HomeMy WebLinkAboutFinal Supplemental EIR Terrabay Specific Plan 10-01-1996 (2)
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FINAL SUPPLEMENTAL ENVIRONMENTAL
IMPACT REPORT FOR THE PROPOSED
TERRABA Y SPECIFIC PLAN AND
DEVELOPMENT AGREEMENT EXTENSION
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RESPONSES TO COMMENTS ON THE DRAFT SEIR
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SCH Number: 95092027
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Prepared by
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WAGSTAFF AND ASSOCIATES
Urban and Environmental Planners
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in association with
The Crane Transportation Group, Transportation Planners and Engineers
Thomas Reid Associates, Consulting Biologists
Harlan Tait Associates, Engineering Geologists
Donald Ballanti, Air Quality Consultant
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October 1996
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FINAL SUPPLEMENTAL ENVIRONMENTAL
IMPACT REPORT FOR THE PROPOSED
TERRABA Y SPECIFIC PLAN AND
DEVELOPMENT AGREEMENT EXTENSION
RESPONSES TO COMMENTS ON THE DRAFT SEIR
SCH Number: 95092027
Prepared by
WAGSTAFF AND ASSOCIATES
Urban and Environmental Planners
in association with
The Crane Transportation Group, Transportation Planners and Engineers
Thomas Reid Associates, Consulting Biologists
Harlan Tait Associates, Engineering Geologists
Donald Ballanti, Air Quality Consultant
October 1996
WP51 \548\FSEIR\ co VER.548
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City of South San Francisco
October 23, 1996
Final SEIR
Contents
Page i
CONTENTS
PaQe
I. INTRODUCTION.................................................. 1
II. RESPONSES TO COMMENTS ON THE DRAFT SEIR .. . . . . . . . . . . . . . . . . . . .. 3
A. List of Commenters ............................................. 4
B. Index to Comments (List of Public Hearing and Written Comments) .......... 5
C. Planning Commission Public Hearing Comments and Responses . . . . . . . . . .. 37
D. Written Comments and Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 51
III. REVISIONS TO THE DRAFT SEIR (ERRATA) .......................... 335
IV. APPENDICES
A. Program EIR Authority
B. SEIR Cumulative Development Assumptions
C. TDM-Based 12% Vehicular Trip Rate Reduction Assumptions
D. Supplemental Geotechnical Information
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September 17, 1996
Final SEIR
Contents
Page Ii
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October 23, 1996
Final SEIR
I. Introduction
Page 1
I. INTRODUCTION
In conformance with Section 15132 of the California Environmental Quality Act (CEQA)
Statutes and Guidelines (1992), the Final Supplemental Environmental Impact Report (FSEIR)
for the proposed Terrabay Specific Plan and Development Agreement Extension consists of
three volumes:
(1) the Draft SEIR, which was distributed for public review and comment on January 5, 1996;
(2) this Final SEIR document, which includes responses to all public and Lead Agency
comments received during the 75-day public review period on the Draft SEIR, plus a set of
Draft SEIR errata incorporating all revisions made to the Draft SEIR in response to these
comments; and
(3) a revised Final SEIR Transportation Section, which includes a revised version of the
Draft SEIR Transportation chapter that, because of the nature of the revisions, was distributed
("recirculated") for additional public review and comment on August 30, 1996, plus associated
responses to all comments received on the revised draft Transportation chapter during the
additional 45-day public review period.
A revised transportation analysis was performed in response to comments received during the
75-day public review period on the DSEIR. The revised traffic analysis identified one
unavoidable significant adverse impact--Le., an impact for which no mitigation is available--that
was not identified in the DSEIR. In conformance with Section 15088.5 of the CEQA
Guidelines,' the revised draft Transportation chapter of the SEIR was recirculated for a 45-day
public review and comment period on August 30, 1996.
Certification of the FSEIR by the city of South San Francisco must occur prior to any final
action on the proposed project.
'CEQA Guidelines section 15088.5 requires recirculation of significant new information added after
public distribution of the DSEIR including:
· a new significant environmental impact not considered in the DSEIR;
. a substantial increase in the severity of a DSEIR-identified environmental impact unless new
mitigation measures are adopted; or
· a new alternative or feasible mitigation measure considerably different from those previously
analyzed in the DSEIR which has not been adopted in the revised plan.
