Amendment would not be required as the FAR
on the site would be consistent with the existing General Plan allowance. However,
the Gateway Specific Plan District zoning allowing an FAR of 1.25 was adopted for
the intent purpose of developing and redeveloping the entire Gateway Specific Plan
District at a higher density. As surrounding properties are redeveloped, it is likely
That they may request General Plan Amendments to allow redevelopment at
increased densities. Although density under Alternative A would be consistent with
the General Plan density for the site, it would not be consistent with the City's vision
for development in the area, and this impact would be slightly greater than under
the project and be less than significant. There are no natural community plans or
applicable habitat conservation plans that apply to the project site and the project
site does not contain any critical or sensitive habitat. Therefore, similar to the
Exhibit A
CEQA Findings
Page 64 of 84
project, Alternative A would have no impact to conflict with any habitat
conservation plan or natural community conservation plans.
Noise
Under Alternative A, the project site would be developed with approximately
984,500 square feet of Office and R & D uses. Heating, ventilation and air-
conditioning (HVAC) equipment for buildings would likely be located on the roof-
tops of the buildings. Similar tc~ the project, mitigation measures would reduce this
impact to a less than significant level. Similar to the project, buildings on the site
under Alternative A could be e:posed to a CNEL of up to 67.6 dBA along Gateway
Boulevard and 73.4 dBA along Oyster Point Boulevard. However, the City would
require that an analysis of noise reduction requirements be conducted and noise
insulation features be included., as needed, in the design and this impact would be
less than significant and the same as under the project.
Alternative A would result in an approximately 20 percent decrease in square
footage of development and there would a corollary decrease in employees on the
site, and therefore, traffic generated noise due to the decrease in vehicular trips.
This would further reduce the less than 1.1 dBA increase in noise attributed to
project generated traffic. This iimpact under the project would be less than
significant and would remain the same under Alternative A. However, in the future
cumulative traffic will increasE~ the traffic noise levels at the commercial land uses
along Gateway and Oyster Poirlt Boulevards by 2.0 to 4.7 dBA. Cumulative traffic
will increase the traffic noise levels at residential land use along Sister Cities
Boulevard by up to 2.5 dBA. These cumulative traffic noise increases exceed the
threshold of 3 dBA for a significant increase. Alternative A would further reduce
noise impacts from traffic due to the decrease in vehicle trips and similar to the
project the contribution to this; increase is generally small (1.4 dBA or less).
However, since Alternative A would contribute the overall increase in traffic noise, it
would contribute to a significant and unavoidable cumulative impact the same as
the project. Impacts from aircraft noise would be less than significant and the same
as under the project. Under
Alternative A, impacts from temporary groundbourne vibration and noise would be
less than significant with mitigation. However, similar to the project, redevelopment
activities would be phased and the Genentech Child Care facility might still be
operational. Therefore, construction noise would significantly affect the noise
sensitive use of the Genentech Child Care facility resulting in a similar significant
and unavoidable impact.
Population and Housing
Exhibit A
CEQA Findings
Page 65 of 84
Development under Alternative A would result in the employment of 2,406
employees at the project site b~~ 2020. ABAG projects an increase in employment in
the City of South San Francisco of 3,110 jobs from 2005 to 2015 and 2,940 jobs from
2015 to 2020. Therefore, this alternative's contribution to the increase in
employment in the City would lbe within ABAG's employment projections for the
City for both the years of 2015 and 2020 and would be less than significant. The
proposed project is also within ABAG's employment projections. However,
Alternative A would result in the generation of fewer employees and therefore,
reduce the demand for housin€; in the City as compared to the demand which would
result from the proposed project. This alternative, as well as the proposed project,
would promote a greater regional jobs balance, and would not directly or indirectly
induce substantial population €;rowth and this impact would be less than significant.
Similar to the proposed projectt, there would be no impact from the displacement of
existing housing, need for construction of replacement housing, nor displacement of
substantial numbers of people. Under this alternative, overall impacts to population
and housing would be less than significant and Incrementally less than the
proposed project.
Public Services
Demand for public services, including police and fire, would be reduced
proportionally with the reduction in development under Alternative A.
Development of this alternative would result in 2,406 employees at the site,
constituting a minor increase (less than 3 percent) in the City's daytime population
and would not lead to a changE~ in response times, service ratios, and/or
requirement for construction of new police or fire facilities. Current response times
and service ratios are adequate and no new police or fire facilities that would result
in potential significant impacts would be required. Therefore, the impact to public
services would be less than si,~gni~cant, and incrementally less than the proposed
project. No mitigation measures would be necessary.
Transportation and Circulation
Under Alternative A, the project site would be developed with approximately
984,500 square feet of Office and R & D uses. Alternative A would result in an
approximately 20 percent decrease in square footage of development and would
include R & D uses and a commensurate reduction in the number of employees on
the site. This reduction would result in an approximately 26 percent decrease in the
number of trips generated under Alternative A as opposed to the project.
Alternative A would generate enough trips to exceed the C/CAG trip generation
limits by 2015 and 2035, but similar to the project this impact would be reduced to
less than significant. Similar to the project, Alternative A would result in less than
significant impacts to intersections and vehicle queuing by 2015. Alternative A
Exhibit A
CEQA Findings
Page 66 of 84
would result in impacts to U.S. 101 mainline and ramps under 2015. Similar to the
project, these impacts would be significant and unavoidable as the reduction in
vehicle trips is not enough to rE~duce the significant unavoidable impacts. Similar to
the project, 2035 intersection impacts would be less than significant. Impacts to U.S.
101 mainline and ramps under 2035 would be the same as under the project,
significant and unavoidable. ,Alternative A would provide parking at a 2.83 ratio
and would, unlike the project, meet code requirements. Assuming that the parking
garages would be located at the back of the site, impacts to pedestrian safety and
vehicular circulation would be the less than significant, and the same under
Alternative A as the project.
Utilities and Service Systems
Under Alternative A, the project site would be developed with approximately
984,500 square feet of Office a:nd R & D uses. Similar to the project, surface and
stormwater runoff would be collected on-site and would not create or contribute
runoff water which would excE~ed the capacity of existing or planned stormwater
drainage systems or result in t:he need for construction of new storm water drainage
facilities or expansion of existing facilities. Alternative A would result in fewer
square feet of development than the project and would result in incrementally less
demand for water supplies for fire flow, domestic, or manufacturing uses.
Additionally, Alternative A would result in reduced wastewater and solid waste
generation due to the smaller :square footage of development. Overall impacts to
utilities and service systems under Alternative A would be incrementally less than
the project and would be less than significant.
Relationship of Alternative A to the Project Objectives
Alternative A would be a feasible alternative to allow redevelopment of the project
site. Alternative A could potentially meet the project objectives of redeveloping the
project site to create a cohesive working campus environment, emphasizing the
pedestrian environment, encouraging high quality architecture, connecting to
various transit modes, and allowing the incremental and phased redevelopment of
the site. However, this redevelopment would occur at the existing General Plan FAR
of 1.0 and Alternative A would not meet the project's objective to increase the floor
area ratio (FAR) from 0.29 to 1.25. Additionally, the 1.25 FAR proposed by the
project is allowed under the Gateway Specific Plan District zoning. This FAR was
adopted by the City for the intent purpose of developing and redeveloping the entire
Gateway Specific Plan District at a higher density. As surrounding properties are
redeveloped, it is likely that they will also be developed at increased densities as
well. Therefore, although Alter°native A would be feasible it would not meet the
project's objective to redevelop the site at an FAR of 1.25 nor meet the City's intent
to redevelopment the Gateway Specific Plan District at this FAR.
Exhibit A
CEQA Findings
Page 67 of 84
Finding: The No Project Alternative fails to meet basic project objectives.
Alternative A would not meet the project's objective to increase the floor area ratio
FAR) from 0.29 to 1.25. Additionally, the 1.25 FAR proposed by the project is
allowed under the Gateway Specific Plan District zoning. This FAR was adopted by
the City for the intent purpose of developing and redeveloping the entire Gateway
Specific Plan District at a higher density. As surrounding properties are
redeveloped, it is likely that they will also be developed at increased densities as
well. Therefore, although Alternative A would be feasible it would not meet the
project's objective to redevelop the site at an FAR of 1.25 nor meet the City's intent
to redevelopment the Gateway Specific Plan District at this FAR. Likewise,
Alternative A would result in retaining aging and inadequate low-density buildings
on the site. The existing site development would generation fewer employees and
would weaken the City's overall support for the Life Sciences Industry cluster in the
East of 101 Area.
ALTERNATIVE B: REDUCED PROJECT ALTERNATIVE
Alternative B would allow redevelopment of the project site at an FAR of 1.25, but
developed with Research & Development (R&D) uses only resulting in a reduced
project due to the reduction of employees on site. This alternative assumes that
development on the site could be phased but that total buildout would occur by
2020. Under Alternative B, buildout on the site would result in the construction of
approximately 1,230,570 sf of R&D uses. Buildout under Alternative B would result
in approximately 2,735 employees on the project site. Parking would be provided at
a ratio of 2.83 spaces per1,00C1 sf of development for a total of 3,544 spaces
ImpactAnalysis
The impact analysis below focuses on those impacts that were determined to be
potentially significant under the proposed Project. Less than significant impacts are
discussed only if implementation of the alternative will substantially increase the
impact. Reduced development; intensity proposed under this Alternative would
produce fewer vehicle trips acid less air pollutant emissions. However, the
Alternative's resulting degree of trip generation reduction would not reduce traffic
Exhibit A
CEQA Findings
Page 68 of 84
levels sufficiently to reduce either the C/CAG peak hour trip generation limit impact
Traf-1), nor any off-site traffic impact to a less than significant level.
Reduced square footage would result in a shorter construction phase so a reduced
impact related to construction noise and diesel emissions from construction
vehicles. Reduced square footage would also be expected to result in a reduced
number of workers/level of operations so would translate to a reduction in the
operational use of hazardous materials and potential for hazardous materials-
related impacts. A reduction in the number of workers on site would also slightly
reduce impacts related to geological events that could pose a danger to people as
there would be fewer people ors site.
Aesthetics
The project site is currently developed as a business park. Under Alternative B,
another business park would be developed on the site housing R & D uses only.
Similar to the project, no public views to scenic vistas would be blocked and there
would be less than significanl~ impacts to scenic vistas. Additionally, similar to the
project there would be no impact to state scenic highways.
The site is currently developed at an FAR of 0.29. Alternative B would result in
development of the site at an FAR of 1.25, the same density as the project. Similar to
the project, this increase in FAR could be accomplished primarily by increasing the
height of the buildings on the site, thereby increasing the amount of open space on
the site, which would minimize the feeling of density on the site. Therefore, similar
to the project, Alternative B would result in improvements to the visual quality of
the site by increasing open space and pedestrian-oriented areas and creating a
cohesive pedestrian-oriented environment. Therefore, impacts to visual character
and light and glare under Alternative B would be less than significant and the same
as under the project. Therefore, impacts under Alternative B would be the same as
under the project.
Air Quality
Similar to the project, Alternative B would involve the demolition of the existing
structures on the site and construction of office buildings and would implement the
same construction mitigation measures as the project. Therefore, construction
impacts would be less than significant and the same under Alternative B as the
project. Similar to the project, Alternative B would result in development of the site
at an FAR of 1.25 and would result in the same impact regarding consistency with
BAAQMD's Clean Air Plan. Although Alternative B would result in the same amount
Exhibit A
CEQA Findings
Page 69 of 84
of development on the site, it v~~ould result in fewer employees and therefore fewer
vehicular trips. However, although Alternative B would result in an approximately
16 percent decrease in employees on the site, this decrease would not be enough to
reduce vehicle trips significantly enough to eliminate the project's significant
unavoidable PM10 emissions.'Cherefore, air quality impacts PM10 emissions from
under Alternative B (both project and cumulative) would remain, similar to the
project, significant and unava~idable.
Impacts from local CO concentrations would be incrementally less than under the
project and less than significant. Assuming that Alternative B would be constructed
in a phased manner and therefore the childcare facility could remain on site during
some phases of the project, they impacts from TACs would remain less than
signifTCant, the same as under the project. Similar to the project, Alternative B
would not create any objectionable odors and would not conflict with the State goals
in AB 32.Overall impacts to air quality under Alternative B, although incrementally
less, would be the same as under the project.
Biological Resources
The project site is currently developed as a business park and the only biological
resources on the site are mature landscaping. Alternative B has the same potential
to remove trees on the site during construction of new buildings as the project.
Under Alternative B, project construction activities could result in the destruction of
active bird nests during removal of vegetation or grading, or may potentially result
in the abandonment of active nests due to noise and increased activity. However,
similar to the project, mitigation measures would reduce this impact to less than
significant. Similar to the project, Alternative B would have no impact to riparian
habitat, wetlands, or to migratory corridors. Regarding the removal of trees, impacts
to tree removal and conflict with existing codes or plans protecting biological
resources would be the same under Alternative B as the project and less than
significant.
Cultural Resources
The project site has been developed and redeveloped several times in the past
century. These processes have almost completely removed potential for, and make
the property quite unlikely to contain, significant cultural resources that could be
impacted by development. Similar to the proposed project, the potential for
disturbance of subsurface resources during ground disturbing activities, including
fossil bearing soils and rock formations, paleontological resources, and
archeological sites and sites oI' cultural significance to Native Americans, still exists
under this alternative. Mitigatiion measures would be developed for any future
Exhibit A
CEQA Findings
Page 70 of 84
construction at the site, and possible impacts to historical resources would be
avoided to the extent feasible, Ensuring impacts remain less than significant. Under
Alternative B, impacts to cultural resources would remain the same as under the
proposed project.
Geology and Soils
Development of the site under this alternative would produce the same amount of
development
1,230,570 sf) as the proposed project. However, restricting uses to R&D would
result in fewer employees at the site. Geologic hazards such as seismic ground
shaking would still exist under this alternative. However, impacts would be lessened
due to decreased employee generation which would directly result in a lower
amount of people that would be exposed to seismic ground shaking and would be
less than significant. Site specific hazards related to erosion, loss of top soil,
subsidence, expansive soils, anal landslides would remain the same under this
alternative as the same amount of the site area that would be built upon (50 percent
of the total site), and the size of the development (1,230, 570 sf) would remain the
same. Collectively, impacts would be less than significant, and less than the
proposed project.
Hazards and Hazardous Materials
Implementation of this alternative could possibly increase impacts related to
hazards and hazardous materials. Development of this alternative would result in
the creation of R&D uses only, which would increase the amount of additional
laboratories and other research facilities that would use, store, or require the
transport and disposal of hazardous materials. As with the proposed project,
compliance with safety procedures mandated by applicable federal, state, and local
laws and regulations would ensure the risks associated with the routine use of
hazardous materials and disposal of hazardous wastes remain less than significant.
However, with this alternative, potential for accidental release or upset could
increase with additional chemicals from R&D uses present at the site. Therefore,
hazards to the public or the environment may increase, compared to the proposed
project. Similar to the proposed project, existing buildings at the site would be
demolished in order to make room for new development. These buildings
potentially contain hazardous materials including waste oil, asbestos, lead paint,
halogenated and non-halogenated solvents, organic compounds, and petroleum
products. During demolition operations hazardous materials could be released from
structures at the site or from the underlying soils. Portions of the project site would
still be included on government lists of hazardous materials sites, and development
at the site could create a significant hazard to the public or the environment.
Exhibit A
CEQA Findings
Page 71 of 84
However, as projects are revie~Ned on a site-by-site basis, mitigation measures
would be identified to reduce these impacts to a less than significant level.
Under this alternative, potential impacts to nearby schools would also remain the
same, and it is expected that mitigation measures would be identified to ensure
impacts remain less than significant.
Hydrology and Water Quality
The reduced project alternative would result in development of 1,230,570 sf of R&D
uses at the site, with a FAR of 1..25. Typical industrial non-point source (NPS)
pollutants associated with industrial activities would still be present at the site.
Development of this alternative would contribute to the levels of NPS pollutants and
litter entering downstream waters, including San Francisco Bay. An increase in NPS
pollutants could have adverse effects on wildlife, vegetation, and human health. NPS
pollutants could also infiltrate into groundwater and degrade the quality of
potential groundwater drinking sources. However, mitigation measures would be
identified, to reduce possible impacts to a less than significant level.
This alternative would result in similar impacts to impervious surfaces, as those
identified for the proposed project. Approximately 70 percent of the project site is
currently covered in impervious surfaces. This alternative would include a number
of strategies designed to decrease the amount of impervious surfaces.
Implementation of these stratE~gies would decrease impervious surfaces from 70
percent to 61 percent of the project site. Reducing the amount of impervious
surfaces would reduce impacts to groundwater supplies and groundwater recharge.
Therefore, it is anticipated that under this alternative, impacts to groundwater
would be less than signi~can~t, and similar to the proposed project.
Redevelopment at the project site under this alternative would involve demolition
of existing structures and paved areas, as well as grading activities. Construction
operations associated with this alternative would present a threat of soil erosion
from soil disturbance by subjecting unprotected bare soil areas to the erosional
forces of runoff during construction. However, it is expected that mitigation
measures would be identified in order to reduce impacts to a less than significant
level. Impacts would be similar to those identified for proposed project. Like the
proposed project, this alternative provides strategies intended to result in a net
benefit to hydrology and water quality. Collectively, impacts related to hydrology
and water quality would be less than significant under Alternative B.
Land Use and Planning
Exhibit A
CEQA Findings
Page 72 of 84
Under Alternative B, the project site would be redeveloped with R & D uses. These
uses would be consistent with. existing land uses in the surrounding area which
include industrial, warehouse, commercial and research and development activities.
Similar to the project, under Alternative B no existing residential communities
would be displaced or divided..and there would be no impact. Under Alternative B, a
General Plan Amendment to increase the FAR to 1.25 would be required. Similar to
the project, once this General Plan Amendment was approved this FAR of 1.25 (and
as allowed under the Gateway Specific Plan District zoning) would be consistent
with the General Plan. Therefore, similar to the project, density under Alternative B
would be consistent with the City's vision for development in the area and would
not be inconsistent or create land use impacts due to the increased density and this
impact would be less than significant. There are no natural community plans or
applicable habitat conservation plans that apply to the project site and the project
site does not contain any critical or sensitive habitat. Therefore, similar to the
project, Alternative B would have no impact to conflict with any habitat
conservation plan or natural community conservation plans.
Noise
Under Alternative B, the project site would be redeveloped with R & D uses and the
heating, ventilation and air-conditioning (HVAC) equipment for buildings would
likely be located on the roof-tops of the buildings. Similar to the project, mitigation
measures would reduce this impact to a less than significant level. Similar to the
project, buildings constructed on the site under Alternative B could be exposed to a
CNEL of up to 67.6 dBA along (iateway Boulevard and 73.4 dBA along Oyster Point
Boulevard. However, the City would require that an analysis of noise reduction
requirements be conducted anal noise insulation features be included, as needed, in
the design and this impact would be the same as under the project and less than
significant.
Alternative B would result in the same square footage of development as the project.
However, R&D uses require fewer employees and there would a corollary decrease
in traffic generated noise due t;o the decrease in vehicular trips. This would further
reduce the less than 1.1 dBA increase in noise attributed to project generated traffic.
This impact under the project would be less than significant and would remain the
same under Alternative B. Hovvever, in the future cumulative traffic will increase the
traffic noise levels at the commercial land uses along Gateway and Oyster Point
Boulevards by 2.0 to 4.7 dBA. Cumulative traffic will increase the traffic noise levels
at residential land use along Sister Cities Boulevard by up to 2.5 dBA. These
cumulative traffic noise increases exceed the threshold of 3 dBA for a significant
increase. Alternative B would reduce noise impacts from traffic due to the decrease
in vehicle trips and similar to t:he project the contribution to this increase is
generally small (1.4 dBA or les;s).
Exhibit A
CEQA Findings
Page 73 of 84
However, since Alternative B v~~ould contribute to this overall increase in traffic
noise, it would result in a signij~cant and unavoidable cumulative impact the same
as the project.
Impacts from aircraft noise would be less than significant, the same as under the
project. Under
Alternative B, impacts from temporary groundbourne vibration and noise would be
less than significant with mitigation. However, similar to the project,
redevelopment activities would be phased and the Genentech Child Care facility
might still be operational. Therefore, construction noise would significantly affect
the noise sensitive use of the Genentech Child Care facility resulting in a similar
significant and unavoidable impact.
Population and Housing
Development under Alternative B would result in the generation of 2,735 employees
at the project site by 2020. AB,~G projects an increase in employment in the City of
3,110 jobs from 2005 to 2015 and 2,940 jobs from 2015 to 2020. Therefore, this
alternative's contribution to the increase in employment in the City would be within
ABAG's employment projections for the City for both the years of 2015 and 2020.
The proposed project is also within ABAG's employment projections; however,
Alternative B would result in the generation of fewer employees and therefore,
reduce the demand for housing in the City as compared to the proposed project.
This alternative, as well as the proposed project, would promote a greater regional
jobs balance, and would not directly or indirectly induce substantial population
growth and this impact would be less than significant.
Similar to the proposed project, implementation of this alternative would not
displace existing housing, necE~ssitate construction of replacement housing, nor
displace substantial numbers of people. Under this alternative, impacts to
population and housing wouldl be less than significant and similar to the proposed
project.
Public Services
Demand for public services, including police and fire, would be reduced
proportionally with the reduc1tion in development under this alternative.
Development of this alternative would result in 2,735 employees at the site. This
alternative would constitute a negligible increase (less than 3 percent) in the City's
daytime population and would not lead to a change in response times, service ratios,
Exhibit A
CEQA Findings
Page 74 of 84
and/or requirement for construction of new police or fire facilities. Current
response times and service ratios are adequate and no new police or fire facilities
that would result in potential significant impacts would be required. Therefore, the
impact to public services would be less than significant, and incrementally less
than the proposed project. No mitigation measures would be necessary.
Transportation and Circulation
Under Alternative B, the same number of square feet of development would occur as
under the project. However this development would be limited to R & D uses only,
which requires fewer workers for the same number of square feet of development.
Therefore, Alternative B would result in approximately 26 percent less employees
on the site and an approximatE~ly 26 percent decrease in the number of trips
generated under Alternative B as opposed to the project.
However, Alternative B would generate enough trips to exceed the C/CAG trip
generation limits by 2015 and 2035. Similar to the project this impact would be
reduced to less than significant. Alternative B would result in less than significant
impacts to intersections and vehicle queuing by 2015. Similar to the project,
Alternative B would result in impacts to U.S. 101 mainline and ramps under 2015.
Similar to the project, these impacts would be significant and unavoidable as the
reduction in vehicle trips is not enough to reduce the significant unavoidable
impacts. Similar to the project, 2035 intersection impacts would be less than
significant. Impacts to U.S. 10'1 mainline and ramps under 2035 would be the same
as under the project, significant and unavoidable.
Alternative B would provide parking at a 2.83 ratio and would, unlike the project,
meet code requirements. Assuming that the parking garages would be located at the
back of the site, impacts to pedestrian safety and vehicular circulation would be the
same under Alternative B as the project and there would be no impact.
Utilities and Service Systems
Under Alternative B, the same number of square feet of development would occur as
under the project. However this development would be limited to R & D uses only,
which requires fewer workers for the same number of square feet of development.
Similar to the project, surface ;and stormwater runoff would be collected on-site and
would not create or contributE~ runoff water which would exceed the capacity of
existing or planned stormwater drainage systems or result in the need for
construction of new storm water drainage facilities or expansion of existing
facilities. Although Alternatives B would result in the same square footage of
development, the development of R&D only uses would result in fewer employees
Exhibit A
CEQA Findings
Page 75 of 84
on the site than the project and would result in incrementally less demand for water
supplies for fire flow, domestic, or manufacturing uses. Additionally, Alternative B
would result in reduced wastewater and solid waste generation due to the smaller
number of employees on the site. Overall impacts to utilities and service systems
under Alternative B would be incrementally less than the project and would be less
than significant.
Relationship of Alternative B to the Project Objectives
Alternative B would be a feasible alternative to allow redevelopment of the project
site and would meet all of the project's objectives. This alternative would allow for
redevelopment of the project site at an FAR of 1.25, however, the use would be
restricted to Research and Development only. Alternative B would be a feasible
alternative to allow redevelop~~nent of the project site and could potentially meet the
project objectives of redeveloping the project site to create a cohesive working
campus environment, emphasiizing the pedestrian environment, encouraging high
quality architecture, connecting to various transit modes, and allowing the
incremental and phased redevelopment of the site. However, Alternative B would
restrict the uses developed on the site and would not allow for varied
redevelopment that the project would provide.
Finding: The Reduced Project Alternative fails to meet basic project objectives.
The Reduced Project Alternative would result in a project similar to the proposed
project, but smaller in size. Therefore, the Reduced Intensity Alternative would be
incapable of generating all of tlhe benefits of the proposed Project. It would not for
example, generate as much tax: revenue for the City, or create as many new
employment opportunities. Furthermore, while the Reduced Intensity Alternative
may further minimize some of the less-than-significant impacts of the proposed
Project, the Alternative would be incapable of minimizing the significant and
unavoidable impact to the off-ramp operation at the mainline diverge. For the
reasons stated, the City Council finds that the Reduced Intensity Alternative fails to
meet basic project objectives.
ALTERNATIVE C: REDUCED :PARKING ALTERNATIVE
Alternative C would develop the site with Office and R&D uses at an FAR of 1.25.
This alternative assumes that development on the site could be phased but that total
buildout would occur by 2020,. Alternative C would result in the construction of
approximately 984,500 sf of development and approximately 3,009 employees on
the site. Under Alternative C, parking would be provided at a reduced ratio of 2.3
spaces per 1,000 sf resulting irl a total of 2,264 parking spaces on the site.
Exhibit A
CEQA Findings
Page 76 of 84
Aesthetics
The project site is currently dE~veloped as a business park. Under Alternative C, a
business park would be developed on the site housing Office and R & D uses. Similar
to the project, no public views to scenic vistas would be blocked and there would be
less than significant impacts to scenic vistas. Additionally, similar to the project
there would be no impact to state scenic highways. The site is currently developed
at an FAR of 0.29. Alternative C would result in development of the site at an FAR of
1.25, the same density as the project. Similar to the project, this increase in FAR
could be accomplished primarily by increasing the height of the buildings on the
site, thereby increasing the amount of open space on the site, which would minimize
the feeling of density on the site. However, due to the reduced number of parking
spaces on the site, parking structures under Alternative C could potentially be
smaller in size and there could be more open space areas provided on the site.
However, this increase in open space would be incremental compared to the project
and would only increase the benefits to visual quality already provided by the
project. Lighting and building materials on the site under Alternative C would
similar to the project, be less than significant, and would be subject to the same
City standards as the project. Therefore, impacts under Alternative C would be the
same as under the project.
Air Quality
Similar to the project, Alternat;ive C would involve the demolition of the existing
structures on the site and con;>truction of office buildings. Similar to the project,
Alternative C would result in development of the site at an FAR of 1.25 and would
result in the same impact regarding consistency with BAAQMD's Clean Air Plan.
Alternative C would implement the same construction mitigation measures as the
project and construction impacts would be less than significant and the same
under Alternative C as the project. Alternative C would result in the same amount of
development on the site, but wrould provide less parking on the site, resulting in
fewer employees driving to the site and therefore fewer vehicular trips. However,
although Alternative C would result in a decrease in employees driving to the site,
this decrease would not be enough to reduce vehicle trips significantly enough to
eliminate the project's significant unavoidable PM10 emissions. Therefore, air
quality impacts PM10 emissions from under Alternative C (both project and
cumulative) would remain, sinnilar to the project, significant and unavoidable.
Impacts from local CO concentrations would remain the same as under the project
and less than significant. Assuming that Alternative C would be constructed in a
phased manner and therefore the childcare facility could remain on site during
some phases of the project, thc~ impacts from TACs would remain less than
Exhibit A
CEQA Findings
Page 77 of 84
significant, the same as under the project. Similar to the project, Alternative C there
would be no impact from objectionable odors and it would not conflict with the
State goals in AB 32. Overall innpacts to air quality under Alternative C, although
incrementally less, would be the same as under the project.
Biological Resources
The project site is currently dE~veloped as a business park and the only biological
resources on the site are mature landscaping. Alternative C has the same potential
to remove trees on the site as the project as it is likely that reduced parking would
result only in smaller parking structures and would not increase the preservation of
existing landscaping. Under Alternative C, project construction activities could
result in the same less than significant impacts due to destruction of active bird
nests during removal of vegetation or grading, or may potentially result in the
abandonment of active nests due to noise and increased activity. However, similar
to the project, mitigation measures would reduce this impact to less than significant.
Similar to the project, Alternative C would have no impact to riparian habitat,
wetlands, or to migratory corridors. Regarding the removal of trees, impacts to tree
removal and conflict with existing codes or plans protecting biological resources
would be the same under Alternative C as the project and less than significant.
Cultural Resources
The project site has been developed and redeveloped several times in the twentieth
century. These processes haves almost completely removed potential for, and make
the property quite unlikely to contain, significant cultural resources that could be
impacted by development. Similar to the proposed project, the potential for
disturbance of subsurface resources during ground disturbing activities, including
fossilbearing soils and rock formations, paleontological resources, and archeological
sites and sites of cultural significance to Native Americans, still exists under this
alternative. Mitigation measures would be expected to be developed for any future
construction at the site, and possible impacts to historical resources would be
avoided to the extent feasible, ensuring impacts remain less than significant. Under
Alternative C, impacts to cultural resources would remain the same as under the
proposed project.
Geology and Soils
Implementation of this alternative would result in the same amount of development
1,230,570 sf) and employees as the proposed project. Geologic hazards such as
seismic ground shaking would still exist under this alternative, and impacts would
remain less than significant. Site specific hazards related to erosion, loss of top soil,
Exhibit A
CEQA Findings
Page 78 of 84
subsidence, expansive soils, and landslides would also remain the same under this
alternative since the amount of the site area that would be built upon (50 percent of
the total site), and the size of the development (1,230, 570 sf) would remain.
Collectively, impacts would be less than significant, but not less than the proposed
project.
Hazards and Hazardous Materials
Development of this alternative would result in the construction 615,285 sf of R&D
uses, resulting in laboratories ;and other research facilities that would use, store, or
require the transport and disposal of hazardous materials. As with the proposed
project, compliance with safety procedures mandated by applicable federal, state,
and local laws and regulations would ensure the risks associated with the routine
use of hazardous materials and disposal of hazardous wastes remain less than
significant. Impacts associated with hazards and hazardous materials would
remain the same as the proposed project. Similar to the proposed project, existing
buildings at the site would be demolished in order to make room for new
development. These buildings potentially contain hazardous materials including
waste oil, asbestos, lead paint, halogenated and non-halogenated solvents, organic
compounds, and petroleum products. During demolition operations hazardous
materials could be released from structures at the site or from the underlying soils.
Portions of the project site would still be included on government lists of hazardous
materials sites, and developmc~nt at the site could create a significant hazard to the
public or the environment. However, as projects are reviewed on a site-by-site basis,
mitigation measures would be identified to reduce these impacts to a less than
significant level.
Under this alternative, potential impacts to nearby schools would also remain the
same as under the proposed project, and it is expected that mitigation measures
would be identified to ensure iimpacts remain less than significant,
Hydrology and Water QualitJr
The reduced parking alternative would result in development of 1,230,570 sf of
R&D and Office uses, a FAR of 1.25, and 2,264 parking spaces. Typical industrial
non-point source (NPS) pollutants associated with industrial activities would still be
present at the site and would be the same as the project and less than significant.
Development of this alternative would contribute to the levels of NPS pollutants and
litter entering downstream waters, including San Francisco Bay. However, it is
expected that mitigation measures would be identified to reduce possible impacts to
a less than significant level. This alternative could result in a reduction to impacts
associated with impervious surfaces. More than 70 percent of the project site is
currently covered in impervious surfaces. This alternative includes a number of
strategies designed to decrease the amount of impervious surfaces at the site.
Exhibit A
CEQA Findings
Page 79 of 84
Implementation of these strategies would decrease impervious surfaces from 70
percent to 61 percent of the project site. This alternative also includes less site
development, and less parking, which could result in a greater reduction of
impervious surfaces. Development of Alternative C would reduce impacts to
groundwater supplies and groundwater recharge at the project site. Mitigation
measures would be expected to be developed on a site by site basis, as individual
projects are proposed and reviewed. Therefore, it is anticipated that under this
alternative, impacts to ground~~ater would be less than significant, and similar to
the proposed project.
Redevelopment at the project site under this alternative would involve demolition
of existing structures and paved areas, as well as grading activities. Construction
operations associated with this alternative would present a threat of soil erosion
from soil disturbance by subjecting unprotected bare soil areas to the erosional
forces of runoff during construction. However, it is expected that mitigation
measures would be identified iin order to reduce impacts to a less than significant
level. Impacts would be similar to those identified for proposed project.
Development of this alternative includes strategies intended to result in a net
benefit to these resources. Collectively, impacts related to hydrology and water
quality would be less than sig.ni~cant under Alternative C, and similar to the
proposed project.
Land Use and Planning
Under Alternative C, the project site would be redeveloped with Office and R & D
land uses. These uses would be consistent with existing land uses in the
surrounding area which include industrial, warehouse, commercial and research
and development activities. Similar to the project, Alternative C would redevelop the
project site with Office and R ~z D uses and there would be no impact to existing
residential communities.
Under Alternative C, a General Plan Amendment to increase the FAR to 1.25 would
be required. The Gateway Specific Plan District zoning allowing an FAR of 1.25 was
adopted for the intent purpose of developing and redeveloping the entire Gateway
Specific Plan District at a higher density. As surrounding properties are
redeveloped, it is likely that they may request General Plan Amendments to allow
redevelopment at increased densities. Therefore, similar to the project, density
under Alternative C would be consistent with the City's vision for development in
the area. Density would not bey inconsistent or create land use impacts due to the
increased density and this impact would be less than significant and similar to the
project. Under Alternative C, t11e anticipated range of total parking provided at
ultimate buildout would be 2,264 spaces. Parking would be provided at a ratio that
Exhibit A
CEQA Findings
Page 80 of 84
would not meet code requirements for this development level of 2.3 spaces per
1,000 s£ Although the City typically allows 2.83 spaces per 1,000 square feet for
office/research and development uses, the City may accept revised parking
standards as long as the amount of parking generated by the standards is supportive
of the recommendations and rf~quirements of the Transportation Demand
Management plan prepared for the project. Therefore, impacts to Gateway Specific
Plan District Zoning parking requirements would be the less than significant and
the same as under the project,
There are no natural community plans or applicable habitat conservation plans that
apply to the project site and the project site does not contain any critical or sensitive
habitat. Therefore, similar to the project, Alternative C would have no impact to
conflict with any habitat conservation plan or natural community conservation
plans.
Noise
Under Alternative C, the project site would be redeveloped with Office and R & D
uses at the same density and square footage as the project, and would employ the
same number of employees on the site. Heating, ventilation and air-conditioning
HVAC) equipment for buildings would likely be located on the roof-tops of the
buildings. As under the project:, mitigation measures would reduce this impact to a
less than significant level. Similar to the project, buildings constructed on the site
under Alternative C could be exposed to a CNEL of up to 67.6 dBA along Gateway
Boulevard and 73.4 dBA along Oyster Point Boulevard. However, the City would
require that an analysis of noise reduction requirements be conducted and noise
insulation features be included, as needed, in the design and this impact would be
the same as under the project.
Alternative C would result in t:he same square footage of development as the project
and employees as the project. 'The number of vehicle trips and, therefore, traffic
generated noise would be the .same as under the project. This impact under the
project would be less than significant and would remain the same under Alternative
C. In the future, cumulative traffic would increase the traffic noise levels at the
commercial land uses along Gateway and Oyster Point Boulevards by 2.0 to 4.7 dBA.
Cumulative traffic would increase the traffic noise levels at residential land use
along Sister Cities Boulevard by up to 2.5 dBA. These cumulative traffic noise
increases exceed the threshold of 3 dBA for a significant increase. Similar to the
project, Alternative C would rE~sult in the contribution to this increase and would
result in a significant and unavoidable cumulative impact to noise the same as the
project. Impacts from aircraft noise would be the same as under the project. Under
Alternative C, impacts from temporary groundbourne vibration and noise would be
Exhibit A
CEQA Findings
Page 81 of 84
less than significant with mitig<~tion. However, similar to the project, redevelopment
activities would be phased and the Genentech Child Care facility might still be
operational. Therefore, construction noise would significantly affect the noise
sensitive use of the Genentech Child Care facility resulting in a similar significant
and unavoidable impact.
Population and Housing
Development under Alternative C would result in the generation of 3,009 employees
at the project site. ABAG projects an increase in employment in the City of 3,110
jobs from 2005 to 2015 and 2,940 jobs from 2015 to 2020. Therefore, this
alternative's contribution to the increase in employment in the City would be within
ABAG's employment projections for the City for both the years of 2015 and 2020.
The proposed project is also within ABAG's employment projections; however,
Alternative C would result in the generation of fewer employees and therefore,
reduce the demand for housing; in the City as compared to the proposed project. .
This alternative, as well as the proposed project, would promote a greater regional
jobs balance, and would not directly or indirectly induce substantial population
growth and this impact would be less than significant.
Similar to the proposed project, implementation of this alternative would not
displace existing housing, necE~ssitate construction of replacement housing, nor
displace substantial numbers of people. Under this alternative, impacts to
population and housing would be less than significant and slightly less than the
proposed project.
Public Services
Demand for public services, including police and fire, would be reduced
proportionally with the reducl_ion in development under this alternative.
Development of this alternative would result in 3,009employees at the site
constituting a minor increase (less than 3 percent) in the City's daytime population
and would not lead to a change in response times, service ratios, and/or
requirement for construction of new police or fire facilities. Current response times
and service ratios are adequate and no new police or fire facilities that would result
in potential significant impacts would be required. Therefore, the impact to public
services would be less than significant, and less than the proposed project. No
mitigation measures would bE~ necessary.
Transportation and Circulation
Exhibit A
CEQA Findings
Page 82 of 84
Under Alternative C, the same number of square feet of development of Office and R
D uses would occur on the site as under the project. Therefore, Alternative C
would result in the same number of employees on the site. However, under
Alternative C, fewer parking spaces would be provided, which would act as a
disincentive for employees to drive. This would theoretically result in an
approximate 27 percent of decrease in the number of trips generated under
Alternative C as opposed to the project. However, Alternative C would generate
enough trips to exceed the C/CAG trip generation limits by 2015 and 2035. Similar
to the project this impact would be reduced to less than significant.
Alternative C would result in lE~ss than significant impacts to intersections and
vehicle queuing by 2015. Similar to the project, Alternative C would result in
impacts to U.S. 101 mainline and ramps under 2015. Similar to the project, these
impacts would be significant and unavoidable as the reduction in vehicle trips is
not enough to reduce the significant unavoidable impacts. Similar to the project,
2035 intersection impacts would be less than significant. Impacts to U.S. 101
mainline and ramps under 20?~5 would be the same as under the project, significant
and unavoidable.
Alternative C would provide parking at a 2.3 ratio and would, similar to the project,
not meet code requirements and this impact would be the same. Assuming that the
parking garages would be located at the back of the site, impacts to pedestrian
safety and vehicular circulation would be less than significant and the same under
Alternative C as the project.
Utilities and Service Systems
Under Alternative C, the same number of square feet of development would occur
on the site as under the project. Similar to the project, surface and stormwater
runoff would be collected on-site and would not create or contribute runoff water
which would exceed the capacity of existing or planned stormwater drainage
systems or result in the need for construction of new storm water drainage facilities
or expansion of existing facilities. Although Alternative C would result in the same
square footage of development, the development of R & D uses would consume
more water and so would result in an increase in water usage on the site. Therefore,
demand for water supplies for' fire flow, domestic, or manufacturing uses would be
incrementally increased. Additionally, Alternative C would result in slightly reduced
amount of wastewater and solid waste generation due to the increase in employees.
However, overall impacts to utilities and service systems under Alternative C would
be the same as under the project and would be less than significant.
Exhibit A
CEQA Findings
Page 83 of 84
Relationship of Alternative C Ito the Project Objectives
Alternative C would be a feasible alternative to allow redevelopment of the project
site and would meet all of the project's objectives. This alternative would allow for
redevelopment of the project site at an FAR of 1.25, however, with fewer parking
spaces provided on the site. Alternative C would be a feasible alternative to allow
redevelopment of the project site and could potentially meet the project objectives
of redeveloping the project site to create a cohesive working campus environment,
emphasizing the pedestrian environment, encouraging high quality architecture,
connecting to various transit Triodes, and allowing the incremental and phased
redevelopment of the site.
Finding: The Reduced Parking Alternative fails to meet basic project
objectives
In light of the entire record, including the letter submitted by DGA Architects, the
City finds that the parking reduction described in this alternative is substantially
greater and more onerous tha~rr the parking restrictions considered, and ultimately
approved, for other similar projects located in the East of 101 Area. The Reduced
Parking Alternative effectively requires a 19% reduction in the number of parking
spaces from the amount required under the Municipal Code. The indirect effects of
the Alternative could prevent 'the Alternative from meeting basic project objectives.
For example, provision of substantially fewer parking spaces per gross square foot,
as compared to other developments in the area, could make finding tenants for the
project difficult. This would negatively affect the viability of the project (Project
Objective #4), as well as the project's ability to generate tax revenue for the City
3) and create quality jobs (#2). It would also impede the growth of the area's high
technology research and development uses. The Reduced Parking Alternative,
therefore, fails to meet the project's basic objectives. For the reasons stated, the City
finds that requiring such a substantial and unique reduction in available parking is
an infeasible alternative to the proposed Project.
ENVIRONMENTALLY SUPERIOR ALTERNATIVE
In addition to the discussion and comparison of impacts of the proposed project and
the alternatives, Section 15126.6 of the CEQA Guidelines requires that an
environmentally superior" alternative be selected and the reasons for such a
selection disclosed. In generall, the environmentally superior alternative is the
alternative that would be expected to generate the least amount of significant
impacts. Identification of the environmentally superior alternative is an
informational procedure and the alternative selected may not be the alternative that
best meets the goals or needs of the City. Table IV-2 in the EIR summarizes the
Exhibit A
CEQA Findings
Page 84 of 84
comparative impacts of each of'the alternatives when compared to the project. The
table lists the level of significance of the impacts of the project to each
environmental topic analyzed in Chapter IV and shows whether the impacts
anticipated under each proposed alternative would be lesser, similar, or greater
than the proposed project. The table provides a comparison of the ability of each
alternative to avoid or substantially reduce the significant impacts of the project.
Alternative A, the No Project/B~uildout Under Existing General Plan Alternative,
proposes a reduced amount of development that would result in the fewest
employees on the site and therefore, potentially the least amount of vehicle trips.
This smaller amount of trips would provide the biggest decrease in operational
emissions, vehicular-related noise increases, and traffic impacts and would
therefore be the environmentally superior alternative.
However, CEQA requires that if the environmentally superior alternative is the "no
project" alternative, the EIR shall also identify an environmentally superior
alternative from among the other alternatives (CEQA Guidelines, Section
15126.6[e] [2]). Based on the analysis provided above, it has been determined that
Alternative C would be the environmentally superior alternative, because this
alternative would result in the next greatest reduction in significant project impacts
to air quality, noise, and traffic. The alternatives to the project considered in this
analysis propose either a reduced amount of development on the site, land uses
requiring fewer employees, or fewer parking spaces on the site (thereby limited
project-generated trips to the site). However, although all these alternatives would
result in some reduction of employees or vehicle trips to the project site, none of the
feasible alternatives would reduce impacts to a level that would reduce the
significant unavoidable impaci:s to air quality, noise, and traffic.
Therefore, no feasible alternative is superior in this regard and, similar to the
project, all feasible alternatives would result in the significant and unavoidable
impacts.
1364466.2
Exhibit B
Statement of Overriding Considerations
STATEMENT OF OVERRIDING CONSIDERATIONS
1. General. Pursuant to CEQA Guidelines section 15093, the City Council of
the City of South San Francisco adopts this Statement of Overriding Considerations
for those impacts identified as significant and unavoidable in the Gateway Business
Park Master Plan Environmental Impact Report ("Gateway Business Park Master
Plan" or "Project"). (Resolution No. .) The City Council has carefully
considered each impact in reaching its decision to approve the Project.
The proposed project is located in the City's East of 101 Area and the
Gateway Redevelopment Project Area. The development is controlled by the South
San Francisco General Plan, The East of 101 Area Plan and the Gateway Specific
Plan. The project consists of a 1Vlaster Plan and a Phase 1 Precise Plan (Precise Plan)
for the redevelopment of the existing Gateway Business Park. The Precise Plan
consists of two sub-phases, la and 1b, and would define the first phase of the
Project while other phases of the Project are more conceptual in nature. The Project
consists of the phased removal and replacement of existing buildings on the 22.6-
acre project site and construction of five to six new buildings, six stories in height,
and two to four parking structures. The project would be constructed in five phases
from 2011 to 2020. The project includes three building types (Gateway Boulevard
frontage buildings, internal site buildings, parking structures) varying
architecturally in style to create visual interest and diversity on the Project site. The
two easterly buildings proposed for 900 and 850 Gateway Boulevard would be six-
stories in height. Other buildings on the site including the parking structures would
be less than six stories in height.
The buildings would be situated close to the perimeter of the site thereby
creating large areas to accommodate open space and landscaping. The ratio of
parking spaces provided on-site will vary during phases of the Project ranging from
2.52 to 2.88. At completion, the Project would provide 3,100 parking spaces on the
site. The parking structures would be situated on the southeastern border of the
master plan area. The office buildings would be situated primarily along Gateway
Boulevard at the western border and the intersection of Gateway Boulevard and
Oyster Point Boulevard. Internal areas of the Project site would contain the Central
Commons, an area incorporatiing open space areas, landscaping, and pedestrian
walkways.
Exhibit B
Statement of Overriding Considerations
Page 2 of 23
The proposed Project would involve increasing density at the site by
developing the site up to an FAR of 1.25. This change in FAR translates to an
increase in permitted development at the site to approximately 1,230,570 square
feet (sf), or a net change of 946,570 sf, as compared to existing development. Upon
buildout of the project, impervious area would be reduced from approximately 70
percent to approximately 61 percent.
The objectives of the Project are as follows:
Increase FAR at the site from approximately 0.29 to 1.25 FAR.
Create a cohesive working campus environment with a clear organization of
buildings, structures parking, and network ofhigh-quality pedestrian
circulation and open space.
Emphasize the pedestrian environment with well-designated and useful
landscaping that respond to the climate of the City.
Encourage high-quality architecture, landscape architecture, and sustainable
design elements.
Connect to and foster the use of various modes of transit such as Caltrain,
BART, and future Ferry service.
Allow for the incremental and phase redevelopment of the existing buildings
while maintaining a functioning working environment for areas not
concurrently being redeveloped.
Promote alternatives to automobile transportation to further the City's
transportation objectives by emphasizing shuttles, linkages, transportation
demand management, and pedestrian access and ease of movement between
buildings.
Generate tax revenue through the Redevelopment Agency.
The City Council hereby adopts specific overriding considerations for the
impacts listed below that are identified in the EIR as significant and unavoidable.
The City Council believes that many of the unavoidable environmental effects
identified in the EIR will be substantially lessened by mitigation measures adopted
with the original General Plan approval and by the measures adopted through the
current project approval, including the Mitigation Monitoring and Reporting Plan
for the EIR. Even with mitigation, however, the City Council recognizes that the
implementation of the Project carries with it unavoidable adverse environmental
effects as identified in the EIR. The City Council specifically finds that to the extent
the identified adverse or potentially adverse impacts for the Project have not been
mitigated to acceptable levels, there are specific economic, social, environmental,
land use, and other considerations that support approval of the Project.
Exhibit B
Statement of Overriding Considerations
Page 3 of 23
2. Unavoidable Significant Adverse Impacts. The following significant and
unavoidable environmental impacts have been identified in the Gateway Business
Park Master Plan Environmental Impact Report:
AIR QUALITY
Impact IV.C-1: The proposed project would conflict with the applicable air quality
plan because the increase in FAR would result in more vehicle miles traveled than
could be generated under the existing General Plan. This is considered a potentially
significant impact. This impact would remain significant and unavoidable because
no feasible mitigation measures are available to reduce this impact.
