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FINAL
Environmental Impact Report
General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco, San Mateo County, California
State Clearinghouse Number 2021020064
Prepared for:
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Date: September 6, 2022
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Table of Contents
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Table of Contents
Section 1: Introduction ............................................................................................................... 1-1
Section 2: Responses to Written Comments ................................................................................ 2-1
2.1 - List of Authors ................................................................................................................ 2-1
2.2 - Responses to Comments ................................................................................................ 2-1
Section 3: Errata.......................................................................................................................... 3-1
3.1 - Changes in Response to Specific Comments .................................................................. 3-1
Attachment A: Updated Exhibits
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Introduction
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SECTION 1: INTRODUCTION
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of
South San Francisco (Lead Agency) has evaluated the comments received on the General Plan
Update, Zoning Code Amendments, and Climate Action Plan Draft Program Environmental Impact
Report (Draft Program EIR). Pursuant to CEQA Guidelines Section 15132, this Final EIR includes a list
of persons, organizations, and agencies that provided comments on the Draft Program EIR;
responses to the comments received regarding the Draft Program EIR; and errata, or revisions to the
Draft Program EIR; as well as a Mitigation Monitoring and Reporting Program (MMRP) for use by the
City of South San Francisco during its review.
This document is organized into three sections:
• Section 1—Introduction. Provides an introduction to the Final EIR.
• Section 2—Responses to Written Comments. Provides a list of the agencies, organizations,
and individuals who commented on the Draft EIR. Copies of all of the letters received
regarding the Draft EIR and responses thereto are included in this section.
• Section 3—Errata. Includes an addendum listing refinements and clarifications on the Draft
EIR, which have been incorporated.
The Final EIR includes the following contents:
• Draft Program EIR (provided under separate cover)
• Draft Program EIR Appendices (provided under separate cover)
• Responses to Written Comments on the Draft Program EIR and Errata (Sections 2 and 3 of this
document)
• Mitigation Monitoring and Reporting Program (MMRP) (provided under separate cover)
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Final EIR Responses to Written Comments
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SECTION 2: RESPONSES TO WRITTEN COMMENTS
2.1 - List of Authors
A list of public agencies, organizations, and individuals that provided comments on the City of South
San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan Draft Program
Environmental Impact Report (Draft Program EIR) is presented below. Each comment has been
assigned a code. Individual comments within each communication have been numbered so
comments can be crossed-referenced with responses. Following this list, the text of the
communication is reprinted and followed by the corresponding response.
Author Author Code
State Agencies
California Department of Transportation .................................................................................... Caltrans
California Geological Survey ............................................................................................................... CGS
Local Agencies
San Francisco International Airport .................................................................................................... SFO
Individuals
Buchalter ............................................................................................................................... BUCHALTER
2.2 - Responses to Comments
2.2.1 - Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the
City of South San Francisco, as the Lead Agency, evaluated the comments received on the Draft
Program EIR (State Clearinghouse No. 2021020064) for the General Plan Update, Zoning Code
Amendments, and Climate Action Plan, and has prepared the following responses to the comments
received. Section 15088(c) of the State CEQA Guidelines specifies that the focus of the responses to
comments shall be on the disposition of significant environmental issues. Responses to comments
regarding the merits of the project or on issues unrelated to the project’s environmental impacts are
not required. Accordingly, such comments are summarized and noted in the responses and will be
reviewed by the City before any action by decision makers.
This Response to Comments document becomes part of the Final EIR for the project in accordance
with CEQA Guidelines Section 15132.
2.2.2 - Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the
List of Authors.
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“Provide a safe and reliable transportation network that serves all people and respects the environment”
DISTRICT 4 OFFICE OF REGIONAL AND COMMUNITY PLANNING P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660 www.dot.ca.gov
August 9, 2022 SCH #: 2021020064
GTS #: 04-SM-2021-00446
GTS ID: 21933
Co/Rt/Pm: SM/101/22.022
Billy Gross, Principal Planner
315 Maple Avenue
South San Francisco, CA 94083
Re: South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan Program Environmental Impact Report
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the General Plan Update, Zoning Code
Amendments and Climate Action Plan Project. We are committed to ensuring that
impacts to the State’s multimodal transportation system and to our natural
environment are identified and mitigated to support a safe, sustainable, integrated,
and efficient transportation system. The following comments are based on our review
of the July 2022 draft EIR.
Project Understanding
The proposed project includes the implementation of the South San Francisco General
Plan Update, Zoning Code Amendments, and Climate Action Plan which are
collectively referred to as the proposed project in this document. The General Plan
Update anticipates approximately 14,312 net new housing units and approximately
42,297 net new employment opportunities by 2040. The Proposed Land Use Map
designates the general location, distribution, and extent of land uses within the
Planning Area and identifies proposed land use designations for each parcel within
the City of South San Francisco and within the City’s SOI. The updated 2022 Climate
Action Plan (CAP) includes a community-wide inventory of greenhouse gas (GHG)
emissions and identifies strategies and measures to reduce GHG emissions generated
by existing and future uses in the City.
Caltrans
Page 1 of 3
Billy Gross, Principal Planner
August 9, 2022
Page 2
“Provide a safe and reliable transportation network that serves all people and respects the environment”
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).
Caltrans’ acknowledges that the project Vehicle Miles Traveled (VMT) analysis and
significance determination are undertaken in a manner consistent with the Office of
Planning and Research’s (OPR) Technical Advisory. However, due to the increased
amount of projected vehicle miles traveled, this project will have significant and
unavoidable impacts to the transportation network as indicated in the environmental
document. The Plan presents an expected jobs to housing ratio of 3.53 by 2040. This
jobs to housing ratio results in greater VMT and greenhouse gas emissions and may
negatively impact local and State climate goals and the transportation network.
Increasing the housing development in the two Priority Development Areas of the City
(the Downtown PDA and the El Camino Real PDA) can support lower VMT and
mitigate impacts from the Plan.
Active Transportation
Class IV facilities, along with Class I paths, are typically the lowest-stress facilities for
users of all ages and abilities. It is noted that the City currently has 0 miles of Class IV
facilities. While the City emphasizes low-stress active transportation networks and
connectivity in this project, Caltrans encourages prioritizing the implementation of a
network of low-stress bikeways so that this number increases. Prioritization and target
build horizons of Class IV facilities should be included in both policy and action in this
General Plan update. Please reach out to Caltrans for coordination as needed to
support this implementation.
MOB-4.1.4 and MOB-4.2 mention incorporating first/last-mile connections and micro-
mobility as an innovation where feasible. Caltrans encourages a more robust
prioritization of micro-mobility, which may realize more mitigation of projected VMT
impacts. Scooters, bikeshare, e-bikes, e-mopeds, and infrastructure to store, dock, and
support these devices can successfully shift users from single occupancy vehicle trips
to non-polluting transportation modes. As with all transport, a well-established multi-
modal network provides compounding positive effects. Caltrans encourages multi-
modal goals, policies and projects that support safe and equitable access for all users,
motorized and non-motorized, within the City’s travelshed. By emphasizing micro-
mobility, low-stress bikeways, and a lower jobs to housing ratio, it will help mitigate
negative impacts of the projected VMT increases.
Caltrans Page 2 of 3
Billy Gross, Principal Planner
August 9, 2022
Page 3
“Provide a safe and reliable transportation network that serves all people and respects the environment”
Transportation Operations
Caltrans appreciates the City working with Caltrans to develop improvement
measures for freeway off-ramps and adjacent intersections that help manage offramp
queues related to safety. When conducting safety reviews for proposed land use
projects and plans affecting the State Highway System, please refer to the Caltrans
Traffic Safety Bulletin.
Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet
American Disabilities Act (ADA) Standards after project completion. As well, the
project must maintain bicycle and pedestrian access during construction. These
access considerations support Caltrans’ equity mission to provide a safe, sustainable,
and equitable transportation network for all users.
Thank you again for including Caltrans in the environmental review process. Should
you have any questions regarding this letter, or for future notifications and requests for
review of new projects, please email [email protected].
Sincerely,
MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
Caltrans Page 1 of 3
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Final EIR Responses to Written Comments
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State Agencies
California Department of Transportation (Caltrans)
Response to Caltrans-1
The commenter provides general introductory remarks and does not raise any environmental issues.
No response is required.
Response to Caltrans-2
The commenter provides general information about the analysis of Vehicle Miles Traveled (VMT) and
does not raise any environmental issues. No response is required.
Response to Caltrans-3
The commenter acknowledges that the Draft Program EIR provided VMT analysis consistent with the
Governor’s Office of Planning and Research (OPR) Technical Advisory. No response is required.
Response to Caltrans-4
The commenter notes that the Draft Program EIR identifies a significant and unavoidable VMT
impact, and suggests that increasing housing development in the two Priority Development Areas in
the City can support lower VMT that would mitigate this impact.
Comment is noted. The General Plan would increase the allowable area of housing in both Priority
Areas, adding allowances for mixed use, as well as the addition of approximately 10,000 housing
units.
Through an extensive community engagement process that included over 75 public meetings, the
General Plan created a land use plan that aimed to:
• Retain life science uses that will ensure South San Francisco will remain a world class life
sciences destination and an economic engine for the region.
• Produce a range of housing types for different income levels and household types across the
City to balance job and housing growth and distribute the potential impacts of future growth.
• Maintain industrial uses in Lindenville and East of 101 Area.