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Final SEIR
I. Introduction
Page 2
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Final SEIR
II. Responses to Comments on the Draft SEIR
Page 3
II. RESPONSES TO COMMENTS ON THE DRAFT SEIR
After completion of the DSEIR, the city of South San Francisco (Le., the Lead Agency) is
required under CEQA guidelines to consult with and obtain comments from other public
agencies having jurisdiction by law with respect to the project, and to provide the general
public with opportunities to comment on the DSEIR. The city is also required to respond in
writing to substantive environmental points raised in this DSEIR review and consultation
process.
The DSEIR was distributed for public review and comment on January 5, 1996. Before the
required 45-day public review period on the DSEIR ended, the South San Francisco City
Council extended the public review period by 30 days to March 20, 1996.
Comments on the DSEIR were received in the form of: (1) public testimony at a Planning
Commission public hearing on the DSEIR held on February 1, 1996; and (2) letters and
memoranda submitted to the city during the 75-day public review period. Nine people from
the community commented at the February 1, 1996 Planning Commission meeting. Thirty-
eight letters and memoranda were received.
This Response to Comments chapter includes the following subsections:
. A list of commenters (section II.A) including all public agencies, organizations and
individuals who commented during the DSEIR public review period.
· An index to comments (section 11.8), which lists the persons, organizations, and public
agencies commenting on the DSEIR; identifies the significant environmental points
addressed in their comments; and indicates by code where the written responses of the
Lead Agency (city) to these comments are provided in this chapter.
· A responses to public hearing comments section (section II.C), which includes
paraphrased minutes describing the comments made at the Planning Commission public
hearing held on February 1, 1996, followed by the responses of the Lead Agency.
. A responses to written comments section (section II.D), which includes copies of all
letters and memoranda received during the public review period pertaining to the
adequacy of the DSEIR, and the response of the Lead Agency to these comments.
Each pertinent written comment is coded in the right margin of the letter or memo.
Responses of the Lead Agency to the various coded comments follow each letter.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 4
A. LIST OF COMMENTERS
The public agencies, organizations, and individuals who commented on the DSEIR during the
public review period (January 5, 1996 to March 20, 1996) are listed below:
1. City of South San Francisco
Francisco (Frank) Vieira, Chair, Historic Preservation Commission (1.04, 29)
Planning Commissioner DeZordo (1.14)
Planning Commissioner Barnett (1.16)
Sgt. Ron Petrocchi, Police Department (2)
Fred Lagomarsino, Fire Marshal, Chief Building Official (3)
Richard Harmon, Senior Engineering Technician (5)
Dennis Chuck, Associate Civil Engineer (6)
Cheryl Mitchel Wade, Stormwater Program Coordinator (9)
Barry Nagel, Director; Parks, Recreation, and Community Services (12)
Arthur Wong, City Engineer (19)
Planning Commissioner John Lucchesi (21)
Eric McHuron, President, McHuron Geosciences, geologic consultant to city (22)
2. Other Public Aaencies
Janice Smith, Assistant Superintendent, Business Services, South San Francisco Unified
School District (1.01, 7)
Ken Aasen, Acting Regional Manager, Region 3, California Department of Fish and Game (4)
John Costas, Administrator, Planning and Environmental Affairs, San Francisco International
Airport (11)
Joel Medlin, Field Supervisor, U.S. Fish and Wildlife Service (13)
Philip Badal, District Branch Chief, California Department of Transportation (14, 23)
Antero Rivasplata, Chief, State Clearinghouse, Governor's Office of Planning and Research
(17)
Blair Allen, Associate Water Resources Control Engineer, California Regional Water Quality