Finding IV.C-1: The proposed Transportation Demand Management Plan will help
reduce this impact. However, there are no feasible mitigation measures that reduce
this impact to a level of less-than-significant. As the mitigation of this impact is not
feasible, this impact would be considered significant and unavoidable.
Impact IV.C-2: The proposed project would violate an air quality standard. This is
considered a potentially signifiicant impact. Mitigation Measure IV.C-2.1 would
reduce impacts from construction/demolition emissions to less than significant.
However, even with implementation of Mitigation Measure IV.C-2.2, this impact
would remain significant and unavoidable because no feasible mitigation
measures are available to reduice this impact.
Mitigation Measure IV.C-2.1 Construction/Demolition Emissions
Implementation of the following measures would reduce airborne dust by reducing
and controlling loose soils in areas subject to dust creating activity. As a condition of
the construction contracts, thE~ project sponsors shall require that construction
contractors follow these construction practices:
a. Water all active construction areas at least twice daily.
b. Cover all trucks hauling soil, sand, and other loose materials or require all trucks
to maintain at least two feet o1~ freeboard.
c. Pave, apply water three times daily, or apply nontoxic soil stabilizers on all
unpaved access roads, parkin€; areas, and staging areas at the construction sites.
Exhibit B
Statement of Overriding Considerations
Page 4 of 23
d. Sweep daily (with water sweepers) all paved access roads, parking areas, and
staging areas at the construction sites.
e. Sweep public streets adjacent to construction sites daily (with water sweepers) if
visible soil material.
f. Hydroseed or apply non-toxic; soil stabilizers to inactive construction areas
previously graded areas inactive for ten days or more).
g. Enclose, cover, water twice daily, or apply non-toxic soil binders to exposed
stockpiles (dirt, sand, etc.).
h. Limit traffic speeds on unpaved roads to 15 miles per hour.
i. Install sandbags or other erosion control measures to prevent silt runoff to public
roadways.
j. Replant vegetation in disturbed areas as soon as possible.
k. Wash off the tires or tracks of all trucks and equipment leaving the construction
site.
1. Install wind breaks at the windward sides of the construction areas
m. Suspend excavation and grading activities when wind (as instantaneous gusts)
exceeds 25 miles per hour.
Mitigation Measure IV.C-2.2 Regional Operational Emissions -Daily Emissions
of ROG, NOx, and PM10
As noted earlier, the primary sources of long-term, indirect emissions associated
with the project are motor vehicles. The current evaluation includes implementation
of a TDM program estimated to account fora 20 percent reduction in trip
generation.
Finding IV.C-2: Mitigation Measure IV.C-2.1 would reduce impacts from
construction/demolition emissions to less than significant. However, even with
implementation of Mitigation 1Measure IV.C-2.2, this impact would remain
significant and unavoidable because no additional feasible mitigation measures
are available to reduce this impact.
NOISE
Exhibit B
Statement of Overriding Considerations
Page 5 of 23
Impact IV.J-4: The proposed project would result in substantial temporary or
periodic increase in ambient noise levels in the project vicinity. This is considered a
potentially significant impact. However, implementation of Mitigation Measure IV.J-
4.1 would reduce the construction noise impact at the existing office buildings and
hotels to less than significant, but the construction noise at the Genentech Child
Care facility is considered significant and unavoidable because no feasible
mitigation measures are available to reduce this impact.
Mitigation Measure IV.J-4.1 Construction Generated Noise
Prepare a demolition and construction noise control plan that identifies detailed,
site-specific noise attenuation :measures that will be used to minimize impacts on
adjacent land uses. The plan should be prepared under the supervision of a qualified
acoustical consultant or person experienced with equipment and techniques that
can be used to reduce construction related noise. The plan must include but is not
limited to the following:
Implement noise attenuation measures, which shall include noise barriers or noise
blankets. Particular attention should be paid to providing a noise barrier (at least
12-feet tall) to protect outdoor uses such as the eastern play area of the Genentech
Child Care facility, if it remains during construction.
Provide advance notification to surrounding land uses disclosing the construction
schedule, including the various types of activities that would be occurring
throughout the duration of they construction period.
Ensure that construction equipment is properly muffled according to industry
standards.
Place noise-generating construction equipment and locate construction staging
areas away from sensitive users, where feasible.
Schedule high noise-producing activities between when they would be least likely
to interfere with the noise sensitive activities of the neighboring land uses. When
near the hotels this would mean restricting construction during sleeping hours.
However, near office buildings or Genentech Child Care uses the evening hours may
be preferable because the buildings are not occupied.
In addition to the preparation of the construction noise control plan, the following
measures are recommended and maybe included in the plan:
Designate an on-site construction noise complaint manager for the duration of the
project.
Exhibit B
Statement of Overriding Considerations
Page 6 of 23
Post signs around the project site to inform persons of the construction hours and
the name and phone number of the person or persons to notify in the event of a
noise related problem.
Apre-construction meeting shall be held with the job inspectors and the general
contractor/on-site project manager to confirm that noise mitigation practices
including construction hours, neighborhood notification, posted signs, etc.) are
completed.
The project applicant shall require by contract specifications that construction
staging areas along with operation of earthmoving equipment within the project site
be located as far away from vibration and noise sensitive sites as possible. Contract
specifications shall be included in the construction documents, which shall be
reviewed by the City prior to issuance of a grading permit.
The project applicant shall require by contract specifications that heavily loaded
trucks should be routed away i`rom noise and vibration sensitive uses, to the extent
possible. Contract specifications shall be included on the construction documents,
which shall be reviewed by thE~ City prior to issuance of a grading permit..
Finding IV.J-4: Implementation of Mitigation Measure IV.J-4.1 would reduce the
construction noise impact at the existing office buildings and hotels to less than
significant, but the construction noise at the Genentech Child Care facility, a
sensitive receptor, is considerf~d significant and unavoidable because no feasible
mitigation measures are available to avoid this impact. Since the construction noise
would significantly affect the noise sensitive use of the Genentech Child Care facility
that includes outdoor play areas and indoor areas that could be used for daytime
sleeping, and mitigation measures such as noise barriers will be only partially
effective in reducing construction noise levels and minimizing noise induced activity
interference (the construction of the upper floors would be elevated above a noise
barrier) construction noise at the Child Care facility, while temporary, is considered
significant and unavoidable after mitigation.
TRANSPORTATION/TRAFFIC
Impact IV.M-4A: The following discussion concerns U.S.101 Southbound Flyover
Off-Ramp to Oyster Point Boulevard /Gateway Boulevard Intersection. During the
AM peak hour, the project would increase off-ramp volumes by 6.9 percent, with
year 2015 Base
Exhibit B
Statement of Overriding Considerations
Page 7 of 23
Case off-ramp traffic occasionally backing up to the freeway mainline. This is
considered a potentially significant impact. Even with implementation of Mitigation
Measure IV.M 4A, this impact v~vould remain significant and unavoidable.
Mitigation Measure IV.M-4A 2015 Off-Ramp Queuing to Freeway Mainline -
SIM Traffic Evaluation (see Figure IV.M-21) at U.S.101 Southbound Flyover Off-
Ramp to Oyster Point Boule~~ard /Gateway Boulevard Intersection
The proposed project should provide a fair share contribution as determined by the
City Engineer to the following measures. See Mitigation Measure IV.M-2A. In
addition, add an exclusive right turn lane to the flyover off-ramp approach for a total
of four lanes. Stripe as three through lanes and one exclusive right turn lane. This
measure will require the approval of Caltrans. Also, this measure is not currently
included in the East of 101 Traffic Impact Fee list. Further, as an improvement to a
freeway ramp, the measure is not within the City's jurisdiction, but rather would
require approval of Caltrans.
Adjust signal timing to provide more green time to flyover off-ramp and Oyster
Point eastbound movements. Resultant Operation: AM Peak Hour: The proposed
mitigation will provide additional capacity and reduce delay, which would eliminate
the 95th percentile southbound flyover offramp queue extending to the freeway
mainline.
It should be noted that because the improvement is within Caltrans' jurisdiction, the
City of South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented. While it is likely that Caltrans will implement the
measure, thereby reducing they impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable.
Finding IV.M-4A: Even with implementation of Mitigation Measure IV.M 4A, this
impact would remain significant and unavoidable. The mitigation will provide
additional capacity and reduce delay, which would eliminate the 95th percentile
southbound flyover off ramp queue extending to the freeway mainline. It should be
noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented. While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable.
Exhibit B
Statement of Overriding Considerations
Page 8 of 23
Impact IV.M-4B: The following; discussion concerns U.S.101 Northbound Off-Ramp
to Dubuque Avenue Intersection. During the AM peak hour, the project would
increase off-ramp volumes by ?..3 percent, with year 2015 Base Case off-ramp traffic
occasionally
backing up to the freeway mainline. This is considered a potentially significant
impact. Even with implementation of Mitigation Measure IV.M-4B, this impact
would remain significant and unavoidable.
Mitigation Measure IV.M-4B ;L015 Off-Ramp Queuing to Freeway Mainline -
SIMTraffic Evaluation (see Figure IV.M-21) at U.S.101 Northbound Off-Ramp
to Dubuque Avenue Intersecttion
The proposed project should provide a fair share contribution as determined by the
City Engineer to the following measures.
Widen the off-ramp approachi to provide three exclusive left turn lanes and a
combined through/ right turn ]lane. In addition, lengthen the offramp lanes to
provide an additiona1600 to 700 feet of storage. This measure will require the
approval of Caltrans. This measure is not currently included in the East of 101
Traffic
Impact Fee list.
Provide an additional lane on northbound Dubuque Avenue extending from the
freeway ramps to Oyster Point Boulevard. Stripe the five-lane approach to Oyster
Point as two lefts, one through and two right turn lanes.
On the Oyster Point Boulevard overpass of the U.S.101 freeway, reconfigure the
westbound lanes on the approach to Airport Boulevard to have one combined
through /right turn lane, one through lane and one exclusive left turn lane
extending the full length between Dubuque Avenue and Oyster Point Boulevard. In
conjunction with this measure, have both eastbound left turn lanes on the approach
to Dubuque Avenue-Northbound On-Ramp extend he full length between Airport
Boulevard and Dubuque Avenue.
Adjust signal timing.
Finding IV.M-4B: AM Peak Hour: The proposed mitigation will provide additional
capacity and reduce delay, which will eliminate the 95th percentile northbound off-
ramp queue extending to the freeway mainline. These measures would also
eliminate the 95th percentile southbound off-rarrip queue on the approach to
Airport Boulevard extending to the freeway mainline. It should be noted that
because the improvement is within Caltrans' jurisdiction, the City of South San
Exhibit B
Statement of Overriding Considerations
Page 9 of 23
Francisco, as lead agency for the project, cannot guarantee that the mitigation will
be implemented While it is likelly that Caltrans will implement the measure, thereby
reducing the impact to a less than significant level, because the measure is beyond
the lead agency's jurisdiction, for CEQA purposes, this impact is considered to be
significant and unavoidable.
Impact IV.M-5A: The following; discussion concerns U.S.101 Southbound Flyover
Off-Ramp to Oyster Point Boulevard /Gateway Boulevard Intersection. AM Peak
Hour: The project would increase off-ramp volumes by 6.9 percent (from 2,099 up
to 2,243 vehicles) with Base Case volumes already exceeding 1,500 vehicles per
hour. This is considered a potentially significant impact. Even with implementation
of Mitigation Measure IV.M-5A, this impact would remain significant and
unavoidable.
Mitigation Measure IV.M-5A 2015 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Southbound Flyover Off-Ramp to Oyster Point Boulevard /
Gateway Boulevard Intersection
No improvements are feasible ~to mitigate project specific impacts. The spacing of
southbound off-ramp connections to Airport Boulevard and to Oyster Point
Boulevard precludes the possibility of providing a second off-ramp lane connection
to southbound U.S.101 to serve the Oyster Point Boulevard southbound off-ramp. A
second off-ramp lane connection would require a long (i.e., 1,000-foot or longer)
deceleration lane, however, due to existing development in the area, only 300 feet of
space is available. There is no room for provision of this lane. Without feasible
measures to mitigate this impaict, the impact would be considered significant and
unavoidable.
Finding IV.M-5A: As noted above, there are no feasible mitigation measures that
reduce this impact to a level of'less-than-significant. As the mitigation of this impact
is not feasible, this impact would be considered significant and unavoidable.
Impact IV.M-5B: The following discussion concerns U.S.101 Northbound Off-Ramp
to Dubuque Avenue Intersection. During the AM peak hour, the project would
increase off-ramp volumes by 3.3 percent (from 1,507 up to 1,556 vehicles) with
Base Case volumes already exceeding 1,500 vehicles per hour. This is considered a
potentially significant impact, Even with implementation of Mitigation Measure
IV.M-5B, this impact would remain significant and unavoidable.
Exhibit B
Statement of Overriding Considerations
Page 10 of 23
Mitigation Measure IV.M-5B x:015 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Northbound Off-Ramp to Dubuque Avenue Intersection
see Figure IV.M-20)
The project should provide a fair share contribution as determined by the City
Engineer to the following measure.
Provide a second off-ramp lane connection to the U.S.101 mainline. Off-ramp
diverge capacity would be increased to at least 2,200 vehicles per hour, which
would accommodate the Base Case + project AM peak hour volume of 1,556 vehicles
per hour.
Finding IV.M-5B: This measure will require the approval of Caltrans. Also, this
measure is currently not included in the East of 101 Traffic Impact Fee list. It should
be noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented. While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agE~ncy's jurisdiction, for CEQA purposes, this impact is
considered t0 be significant and unavoidable.
Impact IV.M-6A: The following discussion concerns U.S. 101 Northbound On-Ramp
from the Oyster Point Boulevard /Dubuque Avenue Intersection. During the PM
peak hour, the project would increase on-ramp volumes by 6.2 percent (from 2,366
up to 2,513
vehicles) with Base Case volunnes already exceeding 2,200 vehicles per hour. This is
considered a potentially significant impact. Even with implementation of Mitigation
Measure IV.M-6A, this impact would remain significant and unavoidable.
Mitigation Measure IV.M-6A 2015 On-Ramp Operation to U.S.101 Mainline at
U.S.101 Northbound On-Ramp from Oyster Point Boulevard
The project should provide a fair share contribution as determined by the City
Engineer to the following measure. Provide a second on-ramp lane connection to the
U.S.101 mainline. On-ramp capacity would be increased to at least 3,000 vehicles
per hour, which would accommodate the Base Case + project PM peak hour volume
of 2,513 vehicles per hour.
Exhibit B
Statement of Overriding Considerations
Page 11 of 23
Finding Impact IV.M-6A: This measure will require the approval of Caltrans. Also,
this measure is currently not included on the East of 101 Traffic Impact Fee list. It
should be noted that because the improvement is within Caltrans' jurisdiction, the
City of South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant acid unavoidable.
Impact IV.M-6B: The following; discussion concerns U.S. 101 Southbound On-Ramp
from Dubuque Avenue. During the PM peak hour, the project would increase on-
ramp volumes by 6.9 percent (iFrom 1,901 up to 2,032 vehicles) and increase Base
Case volumes above the 2,000 vehicle/hour capacity limit. This is considered a
potentially significant impact. I?ven with implementation of Mitigation Measure
IV.M-6B, this impact would remain significant and unavoidable.
Mitigation Measure IV.M-6B ~On-Ramp Operation to U.S.101 Mainline at
U.S.101 Southbound On-Ramp from Dubuque Avenue
The project should provide a fair share contribution as determined by the City
Engineer to the following measure. Provide a second on-ramp lane connection to the
U.S.101 mainline. On-ramp capacity would be increased to at least 3,000 vehicles
per hour, which would accomnnodate the Base Case + Project PM peak hour volume
of 2,032 vehicles..
Finding IV.M-6B: This measure will require the approval of Caltrans. Also, this
measure is currently not included on the East of 101 Traffic Impact Fee list. It should
be noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead a€;ency for the project, cannot guarantee that the
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable
Impact IV.M-7A: The following discussion concerns U.S.101 Southbound (to the
north of the Oyster Point interchange). During the AM peak hour, the project would
increase volumes by 1.5 percent (from 9,331 to 9,475 vehicles per hour) at a
location where acceptable LO> E year 2015 Base Case operation would be degraded
to unacceptable LOS F operation. This is considered a potentially significant impact.
Exhibit B
Statement of Overriding Considerations
Page 12 of 23
Even with implementation of Mitigation Measure IV.M-7A, this impact would remain
significant and unavoidable.
Mitigation Measure IV.M-7A :? 015 Freeway Mainline Operation at U.S.101
Southbound (North of the Oyster Point Boulevard interchange)
Mitigation of this impact would. require widening the current freeway or
construction of a new freeway. Given the location of the mainline freeway and its
close proximity to surrounding development, such mitigation is not feasible.
Additionally, such mitigation would be prohibitively expensive in relation to the
types of land uses it would benefit. Given these specific concerns, mitigation of
Impact 7A is not feasible as defined by CEQA. (See Pub. Resources Code §21061.1
defining "feasible" as "capable of being accomplished...taking into account
economic...and technological factors.").)
Finding IV.M-7A: As noted above, the mitigation measure is not feasible and would
be prohibitively expensive in relation to the types of land uses it would benefit.
Under
CEQA, the City in this matter has an obligation to balance public objectives,
including specific economic concerns, against the benefits of the project. (See Pub.
Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021. subd. (d).) Where
economic concerns render a particular mitigation measure infeasible, the lead
agency may reject the measure. (See Pub. Resources Code §21081. subd. (a)(3).)
Impact IV.M-7B: The following discussion concerns U.S.101 Northbound (to the
north of the Oyster Point interchange). During the PM peak hour, the project 10,162
vehicles per hour) at a location with unacceptable LOS F year 2015 Base Case
operation. This is considered a potentially significant impact. Even with
implementation of Mitigation Pvleasure IV.M-7B, this impact would remain
significant and unavoidable.
Mitigation Measure IV.M-7B 2015 Freeway Mainline Operation at U.S.101
Northbound (North of the Oyster Point Boulevard interchange) Mitigation of
this impact would require widening the current freeway or construction of a new
freeway. Given the location of the mainline freeway and its close proximity to
surrounding development, such mitigation is not feasible. Additionally, such
mitigation would be prohibitively expensive in relation to the types of land uses it
would benefit. Given these specific concerns, mitigation of Impact 7B is not feasible
Exhibit B
Statement of Overriding Considerations
Page 13 of 23
as defined by CEQA. (See Pub. Resources Code §21061.1 (defining "feasible" as
capable of being accomplished...taking into account economic...and technological
factors.").) Under CEQA, the City in this matter has an obligation to balance public
objectives, including specific economic concerns, against the benefits of the project.
See Pub. Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021. subd.
d).) Where economic concern<,~ render a particular mitigation measure infeasible,
the lead agency may reject the measure. (See Pub. Resources Code §21081. subd.
a) (3).)
Finding IV.M-7B: As noted above, the mitigation measure is not feasible and would
be prohibitively expensive in relation to the types of land uses it would benefit.
Under
CEQA, the City in this matter has an obligation to balance public objectives,
including specific economic concerns, against the benefits of the project. (See Pub.
Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021. subd. (d).) Where
economic concerns render a particular mitigation measure infeasible, the lead
agency may reject the measure. (See Pub. Resources Code §21081. subd. (a)(3).)
Impact IV.M-9F: The following; discussion concerns Oyster Point Boulevard /
Dubuque Avenue / U.S. 101 Northbound On-Ramp. During the PM peak hour, the
project would increase volumes by 6.7 percent at a location with unacceptable LOS F
Base Case operation (resultant: operation would be LOS F-254 seconds control
delay). This is considered a potentially significant impact. Even with implementation
of Mitigation Measure IV.M-9F, this impact would remain significant and
unavoidable.
Mitigation Measure IV.M-9F 2035 Intersection Level of Service Oyster Point
Boulevard /Dubuque Avenuie / U.S.101 Northbound On-Ramp Intersection
see Figure IV.M-22 and Table IV.M-25)
See Mitigation Measure IV.M-2D. In light of economic, environmental, and
technological concerns, there are no other financially feasible measures (as
identified by the Public Works Department) that would provide any increased
capacity. Provision of additional lanes on any of the intersection approaches would
require either widening of bridge structures across the U.S. 101 freeway and/or the
Caltrain rail line and possibly Broadway diversion around the supports for the
Southbound Flyover off-ramp.
Exhibit B
Statement of Overriding Considerations
Page 14 of 23
Finding IV.M-9F: PM Peak Hour: The proposed mitigation will provide additional
capacity and reduce delay, which will improve operation to LOS F-223 seconds
control delay, which is not better than Base Case operation (LOS F-196 seconds
control delay). However, as noted above, additional mitigation measures are not
feasible and would be prohibitively expensive in relation to the types of land uses
they would benefit. Under CEQ,~1, the City in this matter has an obligation to balance
public objectives, including specific economic concerns, against the benefits of the
project. (See Pub. Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021.
subd. (d).) Where economic concerns render a particular mitigation measure
infeasible, the lead agency may reject the measure. (See Pub. Resources Code
21081. subd. (a)(3).)
Impact IV.M-10A: The following discussion concerns Oyster Point Boulevard /
Dubuque Avenue / U.S.101 Northbound On-Ramp Intersection. During the AM peak
hour, the project would increase volumes by 7.2 percent in the through lanes on the
eastbound Oyster Point intersection approach where 95th percentile Base Case
queuing would already extend beyond available storage. In addition, the project
would increase volumes by 5.0 percent in the Dubuque Avenue northbound right
turn lane, where Base Case 95t~1 percentile queues would already be exceeding
available storage. During the P:M peak hour, the project would increase volumes by
11.0 percent in the right turn lane on the westbound Oyster Point Boulevard
intersection approach, where 95th percentile Base Case queuing would already
extend beyond available stora€;e; and by 11.2 percent in the left turn lane on the
westbound Oyster Point Boulevard intersection approach, where 95th percentile
Base Case queuing would already extend beyond available storage. This is
considered a potentially significant impact. Even with implementation of Mitigation
Measure IV.M-10A, this impact. would remain significant and unavoidable.
Mitigation Measure IV.M-10A 2035 Vehicle Queuing - Synchro Evaluation at
Oyster Point Boulevard /Dubuque Avenue / U.S.101 Northbound On-Ramp
Intersection (see Figure IV.NI-22)
Same mitigations as for level of service (Mitigation Measure IV.M-9F). In light of
that would provide any increased capacity. Provision of additional lanes on any of
the intersection approaches would require either widening of bridge structures
across the U.S.101 freeway and/or the Caltrain rail line and possibly roadway
diversion around the supports for the Southbound Flyover off-ramp. Resultant
Operation: AM Peak Hour:
Eastbound Approach Through Movement =The proposed mitigation will provide
additional capacity and reduces delay, which would reduce 95th percentile queuing
Exhibit B
Statement of Overriding Considerations
Page 15 of 23
to 432 feet, which would be bei:ter than Base Case queuing of 444 feet. Impact
reduced to a less than significant level.
Northbound Right Turn =The proposed mitigation will provide additional capacity
and reduce delay, which would reduce 95th percentile queuing to 336 feet, which is
longer than Base Case 308-foot: queue. Impact would not be reduced to a less than
significant level. PM Peak Hour:
Westbound Approach Right Turn: The proposed mitigation will provide additional
capacity and reduce delay, which would reduce 95th percentile queuing to 2,095
feet, which is longer than Base Case queuing of 1,892 feet. Impact would not be
reduced to a less than significant level.
Westbound Approach Left Turn: The proposed mitigation will provide additional
capacity and economic, environmental, and technological concerns, there are no
other feasible measures reducE~ delay, which would reduce 95th percentile queuing
to 1,396 feet, which is longer than Base Case queuing of 1,270 feet. impact would
not be reduced to a less than significant level.
Finding IV.M-10A: As noted above, even with implementation of Mitigation
Measure IV.M-10A, this impact: would remain significant and unavoidable. In light
of economic, environmental, and technological concerns, there are no other feasible
measures that would provide any increased capacity beyond those recommended
for 2015 conditions that would reduce 95th percentile queues within available off-
ramp storage.
Impact IV.M-11A: The following discussion concerns U.S.101 Southbound Flyover
Off-Ramp to Oyster Point Boulevard /Gateway Boulevard Intersection. During the
AM peak hour, the project would increase off-ramp volumes by 8.7 percent, with
year 2035 Base Case off-ramp traffic backing up to the freeway mainline. This is
considered a potentially significant impact. Even with implementation of Mitigation
Measure IV.M-11A, this impact: would remain significant and unavoidable.
Mitigation Measure IV.M-11A 2035 Off-Ramp Queuing to Freeway Mainline -
SIM Traffic Evaluation at U.S.101 Southbound Flyover Off-Ramp to Oyster
Point Boulevard /Gateway Ioulevard Intersection
In light of economic, environmental, and technological concerns, there are no other
feasible measures that would provide any increased capacity beyond those
recommended for 2015 conditions that would reduce 95th percentile queues within
available off-ramp storage. Provision of additional lanes would potentially require
Exhibit B
Statement of Overriding Considerations
Page 16 of 23
acquisition of additional righty-~of-way along Oyster Point Boulevard. Also, provision
of additional eastbound lanes on the Oyster Point and Flyover offramp intersection
approaches would not be feasible due to the complexity of merging the departure
lanes on the eastbound (departure leg) of the intersection.
Finding IV.M-11A: In light of economic, environmental, and technological concerns,
there are no other feasible measures that would provide any increased capacity
beyond those recommended for 2015 conditions that would reduce 95th percentile
queues within available off-ramp storage. Even with implementation of Mitigation
Measure IV.M-11A, this impact would remain significant and unavoidable.
Impact IV.M-11B: The following discussion concerns U.S.101 Northbound Off-
Ramp to Dubuque Avenue Intersection. During the AM peak hour, the project would
increase off-ramp volumes by 3.0 percent, with year 2035 Base Case off-ramp traffic
occasionally backing up to the :Freeway mainline. This is considered a potentially
significant impact. Even with implementation of Mitigation Measure IV.M-11B, this
impact would remain significant and unavoidable.
Mitigation Measure IV.M-11I3 2035 Off-Ramp Queuing to Freeway Mainline -
SIM Traffic Evaluation at U.S.101 Northbound Off-Ramp to Dubuque Avenue
Intersection
There are no other feasible signal timing or lane addition measures as identified by
the Public Works Department beyond those recommended for 2015 conditions that
would reduce 95th percentile ,AM peak hour queues within available off-ramp
storage
Finding IV.M-11B: Even with implementation of Mitigation Measure IV.M-11B, this
impact would remain significant and unavoidable.
Impact IV.M-12A: The following discussion concerns U.S.101 Southbound Flyover
Off-Ramp to Oyster Point Boulevard /Gateway Boulevard Intersection. During the
AM peak hour, the project would increase off-ramp volumes by 8.7 percent (from
2,035 up to 3,161 vehicles) with Base Case volumes already exceeding 1,500
vehicles per hour. This is considered a potentially significant impact. Even with
implementation of Mitigation Measure IV.M-12A, this impact would remain
significant and unavoidable.
Exhibit B
Statement of Overriding Considerations
Page 17 of 23
Mitigation Measure IV.M-1212035 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Southbound Flyover Off-Ramp to Oyster Point Boulevard /
Gateway Boulevard Intersecttion
No improvements are feasible ~to mitigate project specific impacts. The spacing of
southbound off-ramp connections to Airport Boulevard and to Oyster Point
Boulevard precludes the possibility of providing a second off-ramp lane connection
to southbound U.S.101 to servE~ the Oyster Point Boulevard southbound off-ramp. A
second off-ramp lane connection to the freeway mainline would require a long
1,000-foot or longer) deceleration lane with only 300 feet of available space. There
is no room for provision of this; lane.
Finding IV.M-12A: No improvements are feasible to mitigate project specific
impacts. The spacing of southbound off-ramp connections to Airport Boulevard and
to Oyster Point Boulevard prec;ludes the possibility of providing a second off-ramp
lane connection to southbound U.S.101 to serve the Oyster Point Boulevard
southbound off-ramp. A second off-ramp lane connection to the freeway mainline
would require a long (1,000-foot or longer) deceleration lane with only 300 feet of
available space. There is no room for provision of this lane. Even with
implementation of Mitigation rvleasure IV.M-12A, this impact would remain
significant and unavoidable.
Impact IV.M-12B: The following discussion concerns U.S.101 Northbound Off-
Ramp to Dubuque Avenue Intersection. During the AM peak hour, the project would
increase off-ramp volumes by 3.0 percent (from 1,680 to 1,730 vehicles) with Base
Case volumes already exceeding 1,500 vehicles per hour. This is considered a
potentially significant impact. Even with implementation of Mitigation Measure
IV.M-12B, this impact would rf~main significant and unavoidable
Mitigation Measure IV.M-12B 2035 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Northbound Off-Ramp to Dubuque Avenue Intersection
see Figure IV.M-22)
Same mitigation as for 2015. (.Add a second off-ramp lane connection to the U.S.101
mainline.) Off-ramp diverge capacity would be increased to at least 2,300 vehicles
per hour, which would accommodate the Base Case + project volume of 1,730
vehicles per hour. This measure will require the approval of Caltrans. It should be
noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
Exhibit B
Statement of Overriding Considerations
Page 18 of 23
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agE~ncy's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable.
Finding IV.M-12B: This measure will require the approval of Caltrans. It should be
noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable.
Impact IV.M-12C: The following discussion concerns U.S.101 Northbound Off-Ramp
to East Grand Avenue/ Executive Drive Intersection. During the AM peak hour, the
project would increase off-rarr~p volumes by 9.8 percent (from 2,897 up to 3,180
vehicles) at a location where the two-lane off-ramp diverge capacity would be 2,300
vehicles per hour. This is considered a potentially significant impact. Even with
implementation of Mitigation rvleasure IV.M-12C, this impact would remain
significant and unavoidable.
Mitigation Measure IV.M-121„ 2035 Off-Ramp Operation at U.S.101 Mainline
Diverge at U.S.101 Northbound Off-Ramp to East Grand Avenue /Executive
Drive Intersection
Provide a second off-ramp lame connection to the U.S. 101 freeway mainline. The
required improvements are contemplated in and funded in the City's East of 101
traffic program, and by paying the City's East of 101 traffic fee, the project
proponent will be funding its fair share of the required improvements. Planned
provision of a second off-ramp would increase diverge capacity to 2,200 to 2,300
vehicles per hour. This could accommodate the project off-ramp volume of about
2,284 vehicles per hour.
Finding IV.M-12C: The identiiFied measure would increase capacity, thereby
reducing the impact, though the impact would not be reduced to a less-than-
significantlevel. Given the roadway geometry, there are no additional physical
measures that could feasibly be implemented and which would be capable of
Exhibit B
Statement of Overriding Considerations
Page 19 of 23
increasing capacity. Even with implementation of Mitigation Measure IV.M-12C, this
impact would remain significant and unavoidable.
Impact IV.M-13A: The following discussion concerns U.S.101 Southbound One-Lane
On-Ramp from Dubuque Avenue. During the PM peak hour, the project would
increase on-ramp volumes by 9.5 percent at a location where Base Case volumes
would already be exceeding the ramp capacity limit of 2,000 vehicles per hour (up
to 2,381 vehicles per hour). This is considered a potentially significant impact. Even
with implementation of Mitigattion Measure IV.M-13A, this impact
Mitigation Measure IV.M-13A 2035 On-Ramp Operation to U.S. 101 Mainline at
U.S.101 Southbound On-Ramp from Dubuque Avenue (see Figure IV.M-22)
The project should provide a fair share contribution as determined by the City
Engineer to the following measure. Provide a second on-ramp lane connection to the
U.S.101 freeway. On-ramp capacity would be increased from 2,000 up to 3,000
vehicles per hour, with a Base Case + project PM peak hour volume of about 2,381
vehicles per hour. This measure will require the approval of Caltrans. It should be
noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing the impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant and unavoidable.
Finding IV.M-13A: This measure will require the approval of Caltrans. It should be
noted that because the improvement is within Caltrans' jurisdiction, the City of
South San Francisco, as lead agency for the project, cannot guarantee that the
mitigation will be implemented While it is likely that Caltrans will implement the
measure, thereby reducing they impact to a less than significant level, because the
measure is beyond the lead agency's jurisdiction, for CEQA purposes, this impact is
considered to be significant a,nd unavoidable.
Impact IV.M-13B: The following discussion concerns U.S.101 Southbound Two-
Lane On-Ramp from Produce Avenue. During the PM peak hour, the project would
increase on-ramp volumes by ~4.7 percent at a location where project traffic would
increase Base
Exhibit B
Statement of Overriding Considerations
Page 20 of 23
Case volumes above atwo-lanE~ on-ramp capacity limit of 3,300 vehicles per hour
from 3,256 up to 3,409 vehicles per hour). This is considered a potentially
significant impact. Even with implementation of Mitigation Measure IV.M-13B, this
impact would remain significant and unavoidable.
Mitigation Measure IV.M-13I3 2035 On-Ramp Operation to U.S. 101 Mainline at
U.S.101 Southbound On-Ramp from Produce Avenue
A second on-ramp lane is already provided at the Produce Avenue on-ramp,
providing a capacity of ±3,300 vehicles per hour. There are no other physical
improvements possible to accommodate the Base Case + project volume of about
3,410 vehicles per hour.
Finding IV.M-13B: Even with implementation of Mitigation Measure IV.M-13B, this
impact would remain signifTCa-nt and unavoidable.
Impact IV.M-13C: The following discussion concerns U.S.101 Northbound One-Lane
On-Ramp from Oyster Point Boulevard. During the PM peak hour, the project would
increase on-ramp volumes by ~~.9 percent at a location where project traffic would
increase Base Case volumes above 2,200 vehicles per hour (from 3,234 up to 3,521
vehicles per hour). This is con:>idered a potentially significant impact. Even with
implementation of Mitigation 1vleasure IV.M-13C, this impact would remain
significant and unavoidable.
Mitigation Measure IV.M-131C 2035 On-Ramp Operation to U.S. 101 Mainline at
U.S.101 Northbound On-Ramp from Oyster Point Boulevard
Provision of a second on-ramp. lane (as recommended for 2015) would increase
capacity to about 3,000 to 3,100 vehicles per hour. This measure will require the
approval of Caltrans. There are no other physical improvements possible acceptable
to Caltrans to
accommodate the Base Case + project volume of about 3,521 vehicles per hour.
Finding IV.M-13C: Even with implementation of Mitigation Measure IV.M-13C, this
impact would remain significant and unavoidable.
Exhibit B
Statement of Overriding Considerations
Page 21 of 23
Impact IV.M-14A: The following discussion concerns U.S.101 Southbound (to the
north of the Oyster Point interc:hange). During the AM peak hour, the project would
increase volumes by 2.4 percent (from 10,381 to 10,633 vehicles per hour) at a
location with unacceptable LO:i F year 2035 Base Case operation. This is considered
a potentially significant impact:. Even with implementation of Mitigation Measure
IV.M-14A, this impact would remain significant and unavoidable.
Mitigation Measure IV.M-14A 2035 Freeway Mainline Operation at U.S.101
Southbound (North of the Oyster Point Boulevard interchange)
Mitigation of this impact would require widening the current freeway or
construction of a new freeway. Given the location of the mainline freeway and its
close proximity to surroundin€; development, such mitigation is not feasible.
Additionally, such mitigation ~n~ould be prohibitively expensive in relation to the
types of land uses it would benefit. Given these specific concerns, mitigation of
Impact 14A is not feasible as defined by CEQA. (See Pub. Resources Code §21061.1
defining "feasible" as "capablE~ of being accomplished...takingfnto account
economic...and technological factors.").) Under CEQA, the City in this matter has an
obligation to balance public objectives, including specific economic concerns,
against the benefits of the project. (See Pub. Resources Code §21081. subd. (a)(3);
CEQA Guidelines, §15021. subd. (d).) Where economic concerns render a particular
mitigation measure infeasible, the lead agency may reject the measure. (See Pub.
Resources Code §21081. subd. (a)(3).)
Finding IV.M-14A: As noted above, the mitigation measure is not feasible and
would be prohibitively expensive in relation to the types of land uses it would
benefit. Under
CEQA, the City in this matter has an obligation to balance public objectives,
including specific economic concerns, against the benefits of the project. (See Pub.
Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021. subd. (d).) Where
economic concerns render a particular mitigation measure infeasible, the lead
agency may reject the measure. (See Pub. Resources Code §21081. subd. (a)(3).)
Impact IV.M-14B: The following discussion concerns U.S.101 Northbound (to the
north of the Oyster Point interchange). During the PM peak hour, the project would
increase volumes by 2.6 percent (from 11,220 to 11,510 vehicles per hour) at a
location with unacceptable LOS F year 2035 Base Case operation. This is considered
a potentially significant impact. Even with implementation of Mitigation Measure
IV.M-14B, this impact would remain significant and unavoidable.
Exhibit B
Statement of Overriding Considerations
Page 22 of 23
Mitigation Measure IV.M-14B'~ 2035 Freeway Mainline Operation at U.S.101
Northbound (North of the Oyster Point Boulevard interchange)
Mitigation of this impact would require widening the current freeway or
construction of a new freeway. Given the location of the mainline freeway and its
close proximity to surrounding development, such mitigation is not feasible.
Additionally, such mitigation would be prohibitively expensive in relation to the
types of land uses it would benefit. Given these specific concerns, mitigation of
Impact 14B is not feasible as dE~fined by CEQA. (See Pub. Resources Code §21061.1
defining "feasible" as "capable of being accomplished...takingfnto account
economic...and technological factors.").) under CEQA, the City in this matter has an
obligation to balance public objectives, including specific economic concerns,
against the benefits of the project. (See Pub. Resources Code §21081. subd. (a)(3);
CEQA Guidelines, §15021. subd. (d).) Where economic concerns render a particular
mitigation measure infeasible, the lead agency may reject the measure. (See Pub.
Resources Code §21081. subd. (a)(3).)
Finding IV.M-14B: As noted above, the mitigation measure is not feasible and
would be prohibitively expensiive in relation to the types of land uses it would
benefit. Under
CEQA, the City in this matter has an obligation to balance public objectives,
including specific economic concerns, against the benefits of the project. (See Pub.
Resources Code §21081. subd. (a)(3); CEQA Guidelines, §15021. subd. (d).) Where
economic concerns render a particular mitigation measure infeasible, the lead
agency may reject the measure. (See Pub. Resources Code §21081. subd. (a)(3).)
3. Overriding Considerations. The City Council now balances the
unavoidable impacts that apply to the development of the Gateway Business Park
Master Plan, against its benefits, and hereby determines that such unavoidable
impacts are outweighed by thE~ benefits of the Project, as further set forth below.
The following specific economic, legal, social, technological, land use, and
other considerations support approval of the Project:
A. The Project is expected to generate a new source of significant
tax revenue and development impact fees for City of approximately $50,000,000
Additionally, at full build out,l:he Project is expected to employ an additional
Exhibit B
Statement of Overriding Considerations
Page 23 of 23
2,531employees by 2020. Many of these new positions will be filled by residents of
local communities.
B. The existing physical environment consists primarily of
industrial development, with limited sidewalks and minimal site improvements, and
which lacks amenities. The Project will convert the property to uses consistent with
the campus oriented research ~u development uses, including additional amenities
and improvements. The proposed Project will be built to the Leadership in Energy
and Environmental Design (LE'.ED) Green Building Rating System standard and also
provide landscaping and lighting for the property and improve the overall aesthetic
character of the site.
C. The Project is consistent with the General Plan Guiding Policies
for the East of 101 Area, which provide appropriate settings for a diverse range of
non-residential uses (3.5-G-1) ;and promotes high-technology, and research and
development uses (3.5-G-3).
D. The Project is consistent with General Plan Implementing
Policies, which generally promote research & development uses, to the exclusion of
residential and more traditional industrial uses. (See 3.5-I-3, 3.5-I-11.).
E. The Project is designed to take advantage of and promote the
use of public transit by adopting a Transportation Demand Management Plan that
provides incentives for employees to use alternative modes of transportation,
promotes parking cash-out incentives, and uses a lower parking ratio to increase
ridership on BART and the East of 101 shuttle service, as well as constructing
pedestrian walkways linking the Project to the adjacent shuttle stops and bikepaths.
1364468.2
Exhibit C
Mitigation Monitoring and Reporting Program
Included in Final Environmental Impact Report
Gateway Business Park Master Plan
Final Environmental Impact Report
GATEWAY OF THE PACIFIC 4 DENSITY TRANSFER
PROJECT, CITY OF SOUTH SAN FRANCISCO
Supplemental Environmental Impact Report
SCH# 2008062059
Prepared for January 2022
City of South San Francisco
GATEWAY OF THE PACIFIC 4 DENSITY TRANSFER
PROJECT, CITY OF SOUTH SAN FRANCISCO
Supplemental Environmental Impact Report
SCH# 2008062059
Prepared for January 2022
City of South San Francisco
315 Maple Avenue
South San Francisco, California 94080
550 Kearny Street
Suite 800
San Francisco, CA 94108
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D202101143
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Gateway of the Pacific 4 Density Transfer Project i ESA / D202101143
City of South San Francisco January 2022
TABLE OF CONTENTS
Gateway of the Pacific 4 Density Transfer
Project
Supplemental Environmental Impact Report
Page
Summary .............................................................................................................................S-1
Chapter 1, Introduction ...................................................................................................... 1-1
1.1 Background ....................................................................................................... 1-2
1.2 CEQA Context ................................................................................................... 1-2
1.3 Purpose and Use of this EIR ............................................................................. 1-3
1.4 CEQA Environmental Review ............................................................................ 1-4
1.5 Document Organization ..................................................................................... 1-6
Chapter 2, Project Description .......................................................................................... 2-1
2.1 Introduction ........................................................................................................ 2-1
2.2 Project Location ................................................................................................. 2-1
2.3 Project Objectives .............................................................................................. 2-4
2.4 Background ....................................................................................................... 2-4
2.5 Existing Conditions ............................................................................................ 2-5
2.6 Project Characteristics ....................................................................................... 2-6
2.7 Open Space ..................................................................................................... 2-11
2.8 Circulation ........................................................................................................ 2-11
2.9 Utilities ............................................................................................................. 2-14
2.10 Sustainability ................................................................................................... 2-15
2.11 Transportation Demand Management Plan ..................................................... 2-16
2.12 Construction Activities and Schedule ............................................................... 2-17
2.13 Project Approvals and Entitlements ................................................................. 2-18
Chapter 3, Environmental Setting, Impacts, and Mitigation Measures ......................... 3-1
3.0 Introduction to the Analysis ................................................................................ 3-1
3.1 Transportation and Circulation ........................................................................ 3.1-1
3.2 Other Resource Topics ................................................................................... 3.2-1
Chapter 4, Project Alternatives ......................................................................................... 4-1
4.1 Overview ............................................................................................................ 4-1
4.2 Factors in the Selection of Alternatives .............................................................. 4-1
4.3 Alternatives Considered but Dismissed from Further Evaluation ....................... 4-2
4.4 Alternatives Selected for Further Consideration ................................................ 4-4
4.5 Environmentally Superior Alternative ................................................................. 4-6
Chapter 5, Other CEQA Required Considerations .......................................................... 5-1
5.1 Introduction ........................................................................................................ 5-1
5.2 Significant and Unavoidable Adverse Impacts ................................................... 5-1
5.3 Significant Irreversible Environmental Effects .................................................... 5-2
Table of Contents
Page
Gateway of the Pacific 4 Density Transfer Project ii ESA / D202101143
City of South San Francisco January 2022
5.4 Growth-Inducing Effects .................................................................................... 5-3
Chapter 6, List of Preparers and Persons Consulted ..................................................... 6-1
6.1 Report Authors................................................................................................... 6-1
6.2 Persons Consulted ............................................................................................ 6-2
Appendices
A. Notice of Preparation ..................................................................................................A-1
B. NOP Scoping Comment Letters ..................................................................................B-1
C. Vehicle Miles Traveled Analysis................................................................................. C-1
D. Air Quality and Greenhouse Gas Emissions Report .................................................. D-1
E. Water Capacity Study .................................................................................................E-1
Figures
Figure 2-1 Project Location ........................................................................................... 2-2
Figure 2-2 GOP 4 Site .................................................................................................. 2-3
Figure 2-3 GOP 4 Site Plan .......................................................................................... 2-7
Figure 2-4 Approved GOP Massing Diagram ............................................................... 2-9
Figure 2-5 Approved GOP Rendering ......................................................................... 2-10
Figure 2-6 Modified GOP Massing Diagram ............................................................... 2-12
Figure 2-7 Modified GOP Rendering........................................................................... 2-13
Figure 3.1-1 Mitigation Measure Improvements .......................................................... 3.1-16
Tables
Table S-1 Summary of Impacts and Mitigation Measures ..........................................S-10
Table 2-1 GOP Master Plan Amendment .................................................................... 2-8
Table 3.1-1 Home-Based Work Vehicle Miles Traveled Per Employee Thresholds .. 3.1-12
Table 3.1-2 Project VMT Impact Determination ......................................................... 3.1-14
Table 3.2-1 Summary of Operational Emissions – Criteria Air Pollutants .................... 3.2-3
Table 3.2-2 Summary of Operational Emissions – Greenhouse Gas Emissions ......... 3.2-5
Gateway of the Pacific 4 Density Transfer Project S-1 ESA / D202101143
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SUMMARY
SGateway of the Pacific 4 Density Transfer Project
Supplemental Environmental Impact Report
Introduction
The City of South San Francisco has prepared this Draft Supplemental Environmental Impact
Report (SEIR) for the Gateway of the Pacific (GOP) 4 Density Transfer project (“proposed
project”) per the requirements of the California Environmental Quality Act (CEQA) statutes
(Public Resources Code [PRC] Section 21000 et seq.) and the CEQA Guidelines (California Code
of Regulations 15000 et seq.). This Draft SEIR is a supplemental analysis to the certified EIR for
the GOP Master Plan project (SCH #2008062059) and subsequently-prepared Addenda, which
are collectively referenced in this Draft SEIR as the “EIR.” The proposed project is a
modification to the GOP 4 project studied in the most recent Addendum.
This Draft SEIR describes the existing environmental conditions in the vicinity of the GOP 4 site,
located on the GOP Master Plan area south of Oyster Point Boulevard between Gateway
Boulevard and Eccles Avenue, analyzes whether new or more severe significant environmental
impacts will occur due to the proposed project, and identifies mitigation measures that could
avoid or reduce the magnitude of those new or more severe significant impacts. The only
environmental resource topic fully evaluated in the Draft SEIR is transportation, and all other
topics are discussed to the extent warranted to disclose the SEIR’s consistency with the guidance
for preparation of a supplemental environmental analysis (CEQA Guidelines Sections 15163 and
15162). The Draft SEIR considers a reasonable range of alternatives for the proposed project.
This Draft SEIR is subject to review and comment by the public, as well as responsible agencies
and other interested jurisdictions, agencies, and organizations for a minimum of forty-five (45)
days. The public may comment on the Draft SEIR by submitting written comments at any time
during the public review period. The City will prepare a Final SEIR, which will include the
written comments received regarding the Draft SEIR, responses to substantial environmental
issues raised in the comments, and any changes to the Draft SEIR that are required by the
responses to written comments, or that are initiated by staff.
Upon publication of the Draft EIR and release of the Final SEIR, each of these environmental
documents will be made available online to the public at https://weblink.ssf.net, and may be
viewed in printed form at the offices of the City’s Planning Division at 315 Maple Avenue, South
San Francisco, California 94083. A scoping hearing to address the scope of this SEIR was held on
December 6, 2021. Public hearings regarding the proposed project, including its CEQA review,
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will occur at various times, and the City will post public notices and hearing agendas at City Hall
and on its website at www.ssf.net.
City staff responsible for the drafting of the environmental document may be contacted with
questions:
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Avenue
South San Francisco, California 94080
Email: billy.gross@ssf.net
The Final SEIR will be submitted to the City of South San Francisco Planning Commission and
City Council for their consideration. As part of the project review and consideration, the City,
prior to approving the project, is required under CEQA to certify that the SEIR has been prepared
in compliance with CEQA, and would also consider adoption of Findings of Fact pertaining to
this SEIR, specific mitigation measures, a Statement of Overriding Considerations relating to any
identified significant and unavoidable effects, and a Mitigation Monitoring Plan.