The General Plan and EIR allows up to 14,312 net new housing units within the General Plan 2040
time horizon, representing a 63 percent increase in housing units in the City (22,877 housing units in
2022 per California Department of Finance). Along with new housing opportunities along El Camino
near the South San Francisco Bay Area Rapid Transit (BART) station and Downtown near the South
San Francisco Caltrain Station, the General Plan establishes new, mixed-use residential
neighborhoods in East of 101 and Lindenville. These areas allow for a mix of high-density residential
and commercial uses. Since these areas did not previously allow residential development, the
General Plan also ensures development of appropriate City services, amenities, and retail to support
new residential growth.
To support this effort and the implementation of mixed-use communities, the City launched a
Specific Plan for Lindenville earlier this year as a follow-up implementation action in the General Plan
(SA-22.1.1). The Specific Plan aims to help realize the General Plan’s vision for the area with the
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Responses to Written Comments Administrative Final EIR
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development of more detailed design standards, implementation programs, and capital
improvements to successfully create residential neighborhoods in a historically industrial area.
Response to Caltrans-5
The commenter provides information about Class IV bikeway facilities and encourages the City to
prioritize the implementation of a network of low-stress bikeways as part of the General Plan
Update.
The comment is noted, and the City agrees with the need for more Class IV facilities. As noted in the
General Plan Update, the proposed project encourages implementation of the Active South City
Plan, which focuses on a number of new bikeway facilities including Class IV facilities.
Response to Caltrans-6 The commenter provides information about first/last-mile connections and encourages the City to
prioritize micro-mobility and multimodal goals, policies and projects to help mitigate the negative
impacts of the projected VMT increases.
The comment is noted, and the City agrees with the need for more micro-mobility facilities. As noted
in the comment, MOB 2.1.3 directs the City to implement the Active South City Pedestrian and
Bicycle Plan. This Plan is the City’s roadmap to encouraging use of and designing facilities for micro-
mobility devices, which have overlap with bicycle and pedestrian facilities.
Response to Caltrans-7
The commenter expresses appreciation for the City in working with Caltrans to develop
improvement measures for freeway off-ramps and adjacent intersections, and provides a link to the
Caltrans Traffic Safety Bulletin.
The comment is noted; no response is required.
Response to Caltrans-8
The commenter notes that the project must maintain bicycle and pedestrian access during
construction and that any Caltrans facilities affected by the project must meet Americans with
Disabilities Act (ADA) standards after project construction.
The comment does not identify any significant environmental issues or raise questions regarding the
analysis in the Draft Program EIR. The City intends to maintain bike and pedestrian access
throughout construction. No further response is required.
Response to Caltrans-9
The commenter provides closing remarks and contact information. No response is required.
From: "Frost, Erik@DOC" <[email protected]>
Date: August 9, 2022 at 10:56:57 AM MDT
To: "Gross, Billy" <[email protected]>
Cc: [email protected], OPR State Clearinghouse <[email protected]>
Subject: City of South San Francisco General Plan Update (SCH 2021020064) - CGS comments
[NOTICE: This message originated outside of City of South San Francisco -- DO NOT CLICK on links or
open attachments unless you are sure the content is safe.]
Mr. Gross,
The California Geological Survey (CGS) has received the Notice of Availability of a Program
Environmental Impact Report (EIR) for the proposed South San Francisco General Plan Update. This
email conveys the following recommendations from CGS concerning geologic issues related to the
subject area:
1. Liquefaction and Landslide Hazards
On September 23, 2021, the CGS released an Official Seismic Hazard Zone Report (SHZR) and
Earthquake Zone of Required Investigation Map (EZRIM) for the San Francisco South
quadrangle, which includes the subject area. Although the EIR does appear to accurately reflect
the extent of Earthquake Zones of Require Investigation (EZRI) for liquefaction in Exhibit 3.6-5,
the EZRI for landslides do not match those published by the CGS. The EIR text should be revised
to note that zone of required investigation for liquefaction and landsliding are mapped within
the City, and Exhibit 3.6-4 should be revised based on information in the links below:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=regulatorymaps
Cities and counties affected by EZRI must regulate certain development projects within them.
The Seismic Hazards Mapping Act (1990) also requires sellers of real property (and their agents)
to disclose at the time of sale that the property lies within such a zone.
If you have any additional comments or questions, please feel free to call or email.
Erik
Dr. Erik Frost
Senior Engineering Geologist | Seismic Hazards Program California Geological Survey 715 P Street, MS 1901, Sacramento, CA 95814 (916) 205-8255
[email protected]
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Final EIR Responses to Written Comments
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California Geological Survey (CGS)
Response to CGS-1
The commenter provides a link to mapping for liquefaction and landslide hazards, and asks that
Exhibit 3.6-4 and Exhibit 3.6-5 be revised accordingly.
The comment is noted, and the updated Exhibit 3.6-4 and Exhibit 3.6-5 are included in Section 3,
Errata. The updated exhibits do not change the analysis or conclusions of the Draft Program EIR.
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August 9, 2022
Billy Gross, Principal Planner TRANSMITTED VIA E-MAIL and U.S. MAIL City of South San Francisco [email protected] Planning Division
315 Maple Ave.
South San Francisco, CA 94080 Subject: Comment Letter: Draft Program Environmental Impact Report for Proposed South San Francisco General Plan Update, Zoning Code Amendments, and
Climate Action Plan
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a Draft Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan (the
Proposed Project). We appreciate this opportunity to coordinate with the City of South San
Francisco (the City) in considering potential land use compatibility issues that the Proposed Project may pose and should address.
As described in the Draft Program EIR, the project site is the geographic limits of the City, in San Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with,
City and County of San Francisco/SFO property boundaries. The City is primarily residential, with
this use occupying approximately 40% of its land area, followed by industrial/research and development at approximately 30%, and parks/open space/common greens at approximately 10%. The Proposed Project would serve as a blueprint for the City’s vision through the year 2040 and would replace the 1999 General Plan and inform updates to the City’s Zoning Ordinance.
The Airport’s specific comments regarding Draft Program EIR are noted below:
1. NOISE COMPATIBILITY The Airport is concerned that much of the land slated for zoning changes is closer to the Airport than the previous General Plan’s housing element, and portions of the proposed mixed-use residential zones are within the Airport’s runway safety zone boundaries and 65 decibel (dB)
Community Noise Equivalent Level (CNEL) noise contour. We expressed concern about this issue in our March 22, 2021 comment letter, which is attached hereto as Exhibit A (and incorporated by reference.). In the 1999 General Plan, the City acknowledged the significance of and retained areas east of U.S. 101 for cargo handling and freight forwarder uses that support the cargo operations of companies using SFO. The Airport appreciates that in the intervening years, the City has
successfully maintained these land uses east of U.S. 101, which enhance and support the relationship among the City, its residents, and the Airport, and supports the City and regional economy. These existing compatible land uses east of U.S. 101 include industrial, warehousing, hotels, and office/research & development. The Airport cautions against the Proposed Project’s departure from this successful practice.
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Billy Gross, City of South San Francisco
August 9, 2022 Page 2 of 4
The Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP) policies for noise are to protect the comfort and quality of life of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher contours. The Draft Program EIR identifies in Impact HAZ-5 that the General Plan Policy SA-12.6
requires the City to encourage residential development in the South Spruce area that is within the 65
dB CNEL, provided that the structure meets the standard indoor 45 dB noise requirement. This impact statement does not acknowledge that the SFO ALUCP also requires the grant of an avigation easement to the City and County of San Francisco, as the proprietor of SFO, as a condition of allowing residential development within the 65 dB CNEL contour.1 At a minimum, the requirement
for granting an avigation easement should be included in Impact HAZ-5 in determining the level of
significance. Impact LUP-2 also acknowledges that portions of the proposed mixed-use residential land use designations are located within the 65 dB CNEL and does state the requirement for granting an avigation easement but does not mention the requirement to reduce the indoor noise level to 45 dB. Also, while avigation easements are an important liability mitigation tool, they do
not replace the imperative to avoid introducing incompatible uses into a noise-affected area. As
shown in ALUCP Table IV-1, residential uses are not compatible within the 70 dB contour and higher, and the Draft Program EIR should evaluate them as such. Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap
or Oyster Point, including one procedure, the Shoreline Departure visual procedure, which is a noise
abatement procedure designed specifically to keep aircraft over the industrial areas of the City east of U.S. 101 and away from its traditional residential areas. Any residential developments east of U.S. 101, such as those proposed in the General Plan Update, could reduce the efficacy of the Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to
protect residents of South San Francisco, Daly City, and Pacifica by maximizing flights over water
and industrial areas between 1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise disturbances from aircraft departures. We expressed concern about this in our March 22, 2021 comment letter. The Draft Program EIR has not specifically analyzed these potential environmental impacts of the Proposed Project. The Airport also urges the City to
engage the SFO Airport/Community Roundtable as soon as possible to notify the public and
stakeholders about the project as it relates to the existing and long-established aircraft noise abatement procedures to the City and adjacent cities. Also, in Impact NOI-3, the Draft Program EIR states “These airport activity noise levels could
exceed the City’s noise/land use compatibility standards for certain land uses.” This language
implies that the Airport is actively exceeding noise and land use compatibility standards. This language is misleading and should be corrected; rather, the General Plan Update would allow for mixed-use residential uses within the already established 65 dBA CNEL. Also, within this impact statement, an incorrect reference to Mitigation Measure (MM) NOI-2 is made; there is no MM
NOI-2. Rather, it should be MM NOI-3, which properly corresponds to the number of the impact
statement.
1 SFO ALUCP Noise Policy-3.
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Billy Gross, City of South San Francisco
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If the City were to propose a development which the ALUC determines is incompatible with the SFO ALUCP, then the City would be compelled to override the ALUC determination through its City Council if it wishes to proceed with the development. An override of the noise compatibility
policy requires granting of an avigation easement to the City and County of San Francisco, as
proprietor of SFO.