Control Board, San Francisco Region (18)
Carole Nelson, Planning Director, City of Brisbane (30)
Samuel Herzberg, Planner III, Planning Division, County of San Mateo (35)
3. Oraanizations
Josephine Coffey, San Bruno Mountain Watch (1.02, 1.03, 20)
David Schooley, San Bruno Mountain Watch (1.06, 31)
Jacob Siggs, President, Verba Buena Chapter, California Native Plant Society (1.1, 10)
Farnum Alston, President, Mitigation Exchange Company (8)
Foster City Rod & Gun Club
Dana Dillworth, President, Bay Area Mountain Watch, inc. (26)
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Final SEIR
II. Responses to Comments on the Draft SEIR
Page 5
Ann Broadwell, attorney, Adams & Broadwell, representing the Building and Construction
Trades Council of San Mateo County (33)
Julia Bott, Chapter Director, Loma Prieta Chapter, Sierra Club (34)
4. Individuals
Edna Harks, 210 Eucalyptus Avenue, South San Francisco (1.05)
Fred Matthews, 843 Easton Avenue, San Bruno (1.08)
Jerome Irwin, 100 Alden Avenue, Colma (1.12, 15)
Jan Pont, 111 Belmont Avenue, South San Francisco (1.13, 36, 38)
Ken Mcintire (16)
Kent Lightfoot, Professor of Anthropology, University of California, Berkeley (27)
Perry Matlock, 300 Second Avenue, #5, South San Francisco (27)
Robert Carillo, P.O. Box 678, Daly City (28)
Don Shattuc, 907 W. Cardinal Drive, Sunnyvale (36,38)
Kathleen Dunning, 46 San Jose Avenue, Pacifica (37)
5. Applicant's Representative
Timothy Tosta, attorney, Baker & McKenzie (32)
B. INDEX TO COMMENTS (LIST OF PUBLIC HEARING AND WRITTEN COMMENTS)
Name/AQency
Response
Code 1 Issues and Concerns
Public Hearing Testimony--
February 1, 1996 Planning
Commission Meeting
Janice Smith, Assistant
Superintendent,
Business Services,
South San Francisco
Unified School District
1.01
The nearby school needs upgrading to current
building code standards.
Josephine Coffey, San
Bruno Mountain Watch
1.02
Concerned over shell mounds. How can impacts on
the shell mounds be determined if detailed traffic
mitigations for Phases II and III are not clear?
Detailed mitigations are needed for all phases.
'See sections C and D of this chapter for responses to comments which correspond to each of
these comment codes.
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1.03
Archaeological investigation performed for previous
owner was not considered in SEIR.
Frank Vieira, Chair,
Historic Preservation
Commission, City of
South San Francisco
1.04
Concerned over impacts on shell mounds. Historical
Commission should be informed when future phases
are reviewed.
Edna Harks, 210
Eucalyptus Avenue
1.05
The city's Historical Preservation Commission was
overlooked in the preparation and distribution of the
SEIR and should be coordinated with directly in the
future.
David Schooley, San 1.06 Concerned over HCP and preserving native species.
Bruno Mountain Watch
1.07 Indian shell mounds need to be preserved as a place
to learn about endangered species and American
Indian history.
Fred Matthews, 843 1.08 Retain as much open space as possible to provide a
Easton Avenue, San place for solace.
Bruno
1.09 Work out a compromise over the irreplaceable Indian
shell mounds.
1.10 Redevelop infill areas before developing sensitive
areas.
Jacob Siggs, President, 1.11 Concerned with HCP compliance, specifically failure
Verba Buena Chapter, of required revegetation and invasive weed problem.
California Native Plant
Society
Jerome Irwin, 100 Alden 1.12 SEIR has not adequately addressed Indian shell
Avenue, Colma mounds. It is important to innovatively preserve this
unique resource.
Jan Pont, 111 Belmont 1.13 Concerned with drainage, emergency vehicle access,
Avenue earthquakes, and geologic studies.
Commissioner DeZordo 1.14 Concerned with HCP compliance and failure of
required replanting and irrigation.
1.15 SEIR does not address trail access parking and
signage.
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II. Responses to Comments on the Draft SEIR
Page 7
Commissioner Barnett
1.16
Exactly how would drainage and soil erosion problems
be handled with normal maintenance?