Project Description
Project Location
The GOP 4 site is located in the City of South San Francisco, approximately 1.5 miles north of
San Francisco International Airport (SFO) and approximately 10 miles south of downtown San
Francisco. The City of South San Francisco is located on the San Francisco Bay plain and the
northern foothills of the Coastal range. The City is located along major transportation routes
including US 101, Interstate 380 (“I-380”), Interstate 280 (“I-280”), and the Union Pacific
Railroad (see Figure 2-1, Project Location).
The GOP 4 project is the fourth phase of the GOP Master Plan project, which is located within
the larger Gateway Specific Plan area and East of 101 Sub-area. The GOP Master Plan area
consists of approximately 23 acres of land and is bounded by Oyster Point Boulevard on the
north, Gateway Boulevard on the west, a narrow band of vacant land to the east, and a hotel to the
south. The GOP Master Plan area is developed with office, warehousing and research and
development (“R&D”) uses.
The GOP 4 site itself is 4.8 acres in size and is generally located in the northeastern portion of the
GOP Master Plan area, south of buildings housing R&D uses located at 180 and 200 Oyster Point
Boulevard, which are located outside the GOP Master Plan area. The site is presently developed
with two one-story buildings, a Federal Express (FedEx) distribution center (900 Gateway
Boulevard) totaling 50,000 sf and an abandoned office building (850 Gateway Boulevard)
totaling approximately 19,300 sf (see Figure 2-2, GOP 4 Site).
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Background
In February 2010, the City certified an EIR, adopted certain findings under CEQA, and approved
the Gateway Business Park Master Plan project and a Precise Plan for Phase 1. Other approvals
included related General Plan and zoning changes, and a Development Agreement. Specifically,
the environmental effects of the project were analyzed in the EIR (State Clearinghouse Number
2008062059) that was certified on February 10, 2010 (City Council Resolution 18-2010)(“2010
EIR”). In addition, a Mitigation Monitoring and Reporting Program (“MMRP”) and a statement
of overriding considerations for the project were adopted at the same time. The master plan
project involved the phased removal and replacement of existing buildings on the 22.6-acre site,
construction of five to six new buildings, and construction of two to four parking structures, in up
to five phases. The plan would have developed the site with a Floor Area Ratio (FAR) of 1.25,
which would have resulted in approximately 1,230,570 square feet (sf) of building space.
In April 2013, the City approved modifications to the Gateway Business Park Master Plan project
and the Precise Plan for Phase 1 (City Council Resolution 44-2013). The City found that the
modifications were within the scope of the 2010 EIR and re-certified that EIR (City Council
Resolution 43-2013). As it considered the modifications to that project, the City re-adopted the
CEQA findings, the MMRP and the statement of overriding considerations. The modifications
included more flexibility in phasing, a new amenity building in Phase 1, a First Amendment to
the Development Agreement, and minor changes to on-site circulation. The overall development
standards and FAR of 1.25 did not change. These modifications were reflected in a revised
Master Plan, which was renamed as the GOP Master Plan, and a revised Precise Plan for GOP 1.
Phase 1 has since been constructed.
In July 2018, the City approved a Second Amended and Restated Development Agreement
(“Second Amendment”) (Ordinance No. 1559-2018). The Second Amendment recognizes a lot
line adjustment that had previously adjusted the property line between Phases 1 and 2, recognized
the current ownership of the various parcels that comprise the GOP Master Plan area, allocated
responsibility for compliance with the conditions of approval and mitigation measures separately
among each phase, and clarified that the requirement for a replacement childcare facility on the
site be triggered upon occupation of 750,000 sf of gross floor area within the GOP Master Plan
area. The City determined that no additional environmental review was required for the Second
Amendment.
In December 2018, the City approved Precise Plans for Phases 2 and 3 of the GOP Master Plan
project (Planning Commission Resolution 2835-2018). The Planning Commission determined
that Phases 2 and 3 were within the scope of the 2010 EIR and adopted an Addendum (Planning
Commission Resolution 2834-2018) (“2018 Addendum”) to the previous analysis. The Precise
Plans provided detailed development plans that implemented the already-approved GOP Master
Plan project. Phases 2 and 3 are currently under construction.
In July 2020, the City approved a Precise Plan for Phase 4 of the GOP Master Plan project, as
well as a Use Permit for the adjacent project at 475 Eccles Avenue to the west, which is now
known as GOP 5 (Planning Commission Resolution No. 2859-2020 and City Council Resolution
No. 119-2020). The Precise Plan for the GOP 4 project provided detailed development plans that
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implemented the already-approved GOP Master Plan project. The GOP 4 project included two
five-story buildings with R&D uses totaling 226,000 sf and a six-story parking structure, with a
partial floor on the sixth level, in the northeastern portion of the GOP Master Plan area. The
Planning Commission determined that Phase 4 was within the scope of the 2010 EIR and 2018
Addendum, and adopted another Addendum (Planning Commission Resolution No. 2858-2020)
(“2020 Addendum”) to the previous analysis. Construction of GOP 4 has not commenced.
The Use Permit for the GOP 5 project integrated the adjacent project at 475 Eccles Avenue into a
campus that would include both the GOP Master Plan and GOP 5 projects. The GOP 5 project
includes the site of some former rail spurs that previously separated the GOP Master Plan area
from the 475 Eccles site, which will be converted into a publicly-accessible multi-use path
connecting Oyster Point Boulevard with Forbes Boulevard, and providing pedestrian connections
within the campus.
Project Characteristics
Previously Approved Project
As discussed above, the approved GOP 4 project included two five-story buildings totaling
226,000 sf and a five-story parking structure. One building would be located on the northern
portion of the site and the other building would be located on the southern portion of the site with
the parking structure located to the east (see Figure 2-3, GOP 4 Site Plan). Both the northern and
southern buildings were approximately the same size with each totaling about 113,000 sf. The
two structures were also each 98 feet above the average level of the highest and lowest points on
the lot. A total of 531 parking spaces would be provided in a six-level parking structure (five full
floors and a partial level on the sixth floor). The massing and height of the approved structures
are shown in Figure 2-4, Approved GOP Massing Diagram, and Figure 2-5, Approved GOP
Rendering. The project would have employed approximately 603 workers. The envelope of the
buildings consisted of a high-quality curtain-wall system with energy-efficient glazing and
accents of metal panels, wood and concrete.
Modified Project
The site of the former rail spurs on the GOP 5 site is 2.76 acres or 120,221 sf in size. Based on an
allowed FAR of 1.0 for R&D establishments permitted by the City’s General Plan, a total of
120,221 sf of R&D use could be developed on this portion of the GOP 5 site. The proposed GOP
4 Density Transfer project would transfer this space from the GOP 5 site to the GOP 4 site. The
developable space would be added to the northern building on the GOP 4 site as four additional
floors. The portion of the GOP 5 site encompassing the rail spurs would then be deed restricted to
not allow any of the density transferred to GOP 4 site to be constructed on the rail spur property.
The additional space would employ an additional 321 workers. The additional square footage
would be parked at 2 spaces per 1,000 sf, which would be accommodated by adding 2.5 floors to
the previously-approved parking structure; a total of approximately 240 new parking spaces
would be provided.
As revised, the northern building on the GOP 4 site would total nine floors and reach a height of
178 feet above the average level of the highest and lowest points on the lot. The northern
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structure would include about 233,300 sf of space. The height and size of the southern building
would remain the same. The parking structure would also now be eight levels in height and
include 771 parking spaces. The massing and height of the modified structures are shown in
Figure 2-6, Modified GOP Massing Diagram, and Figure 2-7, Modified GOP Rendering.
The approved architectural scheme of the buildings would be extended to the new floors, without
any substantive changes in architecture. The modified GOP 4 project also includes a generator
yard at ground level in the landscaped area on the northwest side of the GOP 4 parking structure.
In exchange for reducing current density at the rail spurs to zero, the overall FAR of the GOP
Master Plan area would increase from 1.25 to 1.37 with the addition of the space associated with
the proposed project.
Areas of Controversy
As required by the state CEQA Guidelines, the scope of this Draft SEIR includes all
environmental issues to be resolved and all areas of controversy relevant to the physical
environment known to the Lead Agency (City of South San Francisco), including those issues
and concerns identified by the City, and by other agencies, organizations, and individuals in
response to the City's Notice of Preparation (NOP) published on November 16, 2021 (see
Appendix A for the NOP and Appendix B for the NOP Comment Letters). Areas of potential
controversy or interest regarding the Project, based on the number of public comments received,
include:
• Vehicle miles traveled per capita associated with the proposed project; and
• Compatibility of the proposed project with the Comprehensive Airport Land Use
Compatibility Plan for the Environs of San Francisco International Airport.
These environmental issues are discussed in Chapter 3, Environmental Setting, Impacts, and
Mitigation Measures.
Environmental Effects
The following discussion provides an overview of the key environmental effects of the proposed
project. At the end of this chapter, Table S-1, Summary of Impacts and Mitigation Measures,
includes a complete summary of all impacts and mitigation measures described in Chapter 3 of
the SEIR.
Transportation
Conflict with a Program, Plan, Ordinance, or Policy Addressing the
Circulation System
The GOP Master Plan project would develop a pedestrian-friendly Central Commons open space
in the area created by the parking structures and the office buildings. The master plan would
enhance public street frontages and foster transit use by providing multiple pedestrian
connections to and from the internal campus and shuttle system stops. The proposed project
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would be compatible with the GOP Master Plan project and the existing GOP 4 Precise Plan.
Therefore, the proposed project would not have a detrimental impact to pedestrian circulation.
Bicycle access to the proposed project is provided via the bicycle lanes on Oyster Point
Boulevard and the bike route on Gateway Boulevard. As part of the GOP 5 project, the existing
rail spur that separates the GOP 4 and 5 sites would be redeveloped into a multi-use trail. This
multi-use trail would provide an additional connection between the Class II bicycle lanes on
Oyster Point Boulevard and the existing multi-use trail on Forbes Boulevard. As a result, the
proposed project would not conflict with existing and planned bicycle facilities.
The proposed project is expected to generate trips via transit services, which can be
accommodated by the existing/planned transit capacity. According to California State Office of
Planning and Research guidelines, the addition of new transit riders should not be treated as an
adverse impact as such development also improves regional flow by adding less vehicle travel
onto the regional network. Therefore, the proposed project would not have a detrimental impact
to transit service.
For the reasons presented above, the proposed project would not conflict with a program, plan,
ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and
pedestrian facilities, and this impact is considered less than significant. No new or substantially
more severe impacts would occur than analyzed in the EIR.
Vehicle Miles Traveled
According to the City of South San Francisco’s vehicle miles traveled (VMT) guidelines, a
significant impact would occur for employment generating projects if the baseline project-
generated home-based work (HBW) VMT per employee is higher than 85 percent of the existing
nine-county Bay Area-Wide average for employee VMT, which is 14.2 under current conditions
and 14.6 under cumulative 2040 conditions. Based on the C/CAG – VTA travel demand model,
the VMT per employee for the proposed project would be 16.2 under existing conditions, which
is above the threshold of 12.1 for existing conditions. Under cumulative 2040 conditions, the
VMT per employee for the proposed project would be 12.9, which is above the threshold of 12.4
for cumulative conditions. Therefore, the proposed project would result in a significant impact
with respect to VMT under existing and cumulative conditions.
Even with the implementation of the actions listed in Mitigation Measure 3.1-1, which include
improvements that support and enable first- and last-mile non-auto commute strategies, this
impact would not be reduced to a less-than-significant level as the effectiveness of these actions
are unknown and may not reduce the project’s HBW VMT below the existing and cumulative
thresholds. Therefore, the project’s effect on VMT would be significant and unavoidable.
Design Hazards
The proposed project would increase the intensity of planned uses on the GOP 4 site, but would
not include the introduction of new land uses or changes to the GOP 4 Precise Plan site design.
A project safety impact is considered significant if the proposed project would provide inadequate
design features that present safety concerns within the project site or on the adjacent streets. The
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proposed project would not alter any design components of the recently approved GOP Phase 4
Precise Plan. Therefore, the proposed project would not substantially increase hazards due to a
geometric design feature or incompatible land uses, and no impact would occur. No new or
substantially more severe impacts would occur than analyzed in the EIR.
Emergency Access
The proposed project would not reroute or change any of the city streets in its vicinity that would
impact emergency vehicle access to the GOP 4 site. Access to GOP 4 site would be provided via
driveways along Oyster Point Boulevard and Gateway Boulevard. Park Street, a new internal
access roadway, would be constructed along the east side of the parking garages and would
connect to Oyster Point Boulevard to the north and Gateway Boulevard to the south. The
emergency vehicles would utilize all entries and supplemental access points as necessary to reach
Park Street and the central pedestrian walkway which would be wide enough to serve as an
emergency vehicle route. Thus, the proposed project would not result in inadequate emergency
access, and this impact is considered less than significant. No new or substantially more severe
impacts would occur than analyzed in the EIR.
All Other Topics
The EIR addressed the remaining environmental topics: aesthetics, agricultural resources, air
quality, biological resources, cultural resources, geology and soils, greenhouse gases and climate
change, hazards and hazardous materials, hydrology and water quality, land use and planning,
mineral resources, noise, population and housing, public services and recreation, and utilities.
With the exception of significant impacts related to construction air quality and noise, and
transportation delay-based impacts that can no longer be considered significant impacts under
CEQA, the EIR determined that GOP Master Plan project would not create significant impacts
with respect to these environmental topics once mitigation was incorporated.
The proposed project would be required to implement mitigation set forth in the MMRP approved
in 2010 and again in 2013. In addition, since the increase in building space associated with the
project is not substantial, significant impacts related to construction air quality and noise would
not increase in severity. There has been no substantial change in surrounding circumstances or
new information with respect to these environmental topics since the City most recently
determined, in 2020, that no such changes had occurred in connection with the GOP 4 Precise
Plan approval. As a result, no new or more severe significant impacts with respect to these
environmental topics are anticipated beyond those anticipated and analyzed in the EIR.
Significant and Unavoidable Environmental Effects
Pursuant to CEQA Guidelines Section 15123(b)(1), an EIR must summarize the impacts and
mitigation measures associated with a proposed project, as well as any significant impacts
following mitigation. This information is detailed in this SEIR in Chapter 3, Environmental
Setting, Impacts, and Mitigation Measures, and is summarized in Table S-1 at the end of this
chapter.
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Throughout this SEIR, certain transportation impacts are identified that would be less than
significant without the need for additional mitigation measures. When impacts are identified
which cannot be eliminated or reduced to a less-than-significant level even with the
implementation of feasible mitigation measures, those impacts are identified as significant and
unavoidable environmental impacts. As discussed above, the proposed project has significant and
unavoidable impacts associated with VMT, both at the project-level and the cumulative level.
Alternatives to the Proposed Project
CEQA Guidelines Section 15126.6 requires that an EIR must present and consider a reasonable
range of alternatives to the proposed project. These alternatives should be able to feasibly achieve
the majority of the basic objectives of the project while avoiding or substantially lessening one or
more of the significant effects of the project. The feasibility of an alternative is determined by the
lead agency and is evaluated based on a variety of factors, which may include site suitability,
economic viability, availability of infrastructure, general plan consistency, other plans or
regulatory limitations, jurisdictional boundaries, and site acquisition and control.
Several alternatives were considered for their potential to reduce the project’s significant VMT
impacts but not carried forward for analysis for several reasons. A reduced height alternative was
considered but not carried forward for analysis as a smaller project does not directly correlate to a
reduced VMT impact because VMT is assessed based on a per-capita or per-employee rate. A
residential land use alternative was considered but not carried forward for analysis as the land use
and zoning designations for the GOP 4 site do not permit residential use, residential use would
not be consistent with existing land uses in the vicinity of the GOP 4 site, and residential use
would be inconsistent with all project objectives. Two alternative locations near an existing
Caltrain station and approximately 0.7 miles from the proposed project’s site were considered but
not carried forward for analysis as the City is considering mixed-use development unrelated to
this project on these parcels as part of the City’s general plan update. In addition, neither of these
alternative sites considered are owned by the project applicant, both sites have existing long-term
leases and tenants, and neither site may be available for purchase or development. Finally, as the
proposed project is an addition to an already approved building, it would be more cost efficient
from a construction perspective, as constructing this space on another site would involve
additional construction phases, such as demolition and site preparation.
For these reasons, there are no feasible alternatives that might feasibly accomplish most of the
project’s basic objectives and avoid or substantially lessen one or more of the significant effects
of the project. Thus, only the no project alternative was considered for further analysis.
No Project Alternative
State CEQA guidelines require consideration of the “No Project” alternative, which evaluates the
impacts associated with not moving forward with the proposed project. Under the No Project
Alternative, as required by CEQA Guidelines Section 15126.6(e), the transfer of density under
the proposed project would not occur, and the approved GOP 4 project would be constructed on
the GOP 4 site.
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Environmentally Superior Alternative
Pursuant to State CEQA Guidelines Section 15126.6, an EIR must identify the environmentally
superior alternative from among the range of alternatives that are evaluated. As the No Project
Alternative was the only alternative carried forward for analysis it is the environmentally superior
alternative, although the project- and cumulative level impacts associated with VMT would
remain the same since the fewer vehicle trips associated with this alternative would not directly
correlate to a reduction in VMT, which is assessed based on a per-capita or per-employee rate.
Summary Table
Table S-1, Summary of Impacts and Mitigation Measures, is structured to correspond with the
environmental issues discussed in Chapter 3. The table is arranged in four columns:
1. New or more severe significant environmental impacts (“Impact”)
2. Level of significance without mitigation (“Significance Before Mitigation”)
3. Mitigation measures (“Mitigation Measure”)
4. Level of significance following implementation of mitigation measures (“Significance After
Mitigation”)
If an impact is determined to be significant or potentially significant, mitigation measures are
identified to reduce the effects of that impact, where appropriate. Multiple mitigation measures
may be required to reduce the impact to a less-than-significant level. This SEIR assumes
compliance with all plans, policies, guidelines, and regulations relevant and applicable to the
proposed project. These actions and the plans, policies, guidelines, and laws upon which they are
based are discussed within the Regulatory Setting and applicable impact analysis of each issue
area.
Summary LTS = less than significant; NA = Not applicable; NI = no impact; PS = potentially significant; S = Significant; SU = significant and unavoidable. Gateway of the Pacific 4 Density Transfer Project S-10 ESA / D202101143 City of South San Francisco January 2022 TABLE S-1 SUMMARY OF IMPACTS AND MITIGATION MEASURES Impact Significance Before Mitigation Mitigation Measure Significance After Mitigation 3.1 Transportation Impact 3.1-1: The proposed project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. LTS None Required. NA Impact 3.1-2: The proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision b) related to VMT. PS Mitigation Measure 3.1-1: First- and Last-Mile Transit Connections and Active Transportation Improvements First- and last-mile transit connections and active transportation improvements are likely to yield the greatest VMT reductions. These measures would not only serve the density transfer project but also the entire GOP Master Plan area and all of the existing and planned development in the area. Thus, the new VMT generated by the project would be partially offset by reductions in VMT for other development. The following mitigation measures support and enable the first-and last-mile non-auto commute strategies in the GOP Master Plan TDM Plan. The mitigation measures described below are appropriate under both existing plus project conditions and cumulative plus project conditions. SU a) The project applicant has acquired the rail spur property adjacent to the GOP 4 site and shall use it to connect the GOP Master Plan area with the 475 Eccles site, which is currently referred to as GOP Phase 5, approved for two office/R&D buildings totaling 262,287 square feet and one parking structure. The applicant proposes to develop the rail spurs into a publicly accessible multi-use path connecting Oyster Point Boulevard with Forbes Boulevard, with pedestrian amenities, all to implement the City’s draft “rails to trails” plan. A grand staircase allowing access from the lower elevation of the GOP Master Plan area to the higher elevation of the 475 Eccles site is also proposed. The applicant shall construct these improvements. This multi-use path shall connect to Class II bicycle lanes on Oyster Point Boulevard and to the multi-use trail on Forbes Boulevard. b) The applicant shall construct crossings at the northern and southern ends of the multi-use path required by paragraph (a) above, at Forbes Boulevard and Oyster Point Boulevard, in the configuration determined necessary by the City Engineer for bicycle access from those streets to the multi-use path. c) The applicant shall use good faith efforts to obtain all approvals and consent required to install the improvements required by paragraphs (a) and (b) above, including the use of any necessary land owned by the applicant or its affiliates. Each improvement shall be constructed by the later of (i) issuance of the first certificate of occupancy for any portion of the 120,221 square-foot expansion in GOP 4, or (ii) such time as public agencies have granted all necessary approvals for the mitigation improvement and the applicant has been given the right to construct on any land owned by others that is necessary for the mitigation improvement.
Summary
LTS = less than significant; NA = Not applicable; NI = no impact; PS = potentially significant; SU = significant and unavoidable.
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TABLE S-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Impact
Significance
Before
Mitigation Mitigation Measure
Significance
After
Mitigation
Impact 3.1-3: The proposed project would not
substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible land uses (e.g., farm
equipment).
NI None Required. NA
Impact 3.1-4: The proposed project would not result in
inadequate emergency access.
LTS None Required. NA
Impact 3.1-5: Implementation of the proposed project, in
combination with other development, could contribute to
cumulative conditions where VMT per capita or VMT per
employee could exceed 85 percent of the 2040
cumulative Bay Area-wide regional average daily VMT
per employee.
PS Implement Mitigation Measure 3.1-1. SU
Summary
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CHAPTER 1
Introduction
In February 2010, the City of South San Francisco approved the Gateway Business Park Master
Plan project and a Precise Plan for Phase 1. The master plan project involved the phased removal
and replacement of existing buildings on the 22.6-acre site, construction of five to six new
buildings, and construction of two to four parking structures, in up to five phases.
In April 2013, the City approved modifications to the Gateway Business Park Master Plan project
and the Precise Plan for Phase 1. The modifications included more flexibility in phasing, a new
amenity building in Phase 1, a First Amendment to the Development Agreement, and minor
changes to on-site circulation. These modifications were reflected in a revised Master Plan, which
was renamed as the GOP Master Plan and a revised Precise Plan for Phase 1. Precise Plans were
subsequently approved for phases 2, 3 and 4 as well. When it was considering the precise plans, the
City adopted addenda in 2018 and 2020 to the 2010 EIR, for the subsequent approval of the plans.
As used in this Draft SEIR, the “2010 EIR” refers to the EIR certified on February 10, 2010, as
supplemented by these Addenda. Phase 1 (GOP 1) has since been constructed while Phases 2 and 3
(GOP 2 & 3) are currently under construction; Phase 4 (GOP 4) has yet to begin construction.
In July 2016, the City approved a project on a nearby property to the west of the GOP Master
Plan area known as 475 Eccles. The project consisted of two office buildings and a parking
structure. In 2020, the City approved an expansion of the 475 Eccles site to include the site of some
former rail spurs that currently separate the GOP Master Plan area from the 475 Eccles site. The
purpose of the expansion was to integrate the GOP Master Plan area and the 475 Eccles site into
one life sciences campus connected by pedestrian pathways and a grand staircase. This modified
project, which now includes both 475 Eccles site and the site of the former rail spurs, is now known
as Phase 5 of the GOP Master Plan project (GOP 5). Construction has yet to begin on GOP 5.
BioMed Reality (project applicant) proposes the transfer of 120,221 square feet (sf) of
developable space from the GOP 5 site to the GOP 4 site. The developable space consists of what
could potentially be built on the site of the former rail spurs and would be added to the northern
building on the GOP 4 site as four additional floors. The portion of the GOP 5 site encompassing
the rail spurs would then be deed restricted to allow no development of the density that is
transferred. The new square footage on the GOP 4 site would be parked at 2 spaces per 1,000 sf,
which would be accommodated by adding 2.5 floors to the previously-approved parking structure
on the GOP 4 site.
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The proposed density transfer project is referred to throughout this Draft Supplemental
Environmental Impact Report (SEIR) as the “GOP 4 Density Transfer project” or the “proposed
project.” The City of South San Francisco is the Lead Agency for preparation of this Draft SEIR
and responsible for the majority of approvals required for the project, pursuant to CEQA
Guidelines Section 15051).
1.1 Background
The environmental effects of development on the Gateway Business Park Master Plan project and
a Precise Plan for Phase 1 were analyzed in the 2010 EIR. The 2010 EIR examined the potential
for environmental impacts of the master plan, as well as the specific development proposal for
Phase 1. In April 2013, the City found that the modifications to the Gateway Business Park
Master Plan and GOP 1 Precise Plan were within the scope of the 2010 EIR and re-certified that
EIR. For the Phase 2, 3 and 4 Precise Plans, the City had adopted 2018 and 2020 Addenda that
determined that no new or more significant effects would result from those Precise Plans. The
most recent decision was made on August 6, 2020, when the Planning Commission adopted
Resolution 2858-2020 approving the 2020 Addendum and approving the Precise Plan for GOP 4,
concluding that there were no changes to the project studied in the 2010 EIR, changes in
surrounding circumstances, or significant new information, any of which showed a new or more
severe significant impact.
The currently proposed project modifies the previously-approved GOP 4 Precise Plan to provide
for an expansion of 120,221 square feet.
1.2 CEQA Context
Since the City already determined, as of August 6, 2020, that the 2010 EIR was adequate for the
GOP 4 Precise Plan and that there were no material changes in surrounding circumstances or
significant new information relating to GOP 4, and because the proposed project is a minor
modification to the GOP 4 Precise Plan approved on August 6, 2020, this Supplemental EIR
evaluates whether the changes proposed by the proposed project, or changes in circumstances or
significant new information developed since August 6, 2020, will cause any new or more
significant impacts than are identified in the 2010 EIR.
Preparation of a subsequent or supplemental environmental impact report would be warranted if
and to the extent that the project meets any of the following stated conditions:
1) Substantial changes to the project or substantial changes to circumstances, or new
information of substantial importance; which
2) require major revisions to the EIR; and
3) result in new significant environmental effects or a substantial increase in the severity of
previously identified significant effects. (PRC Section 21166; CEQA Guidelines Sections
15162 and 15163.)
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The findings for each of these standards must be based on substantial evidence (State CEQA
Guidelines Section 15162). The metric for analyzing transportation impacts has changed under
CEQA. Previously, impacts were analyzed using a congestion or delay-based metric, such as
Level of Service. Now, CEQA requires that transportation impacts be assessed using Vehicle
Miles Traveled (VMT), which measures the distance a vehicle will travel to a destination.
Preliminary analysis by the City suggest that the GOP 4 Density Transfer project will create a
significant VMT impact. As a result, the City determined that subsequent or supplemental
environmental analysis for the project is required.
According to Section 15163 of the State CEQA Guidelines, a supplement to an EIR is required if:
(1) any of the conditions described in Section 15162 would require the preparation of a
subsequent EIR, and (2) only minor additions or changes would be necessary to make the
previous EIR adequately apply to the project in the changed situation. When certified, the SEIR,
along with the 2010 EIR, will serve as the environmental document for the proposed project.
This Draft SEIR assesses whether the proposed project would or would not cause new or more
significant impacts not previously identified for the GOP 4 site analyzed in the 2010 EIR.
Pursuant to PRC Section 21166 and CEQA Guidelines Section 15162, the analysis in this Draft
SEIR also considers whether substantial changes to circumstances or new information of
substantial importance exist that could result in the proposed project having a new significant
impact not previously identified for the GOP 4 site in the 2010 EIR.
1.3 Purpose and Use of this EIR
Consistent with CEQA, this SEIR is a public information document, and its key purpose is for
use by governmental agencies and the public to identify and evaluate potential environmental
consequences of a proposed project, to recommend mitigation measures to lessen or eliminate
adverse impacts, and to examine feasible alternatives to the proposed project. The City, as Lead
Agency for this SEIR, will review and consider the information contained in this Draft SEIR prior
to taking action on the proposed project.
The City’s actions on the project include several required discretionary permits and approvals
necessary before development of the project could proceed. The currently anticipated City and
other agency permits and approvals that may be required for the project are described at the end
of Chapter 2, Project Description, of this document. In addition, the project may rely on or
require review and approval by a number of public agencies and jurisdictions that have authority
over specific aspects of the project.
Copies of this Draft SEIR are available at the City of South San Francisco, Planning Division, at
the offices of the City’s Planning Division at 315 Maple Avenue, South San Francisco, California
94083. This Draft SEIR is subject to review and comment by the public, as well as responsible
agencies and other interested jurisdictions, agencies, and organizations for a minimum of forty-
five (45) days. During this review period, written comments on the SEIR may be submitted to the
1. Introduction
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City at the address above. Responses to all comments received on the environmental analysis in
this Draft SEIR and submitted within the 45-day review period will be included in the Final SEIR.
1.4 CEQA Environmental Review
1.4.1 Preliminary Project Evaluation
The State CEQA Guidelines define the role and standards of adequacy of an EIR as follows:
• Informational Document. An EIR is an informational document that will inform public
agency decision-makers and the public of the significant environmental effect(s) of a project,
identify possible ways to minimize the significant effects, and describe reasonable alternatives
to the project. The public agency shall consider the information in the EIR along with other
information that may be presented to the agency (State CEQA Guidelines section 15121[a]).
• Standards for Adequacy of an EIR. An EIR should be prepared with a sufficient degree of
analysis to provide decision-makers with information that enables them to make an informed
decision that takes account of environmental consequences. An evaluation of the
environmental effects of a proposed project need not be exhaustive, but the sufficiency of an
EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts
does not make an EIR inadequate, but the EIR should summarize the main points of
disagreement among the experts. The courts have looked not for perfection but for adequacy,
completeness, and a good faith effort at full disclosure (State CEQA Guidelines section 15151).
State CEQA Guidelines Section 15382 defines a significant effect on the environment as “a
substantial, or potentially substantial, adverse change in any of the physical conditions within the
area affected by the project…” Therefore, in identifying whether the proposed project will cause
new or more severe impacts, this SEIR describes the potential for the proposed project to result in
substantial new physical effects within the area affected by the project, and identifies mitigation
measures that would avoid or reduce the magnitude of those new effects. See Section 3.0,
Introduction to the Analysis, for further description of the approach to analyzing environmental
impacts and identifying mitigation measures presented in this SEIR.
1.4.2 EIR Scoping
On November 16, 2021, the City issued a Notice of Preparation (NOP) of the Draft SEIR to
governmental agencies and organizations and persons interested in the project (included in
Appendix A). The NOP review period ended on December 20, 2021. The NOP was distributed to
governmental agencies, organizations, and persons interested in the proposed project along with
notice to the general public. The City sent the NOP to agencies with statutory responsibilities in
connection with the proposed project with the request for their input on the scope and content of
the environmental information that should be addressed in the EIR.
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The City of South San Francisco received two written comment letters regarding the proposed
project (included in Appendix B). Although many specific issues were mentioned in the NOP
comment letters, the comments generally tended toward larger themes such as:
• Analysis of vehicle miles traveled;
• Support of transit and active transportation modes;
• Implementation of travel demand management measures; and
• Compatibility with the Comprehensive Airport Land Use Compatibility Plan for the Environs
of San Francisco International Airport.
1.4.3 Public Review
The Draft SEIR will be available for public review and comment as set forth in the Notice of
Availability. During the review and comment period written comments (including email)
regarding the Draft SEIR may be submitted to the City at the address below:
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Avenue
South San Francisco, California 94080
Email: billy.gross@ssf.net
The Draft SEIR, Notice of Availability and other supporting documents, such as technical studies
prepared by the City as part of the EIR process, are available for public review at the offices of
the Planning Division at 315 Maple Avenue, South San Francisco, California 94080, and on the
City’s website at https://weblink.ssf.net.
1.4.4 Final EIR and EIR Certification
Following the public review and comment period for the Draft SEIR, the City will prepare
responses that address all substantive written and oral comments on environmental issues
addressed in the Draft SEIR that are received within the specified review period. The responses
and any other revisions to the Draft SEIR will be provided as a Final SEIR. The Draft SEIR and
its Appendices, together with the Final SEIR and the 2010 EIR, will collectively constitute the
EIR for the proposed project.
1.4.5 Mitigation Monitoring and Reporting Program
Throughout this SEIR, mitigation measures have been identified and presented in language that
will facilitate preparation of a mitigation monitoring and reporting program (“MMRP”). As
required under CEQA, an MMRP will be implemented following certification of the Final SEIR
for the proposed project and will identify the specific timing and roles and responsibilities for
implementation of adopted mitigation measures.1
1 See State CEQA Guidelines, section 15097.
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1.5 Document Organization
This Draft SEIR document is organized as follows:
Summary – This section summarizes the proposed project and the conclusions of the Draft SEIR.
A summary table is included and organized to allow the reader to easily identify potentially
significant effects, proposed mitigation measures, and any residual environmental impacts after
implementation of mitigation measures. A summary of the alternatives to the proposed project
and the environmentally superior alternatives are also provided. The Summary also describes
areas of controversy regarding the proposed project that are known to the City as of publication of
this Draft SEIR.
Chapter 1, Introduction – This chapter describes the purpose and organization of the SEIR.
Chapter 2, Project Description – This chapter describes the proposed project. The description
includes, with text and graphics, the location and boundaries of the proposed project, statements
of objectives from the project applicant and the City, and a description of the proposed project’s
components and characteristics.
Chapter 3, Environmental Impact Analysis – For Transportation, this chapter discusses the
environmental and regulatory setting, the methodology used, the detailed analysis of potential
impacts (including direct, indirect, and cumulative impacts), and where necessary, a discussion of
potentially feasible mitigation measures. This section also discusses Other Resource Topics,
summarizing impacts and whether the project would trigger any changes to the conclusions in the
prior certified EIR.
Chapter 4, Alternatives – This chapter describes alternatives considered and an alternative fully
analyzed that may avoid or substantially reduce one or more of the project’s significant impacts
while attaining most of the basic objectives of the project. This section evaluates the comparative
environmental effects of the potentially feasible alternative and identifies the environmental
superior alternative.
Chapter 5, Other CEQA Required Considerations – This chapter discusses several issues
required to be included in an SEIR, including effects not found to be significant, significant and
unavoidable impacts, significant irreversible environmental changes, the potential for the
proposed project to cause urban decay, and the potential for the proposed project to induce urban
growth and development.
Chapter 6, List of Preparers – This chapter identifies the agency staff and consultants who
prepared the SEIR, and agencies or individuals consulted during preparation of the SEIR.
Appendices – The appendices include environmental scoping information and technical reports
and data used in the preparation of the Draft SEIR.
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CHAPTER 2
Project Description
2.1 Introduction
This chapter presents information regarding the components and characteristics of the proposed
Gateway of Pacific (“GOP”) 4 Density Transfer project, or “proposed project.” which modifies
the previously approved GOP 4 Precise Plan, which itself was a later approval for the GOP
Master Plan project studied in the 2010 EIR, and the discretionary approvals anticipated to
implement it. A concise outline of the project elements is provided in the Executive Summary.
2.2 Project Location
The GOP 4 site is located in the City of South San Francisco, approximately 1.5 miles north of
San Francisco International Airport (SFO) and approximately 10 miles south of downtown San
Francisco. The City of South San Francisco is located on the San Francisco Bay plain and the
northern foothills of the Coastal range. The City is located along major transportation routes
including US 101, Interstate 380 (“I-380”), Interstate 280 (“I-280”), and the Union Pacific
Railroad (see Figure 2-1, Project Location).
The GOP 4 project is the fourth phase of the GOP Master Plan project studied in the EIR, which
is located within the larger Gateway Specific Plan area and East of 101 Sub-area. The GOP
Master Plan area consists of approximately 23 acres of land and is generally bounded by Oyster
Point Boulevard on the north, Gateway Boulevard on the west, a narrow band of vacant land to
the east, and a hotel to the south. The GOP Master Plan area is developed with office,
warehousing and research and development (“R&D”) uses.
The GOP 4 site itself is 4.8 acres in size and is located at 850 and 900 Gateway Boulevard, which
is in the northeastern portion of the GOP Master Plan area. The site is located south of buildings
housing R&D uses located at 180 and 200 Oyster Point Boulevard, which are located outside the
GOP Master Plan area. The site is presently developed with two one-story buildings, a Federal
Express (FedEx) distribution center (900 Gateway Boulevard) totaling 50,000 sf and an
abandoned office building (850 Gateway Boulevard) totaling approximately 19,300 sf (see
Figure 2-2, GOP 4 Site).
Regionally, the GOP 4 site is accessible from the northwest via the US 101 Oyster Point
Boulevard off- and on-ramps and from the southwest by the East Grand Avenue exit off of
US 101. Locally, the GOP 4 site is accessible from two points along Oyster Boulevard, a drive
way between 180 and 200 Oyster Point Boulevard, and the FedEx driveway along the eastern
boundary of the GOP Master Plan area that connects with Oyster Point Boulevard.
SOURCE: ESA, 2021
FIGURE 2-1
PROJECT LOCATION
BioMed GOP4 Master Plan Focused SEIR
N
Oakland
Pleasanton
Point Reyes
Station
Richmond
Rio Vista
San Anselmo
San
Bruno
San Francisco
San Jose
San Martin
San
Mateo
Santa Clara
Sonoma
Walnut Creek
Project
Location
San Francisco Bay
82
101
280
280
N
BioMed GOP4 Master Plan Focused SEIR
FIGURE 2-2
GOP 4 SITE
SOURCE: Google Earth, 2021; ESA, 2021
0 200
Feet
OYSTER POINT BLVD
ECCLES AVER
O
Z
Z
I
P
L
GATEWAY BLVDGOP 4 Site
GOP Master Plan Area
GOP 1
GOP 2
GOP 3
GOP 4
GOP 5
180 200
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2.3 Project Objectives
California Environmental Quality Act (“CEQA”) Guidelines Section 15124(b) requires that an
EIR project description include a statement of the objectives intended to be achieved by the
project. The objectives describe the purpose of the project and are intended to assist the lead
agency in developing a reasonable range of alternatives for consideration in the EIR, as well as
assisting the decision makers in assessing the feasibility of mitigation measures and alternatives.
The objective of the GOP 4 Density Transfer project is to transfer unused Floor Area Ratio from
the adjacent rail spur properties to enable an expansion to Phase 4 of the GOP Master Plan project
in a manner that:
• builds upon prior approvals by implementing their conditions, mitigation measures and
architectural treatments;
• softens the height transition between the buildings constructed during GOP Phase 1 and the
buildings to be constructed during GOP Phase 4; and
• locates the expansion in an already-approved campus, allowing it to take advantage of
approved pedestrian connections, the multi-modal improvements approved for the adjacent
rail spur properties and the shuttle stop planned for the campus.
2.4 Background
In February 2010, the City approved the Gateway Business Park Master Plan project and a
Precise Plan for Phase 1. Other approvals included related General Plan and zoning changes, and
a Development Agreement. The environmental effects of the project were analyzed in a 2010 EIR
(State Clearinghouse Number 2008062059) certified via City Council Resolution 18-2010. In
addition, the City Council also adopted CEQA findings, a Mitigation Monitoring and Reporting
Program (“MMRP”) and a statement of overriding considerations for the project. The master plan
project involved the phased removal and replacement of existing buildings on the 22.6-acre site,
construction of five to six new buildings, and construction of two to four parking structures, in up
to five phases. The plan would have developed the site with a Floor Area Ratio (FAR) of 1.25,
which would have resulted in approximately 1,230,570 square feet (sf) of building space.
In April 2013, the City approved modifications to the Gateway Business Park Master Plan project
and the Precise Plan for Phase 1 (City Council Resolution 44-2013). The City found that the
modifications were within the scope of the 2010 EIR and re-certified that EIR (City Council
Resolution 43-2013). In addition, the City re-adopted the CEQA findings, the MMRP and the
statement of overriding considerations. The modifications included more flexibility in phasing, a
new amenity building in Phase 1, a First Amendment to the Development Agreement, and minor
changes to on-site circulation. The overall development standards and FAR of 1.25 did not
change. These modifications were reflected in a revised Master Plan, which was renamed as the
GOP Master Plan, and a revised Precise Plan for GOP 1. Phase 1 has since been constructed.
In July 2018, the City approved a Second Amended and Restated Development Agreement (“Second
Amendment”) (Ordinance No. 1559-2018). The Second Amendment recognizes a lot line adjustment
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that had previously adjusted the property line between Phases 1 and 2, recognized the current
ownership of the various parcels that comprise the GOP Master Plan area, allocated responsibility for
compliance with the conditions of approval and mitigation measures separately among each phase,
and clarified that the requirement for a replacement childcare facility on the site be triggered upon
occupation of 750,000 sf of gross floor area within the GOP Master Plan area. The City
determined that no additional environmental review was required for the Second Amendment.
In December 2018, the City approved Precise Plans for Phases 2 and 3 of the GOP Master Plan
project (Planning Commission Resolution 2835-2018). The Planning Commission determined
that Phases 2 and 3 were within the scope of the 2010 EIR and adopted a 2018 Addendum to the
previous analysis. The Precise Plans provided detailed development plans that implemented the
already-approved GOP Master Plan project. Phases 2 and 3 are currently under construction.
In July 2020, the City approved a Precise Plan for Phase 4 of the GOP Master Plan project, as well
as a Use Permit for the adjacent project at 475 Eccles Avenue to the southeast, which is now known
as GOP 5 (Planning Commission Resolution Nos. 2859-2020 and 119-2020). The Precise Plan for
the GOP 4 project provided detailed development plans that implemented the already-approved
GOP Master Plan project. The GOP 4 project included two five-story buildings with R&D uses
totaling 226,000 sf and a six-story parking structure, with a partial floor on the sixth level, in the
northeastern portion of the GOP Master Plan area. For this project, the Planning Commission
determined that Phase 4 was within the scope of the 2010 EIR and 2018 Addendum, and adopted
a 2020 Addendum to the previous analysis. Construction of GOP 4 has not commenced.
The Use Permit for the GOP 5 project integrated the adjacent project at 475 Eccles Avenue into a
campus that would include both the GOP Master Plan and GOP 5 projects. The GOP 5 project
includes the site of some former rail spurs that previously separated the GOP Master Plan area
from the 475 Eccles site, which will be converted into a publicly-accessible multi-use path
connecting Oyster Point Boulevard with Forbes Boulevard, and provided pedestrian connections
within the campus.
2.5 Existing Conditions
Existing Land Use Regulations
South San Francisco General Plan
The South San Francisco General Plan designates the GOP Master Plan area, including the
GOP 4 site, as Business Commercial. This category is intended for business and professional
offices, visitor service establishments, and retail. The maximum FAR is 0.5, but increases may be
permitted up to a total FAR of 1.0 for uses such as R&D establishments, or for development
meeting specific transportation demand management (TDM), off-site improvements, or specific
design standards.
East of 101 Area Plan
The East of 101 Area Plan, which was adopted by the City Council in 1994, contains a Land Use
Element that designates the East of 101 Sub-area into Planned Commercial, Light Industrial,
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Coastal Commercial, Airport-Related, Mixed-Use Categories, and Planned Industrial. The GOP
Master Plan area, including the GOP 4 site, is designated Planned Commercial in the East of 101
Area Plan. However, land use policies and designations of the General Plan supersede those
outlined in the East of 101 Area Plan. The City has, however, retained the East of 101 Area Plan
Design Element policies to be the design guidelines for development in the East of 101 Area.
South San Francisco Zoning Ordinance
The GOP Master Plan area, including the GOP 4 site, is located in the Gateway Specific Plan
zoning district within the East of 101 Area Plan. The district was created to refine and implement
the City’s General Plan for a specific area within the East of 101 Area Plan. The zoning
regulations for this district have been incorporated into the City’s Municipal Code as set forth in
Chapter 20.220. Uses permitted in this district include, but are not limited to, office buildings for
professional or business purposes, R&D, and office/sales/service. Building limitations in this
zoning district state the building coverage shall not exceed 50 percent of the area of a site,
building heights shall not exceed 250 feet, and that FAR shall not exceed 1.25. Setbacks along
property line adjacent to streets are required to be 40 feet from the property line. Off-street
parking requirements are as follows: one space for each 300 sf of gross floor area (business and
professional offices, financial institutions); one space for each 500 sf of gross floor area and one
space for each 300 sf of gross office or non-storage areas or non-laboratory area (R&D); and one
space for each 300 sf of gross floor area (office/sales/service). All regulations in the Municipal
code relating to the GOP Master Plan area govern its development unless otherwise indicated in
the GOP Master Plan project Development Agreement (which vests the project into the 2013
version of the Zoning code). The GOP Master Plan is subject to a condition that limits parking to
2.73 spaces per 1,000 square feet.
Surrounding Land Uses
The GOP Master Plan area is surrounded by office, R&D, commercial (including childcare
facilities, fitness centers, restaurants), and light industrial uses. In particular, the Cove at Oyster
Point, which is composed of four- to six-story buildings consisting of office and biotechnology
uses, is located to the north across Oyster Point Boulevard, and the Gateway Campus, which is
composed of three- to 16-story buildings consisting of office, R&D, childcare, and amenity uses,
is located to the west across Gateway Boulevard. The GOP 4 site itself is surrounded by R&D
uses to the north, a vacant strip of land to the east/south, and two buildings housing R&D and
amenity uses to the west that were constructed during Phase 1 of the GOP Master Plan project.
2.6 Project Characteristics
Previously Approved Project
As discussed above, the approved GOP 4 project included two five-story buildings totaling
226,000 sf and a five-story parking structure. One building would be located on the northern
portion of the site and the other building would be located on the southern portion of the site with
the parking structure located to the east (see Figure 2-3, GOP 4 Site Plan). Both the northern and
southern buildings were approximately the same size each with each totaling about 113,000 sf.
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GOP 4 SITE PLAN
SOURCE: Flad, 2021
0 160
Feet
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-8 ESA / D202101143
City of South San Francisco January 2022
The two structures were also each 98 feet above the average level of the highest and lowest points
on the lot. A total of 531 parking spaces were be provided in a six-level the parking structure
(five full floors and a partial level on the sixth floor). The massing and height of the approved
structures are shown in Figure 2-4, Approved GOP Massing Diagram, and Figure 2-5, Approved
GOP Rendering. The project would have employed approximately 603 workers. The envelope of
the buildings consisted of a high-quality curtain-wall system with energy-efficient glazing and
accents of metal panels, wood and concrete.
Modified Project
The site of the former rail spurs on the GOP 5 site is 2.76 acres or 120,221 sf in size. Based on an
allowed FAR of 1.0 for R&D establishments permitted by the City’s General Plan, a total of
120,221 sf of R&D use could be developed on this portion of the GOP 5 site. The proposed
GOP 4 Density Transfer project would transfer this space from the GOP 5 site to the GOP 4 site.
The developable space would be added to the northern building on the GOP 4 site as four
additional floors. The portion of the GOP 5 site encompassing the rail spurs would then be deed
restricted to not allow any of the density transferred to GOP 4 site to be constructed on the rail
spur property.
In exchange for effectively reducing the FAR on the rail spurs to zero, the FAR would be
increased at the GOP 4 site, and the GOP Master Plan project would be amended as indicated in
Table 2-1, GOP Master Plan Amendment.
TABLE 2-1
GOP MASTER PLAN AMENDMENT
GOP 1
Parcel C
GOP 2
Parcel B
GOP 3
Parcel A
GOP 4
Parcel D
GOP Master
Plan
(Phases 1-4)
Lot Square Footage,
after most recent LLA
284,584
(6.53 acres)
237,986
(5.46 acres)
185,262
(4.25 acres)
276,6391
(6.35 acres)
984,471
As Built or Entitled – Before GOP 4 Density Transfer Project
Building Floor Area 479,116 371,648 302,722 225,6212 1,379,107
Building Floor Area that
counts towards FAR 427,104 312,130 265,734 225,621 1,230,589
FAR 1.50 1.31 1.43 0.82 1.25
After Implementation of the GOP 4 Density Transfer Project,
Which Proposes to Transfer 120,221 SF from the Rail Spurs to GOP 4
Building Floor Area 479,116 371,648 302,722 345,842 1,499,328
Building Floor Area that
counts towards FAR 427,104 312,130 265,734 345,842 1,350,810
FAR 1.50 1.31 1.43 1.25 1.37
Notes:
Floor Area is calculated pursuant to Municipal Code § 20.040.008. Floor Area Ratio (FAR) is calculated pursuant to Municipal Code
§ 20.040.009.
1 The GOP 4 site was 276,422 SF when BMR first applied for the GOP 4 Precise Plan. Pursuant to a Lot Line Adjustment
subsequently approved by the City, the GOP 4 site is now 276,639 SF.
