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2.0 CO~~E~TS A~D RESPO~SES
2.1 FORMAT OF COMMENTS AND RESPONSES
This section presents responses to the comments that were received on the Draft
EIR during the review period. Responses are provided for those comments that
address the environmental effects of the proposed project. Responses are
generally not provided ("Comment acknowledged") to comments that state
opinions about the overall merit of the project or comments about the project
description, unless a specific environmental issue is raised within the context of
the specific comment. Those comments are most appropriately addressed in the
staff report forwarded to the decision makers for consideration at a public
hearing.
Four (4) comment letters were received concerning the Draft EIR for the
proposed project. The Planning Commission also provided comments during its
review of the Draft EIR on May 17, 2007. The comments received on the Draft
EIR have been grouped by agencies (A), the project applicant (P A), and Planning
Commission comments (PC) as listed below.
Agencies
Al California State Clearinghouse, June 11, 2007
A2 California Department of Transportation (Caltrans), June 7, 2007
A3 California Department of Transportation (Caltrans), June 19, 2007
Project Applicant
P Al Slough Estates USA, Inc., May 31, 2007
Planning Commission
PCl City of South San Francisco Planning Commission, May 17, 2007
Revisions to the Draft EIR that respond to comments on the Draft EIR are
presented in Section 3, Revisions to the Draft EIR.
Impact Sciences, Inc.
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494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0 Response to Comments
Al Terry Roberts
California State Clearinghouse
P.O. Box 997413
Sacramento, California 95899-7413
Al-l The agency's comment is acknowledged.
Impact Sciences, Inc.
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2.0 Response to Comments
A2 Timothy Sable
California Department of Transportation
P.O. Box 23660
Oakland, California 94623-0660
A2-1 The level of significance has been added to Table 2.0-1 to indicate that Impact 4.8-4
would be less than significant with implementation of Mitigation Measure 4.8-4.
A2-2 Impact 4.8-5 would remain significant and unavoidable with implementation of only
Mitigation Measure 4.8-5A.
A2-3 Figure 4.8-2 has been revised to include the southbound on-ramp from Airport
Boulevard. The revised figure is presented in Section 3 Revisions to the Draft EIR
of this document.
A2-4 Table 4.8-3 has been revised to correct the transposition of Signalized and
Unsignalized under the table heading" Average Total Delay per Vehicle (seconds)."
A2-5 The first paragraph on page 4.8-20 and Tables 4.8-6 and 4.8-10 have been revised to
reflect reduced on-ramp capacities in accordance with Caltrans' direction.
A2-6 The City contacted C/CAG and confirmed that ramp metering is a Caltrans project
scheduled for fiscal year 2009/2010, and is currently funded 100% by Caltrans. No
additional fair share funding is required for this scheduled, fully-funded future ramp
proj ect.
A2-7 Implementation of the proposed project would add traffic to Oyster Point and
Northbound (NB) 101 on-ramp intersection. As mitigation, the Draft EIR lists two
alternate improvements to address the impact at this location. The first
improvement, which involves widening the westbound Oyster Point Boulevard
approach to provide a second exclusive right turn lane, if implemented would
improve the intersection operations to an acceptable level. The second listed
improvement would bring the intersection back to, or just better than, the base case
operation. The City has determined that the first option will be implemented in
conjunction with the Genentech Master Plan Project. The project proponent would
pay the project's fair share of the cost of the improvement that is implemented at the
affected intersection and this fair share payment would adequately address the
project's impact at this location.
A2-8 It is the City's intent to update the East of Highway 101 Traffic Study to provide 2025
and 2030 conditions within the next two years. The update has been programmed
into the East of Highway 101 Traffic Impact Fee Program.
A2-9 The document referenced in the Draft EIR is the Genentech Master Environmental
Impact Report. The background growth rate of 0.5 percent (5.1 percent in total
between existing (2005) conditions and 2015) was applied to the existing traffic
volumes to account for the increase in through traffic along the freeway. Second, the
Impact Sciences, Inc.
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August 2007
2.0 Response to Comments
A2-10
vehicle trips associated with all the approved projects in the East of 101 area of South
San Francisco were assigned to the freeway. These included the recently approved
Home Depot, Lowe's, and Terrabay projects, plus anticipated future developments in
office and biotechnology space in the area. Future with Project traffic volumes were
developed by adding the Project vehicle trips to the Future without Project traffic
volumes.