2. SAFETY COMPATIBILITY With respect to safety, Impact LUP-2 identifies that the southern portions of the General Plan Update area are within various runway end safety zones, including the Inner Approach/Departure
Zone (Zone 2), Inner Turning Zone (Zone 3), and Outer Approach/Departure Zone (Zone 4) and has the potential to conflict with respective zone restrictions. We expressed concern about this in our March 22, 2021 comment letter. Each of these zones carries restrictions on what may be located there, based on the safety compatibility criteria and guidelines in the ALUCP, which in turn were adapted from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already recognizes the intense level of existing development in the vicinity of SFO and makes compromises compared to the Handbook’s recommendations, and the Airport recommends against further degradation of these safety restrictions.
The Draft Program EIR concludes, however, under Impact LUP-2 that the Proposed Project would not cause a significant environmental impact. It is not clear how the Draft Program EIR comes to this conclusion as there are clear potential conflicts with safety compatibility policies as acknowledged in Impact LUP-2. The purpose of the safety compatibility policies is twofold: 1) to
protect the public health, safety, and welfare by minimizing the public’s exposure to the risk
associated with potential aircraft accidents in the Airport vicinity and 2) to protect the public interest in providing for the orderly development of SFO by preventing the creation of new safety problems in Airport environs. The overall objective is to minimize risks associated with potential aircraft accidents to persons on the ground and aircraft occupants.
3. AIRSPACE COMPATIBILITY Impact HAZ-5 describes how the City would consult with the City/County Association of Governments (C/CAG) and the Federal Aviation Administration (FAA) when new development is proposed in the vicinity of SFO. This language is potentially misleading as the City is not required to “consult” with but rather, it is required to submit to the C/CAG (or specifically, the Airport Land
Use Commission within C/CAG) for a determination of consistency with the SFO ALUCP. As it pertains to height compatibility, any proposed structure must lie wholly beneath the critical aeronautical surfaces defined in the SFO ALUCP and must obtain a Determination of No Hazard from the FAA. These processes are parallel, as the SFO ALUCP and the FAA study different
airspace surfaces when coming to their determinations. Given the degree of confusion that the City and the Airport have observed on this process over the past several years, the Airport suggests clarifying language that acknowledges these two parallel determination processes. Further, the
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Billy Gross, City of South San Francisco
August 9, 2022 Page 4 of 4
Airport recommends clarifying that for purposes of airspace evaluation, both the FAA and the SFO ALUCP reference elevations above mean sea level (MSL) as defined by the 0-foot origin of the North American Vertical Datum of 1988 (NAVD88), and not the ground level.
* * * The Airport appreciates your consideration of these comments. If I can be of assistance as the City considers airport land use compatibility as they relate to the General Plan update, Program EIR, or any future projects, please do not hesitate to contact me at (650) 821-6678 or at
[email protected]. Sincerely,
Nupur Sinha Director of Planning and Environmental Affairs San Francisco International Airport
P.O. Box 8097 San Francisco, California 94128 Attachment
cc: Susy Kalkin, ALUC Sean Charpentier, C/CAG Sam Hindi, Chairperson, SFO Airport/Community Roundtable Audrey Park, SFO
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ATTACHMENT
Comment Letter from SFO to City of South San Francisco re: Notice of Preparation of a Program
Environmental Impact Report for Proposed South San Francisco General Plan Update (March 22, 2021)
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March 22, 2021
Billy Gross TRANSMITTED VIA EMAIL
Senior Planner [email protected]
City of South San Francisco
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for Proposed South San
Francisco General Plan Update
Dear Mr. Gross,
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a
Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update
(the project). We appreciate this opportunity to coordinate with the City of South San Francisco (the City) in
considering and evaluating potential land use compatibility issues that the project may pose and should address.
As described in the Notice of Preparation (NOP), the project site is the geographic limits of the City, in San
Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with, City and
County of San Francisco/SFO property boundaries. The City is primarily residential, with this use occupying
approximately 40% of its land area, followed by industrial/research and development (RD) at approximately 30%,
and parks/open space/common greens at approximately 10%. The NOP notes that presently there are about 150
acres of vacant land remaining in the City, which amounts to 3.4% of the City. This project will serve as a
blueprint for the City’s vision through the year 2040 and will replace the 1999 General Plan and inform updates to
the City’s Zoning Ordinance.
The City’s proposed changes are highlighted in Proposed Land Use Maps and, specifically, the Land Use Map
depicting the changes from the existing map (see Figure 1). This map highlights the concentration in change along
the U.S. Highway 101 (U.S. 101) corridor, the “East of 101” precinct including Oyster Point, and transit nodes
such as the San Bruno Bay Area Rapid Transit (BART) and South San Francisco BART and Caltrain stations,
which have been targeted for zoning intensification. The NOP notes that the project permits approximately 14,324
net new housing units and approximately 13,352 net new employment opportunities by 2040. This map highlights
that much of this change will come from intensifying land uses which were previously exclusively office/RD or
industrial under the 1999 General Plan to include mixed use or high-density mixed use, which would allow for
residential uses.
The Airport is concerned that much of the land slated for this change is closer to the Airport than the previous
General Plan’s housing element, and portions of the proposed mixed-use residential zones are within the Airport’s
runway safety zone boundaries and 65 decibel (dB) Community Noise Equivalent Level (CNEL) noise contour.
In the 1999 General Plan, the City acknowledged the significance of and retained areas east of U.S. 101 for cargo
handling and freight forwarder uses that support the cargo operations at SFO. The Airport appreciates that in the
intervening years, the City has successfully maintained these land uses east of U.S. 101, which enhance and
support the relationship among the City, its residents, and the Airport. These existing compatible land uses east of
U.S. 101 include industrial, warehousing, hotels, and office/RD. The Airport cautions against the project’s
proposed departure from this successful practice.
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The close proximity of these areas to SFO would require developments to undergo federal, state, and local
regulatory review processes specific to airport noise, airspace safety, and other land use compatibility standards,
including 14 Code of Federal Regulations Part 77 regulations for the safety, efficient use, and preservation of
navigable airspaces. Airport staff encourages the City to work closely with the Airport Land Use Commission
(ALUC)1 to determine project consistency with the Comprehensive Airport Land Use Compatibility Plan for the
Environs of SFO (ALUCP)2 and other regulatory review procedures. The Program EIR should evaluate the
project for consistency with all ALUCP regulatory requirements and policies.
Figure 1: Proposed Changes from Existing Land Use Map (NOP of Program EIR Exhibit 5)
The ALUCP establishes policies, to ensure compatibility between the Airport and surrounding land uses and to
protect local residents and workers from adverse effects of airport operations. All three topics are based on
research into actual effects of airport operations on human health and safety.3
Noise: Reduce the potential number of future residents who could be exposed to noise effects from airport
and aircraft operations.
Safety: Minimize the potential number of future residents and land use occupants exposed to hazards
related to aircraft operations and/or catastrophic incidents.
Elevation/Height: Protect the navigable airspace around the Airport for the safe and efficient operation
of aircraft in flight.
1 State law requires an ALUC for every county with an airport in its jurisdiction. See Cal. Pub. Util. Code §§ 21670-21679.5.
In San Mateo County, the City/County Association of Governments of San Mateo County (C/CAG) board serves as the
ALUC.
2 State law requires the preparation of an ALUCP. See id. In 2012, C/CAG, in consultation with the Airport and surrounding
communities, adopted the current ALUCP, which addresses issues related to compatibility between airport operations and
surrounding proposed land use development, considering noise impacts, safety of persons on the ground and in flight, height
restrictions/airspace protection, and overflight notification.
3 California Department of Transportation (Caltrans) Division of Aeronautics, California Airport Land Use Planning
Handbook, October 2011.
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Most of the City, and all of the areas of proposed land use intensification around and to the east of U.S. 101, are
located within the ALUCP Airport Influence Areas A and B (see Figure 2). The ALUCP requires all residential
development within Area A, which is the entirety of San Mateo County, to provide real estate disclosures, a copy
of which can be found at ALUCP Appendix G-7. Additionally, within the more restrictive Area B, “the ALUC
[the C/CAG Board] shall exercise its statutory duties to review proposed land use policy actions, including new
general plans, specific plans, zoning ordinances, plan amendments and rezoning, and land development
proposals.”4 The City must accordingly submit the proposed general plan update to the ALUC for review.
Figure 2: ALUCP-defined boundaries affecting South San Francisco (ALUCP Exhibit IV-3)
With respect to noise compatibility, portions of the project are situated within the Airport’s 65 dB CNEL noise
contour, and some even within the 70 dB contour. The ALUCP policies for noise are to protect the comfort and
quality of life of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher
contours. To the extent that the project would allow such uses, the Program EIR must disclose and evaluate any
inconsistency with the ALUCP. The ALUCP requires the grant of an avigation easement to the City and County
of San Francisco, as the proprietor of SFO, as a condition of allowing residential development within the 65 dB
contour.5 While avigation easements are an important mitigation tool, they do not replace the imperative to avoid
introducing incompatible uses into a noise-affected area in the first place. As shown in ALUCP Table IV-1,
residential uses are not compatible within the 70 dB contour and higher, and the Program EIR should evaluate
them as such.
Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap or Oyster
Point, including one procedure, the Shoreline Departure visual procedure, which is a noise abatement procedure
designed specifically to keep aircraft over the industrial areas of the City east of U.S. 101 and away from its
traditional residential areas. Any residential developments east of U.S. 101 could reduce the efficacy of the
Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to protect residents
of South San Francisco, Daly City, and Pacifica by maximizing flights over water and industrial areas between
4 ALUCP IP-2 (Airport Influence Area B – Policy/Project Referral Area), p. IV-11.
5 ALUCP NP-3.
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Mr. Billy Gross March 22, 2021 Page 4 of 5
1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise
disturbances from aircraft departures. The Program EIR should evaluate these potential environmental impacts of
the project. The Airport also urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the project as it relates to the existing and long-established
aircraft noise abatement procedures to the City and adjacent cities.
Any proposed residential uses outside of the 65 dB contour should still meet the interior noise requirements of the
California Building Code. Noise impacts on sensitive receptors and any necessary mitigation measures should be
fully evaluated in the Program EIR, and the EIR should describe the project’s consistency with noise policies
described in ALUCP, including noise policies NP-1 through NP-4.
The Airport understands and supports the City’s efforts to address the region’s housing supply shortage with its
General Plan update. SFO has felt the effects of the housing crisis firsthand, with many people who work at the
Airport forced to finding housing 60 miles away, or farther. This places a considerable hardship on the
employees, Airport, neighboring communities, and the regional surface transportation system, and we would
welcome affordable, transit-oriented housing closer to the Airport. However, subjecting new residents to
excessive aircraft noise is not an equitable solution. SFO requests that the City revise its proposals for residential
and mixed uses away from the 65 dB CNEL contour, including the southern portions of Highway 101 and San
Bruno BART station. Any upzoning proposed along the City’s commercial core along Grand Avenue or higher
density around South San Francisco BART station would be outside of the critical 65 dB CNEL contour and
would not pose these concerns.
Figure 3: SFO runway safety compatibility zones around South San Francisco (ALUCP Exhibit IV-8)
With respect to safety, the southern portions of the General Plan area are within various runway end safety zones,
including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer Approach/Departure Zone (see
Figure 3). Each of these zones carry restrictions on what may be located there, based on the safety compatibility
criteria and guidelines from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already recognizes the
intense level of existing development in the vicinity of SFO, and the Airport recommends against overriding these
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Mr. Billy Gross March 22, 2021 Page 5 of 5
restrictions. The Program EIR should also describe and evaluate the project’s consistency with land use criteria
within these runway end safety zones, as described in ALUCP SP-1 through SP-3.
With respect to elevation, the Airport appreciates the City’s commitment to protecting the critical airspace
surfaces defined in the ALUCP, as these surfaces protect the safety and economic vitality of the Airport and the
City. The Airport has observed several points of confusion regarding airspace surfaces and requests that the City
work with SFO staff to ensure the accuracy of the guidance provided in the General Plan Update.
For example, all critical airspace surfaces are based on elevation above mean sea level (AMSL) – not height
above ground level (AGL). Therefore, if the General Plan Update establishes height restrictions, it should note
them in AMSL rather than AGL and incorporate by reference the most recently adopted version of the ALUCP. It
should also note that the finished height of any proposed development must be maintained below these clearance
limits, including architectural parapets, machine rooms, antennas, etc. The Airport suggests that any exhibits
included in the General Plan Update should include prominent notes which address these common concerns.
Finally, the General Plan Update also proposes a new vehicular bridge between Oyster Point, likely around the
southern end of Haskins Way, and North Access Road on Airport property. While we understand this may be
highly notional, if the City does intend to pursue the concept, the Program EIR should fully evaluate it. We also
request that the City keep the Airport apprised of any developments regarding this proposal, which would require
close coordination with the Airport. For example, the Airport would need to understand vehicular movements and
how the bridge could increase or redistribute traffic on the Airport’s roadways and intersection with Interstate 380
in deciding whether to support the project.
The Airport appreciates your consideration of these comments. If I can be of assistance as the City considers
airport land use compatibility as they relate to the General Plan update, Program EIR, or any future projects,
please do not hesitate to contact me at (650) 821-9464 or at [email protected].
Sincerely,
Nupur Sinha
Acting Planning Director
Planning and Environmental Affairs
cc: Susy Kalkin, Airport Land Use Committee
Sandy Wong, C/CAG
Audrey Park, SFO, Acting Environmental Affairs Manager
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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Local Agencies
San Francisco International Airport (SFO)
Response to SFO-1
The commenter provides introductory remarks. No response is required.
Response to SFO-2
The commenter expresses concern about the location of proposed land uses being closer to the
Airport than the previous General Plan’s housing element, noting that appropriate compatible uses
east of U.S. 101 include industrial, warehousing, hotels, and office/research and development. SFO
discourages residential uses within the Airport’s 65 decibel (dB) or higher contours.
The comment is noted. In response to the SFO 2021 letter, the City modified the proposed plan to
ensure that residential uses would not be located within the 70 dB or higher contours identified in
the SFO Airport Land Used Compatibility Plan (ALUCP) . Residential uses within the 65 dB contour are
required to meet the 45 dB interior standard (Title 24).
Response to SFO-3
The commenter notes that GP Policy SA-12.6 requires the City to encourage residential development
in the South Spruce area that is within the 65 dB Community Noise Equivalent Level (CNEL), provided
that the structure meets the standard indoor 45 dB noise requirement. The ALUCP requires the grant
of an avigation easement to the City and County of San Francisco, as the proprietor of SFO, as a
condition of allowing residential development within the 65 dB CNEL contour, and this requirement
should be included in Impact HAZ-5 in determining the level of significance.
The commenter also notes that Impact LUP-2 acknowledges this requirement but does not mention
the requirement to reduce indoor noise to 45 dB.
Proposed/future development must comply with the City’s Policies NOI-1.1 and NOI-1.2, which
establish interior noise compatibility standards. This impact is identified and addressed in Impact
NOI-3 and is mitigated to less than significant with implementation of MM NOI-2.
Response to SFO-4
The commenter notes that while avigation easements are an important liability mitigation tool, they
do not replace the imperative to avoid introducing incompatible uses into a noise-affected area. As
shown in ALUCP Table IV-1, residential uses are not compatible within the 70 dB contour and higher,
and the Draft Program EIR should evaluate them as such.
In response to the SFO 2021 letter, the City modified the proposed plan to ensure that residential
uses would not be located within the 70 dB or higher contours. Residential uses within the 65 dB
contour are required to meet the 45 dB interior standard (Title 24).
Response to SFO-5 The commenter notes that any residential developments east of U.S. 101, such as those proposed in
the General Plan Update, could reduce the efficacy of the Nighttime Preferential Runway Use
program developed in 1988 and put in place specifically to protect residents of South San Francisco,
Daly City, and Pacifica by maximizing flights over water and industrial areas between 1:00 a.m. and
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Responses to Written Comments Administrative Final EIR
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6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise disturbances
from aircraft departures. The Draft Program EIR has not specifically analyzed these potential
impacts.
See Response to Comment SFO-3, in reference to the fact that the impact is mitigated by requiring
developments to comply with interior noise standards.
Response to SFO-6
The commenter urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the proposed project as it relates to the existing
and long-established aircraft noise abatement procedures to the City and adjacent cities.
The comment is noted. No further response is required.
Response to SFO-7
The commenter notes that in the discussion for Impact NOI-3, the Draft Program EIR states “These
airport activity noise levels could exceed the City’s noise/land use compatibility standards for certain
land uses.” This language implies that the Airport is actively exceeding noise and land use
compatibility standards. The comment notes that this language is misleading and should be
corrected to state that the General Plan Update would allow for mixed-use residential uses within
the already established 65 dBA CNEL. The commenter also notes a typographical error related to
Mitigation Measure (MM) NOI-2. The comment states that the correct reference should be MM NOI-
3, which properly corresponds to the number of the impact statement.
The statement has been revised in Section 3, Errata to state, “The General Plan Update would allow
for mixed-use residential uses within the already established 65 dBA CNEL.”
The reference to MM NOI-3 has been corrected in Section 3, Errata to reference MM NOI-2.
Response to SFO-8
The commenter notes that if the City were to propose a development which the Airport Land Use
Commission (ALUC) determines is incompatible with the SFO ALUCP, then the City would be
compelled to override the ALUC determination through its City Council if it wishes to proceed with
the development. An override of the noise compatibility policy requires granting of an aviation
easement to the City and County of San Francisco, as proprietor of SFO.
The comment is noted; no further response is required.
Response to SFO-9
The commenter notes that Draft Program EIR Impact LUP-2 identifies that the southern portions of
the General Plan Update area are within various runway end safety zones, including the Inner
Approach/Departure Zone (Zone 2), Inner Turning Zone (Zone 3), and Outer Approach/Departure
Zone (Zone 4) and has the potential to conflict with respective zone restrictions. The Draft Program
EIR concludes under Impact LUP-2 that the proposed project would not cause a significant
environmental impact. The commenter inquires as to how the Draft Program EIR comes to this
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conclusion as there are clear potential conflicts with safety compatibility policies as acknowledged in
Impact LUP-2.
The Draft Program EIR identifies the requirement that future projects would be required to be
designed to ensure conformance with the SFO ALUCP.
As stated in Impact LUP-2, local plans, policy actions, or development activities that affect areas
within that boundary must receive ALUC approval or have a finding of overriding considerations
prior to local permit issuance. The SFO ALUCP requires all residential development within Area A,
which is the entirety of San Mateo County, to provide real estate disclosures (see SFO ALUCP
Appendix G-7). Additionally, within Area B, the ALUC (C/CAG of San Mateo County) is responsible for
reviewing proposed land use policy actions, including new general plans, specific plans, zoning
ordinances, plan amendments and rezoning, and land development proposals. As such, the City is
required to submit the General Plan Update to the ALUC for review and approval. Further, future
development within the SFO ALUCP areas must also be referred to the ALUC for a determination of
consistency. Future development under the proposed project would be evaluated for consistency
with the 2011 California Airport Land Use Planning Handbook and the SFO ALUCP. In reviewing
individual project applications, the City would determine which policies and actions apply and
whether project modifications would be required to ensure compatibility with the ALUCP, depending
on the specific characteristics of the project type and/or project site during the development review
process. Buildings within the ALUCP area would be required to comply with Federal Aviation
Administration (FAA) regulations for height.