2 The approved plan set for GOP 4 shows 226,000 SF of Floor Area. However, subsequent calculations that took into account the
exact square footage of GOP 1 – 3 revealed that only 225,261 SF of Floor Area (a difference of 379 square feet) is available to be
built on GOP 4 site under the 1.25 FAR currently applicable to the entire GOP Master Plan area.
GOP 4 Density Transfer Proj ect – Proj ect Description
- 2 -
new square footage will be park ed at 2 spaces per 1 , 0 0 0 SF, which BMR proposes to provide by adding 2 .5 floors to the GOP 4 park ing structure.The approved portion of the campus remains subj ect to the 2 .7 3 /1 , 0 0 0 SF park ing limit imposed on the GOP Master Plan.I .B a c k g r ou n d .The GOP Master Plan and GOP 5 proj ects are both located in the City’ s East of 1 0 1 Area.
Though the entitlements for each proj ect remain separate, the physical development is intended
to integrate them into one life sciences campus connected by pedestrian pathways and a grand
staircase. As currently entitled, the GOP Master Plan proj ect and GOP 5 proj ect are as follows,
with GOP 4 highlighted in blue:
A A p p r ov ed GO P M a ster P l a n P r oj ec t.
I n 2 0 1 3 , the City approved a modified master plan for the Gateway Business Park Master Plan
proj ect, which is now k nown as the Gateway of Pacific, or GOP proj ect. The GOP Master Plan
proj ect site is designated Business Commercial in the General Plan, is subj ect to the Gateway
Specific Plan, and is in the Gateway Specific Plan z oning district. The proj ect is vested into
these plans and regulations by a Development Agreement.
The GOP Master Plan contemplates phased development. The City has approved precise
plans for four phases, and has approved Lot Line Adj ustments that accommodate these phases.
The General Plan imposes an FAR 2 limitation of 1 .2 5 on the GOP Master Plan site. The Master
Plan reflects this 1 .2 5 FAR limitation, and permits individual parcels to be developed at FARs
greater than 1 .2 5, so long as development of the entire Master Plan site does not ex ceed 1 .2 5.
2 FAR is Floor Area Ratio, or the ratio of square footage that can be developed on a parcel to the square
footage of the underlying parcel.
BioMed GOP4 Master Plan Focused SEIR
FIGURE 2-4
APPROVED GOP MASSING DIAGRAM
SOURCE: Flad, 2021
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FIGURE 2-5
APPROVED GOP RENDERING
SOURCE: Flad, 2021
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-11 ESA / D202101143
City of South San Francisco January 2022
The additional square footage would be parked at 2 spaces per 1,000 sf, which would be
accommodated by adding 2.5 floors to the previously-approved parking structure; a total of
approximately 240 new parking spaces would be provided.
As revised, the northern building on the GOP 4 site would total nine floors and reach at height of
178 feet above the average level of the highest and lowest points on the lot. The northern
structure would include about 233,300 sf of space. The height and size of the southern building
would remain the same. The parking structure would also now be eight levels in height and
include 771 parking spaces. The massing and height of the modified structures are shown in
Figure 2-6, Modified GOP Massing Diagram, and Figure 2-7, Modified GOP Rendering.
The approved architectural scheme of the buildings would be extended to the new floors, without
any substantive changes in architecture. The modified GOP 4 project also includes a generator
yard at ground level in the landscaped area on the northwest side of the GOP 4 parking structure.
The additional space would employ an additional 321 workers.
2.7 Open Space
The proposed project does not include any changes to open space. The placement of the two
buildings on the GOP 4 site would remain the same, and would allow for an open space area
between the two structures, which would serve as a gathering space and passive use area.
Landscaping on the GOP 4 site would emphasize a natural and informal landscape using simple
plant materials combined in consideration of form, color, and texture. Plants would be chosen
considering the climate of South San Francisco in the East of 101 area and would be combined
with landform to provide a wind-protected space. The approved Precise Plans have approximately
360,000 square feet of irrigated landscaping, including the live roof on the amenity building,
which is less than the 383,500 square feet of irrigated landscaping studied in the EIR.
2.8 Circulation
Vehicular
The proposed project does not include any changes to primary or secondary vehicular access. As
already approved, primary vehicular access to the GOP 4 site will be provided via a driveway at
the intersection of Oyster Point and Veterans Boulevards located between buildings 180 and 200
and the current Fed-ex driveway. Secondary access will be provided from Gateway Boulevard via
a private drive aisle named “Park Street,” to be constructed along the western edges of Phases 2
and 3.
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BioMed GOP4 Master Plan Focused SEIR
FIGURE 2-6
MODIFIED GOP MASSING DIAGRAM
SOURCE: Flad, 2021
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FIGURE 2-7
MODIFIED GOP RENDING
SOURCE: Flad, 2021
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-14 ESA / D202101143
City of South San Francisco January 2022
Service/delivery access also would not change, and would continue to be served by the secondary
access lane or by supplemental access points. Service and delivery vehicles will be limited in
usage of the primary entrances. Emergency vehicles would utilize all entries and supplemental
access points as necessary.1
Pedestrian
The proposed project does not include any changes to onsite or offside pedestrian access. As
already approved, pedestrian circulation within the GOP4 site would be provide by pathways
between the two proposed structures and the parking structure. These pathways would connect to
the central spine running north to south within the GOP Master Plan area, which would
accommodate higher volumes of pedestrian movement and include a central gathering space and
other useable outdoor spaces. Street frontages and the offsite multi-use trail along the former rail
spurs would continue to provide access to offsite areas.
Transit
Transit services have not changed. As was the case when the GOP 4 Precise Plan was approved,
the GOP 4 site is not served directly by regional rail, bus, or ferry services, but these transit
modes provide service to the City of South San Francisco, at varying distances from the GOP 4
site. First- and last-mile connections to regional transit services, in the form of shuttles, provide
periodic access to the GOP 4 site. A description of regional transit serving the City and shuttle
service to the East of 101 Sub-area is provided in Section 3.1, Transportation. Shuttle stops in the
vicinity of the GOP 4 site are located along Gateway and Oyster Point Boulevards.
2.9 Utilities
The proposed project does not include any changes to utility services, and circumstances
regarding utility providers has not changed. This information is summarized below.
Water
The GOP Master Plan area is served by the California Water Service Company, which purchases
most of its water from the San Francisco Public Utilities Commission. Existing water distribution
mains in the vicinity of the GOP Master Plan area include a 12-inch main along Gateway
Boulevard and 16-inch main along Oyster Point Boulevard.
1 The project also proposes a non-substantive modification to Mitigation Measure IV.M-1 to make explicit the
requirement that the Transportation Demand Management program be applied to the additional 120,221 square
feet, as follows:
“The project sponsors shall implement a Transportation Demand Management (TDM) program consistent with the
City of South San Francisco Zoning Ordinance Chapter 20.120 Transportation Demand Management, and
acceptable to C/CAG. These programs, once implemented, must be ongoing for the occupied life of the
development. The C/CAG guidelines specify the number of trips that may be credited for each TDM measure. The
project’s TDM program is included in Appendix H and will generate trip credits to offset the 412 total AM peak
hour and 357 PM peak hour net new trips generated by the project by the year 2015. be applied to all square
footage in the project, with a target of 40% non-drive alone mode during peak periods.”
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-15 ESA / D202101143
City of South San Francisco January 2022
Wastewater
Sewage and wastewater generated within the City is collected through the City’s sewer system
and is disposed of and treated at the South San Francisco/San Bruno Water Quality Control Plant.
Existing wastewater conveyance infrastructure in the vicinity of the GOP Master Plan area
includes a 6- and 12-inch line along Oyster Point Boulevard and a 15-inch line along Gateway
Boulevard. The line along Oyster Boulevard discharges into a pump station located on the
southwestern corner of Oyster Point and Gateway boulevards, which then re-directs the flow to
the line along Gateway Boulevard.
Storm Drainage
The GOP Master Plan area includes three sub-basins. The northern subbasin is served by an
18-inch to 24-inch storm drain line in Oyster Point Boulevard that flows west, the central
subbasin is served by an 18-inch storm drain line in Gateway Boulevard that flows north, and the
southern subbasin is served by a 30-inch storm drainpipe in Gateway Boulevard that flows south.
Electricity and Natural Gas
The GOP Master Plan area is served by the existing natural gas and electric service provided by
Pacific Gas and Electric (PG&E). Underground electrical lines and natural gas mains are located
Oyster Point Boulevard.
2.10 Sustainability
The proposed project would conform to the sustainability criteria already approved for the GOP 4
project. The additional square footage, like the approved square footage, would be designed to
enhance resource efficiency and ensure good indoor environmental quality, as well as reduce
energy consumption, water consumption, and waste generation. Building and landscape design
and material selection would not change. They were selected to support Energy and
Environmental Design (LEED) and high-performance energy and environmental standards. As
set forth in the Development Agreement, the project applicant will use good faith efforts to
achieve a LEED rating of silver or better. The design will follow the framework established by
the GOP Master Plan project and the approach to sustainability and commitment to design quality
would be consistent with the other GOP phases. The modified GOP project would also be
designed to meet requirements contained in the California Building Energy Efficiency Standards
(Title 24, Parts 6 and 11).
The proposed project will also incorporate water-saving measures, such as low flow fixtures, and
leak detection technology and a water meter tied to the building management system for the
cooling towers for each building In addition, the cooling towers for each building will incorporate
the following items and practices:
• Cooling towers and chillers for each building;
• A chiller that is appropriately sized for each cooling tower;
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-16 ESA / D202101143
City of South San Francisco January 2022
• A conductivity controller for each cooling tower, which continuously measures the
conductivity of the water in the cooling tower and will initiate blowdown only when the
conductivity set point is exceeded;
• A high-end central computer controller that has alerts directly to operation staff;
• Submeters on the make-up and blowdown lines of each cooling tower;
• A building operations manager that runs and manages the cooling tower systems;
• Daily visual inspections of system;
• Deep cleanings semiannually;
• If chemicals are contracted out, should be on a fixed fee, rather than based on amount of
chemicals sold; and
• Cycles of concentration for the San Francisco Bay Area great water quality with low TDS is
ideally 10 or higher.
2.11 Transportation Demand Management Plan
The proposed project would be required to adhere to the Transportation Demand Management
(TDM) Plan approved for the GOP Master Plan project. The TDM plan includes a set of
strategies, measures, and incentives to encourage future employees within the GOP Master Plan
area to walk, bicycle, use public transportation, carpool, or use other alternatives to driving alone
when traveling to and from work. Some of the strategies, measures, and incentives listed in the
TDM Plan include:
• Secure on-site bicycle storage such as racks, cages, or lockers;
• Well-lit paths to the most direct route to the nearest transit or shuttle stop from the building;
• Free parking spaces for carpools and vanpools;
• Passenger loading zones for carpools and vanpools near the building entrances;
• Pedestrian connections with lighted paths and sidewalks between buildings, parking areas,
and Gateway and Oyster Point Boulevards;
• Preferential parking spaces for carpools and vanpools;
• Shower facilities with clothing lockers available to employees throughout the campus;
• Employee use of shuttle services including the Oyster Point BART shuttle to/from the South
San Francisco BART Station, and the Gateway Area Caltrain and Oyster Point Caltrain
Shuttles to/from the South San Francisco Caltrain Station;
• Permanent displays of commute alternative information in building lobbies, break rooms, and
other common areas;
• Designated TDM employer contacts (TDM Coordinators);
• Carpool/vanpool ride-matching services provided by TDM Coordinator;
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-17 ESA / D202101143
City of South San Francisco January 2022
• Guaranteed ride home program for emergencies via taxi cabs or rental cars;
• Promotion programs provided by the TDM Coordinators distributed on a quarterly basis, and
provided for new employees, to provide information on transportation options;
• Shuttle maps and schedules posted on campus and on tenant websites, and on-site assistance
provided to visitors by TDM Coordinators;
• Tenants will join the Peninsula Traffic Congestion Relief Alliance;
• TDM Coordinators will administer a biannual employee commute survey to determine
strategy adjustments;
• Transportation options will be outlined in tenant’s employee handbook and new employee
orientation packets;
• Commute alternatives brochure racks will be provided in public spaces within each building;
• Promotion of Spare the Air program by TDM Coordinators;
• Promotion of rideshare week by TDM Coordinators;
• Land dedication for transit/bus shelter;
• Bicycle connections to bicycle parking areas from bicycle routes;
• Tenant-subsidized transit tickets for commuters;
• On-site amenities for employees provided by e-concierge;
• On-site and nearby open space for recreation opportunities;
• On-site transit ticket sales;
• Employee access to nearby childcare center (YMCA);
• Opportunities for telecommuting;
• Employee access to Downtown Dasher lunchtime taxi service;
• At least one video conferencing room per building;
• Dedicated motorcycle parking spaces in garages;
• Tenants will allow employees to work varied work schedule (flextime);
• Development of a Transportation Action Plan between tenant and Transportation
Management Association; and
• Employee access to connections to a future ferry service.
2.12 Construction Activities and Schedule
Construction of the proposed project is scheduled to commence with site preparation in fall 2022
and end in spring 2024, lasting approximately 18 months, if the required entitlements are
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-18 ESA / D202101143
City of South San Francisco January 2022
approved by the City. The proposed project would include the following construction stages:
1) site preparation and demolition, 2) foundation installation, 3) building structure construction,
4) exterior and roof buildout, 5) interior buildout, and 6) commissioning and final inspections.
The hours of construction would be stipulated by the Building Division, and the project
contractor would be required to comply with Section 8.32.050 of the South San Francisco
Municipal Code the South San Francisco Noise Ordinance, which includes regulations related to
noise generated by construction. Project construction would typically occur Monday through
Friday, between 7:00 AM and 5:00 PM, although some work is anticipated to occur on Saturdays
between 9:00 AM and 8:00 PM or on Sundays between 10:00 AM and 6:00 PM. Construction is
not anticipated to occur on major legal holidays.
Construction materials and equipment would be staged entirely on-site, in areas where
construction is not occurring. Construction workers would park on the GOP 4 site or use existing
parking within the GOP Master Plan area. No temporary road closures that would affect the
public right-of-way would be required during project construction.
A stormwater pollution prevention plan (SWPPP) has been approved for the site as part of the
GOP 4 Precise Plan approvals, and would be implemented during project construction. Project
construction would use water from a metered hydrant up to 1,600 gallons a day, maximum). No
dewatering would be required during project construction.
The proposed project includes no changes to the requirement that, 100 percent of all inert solids
(building materials) and 65 percent of non-inert solids (all other materials) would be recycled as
required by the City under Chapter 15.60 of the South San Francisco Municipal Code.
2.13 Project Approvals and Entitlements
City of South San Francisco
Approval of the GOP 4 Density Transfer project is anticipated to require, but may not be limited
to, the following City actions:
• Amend General Plan to allow a density transfer. Specifically, add text to the notes in General
Plan FAR tables 2.2-1 and 2.2-2 that apply to the Business Commercial land use. The notes
would be amended to add the following underlined text:
The Gateway Business Park Master Plan and the Oyster Point Specific Plan are permitted to
develop up to a FAR of 1.25 with a TDM, and are allowed to develop additional density to
the extent such density would otherwise be available on immediately adjacent property that is
(a) subject to an FAR limitation of 1.25 or less; (b) part of the same research & development
campus; and (c) deed-restricted to preclude development of the transferred FAR;
BMR also seeks an amendment to the text on pages 2-21 to 2-22 of the General Plan
currently published on line, as follows:
The Gateway Business Park Master Plan area, comprising several parcels on 22.6 acres at the
southeast corner of Gateway Boulevard and Oyster Point Boulevard, is permitted to develop
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-19 ESA / D202101143
City of South San Francisco January 2022
up to a FAR of 1.25 and is allowed to develop additional density in limited circumstances as
provided in Tables 2.2-1 and 2.2-2.
• Repeal of Gateway Specific Plan as it may be considered outdated and because the relevant
components of the Specific Plan have already been incorporated into the applicable zoning
district regulations. Barring repeal, amend Gateway Specific Plan to allow a transfer of
density from adjacent property into the Specific Plan area;
• Amend Gateway Specific Plan Zoning District regulations to allow transfer of density from
an adjacent zoning district;
• Amend GOP Master Plan to allow a transfer of density from an adjoining property;
• Modify GOP 4 Precise Plan to incorporate an additional 120,221 square feet, with four
additional floors on the GOP 4 North building, and 2.5 additional floors on the parking
structure. Undergo associated design review.
• Certify EIR to verify that the EIR was completed in compliance with the requirements of
CEQA, that the decision-making body has reviewed and considered the information in the
EIR, and that the EIR reflects the independent judgement of the City of South San Francisco;
• Amend Development Agreement for the GOP Master Plan to encompass the above
approvals;
• Adopt a MMRP, which specifies the methods for monitoring mitigation measures required to
eliminate or reduce the project’s significant effects on the environment; and
• Adoption of Findings of Fact and a Statement of Overriding Considerations.
Other Local, Regional, State, or Federal Agencies
The proposed project would be anticipated to include, but may not be limited to, the following
actions by entities other than the City:
• Notice of Proposed Construction and Alteration and Federal Aviation Administration
Determination per Code of Federal Regulations Title 14, Part 77.9
2. Project Description
Gateway of the Pacific 4 Density Transfer Project 2-20 ESA / D202101143
City of South San Francisco January 2022
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Gateway of the Pacific 4 Density Transfer Project 3-1 ESA / D202101143
City of South San Francisco January 2022
CHAPTER 3
Environmental Setting, Impacts, and
Mitigation Measures
3.0 Introduction to the Analysis
This Supplemental Environmental Impact Report (SEIR) evaluates the potential physical
environmental effects resulting from implementation of the proposed GOP 4 Transfer Density
project. Some environmental issue areas that are typically considered under CEQA would not be
affected by the proposed project and, pursuant to CEQA, are not further analyzed in this SEIR.
A discussion of those issues is found in Section 3.2, Other Resource Topics.
3.0.1 Definitions of Terms Used in the SEIR
This SEIR uses a number of terms that have specific meaning under CEQA. Among the most
important of the terms used in the SEIR are those that refer to the significance of environmental
impacts. The following terms are used to describe environmental effects of the proposed GOP 4
Transfer Density project:
• Significance Criteria: A set of criteria used by the lead agency to determine at what level or
threshold an impact would be considered significant. Standards of Significance used in this
EIR include those standards provided by the City of South San Francisco. In determining the
level of significance, the analysis assumes that the project would comply with relevant
federal, State, and local regulations and ordinances.
• Significant Impact: A project impact is considered significant if the project would result in a
substantial adverse change in the physical conditions of the environment. Significant impacts
are identified by the evaluation of project-related physical change compared to specified
significance criteria. A significant impact is defined as “a substantial, or potentially
substantial, adverse change in any of the physical conditions within the area affected by the
project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic
or aesthetic significance.”1
• Potentially Significant Impact: A potentially significant impact is identified where the
project may cause a substantial adverse change in the environment, depending on certain
unknown conditions related to the project or the affected environment. For CEQA purposes, a
potentially significant impact is treated as if it were a significant impact.
1 State CEQA Guidelines, section 15382.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3-2 ESA / D202101143
City of South San Francisco January 2022
• Less-than-Significant Impact: A project impact is considered less than significant when the
physical change caused by the project would not exceed the applicable significance criterion.
• Significant and Unavoidable Impact: A project impact is considered significant and
unavoidable if it would result in a substantial adverse physical change in the environment that
cannot be feasibly avoided or mitigated to a less-than-significant level.
• Cumulative Impact: Under CEQA, a cumulative impact refers to “two or more individual
effects which, when considered together, are considerable or which compound or increase
other environmental impacts.”2 Like any other significant impact, a significant cumulative
impact is one in which the cumulative adverse physical change would exceed the applicable
significance criterion and the project’s contribution is “cumulatively considerable.”3
• Mitigation Measure: A mitigation measure is an action that could be taken that would avoid
or reduce the magnitude of a significant impact. Section 15370 of the State CEQA Guidelines
defines mitigation as:
a. Avoiding the impact altogether by not taking a certain action or parts of an action;
b. Minimizing impacts by limiting the degree of magnitude of the action and its
implementation;
c. Rectifying the impact by repairing, rehabilitating, or restoring the affected environment;
d. Reducing or eliminating the impact over time by preservation and maintenance
operations during the life of the action; and
e. Compensating for the impact by replacing or providing substitute resources or
environments.
3.0.2 Section Format
Chapter 3 includes one technical section (i.e., Section 3.1, Transportation) that presents the
physical environmental setting, regulatory setting, significance criteria, methodology and
assumptions, and impacts on the environment with respect to traffic. Where required, potentially
feasible mitigation measures are identified to lessen or avoid significant impacts. Section 3.1,
Transportation, includes an analysis of both project-specific and cumulative impacts.
Section 3.1, Transportation, begins with a description of the proposed GOP 4 Density Transfer
project’s environmental setting and the regulatory setting as it pertains to transportation. The
environmental setting provides a point of reference for assessing the environmental impacts of the
proposed project and project alternatives. The environmental setting discussion addresses the
conditions that exist prior to implementation of the proposed project. This setting establishes the
baseline by which the proposed project and project alternatives are measured for environmental
impacts. The regulatory setting presents relevant information about federal, state, regional, and/or
local laws, regulations, plans or policies that pertain to the environmental resources addressed in
each section.
2 State CEQA Guidelines, section 15355. 3 State CEQA Guidelines, section 15130(a).
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Next, Section 3.1, Transportation, presents significance criteria, which identify the standards
used by the City of South San Francisco to determine the significance of effects of the proposed
GOP 4 Density Transfer project. The significance criteria used for this analysis were derived
from the City of South San Francisco’s established significance standards, which, in turn, reflect
policies of the 1999 General Plan, as well as other criteria applicable under CEQA, including
thresholds established by trustee and responsible agencies.
The methods and assumptions description in Section 3.1, Transportation, presents the analytical
methods and key assumptions used in the evaluation of effects of the proposed GOP 4 Density
Transfer project, and is followed by an impacts and mitigation discussion. The impact and
mitigation portion of Section 3.1, Transportation, includes impact statements, prefaced by a
number in bold-faced type. An explanation of each impact is followed by an analysis of its
significance. The subsection concludes with a statement that the impact, following implementation
of the mitigation measure(s) and/or the continuation of existing policies and regulations, would be
reduced to a less-than-significant level or would remain significant and unavoidable.
The analysis of environmental impacts considers both the construction and operational phases
associated with implementation of the proposed GOP 4 Density Transfer project. As required by
Section 15126.2(a) of the State CEQA Guidelines, direct, indirect, short-term, long-term, onsite,
and/or off-site impacts are addressed, as appropriate, for the environmental issue area being
analyzed. Under CEQA, economic or social changes by themselves are not considered to be
significant impacts, but may be considered in linking the implementation of a project to a
physical environmental change, or in determining whether an impact is significant.
Where enforcement exists and compliance can be reasonably anticipated, this EIR assumes that
the proposed GOP 4 Density Transfer project would meet the requirements of applicable laws and
other regulations.
Mitigation measures pertinent to each individual impact, if available, appear after the impact
discussion section. The magnitude of reduction of an impact and the potential effect of that
reduction in magnitude on the significance of the impact is also disclosed. An example of the
format is shown below.
Impacts and Mitigation Measures
Impact 3.X-1: Impact Statement.
A discussion of the potential impact of the project on the resource is provided in paragraph form.
To identify impacts that may be site- or project element-specific, where appropriate, the
discussion differentiates between construction effects and operational effects. A statement of the
level of significance before application of any mitigation measures is provided in bold.
Mitigation Measure 3.X-1:
Recommended mitigation measure numbered in consecutive order. OR
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Mitigation: None required.
Where appropriate, one or more potentially feasible mitigation measures are described. If
necessary, a statement of the degree to which the available mitigation measure(s) would reduce
the significance of the impact is included in bold.
Cumulative Impacts
An analysis of cumulative impacts follows the project-specific impacts and mitigation measures
evaluation in Section 3.1, Transportation. A cumulative impact consists of an impact that is
created as a result of the combination of the project evaluated in the EIR together with other past,
present and reasonably foreseeable projects causing related impacts.4
The beginning of the cumulative impact analysis in each technical section includes a description
of the cumulative analysis methodology and the geographic or temporal context in which the
cumulative impact is analyzed (e.g., the City of South San Francisco, the San Francisco Bay Area
Air Basin, other activity concurrent with project construction). In some instances, a project-
specific impact may be considered less than significant, but when considered in conjunction with
other cumulative projects or activities may be considered significant or potentially significant.
As noted above, where a cumulative impact is significant when compared to existing or baseline
conditions, the analysis must address whether the project’s contribution to the significant
cumulative impact is “considerable.” If the contribution of the project is considerable, then the
EIR must identify potentially feasible measures that could avoid or reduce the magnitude of the
project’s contribution to a less-than-considerable level. If the project’s contribution is not
considerable, it is considered less than significant and no mitigation of the project contribution is
required.5 The cumulative impacts analysis is formatted the same as the project-specific impacts,
as shown above.
The State CEQA Guidelines suggest that the analysis of cumulative impacts can employ one of
two methods to establish the effects of other past, current, and probable future projects. A lead
agency may select a list of projects, including those outside the control of the agency, or
alternatively, a summary of projections. These projections may be from an adopted general plan
or related planning document, or from a prior environmental document that has been adopted or
certified, and these documents may describe or evaluate regional or area-wide conditions
contributing to the cumulative impact.
In this Draft SEIR, the evaluation of impacts to the local and regional transportation system uses
the projected growth in traffic through 2040 based on San Mateo City/County Association of
Governments projections.
4 State CEQA Guidelines section 15355. 5 State CEQA Guidelines section 15130(a)(3).
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3.1 Transportation and Circulation
This section analyzes the potential transportation impacts associated with the proposed GOP 4
Density Transfer project to the roadway, bicycle, pedestrian, and transit systems in the study area.
This section presents the project-specific and cumulatively considerable impacts of the proposed
project and recommends mitigation measures to lessen their significance. All supporting technical
calculations and additional technical information can be found in Appendix C of the Draft SEIR.
In response to the Notice of Preparation (NOP), the City received a comment letter from the
California Department of Transportation (Caltrans) requesting that a detailed analysis of vehicle
miles traveled (VMT) be included in the Draft SEIR. Specifically, Caltrans requested that if
project VMT exceeded the threshold of significance for city-wide or regional VMT that
mitigation should be identified. Caltrans also requested that the SEIR include a robust
Transportation Demand Management (TDM) program to reduce VMT and greenhouse gas
emissions from future development in this area. The requested VMT analysis, along with
proposed mitigation and a discussion of the project’s TDM program, is provided below.
3.1.1 Environmental Setting
Roadway Network
The City’s General Plan includes a street classification system, which identifies the types of
roadways that exist within the City. These classifications include freeways, arterials (both major
and minor), collectors, and local streets.
The project area is served by two north-south freeways, U.S. 101 and Interstate 280 (I-280),
which provide regional connectivity between the City and areas to the north, including the City of
San Francisco, areas further to north and east via the San Francisco Bay and Golden Gate bridges,
and areas to the south, including the City of San José and other cities in the south Bay Area. In
addition, the project area is served by an east-west freeway, Interstate 380 (I-380), which
provides local connectivity between the southeastern portion of City of South San Francisco and
the City of San Bruno. Finally, the project area is served by State Route 82 (SR-82), an arterial
road that runs the length of the San Francisco peninsula from San Francisco to the north and San
José to the south.
U.S. 101
U.S. 101 runs north-south in the project area, and runs through the City of South San Francisco,
extending from Los Angeles, through the City of South San Francisco, north to the State of
Washington.
I-280
I-280 runs north-south in the project area and provides regional connectivity, extending from the
City of San Francisco, through the City of South San Francisco, to the City of San José.
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I-380
I-380 runs east-west in the project area and provides local connectivity, extending from the South
Airport Sub-area in the City of South San Francisco, through the City of San Bruno, to I-280.
SR-82
SR 82 (also known as El Camino Real) runs north-south in the project area and provides regional
connectivity, extending from the City of San Francisco, through the City of South San Francisco,
to the City of San José.
Oyster Point Boulevard/Sister Cities Boulevard
Oyster Point Boulevard runs east-west to the north of the GOP 4 site. It is the eastward extension
of Sister Cities Boulevard, which is designated as a major arterial in the City’s General Plan. The
Oyster Point Boulevard/U.S. 101 interchange is the nearest freeway access to the GOP 4 site.
Gateway Boulevard
Gateway Boulevard runs southwest/northeast in the project area, extending south from Oyster
Point Boulevard to the San Francisco International Airport (SFO).
East Grand Avenue
East Grand Avenue runs east-west to the south of the GOP 4 site. East Grand Avenue is
designated in the City’s general plan as a major arterial, and extends from Point San Bruno Park
near the San Francisco Bay shoreline, west to U.S. 101, where it becomes Grand Avenue and
extends west to Mission Road.
Eccles Avenue
Eccles Avenue is a local street that runs northeast-southwest to the southeast of the GOP 4 site.
Eccles Avenue extents from Oyster Point Boulevard to Forbes Boulevard, just south of the GOP 4
site.
Bicycle and Pedestrian Facilities
Roadways within the project area include sidewalks. The GOP Master Plan area includes
pedestrian walkways that intersperse the overall site and connect to sidewalks along roadways in
the project vicinity.
Bicycle facilities in the project area include a Class II bicycle lane along the north and south sides
of Oyster Point Boulevard, which span east from the intersection of Gateway Boulevard and
Oyster Point Boulevard to the Oyster Point Marina area. A Class III bicycle route is located along
Gateway Boulevard that extends south from Oyster Point Boulevard to East Grand Avenue,
which provides access to the South San Francisco Caltrain Station, located approximately
0.3 miles to the west of the intersection of Gateway Boulevard and Grand Avenue. A pedestrian
plaza is provided on the east end of Grand Avenue underpass on the west side of the E. Grand
Avenue/Poletti Way intersection. Access to the existing Caltrain station is provided via Grand
Avenue to Dubuque Avenue. A metal staircase is provided at the northeast corner of Grand/
Dubuque for pedestrians to access the Caltrain station. The San Francisco Bay Trail is a Class I
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bicycle path located along the shoreline of the San Francisco Bay, to the north, east, and south of
the GOP 4 site. There is a Class I multi-use path, that connects the San Francisco Bay Trail to
Oyster Point Boulevard, at the intersection of Oyster Point and Veterans boulevards directly north
of the GOP 4 site.
The approved GOP Master Plan and GOP 5 projects have and will construct pedestrian
connections within the GOP Master Plan area, and a multi-modal trail connecting Oyster Point
Boulevard to Forbes Avenue.
Transit
The GOP 4 site is not served directly by regional rail, bus, or ferry services, but these transit
modes provide service to the City of South San Francisco, at varying distances from the GOP 4
site. First- and last-mile connections to regional transit services provide periodic access to the
project site.
Bay Area Rapid Transit (BART)
BART provides regional commuter rail service between San Francisco and the East Bay
(Pittsburg/Bay Point, Richmond, Dublin/Pleasanton and Fremont), as well as between San
Francisco and San Mateo County (SFO Airport and Millbrae). Weekday hours of operation are
currently between 5:00 AM and midnight. During the weekday PM peak period, headways are 5
to 15 minutes along each line. Within the City of South San Francisco, BART operates
underground. The closest BART station to the GOP 4 site is the San Bruno Station, located
approximately two miles southwest of the GOP 4 site, at South Huntington Avenue and Sneath
Lane.1 Transit connection to the project area is provided via SamTrans bus Route 130, which
stops nearest the GOP 4 site at the intersection of Airport Boulevard and Linden Avenue, and a
free Commute.org shuttle route (OPB), which operates Monday through Friday, during peak
commute times. BART trains operate on 15-minute headways during peak hours, and 20-minute
headways during off-peak hours.
Caltrain
Caltrain provides passenger rail service on the Peninsula between San Francisco and Downtown
San José with several stops in San Mateo County and Santa Clara County. Limited service is
available south of San José. Caltrain service headways during the AM and PM peak periods are
10 to 60 minutes, depending on the type of train. The peak direction of service is southbound
during the AM peak period and northbound during the PM peak period. The nearest Caltrain
station to the GOP 4 site is located at 590 Dubuque Avenue, an approximately 1-mile walk
southwest from the GOP 4 site. This station is currently a limited stop, providing service only
once per hour in either direction. Preliminary planning calls for service at the station to increase
by up to eight stops per hour by 2040.2 Peak period shuttle service is provided from the South
San Francisco Caltrain station to locations along Oyster Point Boulevard, via the Oyster Point
Caltrain Shuttle (OPC) provided by Commute.org.
1 Bay Area Rapid Transit, 2021. Bay Area Rapid Transit webpage; System map. Available:
https://www.bart.gov/system-map. Accessed November 11, 2021.
2 Caltrain Business Plan, May 2019.
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Caltrain is in the process of implementing a Modernization Program that will electrify the
railway. The electrification project is scheduled to be complete by 2022 and will upgrade rail
performance, improve operational efficiency, and result in higher capacity. For example, whereas
today Caltrain operates 10 trains per hour during peak periods, electrification will support an
increase to 12 trains per hour. Additionally, Caltrain is anticipating a “blended system,” with
California High Speed Rail trains running alongside Caltrain on the same tracks by 2040.
Electrification of Caltrain (and the associated improved travel times and frequencies), as well as
the introduction of High Speed Rail, may improve the GOP 4 site’s regional transit access.
San Mateo Transit District (SamTrans)
SamTrans operates bus and rail service in San Mateo County, through Caltrain. A couple of
SamTrans routes also serve the project area, but do not provide direct service to the East of 101
area. Those include Routes 292 and 397, which both stop near the intersection of Airport
Boulevard and Grand Avenue. AM peak hour headways are between 10 and 15 minutes, and PM
peak hour headways are 20 minutes.3,4 SamTrans riders may need to walk to the nearby South
San Francisco Caltrain station to access first- and last-mile connection shuttles provided by
Commute.org, for connecting transit closer to the GOP 4 site.
SamTrans is currently undergoing “Reimagine SamTrans,” a comprehensive operational analysis
(COA) to redesign the entire SamTrans system. As part of the COA, SamTrans is proposing to
extend Route 130 into the East of 101 area by continuing service east along Grand Avenue from
its present terminus at Linden Ave, north along Gateway Boulevard, and east on Oyster Point
Boulevard to the Oyster Point ferry terminal.
Commute.org
Commute.org is a joint powers agency (JPA) located in San Mateo County, and is comprised of
17 cities and towns, as well as the County of San Mateo.5 The agency provides transportation
demand management (TDM) programming and services to employers, residents, and commuters.
In the project area, Commute.org provides free first- and last-mile shuttle service connections
from regional transit stops to local business centers, Monday through Friday, during morning and
afternoon commute hours. The following Commute.org shuttle routes provide connectivity
between stops near the GOP 4 site and regional transit stops.
Oyster Point Caltrain Shuttle (OPC):
The Oyster Point Caltrain shuttle (OPC) operates from the South San Francisco Caltrain Station and
provides free service for all passengers, to offices and businesses along Oyster Point Boulevard.6
3 San Mateo Transit District (SamTrans), 2021. SamTrans website; Route 292 page. Available:
https://www.samtrans.com/schedulesandmaps/timetables/292.html. Accessed November 12, 2021.
4 San Mateo Transit District (SamTrans), 2021. SamTrans website; Route 397 page. Available:
https://www.samtrans.com/schedulesandmaps/timetables/397.html. Accessed November 12, 2021.
5 Commute.org, 2021. Commute.org webpage; About. Available: https://commute.org/about/. Accessed
November 12, 2021.
6 Commute.org, 2021. OPC – Oyster Point Caltrain (SSF Caltrain) webpage. Available:
https://commute.org/route/oyster-point-caltrain/. Accessed November 12, 2021.
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Oyster Point BART Shuttle (OPB)
The Oyster Point BART shuttle (OPB) operates from the South San Francisco BART Station and
provides service to offices and businesses along Oyster Point Boulevard.7
Oyster Point Ferry Shuttle (OPF)
The Oyster Point Ferry shuttle (OPF) connects riders from the South San Francisco Ferry
Terminal to businesses on Oyster Point Boulevard and Genesis Towers, as well as service to the
South San Francisco Caltrain Station.8
San Francisco Bay Ferry
The San Francisco Bay Ferry provides ferry commute service for East Bay residents who work in
South San Francisco, particularly in the Oyster Point area. The South San Francisco Ferry
Terminal is located approximately 0.8 miles east of the GOP 4 site, at Oyster Point Marina. Ferry
route connections to the South San Francisco Ferry Terminal are provided from Alameda and
Oakland, primarily serving travel to South San Francisco during morning peak commute times
and travel to East Bay during the afternoon peak commute times.9 First- and last-mile transit
connection from the San Francisco Ferry Terminal to the project site is provided via the Oyster
Point Ferry Shuttle (OPF) provided by Commute.org during peak morning and afternoon
commute times.
3.1.2 Regulatory Setting
Federal
There are no federal regulations applicable to the proposed project.
State
California Department of Transportation
The California Department of Transportation (Caltrans) owns and operates the State highway
system, which includes the freeways and State routes within California. In South San Francisco,
Caltrans maintains the freeways (U.S. 101 and I-280), and SR-82. Caltrans has mandated that an
impact on the freeway facility would occur if off-ramp queuing were to spill back into the
mainline or metered on-ramp queuing were to spill back into the arterial roadway. The passage of
Senate Bill 743 in Fall 2013 led to a change in the way that transportation impacts are measured
under CEQA. As of July 1, 2020, automobile delay and level of service may no longer be used as
the performance measure to determine the transportation impacts of land development projects
under CEQA. Instead, an alternative metric that supports the goals of Senate Bill 743 is required.
This requirement does not modify the discretion lead agencies have to develop their own
methodologies or guidelines, or to analyze impacts on other components of the transportation
system, such as walking, bicycling, transit, and safety.
7 Commute.org, 2021. OPB – Oyster Point BART (SSF BART) webpage. Available:
https://commute.org/route/oyster-point-bart/. Accessed November 12, 2021.
8 Commute.org, 2021. OPF – Oyster Point Ferry (SSF Ferry Terminal/Caltrain) webpage. Available:
https://commute.org/route/oyster-point-sf-bay-ferry/. Accessed November 12, 2021.
9 San Francisco Bay Ferry, 2021. San Francisco Bay Ferry website; South San Francisco Ferry Route page.
Available: https://sanfranciscobayferry.com/south-san-francisco-ferry-route. Accessed November 12, 2021.
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Senate Bill 743
Senate Bill 743 (SB 743), passed in 2013, required the OPR to develop new CEQA guidelines
that address traffic metrics under CEQA. As stated in the legislation, upon adoption of the new
guidelines, “automobile delay, as described solely by level of service or similar measures of
vehicular capacity or traffic congestion shall not be considered a significant impact on the
environment pursuant to this division, except in locations specifically identified in the guidelines,
if any.” OPR recently updated its CEQA Guidelines to implement SB 743 to require that VMT be
the primary metric used to identify transportation impacts. The VMT standard for evaluating
transportation impacts under CEQA became mandatory statewide on July 1, 2020.
VMT is defined as a measurement of miles traveled by vehicles within a specified region and for
a specified time period. VMT is a measure of the efficiency of land use patterns. VMT is
calculated based on individual vehicle trips generated and their associated trip lengths. VMT
accounts for two-way (round trip) travel and is estimated for a typical weekday to measure
transportation impacts. The City of South San Francisco’s VMT guidelines are consistent with
OPR’s recommendation of using VMT as a metric.
SB 743 also established CEQA exemptions for certain qualifying projects, which do not apply to
the proposed project. (PRC Section 21155.4)
Regional
San Mateo City/County Association of Governments
The San Mateo City/County Association of Governments (C/CAG) provides regional
coordination and guidance on issues relevant to transportation, air quality, stormwater runoff,
hazardous waste, solid waste and recycling, land use near airports, and abandoned vehicle
abatement. Member agencies of C/CAG include 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, and Woodside. C/CAG maintains programs and reports that
provide relevant policy guidance to the proposed project including the San Mateo County
Comprehensive Bicycle and Pedestrian Plan.
C/CAG is also the congestion management agency for San Mateo County. In this role, C/CAG
develops and maintains a countywide travel demand model. Travel models are tools that can be
used to project future transportation conditions, forecast the need for and potential effectiveness
of transportation projects and infrastructure improvements, and identify the impacts of land use
development. C/CAG licenses the countywide travel demand model for San Mateo County from
the Santa Clara Valley Transportation Authority (VTA), which maintains a travel demand model
that is optimized for the counties of Santa Clara and San Mateo and accounts for transportation
impacts from neighboring counties and regional commute sheds.
San Mateo County Comprehensive Bicycle and Pedestrian Plan
The San Mateo County Comprehensive Bicycle and Pedestrian Plan (SM CCBP) was adopted by
C/CAG and the San Mateo County Transportation Authority (SMCTA) in September 2011. This
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plan addresses the planning, design, funding and implementation of bicycle and pedestrian
projects of countywide significance. An update to the SM CCBP is presently under consideration.
Peninsula Traffic Congestion Relief Alliance
The Peninsula Traffic Congestion Relief Alliance (Alliance) is a joint powers authority (JPA)
which implements transportation demand management programs across San Mateo County. The
Alliance manages twenty-six shuttle routes in San Mateo County. In the City of South San
Francisco, the Alliance provides service to seven shuttle routes, which provide connectivity
between large employment areas and the South San Francisco Caltrain and BART stations, and
the South San Francisco Bay Ferry terminal, during peak commute periods.
Local
City of South San Francisco
General Plan
The City of South San Francisco General Plan provides goals, objectives, and policies that define
the City’s desired transportation and circulation function as it applies to current and future
conditions. The following goals and policies are relevant to the proposed project.
Transportation Element
Street System
Guiding Policy 4.2-G-12: Provide fair and equitable means for paying for future street
improvements including mechanisms such as development impact fees. (Amended by
Resolution 98-2001, adopted September 26, 2001)
Implementing Policy 4.2-I-5: Establish accessibility requirements for all streets designated
as arterial or collector on Figure 4-1. As part of development review of all projects along
these streets, ensure that access to individual sites does not impede through traffic flow.
Implementing Policy 4.2-I-7: Continue to require that new development pays a fair share of
the costs of street and other traffic and transportation improvements, based on traffic
generated and impacts on service levels. Explore the feasibility of establishing impact fee,
especially for improvements required in the Lindenville area. (Amended by Resolution 98-
2001, adopted September 26, 2001)
Implementing Policy 4.2-I-7a: Establish a traffic improvement fee to fund transportation
improvements in the East of 101 area. The fee should be updated to also fund enhancements
to pedestrian and bicycle infrastructure, consistent with the objectives of the Bicycle Master
Plan and Pedestrian Master Plan. (Amended by Resolution 98-2001, adopted September 26,
2001; and Resolution 27-2014, adopted February 12, 2014)
Implementing Policy 4.2-I-12: Develop policies and tools to improve South San Francisco’s
Complete Streets practices.
• Develop a pedestrian crossings policy, addressing matters such as where to place
crosswalks and when to use enhanced crossing treatments.
• Develop policies to improve the safety of crossings and travel in the vicinity of schools
and parks.
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• Develop a checklist for South San Francisco’s development and redevelopment projects,
to ensure the inclusion of infrastructure providing for safe travel for all users and enhance
project outcomes and community impact.
• As feasible, South San Francisco shall incorporate Complete Streets infrastructure into
existing public and private streets to improve the safety and convenience of Users,
construct and enhance the transportation network for each category of Users, and create
employment. (Amended by Resolution 136-2014, adopted December 10, 2014)
Alternative Transportation Systems
Guiding Policy 4.3-G-5: In partnership with employers, continue efforts to expand shuttle
operations.
Guiding Policy 4.3-G-6: In partnership with the local business community, develop a
transportation systems management plan with identified trip-reduction goals, while
continuing to maintain a positive and supportive business environment.
Implementing Policy 4.3-I-4: Require provision of secure covered bicycle parking at all
existing and future multifamily residential, commercial, industrial, and office/ institutional
uses. Secure parking means areas where bicycles can be secured to a non-movable rack to
prevent theft.
Pedestrian Circulation
Implementing Policy 4.3-I-6: Expand pedestrian facilities in new development, using the
Pedestrian Master Plan (PMP) for pedestrian design guidelines and to identify other
improvements that should be considered for projects proposed in areas that are identified in
PMP concept plans. (Amended by Resolution 26-2014, adopted February 26, 2014)
Implementing Policy 4.3-I-11: As part of any development in Lindenville or East of 101,
require project proponents to provide sidewalks and street trees as part of frontage
improvements for new development and redevelopment projects.
Transportation Demand Management
Implementing Policy 4.3-I-15: Adopt a TDM program or ordinance which includes, but is
not limited to, the following components:
• Methodology to determine eligibility for land use intensity bonuses for TDM programs
identified in the Land Use Element.
• Procedures to ensure continued maintenance of measures that result in intensity bonuses.
• Requirements for off-site improvements (such as bus shelters and pedestrian connections)
that are directly necessary as a result of development.
• Establishment of baseline TDM requirements for all new projects generating more than
100 peak period trips.
• Establishment of additional requirements for all new projects seeking a FAR bonus.
• An ongoing monitoring and enforcement program to ensure TDM measures are actually
implemented.
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• Reduce parking requirements for new projects implementing a TDM Program in
proximity to fixed guide way transit or those with demonstrated measures that would
reduce trip generation.
(Amended by Resolution 98-2001, adopted September 26, 2001)
Bicycle Master Plan
The South San Francisco Bicycle Master Plan (Bicycle Plan), adopted February 9, 2011, is
intended to guide the development of a comprehensive and integrated system of bikeways that
accommodates safer, more direct bicycle travel through residential neighborhoods, employment
and shopping areas, and to transit stops. As of the adoption of the Bicycle Mater Plan, the City
maintained approximately 48.3 miles of existing bikeways.
In the project area, the Bicycle Plan identified an existing Class II bicycle lane on Oyster Point
Boulevard, that extends east from Gateway Boulevard, and a Class III bicycle route along
Gateway Boulevard. The San Francisco Bay Trail is a Class 1 bicycle path located along the
shoreline of the San Francisco Bay, to the north, east, and south of the GOP 4 site. In the project
vicinity the Bicycle Plan identifies a proposed Class I multi-use path, that would connect the San
Francisco Bay Trail to Oyster Point Boulevard, at the Oyster Point Boulevard/Veterans Boulevard
intersection directly north of the project site. This travel route has been subsequently constructed.
The Bicycle Master Plan provides goals, objectives, and policies intended to make bicycle travel
accessible to the widest range of users. The following goals and policies have relevance to the
proposed project:
Goal 1: Promote and Encourage Bicycle Transportation
Policy 1.1: Integrate bicycle facility and planning into all of the City’s planning review
and construction activities, legitimizing bicycling as a transportation mode.
Implementing Measure 1.1-1: All Development projects shall be required to
conform to the Bicycle Transportation Plan goals, policies and implementation
measures.
Policy 1.2: Reduce reliance on travel by single occupant passenger vehicles.
Implementing Measure 1.2-1: All major developments shall be required to establish
and maintain a Transportation Demand Management Plan as prescribed in the South
San Francisco Municipal Code Title 20 Zoning Regulations.
Implementing Measure 1.2-2: All developments with approved Transportation
Demand Management Plans shall be required to prepare periodic reports as
prescribed in the South San Francisco Municipal Code Title 20 Zoning Regulations.
Goal 3: Improve Bicycle Access
Policy 3.2: Bicycle parking facilities should be provided at schools, parks and transit
stops, and shall be required to be provided at private developments including places of
work, commercial shopping establishments, parks, community facilities and other
bicyclist destinations.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-10 ESA / D202101143
City of South San Francisco January 2022
Traffic Calming Program
The City of South San Francisco has established an ongoing Traffic Calming program,
accompanied by a local Traffic Calming Plan. This program was developed to provide policies
and procedures that will act as guidelines to address traffic complaints related to excessive
speeding, cut-through traffic, and high vehicular volumes while maintaining pedestrian and
vehicular safety. The Traffic Calming Plan provides a toolkit for implementing solutions;
however, the City has no dedicated funding source for implementation at the present time.