Please refer to the response to comment A2-8.
Impact Sciences, Inc.
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494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0-4
2.0 Response to Comments
A3 Timothy Sable
California Department of Transportation
P.O. Box 23660
Oakland, California 94623-0660
A3-1 Please refer to the response to comment A2-2.
A3-2 All projects located within the East of 101 Area shall pay their "fair share" of Traffic
Impact Fees. "Fair share" is based on the amount of peak hour trips generated by the
development. The Traffic Impact Fees are collected to fund the improvements and
will be updated by the end of 2007.
Impact Sciences, Inc.
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494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0 Response to Comments
P Al Jonathon M. Bergschneider
Slough Estates USA, Inc.
400 Oyster Point Boulevard, Suite 409
South San Francisco, California 94080
PA1-1
PAl-2
PAl-3
PAl-4
PAl-5
PAl-6
PAl-7
PAl-8
The Bay Area Air Quality Management District has not provided a definition of the
term "sustained" in its CEQA Guidelines. This mitigation measure shall be
interpreted to mean that if winds exceed 25 miles per hour and there is a visible dust
cloud or plume at the edge of the project site, at that point grading and other earth
moving or disturbing activities shall be suspended.
The Erosion Control Plan shall comply with accepted Best Management Practices and
shall be designed by a registered civil engineer approved by the City to design
erosion control plans.
The monitoring well may be relocated, subject to approval of the San Mateo County
Health Services Agency, insofar as the relocated well allows the same level of
monitoring as the existing location. Text has been added to Mitigation Measure 4.4-5
to allow for the relocation of the monitoring well.
The comment correctly interprets Mitigation Measure 4.4-1' s intent and
implementation.
Mitigation Measure 4.5-2 has been revised to state that the water from the separator
will drain into the City's storm water drainage system. The mitigation measure is
intended for all parking areas (outdoor parking and parking garage) that will drain
to the storm water drainage system.
The language of Mitigation Measure 4.5-3 states that alternative drainage solutions
shall be installed "where feasible." The language of the measure is permissive and
does not mandate the construction and maintenance of a pond if not feasible.
The intent of Mitigation Measure 4.5-4 is to require the applicant to design a storm
water detention/retention system to retain excess storm water runoff beyond
pre development levels. Excess runoff conveyed from building rooftops via down-
sprouts may be infiltrated on site or retained in underground storm water vaults in
case rooftop retention is not possible. The text of Mitigation Measure 4.5-4 has been
revised to allow for the project to meet this requirement without necessarily
providing rooftop retention.
To calculate potential spills within truck dock sumps, the applicant's design engineer
is to use the maximum allowable truck capacity to be allowed on site to determine
the largest possible spill. Multiple trucks at a dock should be included in the
maximum capacity calculations. With regard to rainfall drainage issues, the capacity
Impact Sciences, Inc.
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August 2007
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2.0 Response to Comments
PAl-9
PA1-10
PAl-II
PAl-12
PAl-13
PAl-14
PAl-IS
PAl-16
of the sump is to be determined by utilizing a 10-year storm event with as-minute
time concentration to be pumped out.
Trip rates for new Genentech activities utilized in the Genentech Corporate Facilities
Master EIR were based upon trip generation surveys of existing activities on the
Genentech campus. Because specific uses for the 494 Forbes project are unknown at
this time, the most conservative trip rates for potential activities (i.e. for offices) were
utilized to provide a conservative analysis.
The applicant will be required to pay the project's fair share towards the cost of
constructing various traffic improvements at the time the Certificate of Use and
Occupancy for the buildings is issued.
The recommendation to widen the westbound Oyster Point intersection approach to
provide a second right turn lane rather than restriping and shifting the concrete
median was made because there is not enough median width or overall width of
Oyster Point Boulevard in order to complete this mitigation without widening. The
measure suggested in the Genentech EIR to restripe and narrow the median has been
rejected by City Public Works staff.
Widening the Dubuque Avenue leg of the intersection was suggested as an
alternative mitigation to providing a second westbound right turn lane on Oyster
Point Boulevard because it also reduces the project impact to a less than significant
level. Measures are not always recommended because they will be implemented on
an intersection leg accommodating project traffic, but rather because they achieve the
overall goal of reducing the project's impact to a less than significant level, possibly
for a lower cost than a mitigation on an intersection leg used by project traffic.