Furthermore, the General Plan Update includes policies and actions related to land use compatibility.
Action SA-12.5.1 requires the General Plan to be in conformance with land use compatibility
standards in the ALUCP. Policy SA-21.3 allows building heights within maximum limits permitted
under FAA regulations. These actions, along with the requirements of the ALUCP and South San
Francisco Municipal Code ensure that future development would be consistent with the ALUCP.
Response to SFO-10
The commenter clarifies that the use of the term consultation with the City/County Associations of
Governments (C/CAG) and FAA is misleading, as the City is actually required to submit to the C/CAG
for a determination of consistency.
Impact HAZ-5 is revised in the Final EIR to clarify that the City is required to submit to the C/CAG for
a determination of consistency with the SFO ALUCP. Please refer to Section 3, Errata.
Response to SFO-11 The commenter notes that any proposed structure must lie wholly beneath the critical aeronautical
surfaces defined in the SFO ALUCP and must obtain a Determination of No Hazard from the FAA. The
commenter recommends clarifying that for purposes of airspace evaluation, both the FAA and the
SFO ALUCP reference elevations above mean sea level (MSL) as defined by the 0-foot origin of the
North American Vertical Datum of 1988 (NAVD88), and not the ground level.
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As the commenter notes, for purposes of airspace elevation, MSL and not ground level is used to
reference elevations. This comment does not raise any environmental issues with respect to the
Draft Program EIR or proposed project and no further response is required.
Response to SFO-12 The commenter provides closing remarks. No response is required.
Response to SFO-13
The commenter provides introductory remarks in response to the March 22, 2021 Notice of
Preparation (NOP). The comment does not raise any environmental concerns or questions regarding
the project. No further response is required.
Response to SFO-14
This NOP comment raises questions regarding the location of proposed land uses in relation to the
airport. In response to this comment, the proposed plan was revised as further explained in
Response to SFO-2.
Response to SFO-15
This NOP comment summarizes the proposed project and states that the City must submit the
proposed plan to the ALUC for review. As explained in Impact LUP-2 and Response to SFO-9, the City
is required to submit the General Plan Update to the ALUC for review and approval. Moreover, the
Draft Program EIR identifies the requirement that future projects would be required to be designed
to ensure conformance with the SFO ALUCP.
Response to SFO-16
This NOP comment discusses the need for an avigation easement. Please refer to Response to SFO-4.
Response to SFO-17
This NOP comment regarding residential development east of U.S. 101 and the relationship to the
efficacy of the Nighttime Preferential Runway Use program is addressed in Response to SFO-5. The
suggestion to SFO Airport/Community Roundtable is noted; however, this suggestion does not raise
any environmental concern or question that requires a further response under CEQA. This NOP
comment also suggests that Draft Program EIR discuss noise impacts with relation to areas outside of
the 65 dBA contour. Accordingly, potential impacts to areas outside of the 65dBA CNEL contours are
discussed in Section 3.11 of the Draft Program EIR. (See, e.g., Draft EIR, pp, 3.11-13, 3.11-34-3.11-
35.)
Response to SFO-18
This NOP comment expresses support for the City’s housing supply shortage and raises concerns
about location of proposed land uses. In response, the City modified the proposed plan to ensure
that residential uses would not be located within the 70 dBA or higher contours identified in the
ALUCP. Please refer to Response to SFO-3.
Response to SFO-19
This NOP comment states that the southern portions of the Planning Area are within various runway
end safety zones, including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer
Approach/Departure Zone, and requests that the Draft Program EIR describe and evaluate the
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
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project’s consistency with land use criteria within these runway end safety zones, as described in the
SFO Airport Land Use Compatibility Plan (ALUCP) SP-1 through SP-3. Please refer to Response to SFO-
9.
Response to SFO-20 This NOP comment notes that for purposes of airspace elevation, MSL and not ground level is used
to reference elevations. This comment does not raise any environmental issues with respect to the
Draft Program EIR or proposed project and no further response is required.
Response to SFO-21
This NOP comment requests that the Draft Program EIR evaluate impacts of the proposed vehicular
bridge between Oyster Point and North Access Road on airport property. Proposed improvements on
airport property and potential hazards are addressed in Impact HAZ-5 in Section 3.8 of the Draft
Program EIR. Land use compatibility of proposed improvements are further discussed in Section 3.10
of the Draft Program EIR.
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425 Market Street Suite 2900 San Francisco, CA 94105 415.227.0900 Phone 415.227.0770 Fax
BN 71998654v5
415.227.3508 Direct [email protected]
August 9, 2022
VIA E-MAIL ([email protected])
Billy Gross Principal Planner City of South San Francisco 315 Maple Avenue
South San Francisco, CA 94080
Re: Comments on the Shape SSF 2040 General Plan Update and Draft Environmental Impact Report (SCH# 2021020064)
Dear Billy:
Thank you for the opportunity to comment on the City of South San Francisco’s Shape
SSF 2040 General Plan Update (the “General Plan Update”), associated Zoning Code Update and Draft Environmental Impact Report (“DEIR”).
As you know, Healthpeak is the owner of the property located at 420, 440, 466, and 494 Forbes Boulevard (“Property”) in the “East of 101” area of the City of South San Francisco,
California (the “City,” or “South S.F.”). Buchalter represents Healthpeak as land use counsel for
the development of the Property. Healthpeak looks forward to the City Council’s adoption of the General Plan Update and Zoning Code Update so that Healthpeak may proceed with its efforts to develop the Property with approximately 1,652,930 square feet of office and lab space and associated amenities (the “Vantage Project”). Healthpeak also proposes to construct a new fire
station on the Property to benefit the Forbes Boulevard area.
Healthpeak supports and endorses the City’s efforts to prepare a General Plan Update and Zoning Code amendments that incorporate the vision for a more intensive level of development in the East of 101 area. We are encouraged by the policies the City is proposing to incorporate into the General Plan Update and Zoning Code amendments, and appreciate the DEIR’s
thorough analysis of the potential impacts of buildout of the General Plan. The proposed changes to the General Plan and City zoning ordinance increase the intensity within the Business and
Technology Park land use designation and will allow Healthpeak to develop the Vantage Project
Billy Gross August 9, 2022 Page 2
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at the 2.0 FAR density it envisions. Accordingly, the purpose of this letter is to submit clarifying
comments regarding the General Plan Update as applied to the Property, and clarify the DEIR’s assessment of impacts associated with the proposed increased development potential in furtherance of implementing the City’s development vision for the area.
The General Plan contemplates development at a 2.0 FAR on the Property, and the DEIR fully evaluates associated impacts.
General Plan, pages 60-64 – General Plan Update Figure 6 and Table 2: General Plan Land Use Designations designate the Property Business Technology Park (BTP) High. According to the General Plan, the BTP High designation allows high-density corporate headquarters, research and development facilities, and offices (FAR ranges from 0.5 up to 2.0
with community benefits). Healthpeak supports the proposed General Plan Update land use designation on the Property.
General Plan, page 116– Policy SA-21.1 promotes urban campus-style life science uses for R&D uses for life science and other innovative companies. Policy SA-21.2 proposes to restrict warehousing and distribution uses in BTP High areas. R&D campus uses often include
distribution facilities and warehouses as ancillary uses to support R&D and life science uses. Please clarify that such ancillary uses would be allowed as secondary uses under the BTP High designation.
DEIR, Pages 2-7, -10 through -11, -13, -15 – Healthpeak understands that the building projections in the General Plan Update and DEIR are based on the General Plan Update
designation for the Property as Business Technology Park (BTP) High. The BTP High land use
designation allows “high-density corporate headquarters, research and development facilities, and offices” with FAR density ranging from 0.5 to 2.0 with community benefits. (General Plan Update, p. 65.) This is necessary to achieve the City’s Policy LU-5.2 for the City to “support a mix of larger, higher-intensity [R&D company] campuses.” (General Plan Update, p. 72.)
Recognizing that the City “is a fully built city,” the DEIR explains that, “new development will primarily occur on parcels that already contain some existing homes or businesses” and that this will require locating much of this new development in the East of 101 area. (DEIR, p. 2-10.) Approximately 493 acres of the East of 101 area is slated for the BTP High designation. (DEIR, Table 2-2.) The Draft EIR and specifically Tables 2-4, 2-6, and 2-7
describe the estimated “development activity anticipated to occur through buildout of the General Plan Update.” These estimates include the number of Projected Jobs, as well as Projected Square Footage to increase in the Business Technology Park High land use designation upon General Plan buildout. For example, the BTP High designation is projected to create approximately 16,198 jobs and to amount to approximately 7,788,187 additional square feet of
development in the City. (DEIR, Table 2-6.)
Billy Gross August 9, 2022 Page 3
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The Property is currently underutilized. We agree with the City’s proposal to designate
the Property as BTP High, as it is a prime location for accommodating some of the General Plan Update’s anticipated development. Currently, much of the Property contains a variety of low intensity single-story commercial uses. One parcel is undeveloped and is used for semi-truck parking. The Vantage Project would redevelop this underutilized Property at a 2.0 FAR with
over 1.6 million square feet of high-intensity research and development and office facilities as envisioned in the General Plan Update and thoroughly evaluated in the DEIR.