Comments Received in Writing
2. Sgt. Ron Petrocchi, 2.01 Omission of needed police service mitigations from
South San Francisco the SEIR summary appears to suggest that there are
Police Department; no police service impacts that warrant mitigation. The
1-9-96 SEIR summary should note that mitigation needs
have not changed since the 1982 EIR and should
refer to the 1982 EIR.
2.02 No traffic analysis of the Hillside/Stonegate and
Hillside/Lincoln intersections was completed to
determine if current controls are adequate or if they
should change over the development of the project.
2.03 Concerned with the safety of crossings and pedestrian
routes to school for school age children, and the
potential impact on police services if adult crossing
guards will be needed.
2.04 The SEIR traffic analysis assumptions about timing of
Hickey Boulevard extension from Mission to Hillside
may be inadequate. The SEIR should consider
potential traffic impacts if Hickey is not extended when
planned.
2.05 The relative merits of recommended supplemental
traffic mitigation options should be described and a
preferred option identified.
2.06 The Police Department maintains that onsite security
is a condition of the specific plan and Phase I precise
plan and is required for all project phases. The
applicant disputes the requirement for onsite security
during non-construction hours and will not comply with
police request for continuous onsite security. This will
result in impacts on police services.
3. Fred Lagomarsino, Fire 3.01 Comment supports the SEIR fire protection services
Marshal/Chief Building supplemental impact and mitigation findings.
Official, City of South
San Francisco; 1-15-96
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4. Ken Aasen, Acting 4.01 Comment supports the SEIR vegetation and wildlife
Regional Manager, supplemental impact and mitigation findings.
Region 3, California
Department of Fish and
Game; 1-18-96
5. Richard Harmon, Senior 5.01 The mitigation measures in the SEIR summary
Engineering Technician, section should be numbered.
City of South San
Francisco; 1-22-96 5.02 Include figures to illustrate traffic mitigation
improvements.
5.03 SEIR should discuss Phases II and III noise impacts
from Sister Cities Boulevard, Bayshore Boulevard and
US 101 traffic.
5.04 The SEIR incorrectly states that the city will maintain
the linear park.
5.05 The city has considered and rejected formation of a
geologic hazards abatement district. Do the project
CC&Rs and homeowners association assessments
provide adequately for the needed ongoing
maintenance?
5.06 Project sponsor should file additional copies of the
Geotechnical Appendix reports.
6. Dennis Chuck, Associate 6.01 Potential impacts on the all-way stop control at the
Civil Engineer, City of Hillside/Lincoln intersection need to be evaluated.
South San Francisco;
1-25-96 6.02 Verify that the county will install a signal and not just
a stop sign at the planned Hickey/Hillside intersection.
7. Janice Smith, Assistant 7.01 SEIR recommended "voluntary" schools mitigation is
Superintendent, insufficient to reduce impacts to less than significant
Business Services, levels. City should condition project approval on an
South San Francisco agreement between the school district and developer
Unified School District; on measures to fully mitigate project school impacts.
1-29-96
7.02 Jefferson Union School District boundaries include all
of the project area served by the Brisbane School
District.
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8. Farnum Alston, 8.01 The SEIR does not evaluate a reasonable range of
President, Environmental alternatives, including alternatives with more open
Mitigation Exchange space in Phases II and III, and does not evaluate the
Company; 2-1-96 four 1982 EIR alternatives under current (1996)
conditions, as required by CEOA.
8.02 The "modified" No Project Alternative warrants serious
consideration given implications of the failure of
Phase I habitat restoration for Phases II and III, and
because it would avoid the significant unavoidable
adverse air quality impact identified for all three
phases.
8.03 The EI R has incorrectly identified the Concept Plan
Alternative as the "environmentally superior
alternative." The environmentally superior alternative
is the "modified" No Project Alternative.
8.04 Urges city to further consider continued Phase I
development, but manage Phases II and III areas as
open space and habitat. The Phases II and III areas
.have significant potential as environmental mitigation
banks.
9. Cheryl Mitchell Wade, 9.01 Comment suggests additional language to clarify
Stormwater Program recommended mitigation measure for Supplemental
Coordinator, City of Impact 0-3.