The applicant will be required to pay the project's fair share towards the cost of
constructing various traffic improvements at the time the Certificate of Use and
Occupancy for the buildings is issued.
Mitigation Measure 4.8-5A has been revised to delete the second citation for U.s. 101
Northbound Off-Ramp to East Grand Avenue/Executive Drive Intersection.
The improvements outlined in Mitigation Measure 4.8-7 shall be completed prior to
the issuance of a Certificate of Use and Occupancy for the buildings. Please note that
outbound movements from the project's northerly driveway have limited sight lines
to the north to see southbound Allerton Avenue traffic. Therefore, the City will
allow outbound movements from this driveway as right turns only
The improvements identified in Mitigation Measure 4.8-8 shall be completed as
outlined in the Draft EIR.
The project will be required to comply with all current and future recycled water
requirements. Currently, there is no delivery system for recycled water in place. The
applicant may install a recycled water infrastructure now to reduce future costs
associated with connections to any future systems.
Impact Sciences, Inc.
868-01
494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0-7
2.0 Response to Comments
Planning Commission Comments, May 17, 2007
The Planning Commission conducted a study session for the proposed project on May 17, 2007.
During the course of the Commission's session, a number of questions concerning the proposed
project were raised:
PC1-1
How long will it take to drive from the site to Highway 101 ?
PCl-2
How much traffic from East of u.s. 101 will make it into South San Francisco west of
u.S. 101?
PCl-3
Follow-up on/note the staggered work hours (per Mr. Monfreddini's comments).
PCl-4
Follow-up on/note ancillary services (per Mr. Monfreddini's comments).
Impact Sciences, Inc.
868-01
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494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0 Response to Comments
PCl City of South San Francisco Planning Commission
Meeting of May 17, 2007
PC1-1
PCl-2
Results are presented below of six travel time runs during the PM commute peak
hour between the project site and the Oyster Point interchange. Also presented are
projections of the increased travel times drivers would expect by 2015 for the same
trip with no new intersection mitigations and then with proposed mitigations.
Increased travel times were projected using the increases in average delay expected
at all intersections along the route (as presented in the EIR) along with some
additional travel time expected between intersections. The routing was Forbes
Boulevard/Eccles Avenue/Oyster Point Boulevard. From a distance standpoint, this is
a longer route than Forbes/Gull/Oyster Point. However, by observation, there is so
much Genentech traffic using Gull Road to Reach Oyster Point Boulevard during the
PM commute (which occasionally backs up much of the distance from Oyster Point
to Forbes), that the travel time by this route should be slower than the lightly used
(but longer) Eccles Avenue route.
Travel Time Surveys, Wednesday, May 30, 2007
Start Point: Forbes/ Atherton Intersection
End Point: Turning to U.S. 101 northbound on-ramp at Oyster
Point/Dubuque intersection
Route: Forbes/Eccles/Oyster Point
Run No.
1
2
3
4
5
6
Travel Time (in seconds)
255
245
260
255
350
310
Start Time
4:27 PM
4:39 PM
4:50 PM
5:03 PM
5:13 PM
5:29 PM
Average travel time =
Maximum travel time =
280 seconds (4 min 40 sec)
350 seconds (5 min 50 sec)
Travel time by 2015 with projected East of 101 development and no
mitigations:
Average travel time = 11 min 40 sec
Travel time by 2015 with projected East of 101 development and proposed
maximum intersection mitigations:
Average travel time = 9 min 30 sec
Based upon previous surveys of East of 101 employee traffic routings, about 3
percent of project traffic would be expected to travel to downtown South San
Francisco, with another 8 percent passing through the central area to/from Daly City
and western South San Francisco via Sister Cities Boulevard or East Grand Avenue.
Impact Sciences, Inc.
868-01
494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0-9
2.0 Response to Comments
PCl-3
PCl-4
The City of South San Francisco's Transportation Demand Management (TDM)
regulations are a requirement of the proposed project. The TDM plan addresses
staggered work hours as well as other methods to reduce AM and PM peak period
traffic.
Ancillary services, such as food service, are being provided within larger campus
type developments in the East of 101 area. These ancillary services are one of several
methods being used to reduce vehicle trips.
Impact Sciences, Inc.
868-01
494 Forbes Blvd. Office/R&D Project Final EIR
August 2007
2.0-10