City of South San Francisco Pedestrian Master Plan
The City of South San Francisco Pedestrian Master Plan (Pedestrian Plan) provides policies and
plans for the design, maintenance, and improvement of pedestrian facilities in the City of South
San Francisco, with a focus on access and connectivity. Figure 3-2 of the Pedestrian Plan
identified missing sidewalks in a citywide inventory, including segments of sidewalk near the
GOP 4 site. Eccles Avenue near the GOP 4 site, was identified as a roadway that needed
additional pedestrian facilities. Recommended improvements included the addition of pedestrian
facilities between the Bay Trail and the Oyster Point Boulevard/Veterans Boulevard intersection.
As described in the environmental setting, these facilities have already been constructed. The
Pedestrian Plan calls for a sidewalk along the south side of Oyster Point Boulevard, between
Dubuque Avenue and Gateway Boulevard. However, these facilities have not been constructed.
The Pedestrian Plan also provides goals and policies, the following of which are relevant to the
proposed project:
Goal 1: Promote and Encourage Walking
Policy 1.1: Integrate pedestrian facilities and planning into all of the City’s planning
review and construction activities, legitimizing walking as a transportation mode.
Implementation Measure 1.1-1: All development projects shall be required to
conform to the Pedestrian Master Plan goals, policies, and implementation measures.
Implementation Measure 1.1-2: All public and private street projects shall
incorporate pedestrian improvements and amenities.
Policy 1.2: Reduce reliance on travel by single occupant passenger vehicles.
Implementing Measure 1.2-1: All major developments shall be required to establish
and maintain a Transportation Demand Management Plan as prescribed in the South
San Francisco Municipal Code Title 20 Zoning Regulations.
Implementing Measure 1.2-2: All developments with approved Transportation
Demand Management Plans shall be required to prepare periodic reports as
prescribed in the South San Francisco Municipal Code Title 20 Zoning Regulations.
Policy 3.2: Pedestrian facilities and amenities should be provided at schools, parks and
transit stops, and shall be required to be provided at private developments including
places of work, commercial shopping establishments, parks, community facilities and
other pedestrian destinations.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-11 ESA / D202101143
City of South San Francisco January 2022
Implementing Measure 3.2-1: Amend the City’s Transportation Demand
Management Ordinance to clarify and quantify the requirements for pedestrian
amenities and facilities within individual development projects and access to other
destinations (i.e., connections to transit, safe crossing treatments for pedestrians, and
continuous sidewalks).
South San Francisco Transportation Demand Management Ordinance
The City of South San Francisco Transportation Demand Ordinance (1432-2010, Section 2)
establishes a performance target of 28 percent minimum alternative mode share for all
nonresidential projects resulting in more than 100 average daily trips and identifies a higher
threshold for projects requesting a floor area ratio bonus.
All projects are required to submit annual mode share surveys and floor area ratio bonus project
sponsors are required to submit triennial reports assessing project compliance with the required
alternative mode share target. Where targets are not achieved, the report must include program
modification recommendations and City officials may impose administrative penalties should
subsequent triennial reports indicate mode share targets remain unachieved.
3.1.1 Analysis, Impacts and Mitigation
Significance Criteria
For purposes of this Draft SEIR and consistent with the criteria presented in Appendix G of the
State CEQA Guidelines, impacts related to transportation and traffic are considered significant if
the proposed project would result in the following:
• Conflict with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadway, bicycle, and pedestrian facilities;
• Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision b) related to
VMT;
• Substantially increase hazards due to a geometric design feature e.g., sharp curves or
dangerous intersections) or incompatible land uses e.g., farm equipment); or
• Result in inadequate emergency access.
VMT Threshold of Significance
Section 15064.3, subdivision b) of the State CEQA Guidelines outlines criteria for analyzing
transportation impacts. Subpart 4) of subdivision b) identifies that a lead agency has discretion to
choose the most appropriate methodology to evaluate a project’s VMT, including whether to
express the change in absolute terms, per capita, per household or in any other measure.
According to the City of South San Francisco’s VMT guidelines, a significant impact would
occur for employment generating projects if the baseline project-generated home-based work
(HBW) VMT per employee is higher than 85 percent of the existing nine-county Bay Area-Wide
average for employee VMT. According to the C/CAG – VTA Travel Demand Model, the existing
Bay Area-wide regional average daily VMT per employee is 14.2. With the 15 percent reduction
factor, the average daily HBW VMT per employee threshold is 12.1 (see Table 3.1-1, Home-
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-12 ESA / D202101143
City of South San Francisco January 2022
Based Work Vehicle Miles Traveled per Employee Thresholds).10 The 2040 cumulative Bay
Area-wide regional average daily VMT per employee is 14.6, so the threshold is an average daily
HBW VMT per employee of 12.4 for cumulative conditions.11
TABLE 3.1-1
HOME-BASED WORK VEHICLE MILES TRAVELED PER EMPLOYEE THRESHOLDS
Location Estimated HBW VMT Estimated Employees
Estimated HBW VMT
per Employee
Bay Area Region (Existing) 63,336,200
4,461,670 14.2
VMT Reduction Factor -15%
HBW VMT Per Employee Threshold 12.1
Bay Area Region
(2040 Cumulative) 78,980,240
5,406,190 14.6
VMT Reduction Factor -15%
HBW VMT Per Employee Threshold 12.4
Source: Fehr & Peers, 2020; C/CAG-VTA Bi County Transportation Demand Model, 2019; as used in Hexagon, 2021.
Methodology and Assumptions
VMT Analysis
Project-generated HBW VMT per employee is estimated based on the HBW VMT for the
project’s transportation analysis zone (TAZ) in the C/CAG – VTA travel demand model. A TAZ
is the smallest resolution available in the C/CAG – VTA model. Each TAZ included in the model
contains information related to the existing and proposed land uses and transportation options in
that zone. Therefore, the transportation properties of the project’s TAZ are an appropriate proxy
for transportation properties of the project itself.
A significant project impact would occur under the following conditions.
• If the existing HBW VMT per employee in the travel demand model TAZ that encompasses
the project is greater than 12.1 under existing conditions.
• If the 2040 HBW VMT per employee in the travel demand model TAZ that encompasses the
project is greater than 12.4 under cumulative conditions.
The existing land use and transportation characteristics of the East of 101 area contribute to the East
of 101 area’s higher-than-average VMT per employee. As a single-use employment center, all
homebased trips begin or end outside the East of 101 area, requiring longer travel along auto-
oriented roadways. Longer trips also result from the fact that South San Francisco, and especially
the East of 101 area, is bounded by the Bay on its eastern side, further limiting the locations where
housing could be located. Also, transit service to the area is limited. As a result, all employment-
based uses in the East of 101 area are likely to have longer commute trips compared to average
10 Fehr & Peers 2020; C/CAG-VTA Bi-County Transportation Demand Model, 2019 in Hexagon, 2021 (see
Appendix C)
11 Fehr & Peers 2020; C/CAG-VTA Bi-County Transportation Demand Model, 2019 in Hexagon, 2021 (see
Appendix C)
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-13 ESA / D202101143
City of South San Francisco January 2022
HBW trips in the Bay Area. However, it should be noted that the higher-than-average VMT per
employee is not unique to South San Francisco and is common for many cities in the peninsula.
Impacts and Mitigation Measures
Impact 3.1-1: The proposed project would not conflict with a program, plan, ordinance, or
policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian
facilities. (Less than Significant)
The proposed project does not alter bicycle or pedestrian access, or transportation system access
approved as part of the GOP 4 Precise Plan in August 2020. The proposed project adds only 321
employees, which are not anticipated to overwhelm the already-approved pedestrian and bicycle
facilities, or transit facilities.
A significant impact would occur if the proposed project conflicted with applicable or adopted
policies, plans or programs related to pedestrian facilities or otherwise decreased the performance
or safety of pedestrian facilities. The GOP Master Plan project would develop a pedestrian-
friendly Central Commons open space in the area created by the parking structures and the office
buildings. The master plan would enhance public street frontages and foster transit use by
providing multiple pedestrian connections to and from the internal campus and shuttle system
stops. The proposed project would be compatible with the GOP Master Plan project and the
existing GOP 4 Precise Plan. Therefore, the proposed project would not have a detrimental
impact to pedestrian circulation.
Bicycle access to the proposed project is provided via the bicycle lanes on Oyster Point
Boulevard and the bike route on Gateway Boulevard. As part of the GOP 5 project, the existing
rail spur that separates the GOP 4 and 5 sites would be redeveloped into a multi-use trail. This
multi-use trail would provide an additional connection between the Class II bicycle lanes on
Oyster Point Boulevard and the existing multi-use trail on Forbes Boulevard. As a result, the
proposed project would not conflict with existing and planned bicycle facilities.
The proposed project is expected to generate trips via transit services, which can be
accommodated by the existing/planned transit capacity. According to OPR guidelines, the
addition of new transit riders should not be treated as an adverse impact as such development also
improves regional flow by adding less vehicle travel onto the regional network. Therefore, the
proposed project would not have a detrimental impact to transit service.
For the reasons presented above, the proposed project would not conflict with a program, plan,
ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and
pedestrian facilities, and this impact is considered less than significant. No new or substantially
more severe impacts would occur than analyzed in the EIR.
Mitigation Measure
None required.
________________________________
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-14 ESA / D202101143
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Impact 3.1-2: The proposed project would conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision b) related to VMT. (Significant and Unavoidable)
According to the City of South San Francisco’s VMT guidelines, a significant impact would
occur for employment generating projects if the baseline project-generated HBW VMT per
employee is higher than 85 percent of the existing nine-county Bay Area-Wide average for
employee VMT. Based on the C/CAG – VTA travel demand model, the VMT per employee for
the proposed project would be 16.2 under existing conditions (see Table 3.1-2, Project VMT
Impact Determination), which is above the threshold of 12.1 for existing conditions. Under
cumulative 2040 conditions, the VMT per employee for the proposed project would be 12.9,
which is above the threshold of 12.4 for cumulative conditions. Therefore, the proposed project
would result in a significant impact with respect to VMT under existing and cumulative conditions.
TABLE 3.1-2
PROJECT VMT IMPACT DETERMINATION
Location Estimated
HBW VMT
Estimated
Employees
Estimated
HBW VMT per
Employee
VMT per
Employee
Threshold
VMT Impact
Project (Existing) 5,194 321 16.2 12.1 Yes
Project (2040 Cumulative) 4,136 321 12.9 12.4 Yes
Source: Fehr & Peers 2020; C/ CAG-VTA Bi-County Transportation Demand Model, 2019.
The TDM program prepared for the GOP Master Plan project was designed to achieve a
40 percent non-drive alone mode share during peak periods under the City’s current TDM
requirements and policy direction to reduce single-occupant vehicle trips. A discussion of the
TDM program for the GOP Master Plan project is provided in Chapter 2, Project Description. As
the additional R&D space associated with the proposed project would become part of the GOP
Master Plan project and is expected to generate more than 100 average daily trips, the proposed
project would be subject to this TDM program.
Based on U. S. Census Bureau, 2006-2010 American Community Survey, the non-drive alone
mode share for commute trips in San Mateo County is 29 percent. The proposed project will be
required to achieve a 40 percent non-drive alone mode share, which represents an additional
11 percent reduction in non-drive alone mode share from baseline conditions.
However, reductions in non-drive alone mode share are not necessarily interchangeable with
VMT reductions on a percentage point for percentage point basis because mode share targets do
not necessarily correlate with trip generation and trip length. Although many East of 101 area
employers meet their non-drive alone mode share targets, and while trip generation is lower than
ITE rates due to TDM programs, vehicle trip generation and trip lengths in this area are slightly
higher than regional averages based on the C/CAG – VTA travel demand model outputs.
Therefore, project HBW VMT per employee was not adjusted based on the GOP Master Plan
TDM plan, and the impact with respect to VMT would be potentially significant.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-15 ESA / D202101143
City of South San Francisco January 2022
Mitigation Measures
Mitigation Measure 3.1-1: First- and Last-Mile Transit Connections and Active
Transportation Improvements
First- and last-mile transit connections and active transportation improvements are likely
to yield the greatest VMT reductions. These measures would not only serve the density
transfer project but also the entire GOP Master Plan area and all of the existing and
planned development in the area. Thus, the new VMT generated by the project would be
partially offset by reductions in VMT for other development. The following mitigation
measures support and enable the first-and last-mile non-auto commute strategies in the
GOP Master Plan TDM Plan. The mitigation measures described below are appropriate
under both existing plus project conditions and cumulative plus project conditions. These
improvements are shown on Figure 3.1-1, Mitigation Measure Improvements.
a) The project applicant has acquired the rail spur property adjacent to the GOP 4 site
and shall use it to connect the GOP Master Plan area with the 475 Eccles site, which
is currently referred to as GOP Phase 5, approved for two office/R&D buildings
totaling 262,287 square feet and one parking structure. The applicant proposes to
develop the rail spurs into a publicly accessible multi-use path connecting Oyster
Point Boulevard with Forbes Boulevard, with pedestrian amenities, all to implement
the City’s draft “rails to trails” plan. A grand staircase allowing access from the lower
elevation of the GOP Master Plan area to the higher elevation of the 475 Eccles site
is also proposed. The applicant shall construct these improvements. This multi-use
path shall connect to Class II bicycle lanes on Oyster Point Boulevard and to the
multi-use trail on Forbes Boulevard.
b) The applicant shall construct crossings at the northern and southern ends of the multi-
use path required by paragraph (a) above, at Forbes Boulevard and Oyster Point
Boulevard, in the configuration determined necessary by the City Engineer for
bicycle access from those streets to the multi-use path.
c) The applicant shall use good faith efforts to obtain all approvals and consent required
to install the improvements required by paragraphs (a) and (b) above, including the
use of any necessary land owned by the applicant or its affiliates. Each improvement
shall be constructed by the later of (i) issuance of the first certificate of occupancy for
any portion of the 120,221 square-foot expansion in GOP 4, or (ii) such time as
public agencies have granted all necessary approvals for the mitigation improvement
and the applicant has been given the right to construct on any land owned by others
that is necessary for the mitigation improvement.
Significance After Mitigation
Implementation of the actions listed in Mitigation Measure 3.1-1 include improvements that
support and enable the first- and last-mile non-auto commute strategies, which would be
anticipated to increase the use of alternative modes by project employees, in place of single-
occupant vehicle travel, thus reducing HBW VMT. However, the mitigation measure’s
effectiveness is unknown and may not reduce the project’s HBW VMT below the existing and
cumulative thresholds to reach a less-than-significant conclusion. Therefore, the project’s effect
on VMT would be significant and unavoidable.
________________________________
South
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BioMed GOP4 Master Plan Focused SEIR
FIGURE 3.1-1
MITIGATION MEASURE IMPROVEMENTS
SOURCE: Hexagon, 2021
N Not to scale
= GOP Master Plan Boundary
= Trail Pathway
= GOP 4
= GOP 5
LEGEND
Notes:
Construct a new multi-use trail within the GOP Master Plan connecting Oyster Point Boulevard to the north and Forbes Boulevard to the south.
Pay fair-share contribution towards upgrades to trail connection between the new multi-use trail and Grand Avenue/E Grand Avenue.
1
2
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-17 ESA / D202101143
City of South San Francisco January 2022
Impact 3.1-3: The proposed project would not substantially increase hazards due to a
geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible
land uses (e.g., farm equipment). (No Impact)
The proposed project would increase the intensity of planned uses on the GOP 4 site, but would
not include the introduction of new land uses or changes to the GOP 4 Precise Plan. A project
safety impact is considered significant if the proposed project would provide inadequate design
features that present safety concerns within the project site or on the adjacent streets. The
proposed project would not alter any design components of the recently approved GOP Phase 4
Precise Plan. Therefore, the proposed project would not substantially increase hazards due to a
geometric design feature or incompatible land uses, and no impact would occur. No new or
substantially more severe impacts would occur than analyzed in the EIR.
Mitigation Measure
None required.
________________________________
Impact 3.1-4: The proposed project would not result in inadequate emergency access. (Less
than Significant)
The proposed project would not reroute or change any of the city streets in its vicinity that would
impact emergency vehicle access to the GOP 4 site, and would not alter the emergency access
approved as part of the GOP 4 Precise Plan in August 2020. Access to GOP 4 site would be
provided via driveways along Oyster point Boulevard and Gateway Boulevard. Park Street, a new
internal access roadway would be constructed along the east side of the parking garages and
would connect to Oyster Point Boulevard to the north and Gateway Boulevard to the south. The
emergency vehicles would utilize all entries and supplemental access points as necessary to reach
Park Street and the central pedestrian walkway which would be wide enough to serve as an
emergency vehicles route. Thus, the proposed project would not result in inadequate emergency
access, and this impact is considered less than significant. No new or substantially more severe
impacts would occur than analyzed in the EIR.
Mitigation Measure
None required.
________________________________
Cumulative Impacts
Impact 3.1-5: Implementation of the proposed project, in combination with other
development, could contribute to cumulative conditions where VMT per capita or VMT per
employee could exceed 85 percent of the 2040 cumulative Bay Area-wide regional average
daily VMT per employee. (Significant and Unavoidable)
The analysis in Impact 3.1-2 described how the proposed GOP 4 Density Transfer project would
result in a significant unavoidable impact, as the daily VMT per employee within the 120,221
square foot expansion proposed by the density transfer project would be 16.2 under existing
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.1-18 ESA / D202101143
City of South San Francisco January 2022
conditions, which exceeds the Bay Area-wide regional average threshold of 12.1 daily VMT per
employee for existing conditions.
The C/CAG - VTA Travel Demand Model was used to identify the 2040 cumulative Bay Area-
wide regional average daily VMT per employee. The 2040 cumulative Bay Area-wide regional
average daily VMT per employee is 14.6, so the cumulative threshold is 12.4 daily VMT per
employee, with the 15 percent VMT reduction factor. The methodologies for conducting this
analysis are identical to the ones described above, but rather than add the proposed project to the
existing conditions scenario, the project was added to the future-year scenario, designed to
represent 2040 conditions. As shown in Table 3.1-2, the proposed project’s daily VMT per
employee would be 12.9, which would exceed the cumulative threshold.
As discussed in Impact 3.1-2, the GOP Master Plan project is required to implement a TDM
program designed to achieve a 40 percent non-drive alone mode share during peak periods under
the City’s current TDM requirements and policy direction to reduce single-occupant vehicle
trips. Because the proposed project would become part of the GOP Master Plan project and is
expected to generate more than 100 average daily trips, the proposed project would be
subject to this TDM program. However, reductions in non-drive alone mode share are not
necessarily interchangeable with VMT reductions on a percentage point for percentage point
basis because mode share targets do not necessarily correlate with trip generation and trip
length. Although many East of 101 area employers meet their non-drive alone mode share
targets, and while trip generation is lower than ITE rates due to TDM programs, vehicle trip
generation and trip lengths in this area are slightly higher than regional averages based on the
C/CAG travel demand model outputs. Therefore, project HBW VMT per employee was not
adjusted based on the GOP TDM plan, and would be cumulatively considerable.
Because the proposed project has no impact relating to circulation system plans (Impact 3.1-1) and
hazards (Impact 3.1-3), it would not contribute towards any cumulative impacts related to those
resources.
Mitigation Measures
Implement Mitigation Measure 3.1-1: First- and Last-Mile Transit Connections and Active
Transportation Improvements.
Significance After Mitigation
Implementation of these mitigation measures include improvements that support and enable the
first- and last-mile non-auto commute strategies, which would be anticipated to increase the use
of transit by Project employees, in place of single-occupant vehicle travel, thus reducing HBW
VMT. This mitigation could be anticipated to benefit cumulative development in the project area,
as employees from surrounding uses could be anticipated to utilize those connections and
improvements. However, the mitigation measure’s effectiveness is unknown and may not reduce
the project’s cumulatively considerable HBW VMT below the cumulative thresholds to reach a
less-than-significant level. Therefore, the project’s effect on VMT would be cumulatively
considerable, thus resulting in a significant and unavoidable impact.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.2-1 ESA / D202101143
City of South San Francisco January 2022
3.2 Other Resource Topics
3.2.1 Resource Topics addressed in the EIR
The environmental impacts discussed and analyzed below include impacts specific to the GOP 4
Density Transfer project, the GOP Master Plan project, and cumulative impacts. This analysis
addresses the impacts of the proposed project, and analyzes whether the project would trigger any
changes to the conclusions in Resolution 2858-2020 determining that the GOP 4 Precise Plan was
fully within the scope of the 2010 EIR, that the 2020 Addendum prepared for GOP 4 was the
appropriate environmental document for the project, and confirming the continued applicability
of the MMRP for the project.
The mitigation measures, as set forth in the MMRP attached to Resolution 2858-2020, are
applicable to all phases of the GOP Master Plan project and will be implemented in connection
with the GOP 4 Density Transfer project insofar as they are relevant.
Aesthetics
The EIR determined that with mitigation neither the GOP Master Plan project nor the GOP 4
Precise Plan would have created significant impacts with respect to aesthetics. The proposed
project proposes construction of a structure (GOP 4 north) that is four-stories higher than
contemplated in the GOP 4 Precise Plan approved in 2020. However, at 178 feet total (with the
additional four stories), this structure would conform to the 250-foot building height limitation
provided in the GOP Master Plan criteria. In addition, the taller northern building on the GOP 4
site would provide a transition between the 12-story structure to the northwest that was
constructed during GOP Phase 1 and the five-story southern building on the GOP 4 site to the
south. The proposed project would also be subject to mitigation measures found in Resolution
2858-2020 that reduce impacts with respect to light and glare. As a result, the change in impacts
with regard to aesthetics would be immaterial.
There has been no substantial change in surrounding circumstances or new information with
respect to aesthetics since the 2010 EIR was approved that show new or more severe significant
impacts. Based on the discussion above, no new or more severe significant impacts to aesthetics
are anticipated beyond those anticipated and analyzed in the 2010 EIR. Thus, in accordance with
Sections 15162 and 15163 of the State CEQA Guidelines, no additional environmental review is
required.
Agricultural Resources
The EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan would
have created significant impacts with respect to agricultural resources. The GOP 4 site does not
include any agricultural resources; this circumstance has not changed since approval of the 2010
EIR, and the proposed project does not include any changes to the area of ground disturbance.
Thus, in accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no additional
environmental review is required.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.2-2 ESA / D202101143
City of South San Francisco January 2022
Air Quality
Operational emissions of the proposed project are addressed in a report prepared by Ramboll,
which is attached as Appendix D. As demonstrated in that report, the proposed project will not
trigger any new or more severe air quality impacts. In general, due to emissions reductions in the
vehicle fleet as well as a more efficient building design standards contained in the California
Building Energy Efficiency Standards (Title 24, Parts 6 and 11), the operational emissions
associated with the GOP Master Plan project as modified by the proposed project are well below
the net operational emissions that were estimated for the GOP Master Plan project as part of the
EIR. Details are discussed below.
The 2010 EIR determined that construction emissions associated with the GOP Master Plan
project and the GOP 4 Precise Plan would have resulted in a significant and unavoidable impact
with mitigation. The proposed project would incrementally increase the short-term emissions
generated during construction. The proposed project would be subject to numerous mitigation
measures found in the Resolution 2858-2020, conditions of approval, and requirements of the
Bay Area Air Quality Management District (BAAQMD). These include condition A.14, which
requires that the developer provide the City with a Health Risk Assessment (HRA) report,
acceptable to the City, evaluating the impact of toxic air contaminants resulting from demolition
and construction of the project on nearby sensitive receptors. However, even with these measures
in place, the construction of additional space associated with the proposed project could still
adversely affect nearby sensitive receptors. The proposed project would increase the total amount
of R&D space allowed within the GOP Master Plan area by 9.8 percent. However, this increase is
not substantial, and thus no change in the severity of this impact is anticipated.
The 2010 EIR determined that because the GOP Master Plan project included a General Plan
Amendment that would increase VMTs compared to those associated with the General Plan in
effect at the time, it would therefore conflict with the applicable air quality plan. It further
determined the GOP Master Plan project would exceed BAAQMD thresholds for respirable
particulate matter (PM10). The U.S. Environmental Protection Agency has established federal
ambient air quality standards for six of the most common air pollutants— carbon monoxide (CO),
lead (Pb), ground-level ozone (O3), particulate matter (PM) in size fractions of 10 microns or less
in diameter (PM10) and 2.5 microns or less in diameter (PM2.5), nitrogen dioxide (NO2), and
sulfur dioxide (SO2)—known as “criteria” air pollutants (or simply “criteria pollutants”). In
addition, California has also established state ambient air quality standards for criteria pollutants,
which in some cases are more stringent than the national standards. The Bay Area Basin is
considered “nonattainment” for federal ambient air quality standards for ozone, whose precursors
are reactive organic gases (ROG) and oxides of nitrogen Oxides (NOx), and is considered
“nonattainment” for State ambient air quality standards for ozone and PM10. As shown in
Table 3.2-1, Summary of Operational Emissions – Criteria Air Pollutants, emissions of these
pollutants associated with GOP Master Plan project as modified by the proposed project would be
well below the emissions of these pollutants associated with the GOP Master Plan project that
was evaluated in the 2010 EIR. As a result, operational emissions associated with the additional
space added by the proposed project would not cause new or more severe air quality impacts.
3. Environmental Setting, Impacts, and Mitigation Measures
Gateway of the Pacific 4 Density Transfer Project 3.2-3 ESA / D202101143
City of South San Francisco January 2022
TABLE 3.2-1
SUMMARY OF OPERATIONAL EMISSIONS – CRITERIA AIR POLLUTANTS
Criteria Air Pollutant Emissions (lbs/day)
ROG NOX PM10
Original GOP Project 44.8 59.4 151.4
Modified GOP Project 26.5 44.1 41.9
Difference -18.3 -15.3 -109.5
Source: Ramboll, 2021.
The 2010 EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan
would have created a significant impact with respect to exposing sensitive receptors to substantial
pollutants. Vehicle trips associated with the proposed project would result in an incremental
increase in emissions of CO and toxic air contaminants. The proposed project would increase the
total amount of R&D space allowed within the GOP Master Plan area by 9.8 percent. However,
this increase is not substantial, and thus no change in the severity of this impact is anticipated.
There has been no substantial change in surrounding circumstances or new information with
respect to air quality since the 2010 EIR was approved that show new or more severe significant
impacts. Accordingly, no new or more severe significant impacts to air quality are anticipated
beyond those anticipated and analyzed in the EIR. Thus, in accordance with Sections 15162 and
15163 of the State CEQA Guidelines, no additional environmental review is required.
Biological Resources
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the
GOP 4 Precise Plan would have created significant impacts with respect to biological resources.
The proposed project will not alter any impacts to biological resources, as it proposes no change
in grading and no change in ground-level activities. The GOP 4 site has been developed with
warehouse distribution and office uses for decades and, as discussed in the 2010 EIR, does not
provide any habitat of high biological value. The proposed project is subject to mitigation
measures requiring pre-construction surveys for nesting birds, special-status birds and/or raptors,
and compliance with local tree protection ordinances. These measures will help ensure that the
proposed project will not alter the impacts to biological resources.
There has been no substantial change in information or the circumstances regarding the GOP 4
site or the surrounding East of 101 area since the 2010 EIR was approved that would affect
biological resources. Accordingly, no new or more severe significant impacts to biological
resources are anticipated beyond those anticipated and analyzed in the 2010 EIR. Thus, in
accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no additional
environmental review is required.
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Cultural Resources
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the GOP 4
Precise Plan would have created significant impacts with respect to cultural resources. The
proposed project will not affect cultural resources, as it proposes no change in grading or ground
disturbance activities. The GOP 4 site includes fill imported from unknown locations, and has
already been extensively disturbed for development. The 2010 EIR determined that the area did not
contain any recorded historic or archaeological resources. It further explained that the area was
initially impacted by development late in the nineteenth century, and noted that past development
and placement of fill have significantly reduced the archaeological potential of the GOP Master
Plan area. The proposed project is subject to mitigation measures requiring that specific actions be
taken if previously unknown cultural or archeological resources, or human remains, are discovered
during excavation that are found, as required by Resolution 2858-2020. These measures will help
ensure that the proposed project will not alter the impacts to cultural resources.
There has been no substantial change to the circumstances regarding the GOP 4 site since the
2010 EIR was approved that would show new or more severe impacts. Construction of Phase 1
revealed only the railroad spurs mentioned in the 2010 EIR, and did not uncover any previously
unknown significant cultural resources. In addition, construction in the surrounding East of 101
area has not revealed any significant finds that would affect the 2010 EIR’s analysis of the GOP
Master Plan project or the GOP 4 Precise Plan. Accordingly, no new or more severe significant
impacts to cultural impacts are anticipated beyond those anticipated and evaluated in the 2010
EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no
additional environmental review is required.
Geology and Soils
The EIR determined that with mitigation neither the GOP Master Plan project nor the GOP 4
Precise Plan would have created significant impacts with respect to geology and soils. The
proposed project will not affect geological or soil resources, as it proposes no change in grading
and no change in construction or activities other than the addition of four floors to the approved
building footprint. As discussed in the 2010 EIR, GOP Master Plan area is not within the Alquist-
Priolo Earthquake Fault Zone boundary, is not within a liquefaction hazard zone, and that while
the Hillside Fault may cross the GOP Master Plan area, this fault has not shown evidence of
activity for at least the past 2 million years. The proposed project is subject to mitigation
measures imposed under Resolution 2858-2020 and conditions of approval requiring compliance
with building codes, other regulatory requirements, and recommendations of licensed
geotechnical engineers, which are all designed to protect against any remaining risk of seismic
shaking, landslide or soil erosion. These measures will help ensure that the proposed project will
not materially alter impacts to geologic and soil resources.
There has been no substantial change in surrounding circumstances or new information since the
2010 EIR was approved that show new or more severe impacts. The construction of Phases 1, 2
and 3 has not revealed any unanticipated issues relating to geology and soils. Accordingly, no
new or more severe significant impacts are anticipated beyond those anticipated and analyzed in
the EIR. In addition, the California Supreme Court made clear, in California Building Industry
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Assn. v. Bay Area Air Quality Management District, (2015) 62 Cal.4th 369, that the impacts of
existing soil conditions on a project are not within the purview of CEQA. Thus, in accordance
with Sections 15162 and 15163 of the State CEQA Guidelines, no additional environmental
review is required.
Greenhouse Gases and Climate Change
Greenhouse gas (GHG) emissions are addressed in a report prepared by Ramboll, which is
attached as Appendix D. As demonstrated in that report, the proposed project will not trigger any
new or more severe GHG emissions impacts. In general, due to emissions reductions in the
vehicle fleet as well as a more efficient building design standards contained in the California
Building Energy Efficiency Standards (Title 24, Parts 6 and 11), the GHG emissions associated
with the GOP Master Plan project as modified by the proposed project are well below the net
operational emissions that were estimated for the original GOP Master Plan project as part of the
2010 EIR. Details are discussed below.
The 2010 EIR determined that neither the original GOP Master Plan project nor the GOP 4
Precise Plan would have created significant impacts with respect to GHG emissions. The
proposed project would achieve a LEED Silver or better rating, and be designed to meet South
San Francisco Municipal Code standards and California Building Energy Efficiency Standards
(Title 24, Parts 6 and 11), which would reduce GHG emissions associated with the operation of
the buildings. As shown in Table 3.2-2, Summary of Operational Emissions – Greenhouse Gas
Emissions, GHG emissions associated with the GOP Master Plan project as modified by the
proposed project would be well below GHG emissions associated with the original GOP Master
Plan project evaluated in the EIR. As a result, GHG emissions associated with the additional
space added by the proposed project would not cause new or more severe GHG impacts.
TABLE 3.2-2
SUMMARY OF OPERATIONAL EMISSIONS – GREENHOUSE GAS EMISSIONS
CO2e Emissions
(metric tons/year)
Original GOP Project 19,909
Modified GOP Project 13452
Difference -6,457
Source: Ramboll, 2021.
Based on the discussion above, no new or more severe significant impacts with respect to GHG
emissions are anticipated beyond those anticipated and analyzed in the EIR. Thus, in accordance
with Sections 15162 and 15163 of the State CEQA Guidelines, no additional environmental
review is required.
Hazards and Hazardous Materials
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the
GOP 4 Precise Plan would have created significant impacts with respect to hazards and hazardous
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materials. The GOP 4 site formerly hosted many industrial uses that involved hazardous
materials. The approval of the GOP Master Plan project and the GOP 4 Precise Plan included
imposition of numerous mitigation measures imposed by Resolution 2858-2020 and conditions to
address the potential for hazardous materials to be encountered. As expected, hazardous materials
were encountered during excavation for earlier phases, and these were and are being handled
pursuant to the requirements of the mitigation measures and conditions. The proposed project will
not affect the amount of excavation. The additional mitigation measures that were imposed on the
GOP Master Plan project and the GOP 4 Precise Plan are intended to reduce the risk of handling
hazardous materials during operation of R&D businesses. The proposed project remains subject
to these measures and to laws and regulations regarding the handling of hazardous materials.
There has been no substantial change in surrounding circumstances or new information related to
hazards and hazardous emissions since the 2010 EIR was approved that would create new or
more severe impacts. Based on the discussion above, no new or more severe significant impacts
from hazards and hazardous materials are anticipated beyond those anticipated and analyzed in
the EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no
additional environmental review is required.
Hydrology and Water Quality
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the
GOP 4 Precise Plan would have created significant impacts with respect to hydrology and water
quality. The proposed project would not alter any impacts related to hydrology or water quality,
as it includes no changes to grading, building footprints, stormwater systems, or water quality
protections. Further, the proposed project would be subject to numerous mitigation measures
imposed by Resolution 2858-2020 and conditions of approval regarding stormwater management
and water quality protections that also will ensure no material change in impact conclusions.
There has been no substantial change in surrounding circumstances or new information related to
hydrology and water quality since the 2010 EIR was approved. Accordingly, no new or more
severe significant impacts to hydrology or water quality are anticipated beyond those anticipated
and analyzed in the EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA
Guidelines, no additional environmental review is required.
Land Use and Planning
The 2010 EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan
would have created significant impacts with respect to land use as they would have implemented
prior city plans for R&D/office development in the area. The proposed project includes changes
to the General Plan and zoning, but these changes would merely transfer density that is already
allowed to an adjacent location, and therefore would not materially affect land use or planning
resources. The proposed project would conform to all of the development standards in the GOP
Master Plan project except for the proposed increase in FAR, and would otherwise be consistent
with all land use plan and regulations that are applicable to the GOP 4 site. The proposed change
in FAR would be used to increase the height on previously-approved R&D buildings and
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associated parking structure, with no substantive change in architecture. As a result, impacts with
respect to land use and planning would not change materially.
There has been no substantial change in surrounding circumstances or new information since the
2010 EIR was approved that show new or more severe impacts. Based on the discussion above,
no new or more severe significant impacts to land use and planning are anticipated beyond those
anticipated and analyzed in the EIR. Thus, in accordance with Sections 15162 and 15163 of the
State CEQA Guidelines, no additional environmental review is required.
Mineral Resources
The 2010 EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan
would have created significant impacts with respect to mineral resources. The GOP 4 site does
not include any mineral resources, and this circumstance has not changed since approval of the
2010 EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no
additional environmental review is required.
Noise
The 2010 EIR determined that construction noise associated with the GOP Master Plan project
and the GOP 4 Precise Plan would have resulted in a significant and unavoidable impact with
mitigation as construction noise would have interfered with the operation of an onsite childcare
center that would have been in operation during the first phase of the GOP Master Plan project.
The proposed project would generate noise during construction, and would be subject to a
mitigation measure found in Resolution 2858-2020 that would ensure that detailed, site specific
noise attenuation measures are implemented. The onsite childcare center has since closed, and the
significant and unavoidable construction noise impact associated with the child care center is no
longer an issue. Therefore, noise generated during the construction of the additional space
associated with the proposed project would not adversely affect nearby sensitive receptors.
The EIR determined that with mitigation neither the GOP Master Plan project nor the GOP 4
Precise Plan would have created a significant impact with respect to vibration generated during
construction. The proposed project may incrementally increase the vibration generated during
construction, and would be subject to a mitigation measure imposed by Resolution 2858-2020
that would require a pre-construction survey be conducted to determine whether a project’s
construction activities would impact vibration sensitive equipment located in adjacent buildings
within 100 feet of the construction activity. As a result, vibration generated during the
construction of the additional space associated with the proposed project would not materially
change the effect on nearby sensitive receptors.
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the
GOP 4 Precise Plan would have created significant impacts with respect to operational noise. The
proposed project may incrementally increase the noise generated during operation, and would be
subject to mitigation imposed by Resolution 2858-2020 to reduce noise associated with HVAC
equipment. In addition, given the relatively small amount of additional space associated with the
proposed project, traffic generated by the proposed project would not discernably increase
ambient noise levels in the vicinity of the GOP 4 site as it would take a doubling of traffic on
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roadways to result in a perceptible increase in noise. As a result, noise generated during the
operation of additional space associated with the proposed project would not adversely affect
nearby sensitive receptors.
With the exception of the closure of the onsite child care center, there has been no substantial
change in surrounding circumstances or new information with respect to noise since the 2010 EIR
was approved. Accordingly, no new or more severe significant impacts with respect to noise are
anticipated beyond those anticipated and analyzed in the EIR. Thus, in accordance with Sections
15162 and 15163 of the State CEQA Guidelines, no additional environmental review is required.
Population and Housing
The 2010 EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan
would have created significant impacts with respect to population and housing as the increase in
employees associated with the plan was within employment estimates for the City of South San
Francisco prepared by the Association of Bay Area Governments (ABAG), and overall, the plan
would have promoted a greater regional jobs balance. The GOP Master Plan project would result in
the net increase 2,531 employees within the GOP Master Plan area, and the proposed project would
add 321 workers to the area, an increase of 12.6 percent. However, as this increase in employment
is not substantial, impacts with respect to population and housing would not change appreciably.
There has been no substantial change in surrounding circumstances or new information since the
2010 EIR was approved. Based on the discussion above, no new or more severe significant
impacts are anticipated with respect to population and housing beyond those anticipated and
analyzed in the EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA
Guidelines, no additional environmental review is required.
Public Services and Recreation
The 2010 EIR determined that neither the GOP Master Plan project nor the GOP 4 Precise Plan
would have created significant impacts with respect to public services and recreation. The 2010 EIR
determined that employees in the GOP Master Plan area would likely visit parks and recreational
facilities near their places of residency and not their place of employment. Further, recreational
activities will be available in onsite areas and the immediately adjacent multi-use trail. The
proposed project would increase the total amount of R&D space allowed within the GOP Master
Plan area by 9.8 percent, and thus would place additional demand on public services. However, as
this increase is not substantial, no changes to these impact conclusions are anticipated.
There has been no substantial change in surrounding circumstances or new information since the
2010 EIR was approved. Accordingly, no new or more severe significant impacts are anticipated
beyond those anticipated and analyzed in the EIR. Thus, in accordance with Sections 15162 and
15163 of the State CEQA Guidelines, no additional environmental review is required.
Utilities
The 2010 EIR determined that with mitigation neither the GOP Master Plan project nor the
GOP 4 Precise Plan would have created significant impacts with respect to utilities and service
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systems. The proposed project would increase the total amount of R&D space allowed within the
GOP Master Plan area by 9.8 percent, and thus would place additional demand of utilities and
service systems serving the GOP Master Plan area. However, as this increase is not substantial,
no changes to these impact conclusions are anticipated.
There has been no substantial change in surrounding circumstances or new information since the
2010 EIR was approved. The City has monitored and kept pace with the expansion of utilities for
new development projects. Construction of the proposed project will be more water and energy
efficient than anticipated due to imposition of stricter requirements found in the California
Building Energy Efficiency Standards (Title 24, Parts 6 and 11). The site will incorporate water-
saving measures and will not increase the water demand of the GOP project above that projected
in the 2010 EIR, as documented in a report prepared by Maddaus Water Management, which is
attached as Appendix E. No new or more severe significant impacts to utilities are anticipated
beyond those anticipated and analyzed in the EIR. Thus, in accordance with Sections 15162 and
15163 of the State CEQA Guidelines, no additional environmental review is required.
3.2.2 Other Topics
The following impact discussions were not required topics of analysis when the 2010 EIR was
approved. Current CEQA analysis includes the evaluation of potential environmental impacts
resulting from energy consumption, disturbance of tribal cultural resources, and potential to
expose individuals or property to wildfires. The following analysis is provided for discussion
purposes. As discussed below, unlike VMT, none of the impacts associated with these
environmental topics would result in a new significant and unavoidable impact. None of the
following constitute “information of substantial importance, which was not known and could not
have been known with the exercise of reasonable diligence at the time the previous EIR was
certified as complete.” Therefore, any potential impacts do not require a subsequent or
supplemental EIR pursuant to CEQA Guidelines Section 15162. (See Concerned Dublin
Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, 1319-1320; Fort Mojave Indian Tribe v.
Department of Health Services (1995) 38 Cal.App.4th 1574, 1605-1606.)
Energy
The 2010 EIR did not include an analysis of energy impacts, though it noted that the GOP Master
Plan project and the GOP 4 Precise Plan would be more energy efficient that the buildings and
uses that were being redeveloped, that the project would be required to adhere to an “energy
budget” per Title 24, and that there were no shortages of energy resources that would preclude the
construction and operation of the project. The proposed project would result in an incremental
increase in energy use compared to the approved GOP 4 Precise Plan. The proposed project does
not include uses or construction plans that would be more energy intensive than is normal for
typical R&D uses. The additional R&D uses included in the proposed project are similar in type
to those anticipated for the GOP 4 site by the GOP Master Plan project. Further, the proposed
project would achieve a LEED rating of silver or better, and would be designed to meet South
San Francisco Municipal Code standards and California Building Energy Efficiency Standards
(Title 24, Parts 6 and 11), which would reduce energy demand. The proposed project is an
expansion of an already-approved use and building, and would be built as part of a larger life
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sciences campus, which would result in concentrated and efficient land use patterns that promote
more energy savings than would development of the 120,221 square feet in a new, separate
building. Thus, the proposed project would not be anticipated to result in the wasteful, inefficient,
or unnecessary consumption of energy resources. This impact would be less than significant.
State renewable energy and energy efficiency plans that are applicable to the proposed project
include the AB 1493 Pavley Rules to increase fuel efficiency, California Title 24 energy
efficiency standards, Executive Order O B-16-12, which orders state entities to support rapid
commercialization of zero-emission vehicles, SB 350, which requires (1) a Renewables Portfolio
Standard (RPS) of 50 percent and (2) a doubling of the statewide energy efficiency savings
related to natural gas and electricity end uses, and SB 100, which increases the 2030 RPS target
set in SB 350 to 60 percent and requires an RPS of 100 percent by 2045. Local plans that address
energy efficiency and are designed to achieve the state’s RPS mandates include Pacific Gas &
Electric’s (PG&E) and Peninsula Energy’s (PCE) 2018 Integrated Resource Plans (IRP) and the
City’s Climate Action Plan (CAP). The City’s General Plan and East of 101 Area Plan also
include goals and policies related to energy use and energy reductions.
The proposed project would benefit from these renewable energy developments and increases in
energy efficiency. Therefore, the proposed project would not conflict with or obstruct a state or
local plan for renewable energy or energy efficiency.
Tribal Cultural Resources
The 2010 EIR did not include an analysis of tribal cultural resources, though it discussed the
history of the Ohlones population and culture at length, and included mitigation measures to
protect unknown subsurface resources. The addition of four stories to an already-approved
building in a manner that will not alter grading activities or the building footprint will not alter
any impacts to tribal resources.
Assembly Bill (AB) 52 requires that lead agencies consider the effects of projects on tribal
cultural resources and conduct notification and consultation with federally and non-federally
recognized Native American tribes early in the environmental review process. According to
AB 52, it is the responsibility of the tribes to formally request of a lead agency that they be
notified of projects in the lead agency’s jurisdiction so that they may request consultation. As of
the publication of this SEIR, no tribes have formally requested to be notified of projects within
the City of South San Francisco. However, the City did send the Notice of Preparation (NOP) to a
large group of interested parties that included four tribes in the region; none of the tribes provided
comments in response to the NOP.
Wildfire
The GOP 4 site is not located in an area that is designated as high risk for the occurrence of
wildfires. The addition of four stories in an urbanized area will not increase any potential for
wildfire. Based on the location of the GOP 4 site and the nature of the GOP 4 Density Transfer
project, there would be no new or more severe impact related to wildfire hazards.
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CHAPTER 4
Project Alternatives
4.1 Overview
Under CEQA, an environmental impact report (EIR) must describe a range of reasonable
alternatives to the proposed project that might feasibly accomplish most of the project’s basic
objectives and could avoid or substantially lessen one or more of the significant effects of the
project. The feasibility of an alternative is determined by the lead agency based on a variety of
factors including, but not limited to, site suitability, economic viability, availability of
infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional
boundaries, and site accessibility and control (CEQA Guidelines section 15126.6(f)(1)).
This chapter discloses the comparative effects of each of the alternatives relative to the proposed
GOP4 Transfer Density project, and evaluates the relationship of the alternatives to the objectives
of the proposed project. As required under section 15126.6(e)(2) of the CEQA Guidelines, the
discussion describes the relative environmental merits of the alternatives and identifies which of
them may be considered the “environmentally superior” alternative.
4.2 Factors in the Selection of Alternatives
Project Objectives
The objectives of the proposed GOP4 Transfer Density project are used to evaluate the
reasonableness and potential feasibility of each alternative. As presented in Chapter 2, the
objective of the GOP 4 Density Transfer project is to transfer unused Floor Area Ratio (FAR)
from the adjacent rail spur properties to enable an expansion to Phase 4 of the GOP Master Plan
project in a manner that:
• builds upon prior approvals by implementing their conditions, mitigation measures and
architectural treatments;
• softens the height transition between the buildings constructed during GOP Phase 1 and the
buildings to be constructed during GOP Phase 4; and
• locates the expansion in an already-approved campus, allowing it to take advantage of
approved pedestrian connections, the multi-modal improvements approved for the adjacent
rail spur properties and the shuttle stop planned for the campus.
4. Project Alternatives
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Significant Effects of the Proposed Project
Section 15126.2(c) of the CEQA Guidelines requires that an EIR describe any significant impacts
that cannot be avoided, even with the implementation of feasible mitigation measures. The
environmental effects of the proposed GOP4 Transfer Density project on transportation are discussed
in detail in Chapter 3, Environmental Setting, Impacts, and Mitigation Measures. The analysis of
transportation in Chapter 3 of this Draft SEIR did identify one project level impact (Impact 3.1-2)
and one cumulative level impact (Impact 3.1-5) associated with the generation of vehicle miles
traveled (VMT) that cannot be avoided if the project is approved as proposed. Therefore, there
would be two significant and unavoidable impacts resulting from the proposed project.
4.3 Alternatives Considered but Dismissed from
Further Evaluation
As required under section 15126.6(c) of the State CEQA Guidelines, the City is required to
disclose alternatives that were considered but rejected from further analysis in this Draft SEIR.
The screening process for identifying viable alternatives included consideration of the following
criteria.
• Ability to meet the project objectives
• Potential ability to substantially lessen or avoid environmental effects associated with the
proposed project
• Potential feasibility
The discussion below describes alternatives that were considered during preparation and scoping
of this Draft SEIR, and gives the rationale for eliminating these alternatives from detailed
consideration.
Reduced Height Alternative
The proposed project includes the addition of four additional stories to the northern building on
the GOP 4 site. Alternatives similar to the proposed project but with a building reduced in height
by one to three stories and reduced in size by approximately 30,000 to 90,000 square feet were
evaluated for their its potential to reduce the project’s significant VMT impacts (Impacts 3.1-2
and 3.1-5) as a result of their smaller size. However, a smaller project does not directly correlate
to a reduced VMT impact because VMT is assessed based on a per-capita or per-employee rate.
Regardless of how many workers are employed on the GOP 4 site, as VMT is defined as a
measurement of miles traveled by vehicles within a specified region and for a specified time
period, VMT per capita or per-employee would not change. Also, these alternatives would only
partially meet the prime project objective of transferring unused FAR from the adjacent rail spur
properties. Therefore, although these alternatives would meet most of the project objectives, they
were not carried forward for analysis because they would not substantially reduce or eliminate the
project’s significant VMT impacts.