The DEIR assumes that future development under the BTP High land use designation would generate approximately 40,656 jobs at 83 new jobs per acre. Healthpeak, however, is concerned that the employment generation estimates identified in Table 2-6 in the DEIR may be
low compared to the actual employment generated by life sciences and R&D land uses based on the tenants that occupy Healthpeak’s campuses in the City. Please clarify the basis for the employment estimates presented in Table 2-6 and confirm that the estimates correspond to the nature of higher intensity life science uses contemplated by the BTP High designation.
The Vantage Project is consistent with General Plan Update policy to locate
employment uses near transit centers, which, in part, further the reduction in the City’s greenhouse gas (“GHG”) emissions.
General Plan Update pages 70, 198; DEIR, Pages 3.2-25, 3.7-36, 3.7-41, and 3.7-55 – General Plan Update Policy LU-2.1 encourages the City to “Prioritize development near transit
centers. Collaborate with developers and property owners to locate new . . . employment uses
near transit centers to minimize reliance on personal automobiles.” Policy LU-2.1 encourages that development “assist in reducing or avoiding potential impacts related to GHG emissions.” Additionally, mobility Policy MOB-4.1 and its associated action items require a substantial increase in “the proportion of travel using modes other than driving alone.” This may be through
site connectivity improvements, expanded transit services, employee transit subsidies, and
first/last mile connection improvements. These General Plan Update policies and actions “would help reduce GHG emission generation from existing and future development.” (DEIR, p. 3.7-55.)
Under the BTP High designation, the higher FAR will enable the Vantage Project to intensify business and employment-generating uses on the Property. The Vantage Project would
provide office and lab space for life science research and development uses, employing
thousands of workers. Since the Property is located approximately three-quarters of a mile from the South San Francisco Caltrain Station, Healthpeak’s Project is primed to take advantage of its proximity to reliable transit service. Through Transportation Demand Management (“TDM”) measures, the Vantage Project will encourage and incentivize a significant share of future
employees to utilize other means of transportation than single-occupancy vehicles as contemplated in the General Plan Update. Healthpeak intends to implement TDM strategies reflected in the General Plan Update to contribute to efforts to promote fewer employees
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utilizing vehicle travel in the East of 101 area. This significant reduction in single-occupancy
vehicle travel will reduce corresponding GHG emissions consistent with the GP Update and recommended DEIR mitigation measures.
General Plan Update, page 184; DEIR Pages 3.14-17, -19 through 20, -25, -38 through -40 – The General Plan Update includes policies that would improve transportation
throughout the City and reduce reliance on single-occupancy vehicles. These policies dovetail with the policies intended to reduce GHG emissions and to encourage environmentally sensitive design policies. Healthpeak supports the new General Plan Update policies.
The General Plan Update Should Encourage Shared Parking Districts and Coordinate with TDM to Promote Parking for East of 101 Area BTP Land Uses.
General Plan Update, pages 130 & 200 – East of 101 Area Action SA-16.1.1 provides
that the City should introduce shared, district parking facilities to support visitors and employees in the East of 101 Area. Healthpeak supports the City’s proposed policy SA-16.1 to provide shared parking in this employment intensive area. Action MOB 3.3.1 provides that the City may incorporate parking maximums for office/R&D developments. Although the Vantage Project is
designed to comply with the 2 spaces per 1,000 square foot of office floor area in the Zoning
Code amendment, Healthpeak believes shared parking arrangement (per SA-16.1) will facilitate efforts to meet parking demand that exceeds 2.0 spaces per 1,000 square feet. Healthpeak is concerned without flexible parking requirements that it will be unable to meet parking demand for life sciences and other R&D activities within the East of 101 area, and specifically on Forbes
Boulevard. In this regard, the Zoning Code amendment proposes different parking ratios for
different uses. For example, a parking ratio of 2 spaces per 1,000 square feet of floor area applies to office uses1 which differs from the parking requirement for R&D facilities. R&D uses may provide parking at a rate of 1.5 spaces per 1,000 square feet of floor area. (Amended Zoning Code, Table 20.330.004.) Office uses may have their parking ratio adjusted “based on
anticipated employee density at the discretion of City.” (Amended Zoning Code, Table 20.330.004.) Healthpeak believes that BTP High uses should be allowed to have a minimum parking ratio rather than a maximum parking ratio of 2 spaces per 1,000 and to be able to rely on shared parking arrangements (pursuant to Policy LU-2.5) and other TDM measures to meet parking demand.
The City Should Equitably Distribute Transportation Improvement Costs on all
New Development and Not Disproportionately Allocate Such Costs Only to R&D
General Plan Update, page 186, Table 6, Proposed New Streets and Major Transportation Investments – The General Plan Update identifies the Roebling Road Extension across East Grand Avenue to proposed Railroad Avenue for two lanes, to improve
1 Applicable to office spaces over 10,000 square feet.
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internal connectivity in East of 101 Area. Healthpeak supports this road improvement, provided
that other new development on Roebling Road contribute to funding these local transportation improvements.
General Plan Update, page 194 – The General Plan Update notes that the City of South San Francisco funds transportation improvements through various sources. The primary source is
via a Transportation Impact Fee (Resolution 120-2020). At current fees, the General Plan buildout could generate approximately $1 billion upon full buildout of the General Plan. The City is also considering a community facilities district (CFD) within the East of 101 Area to augment transportation funding for the district. Preliminary funding plans for the CFD expect that it could generate approximately $160 to $290 million.
The General Plan Update does not clearly identify all of the transportation related impact fees that would be imposed on new development. For example, we understand that new R&D development in the East of 101 area may be subject to an “Overpass Contribution Fee” and the “East of 101 Traffic Impact Fee.” We understand the City is proposing that a Transportation Impact Fee or CFD assessment supersede the former East of 101 Impact Fee. It is one of the
most significant impact fees anticipated but appears to impact developers differently depending on the type of land use. For example, the Commercial Linkage Fee seems disproportionate to R&D developers with a $16.55/SF fee. We are concerned that this fee may further increase, and be disproportionately allocated to R&D uses.
Healthpeak is concerned that the City will apply new traffic impact fees or a CFD assessment, fairly and in a proportional and equitable manner for all new development in the East of 101 area, and requests that the City not disproportionately impact R&D uses with higher
traffic impact fees and assessments.
General Plan Update, page 200 – To support the City’s TDM policies, the General Plan Update proposes implementation of Action MOB-3.3.1, which calls for incorporating maximum parking requirements and other TDM requirements for new office/R&D projects. Given the diversity in uses in the East of 101 Area, we request that the City not disproportionately impose
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TDM requirements on office/R&D uses, but instead develop a policy that requires all uses in the
East of 101 Area to equitably reduce their impacts caused by vehicle transportation.
The Vantage Project would further the City’s sustainable and environmentally sensible design policies and policies designed to reduce GHG emissions.
General Plan Update, Policy SA-28.5; DEIR, Pages 3.5-11, -15, 3.7-40, and 3.7-55 –
Policy SA-28.5 requires new projects to implement “sustainable and environmentally sensitive design. Incorporate sustainable and environmentally sensitive design and equipment, energy conservation features, water conservation measures and drought-tolerant or equivalent landscaping, and sustainable stormwater management features.” South S.F. Climate Action Plan Action Item CL 1.1 additional requires “Minimum LEED™ certification or equivalent for new
buildings. Require all new municipal buildings and facilities to meet a minimum LEED™ silver standards.” Climate Protection Element Policy CP-5.1 provides an identical requirement for LEED certification. Implementation of this policy supports the City’s efforts to reduce its GHG emissions. These General Plan Update policies and actions “would help reduce GHG emission generation from existing and future development.” (DEIR, p. 3.7-55.)
The Vantage Project would be designed to achieve sustainable and environmentally sensitive design in accordance with the DEIR and General Plan Update. Under the existing development agreement, Healthpeak committed to pursue a Leadership in Energy and Environmental Design (“LEED”) Green Building Rating of “Silver” or higher. Such certifications are awarded only to buildings that “improve efficiency, lower carbon emissions
and create healthier places for people.” (LEED Rating System, How LEED Works.) Both phases
of the Vantage Project target achieving LEED Gold certification. The Vantage Project is consistent with the City’s building efficiency and climate action policies. Healthpeak supports the General Plan Update policies promoting sustainable development.
The General Plan Update EIR evaluates potential impacts associated with construction of a new fire station in the East of 101 Area.
Page 3.13-24. – In order to achieve its goal of densifying the East of 101 area, the General Plan Update proposes Policy SA-16.4, which requires the City to coordinate with the Fire Department “to ensure public services can accommodate growth” in the East of 101 area. (General Plan Update, p. 113.) Further, the General Plan Update recognizes the need for an
equitable distribution of public services throughout the City, including fire stations through Action Item ECS-6.1.1. (General Plan Update, p. 252.) Amendments to the Zoning Code would permit the “Public Safety Facilities” (which is defined to include fire protection services) in the BTP-H zone. (Amended Zoning Code, Table 20.100.00; § 20.620.020.) Thus, both the General Plan Update and proposed Zoning Code amendments allow for the development of a fire station
in the BTP High land use designation of the East of 101 area.