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Residential Land Use Alternative
An alternative that would develop the additional space as residential was considered based on its
potential to reduce the project’s significant VMT impacts (Impacts 3.1-2 and 3.1-5). A residential
alternative would have the potential to reduce the average home-based work (HBW) VMT per
employee 1 by locating residential uses in an area predominantly occupied by employment uses,
providing more opportunities for employees in the East of 101 area to live closer to their place of
work. The GOP 4 site is identified as Business Commercial (BC) in the General Plan and is zoned
Gateway Specific Plan District under the City’s zoning ordinance. Neither of these designations
permit residential uses, nor would residential uses be consistent with existing land uses in the
vicinity of the GOP 4 site. Residential development at this site is not consistent with current
General Plan direction and policies to preserve land East of 101 for employment uses. As part of
the City’s Shape SSF 2040 General Plan process, the City is considering residential uses in the
East of 101 area, including high-density mixed use residential uses in areas adjacent to and within
0.5 mile to the Caltrain station in one of the alternatives. The areas along Gateway Boulevard that
are under consideration for residential uses are within 0.5 mile of the Caltrain station, and do not
include the GOP 4 site.2 The City does not anticipate that the Shape SSF 2040 General Plan will
consider residential uses for the GOP 4 site. Furthermore, a residential alternative would be
inconsistent with all of the project objectives. Therefore, this alternative was not carried forward
for analysis based on its infeasibility and inability to meet the project objectives.
Alternative Project Location
An alternative that would transfer the density to a parcel closer to transit was considered based on
its potential to reduce the project’s significant VMT impacts (Impacts 3.1-2 and 3.1-5). Two
potential alternative project locations were considered in the East of 101 area. The first location is
an approximately 2.6 acre parcel located at 100 East Grand Avenue. The site is currently
occupied by a warehouse. The second location is an approximately 3.6 acre parcel located at 121
East Grand Avenue. The site is currently occupied by a Comfort Inn and Suites. As part of the
City’s Shape SSF 2040 General Plan process, the City is considering a mixed-use development
with residential uses at these sites in several of the land use alternatives. The Caltrain Station at
East Grand Avenue is approximately 0.25 to 0.5 mile north of the two alternative project
locations. CEQA Guidelines Section 15064.3, subdivision (b) (1), states that “generally, projects
within one-half mile of an existing major transit stop 3 or a stop along an existing high quality
transit corridor 4 should be presumed to cause less-than-significant transportation impact.” OPR
1 The key metric used to determine a VMT impact is home-based work HBW VMT per capita, which is expressed as
a rate per employee. For example, if an alternative would have fewer employees compared to the proposed project,
it would still be required to substantially reduce the average trip length between employees’ home and work to
substantially reduce the average HBW VMT per employee compared to the proposed project. 2 City of South San Francisco. 2020.Shape SSF 2040 General Plan. Available: https:// shapessf.com/ alternatives/.
Accessed: November 9, 2021. 3 major transit stop” means a site containing an existing rail transit station, a ferry terminal served by either a bus or
rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15
minutes or less during the morning and afternoon peak commute periods. 4 high-quality transit corridor” means a corridor with fixed route bus service with service intervals no longer than 15
minutes during peak commute hours.
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advises that the less than significant presumption would not apply, however, if project-specific or
location-specific information indicates the project will still generate significant levels of VMT.
As discussed in Section 3.1, Transportation, the HBW VMT per employee for the proposed
project is higher than that of the Bay Area Region (16.2 compared to 14.2), which is representative
of other sites in the East of 101 area. Given the high levels of VMT generated by sites in the East
of 101 area, sites within 0.5 mile of an existing major transit stop in the East of 101 area may still
generate significant levels of VMT. Furthermore, this alternative was rejected because neither of
the potential alternative sites are owned by the project applicant. In addition, both sites have
existing long-term leases and tenants, and neither site may be available for purchase or
development. Next, as the proposed project is an addition to an already approved building, it
would be more cost efficient from a construction perspective, as constructing this space on
another site would involve additional construction phases, such a demolition and site preparation.
Finally, locating the proposed project on these sites would not be consistent with the project
objectives as it would not build upon prior approvals or be located an already-approved campus.
It is anticipated that an alternative that would transfer the density to a parcel in another area of the
city (possibly outside of the East of 101 area) would not reduce the project’s significant VMT
impacts (Impacts 3.1-2 and 3.1-5) because there are no low VMT office areas anywhere in the
City outside of areas in close proximity to major transit stations.5 In addition, this alternative
would not reduce the project’s significant VMT impacts because any new jobs added to the City
of South San Francisco (particularly in the East of 101 area and in the biotech industry) would
likely attract employees from throughout the Bay Area, which would generate substantially more
VMT and worsen the regional balance between jobs and housing. Therefore, this alternative was
rejected because of its potential infeasibility.
4.4 Alternatives Selected for Further Consideration
Based on the screening criteria list above, there are no feasible alternatives that might feasibly
accomplish most of the project’s basic objectives and avoid or substantially lessen one or more of
the significant effects of the project. As a result, this alternatives analysis only considers the no
project alternative.
The evaluation of the no project alternative is organized to facilitate a clear comparison between
the effects of the alternative and the effects of the proposed project. There is a discussion of those
impacts of the alternative that would be the same or similar to those of the proposed project. This
is followed by a discussion of those effects of the alternative that would be less substantial than
those of the proposed project, followed by those effects of the alternative that would be more
substantial than those of the proposed project. Each discussion concludes with a discussion of the
relationship between the alternative and the basic objectives of the proposed project.
5 City of South San Francisco. 2020. City of South San Francisco Significance Thresholds for Transportation.
4. Project Alternatives
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No Project Alternative
Description
Under the No Project/No Development Alternative, the transfer of density under the proposed
project would not occur, and the approved GOP 4 project would be constructed on the GOP 4
site. Under the No Project Alternative, Mitigation Measure 3.1-1, which requires the
implementation first- and last-mile transit connections and active transportation improvements to
offset the impacts of the expansion enabled by the density transfer, would not be implemented.
Comparative Analysis of Environmental Effects
The No Project Alternative would result in the construction of the approved GOP 4 project on the
GOP 4 site.
Impacts Identified as Being the Same or Similar to the Proposed Project
Impacts identified for the proposed project associated with VMT would be the same or similar
under the No Project Alternative, as the fewer vehicle trips associated with this alternative would
not directly correlate to a reduction in VMT.
Impacts Identified as Being Less Substantial than the Proposed Project
There would be no impacts identified for the proposed project that would less substantial under
the No Project Alternative, as no addition space for R&D uses would be constructed.
Impacts Identified as Being More Substantial than the Proposed Project
There would be no impacts identified for the proposed project that would be more substantial
under the No Project Alternative, as no addition space for R&D uses would be constructed.
Relationship to Significant and Unavoidable Impacts
As noted in Chapter 3, the proposed project does have one project level impact (Impact 3.1-2) and
one cumulative-level impact (Impact 3.1-5) associated with VMT that cannot be avoided.
Similarly, the No Project Alternative would also have one project-level and on cumulative level
significant and unavoidable impact with respect to VMT as the VMT per capita associated with
the approved GOP 4 project would remain the same. Therefore, the relationship of the No Project
Alternative to significant and unavoidable VMT impacts would be the same as that under the
proposed project.
Relationship to Project Objectives
This alternative would not meet the basic project objective of transferring unused FAR from the
adjacent rail spur properties to enable a relatively small expansion to Phase 4 of the GOP Master
Plan project.
4. Project Alternatives
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4.5 Environmentally Superior Alternative
From the alternatives considered for the proposed project in this Draft SEIR, the environmentally
superior alternative would be the No Project Alternative, although the project- and cumulative
level impacts associated with VMT would remain the same.
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CHAPTER 5
Other CEQA Required Considerations
5.1 Introduction
Section 15126 of the CEQA Guidelines requires that all phases of a project must be considered
when evaluating its impact on the environment, including planning, acquisition, development,
and operation. Further, CEQA Guidelines Section 15126.2(a) requires that the evaluation of
significant impacts consider direct and reasonably foreseeable indirect effects of the project over
the short-term and long-term. The EIR must identify (1) significant environmental effects of the
proposed project, (2) feasible mitigation measures proposed to minimize significant effects,
(3) significant environmental effects that cannot be avoided if the proposed project is
implemented, (4) significant irreversible environmental changes that would result from
implementation of the proposed project, (5) growth-inducing impacts of the proposed project, and
(6) alternatives to the proposed project.1
Sections 3.1 and 3.2 of the SEIR provide a comprehensive presentation of the proposed GOP 4
Density Transfer project’s new environmental effects, proposed mitigation measures, and
conclusions regarding the level of significance of each impact both before and after mitigation.
Chapter 4, Project Alternatives, presents a comparative analysis of alternatives to the proposed
GOP 4 Density Transfer project.
The other CEQA-required analyses described above are presented below.
5.2 Significant and Unavoidable Adverse Impacts
Section 15126.2(c) of the State CEQA Guidelines requires that an EIR describe any significant
impacts that cannot be avoided, even with the implementation of feasible mitigation measures.
The environmental effects of the proposed GOP 4 Density Transfer project on various aspects of
the environment are discussed in detail in Chapter 3, Environmental Setting, Impacts, and
Mitigation Measures. As discussed in Chapter 3, the proposed GOP 4 Density Transfer project
would have the following new impacts that would be significant and unavoidable, that were not
identified in the EIR:
1 CEQA Guidelines sections 15126.2(a), (c-e), 15126.4, and 15126.6.
5. Other CEQA Required Considerations
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Impact 3.1-2: The proposed project would conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision b) related to VMT.
Impact 3.1-5: Implementation of the proposed project, in combination with other
development, could contribute to cumulative conditions where VMT per capita or VMT per
employee could exceed 85 percent of the 2040 cumulative Bay Area-wide regional average
daily VMT per employee.
5.3 Significant Irreversible Environmental Effects
Under CEQA, an EIR must analyze the extent to which a project's primary and secondary effects
would generally commit future generations to the allocation of nonrenewable resources and to
irreversible environmental damage (State CEQA Guidelines section 15126.2(c); 15127). Section
15126.2(c) states:
Uses of nonrenewable resources during the initial and continued phases of the
project may be irreversible, since a large commitment of such resources makes
removal or nonuse thereafter unlikely. Primary impacts and, particularly,
secondary impacts (such as highway improvement which provides access to a
previously inaccessible area) generally commit future generations to similar uses.
Also, irreversible damage can result from environmental accidents associated
with the project. Irretrievable commitments of resources should be evaluated to
assure that such current consumption is justified.
Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar
uses;
• The project would involve a large commitment of nonrenewable resources;
• The project would involve uses in which irreversible damage could result from any potential
environmental accidents associated with the project; or
• The proposed consumption of resources is not justified (e.g., the project involves the wasteful
use of energy).
Development of the already-approved GOP 4 Precise Plan would result in the dedication of the
GOP 4 project site to R&D building complex, thereby precluding other uses for the lifespan of
the project. The proposed project does not exacerbate that circumstance.
The State CEQA Guidelines also require a discussion of the potential for irreversible environmental
damage caused by an accident associated with the proposed GOP 4 Density Transfer project.
While the proposed GOP 4 Density Transfer project would incrementally increase the use,
transport, storage, and disposal of hazardous wastes during construction and operation, as
described in EIR prepared for the GOP Master Plan project, all activities would comply with
applicable state and federal laws related to hazardous materials, which significantly reduce the
likelihood and severity of accidents that could result in irreversible environmental damage.
5. Other CEQA Required Considerations
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Implementation of the proposed GOP 4 Density Transfer project also would incrementally
increase the long-term commitment of resources to urban development. The most notable
significant irreversible impacts are increased generation of pollutants from vehicle travel and
stationary operations, and the short-term commitment of non-renewable and/or slowly renewable
natural and energy resources, such as water resources during construction activities. The
environmental consequences of the proposed GOP 4 Density Transfer project are described in the
appropriate sections in Chapter 3, Environmental Setting, Impacts, and Mitigation Measures.
Resources that would be permanently and continually consumed by implementation of the
proposed GOP 4 Density Transfer project include water, electricity, natural gas, and fossil fuels;
however, the amount and rate of consumption of these resources would not result in the
unnecessary, inefficient, or wasteful use of resources. With respect to operational activities,
compliance with applicable building codes, including the 2021 Title 24 Energy Efficiency
Standards (Effective January 1, 2022), as well as mitigation measures, planning policies, and
standard conservation features, would ensure that natural resources are conserved to the
maximum extent feasible. It is also possible that, over time, new technologies or systems will
emerge, or will become more cost-effective or user-friendly, to further reduce the reliance upon
nonrenewable natural resources. Nonetheless, construction activities related to the proposed
GOP 4 Density Transfer project would result an incremental increase in the irretrievable
commitment of nonrenewable energy resources, primarily in the form of fossil fuels (including
fuel oil), natural gas, and gasoline for automobiles and construction equipment.
Based on the discussion above, no new or more severe significant impacts with respect to
significant irreversible environmental effects are anticipated beyond those anticipated and
analyzed in the EIR. Thus, in accordance with Sections 15162 and 15163 of the State CEQA
Guidelines, no additional environmental review is required.
5.4 Growth-Inducing Effects
As required by Section 15126.2(e) of the State CEQA Guidelines, an EIR must discuss ways in
which a proposed project could foster economic or population growth or the construction of
additional housing, either directly or indirectly, in the surrounding environment. Also, the EIR
must discuss the characteristics of the project that could encourage and facilitate other activities
that could significantly affect the environment, either individually or cumulatively. Growth can
be induced in a number of ways, such as through the elimination of obstacles to growth, through
the stimulation of economic activity within the region, or through the establishment of policies or
other precedents that directly or indirectly encourage additional growth. The purpose of this
section is to evaluate the potential growth-inducing effects resulting from the implementation of
the proposed GOP 4 Density Transfer project in the City of South San Francisco, and throughout
the region.
In general, a project may foster spatial, economic, or population growth in a geographic area if
the project removes an impediment to growth (e.g., the establishment of an essential public
5. Other CEQA Required Considerations
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service, the provision of the new access to or infrastructure capacity that serves an area; a change in
zoning or general plan designations that increase density for areas outside the boundaries of the
project site); or indirectly stimulates economic expansion or growth that occurs in an area in
response to the project (e.g., changes in revenue base, employment expansion, etc.). These
circumstances are further described below:
• Elimination of Obstacles to Growth: This refers to the potential for a proposed project to
remove infrastructure limitations or provides infrastructure capacity, or removes regulatory
constraints that could result in growth unforeseen at the time of project approval;
• Precedent-setting Effects: This refers to the potential for a project to establish a precedent
for allowing more growth, that will likely be copied by other, future projects; and
• Economic Effects: This refers to the potential for a proposed project to cause increased
activity in the local or regional economy.
Elimination of Obstacles to Growth
The elimination of physical obstacles to growth is considered a growth-inducing effect. Growth
within the East of 101 Area and the City of South San Francisco as a whole is affected by the
capacity of utility systems serving the City including the wastewater and drainage, water supply,
and electrical systems. Growth within the City is also affected by the roadway circulation system,
public transit infrastructure and services and bikeway/pedestrian facilities.
The implementation of the proposed GOP 4 Density Transfer project would not result in the
elimination of obstacles to growth. The proposed project is located within an urban area of the
City. The proposed project would not include localized circulation improvements, other than on-
site driveways and pathways, and thus would not expand the capacity of area roadways. As
described in the EIR, existing service systems for drainage and wastewater within the GOP
Master Plan area are either adequate to serve the proposed project, or would require
improvements to accommodate the incremental increase in demand proposed by the GOP 4
Density Transfer project. Improvements to utility infrastructure would be intended to serve the
proposed project; they would not be sized to provide substantial excess capacity beyond what is
needed to serve the proposed GOP 4 Density Transfer project. Therefore, improvements
associated with the proposed project would not expand the capacity of local infrastructure to the
extent that current constraints to development in surrounding areas would be eliminated. As such,
the proposed GOP 4 Density Transfer project would not eliminate obstacles to further growth
within the East of 101 Area and the City of South San Francisco.
Accordingly, no new or more severe significant impacts with respect to the elimination of
obstacles to growth are anticipated beyond those anticipated and analyzed in the EIR. Thus, in
accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no additional
environmental review is required.
5. Other CEQA Required Considerations
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Precedent-Setting Effects
The proposed project includes legislative changes to allow an expansion. Specifically, the
applicant seeks amendments to allow the development of additional density to the extent such
density would otherwise be available on immediately adjacent property that is (1) subject to an
FAR limitation of 1.25 or less; (2) part of the same research & development campus; and
(3) deed-restricted to preclude development of the transferred FAR. These legislative changes
would not be precedent-setting, as the circumstances under which the density transfer would be
allowed are narrow and there are no other known sites that could qualify. Further, the legislative
changes would allow only a transfer of density and would not set a precedent for increasing the
amount of development that is allowed overall.
Economic Effects
As is presented in Chapter 2, Project Description, under the future conditions it is anticipated that
the expansion proposed by the GOP 4 Density Transfer project would employ 321 workers. In
addition to employment growth generated by the proposed project, employment could be
generated in the local and regional economy through what is commonly referred to as the
“Multiplier Effect.” The Multiplier Effect generally refers to the secondary economic effects
caused by spending from project-generated employees and resulting in additional employment in
the local and regional economy.
Indirect employment includes those additional jobs that are generated through the expenditure
patterns of employees associated with the project. Induced employment follows the economic
effect of employment beyond the expenditures of the employee within the project vicinity to
include jobs created by the stream of goods and services necessary to construct the proposed
project and support businesses within the South San Francisco area.
It is estimated that the proposed GOP 4 Density Transfer project would employ 321 workers. The
environmental consequences of economic growth resulting from this relatively low number of
employees are too speculative to predict or evaluate, since they can be spread throughout the Bay
Area region and beyond.
The future cumulative context of citywide and regional growth used for the cumulative analyses in
the City of South San Francisco’s General Plan EIR and the cumulative analyses in the Association
of Bay Area Governments (ABAG) Metropolitan Transportation Plan/Sustainable Communities
Strategy (MTP/SCS) EIR includes the multiplier effects of the project. Consequently, the
cumulative impact analyses in the General Plan EIR and the MTP/SCS EIR account for additional
growth beyond the GOP 4 project site that would be generated by the proposed GOP 4 Density
Transfer project.
It should be noted that, while the proposed GOP 4 Density Transfer project would contribute to
direct, indirect, and induced growth in the region, it would develop employment land uses in a
manner that is efficient, and utilizes existing and planned urban resources. As is described in
5. Other CEQA Required Considerations
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Section 3.2, Other Resource Topics, development of the proposed project is consistent with the
goals and policies of the City’s General Plan. Contributing to the vitality of the community is also
a General Plan goal, which would be achieved as a result of the proposed GOP 4 Density Transfer
project.
Accordingly, no new or more severe significant impacts with respect to economic effects are
anticipated beyond those anticipated and analyzed in the 2010 EIR. Thus, in accordance with
Sections 15162 and 15163 of the State CEQA Guidelines, no additional environmental review is
required.
Environmental Effects of Induced Growth
Because the proposed project will not induce growth, there will be no environmental effects of
induced growth. Furthermore, the incremental increase in economic activity created by the
indirect and induced employment associated with the proposed project would be a small part of
the overall future growth in economic activity in the Bay Area region. Local governments
throughout the region are planning for additional residential and employment-generating land
uses, some of which could meet the demands created indirectly by the proposed GOP 4 Density
Transfer project. Through their planning and entitlement actions, the future actions of those local
agencies would be subject to environmental review under CEQA, and would be required to be
consistent with regional and state plans and regulations. To the extent that future development
that accommodates indirect and induced growth from the proposed project is undertaken in a
manner consistent with the South San Francisco General Plan and SACOG MTP/SCS, as well as
a multitude of planning and regulatory documents, many of the potential adverse environmental
consequences would be reduced in magnitude or avoided altogether.
Accordingly, no new or more severe significant impacts with respect to the environmental effects
of induced growth are anticipated beyond those anticipated and analyzed in the 2010 EIR. Thus,
in accordance with Sections 15162 and 15163 of the State CEQA Guidelines, no additional
environmental review is required.
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CHAPTER 6
List of Preparers and Persons Consulted
6.1 Report Authors
Lead Agency
The City of South San Francisco is the CEQA lead agency for preparation of this SEIR.
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Avenue
South San Francisco, California 94080
Environmental Science Associates (ESA)
The following ESA staff contributed to the preparation of the SEIR.
Crescentia Brown: B.A., Landscape Architecture and Certificate of Regional Planning; M.U.P.,
Urban Planning. 21 years of experience. Project Director. Responsible for oversight of EIR
preparation, providing overall CEQA strategy, client and agency coordination, allocation of
corporate resources, and QA/QC of all work products.
Paul Stephenson, AICP: B.S. Environmental Policy Analysis and Planning; M.A. Planning.
17 years of experience. Project Manager. Responsible for EIR preparation, day-to-day project
management,
Jonathan Teofilo: B.S. Environmental Studies. 8 years of experience. Responsible for EIR
preparation.
Kristine Olsen: A.S. Natural Science. 20 years of experience. Responsible for managing,
coordinating, and ensuring word processing and publication quality control for all elements of
document production for the EIR.
James Songco: B.F.A. Graphic Design. 20 years of experience. Responsible for preparation of
graphics, figures and exhibits in the EIR.
6. List of Preparers and Persons Consulted
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Hexagon Transportation Consultants, Inc. (Consultant to the
Applicant)
Gary Black, AICP, President
Trisha Dudala, P.E., Senior Associate
Ramboll (Consultant to the Applicant)
Michael Keinath, P.E., Principal
Rishabh Shah, PhD, Senior Air Quality Consultant
Maddaus Water Management Inc. (Consultant to the
Applicant)
Michelle Maddaus, P.E., M.B.A, President
6.2 Persons Consulted
City of South San Francisco
Billy Gross, Principal Planner
Claire Lai, Assistant City Attorney
Other Organizations
California Department of Transportation
Mark Leong, District Branch Chief, Local Development Review
San Francisco International Airport
Nupur Sinha, Director of Planning and Environmental Affairs
Project Applicant Team
BioMed Realty Group
Ethan Warsh, Senior Project Manager
Appendix A
Notice of Preparation
1
NOTICE OF PREPARATION
OF AN SEIR AND SCOPING MEETING FOR THE
PROPOSED GOP 4 DENSITY TRANSFER PROJECT
MODIFYING THE PREVIOUSLY APPROVED GATEWAY
BUSINESS PARK MASTER PLAN PROJECT
SCH #2008062059
To: Agencies, Organizations, and Interested Parties
From: City of South San Francisco, Economic and Community Development Departme nt
Subject: Notice of Preparation (NOP) of a Focused Supplemental Environmental Impact Report (SEIR) in
Compliance with Public Resources Code section 21166 and section 15163 of Title 14 of the California Code of
Regulations (CEQA Guidelines). The City of S outh San Francisco (City) is the Lead Agency under CEQA for
the proposed project identified below. The City will prepare an SEIR focused on transportation issues
(including Vehicle Miles Traveled) for the proposed project identified below .
Project Title and Description: The Project is entitled the “GOP 4 Density Transfer Project .” This Project
would modif y the previously-approved Gateway Business Park Master Plan project. The GOP 4 Density
Transfer Project proposes to transfer up to 120,221 square feet of development potential from some
undeveloped adjacent property, and use it to expand one of the buildings approved for Phase 4 of the Gateway
Business Park Master Plan project (“GOP 4”) by that amount, to be configured in four additional floors.
Additional details are set forth below.
Project Location: GOP 4 is located at 850 and 900 Gateway Boulevard, southeast of the intersection of
Gateway Boulevard and Oyster Point Boulevard, in the City of South San Francisco, County of San Mateo.
Modifications to the GOP Master Plan, which also encompasses 1000 Gateway (GOP 1), 750 Gateway (GOP
2), and 700 Gateway (GOP 3), will be required to implement the GOP 4 Density Transfer Project . Conforming
amendments to or repeal of the Gateway Specific Plan would also be required. The Specific Plan encompasses
the area generally bounded by Oyster Point Boulevard on the north, East Grand Avenue on t he south, Forbes
Boulevard extending northerly along a line generally west of and parallel to Eccles Avenue on the east, and
Poletti Way on the west.
Prior Environmental Review : The Gateway Business Park Master Plan project was studied in an EIR, SCH
#2008062059. The City Council certified the EIR and adopted CEQA findings in Resolution No. 18-2010.
The project was subsequently modified to reconfigure the layout and update th e architecture. The City Council
found the EIR adequate for the modified Master Plan project and for a Precise Plan for Phase 1, and re-adopted
CEQA findings, in Resolution No. 43 -2013. The Planning Commission later adopted Addenda addressing
Precise Plans for Phases 2, 3 and 4 of the Master Plan project, in Resolutions No. 2834-2018 and No. 2858-
2020.
Current Environmental Review : The Supplemental EIR will supplement the prior EIR with a project -level
discussion of the transportation impacts of the 120,221 square foot expansion proposed by the GOP 4 Density
Transfer Project. The SEIR also will include evaluations of all other resource areas, for which it is probable
there will be no new or more severe significant environmental impacts, to demonstrate tha t no supplemental or
subsequent analysis is required for those resource areas. The SEIR will be prepared in compliance with CEQA
and the CEQA Guidelines. An Initial Study has not been prepared. Further details are provided below.
2
Agency/Public Comments: The City requests your comments regarding the scope and content of the
environmental review to be conducted for the proposed GOP 4 Density Transfer P roject. The City will accept
written comments on this NOP between November 16, 2021 and December 20, 2021, a period of thirty f our
(34) days to account for the Thanksgiving holiday . Please send your comments by email to
Billy.Gross@ssf.net or by mail to:
City of South San Francisco
Department of Economic and Community Development
Attn: Billy Gross, Principal Planner
315 Maple Avenue
South San Francisco, CA 94080
Scoping Meeting: Pursuant to Public Resources Code Section 21083.9 and Sections 15206 and 15082 of the
CEQA Guidelines, the Lead Agency also hereby gives notice of a public scoping meeting on this project to
receive comments on the scope of the EIR. In accordance with current shelter-in-place mandates related to
COVID-19, the Lead Agency will conduct a virtual scoping meeting on December 6, 2021, beginning at
4:00 PM, via webinar and telephone conference line. During the scoping meeting, agencies, organizations,
and the public will have an opportunity to submit comments. The scoping meeting w ill include a presentation
providing an overview of the project and the CEQA process, followed by a question and answer session for
online and phone attendees. Please note that comments are limited to three minutes per speaker.
Join Zoom Meeting
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3
Please note that there are three ways to comment during the meeting:
1. Send a comment via email to Billy.G ross@ssf.net. City staff will monitor emails during the meeting
and any email comment received during the meetin g will be read into the record. Your email should
be limited so that it complies with the 3-minute time limitation for public comment.
2. Call the Planning Division Hotline at (650) 829-4669. Voice Messages will be monitored during the
meeting and read into t he record. Your voicemail should be limited so that it complies with the 3 -
minute time limitation for public comment.
3. Submit a comment via the “chat” function in the Zoom meeting app. City staff will monitor the
chat and will read comments and questions into the record.
EIR Process: Following the close of the NOP comment period, a Draft Supplemental Focused EIR will be
prepared that will take into consideration NOP comments. The Draft Supplemental Focused EIR will be
released for public review and comment for the required 45 -day review period. Following the close of the
public review period, the City will prepare a Final Supplemental Focused EIR that will include responses to
all substantive comments received on the Draft Supplemental Focused EIR. The Draft SFEIR and Final
SFEIR will be considered by City decisionmakers in making the decision to certify the SFEIR and to
approve or deny the components of the proposed project. If certified by the City, the SFEIR may be relied
on by other agencies for purposes of carrying out portions of the proposed project within their respective
jurisdictions. The certified SFEIR may also be relied upon by the City and other agencies in connection with
subsequent activities within the Master Plan project, and to determine the nature and scope of any
supplemental or subsequent environmental review.
Project Description , Location and Property Ownership
Affiliates of BioMed Realty (BMR) propose to modify the approvals for Phase 4 of the GOP Master Plan
project to implement what is, in essence, a transfer of density from some adjacent former rail spur properties
included in the separate GOP 5 project. Specifically, BMR proposes to deed restrict the rail spur properties to
eliminate development of the transferred FAR. In exchange, BMR has applied to the City to modify the
Precise Plan for Phase 4 (GOP 4) to add 4 floors to the northern GOP 4 building. This modification would
allow BMR to take advantage of up to 120,221 additional square fee t that could otherwise be built on the
adjacent rail spur properties.
I. Background.
The GOP Master Plan project and the adjacent GOP 5 project are both located in the City’s East of 101 Area.
Though the entitlements for each project remain separate, the p hysical development is intended to integrate the
two project s into one life sciences campus connected by pedestrian pathways and a grand staircase. As
currently entitled, the GOP Master Plan project and GOP 5 project are as follows, with GOP 4 highlighted in
blue:
4
A. Approved GOP Master Plan Project and Location.
In 2013, the City approved a modified master plan for the Gateway Business Park Master Plan project, which
is now known as the Gateway of Pacific, or GOP project. The GOP Master Plan project site is located
southeast of the intersection of Gateway Boulevard and Oyster Point Boulevard, at 1000 Gateway (GOP 1 ),
750 Gateway (GOP 2), 700 Gateway (GOP 3), and 850 & 900 Gateway (GOP 4), in San Mateo County. The
Master Plan project site is designated Business Commercial in the General Plan, is subject to the Gateway
Specific Plan, and is in the Gateway Specific Plan zoning district. The project is vested into these plans and
regulations by a Development Agreement.
The GOP Master Plan contemplates phased development. The City has approved precise plans for four phases,
and has approved Lot Line Adjustments that accommodate these phases.
The General Plan currently imposes an FAR limitation of 1.25 on the GOP Master Plan site. The Master Plan
currently reflects this 1.25 FAR limitation and permits individual parcels to be developed at FARs greater than
1.25, so long as development of the entire Master Plan site does not exceed 1.25.
1. GOP 1.
The Precise Plan for GOP 1 was approved by City Council Resolution 44 -2013 in 2013. Construction started
around May 2017 and the first tenants occupied the building in early 2021. GOP 1 has north and south towers.
GOP 1 also hosts an amenity building designed to serve the entire campus, known as “Traverse.” There are
two parking levels under the plaza and amenity building.
2. GOP 2.
The Precise Plan for GOP 2 was approved by Planning Commission Resolution No. 2835 -2018 in 2018.
Construction started around April 2019, and occupancy is projected in approximately March 2022. GOP 2 has
north and south towers, with parking accommodated in a parking structure on the GOP 2 site.
3. GOP 3.
The Precise Plan for GOP 3 also was approved by Planning Commission Resolut ion No. 2835-2018 in 2018.
Construction started around August 2019, and occupancy is targeted for late 2022. GOP 3 has a single
building, with parking accommodated in a parking structure on the GOP 3 site.
5
4. GOP 4.
The GOP 4 Precise Plan was approved by P lanning Commission Resolution No. 2859 -2020 in 2020. Neither
demolition nor construction have commenced. GOP 4 was approved for two five -story buildings and a parking
structure of 6 levels, with a partial floor on the 6th level. The approved GOP 4 Precise Plan allows the
following development:
5. GOP Master Plan Parking Ratio.
The GOP Master Plan and the Phase 1 Precise Plan were approved in 2013 subject to condition of approval
A.2, which states:
The parking ratio for the Master Plan and Precise Plan pro ject shall not exceed
2.73 spaces per 1,000 square feet at any time. The current and all future Precise
Plan applications shall include site development plans that specify the campus -
wide parking ratio does not exceed 2.73 spaces per 1,000 square feet. If the
campus-wide ratio exceeds the 2. 73 spaces per 1,000 square feet ratio, the
developer shall provide a site plan that indicates how parking spaces on the entire
campus will be allocated and used.
Accordingly, GOP 1 through 4, as currently entitled, are parked at a ratio of 2.73 spaces per 1,000 square feet
of Floor Area . The total number of parking spaces built, under construction or approved is 3,776.
6. Prior GOP Master Plan Environmental Review.
The GOP Master Plan was approved based upon a comprehe nsive EIR the City re-certified in 2013. For each
Precise Plan approval, the City relied upon an Addendum to that EIR, which had been prepared to address any
changes that had arisen since the EIR was certified. The City determined that there were no chan ges to the
project or the surrounding circumstances, and no significant information, that showed any new or more severe
impacts. The most recent such decision was made in Resolution 2858 -2020, adopted on August 6, 2020 in
connection with approval of the G OP 4 Precise Plan. No challenges were filed against that Resolution.
6
7. GOP Master Plan Land Ownership.
BMR is seeking modified entitlements on behalf of the following affiliates, which own the lands within the
GOP Master Plan site as follows:
GOP 1 - BMR-Gateway of Pacific I LP
GOP 2 - BMR-Gateway of Pacific II LP
GOP 3 - BMR-Gateway of Pacific III LP
GOP 4 - BMR-Gateway of Pacific IV LP
B. Approved GOP 5 Project.
No modifications are proposed to the GOP 5 Project approvals. However, GOP 5 is described here because it
is the source of the density transfer.
The GOP 5 project site is designated Business and Technology Park in the General Plan, and is located in the
Business Technology Park zoning district. The General Plan and zoning both limit FAR at the si te to 1.0. The
GOP 5 project is vested into these plans and regulations by a Development Agreement.
In 2016, the City Council adopted Resolution 94 -2016 approving a use permit, design review, transportation
demand management plan and alternative landscape plan for a project then known as 475 Eccles. The 475
Eccles project approvals allowed construction of two life sciences buildings, which achieved the 1.0 FAR on
the 475 Eccles parcel, and a parking structure. At that time, 475 Eccles was separated from the GOP Master
Plan site by some former rail spurs that connect Oyster Point Boulevard to Forbes Boul evard.
BMR subsequently acquired the rail spur property, and proposed to use it to connect the GOP Master Plan site
with the 475 Eccles project site. Specifically, BMR proposed to develop the rail spurs into a publicly
accessible multi-use path connecting Oyster Point Boulevard with Forbes Boulevard, with pedestrian
amenities, all to implement the City’s draft “rails to trails” plan. A grand staircase allowing access from the
lower elevation of the GOP Master Plan site to the higher elevation of the 475 Eccles site was also proposed.
Accordingly, BMR submitted applications to modify the 2016 approvals for 475 Eccles to expand the project
to encompass the rail spurs and include this development. At the same time, BMR also sought appro val to
update the 475 Eccles design to bring it up to date and make it more compatible with the neighboring GOP
Master Plan project, without increasing the square footage previously approved for 475 Eccles. This revised
475 Eccles project, including the addition of the rail spur development, is known as “GOP 5.”
In 2020, the City Council adopted Resolution 119 -2020 approving the GOP 5 project. The approvals allow up
to 262,287 square feet of Floor Area in two new buildings, plus a parking structure. Th e approved project is
depicted as follows:
7
Because the GOP 5 project does not include any development that would take advantage of the 1.0 FAR
applicable to the rail spurs, the Development Agreement the City entered into for GOP 5 recognizes that:
L. WH EREAS, the modified development proposal is 262,287 square feet . . .
based on the application of an FAR of approximately 1.0 to the [475 Eccles
parcel], and does not include the density that could be available to Owner based
on the application of allowable FAR to the [rail spurs]; and
M. WHEREAS, by entering into this Agreement, Owner has not waived any
right it may have for future additional development on the Property based on the
application of allowable FAR to the Property.
The rail spurs consist of tw o legal parcels. APN 015-071-220 has 39,802 square feet (0.91 acres) and APN
015-071-340 has 80,419 square feet (1.85 acres). Together, this totals 120,221 square feet, or 2.76 acres.
Accordingly, the 1.0 FAR allows an additional 120,221 square feet of development that was not used in the
GOP 5 project.
II. Proposed GOP 4 Density Transfer Project.
A. Deed Restriction To Reduce FAR of Rail Spurs.
BMR proposes to deed -restrict the rail spur property to eliminate the 1.0 FAR development potential on the rail
spurs. The deed restriction would not allow any of the density transferred to GOP 4 to be constructed on the
rail spur property. This deed restriction would be required by a condition of approval to the GOP 4 Density
Transfer Project approvals. This deed restriction would be recorded in favor of the City and bind the land.
Accordingly, the practical effect of this deed restriction would be to reduce the current FAR at the rail spurs to
zero.
8
B. Use of Rail Spur FAR at GOP 4.
The square footage that could be developed under the 1.0 FAR applicable to the rail spurs would be transferred
to GOP 4. The GOP 4 North building would be expanded by 4 floors and 120,221 square feet. The resulting
building would provide a step-down transition between the GOP 1 North bu ilding, which was built at 12 stories
above ground level plus a penthouse, and GOP 4 South, which will remain as approved at 5 floors and a
penthouse. The approved architectural scheme of the buildings would be extended to the new floors, without
any substantive changes in architecture. The Density Transfer Project also includes a generator yard at ground
level in the landscaped area on the northwest side of the GOP 4 parking structure.
1. Resulting Square Footage and FAR.
In exchange for effectively reducing the FAR on the rail spurs to zero, the FAR would be increased at GOP 4,
and the GOP Master Plan would be amended to conform, as follows:
GOP 1
Parcel C
GOP 2
Parcel B
GOP 3
Parcel A
GOP 4
Parcel D
GOP Master
Plan (1-4)
Lot Square
Footage, after
most recent
LLA
284,584
(6.53 acres)
237,986
(5.46 acres)
185,262 (4.25
acres)
276,639a
(6.35 acres) 984,471
As Built or Entitled – Before GOP 4 Density Transfer Project
Building Floor
Area 479,116 371,648 302,722 225,621b 1,379,107
Building Floor
Area that
counts towards
FAR
427,104 312,130 265,734 225,621 1,230,589
FAR 1.50 1.31 1.43 0.82 1.25
After Implementation of the GOP 4 Density Transfer Project,
Which Proposes to Transfer 120,221 SF from the Rail Spurs to GOP 4
Building Floor
Area 479,116 371,648 302,722 345,842 1,499,328
Building Floor
Area that
counts towards
FAR
427,104 312,130 265,734 345,842 1,350,810
FAR 1.50 1.31 1.43 1.25 1.37
Notes
Floor Area is calculated pursuant to Municipal Code § 20.040.008. Floor Area Ratio (FAR) is
calculated pursuant to Municipal Code § 20.040.009.
a. The GOP 4 parcel was 276,422 SF when BMR first applied for the GOP 4 Precise Plan.
Pursuant to a Lot L ine Adjustment subsequently approved by the City, the GOP 4 parcel is
now 276,639 SF.
b. The approved plan set for GOP 4 shows 226,000 SF of Floor Area. However, subsequent
calculations that took into account the exact square footage of GOP 1 – 3 revealed that
only 225,261 SF of Floor Area (a difference of 379 square feet) is available to be built at
GOP 4 under the 1.25 FAR currently applicable to the entire GOP Master Plan site.
9
2. Resulting Parking.
The GOP 4 parking structure was approved at 6 levels (including 5 full floors and a partial level on the 6th
floor) and 531 stalls. The parking structure would be expanded by 2.5 floors and 240 stalls, resulting in a
structure of 8 levels and 771 stalls. These additional spaces will park the increment of additional square
footage at 2.0 spaces per 1,000 square feet of Floor Area. The remainder of the approved GOP Master Plan
campus will remain subject to the 2.73/1,000 parking ratio limitation of the Mas ter Plan. After development of
the GOP 4 Density Transfer Project, the blended parking ratio for the GOP Master Plan campus as a whole will
be 2.67 spaces per 1,000 SF.
C. Approvals Requested.
The approvals anticipated for the GOP 4 Density Transfer Projec t are:
1. Minor General Plan Amendment to Allow Density Transfer.
A minor amendment to the General Plan would be required to allow a density transfer. Specifically, BMR
seeks to add text to the notes in General Plan FAR tables 2.2 -1 and 2.2-2 that apply to the Business
Commercial land use. The notes would be amended to add the following underlined text:
The Gateway Business Park Master Plan and the Oyster Point Specific Plan are
permitted to develop up to a FAR of 1.25 with a TDM, and are allowed to
develop additional density to the extent such density would otherwise be
available on immediately adjacent property that is (a) subject to an FAR
limitation of 1.25 or less; (b) part of the same research & development campus;
and (c) deed -restricted to preclude d evelopment of the transferred FAR .
2. Specific Plan Repeal or Amendment.
Because the Gateway Specific Plan may be considered outdated, and because the relevant components of the
Specific Plan have already been incorporated into the applicable zoning distr ict regulations, the Specific Plan
could be repealed. Barring repeal, the Specific Plan would be amended to allow a transfer of density from
adjacent property into the Specific Plan area, using the same text as quoted above.
3. Zoning Text Amendment.
The Gateway Specific Plan Zoning District regulations would be amended to allow a transfer of density from
an adjacent zoning district, using the same text as quoted above.
4. GOP Master Plan Amendment.
The GOP Master Plan would be amended to allow a transfer of density from adjoining property, using the
same text as quoted above.
5. GOP 4 Precise Plan Modification and Design Review.
The GOP 4 Precise Plan would be modified to incorporate an additional 120,221 square feet, with four
additional floors on the GOP 4 North building, and 2.5 additional floors on the parking structure. The
modifications would undergo associated design review.
10
154410725.2
6. GOP Master Plan Development Agreement Amendment.
The Development Agreement for the GOP Master Plan project would be amended to e ncompass the above
approvals.
III. Environmental Review of the GOP 4 Density Transfer Project.
The physical changes to the approved Master Plan project that are proposed by the GOP 4 Density Transfer
Project consistent of a relatively small expansion of 120,2 21 square feet configured in four floors to be added
to the approved design for the GOP 4 North building. Under CEQA, the City is required to evaluate whether,
since the most recent CEQA determination was made on August 6, 2020, th is change to the GOP Master Plan
project, or any changes in the surrounding circumstances, or significant new information relevant to the scope
of approvals requested for the GOP Density Transfer Project , result in new or more severe significant adverse
environmental impacts.
Because the GOP 4 Density Transfer Project proposes to add additional floors to the approved project without
changing building footprints, no new or more severe significant impacts are anticipated in relation to
agricultural/forest ry resources, biological resources, cultural resources, geology/soils, hydrology/water quality,
wildfire, mineral resources, tribal cultural resources or exposure to any hazardous materials resulting from
demolition of existing buildings or grading. Due to building, operational and transportation efficiencies that
have developed since the EIR was certified , it is anticipated that the 120,221 square -foot expansion will not
cause the Master Plan project , as modified by the GOP 4 Density Transfer Project, to exceed the projections of
the original EIR with respect to air quality emissions, water demand, or greenhouse gas emissions. The
relatively minor expansion without any changes to land uses is not anticipated to result in material changes
with respect to impacts related to population/housing, energy demand, public services and utilities, recreation,
noise, growth-inducing impacts or land use/planning. The additional floors will provide a visual transition
between the GOP 1 buildings and the GOP 4 south build ing, such that no new or more severe significant
aesthetic impacts are anticipated. No changes are proposed to height limitations, and the expansion proposed
by the GOP 4 Density Transfer Project would remain subject to mitigation imposed regarding aircra ft noise.
Accordingly, the Density Transfer Project is not anticipated to change any conclusions relating to consistency
with the applicable Airport Land Use Plan. The expansion area will be subject to the same regulations relating
to the handling of hazardous materials as the rest of the site, so no new or more severe impacts are anticipated
in that context . The SEIR will document the conclusion and none of these resource areas trigger the need for
supplemental or subsequent review.
The Supplemental EIR will evaluate whether the vehicle miles travelled associated with the 120,221 square -
foot expansion would be significant , and explore mitigation if the impact is found to be significant . The
Supplemental EIR also will evaluate whether there are any ne w or more significant impacts to any other
transportation-related resources. The SEIR will evaluate the no project alternative and will assess whether any
other potentially feasible alternatives to the GOP 4 Density Transfer Project would reduce or offset any
significant Vehicle Miles Traveled impacts.
Appendix B
NOP Scoping Comment Letters
“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
December 15, 2021 SCH #: 2008062059
GTS #: 04-SM-2021-00398
GTS ID: 24810
Co/Rt/Pm: SM/101/22.7
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Avenue
South San Francisco, CA 94080
Re: GOP 4 Density Transfer Project Notice of Preparation (NOP)
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the GOP 4 Density Transfer 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 November 2021 NOP.
Project Understanding
The project would modify the previously approved Gateway Business Park Master Plan
project. The Gateway Business Park Master Plan project (“GOP 4”) Density Transfer
Project proposes to transfer up to 120,221 square feet of development potential from
undeveloped adjacent property to expand one of the buildings approved for Phase 4
of the GOP 4 by that amount, to be configured in four additional floors. The project
also proposes the addition of 240 parking stalls. Furthermore, the City of South San
Francisco (City) will conduct a Supplemental EIR (SEIR) to evaluate impacts related to
vehicle miles travelled associated with the 120,221 square-foot expansion and to other
transportation-related resources. The project is located roughly 0.4 miles southeast of
the US Route (US)-101/Oyster Point Boulevard interchange.
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, Principal Planner
December 15, 2021
Page 2
“Provide a safe and reliable transportation network that serves all people and respects the environment”
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 SEIR, which should
include the following:
● VMT analysis pursuant to the City’s 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 traffic safety issues to the State Transportation
Network (STN) may be assessed by Caltrans via the Interim Safety Guidance.
● 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.
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 variable.
Given the place, type and size of the project, the SEIR 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:
● Project design to encourage mode shift like walking, bicycling and transit access;
● Transit and trip planning resources such as a commute information kiosk;
Billy Gross, Principal Planner
December 15, 2021
Page 3
“Provide a safe and reliable transportation network that serves all people and respects the environment”
● Real-time transit information systems;
● Transit access supporting infrastructure (including bus shelter improvements and
sidewalk/ crosswalk safety facilities);
● New development vehicle parking reductions;
● Implementation of a neighborhood electric vehicle (EV) network, including
designated parking spaces for EVs;
● Designated parking spaces for a car share program;
● Unbundled parking;
● Wayfinding and bicycle route mapping resources;
● Participation/Formation in/of a Transportation Management Association (TMA) in
partnership with other developments in the area;
● Aggressive trip reduction targets with Lead Agency monitoring and enforcement;
● VMT Banking and/or Exchange program; and/or
● Area or cordon pricing.
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.
Transportation Impact Fees
Please identify project-generated travel demand and estimate the costs of transit and
active transportation improvements necessitated by the proposed project; viable
funding sources such as development and/or transportation impact fees should also
be identified. We encourage a sufficient allocation of fair share contributions toward
multi-modal 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.
Billy Gross, Principal Planner
December 15, 2021
Page 4
“Provide a safe and reliable transportation network that serves all people and respects the environment”
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 LDR-D4@dot.ca.gov.
Sincerely,
MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
December 20, 2021
TRANSMITTED VIA E-MAIL and U.S. MAIL
billy.gross@ssf.net
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Street
South San Francisco, California 94080
Subject: Notice of Preparation of a Supplemental Environmental Impact Report (SEIR) Comments
for the GOP 4 Density Transfer Project (SCH #2008062059)
Dear Mr. Gross:
San Francisco International Airport (SFO or the Airport) staff have reviewed the Notice of Preparation
(NOP) of a Supplemental Environmental Impact Report (SEIR) for the GOP 4 Density Transfer Project (the
Proposed Project), located in the City of South San Francisco. We appreciate this opportunity to provide
comments on the NOP.
The Proposed Project is located at 850 and 900 Gateway Boulevard, southeast of the intersection of Gateway
Boulevard and Oyster Point Boulevard, in the City of South San Francisco. The Proposed Project includes
transfer of up to 120,221 square feet of development potential from undeveloped adjacent property (at
GOP 5) and use it to expand one of the buildings approved for Phase 4 of the Gateway Business Park Master
Plan Project (GOP 4). GOP 4 was originally approved by the Planning Commission in 2020 for two
five-story buildings (at an elevation of 137 feet above the North American Datum of 1988 [NAVD88]) and a
six-story parking structure. The Proposed Project would include expansion of the GOP 4 North building by
four floors, for a total of nine floors estimated at an elevation of 201 feet NAVD88.1
The Proposed Project site is inside Airport Influence Area B as defined by the Comprehensive Airport Land
Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP). The entire
Proposed Project site would be located outside the 65 decibel (dB) Community Noise Equivalent Level
(CNEL) contour and the Safety compatibility zones, and therefore appear compatible with the ALUCP.
As described in Exhibit IV-17 of the ALUCP, the critical airspace surfaces at the Proposed Project location
are 510-540 feet NAVD88. Thus, the heights of the buildings would be below the critical airspace surfaces
and the Proposed Project would be compatible with the ALUCP, subject to the issuance of a Determination
of No Hazard from the Federal Aviation Administration (see below) for any proposed structures.
1 The total proposed height of GOP 4 North was not provided in the NOP. The proposed elevation was calculated by
assuming 16 feet per floor, based on the GOP 4 Precise Plan (available at: https://ci-ssf-
ca.legistar.com/LegislationDetail.aspx?ID=4605845&GUID=169A73FE-0F56-4B24-8B15-05740E1C5112 ). The
original plan for GOP 4 North was for an elevation of 137 feet NAVD88. An additional fou r floors would add 4 x 16
feet (or 64 feet) for a total of 201 feet NAVD88.
DocuSign Envelope ID: 55A93235-E9DF-4544-B3BD-65AEE80E79D9
Billy Gross, City of South San Francisco
December 20, 2021
Page 2 of 2
This determination does not negate the requirement for the Project proponent to undergo Federal Aviation
Administration review as described in 14 Code of Federal Regulations Part 77 for both the permanent
structures and any temporary cranes or other equipment taller than the permanent buildings which would be
required to construct those structures.
* * *
The Airport appreciates your consideration of these comments. We look forward to reviewing the
Supplemental Environmental Impact Report when made public. If I can be of assistance, please do not
hesitate to contact me at (650) 821-9464 or at nupur.sinha@flysfo.com.
Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
cc: Susy Kalkin, ALUC
Audrey Park, SFO, Acting Environmental Affairs Manager
DocuSign Envelope ID: 55A93235-E9DF-4544-B3BD-65AEE80E79D9
Appendix C
Vehicle Miles Traveled Analysis
154432543.2
Gateway of Pacific (GOP) Phase 4
Expansion
Transportation Analysis – CEQA Analysis
Prepared for:
BioMed Realty – Gateway of Pacific IV LP
December 29, 2021
Hexagon Transportation Consultants, Inc.
Hexagon Office: 4 North Second Street, Suite 400
San Jose, CA 95113
Phone: 408.971.6100
Hexagon Job Number: 21TD06
Client Name: BMR – Gateway of Pacific IV LP
GOP Phase 4 Expansion December 29, 2021
Page | 2
154432543.2
Project Description
This report presents the results of the California Environmental Quality Act (CEQA) transportation
analysis (TA) conducted for the proposed expansion of an approved Office/Research and Development
(R&D) building in the East of 101 Area in South San Francisco, California. The project consists of a
transfer of density from adjacent undeveloped former rail spurs, resulting in a 120,221 square foot (s. f.)
expansion of “Gateway of Pacific (GOP) 4 North”, an R&D building that was approved as part of phase
4 development of the Gateway of the Pacific (GOP) Master Plan. The GOP Master Plan currently
consists of a total of 1,231,000 s.f. of R&D uses that would be built in 4 phases and was approved in
2013. The GOP Phase 4 Precise Plan consists of two R&D buildings and a parking structure and was
approved recently in 2020. The project is seeking to modify the Precise Plan and related entitlements to
allow an expansion of 120,221 s.f. to be configured in four extra floors added to the GOP 4 North
building and adding 2.5 additional levels to the GOP 4 parking structure.
The potential project related transportation deficiencies were evaluated in accordance with the
standards and methodologies set forth by the City of South San Francisco. This study evaluates the
potential impacts on vehicle miles traveled (VMT), transit, pedestrian and bicycle facilities, safety, and
emergency access.
GOP Phase 4 Expansion December 29, 2021
Page | 3
154432543.2
CEQA Analysis
VMT Analysis
Pursuant to SB 743, the CEQA 2019 Update Guidelines Section 15064.3, subdivision (b) states that
vehicle miles travelled (VMT) will be the metric in analyzing transportation impacts for land use projects
for California Environmental Quality Act (CEQA) purposes. Consistent with the State CEQA guidelines,
the City of South San Francisco has adopted the thresholds of significance based on type of
development projects to guide in determining when a project will have a significant transportation
impact.
Thresholds of significance identify whether a project's effect on VMT is significant. According to the City
of South San Francisco’s VMT guidelines (adopted in June 2020), a significant impact would occur for
employment generating projects if the baseline project-generated home-based work (HBW) VMT per
employee is higher than 85% of the existing nine-county Bay Area-Wide average for employee VMT.
According to the City/County Association of Governments (C/CAG) – Valley Transportation Authority
(VTA) Travel Demand Model, the existing Bay Area-wide regional average daily VMT per employee is
14.2, so the threshold is 12.1 daily VMT per employee (see Table 1). The 2040 cumulative Bay Area-
wide regional average daily VMT per employee is 14.6, so the threshold is 12.4 VMT per employee for
cumulative conditions.
Table 1
Home-Base Work Vehicle Miles Traveled Per Employee Thresholds
Project-generated HBW VMT per employee is estimated based on the HBW VMT for the project’s
transportation analysis zone (TAZ) in the C/CAG travel demand model. A TAZ is the smallest resolution
available in the C/CAG model. Each TAZ included in the model contains information related to the
existing and proposed land uses and transportation options in that zone. Therefore, the transportation
properties of the project’s TAZ are an appropriate proxy for transportation properties of the project itself.
A significant project impact would occur under the following conditions.
• If the existing HBW VMT per employee in the travel demand model TAZ that encompasses the
project is greater than 12.1 under existing conditions.
Location Estimated HBW VMT Estimated
Employees
Estimated HBW
VMT per Employee
Bay Area Region
(Existing)63,336,200 4,461,670 14.2
VMT Reduction
Factor -15%
12.1
Bay Area Region
(2040 Cumulative)78,980,240 5,406,190 14.6
VMT Reduction
Factor -15%
12.4
Source: Fehr & Peers 2020; C/ CAG-VTA Bi-County Transportation Demand Model, 2019.
HBW VMT Per Employee Threshold
HBW VMT Per Employee Threshold
GOP Phase 4 Expansion December 29, 2021
Page | 4
154432543.2
• If the 2040 HBW VMT per employee in the travel demand model TAZ that encompasses the
project is greater than 12.4 under cumulative conditions.
The existing land use and transportation characteristics of the East of 101 area contribute to the East of
101 Area’s higher-than-average VMT per employee. As a single-use employment center, all
homebased trips begin or end outside the East of 101 area, requiring longer travel along auto-oriented
roadways. Longer trips also result from the fact that South San Francisco, and especially the East of
101 area, is bounded by the Bay on its eastern side, further limiting the locations where housing could
be located. Also, transit service to the area is limited. As a result, all employment-based uses in the
East of 101 Area are likely to have longer commute trips compared to average HBW trips in the Bay
Area. It is noted that the higher-than-average VMT per employee is not unique to South San Francisco
and is common for many cities in the peninsula.
Based on the C/CAG travel demand model, the VMT per employee within the 120,221 square foot
expansion proposed by the density transfer project would be 16.2 under existing Conditions (see Table
2). This is above the threshold of 12.1 for existing conditions. Under cumulative 2040 conditions, the
project VMT per employee would be 12.9, which is above the threshold of 12.4 HBW VMT per
employee. Therefore, the project would result in a significant VMT impact under existing and cumulative
conditions.
Table 2
Project VMT Impact Determination
The GOP Master Plan is required to implement a TDM program designed to achieve a 40% non-drive
alone mode share during peak periods under the City’s current TDM requirements and policy direction
to reduce single-occupant vehicle trips. Because the expansion proposed by the density transfer
project would become part of the GOP Master Plan and is expected to generate more than 100
average daily trips, the 120,221 square-foot expansion would be subject to this TDM program, and
it would become part of a life sciences campus that is already subject to this program. The purpose
of the TDM plan is to develop a set of strategies, measures, and incentives to encourage future
employees of GOP to walk, bicycle, use public transportation, carpool, or use other alternatives to
driving alone when traveling to and from work. Some of the GOP Master Plan TDM Measures
(based on Gateway Business Park Transportation Demand Management Program, April 2013)
include:
• The tenants of GOP will join commute.org, a joint powers agency (JPA) located in San Mateo
County whose mission is to reduce the VMT generated by commuters to decrease congestion,
improve the environment, and enhance quality of life by encouraging and supporting the use of
sustainable alternatives to driving alone.
• Transportation options will be outlined in the tenant’s employee handbook, or on an intranet site.
• The GOP building lobbies, employee break rooms, or other common areas will include
permanent displays of commute alternative information.
Location Estimated HBW
VMT
Estimated
Employees
Estimated HBW
VMT per Employee
VMT per
Employee
Threshold
VMT
Impact
Project (Existing)5,194 321 16.2 12.1 Yes
Project (2040
Cumulative)4,136 321 12.9 12.4 Yes
Source: Fehr & Peers 2020; C/ CAG-VTA Bi-County Transportation Demand Model, 2019.
GOP Phase 4 Expansion December 29, 2021
Page | 5
154432543.2
• Bicycle storage will be provided on-site as racks, cages, lockers, or within a secured area inside
the buildings. Both long- and short-term bicycle parking will be accommodated in accordance
with requirements of the South San Francisco Municipal Code.
• Shower facilities with clothing lockers will be provided within each building to ensure shower
access is available to all employees.
• Free preferential parking spaces will be provided for carpools and vanpools at a ratio of not less
than 10% of all parking spaces.
• The tenants of the buildings will designate an individual TDM Coordinator(s) (or may share a
coordinator with other tenants).
• The TDM Coordinator will provide new employee orientation packets, flyers, posters, email, and
educational programs on a quarterly basis.
• The TDM Coordinator will provide ride-matching services for carpool and vanpool users through
511.org and/or an internal program.
• Employees will be able to utilize commute.org’s free guaranteed ride home program for
emergencies via taxicabs or rental cars. If commute.org discontinues its program,
employers/tenants will provide an equal program in order to maintain access to free guaranteed
rides home for emergencies.
• A well-lit path or sidewalk will be provided on site to the most direct route to the nearest transit
or shuttle stop from the building.
• A future shuttle stop for northbound shuttles will be located along the GOP frontage directly
across from 751 Gateway Boulevard.
• The landlord will complement existing shuttle services with additional shuttles as necessary to
ensure adequate connections to transit.
• A loading zone for vanpool and carpool rides will be provided near the building entrances.
• Lighted paths and sidewalks will be provided between the buildings, and parking areas.
• Tenants will be required to offer flextime options such as compressed workweeks and
alternative work hours.
• Employees will have the option to forego their parking space for a cash benefit.
• Bicycle connections will be provided to bicycle parking areas from bicycle routes.
• The site will contain several amenities, such as a restaurant establishment, convenience store,
and outdoor spaces.
• Transit ticket sales will be provided on-site and facilitated online.
• While parking spaces for vanpools and carpools will be free and in preferential locations,
employees driving alone must pay a monthly fee for parking.
• The tenants will subsidize transit tickets. This will be done through the Commuter Check
Program which allows employees to make additional pre-tax payroll contributions to purchase
transit tickets or monthly passes.
• The TDM Coordinator will administer an annual survey to determine alternative transportation
mode use and opportunities to TDM strategy adjustments.
Based on U. S. Census Bureau, 2006-2010 American Community Survey, the non-drive alone mode
share for commute trips in San Mateo County is 29%. The project will be required to achieve a 40%
non-drive alone mode share, which represents an additional 11% percent reduction in non-drive
alone mode share from baseline conditions.
However, reductions in non-drive alone mode share are not necessarily interchangeable with VMT
reductions on a percentage point for percentage point basis because mode share targets do not
necessarily correlate with trip generation and trip length. Although many East of 101 employers meet
their non-drive alone mode share targets, and while trip generation is lower than ITE rates due to TDM
programs, vehicle trip generation and trip lengths in this area are slightly higher than regional averages
GOP Phase 4 Expansion December 29, 2021
Page | 6
154432543.2
based on the C/CAG travel demand model outputs. Therefore, project HBW VMT per employee was
not adjusted based on the GOP TDM plan.
Mitigation Measures
First- and last-mile transit connections and active transportation improvements are likely to yield the
greatest VMT reductions. These measures would not only serve the density transfer project but also the
entire GOP campus and all of the existing and planned development in the area. Thus, the new VMT
generated by the project would be partially offset by reductions in VMT for other development. The
following mitigation measures support and enable the first-and last-mile non-auto commute strategies in
the GOP Master Plan TDM Plan. The mitigation measures described below are appropriate under both
existing plus project conditions and cumulative plus project conditions. These improvements are shown
on Figure 1.
• The project applicant has acquired the rail spur property adjacent to GOP Phase 4 and shall use
it to connect the GOP Master Plan site with the 475 Eccles project site, which is currently
referred to as GOP Phase 5, approved for two office/R&D buildings totaling 262,287 s.f. and
one parking structure. The applicant proposes to develop the rail spurs into a publicly accessible
multi-use path connecting Oyster Point Boulevard with Forbes Boulevard, with pedestrian
amenities, all to implement the City’s draft “rails to trails” plan. A grand staircase allowing
access from the lower elevation of the GOP Master Plan site to the higher elevation of the 475
Eccles site is also proposed. This multi-use path shall connect to Class II bicycle lanes on
Oyster Point Boulevard and to the multi-use trail on Forbes Boulevard.
• The project shall make a fair-share contribution towards upgrades to the trail connection
between the GOP Master Plan’s multi-use trail and Caltrain access at E. Grand Avenue as
identified in the Mobility 2020 East of 101 Transportation Plan for the Caltrain Access
Improvement Concept (see attachment). The City is upgrading the block on E. Grand Avenue
(south of Grand Avenue) to be a wider multi-use trail, but the remaining segment on E. Grand
Avenue (east of Grand Avenue) and Forbes Boulevard is currently a split sidewalk/narrow trail
that would not support long-term capacity needs. Improvements to Caltrain access along East
Grand Avenue will help maximize station ridership and provide convenient bicycle and
pedestrian connectivity between downtown and the entire East of 101 Area.
The amount of the fair share contribution shall be determined in the conditions of approval of the
modified Precise Plan for GOP 4. The project shall pay a fair share fee towards the cost of
these trail connection upgrade improvements without regard to whether the project would
otherwise be vested against payment of that fee, but in no event will the project be required to
pay both a fair share fee and a citywide fee that will help fund the trail connection upgrade
improvements.
If fair share responsibilities for the cost of these trail connection upgrade improvements have
already been determined as part of the City’s development impact fee program, then the project
shall pay a fee for each square foot of the approved expansion area (up to 120,221 square feet)
equal to the portion of the Citywide fee for R&D/Office uses that is attributable to the cost of
these trail connection upgrade improvements. If fair share responsibilities have not been
determined, then the project’s fair share shall be calculated by using vehicle trips as an
approximation of pedestrian and bicycle trips. The project’s fair share will be equal to the
percentage of trips the expansion (up to 120,221 square feet) will generate on the roadways
adjacent to the trail connection upgrade improvements compared to all vehicle trips on such
GOP Phase 4 Expansion December 29, 2021
Page | 7
154432543.2
roadways. The city has advised that it is considering construction of certain bicycle connections
instead, which would mitigate with more certainty than the fair share contribution would.
Implementation of these mitigation measures include improvements that support and enable the first-
and last-mile non-auto commute strategies. However, the mitigation measure’s effectiveness is
unknown and may not reduce the project’s HBW VMT below the existing and cumulative thresholds to
reach a less-than-significant level. Therefore, the project’s effect on VMT would be significant and
unavoidable.
Transit, Pedestrian and Bicycle Analysis
A significant impact would occur if the proposed project conflicted with applicable or adopted policies,
plans or programs related to pedestrian facilities or otherwise decreased the performance or safety of
pedestrian facilities. The GOP Master Plan would develop a pedestrian-friendly Central Commons open
space in the area created by the parking structures and the office buildings. The master plan would
enhance public street frontages and foster transit use by providing multiple pedestrian connections to
and from the internal campus and shuttle system stops. The proposed expansion would be compatible
with the Master Plan and the existing GOP 4 Precise Plan. Therefore, the project would not have a
detrimental impact to pedestrian circulation and would not trigger any new or more severe significant
pedestrian circulation impacts.
Bicycle access to the project is provided via the bicycle lanes on Oyster Point Boulevard and the bike
route on Gateway Boulevard. As part of GOP Phase 5, the existing rail spur that separates the phases
4 and 5 sites would be redeveloped into a multi-use trail. This multi-use trail would provide an additional
connection between the Class II bicycle lanes on Oyster Point Boulevard and the existing multi-use trail
on Forbes Boulevard. The proposed project would not conflict with existing and planned bicycle
facilities; therefore, the impact to bicycle facilities would be less-than-significant.
The 120,221 square foot expansion proposed by the density transfer project is expected to generate
trips via transit services, which can be accommodated by the existing/planned transit capacity.
According to OPR guidelines, the addition of new transit riders should not be treated as an adverse
impact as such development also improves regional flow by adding less vehicle travel onto the regional
network. Therefore, the project will not cause any new or more severe significant transit service
impacts.
Safety
A project safety impact is considered significant if the proposed project would provide inadequate
design features that present safety concerns within the project site or on the adjacent streets. The
proposed expansion would not alter any design components of the recently approved GOP Phase 4
Precise Plan, and thus the project would not result in any new or more severe safety impacts.
Emergency Access
The proposed project would not reroute or change any of the city streets in its vicinity that would impact
emergency vehicle access to the GOP Master Plan site. Access to GOP Master Plan sites would be
provided via driveways along Oyster point Boulevard and Gateway Boulevard. Park Street, a new
internal access roadway would be constructed along the east side of the parking garages and would
connect to Oyster Point Boulevard to the north and Gateway Boulevard to the south. The emergency
vehicles would utilize all entries and supplemental access points as necessary to reach Park Street and
the central pedestrian walkway which would be wide enough to serve as an emergency vehicles route.
Thus, the project would not result in any new or more severe adverse emergency vehicle access
impact.
South
San Francisco
101Airport BlvdAirport BlvdGateway BlvdLinden AveE
G
r
a
n
d
A
v
e
Utah Av
e
Forbes BlvdDubuque AveEccles AveRandol
p
h
A
v
e
Cypress AvePoletti WyPoletti WyHarbor WayS Airport BlvdSister
C
i
t
i
e
s
B
l
v
d
Hil
l
s
i
de
B
l
v
d
Oyster Point Blvd
Mitchell Ave
Ar
m
o
u
r
A
v
e
GrandGrandAveAve
E GrandE Grand
AveAve
Miller
A
v
e
Miller Ave
C
o
r
p
o
r
a
t
e
D
r Ve
t
e
r
a
n
sVe
t
e
r
a
n
sBl
v
dBl
v
d
Airport BlvdPoletti WyGrand
Ave
E Grand
Ave
Miller
A
v
e Ve
t
e
r
a
n
sBl
v
d
San Mateo AveSpruc
e
A
v
e
S p ru c e A v e
Spruc
e
A
v
e
= GOP Master Plan Boundary
= Trail Pathway
= GOP 4
= GOP 5
LEGEND
Notes:
Caltrain
Station
Relocation
Construct a new multi-use trail within the GOP Master Plan connecting
Oyster Point Boulevard to the north and Forbes Boulevard to the south.
Pay fair-share contribution towards upgrades to trail connection between
the new multi-use trail and Grand Avenue/E Grand Avenue.
1
1
2
2
GOP 4 Expansion
Figure 1
Project Mitigation Measures
Attachment
East Grand Avenue – Caltrain Access Improvement Concept
31 31Project Opportunities
JUNE 2019
Figure 17: East Grand Avenue - Caltrain Access Improvement Concept
Cross-section west of Forbes/Harbor Cross-section west of Forbes/Harbor
O-ramp realignment
for direct connection
to Caltrain station and
Grand Avenue
New sidewalk and
staircase to bicycle/pe-
destrian underpass as
part of Caltrain station
improvements
Trail network /
extensions to connect
Caltrain station to
surrounding streets
New crosswalk / trail
crossing
New crosswalk / trail
crossing
Slip lane closures
On-street buered or
separated bike lanes
On-street buered or
separated bike lanes
Short bus-only lanes /
queue jump lanes
Redesign street aer
reconfiguration of
US-101 o ramp
Eastbound bus lane serves
shuttles and potential
expansion of SamTrans
service; westbound more
challenging due to NB
US-101 onramp Bus-only le turn lane
to provide shortcut for
shuttles accessing
Caltrain station
Widen approach to
provide bus queue
jump lane
ROW narrows - buers
or separation would
require curb
reconstruction
New signal planned
with 213 E Grand
project
East Grand Ave Roebling RdForbes BlvdHarbor WayGateway BlvdEast Grand Ave
Gra
n
d
A
v
e
100 feet
Proposed Trail
Sidewalk or curb extension
Bike lane
Bus Lane
Roadway StripingBus StopCaltrain Station
TRAIL
Improvements to Caltrain access along East Grand Avenue will help maximize station ridership and provide
convenient bicycle and pedestrian connectivity between downtown and the entire East of 101 Area. Over
the long term, the reconfiguration of the northbound US-101 offramp presents an opportunity to redesign
East Grand Avenue adjacent to the Caltrain station.
Appendix D
Air Quality and Greenhouse Gas
Emissions Report
1/4
Ramboll
2200 Powell Street
Suite 700
Emeryville, CA 94608
USA
T +1 510 655 7400
F +1 510 655 9517
www.ramboll.com
MEMO
Date: December 1, 2021
To: Paul Stephenson, AICP, ESA
From: Michael Keinath, PE
Rishabh Shah, PhD
Subject: OPERATIONAL EMISSIONS OF CRITERIA AIR POLLUTANTS AND
GREENHOUSE GAS AND ENERGY CONSUMPTION FOR REVISED
GOP MASTER PLAN, SOUTH SAN FRANCISCO, CALIFORNIA
Ramboll evaluated operational emissions of criteria air pollutants (CAPs) and
greenhouse gases (GHG) for the GOP 4 density transfer project in South San
Francisco, California. The GOP 4 density transfer project will modify the Gateway of
Pacific (GOP) project, which is formerly known as the Gateway Business Park
Master Plan project, resulting in an expansion of up to 120,221 square feet. We
compared the emissions of the modified GOP project to the emissions projected in
the EIR for the original project and determined that the density transfer project will
not result in increased emissions.
As used in this report, “Original Project” refers to the Gateway Business Park
Master Plan project studied in the EIR, and “Modified Project” refers to the GOP
project as modified to incorporate the 120,221 additional square feet proposed by
the GOP 4 density transfer project.
PROJECT UNDERSTANDING
The Gateway Business Park Master Plan project was originally entitled in 2010 for a
total 1,230,570 square feet to replace the then existing 284,000 square feet at the
site (Draft EIR dated October 2009 and Final EIR dated January 2010). It was
originally anticipated to be constructed in five phases over roughly 9 years from
2011 through 2020. The project was modified in 2013 to update the architecture,
provide for a different site layout and alter the phasing, all without changing the
square footage, at which point it became known as the Gateway of Pacific (GOP)
project. BMR is currently executing the project in four phases (called GOP 1-4).
Construction on GOP 1 began in May 2017, and first occupancy was in March 2021.
Construction on GOP 2 began in April 2019, and occupancy is expected to begin
March 2022. Construction on GOP 3 began in August 2019, and occupancy is
expected to begin in the third financial quarter of 2022. A Precise Plan for GOP 4
was approved o n August 6, 2020, and construction has not commenced.
BMR is currently pursuing the GOP 4 density transfer project to transfer floor-area
ratio (FAR) from some adjacent former rail spur properties to GOP 4, to allow a
potential expansion of up to 120,221 SF at GOP 4. This will likely take the form of
2/4
adding four full floors to GOP 4 North and an additional 2.5 floors to the GOP 4 parking garage,
collectively referred to as the “GOP 4 Density Transfer Project.”
In this report, we present our analyses which demonstrate that due to emissions reductions in the
vehicle fleet as well as building design which exceed the incre asingly stringent energy requirements
from California Building Code (Title 24), the operational emissions associated with the Modified Project
are within equal to or lower than the net operational emissions that were estimated for the Original
Project as part of the EIR. Consequently, the Modified Project buildout, including the proposed
expansion, will not exceed the emissions disclosed in the EIR.
SUMMARY OF RESULTS
Operational emissions of CAPs and GHGs are presented in Table 1. As shown in the table, re-
evaluated operational emissions are below those disclosed in the EIR. Energy use will also be lower
than those evaluated in the EIR.
DATA SOURCES AND EMISSIONS METHODOLOGIES
The following sections describe the input data and methodologies used in the operational emissions
analysis.
Emissions Estimation
Ramboll utilized the California Emission Estimator Model version 2020.4.0 (CalEEMod®)1 to quantify
all operational CAP emissions. CalEEMod® is a statewide program designed to calculate both CAP and
GHG emissions for development projects in California. It utilizes widely accepted models for emission
estimates combined with appropriate default data that can be used if site -specific information is not
available. CalEEMod® uses sources such as the US Environmental Protection Agency (USEPA) AP -42
emission factors,2 California Air Resources Board’s (CARB) on-road and off-road equipment emission
models such as the EMission FACtor model (EMFAC2017) and the Emissions Inventory Program model
(OFFROAD), and studies commissioned by California agencies such as the California Energy
Commission (CEC) and CalRecycle. It calculates both the daily maximum and annual average for CAPs
as well as total or annual GHG emissions.
Updates to CalEEMod ® Default Assumptions
In preparing Project operational emissions, the Project sponsor made several updates to the
CalEEMod® default factors and assumptions. These are described below:
• Project energy usage intensity was provided by the Project sponsor for GOP 1, 2, and 3. This
includes electricity and natural gas consumption for the buildings that was developed through
energy modelling used for LEED and Title 24 compliance. Since energy intensity was not provided
for GOP 4, we modelled a scenario for GOP 4 by averaging the energy intensities of GOP 1, 2, and
3 instead of using CalEEMod® defaults.
• Project indoor water demand was provided by Project sponsor for GOP 1, 2, 3, and 4. Since
outdoor water demand was not provided, CalEEMod® defaults were applied.
• Project vehicle trip rate (trips/day) was provided by Hexagon, the Project sponsor’s traffic
consultant. The total trip length for all employee trips was also provided by Hexagon. Trip
1 California Air Pollution Control Officers Association (CAPCOA). 2016. California Emissions Estimator Model.
Available at: http://www.CalEEMod.com/.
2 The USEPA maintains a compilation of Air pollutant Emission Factors and process information for several air
pollution source categories. The data is based on source test data, material balance studies, and engineering
estimates. Available at: http://epa.gov/ttnchie1/ap42/.
3/4
information data provided by Hexagon were more up-to -date and representative of the project
compared to the data that were used in the original EIR. CalEEMod® defaults were used to
extrapolate the total trip length for visitors, such as vendors.
• Information on on-site emergency generators (horsepower, engine tier, fuel type) was provided by
Project sponsor. CalEEMod® default emission factors were replaced with factors appropriate for
provided tier level and horsepower, per CARB guidance.3 A maximum of 50 operational hours per
year was assumed for each generator, in accordance with BAAQMD limits.
• Reactive organic gas (ROG) emissions from consumer products (e.g., cleaners, personal care
products, paints, etc.) were not considered in the original EIR. For consistency, we also did not
consider ROG emissions from consumer products in this analysis.
DAILY OPERATIONAL EMISSIONS OF ROG, NOX, AND PM10
Operational emissions of ROG, NOX, and PM10 associated with the project originate from area sources
(e.g., architectural coating, landscaping), energy use (electricity and natural gas consumption),
transportation (employee and vendor trips to and from the site), and on-site emergency generators.
While emissions in the original EIR were predicted using the URBEMIS 2007 emissions model, the re-
evaluated emissions were predicted using CalEEMod® which has more up-to -date emission sources
and factors. As shown in Table 1 , the Modified Project (including GOP 4 expansion) would be
significantly below the mass emissions disclosed in the EIR for the Original Project.
ANNUAL OPERATIONAL EMISSIONS OF GREENHOUSE GASES (GHG)
Operational emissions of GHGs associated with the project originate from two major sources: energy
use (electricity and natural gas consumption) and transportation (employee and vendor trips to and
from the site). In the EIR for the Original Project, GHG emissions from on-site emergency generators
were not evaluated. While relatively trivial, we include GHG emissions from on-site emergency
generators in our evaluation of the Modified Project. As shown in Table 1, the Modified Project would
be significantly below the mass emissions of the Original Project as disclosed in the EIR. The GHGs
considered in our analysis are carbon dioxide (CO2), nitrous oxide (N2O), and methane (CH4). Since
these GHGs have different global warming potentials, we converted all emissions to “CO2e” (CO2-
equivalent), consistent with the EIR.
ENERGY CONSUMPTION
As shown through the reduction in CAP and GHG emissions from the Original Project to the Modified
Project, energy use will be lower for a variety of reasons. First, the vehicle fleet is now more fuel
efficient due to increasingly stringent state and federal fuel efficiency standards. Additionally,
California building code has increasingly stringent energy requirements with each iteration of the Title
24 code. As all buildings in GOP are designed to be lower than the current (at time of plan approval)
Title 24 code, energy use in buildings is lower than it would have been at the time of the EIR. Lastly,
the overall electrical grid is much cleaner as a result of the statewide renewable portfolio standard,
which mandates increasingly higher percentages of renewable energy sources. As such, electricity
emissions are lower than was projected at the time of the EIR, and as a result, the 120,221 square -
foot expansion can be accommodated without increasing the projected energy demand. This is shown
explicitly by the reduction in CAP and GHG emissions.
3 CARB. Non-road Diesel Engine Certification Tier Chart. Available at:
https://ww2.arb.ca.gov/resources/documents/non-road-diesel-engine-certification-tier-chart. Accessed:
November 24, 2021.
4/4
CLOSING
The analysis presented above represents operational emissions of CAPs (ROG, NOX, and PM10), and
GHGs (represented as CO2e) associated with the originally permitted and proposed expansion of the
GOP development project in South San Francisco, California. Our analyses show that the Modified
Project will have operational emissions of CAPs and GHGs well under the emissions originally disclosed
in the EIR. Additionally, our analysis shows that energy demand will be lower for the Modified Project.
Attachment:
Table
Ramboll
TABLE
ROG NOx PM10
Original Project 44.8 59.4 151.4 19,909
Modified Project 26.5 44.1 41.9 13,452
Difference -18.3 -15.3 -109.5 -6,457
Criteria Air Pollutant Emissions (lbs/day)CO2e Emissions
(metric tons/year)
Table 1
Summmary of operational emissions
Gateway of Pacific
South San Francisco, CA
Appendix E
Water Capacity Study
Technical Memorandum
Date: December 13, 2021
To: Ethan Warsh, BioMed Realty
From: Maddaus Water Management Inc.
Title: Water Capacity Study for GOP Master Plan Project
Overview
A Water Supply Assessment was undertaken for the GOP Master Plan project in 2009. The owner now proposes to
expand the site by 120,221 square feet (sq ft). This study determines that, due to water efficiencies developed since
2009 and implemented in the project, the expanded project will not demand any more water than was projected
in the 2009 Water Supply Analysis.
Introduction
This technical memorandum presents a Water Capacity Study (WCS), or preliminary site water use analysis,
prepared by Maddaus Water Management Inc. (MWM) for BioMed Realty (BMR) for a biomedical facility in South
San Francisco, CA. The GOP Master Plan site (also called the Gateway of Pacific site or Gateway Business Park site)
development project consists of four phases: GOP 1, GOP 2, GOP 3, and GOP 4. Overall project construction began
in May 2017 for GOP 1, the majority of which is now occupied. Construction of GOP 2 started in April 2019 with
occupancy expected in March 2022. GOP 3 construction commenced in August 2019 with occupancy targeted for
fall 2022. A Precise Plan for GOP 4 was approved in 2020, but construction has not commenced. BMR is now
pursuing the GOP 4 Density Transfer Project, which proposes to transfer unused density from an adjacent offsite
parcel to the GOP 4 site, resulting in a 120,221 sq ft expansion. A total overall site area increase of 10% is being
proposed, which would result in a campus of 1,350,810 square feet.
In the January 2009 Water Supply Assessment (2009 WSA) for the GOP Master Plan site, the estimated net increase
in site water demand due to the replacement of then-existing 284,000 square feet with the GOP campus was 49,411
gallons per day (potable water demand). The 2009 WSA addressed a proposed project that, as revealed by the more
detailed and precise calculations conducted for subsequent approvals, was 19 square feet less than the square
footage that could be developed under the FAR 1 approved for the Master Plan. This WCS concludes that the entire
GOP Master Plan site, including the GOP 4 Density Transfer Project and the additional 19 square feet, will result
in a net increase that does not exceed the 49,411 gallons per day that was projected in the 2009 WSA. This
conclusion is supported by water savings realized as a result of two elements that will be implemented as part of
the project based on current construction plans, water management practices, and building codes: (1) more
efficient indoor fixtures being installed than was estimated as part of the baseline demand assumptions; and (2)
significantly more water-efficient cooling tower technologies and management protocols: and (3) leak detection
technology to GOP 1-4, and a water meter tied to the building management system for the cooling tower makeup.
The conclusion that water demand will not exceed that studied in the 2009 WSA is conservative. The WSA studied
a then-proposed Master Plan project with 383,500 square feet of drought-tolerant plants that would replace
295,100 square feet of then-existing turf. The WSA projected that landscape irrigation demand would not change,
since the substitution of drought-tolerant plants for turf would offset the increase in landscaped area. This current
analysis assumes that irrigation demand will not change from that assumed in the WSA. However, that assumption
may overstate irrigation demand. Including the live roof on the amenity building, the current GOP Master Plan
proposes only 358,742 square feet of irrigated landscaping area, which is 24,758 square feet less than studied in
1 Floor Area Ratio, or FAR, is the ratio of square footage that can be developed on a parcel to the square footage of the
underlying parcel (total lot size).
2
the WSA. In addition, landscaping requirements have become more strict since the 2009 WSA was prepared, making
it likely that the proposed plants will demand less water than the plants considered in 2009.
Baseline Water Use Review
This section presents a summary review of the net increase in demand volume reported in the 2009 WSA for the
GOP Master Plan site. This included a review of potentially available demand values provided in the California Water
Service South San Francisco District (Cal Water SSF) 2020 Urban Water Management Plan (UWMP) for the GOP
Master Plan site. However, MWM was not able to ascertain a specific demand for the GOP Master Plan site from
the 2020 UWMP. Therefore, the demand factors calculated in the 2009 WSA were considered to determine an
updated site water use.
Presented in more detail in the 2009 WSA, these demand factors were based on 2007-2008 internal metered water
use for existing buildings for primarily office space use and biotechnology research and development laboratory
(R&D) space use. The office space average daily water use was estimated to be 0.036 gallons/day/sq ft. The R&D
average daily water use was estimated to be 0.063 gallons/day/sq ft. The average daily irrigation water use was
estimated to be 0.079 gallons/day/sq ft. As reported in the 2009 WSA, for the GOP Master Plan site development
project, it was assumed that water usage rates for new office and new R&D laboratories space would remain the
same including the approximate use type profile of 40% office and 60% R&D space.
The GOP Master Plan site landscaped area (which was mainly grass in 2009) was designed to increase by 30% and
be replaced with mainly drought-tolerant plants. As part of the 2009 WSA effort, landscape architects estimated a
reduction in irrigation rate of at least 33% due to conversion from grass to drought-tolerant plants, thereby
balancing out the 30% landscape area increase. Therefore, in the 2009 WSA it was assumed that there would be no
change in total water use for irrigation due to the proposed GOP Master Plan site development project and that the
only change in water demand would be from the net increase in building space.
The 2009 WSA used the following equation to estimate the rise in water demand from the project’s increased
building space:
0.036 gallons/day/sq ft x 946,570 sq ft x 40% + 0.063 gallons/day/sq ft x 946,570 sq ft x 60% =
13,631 gallons/day + 35,780 gallons/day =
49,411 gallons/day
The table below summarizes the 2009 WSA estimated increase in water demand.
Table 1. 2009 WSA Net Demand Increase
Demand (gallons per day) Notes
Demand for Proposed
R&D Space (60% of
1,230,570 sq ft)
46,516
Based on internal metered water use for July 2007 – June 2008 for
800 Gateway Blvd, nearly all biotechnology research and
development laboratory space. Demand factor: 0.063 gal/day/sq ft.
Demand for Proposed
Office Space (40% of
1,230,570 sq ft)
17,720
Based on total internal metered water use for July 2007 – June 2008
for the five pre-existing buildings on Gateway Blvd (700, 1000, 750,
800 and 850). Demand factor: 0.036 gal/day/sq ft.
Demand for Proposed
Landscaping -
The WSA assumed no increase in landscaping demand. The pre-
existing landscaped area was mainly grass, and though 30% more
landscaped area was proposed, it would be at least 30% more water
efficient with mainly drought-tolerant plants.
Demand from Existing
Buildings To Be
Demolished (284,000 sq
ft with 60% R&D space
and 40% office space)
(14,825)
The 2009 WSA netted out the demand of the 284,000 sq ft of pre-
existing buildings estimated to have 60% R&D and 40% office space
proportions that was then proposed to be demolished. This demand
volume is subtracted from the sum total of the previous table
demand estimate rows.
3
Demand (gallons per day) Notes
Net Project Demand 49,411
This value was reported in the 2009 WSA and is the net demand that
this WCS confirms will not be exceeded by the GOP Master Plan
development implementation.
Note: The 2009 WSA new net square footage was 946,570 square feet. This is based on 1,230,570 sq ft total site area less the
284,000 sq ft demolished.
Adjustments to Baseline Water Use/Water Demand Analysis
This section presents the water demand estimate for the GOP Master Plan, with the 120,221 sq ft biomedical
building expansion included, based on current plans, practices, and codes as well as analysis outputs.
Because MWM was unable to ascertain a specific site demand from Cal Water SSF’s 2020 UWMP, the demand
numbers calculated in the 2009 WSA were utilized with considerations made to affect water use reductions similar
to the adjustment factors used in the 2020 UWMP. These water use reductions reflect increases in water efficiency
due to California building and plumbing codes as well as the fixtures the four projects are installing on site.2 These
demand reductions decreased the estimated baseline demand factors, which were based on older (2007 and 2008)
building water use patterns. Fixture flow rates in a commercial building built to 2008 or older codes as compared
to a new commercial building built to 2021 codes differ in water use by more than 20% for the site overall. The LEED
data for GOP 4 provided by BMR consultants reports indoor water use savings from efficient fixtures to be as high
as 45%. Table 2 shows water use efficiency levels for indoor fixtures.
Table 2. Indoor Water Using Fixture Efficiencies
Fixture Type
Ultra-Efficient
Flow Rate
Proposed
Assumed
Flow Rate of Fixture
Replaced
California Code
as of 2021
Toilets 1.1 gpf 1.6 gpf 1.28 gpf
Urinals 0.125 gpf 1.0 gpf 0.125 gpf
Lavatory Faucets 0.35 gpm 0.5 gpm 0.5 gpm
Non-Lavatory Faucets 1.5 gpm 2.2 gpm 1.8 gpm
Showerheads 1.5 gpm 2.5 gpm 1.8 gpm
Pre-Rinse Spray Nozzles 1.15 gpm* 2.5 gpm 1.15 gpm*
* Federal code
These fixture savings assumptions were calibrated using estimated employees per square foot factors consistent
with the 2009 WSA and the related Environmental Impact Report of one employee per 375 square feet. This
estimate was confirmed by BMR personnel as being within the range of typical employee populations at BMR
facilities. This analysis conservatively assumes that a reduction of 8% is needed for the site’s increased area water
use to align with the 2009 WSA’s smaller area net water demand; however, it is likely the site will demonstrate a
much more significant reduction in use compared to the 2009 WSA demand factors.
Additional site savings estimates also were considered for the integration of an efficient cooling system. At this
point in the GOP Master Plan site development, cooling tower efficiency savings were only applied to buildings not
yet under construction. This left only GOP 4 since GOP 1 is already built and occupied, and GOP 2 and GOP 3 are
under construction. Any water demand management initiatives already in play at GOP 1, GOP 2, and GOP 3 were
not included in the cooling tower demand savings estimates. However, these have cooling towers driven by variable
frequency drive (VFD). GOP 2 and GOP 3 also have water meters tied to the building management system for the
cooling tower makeup water. GOP 4 will have VFDs. In addition we assume leak detection technology to GOP 1-4,
and a water meter tied to the building management system for the cooling tower makeup.
2 Information about what fixtures each site is installing was provided by site LEED (Leadership in Energy and Environmental
Design) efforts.
4
A cooling tower water savings factor of 0.73 gal/year/sq ft was used based on the 2013 California Building Energy
Efficiency Standards: Cooling Tower Water Savings report which was published in October 2011.3 Climate-zone
dependent analysis played a role in this 2013 study and, due to the use of very localized water quality within each
of the climate zones, a weighted statewide average was ultimately used to determine water savings. The average
annual water savings factor included a conductivity or flow-based controller, a flow meter, overflow alarm, and
drifty eliminator. The 2013 report was based on an office building with 117,000 sq ft of conditioned space and
cooling operations from 6am-6pm seven days a week. The 85,984 gallons of water per year saved for the 117,000
sq ft protype building yielded the 0.73 gal/year/sq ft savings water factor that was used in this analysis.
The following items and practices would be necessary to achieve the aforementioned cooling tower water savings:
• Cooling towers and chillers for each building
• A chiller should be appropriately sized for each cooling tower
• Each cooling tower should have a conductivity controller, which continuously measures the conductivity of
the water in the cooling tower and will initiate blowdown only when the conductivity set point is exceeded
• A high-end central computer controller that has alerts directly to operation staff
• Submeters on the make-up and blowdown lines of each cooling tower
• A building operations manager that runs and manages the cooling tower systems
• Daily visual inspections of system
• Deep cleanings semiannually
• If chemicals are contracted out, should be on a fixed fee, rather than based on amount of chemicals sold
• Cycles of concentration for the San Francisco Bay Area great water quality with low TDS is ideally 10 or higher
The following table reflects the same methodology for calculating the net increase in water demand as was used in
the 2009 WSA. However, this table substitutes water demand factors that take into account the 120,221 square-
foot expansion, the additional 19 square feet, and the water saving measures noted above. Note that the net
increase in site water demand for GOPs 1-4 will not exceed the 49,411 gallons per day that was projected in the
2009 WSA.
Table 3. 2021 Estimated GOP Master Plan Net Demand Increase
Demand (gallons per day) Notes
Demand for Proposed
R&D Space (60% of
1,350,810 sq ft)
46,976
Based on the 2009 WSA 2007- and 2008-based demand factors and
conservatively reduced by 8% due to water-using fixture efficiencies that
were not present or planned for in that 2009 effort. GOP 4 LEED application
reports savings as much as 45% of indoor fixture water use. Estimated
fixture savings based on generic commercial account end use water profile
over 20%. R&D space demand factor: 0.058 gal/day/sq ft. Office space
demand factor: 0.033 gal/day/sq ft.
Demand for Proposed
Office Space (40% of
1,350,810 sq ft)
17,896
Demand for Proposed
Landscaping -
No change in landscaping demand is included in this current analysis. As
noted, this assumption is conservative since the landscaped areas in the
current plans are smaller than the landscaped areas in the project studied
in the WSA, and plant regulations are now stricter.
Demand Savings from
Cooling Tower Efficiency
Protocols (GOP 4 only at
345,832 sq ft)
(696)
Cooling tower savings are only applicable for buildings not yet under
construction (the two R&D buildings in GOP 4). Cooling tower demand
factor savings: 0.73 gal/year/sq ft.
Demand from Existing
Buildings to be
Demolished (284,000 sq
(14,825) As was done in the 2009 WSA, the demand of this 284,000 sq ft of pre-
existing uses, estimated to have 60% R&D and 40% office space
3 2013 California Building Energy Efficiency Standards: Cooling Tower Water Savings. October 2011.
http://title24stakeholders.com/wp-content/uploads/2017/10/2013_CASE-Report_Cooling-Tower-Water-Savings.pdf
5
Demand (gallons per day) Notes
ft with 60% R&D space
and 40% Office space)
proportions, was netted out. This demand volume is the same as that
estimated in the 2009 WSA.
Net Project Demand 49,350 This value is 0.12% less than the 49,411 gal/day net added demand
reported in the 2009 WSA.
Notes:
1. Estimated new net square footage in the WCS is 1,066,810 sq ft. This is based on the 2009 WSA 1,230,570 sq ft total site
area less the 284,000 sq ft demolished plus the 19 sq ft added in actual building of GOP 1 plus the proposed 120,221 sq
ft expansion based on a density transfer being processed as of October 2021. Total proposed site area is 1,350,810 sq ft.
2. All 2009 WSA project site and demand assumptions are applicable unless otherwise noted. For example, no further
demolition is assumed with the additional 120,221 sq ft development.
MWM assessed the refined demand factor values to unit water use estimates for biomedical facilities at University
of California San Francisco, Stanford University, and Foster City as well as Cal Water SSF records and in consideration
of more than 20 years of experience conducting commercial building audits in the region.
Conclusion
This WCS concludes that the increase in site water demand for GOPs 1-4 will not exceed the 49,411 gallons per day
that was projected in the WSA; this includes, but is not limited to, the proposed 120,221 sq ft expansion and an
additional 19 sq ft that was actually built, for a total of 1,066,810 sq ft of net new development area. This is
supported by water savings realized from the installation of more efficient indoor fixtures than what was estimated
as part of the baseline demand assumptions, as well as more water-efficient cooling tower technologies and
management protocols and leak detection and metering technology.
This analysis has estimated that the GOP Master Plan proposed site water use would be 49,350 gallons/day (potable
water demand) after implementation of the GOP 4 Density Transfer project and net of the water use of the 284,000
square feet existing when the 2009 WSA was prepared.
155105932.4
GATEWAY OF THE PACIFIC 4 DENSITY TRANSFER
PROJECT
Final Supplement Environmental Impact Report
SCH # 2008062059
Prepared for May 2022
City of South San Francisco
GATEWAY OF THE PACIFIC 4 DENSITY TRANSFER
PROJECT
Final Supplement Environmental Impact Report
SCH # 2008062059
Prepared for May 2022
City of South San Francisco
550 Kearny Street
Suite 800
San Francisco, CA 94108
415.896.5900
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Gateway of the Pacific 4 Density Transfer Project i ESA / D202101143
City of South San Francisco May 2022
TABLE OF CONTENTS
Gateway of the Pacific 4 Density Transfer Project
Final Supplemental Environmental Impact Report
Chapter 1, Introduction and List of Commenters ............................................................ 1-1
1.1 Purpose of this Document ................................................................................. 1-1
1.2 Summary of Proposed Project ........................................................................... 1-1
1.3 Project Actions ................................................................................................... 1-4
1.4 Organization of the Final EIR ............................................................................. 1-5
1.5 Public Participation and Review ......................................................................... 1-6
1.6 List of Commenters ............................................................................................ 1-6
Chapter 2, Comments and Responses ............................................................................. 2-1
2.1 Introduction ........................................................................................................ 2-1
Chapter 3, Mitigation Monitoring and Reporting Program (MMRP) ............................... 3-1
3.1 Introduction ........................................................................................................ 3-1
3.2 Mitigation Measures ........................................................................................... 3-1
3.3 MMRP Components .......................................................................................... 3-1
List of Tables
Table 1-1 Comment Letters Regarding the Draft SEIR ...................................................... 1-7
Table 3-1 Mitigation Monitoring and Reporting Program .................................................. 3-3
Gateway of the Pacific 4 Density Transfer Project 1-1 ESA / D202101143
City of South San Francisco May 2022
CHAPTER 1
Introduction and List of Commenters
1.1 Purpose of this Document
This document includes all agency and public written comments received on the Draft
Supplemental Environmental Impact Report (Draft SEIR, SCH # 2008062059) for the Gateway
of Pacific (GOP) 4 Density Transfer Project. No changes in the text of the Draft SEIR are
necessary or appropriate.
Written comments were received by the City of South San Francisco during the public comment
period from January 26, 2022 through March 14, 2022. This document includes written responses
to each comment received on the Draft SEIR. This Final SEIR document has been prepared in
accordance with the California Environmental Quality Act (CEQA) and together with the Draft
SEIR (and Appendices) constitutes the EIR for the GOP 4 project that will be used by the decision-
makers during project hearings. The responses and text changes correct, clarify, and amplify text
in the Draft SEIR, as appropriate. These changes do not alter the conclusions of the Draft SEIR.