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Likewise, the General Plan Update EIR acknowledges that new fire stations may be
required to serve future development in South San Francisco. The DEIR states project-specific environmental impacts of constructing new or expanded fire protection facilities to support the growth anticipated under the proposed project cannot be determined at this time because the site-specific locations and designs of future new or expanded facilities are not known. Nonetheless,
the General Plan Update DEIR indicates that fire protection facilities are contemplated as part of the General Plan Update. (DEIR, p. 3.13-24.) The DEIR further explains that Table 2-7 assumes that “buildout under the proposed [General Plan] could result in approximately 68,367 square feet of nonresidential uses under the “Public” land use designation, which could include fire protection facilities.” (DEIR, p. 3.13-24.) The DEIR expects that “construction and operation of
future new or expanded fire protection facilities would have similar impacts as would construction and operation of other types of new development.” (DEIR, p. 3.13-24.) New fire facilities are addressed in the DEIR and are not expected to cause significant environmental impacts. (DEIR, p. 3.13-24.)
As you are aware, City representatives have advised Healthpeak of their interest in
locating a fire station on the former Gallo property (included in the Vantage Project). Healthpeak is designing its Vantage Project to include a new fire station on a portion of the Property, provided that Healthpeak’s proposed Vantage Project is approved in a manner consistent with the level of development Healthpeak considers under the BTP High designation.
DEIR, Pages 3.14-17, -19 through 20, -25, -38 through -40 - The DEIR recognizes that
Mitigation Measure (“MM”) TRANS-1, which requires the City to update and implement its TDM Ordinance, would help reduce total vehicle miles traveled (“VMT”) per employee for new developments. The General Plan Update and the DEIR provide for a number of new circulation improvements in the East of 101 Area to mitigate significant traffic impacts.
Conclusion
We believe that the DEIR thoroughly discussed the General Plan Update’s anticipated environmental impacts and appreciate the City’s consideration of the further clarifying information we have provided in support of the DEIR analysis. We look forward to reviewing the final product and working with the City to developing a project that meets the City’s vision for the East of 101 neighborhood.
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Healthpeak looks forward to continued cooperation with the City to achieve a mutually beneficial General Plan Update, and supports the City’s vision for the East of 101 area and the Vantage Property.
Regards,
BUCHALTER A Professional Corporation
By
Alicia Guerra
AG:nj
cc: Scott Bohn Natalia De Michele Heidi Taliaferro Devin Bertsch Michele Niaki
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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Individuals
Buchalter (BUCHALTER)
Response to BUTCHALTER-1
The commenter provides introductory remarks, noting that they represent Healthpeak in the
development of their property located at 420, 440, 466, and 494 Forbes Boulevard.
No response is required.
Response to BUCHALTER-2
The commenter supports the City’s efforts to allow for more intensive development east of U.S. 101
within the Business and Technology Park land use designation, which would allow Healthpeak to
develop the Vantage Project at the 2.0 floor area ratio (FAR) density it envisions.
The comment is noted; no further response is required.
Response to BUCHALTER-3
Healthpeak supports the proposed General Plan Update land use designation of Business Technology
Park (BTP) High on the property.
The comment is noted; no further response is required.
Response to BUCHALTER-4
The commenter requests the City to confirm that ancillary uses such as distribution facilities and
warehouses would be allowed in the BTP High designated areas.
The comment is noted, but it does not raise an environmental issue. The specifics regarding ancillary
uses are presented in the Zoning Code.
Response to BUCHALTER-5 The commenter notes that the Draft Program EIR assumes that future development under the BTP
High land use designation would generate approximately 40,656 jobs at 83 new jobs per acre.
Healthpeak, however, is concerned that the employment generation estimates identified in Table 2-6
in the Draft Program EIR may be low compared to the actual employment generated by life sciences
and R&D land uses based on the tenants that occupy Healthpeak’s campuses in the City. The
comment requests that the basis for the employment estimates presented in Table 2-6 be clarified
and further requests confirmation that the estimates correspond to the nature of higher intensity
life science uses contemplated by the BTP High designation.
The growth projections do not represent the full development capacity of the City. Rather, the
growth projections represent a reasonably foreseeable estimate of the potential amount of growth
within the General Plan 2040 time horizon. The BTP High designation ranges from 0.5 FAR up to 2.0
FAR with community benefits.
Employee generation for office and R&D uses are based on existing conditions in South San
Francisco. It is estimated that office and R&D uses generate one employee per 425 square feet. This
ratio was used to estimate future employees for office and R&D uses.
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Response to BUCHALTER-6
The commenter notes that the Vantage Project would provide office and lab space for life science
research and development uses, employing thousands of workers. Since the property is located
approximately 0.75-mile from the South San Francisco Caltrain Station, Healthpeak’s Project is
primed to take advantage of its proximity to reliable transit service. Through Transportation Demand
Management (TDM) measures, the Vantage Project would encourage and incentivize a significant
share of future employees to utilize other means of transportation than single-occupancy vehicles as
contemplated in the General Plan Update. Healthpeak intends to implement TDM strategies
reflected in the General Plan Update to contribute to efforts to promote fewer employees utilizing
vehicle travel in the East of 101 Area. This significant reduction in single-occupancy vehicle travel
would reduce corresponding greenhouse gas (GHG) emissions consistent with the General Plan
Update and recommended Draft Program EIR mitigation measures.
The comment is noted; individual projects will be reviewed for compliance and consistency with the
General Plan Update mitigation measures related to TDM, which would ensure less than significant
impacts. No further response is required.
Response to BUCHALTER-7
The commenter notes that they are in support of the proposed General Plan Update policies related
to reducing reliance on single-occupancy vehicles.
The comment is noted; no response is required.
Response to BUCHALTER-8
The commenter believes that BTP High uses should be allowed to have a minimum parking ratio
rather than a maximum parking ratio of two spaces per 1,000 and to be able to rely on shared
parking arrangements (pursuant to Policy LU-2.5) and other traffic demand measures to meet
parking demand.
The Draft Program EIR concludes that the buildout of the General Plan would result in significant and
unavoidable VMT impacts; General Plan policies and mitigation measures are aligned to mitigate
VMT impacts to the extent feasible.
Response to BUCHALTER-9
The commenter supports Healthpeak and the proposed expansion of the Roebling Road Extension to
two lanes, provided that other new development on Roebling Road contribute to funding these local
transportation improvements.
Funding for transportation improvements identified in the General Plan Update would come from a
combination of sources including but not limited to impact fees and/or as a condition of approval.
Response to BUCHALTER-10
The commenter discusses the proposed funding of transportation improvements and the need to
clarify how the fees would be assessed to future development projects. Healthpeak is concerned
that the City will apply new traffic impact fees or a Community Facilities District (CFD) assessment
fairly and in a proportional and equitable manner for all new development in the East of 101 Area,
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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and requests that the City not disproportionately impact R&D uses with higher traffic impact fees
and assessments.
The commenter also discusses Action MOB-3.3.1, which calls for incorporating maximum parking
requirements and other TDM requirements for new office/R&D projects. Given the diversity in uses
in the East of 101 Area, the commenter requests that the City not disproportionately impose TDM
requirement on office/R&D uses, but instead develop a policy that requires all uses in the East of 101
Area to equitably reduce their impacts caused by vehicle transportation.
Please review the Transportation Impact Fee Study. Funding for the implementation of the proposed
roadway improvement may be through Capital Improvement Program (CIP) or may be through
impact fees or conditions of approval for individual projects. New TDM policies would be applied to
all projects, so will more equitably apply requirements. Impact fees and TDM requirements are set
proportional to the transportation impacts generated by a particular land use type. Office and R&D
uses in South San Francisco generate the greatest transportation-related impacts and thus, have the
highest transportation-related impact fees and most aggressive TDM requirements. All new land use
types of a minimum size are responsible for their fair share of fees and TDM strategies.
Response to BUCHALTER-11
The commenter discusses sustainable and environmentally sensible design policies designed to
reduce GHG emissions, and notes that both phases of the Vantage Project target achieving
Leadership in Energy and Environmental Design (LEEDTM) Gold certification. The Vantage Project is
consistent with the City’s building efficiency and climate action policies. Healthpeak supports the
General Plan Update policies promoting sustainable development.
The comment is noted; no response is required.
Response to BUCHALTER-12
The commenter discusses public services and specifically the need for a new fire station in the East
of 101 Area. Healthpeak is designing its Vantage Project to include a new fire station on a portion of
the property, provided that Healthpeak’s proposed Vantage Project is approved in a manner
consistent with the level of development Healthpeak considers under the BTP High designation.
The comment is noted; no response is required.
Response to BUCHALTER-13
The commenter notes the efficacy of MM TRANS-1, which requires the City to update and
implement its TDM Ordinance, would help reduce total VMT per employee for new developments.
No response is required.
Response to BUCHALTER-14
The commenter provides concluding remarks and offers general support for the project. No
environmental issues are raised and no further response is required.
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Final EIR Errata
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SECTION 3: ERRATA
The following are revisions to the Draft Program Environmental Impact Report (Draft Program EIR)
for the General Plan Update, Zoning Code Amendments, and Climate Action Plan. These revisions are
minor modifications to clarify inadvertent typographical errors to the document, and/or to clarify
the discussion and do not change the analysis or significance of any of the environmental issue
conclusions within the Draft Program EIR. The revisions are listed by page number. All additions to
the text are underlined (underlined) and all deletions from the text are stricken (stricken).
3.1 - Changes in Response to Specific Comments
Executive Summary
Page ES-12
Table ES-1: Executive Summary Matrix. The following revision is made to ensure Table ES-1 accurately
reflects the analysis in the Air Quality discussion at pages 3.2-57–3.2-58 of the Draft Program EIR.
None of the conclusions in the Draft Program EIR were revised.
Impacts Mitigation Measures Level of Significance After Mitigation
Impact AIR-4: The proposed
project would not result in other
emissions (such as those leading
to odors) adversely affecting a substantial number of people.