1.2 Summary of Proposed Project
Project Location
The GOP 4 site is located in the City of South San Francisco, approximately 1.5 miles north of
San Francisco International Airport (SFO) and approximately 10 miles south of downtown San
Francisco. The City of South San Francisco is located on the San Francisco Bay plain and the
northern foothills of the Coastal range. The City is located along major transportation routes
including US 101, Interstate 380 (“I-380”), Interstate 280 (“I-280”), and the Union Pacific
Railroad.
The GOP 4 project is the fourth phase of the GOP Master Plan project, which is located within
the larger Gateway Specific Plan area and East of 101 Sub-area. The GOP Master Plan area
consists of approximately 23 acres of land and is bounded by Oyster Point Boulevard on the
north, Gateway Boulevard on the west, a narrow band of vacant land to the east, and a hotel to the
south. The GOP Master Plan area is developed with office, warehousing and research and
development (“R&D”) uses.
The GOP 4 site itself is 4.8 acres in size and is generally located in the northeastern portion of the
GOP Master Plan area, south of buildings housing R&D uses located at 180 and 200 Oyster Point
Boulevard, which are located outside the GOP Master Plan area. The site is presently developed
with two one-story buildings, a Federal Express (FedEx) distribution center (900 Gateway
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-2 ESA / D202101143
City of South San Francisco May 2022
Boulevard) totaling 50,000 sf and an abandoned office building (850 Gateway Boulevard)
totaling approximately 19,300 sf.
Background
In February 2010, the City certified an EIR, adopted certain findings under CEQA, and approved
the Gateway Business Park Master Plan project and a Precise Plan for Phase 1. Other approvals
included related General Plan and zoning changes, and a Development Agreement. Specifically,
the environmental effects of the project were analyzed in the EIR (State Clearinghouse Number
2008062059) that was certified on February 10, 2010 (City Council Resolution 18-2010)(“2010
EIR”). In addition, a Mitigation Monitoring and Reporting Program (“MMRP”) and a statement
of overriding considerations for the project were adopted at the same time. The master plan
project involved the phased removal and replacement of existing buildings on the 22.6-acre site,
construction of five to six new buildings, and construction of two to four parking structures, in up
to five phases. The plan would have developed the site with a Floor Area Ratio (FAR) of 1.25,
which would have resulted in approximately 1,230,570 square feet (sf) of building space.
In April 2013, the City approved modifications to the Gateway Business Park Master Plan project
and the Precise Plan for Phase 1 (City Council Resolution 44-2013). The City found that the
modifications were within the scope of the 2010 EIR and re-certified that EIR (City Council
Resolution 43-2013). As it considered the modifications to that project, the City re-adopted the
CEQA findings, the MMRP and the statement of overriding considerations. The modifications
included more flexibility in phasing, a new amenity building in Phase 1, a First Amendment to
the Development Agreement, and minor changes to on-site circulation. The overall development
standards and FAR of 1.25 did not change. These modifications were reflected in a revised
Master Plan, which was renamed as the GOP Master Plan, and a revised Precise Plan for GOP 1.
Phase 1 has since been constructed.
In July 2018, the City approved a Second Amended and Restated Development Agreement
(“Second Amendment”) (Ordinance No. 1559-2018). The Second Amendment recognizes a lot
line adjustment that had previously adjusted the property line between Phases 1 and 2, recognized
the current ownership of the various parcels that comprise the GOP Master Plan area, allocated
responsibility for compliance with the conditions of approval and mitigation measures separately
among each phase, and clarified that the requirement for a replacement childcare facility on the
site be triggered upon occupation of 750,000 sf of gross floor area within the GOP Master Plan
area. The City determined that no additional environmental review was required for the Second
Amendment.
In December 2018, the City approved Precise Plans for Phases 2 and 3 of the GOP Master Plan
project (Planning Commission Resolution 2835-2018). The Planning Commission determined
that Phases 2 and 3 were within the scope of the 2010 EIR and adopted an Addendum (Planning
Commission Resolution 2834-2018) (“2018 Addendum”) to the previous analysis. The Precise
Plans provided detailed development plans that implemented the already-approved GOP Master
Plan project. Phases 2 and 3 are currently under construction.
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-3 ESA / D202101143
City of South San Francisco May 2022
In July 2020, the City approved a Precise Plan for Phase 4 of the GOP Master Plan project, as
well as a Use Permit for the adjacent project at 475 Eccles Avenue to the west, which is now
known as GOP 5 (Planning Commission Resolution No. 2859-2020 and City Council Resolution
No. 119-2020). The Precise Plan for the GOP 4 project provided detailed development plans that
implemented the already-approved GOP Master Plan project. The GOP 4 project included two
five-story buildings with R&D uses totaling 226,000 sf and a six-story parking structure, with a
partial floor on the sixth level, in the northeastern portion of the GOP Master Plan area. The
Planning Commission determined that Phase 4 was within the scope of the 2010 EIR and 2018
Addendum, and adopted another Addendum (Planning Commission Resolution No. 2858-2020)
(“2020 Addendum”) to the previous analysis. Construction of GOP 4 has not commenced.
The Use Permit for the GOP 5 project integrated the adjacent project at 475 Eccles Avenue into a
campus that would include both the GOP Master Plan and GOP 5 projects. The GOP 5 project
includes the site of some former rail spurs that previously separated the GOP Master Plan area
from the 475 Eccles site, which will be converted into a publicly-accessible multi-use path
connecting Oyster Point Boulevard with Forbes Boulevard, and providing pedestrian connections
within the campus.
Project Characteristics
Previously Approved Project
As discussed above, the approved GOP 4 project included two five-story buildings totaling
226,000 sf and a five-story parking structure. One building would be located on the northern
portion of the site and the other building would be located on the southern portion of the site with
the parking structure located to the east. Both the northern and southern buildings were
approximately the same size with each totaling about 113,000 sf. The two structures were also
each 98 feet above the average level of the highest and lowest points on the lot. A total of 531
parking spaces would be provided in a six-level parking structure (five full floors and a partial
level on the sixth floor). The project would have employed approximately 603 workers. The
envelope of the buildings consisted of a high-quality curtain-wall system with energy-efficient
glazing and accents of metal panels, wood and concrete.
Modified Project
The site of the former rail spurs on the GOP 5 site is 2.76 acres or 120,221 sf in size. Based on an
allowed FAR of 1.0 for R&D establishments permitted by the City’s General Plan, a total of
120,221 sf of R&D use could be developed on this portion of the GOP 5 site. The proposed
GOP 4 Density Transfer project would transfer this space from the GOP 5 site to the GOP 4 site.
The developable space would be added to the northern building on the GOP 4 site as four
additional floors. The portion of the GOP 5 site encompassing the rail spurs would then be deed
restricted to not allow any of the density transferred to GOP 4 site to be constructed on the rail
spur property. The additional space would employ an additional 321 workers. The additional
square footage would be parked at 2 spaces per 1,000 sf, which would be accommodated by
adding 2.5 floors to the previously-approved parking structure; a total of approximately 240 new
parking spaces would be provided.
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-4 ESA / D202101143
City of South San Francisco May 2022
As revised, the northern building on the GOP 4 site would total nine floors and reach a height of
178 feet above the average level of the highest and lowest points on the lot. The northern
structure would include about 233,300 sf of space. The height and size of the southern building
would remain the same. The parking structure would also now be eight levels in height and
include 771 parking spaces.
The approved architectural scheme of the buildings would be extended to the new floors, without
any substantive changes in architecture. The modified GOP 4 project also includes a generator
yard at ground level in the landscaped area on the northwest side of the GOP 4 parking structure.
In exchange for reducing current density at the rail spurs to zero, the overall FAR of the GOP
Master Plan area would increase from 1.25 to 1.37 with the addition of the space associated with
the proposed project.
1.3 Project Actions
Approval of the GOP 4 Density Transfer project is anticipated to require, but may not be limited
to, the following City actions:
• Certify EIR to verify that the EIR was completed in compliance with the requirements of
CEQA, that the decision-making body has reviewed and considered the information in the
EIR, and that the EIR reflects the independent judgement of the City of South San Francisco;
• Adopt a MMRP, which specifies the methods for monitoring mitigation measures required to
eliminate or reduce the project’s significant effects on the environment; and
• Adoption of Findings of Fact and a Statement of Overriding Considerations.
• Amend General Plan to allow a density transfer. Specifically, add text to the notes in General
Plan FAR tables 2.2-1 and 2.2-2 that apply to the Business Commercial land use. The notes
would be amended to add the following underlined text:
The Gateway Business Park Master Plan and the Oyster Point Specific Plan are permitted to
develop up to a FAR of 1.25 with a TDM, and are allowed to develop additional density to
the extent such density would otherwise be available on immediately adjacent property that is
(a) subject to an FAR limitation of 1.25 or less; (b) part of the same research & development
campus; and (c) deed-restricted to preclude development of the transferred FAR;
BMR also seeks an amendment to the text on pages 2-21 to 2-22 of the General Plan
currently published on line, as follows:
The Gateway Business Park Master Plan area, comprising several parcels on 22.6 acres at the
southeast corner of Gateway Boulevard and Oyster Point Boulevard, is permitted to develop
up to a FAR of 1.25 and is allowed to develop additional density in limited circumstances as
provided in Tables 2.2-1 and 2.2-2.
• Repeal of Gateway Specific Plan as it may be considered outdated and because the relevant
components of the Specific Plan have already been incorporated into the applicable zoning
district regulations. Barring repeal, amend Gateway Specific Plan to allow a transfer of
density from adjacent property into the Specific Plan area;
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-5 ESA / D202101143
City of South San Francisco May 2022
• Amend Gateway Specific Plan Zoning District regulations to allow transfer of density from
an adjacent zoning district;
• Amend GOP Master Plan to allow a transfer of density from an adjoining property;
• Modify GOP 4 Precise Plan to incorporate an additional 120,221 square feet, with four
additional floors on the GOP 4 North building, and 2.5 additional floors on the parking
structure. Undergo associated design review;
• Amend Development Agreement for the GOP Master Plan to encompass the above approvals.
The proposed project would be anticipated to include, but may not be limited to, the following
actions by entities other than the City:
• Notice of Proposed Construction and Alteration and Federal Aviation Administration
Determination per Code of Federal Regulations Title 14, Part 77.9.
1.4 Organization of the Final EIR
The Final EIR is organized as follows:
Chapter 1 – Introduction and List of Commenters: This chapter summarizes the projects
under consideration and describes the contents of the Final SEIR. This chapter also contains a list
of all of the agencies or persons who submitted comments on the Draft SEIR during the public
review period, presented in order by agency, organization, individual and date received.
Chapter 2 – Comments and Responses: This chapter contains the comment letters received on
the Draft SEIR followed by responses to individual comments. Each comment letter is presented
with brackets indicating how the letter has been divided into individual comments. Each comment
is given a binomial with the letter number appearing first, followed by the comment number. For
example, comments in Letter 1 are numbered 1-1, 1-2, 1-3, and so on. Immediately following the
letter are responses, each with binomials that correspond to the bracketed comments.
If the subject matter of one letter overlaps that of another letter, the reader may be referred to
more than one group of comments and responses to review all information on a given subject.
Where this occurs, cross-references to other comments are provided.
Some comments that were submitted to the City do not pertain to substantial environmental issues
or do not address the adequacy of the analysis contained in the Draft SEIR. Responses to such
comments, though not required, are included to provide additional information. When a comment
does not directly pertain to environmental issues analyzed in the Draft SEIR, does not ask a
question about the adequacy of the analysis contained in the Draft SEIR, expresses an opinion
related to the merits of the proposed project, or does not question an element of or conclusion of
the Draft SEIR, the response notes the comment and may provide additional information where
appropriate. Comments, including any that express opinions about the merits or specific aspects
of the proposed project, are included in the Final SEIR for consideration by the decision-makers.
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-6 ESA / D202101143
City of South San Francisco May 2022
Chapter 3 – Mitigation Monitoring and Reporting Program: This chapter contains the
Mitigation Monitoring Plan (MMRP) to guide the City in its implementation and monitoring of
measures adopted in the SEIR, and to comply with the requirements of Public Resources Code
Section 21081.6(a).
1.5 Public Participation and Review
The City of South San Francisco has complied with all noticing and public review requirements
of CEQA for the proposed project. This compliance included notification of all responsible and
trustee agencies and interested groups, organizations, and individuals that the Draft SEIR was
available for review. The following list of actions took place during the preparation, distribution,
and review of the Draft SEIR:
• A Notice of Preparation (NOP) for the EIR was filed with the State Clearinghouse on
November 16, 2021. The official 30-day public review comment period for the NOP ended
on December 20, 2021 (SCH# 2008062059). The NOP was distributed in particular to
governmental agencies, organizations, and persons interested in the GOP 4 project. The City
sent the NOP to agencies with statutory responsibilities in connection with the GOP 4 project
with the request for their input on the scope and content of the environmental information that
should be addressed in the EIR. Though no tribes have submitted requests for notice under
Public Resources Code § 21080.3.1(b), the NOP was sent to relevant tribes.
• A Notice of Completion (NOC) and copies of the Draft SEIR were distributed to the Office
of Planning and Research on January 26, 2022 to those public agencies that have jurisdiction
by law with respect to the GOP 4 project, or which exercise authority over resources that may
be affected by the GOP 4 project, and to other interested parties and agencies as required by
law. The comments of such persons and agencies were sought.
• An official 45-day public comment period for the Draft SEIR was established. The public
comment period began on January26, 2022 and ended on March 14, 2022.
• A Notice of Availability (NOA) of the Draft SEIR was emailed to all interested groups,
organizations, and individuals who had previously requested notice in writing on January 26,
2022. The NOA stated that the City of South San Francisco had completed the Draft SEIR
and that it was available for public review either online at https://weblink.ssf.net, and in
printed form at the offices of the City’s Planning Division at 315 Maple Avenue, South San
Francisco, California 94083. The notice also indicated that the official 45-day public review
period for the Draft SEIR would end on March 14, 2022.
• A public notice was posted in the office of the San Mateo County Clerk on January 27, 2022.
1.6 List of Commenters
The City of South San Francisco received two (2) comment letters during the comment period on
the Draft SEIR for the proposed project. Table 1-1 below indicates the numerical designation for
each comment letter, the author of the comment letter, and the date of the comment letter.
1. Introduction and List of Commenters
Gateway of the Pacific 4 Density Transfer Project 1-7 ESA / D202101143
City of South San Francisco May 2022
TABLE 1-1
COMMENT LETTERS REGARDING THE DRAFT SEIR
Letter # Entity Author(s) of Comment Letter/e-mail Date of Comment Letter/e-mail
1 Caltrans Mark Leong March 14, 2022
2 SFO Nupur Sinha March 14, 2022
Gateway of the Pacific 4 Density Transfer Project 2-1 ESA / D202101143
City of South San Francisco May 2022
CHAPTER 2
Comments and Responses
2.1 Introduction
This section contains the comment letters that were received on the Draft SEIR. Following each
comment letter is a response by the City intended to supplement, clarify, or amend information
provided in the Draft SEIR or refer the reader to the appropriate place in the document where the
requested information can be found. Comments that are not directly related to environmental
issues may be discussed or noted for the record.
“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
March 14, 2022 SCH #: 2008062059
GTS #: 04-SM-2021-00419
GTS ID: 24810
Co/Rt/Pm: SM/101/22.7
Billy Gross, Principal Planner
City of South San Francisco
Economic and Community Development Department
315 Maple Street
South San Francisco, CA 94080
Re: Gateway of the Pacific (“GOP”) 4 Density Transfer Project Draft Supplemental
Environmental Impact Report (Draft SEIR)
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the GOP 4 Density Transfer 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 2022 Draft SEIR.
Project Understanding
The project would transfer up to 120,221 square feet of development potential from
undeveloped adjacent property to expand one of the buildings approved for Phase 4
of the GOP 4 by that amount, to be configured in four additional floors. The project
also proposes the addition of 240 parking stalls. The project is located roughly 0.4 miles
southeast of the United States Route (US)-101/ Oyster Point Boulevard interchange in
South San Francisco.
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).
Letter 1
1-1
1-2
Billy Gross, Principal Planner
March 14, 2022
Page 2
“Provide a safe and reliable transportation network that serves all people and respects the environment”
Caltrans commends the Lead Agency regarding the proposed First-and Last-Mile
transit connections and active transportation improvements. This project potentially
supports the State’s goals to reduce greenhouse gas emissions and improve
multimodal transportation options for land use development.
The project VMT analysis and significance determination are undertaken in a manner
consistent with the Office of Planning and Research’s (OPR) Technical Advisory.
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 LDR-D4@dot.ca.gov.
Sincerely,
MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
Letter 1
1-2
cont.
2. Comments and Responses
Gateway of the Pacific 4 Density Transfer Project 2-5 ESA / D202101143
City of South San Francisco May 2022
Letter 1
Response
Mark Leong, California Department of Transportation (Caltrans)
March 14, 2022
1-1 The comment provides a summary of the proposed project. No further response is
required.
1-2 The comment states that the project potentially supports the State’s goals to reduce
greenhouse gas emissions and improve multimodal transportation options for land
use development, and that the project’s analysis of Vehicle Miles Traveled and
significance determination were undertaken in a manner consistent with the
Technical Advisory on Evaluated Transportation Impact in CEQA prepared by the
California Office of Planning and Research. The comment does not assert any
inadequacies in the analysis included in the Draft SEIR. No further response is
required.
March 14, 2022
Billy Gross, Principal Planner
City of South San Francisco
Department of Economic and Community Development
315 Maple Street
South San Francisco, California 94080
San Francisco lhternational Airport
TRANSMITTED VIA E-MAIL and U.S. MAIL
billy. gross@ssf.net
Subject: Draft Supplemental Environmental Impact Report Comments: GOP Density Transfer
Project, South San Francisco
Dear Mr. Gross:
San Francisco International Airport (SFO or the Airport) staff have reviewed the Draft Supplemental
Environmental Impact Report (Draft SEIR) for the Gateway of the Pacific (GOP) 4 Density Transfer Project
(the Proposed Project), located in the City of South San Francisco's Gateway Specific Plan area and East of
101 sub area, as described in the Draft SEIR. We appreciate this opportunity to provide comments on the
Draft SEIR.
According to the Notice of Availability for the Draft SEIR, the Proposed Project is located at 850 and 900
Gateway Boulevard, southeast of the intersection of Gateway Boulevard and Oyster Point Boulevard, in the
City of South San Francisco. The Proposed Project includes transfer ofup to 120,221 square feet of
development potential from undeveloped adjacent property (at GOP 5) and use it to expand one of the
buildings approved for Phase 4 of the Gateway Business Park Master Plan Project (GOP 4). GOP 4 was
originally approved by the South San Francisco Planning Commission in 2020 for two five-story buildings
(at an elevation of 137 feet as defined from the origin of the North American Vertical Datum of 1988
[NA VD88]) and a six-story parking structure. The Proposed Project would include expansion of the GOP 4
North building by four floors, for a total of nine floors estimated at an elevation of 201 feet NA VD88.1
The Proposed Project site is inside Ai.tpo1t Influence Area B as defined by the Comprehensive Airport Land
Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP). The
Proposed Project site would be located outside the 65 decibel ( dBA) Community Noise Equivalent Level
(CNEL) contour and the Safety compatibility zones, and therefore would not appear to be inconsistent with
the Noise and Safety Compatibility policies adopted in the SFO ALUCP.
As described in Exhibit N-17 of the SFO ALUCP (see Attachment), the critical aeronautical surfaces at the
Proposed Project location would be at an elevation of between approximately 510 and 540 feet NA VD88.
Thus, the estimated maximum elevation of the Proposed Project (201 feet NA VD88) would be below the
1 The total proposed elevation of GOP 4 North was not provided in the Draft SEIR. The proposed elevation was calculated by
assuming 16 feet per floor, based on the GOP 4 Precise Plan (available online at: https://c i-ssf
ca.legistar.com/legislationDetail.aspx?ID=4605845&GIBD= 169A 73 FE-0F56-4824-8Bl 5-05740E l CS 112 ). The original plan for
GOP 4 North was for an elevation of 137 feet NA VD88. An additional four floors would add 4 x 16 feet (or 64 feet) for a total of201
feet NA VD88.
AIRPORT COMMISSION CITY AND COUNTY OF SAN FRANCIS(O
LONDON N. BREED
MAYOR
HEANOR JOHNS
PRESIDENT
MALCOLM YEUNG VIC£ PRESIDENT EVERETT A. HEWLETT JR. JAl!E NAIOLI IV I\H C. SATE.RO
A/RPO/IT DIRECTO/1
f'05l Office Box 8097 San Franmco, California 94128 Tel 650.821.5000 Fax 650.821.5005 www.Oysfo.com
Letter 2
2-1
2-2
2-3
Billy Gross, City of South San Francisco
March 14, 2022
Page 2 of2
critical aeronautical surfaces and the Proposed Project would not appear to be incompatible with the Airspace
Compatibility Policies of the SFO ALUCP, subject to the issuance of a Determination of No Hazard from the
Federal Aviation Administration (see below) for any proposed structures and determinations from the
City/County Association of Governments of San Mateo County as the designated Airport Land Use
Commission.
This determination does not negate the requirement for the Proposed Project sponsor to undergo Federal
Aviation Administration review as described in 14 Code of Federal Regulations Part 77 for both ( 1) the
permanent structures and (2) any temporary cranes or other equipment taller than the pe1manent buildings
which would be required to construct those structures.
Due to the proximity of the Proposed Project to the Airport and certain aircraft procedures from Runway
10L-28R, Airspace Protection Policies (AP-1 tbrougbAP-4) from the SFO ALUCP is enclosed as reminders
of incompatible site characteristics, especially as it pertains to solar panels building materials/features that
reflect and create bright lights/glare.
** *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not
hesitate to contact me at (650) 821-6678 or at nupur.sinha@flysfo.com.
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, A.LUC
Audrey Park, SFO
Letter 2
2-3
cont.
2-4
2-5
THE CITY/COUNTY ASSOCIAT.ION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 and associated with human disease of varying severity.
b.Biosafety Level 3 practices, safety equipment, and facility design and construction are
applicable to clinical, diagnostic, teaching, research, or production facilities in which work
is done with indigenous or exotic agents with a potential for respiratory transmission, and
which may cause serious and potentially lethal infection.
c.Biosafety Level 4 practices, safety equipment, and facility design and construction are
applicable for work with dangerous and exotic agents that pose a high individual risk of
life-threatening disease, which may be transmitted via the aerosol route and for which
there is no available vaccine or therapy.
4.5 Airspace Protection
The compatibility of proposed land uses with respect to airspace protection shall be evaluated in accordance with the
policies set forth in this section. These policies are established with a twofold purpose:
I.To protect the public health, safety, and welfare by minimizing the public's exposure to potential safety
hazards that could be created through the construction of tall structures.
2.To protect the public interest in providing for the orderly development of SFO by ensuring that new
development in the Airport environs avoids compromising the airspace in the Airport vicinity. This avoids the
degradation in the safety, utility, efficiency, and air service capability of the Airport that could be caused by the
attendant need to raise visibility minimums, increase minimum rates of climb, or cancel, restrict, or redesign flight
procedures.
4.5.1 FEDERAL REGULATIONS REGARDING TALL STRUCTURES
14 Code of Federal Regulations (CFR) Part 77, Safe, Efficient Use and Preservation of the Navigable Airspace, governs the
FM's review of proposed construction exceeding certain height limits, defines airspace obstruction criteria, and
provides for FM aeronautical studies of proposed construction. Appendix F describes the FM airspace review
process and the extent of FM authority related to airspace protection.
4.5.2 PART 77, SUBPART B, NOTIFICATION PROCESS
Federal regulations require any person proposing to build a new structure or alter an existing structure with a height
that would exceed the elevations described in CFR Part 77, Subpart B, Section 77.9, to prepare an FM Form 7460-1,
Notice of Proposed Construction or Alteration, and submit the notice to the FM. The regulations apply to buildings and
other structures or portions of structures, such as mechanical equipment, flag poles, and other projections that may
·exceed the aforementioned elevations.
[IV-34]
Comprehensive. Airport Land Use. Compatibility Plan
for the Environs of San Francisco lnuirnatlonal Altport
Airpo,.tlland Use Compatibility Policies
Letter 2
THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2011 Exhibit IV-IO depicts the approximate elevations at which the 14 CFR Part 77 notification requirements would be
triggered; see Exhibit IV-I I for a close-up view of the northern half and Exhibit IV-12 for a close-up view of the
southern half of the area. These exhibits are provided for informational purposes only. Official determinations of the
areas and elevations within which the federal notification requirements apply are subject to the authority of the FAA.
The FAA is empowered to require the filing of notices for proposed construction based on considerations other than
height. For example, in some areas of complex airspace and high air traffic volumes, the FAA may be concerned about
the potential for new construction of any height to interfere with electronic navigation aids. In these areas, the FAA
will want to review all proposed construction projects.
The FAA has developed an on-line tool for project sponsors to use in determining whether they are required to file a
Notice of Proposed Construction or Alteration. Sponsors of proposed projects are urged to refer to this website to
determine whether they are required to file Form 7460-1 with the FAA:
https://oeaaa.faa.gov/oeaaa/external/gis T ools/gisAction.jsp?action=showNoNoticeRequiredT oo!Form
4.5.3 AIRSPACE MAPPING
Part 77, Subpart C, establishes obstruction standards for the airspace around airports including approach zones, conical
zones, transitional zones, and horizontal zones known as "imaginary surfaces." Exhibit IV-13 depicts the Part 77 Civil
Airport Imaginary Surfaces at SFO. The imaginary surfaces rise from the primary surface, which is at ground level
immediately around the runways. The surfaces rise gradually along the approach slopes associated with each runway
end and somewhat more steeply off the sides of the runways. The FAA considers any objects penetrating these
surfaces, whether buildings, trees or vehicles travelling on roads and railroads, as obstructions to air navigation.
Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on
aeronautical publications to ensure that pilots can see and avoid them.
Close-up views of the north and south sides of the Part 77 surfaces are provided in Exhibit IV-14 and Exhibit IV-I 5,
respectively. Additionally, Exhibit IV-16 provides an illustration of the outer approach and transitional surfaces
located on the southeast side of the Part 77 surfaces.
Together with its tenant airlines, SFO has undertaken a mapping effort to illustrate the critical aeronautical surfaces
that protect the airspace required for multiple types of flight procedures such as those typically factored into FAA
aeronautical studies, as shown on Exhibit IV-17 and Exhibit IV-18. These aeronautical surfaces include those
established in accordance with FAA Order 8260.3B, U.S. Standard for Terminal Instrument Procedures (TERPS), and a
surface representing the airspace required for One-Engine Inoperative (OEI) departures from Runway 28L (to the west
through the San Bruno Gap).16 The exhibits depict the lowest elevations from the combination of the OEI procedure
surface and all TERPS surfaces. The surfaces are defined with Required Obstacle Clearance (ROC) criteria to ensure
safe separation of aircraft using the procedures from the underlying obstacles. Any proposed structures penetrating
these surfaces are likely to receive Determinations of Hazard (DOH) from the FAA through the 7460-1 aeronautical
study process. These surfaces indicate the maximum height at which structures can be considered compatible with
Airport operations.
16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.
Comprehensive Airport Land Us� Compatibilfty Plan
for the Environs of San Francisco lnte,.natlonal Airport
Airport/Land Use Compatlbility Policies [IV-35)
Letter 2
Letter 2
THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace
surfaces along the extended centerline of Runway I 0L-28R -the TERPS Obstacle Departure Procedure (ODP) surface,
representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent
study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace
surfaces and various aircraft approach and departure profiles, based on varying operating assumptions. The exhibit
illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always
designed below the actual aircraft fl ight profile which they are designed to protect, thus providing a margin of safety.
Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI
airspace surface.
4.5.4 AIRSPACE PROT ECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.
AP-I COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED
CONSTRUCTION OR ALTERATION
AP-I. I Local Government Respo nsibility to Notify Project Sponsors
Local governments should notify sponsors of proposed projects at the earliest opportunity to file Form
7460-1, Notice of Proposed Construction or Alteration, with the FAA for any proposed project that would
exceed the FAA notification heights, as shown approximately on Exhibit IV-I 0. Under Federal law, it is
the responsibility of the project sponsor to comply with all notification and other requirements described
in 14 CFR Part 77. This requirement applies independent of this ALUCP.
AP-1.2 FAA Aeronautical Study Findings Required Before Processing Development
Application
The sponsor of a proposed project that would exceed the FAA notification heights, as shown
approximately on Exhibit IV-10, shall present to the local government permitting agency with his or her
application for a development permit, a copy of the findings of the FAA's aeronautical study, or evidence
demonstrating that he or she is exempt from having to file an FAA Form 7460-1. It is the responsibility of
the local agency to consider the FAA determination study findings as part of its review and decision on
the proposed project.
AP-2 COMPLIANCE WITH FINDINGS OF FAA AERONAUTICAL STUDIES
Project sponsors shall be required to comply with the findings of FAA aeronautical studies with respect to
any recommended alterations in the building design and height and any recommended marking and lighting
of their structures for their proposed projects to be deemed consistent with this ALUCP.
Compre:hensiv� Airport Land Use Compatibility Plan
lor the Environs of San Francisco lnterni.tlona l Airport
Airport/Land Use Compacibllity Pollcles [IV-55]
Letter 2
THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 20 I 2 AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the
lower of (I) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or
(2) the maximum height determined not to be a "hazard to air navigation" by the FAA in an aeronautical
study prepared pursuant to the filing of Form 7460-1.
For the vast majority of parcels, the height limits established in local zoning ordinances are lower than the
critical airspace surfaces. In those cases, the zoning district height regulations will control. Compliance
with the zoning district height and the SFO critical aeronautical surfaces map, however, does not relieve
the construction sponsor of the obligation to file a FAA Form 7460-1 Notice of Proposed Construction or
Alteration, if required, and to comply with the determinations resulting from the FAA's aeronautical study.
For a project to be consistent with this ALUCP, no local agency development permits shall be issued for
any proposed structure that would penetrate the aeronautical surfaces shown on Exhibits IV-17 and IV-18
or the construction of which has not received a Determination of No Hazard from the FAA, or which
would cause the FAA to increase the minimum visibility requirements for any instrument approach or
departure procedure at the Airport.
AP-4 OTHER FLIGHT HAZARDS ARE INCOMPATIBLE
Proposed land uses with characteristics that may cause visual, electronic, or wildlife hazards, particularly
bird strike hazards, to aircraft taking off or landing at the Airport or in fl ight are incompatible in Area B of
the Airport Influence Area. They may be permitted only if the uses are consistent with FAA rules and
regulations. Proof of consistency with FAA rules and regulations and with any performance standards
cited below must be provided to the Airport Land Use Commission (C/CAG Board) by the sponsor of
the proposed land use action.
Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a)Sources of glare, such as highly reflective buildings or building fea tures, or bright lights, including
search lights or laser displays, which would interfere with the vision of pilots making approaches to
the Airport.
(b) Distr acting lights that that could be mistaken by pilots on approach to the Airport for airport
identification lighting, runway edge lighting, runway end identification lighting, or runway approach
lighting.
(c) Sources of dust, smoke, or water vapor that may impair the vision of pilots making approaches
to the Airport.
(d) Sources of electrical interference with aircraft or air traffi c control communications or navigation
equipment, including radar.
(e)Land uses that, as a regular byproduct of their operations, produce thermal plumes with the
potential to rise hi.l?h enough and at sufficient velocities to interfere with the control of aircraft in
Comprehensive Airport Land Use Compatibility Plan
for the Environ.s of San Francisco International Airport
Airport/land Use Compatibility Policies [IV-59)
Letter 2
THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBE!t 2012 flight. Upward velocities of 4.3 meters ( 14.1 feet) per second at altitudes above 200 feet above the
ground shall be considered as potentially interfering with the control of aircraft in flight.17
(f) Any use that creates an increased attraction for wildlife, particularly large flocks of birds, that is
inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.SA, Waste
Disposal Sites On or Near Airports, FAA Advi sory Circular 150/5200-33B, Hazardous Wildlife Attractants
On or Near Airports, and any successor or replacement orders or advisory circulars. Exceptions to
this policy are acceptable for wetlands or other environmental mitigation projects required by
ordinance, statute, court order, or Record of Decision issued by a federal agency under the National
Environmental Policy Act.
4.5.5 iALP AIRSPA CE TOOL
17
In consultation with C/CAG, SFO developed the iALP Airspace Tool, a web-based, interactive tool to evaluate the
relationship of proposed buildings with the Airport's critical airspace surfaces. The iALP Airspace Tool is designed to
assist planners, developers, and other interested persons with the implementation of the airspace protection policies of
the SFO ALUCP. The tool helps users determine: (I) the maximum allowable building height at a given site, and/or (2)
whether a building penetrates a critical airspace surface, and by how much, given the proposed building height.
A more detailed description of the iALP Airspace Tool and a tutorial explaining how to use it is presented in
Appendix J. Use of this tool, however, does not relieve a project sponsor of the duty to comply with all federal
regulations, including the obligation to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA.
This is a threshold established by the California Energy Commission in its review of power plant licensing applications. See Blythe Solar Power Project:
Supplemental Stoff Assessmen� Part 2,. CEC-700-20 I 0-004-REV I -SUP-PT2, July 20 I 0. California Energy Commission. Docket Number 09-AFC-6, p.
25. This criterion is based on guidance established by the Australian Government Civil Aviation Authority (Advisory Circular AC 139-05(0), June
2004). The FAA's Airport Obstructions Standards Committee (AOSC) is studyi ng this matter but has not yet issued specific guidance.
[IV-60)
Compre.hensive Airport Land Use Compa.tibilicy Plan
for rht! Environs of San Fr.i.nchco lnterriational Airport
Airport/Land Use Comp•tibility Policies
Letter 2
2. Comments and Responses
Gateway of the Pacific 4 Density Transfer Project 2-14 ESA / D202101143
City of South San Francisco May 2022
Letter 2
Response
Nupur Sinha, San Francisco International Airport (SFO)
March 14, 2022
2-1 The comment provides a summary of the proposed project. In addition, the comment
estimates that the elevation of the north building on the GOP 4 site under the
modified project would be 201 feet North American Vertical Datum (NAVD) 88.
Various methodologies have been used to determine height. The Supplemental Draft
EIR estimated a height to the top of the parapet of 178 feet above the average of the
highest and lowest points on the lot. BKF Engineering subsequently provided a
correlation between the building height above ground level to Mean Sea Level for the
Project’s submittal to the Airport Land Use Commission, which determined that the
top of the parapet will be 201 feet AMSL, and the top of the mechanical
screen/mechanical penthouse will be 217 feet AMSL. Ground level elevation at the
building was determined to be equivalent to about 39 feet AMSL. These elevations
utilize the National Geodetic Vertical Datum (NGVD) 29, which is generally
accepted as equivalent to elevations above MSL in the San Francisco Bay Area and
as the acceptable datum for use in requesting an FAA obstruction determination. The
commenter is referencing elevations based upon NAVD 88, which is approximately
2.8 feet lower than NGVD 29 at the project site, resulting in a building elevation
approximately 2.8 feet lower. The difference between the measurements resulting
from these two methodologies is not material. The GOP 4 North building will be
shorter than GOP 1, and approximately the same height as GOP 2. As the
commenter notes, the critical aeronautical surfaces at the project site would be at an
elevation between approximately 510 and 540 feet NAVD 88, which is several
hundred feet above the tallest portion of GOP 4 regardless how it is measured. The
comment does not assert any inadequacies in the analysis included in the Draft SEIR.
No further response is required.
2-2 The comment states that the proposed project does not appear to be inconsistent with
the Noise and Safety Compatibility policies adopted in the Comprehensive Airport
Land Use Compatibility Plan for the Environs of San Francisco International Airport
(SFO ALUCP). The comment does not assert any inadequacies in the analysis
included in the Draft SEIR. No further response is required.
2-3 The comment states that the proposed project does not appear to be incompatible
with the Airspace Compatibility policies of the SFO ALUCP, subject to the issuance
of a Determination of No Hazard from the Federal Aviation Administration (FAA)
and determinations from the San Mateo County Airport Land Use Commission. The
comment does not assert any inadequacies in the analysis included in the Draft SEIR.
No further response is required.
2-4 The comment states that the proposed project will be required to undergo FAA
review as described in 14 Code of Federal Regulations Part 77, which is correct. The
2. Comments and Responses
Gateway of the Pacific 4 Density Transfer Project 2-15 ESA / D202101143
City of South San Francisco May 2022
comment does not assert any inadequacies in the analysis included in the Draft SEIR.
No further response is required.
2-5 The comment references Airspace Protection Policies (AP-1 through AP-4) from the
SFO ALUCP. The Project has been submitted to the Airport Land Use Commission
for a review of consistency with the SFO ALUCP. The comment does not assert any
inadequacies in the analysis included in the Draft SEIR. No further response is
required.
Gateway of the Pacific 4 Density Transfer Project 3-1 ESA / D202101143
City of South San Francisco May 2022
CHAPTER 3
Mitigation Monitoring and Reporting Program
(MMRP)
3.1 Introduction
Public Resources Code section 21081.6 and section 15097 of the California Environmental
Quality Act (CEQA) Guidelines require public agencies to establish monitoring or reporting
programs for projects approved by a public agency whenever approval involves the adoption of
either a mitigated negative declaration or specified environmental findings related to
environmental impact reports.
The following is the Mitigation Monitoring and Reporting Program (MMRP) for the Gateway of
the Pacific (GOP) 4 Density Transfer project. The intent of the MMRP is to track and
successfully implement the mitigation measures identified within the GOP 4 Density Transfer
Project Draft Supplemental Environmental Impact Report (SEIR) prepared for the GOP 4 Density
Transfer project.
3.2 Mitigation Measures
The mitigation measures are taken from the GOP 4 Density Transfer Project Draft SEIR prepared
for the GOP 4 Density Transfer project and are assigned the same number as in those documents.
The following MMRP describes the actions that must take place to implement each mitigation
measure for the expansion proposed by the GOP 4 Density Transfer Project, the timing of those
actions, and the entities responsible for implementing and monitoring the actions. The GOP 4
Precise Plan, as amended by the GOP 4 Density Transfer Project, remains subject to the MMRP
attached to Planning Commission Resolution No. 2858-2020 (which adopted an Addendum for
the original GOP 4 Precise Plan).
3.3 MMRP Components
The components of the attached table, which contains applicable mitigation measures, are
addressed briefly, below.
Impact: This column summarizes the impact stated in the GOP 4 Density Transfer Project Draft
SEIR prepared for the GOP 4 Density Transfer project.
Mitigation Measure: All mitigation measures identified in the GOP 4 Density Transfer Project
Draft SEIR are presented and numbered accordingly.
3. Mitigation Monitoring and Reporting Program (MMRP)
Gateway of the Pacific 4 Density Transfer Project 3-2 ESA / D202101143
City of South San Francisco May 2022
Time Frame/Monitoring Milestone: Implementation of the action must occur prior to or during
some part of project approval, project design or construction or on an ongoing basis. The timing
for each measure is identified.
Responsible Monitoring Party: This item identifies the entity that will undertake the required
action.
3. Mitigation Monitoring and Reporting Program (MMRP)
Gateway of the Pacific 4 Density Transfer Project 3-3 ESA / D202101143
City of South San Francisco May 2022
TABLE 3-1
MITIGATION MONITORING AND REPORTING PROGRAM (MMRP)
Impact Mitigation Measure Timing Monitoring Party
Environmental Impact Report
4.1 Transportation and Circulation
Impact 3.1-2: The proposed project
would conflict or be inconsistent with
CEQA Guidelines Section 15064.3,
subdivision b) related to VMT.
Mitigation Measure 3.1-1: First- and Last-Mile Transit Connections and Active
Transportation Improvements
First- and last-mile transit connections and active transportation improvements are likely
to yield the greatest VMT reductions. These measures would not only serve the density
transfer project but also the entire GOP Master Plan area and all of the existing and
planned development in the area. Thus, the new VMT generated by the project would be
partially offset by reductions in VMT for other development. The following mitigation
measures support and enable the first-and last-mile non-auto commute strategies in the
GOP Master Plan TDM Plan. The mitigation measures described below are appropriate
under both existing plus project conditions and cumulative plus project conditions.
A) The project applicant has acquired the rail spur property adjacent to the GOP 4 site
and shall use it to connect the GOP Master Plan area with the 475 Eccles site, which
is currently referred to as GOP Phase 5, approved for two office/R&D buildings
totaling 262,287 square feet and one parking structure. The applicant proposes to
develop the rail spurs into a publicly accessible multi-use path connecting Oyster
Point Boulevard with Forbes Boulevard, with pedestrian amenities, all to implement
the City’s draft “rails to trails” plan. A grand staircase allowing access from the lower
elevation of the GOP Master Plan area to the higher elevation of the 475 Eccles site
is also proposed. The applicant shall construct these improvements. This multi-use
path shall connect to Class II bicycle lanes on Oyster Point Boulevard and to the
multi-use trail on Forbes Boulevard.
B) The applicant shall construct crossings at the northern and southern ends of the
multi-use path required by paragraph (a) above, at Forbes Boulevard and Oyster
Point Boulevard, in the configuration determined necessary by the City Engineer for
bicycle access from those streets to the multi-use path.
C) The applicant shall use good faith efforts to obtain all approvals and consent required
to install the improvements required by paragraphs (a) and (b) above, including the
use of any necessary land owned by the applicant or its affiliates. Each improvement
shall be constructed by the later of (i) issuance of the first certificate of occupancy for
any portion of the 120,221 square-foot expansion in GOP 4, or (ii) such time as
public agencies have granted all necessary approvals for the mitigation improvement
and the applicant has been given the right to construct on any land owned by others
that is necessary for the mitigation improvement.
Prior to the issuance of first occupancy
permit; or such time as public agencies
have granted all necessary approvals for
the mitigation improvement and the
applicant has been given the right to
construct on any land owned by others
that is necessary for the mitigation
improvement.
City of South San
Francisco Public
Works Department
Impact 3.1-5: Implementation of the
proposed project, in combination with
other development, could contribute
to cumulative conditions where VMT
per capita or VMT per employee
could exceed 85 percent of the 2040
cumulative Bay Area-wide regional
average daily VMT per employee.
Implement Mitigation Measure 3.1-1. Prior to the issuance of first occupancy
permit; or such time as public agencies
have granted all necessary approvals for
the mitigation improvement and the
applicant has been given the right to
construct on any land owned by others
that is necessary for the mitigation
improvement.
City of South San
Francisco Public
Works Department
Gateway of the Pacific 4 Density Transfer Project 3-1 ESA / D202101143
City of South San Francisco May 2022
CHAPTER 3
Mitigation Monitoring and Reporting Program
(MMRP)
3.1 Introduction
Public Resources Code section 21081.6 and section 15097 of the California Environmental
Quality Act (CEQA) Guidelines require public agencies to establish monitoring or reporting
programs for projects approved by a public agency whenever approval involves the adoption of
either a mitigated negative declaration or specified environmental findings related to
environmental impact reports.
The following is the Mitigation Monitoring and Reporting Program (MMRP) for the Gateway of
the Pacific (GOP) 4 Density Transfer project. The intent of the MMRP is to track and
successfully implement the mitigation measures identified within the GOP 4 Density Transfer
Project Draft Supplemental Environmental Impact Report (SEIR) prepared for the GOP 4 Density
Transfer project.
3.2 Mitigation Measures
The mitigation measures are taken from the GOP 4 Density Transfer Project Draft SEIR prepared
for the GOP 4 Density Transfer project and are assigned the same number as in those documents.
The following MMRP describes the actions that must take place to implement each mitigation
measure for the expansion proposed by the GOP 4 Density Transfer Project, the timing of those
actions, and the entities responsible for implementing and monitoring the actions. The GOP 4
Precise Plan, as amended by the GOP 4 Density Transfer Project, remains subject to the MMRP
attached to Planning Commission Resolution No. 2858-2020 (which adopted an Addendum for
the original GOP 4 Precise Plan).
3.3 MMRP Components
The components of the attached table, which contains applicable mitigation measures, are
addressed briefly, below.
Impact: This column summarizes the impact stated in the GOP 4 Density Transfer Project Draft
SEIR prepared for the GOP 4 Density Transfer project.
Mitigation Measure: All mitigation measures identified in the GOP 4 Density Transfer Project
Draft SEIR are presented and numbered accordingly.
3. Mitigation Monitoring and Reporting Program (MMRP)
Gateway of the Pacific 4 Density Transfer Project 3-2 ESA / D202101143
City of South San Francisco May 2022
Time Frame/Monitoring Milestone: Implementation of the action must occur prior to or during
some part of project approval, project design or construction or on an ongoing basis. The timing
for each measure is identified.
Responsible Monitoring Party: This item identifies the entity that will undertake the required
action.
3. Mitigation Monitoring and Reporting Program (MMRP)
Gateway of the Pacific 4 Density Transfer Project 3-3 ESA / D202101143
City of South San Francisco May 2022
TABLE 3-1
MITIGATION MONITORING AND REPORTING PROGRAM (MMRP)
Impact Mitigation Measure Timing Monitoring Party
Environmental Impact Report
4.1 Transportation and Circulation
Impact 3.1-2: The proposed project
would conflict or be inconsistent with
CEQA Guidelines Section 15064.3,
subdivision b) related to VMT.
Mitigation Measure 3.1-1: First- and Last-Mile Transit Connections and Active
Transportation Improvements
First- and last-mile transit connections and active transportation improvements are likely
to yield the greatest VMT reductions. These measures would not only serve the density
transfer project but also the entire GOP Master Plan area and all of the existing and
planned development in the area. Thus, the new VMT generated by the project would be
partially offset by reductions in VMT for other development. The following mitigation
measures support and enable the first-and last-mile non-auto commute strategies in the
GOP Master Plan TDM Plan. The mitigation measures described below are appropriate
under both existing plus project conditions and cumulative plus project conditions.
A) The project applicant has acquired the rail spur property adjacent to the GOP 4 site
and shall use it to connect the GOP Master Plan area with the 475 Eccles site, which
is currently referred to as GOP Phase 5, approved for two office/R&D buildings
totaling 262,287 square feet and one parking structure. The applicant proposes to
develop the rail spurs into a publicly accessible multi-use path connecting Oyster
Point Boulevard with Forbes Boulevard, with pedestrian amenities, all to implement
the City’s draft “rails to trails” plan. A grand staircase allowing access from the lower
elevation of the GOP Master Plan area to the higher elevation of the 475 Eccles site
is also proposed. The applicant shall construct these improvements. This multi-use
path shall connect to Class II bicycle lanes on Oyster Point Boulevard and to the
multi-use trail on Forbes Boulevard.
B) The applicant shall construct crossings at the northern and southern ends of the
multi-use path required by paragraph (a) above, at Forbes Boulevard and Oyster
Point Boulevard, in the configuration determined necessary by the City Engineer for
bicycle access from those streets to the multi-use path.
C) The applicant shall use good faith efforts to obtain all approvals and consent required
to install the improvements required by paragraphs (a) and (b) above, including the
use of any necessary land owned by the applicant or its affiliates. Each improvement
shall be constructed by the later of (i) issuance of the first certificate of occupancy for
any portion of the 120,221 square-foot expansion in GOP 4, or (ii) such time as
public agencies have granted all necessary approvals for the mitigation improvement
and the applicant has been given the right to construct on any land owned by others
that is necessary for the mitigation improvement.
Prior to the issuance of first occupancy
permit; or such time as public agencies
have granted all necessary approvals for
the mitigation improvement and the
applicant has been given the right to
construct on any land owned by others
that is necessary for the mitigation
improvement.
City of South San
Francisco Public
Works Department
Impact 3.1-5: Implementation of the
proposed project, in combination with
other development, could contribute
to cumulative conditions where VMT
per capita or VMT per employee
could exceed 85 percent of the 2040
cumulative Bay Area-wide regional
average daily VMT per employee.
Implement Mitigation Measure 3.1-1. Prior to the issuance of first occupancy
permit; or such time as public agencies
have granted all necessary approvals for
the mitigation improvement and the
applicant has been given the right to
construct on any land owned by others
that is necessary for the mitigation
improvement.
City of South San
Francisco Public
Works Department