MMs AIR-1a, AIR-1b, and TRANS-1. – Significant and unavoidable. N/A
Executive Summary
Page ES-14, ES-19
Table ES-1: Executive Summary Matrix. The following revision is made to clarify that Impact CUL-3
and Impact NOI-2 would not have any significant impacts. This revision accurately reflects the
analysis in the Draft Program EIR.
Impacts Mitigation Measures Level of Significance After Mitigation
Impact CUL-3: The proposed project
could would not disturb human
remains, including those interred
outside of formal cemeteries.
– N/A
Impacts Mitigation Measures Level of Significance After Mitigation
Impact NOI-2: The proposed project
could would not result in generation of
excessive groundborne vibration or
groundborne noise levels.
– N/A
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Errata Final EIR
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3.4 - Cultural Resources and Tribal Resources
Page 3.4-36 The following revision is made to clarify that Impact CUL-3 would not have any
significant impacts. This revision accurately reflects the analysis in the Draft Program EIR.
Human Remains
Impact CUL-3: The proposed project could would not disturb human remains, including those
interred outside of formal cemeteries.
3.6 - Geology, Soils, and Seismicity
Exhibit 3.6-4 and Exhibit 3.6-5 are revised to reflect a more recent data source from the California
Geological Survey. These revisions do not change any of the analysis or conclusions in the Draft
Program EIR. Please refer to Exhibit 3.6-4 and Exhibit 3.6-5 in Attachment A.
3.8 - Hazards and Hazardous Materials
Page 3.8-32 The following revisions correct an inadvertent typographical error and provide
clarification. None of the conclusions or analysis in the Draft Program EIR is changed with this
correction.
Proximity to Public Airport Safety Hazard
The General Plan Update contains policies and actions that minimize the exposure of people
residing or working in the Planning Area to a safety hazard or excessive noise because of
proximity to SFO. Policy SA-12.6 requires the City to encourage residential development in
the South Spruce area that are within the 65 decibel (db) CNEL contour, provided the interior
of a structure meets the standard indoor 45 db CNEL noise requirement. Action SA-12.6.1
requires the City to review the SFO ALUCP and, as needed, to update the City of South San
Francisco’s General Plan to be in conformance with land use compatibility standards in the
ALUCP. Action SA-12.6.1 further states that in the event that updates to the ALUCP allow
residential land uses on suitable sites on the El Camino Real corridor where residential is not
currently permitted, the City will update the General Plan to allow Urban Residential uses.
Lastly, Policy SA-21.3 requires the City to allow building heights in the East of 101 area to the
maximum limits permitted under Federal Aviation regulations. Section 3.11, Noise, identifies
additional policies and actions, as well as Mitigation Measure (MM) NOI-3 NOI-2, Airport
Noise Impact Reduction Plan, to address potential exposure to people residing or working in
the vicinity of SFO to excessive noise levels. There are no actions identified in the Climate
Action Plan that minimize the exposure of people residing or working in the Planning Area to
a safety hazard or excessive noise because of proximity to SFO.
As the City receives development applications for subsequent development under the
proposed project, those applications will be reviewed by the City of South San Francisco for
compliance with the policies and actions of the General Plan Update to reduce the exposure
of people residing or working in the City to a safety hazard or excessive noise because of
proximity to SFO. In addition, the City’s Municipal Code, which implements the City’s
General Plan would be reviewed when development applications are received, including
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Errata
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Chapter 15.08, California Building Code, and Chapter 8.32, Noise Regulations. Further,
Section 20.320.002 (Establishment of Lawful Nonconforming Uses, Structures and Lots)
(revised) ensures that no permit shall be granted that would allow the establishment or
creation of an airport hazard or permit a nonconforming structure or nonconforming use to
be made or become higher or become a greater hazard to air navigation. Lastly, in
accordance with the SFO ALUCP, the City would consult with the C/CAG and Federal Aviation
Administration when development applications for subsequent development under the
proposed project in the vicinity of SFO are received, including submitting applications to the
C/CAG for a determination of consistency with the SFO ALUCP.
Section 3.11 - Noise and Vibration
Page 3.11-35 The following revisions correct an inadvertent typographical error and clarify the
discussion. None of the conclusions or analysis in the Draft Program EIR is changed with this
correction.
Excessive Noise Levels from Airport Activity
These airport activity noise levels could exceed the City’s noise/land use compatibility
standards for certain land uses. The General Plan Update would allow for mixed-use
residential uses within the already established 65 dBA CNEL. Therefore, mitigation would be
required to reduce this potential impact. Airport activity noise can be mitigated at the
receiving land use using acoustic-rated wall and window assemblies. For example, a
combined wall assembly with a Sound Transmission Class (STC) rating of 30-STC can provide
an expected 30 dBA exterior to interior reduction in noise levels. With such an assembly,
exterior noise levels of 70 dBA CNEL would be reduced to approximately 40 dBA CNEL.
Therefore, with implementation of MM NOI-3 NOI-2, which requires preparation of a noise
study to identify appropriate design measures, where required, to reduce the potential
effect of airport activity noise, impacts generated by future development projects under the
proposed project would be reduced to less than significant with mitigation incorporated.
See also Section 3.8, Hazards and Hazardous Materials, which addresses the exposure of
people residing or working in the Planning Area to a safety hazard or excessive noise
because of proximity to SFO.
Page 3.11-37 The following revisions correct an inadvertent typographical error. None of the
conclusions or analysis in the Draft Program EIR is changed with this correction.
3.11.7–Cumulative Impacts
With regard to airport activity noise impacts, the combined effects of cumulative projects
(other cities) surrounding South San Francisco would not result in any additional special
events or sources of single-event noise in the form of aircraft flyover noise, and therefore,
would not result in changes in the 65 dBA CNEL airport noise contours and would not
increase airport noise impacts. However, future buildout cumulative conditions related to
airport activity related noise would be the same as that identified in Impact NOI-3 discussion
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above. The proposed project could still result in the introduction of land use development
that could be potentially incompatible with the noise environment in the vicinity of SFO.
However, as discussed in Impact NOI-3, implementation of MM NOI-3 NOI-2, Airport Noise
Impact Reduction Plan, would reduce airport activity noise impacts from implementation of
the proposed project to less than significant. Therefore, with implementation of MM NOI-3
NOI-2, airport activity noise levels from implementation of the proposed project would not
result in a cumulatively considerable contribution to this less than significant cumulative
impact. Therefore, the proposed project’s contribution to cumulative impacts would be less
than significant.
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR
FirstCarbon Solutions
Attachment A:
Updated Exhibits
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San Andreas Fault
San Francisco Bay
FerryTerminal
San Bruno Creek
C o l m a C r e e k AirportBlvdChestnut AveE Grand Ave
Grand Ave
Oyster Point Blvd
SAi
rport
Bl
v
d
H ills id e B lvd
ForbesBlvd
Gateway B lv d
DNAW aySisterCitiesBlvd
El
Ca
mino
R
e
al
J
uni
per
o Serr
a Bl
vd
W e s tb o roug hB lvd
C
allan
Blvd
Hickey Blvd
SpruceA v e
S Linden AveUtah AveSSpruceAveGellertBlvd
380
280
35
82
101
California
Golf Club
Unincorporated
AreaPacifica
San Bruno
Colma
Daly City
Brisbane
San Francisco
International
Airport
50000006 • 08/2022 | 3.6-4_Landslide_Potential.mxd
Exhibit 3.6-4Landslide Potential
Source: Raimi + Associates, July 2019. ESRI, U.S. Geological Survey (USGS). California Department of Conservation. California Geological Survey (CGS).
CITY OF SOUTH SAN FRANCISCOGENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLANENVIRONMENTAL IMPACT REPORT
3,000 0 3,0001,500
Feet
City of South San Francisco
Other City Boundaries
Jurisdictional Boundary
Sphere of Influence
BART
Caltrain
Highway
Transportation Features
Arterial
Local Street
CGS Landslide Zones
Zones of Required Investigation for
Earthquake-Induced Landslides
CGS Alquist Priolo Fault Zones & Traces
Accurately Located
Approximately Located
Approximately Located, Queried
Inferred
CGS Alquist Priolo Fault Zones
San Francisco Bay
FerryTerminal
San Bruno Creek
C o l m a C r e e k AirportBlvdChestnut AveE Grand Ave
Grand Ave
Oyster Point Blvd
SAi
rport
Bl
v
d
H ills id e B lvd
ForbesBlvd
Gateway B lv d
DNAW aySisterCitiesBlvd
El
Ca
mino
R
e
al
J
uni
per
o Serr
a Bl
vd
W e s tb o roug hB lvd
C
allan
Blvd
Hickey Blvd
SpruceA v e
S Linden AveUtah AveSSpruceAveGellertBlvd
380
280
35
82
101
California
Golf Club
Unincorporated
AreaPacifica
San Bruno
Colma
Daly City
Brisbane
San Francisco
International
Airport
50000006 • 08/2022 | 3.6-5_Liquefaction Potential.mxd
Exhibit 3.6-5Liquefaction Potential
Source: Raimi + Associates, July 2019. ESRI, U.S. Geological Survey (USGS). California Department of Conservation. California Geological Survey (CGS).
CITY OF SOUTH SAN FRANCISCOGENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLANENVIRONMENTAL IMPACT REPORT
3,000 0 3,0001,500
Feet
City of South San Francisco
Other City Boundaries
Jurisdictional Boundary
Sphere of Influence
BART
Caltrain
Highway
Transportation Features
Arterial
Local Street
CGS Liquefaction Zones
Zones of Required Investigation
for Liquefaction