South San Francisco;
2-7-96
10. Jacob Siggs, President, 10.01 Given the failure of habitat restoration, references to
Verba Buena Chapter, "permanent" versus "temporary" disturbance are
California Native Plant misleading.
Society; 2-14-96
10.02 Project grading has caused invasive weeds to spread
into adjacent offsite wild areas. As mitigation for this
project impact, the Terrabay project should finance
their complete eradication.
10.03 The SEIR should evaluate impacts of human
habitation next to wild areas.
10.04 There is too much emphasis on plants which benefit
the endangered butterflies and not enough on the
ecosystem which supports those plants.
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11. John Costas,
Administrator, Planning
and Environmental
Affairs, San Francisco
International Airport;
2-15-96
12. Barry Nagel, Director,
Parks, Recreation and
Community Services,
City of South San
Francisco; 2-15-96
13. Joel Medlin, Field
Supervisor, U.S. Fish
and Wildlife Service;
2-15-96
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II. Responses to Comments on the Draft SEIR
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10.05
Although only a very small area of the Callippe
silverspot's habitat would be eliminated, there has
been no success in regeneration of its larval food
plant.
10.06
Ecologically, Terrabay has been severely damaging.
The HCP is loosely worded and permits violations in
spirit if not in letter. Lack of provision for monitoring
and evaluation is unfortunate.
11.01
Comment suggests additional language to clarify
recommended mitigation measure for Supplemental
Impact N-3.
12.01
The SEIR incorrectly states that the linear park will be
maintained by the city.
13.01
The SEIR should address whether the project is in
compliance with the HCP obligations. If it is not, the
city should withhold all development approvals.
13.02 The city should delay all approvals until successful
restoration is established and sufficient funding for its
future implementation is assured. The SEIR should
state success criteria, status, progress, funding and
future plans for restoration.
13.03 Comment notes changes in listing status of sensitive
plant species.
13.04 The SEI R must include information from recent site-
specific sensitive plant surveys.
13.05 The SEIR should include detailed mitigation requiring
complete botanical inventories during the pre-
construction phase for individual subsequent Phases
II and III projects and avoidance of any sensitive
plants found.
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City of South San Francisco
October 23, 1996
13.06
14. Phillip Badal, District 14.01
Branch Chief, California
Department of
Transportation; 2-16-~6
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 11
Pages from Appendix C appear to be missing and the
report is incorrectly referred to as Appendix E on p.
198.
Will the recommended mitigation requiring widening of
Bayshore Boulevard be feasible without affecting the
US 101 right-of-way or Phase III development? Is
there room for a four-lane southbound US 101 off-
ramp without traffic backing up onto the freeway? Will
Oyster Point Boulevard between Airport and Dubuque
be overloaded, even with signal coordination?
14.02 The note with two asterisks is missing from Table 10.
14.03 Has the two percent traffic volume increase
significance criterion for facilities that already exceed
unacceptable levels of service been approved by the
Congestion Management Agency?
14.04 The data in Table 15 should be depicted on a figure.
15. Jerome Irwin, 100 Alden 15.01
Avenue, Colma; 2-16-96
Comment refers to attached comment letters
supporting preservation of the Indian shell mounds as
the nucleus of an Ohlone Cultural Property Preserve.
15.02 Because of their great scientific significance, and their
legal and moral status as burial grounds, the Indian
shell mounds should be preserved.
15.03 The International Indian treaty Council is in support of
the proposal to preserve the Indian shell mounds as
the nucleus of an Ohlone Cultural Property Preserve.
15.04 The shell mounds are traditional cultural heritage of
indigenous peoples; the threat of development
represents lack of religious tolerance to traditional
spiritual practices. Accordingly, the city should delay
project approvals until such communities have been
informed, involved and have consented.
16. Ken Mcintire; 2-18-96
16.01
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Given the past revegetation failure, the city should
delay all approvals until successful vegetative
restoration is established and the continued future
successful implementation of the restoration program
is assured.
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City of South San Francisco II. Responses to Comments on the Draft SEIR
October 23. 1996 Page 12
17. Antero Rivasplata, Chief, 17.01 Transmittal of comments received from responding
State Clearinghouse, state agencies.
Governor's Office of
Planning and Research;
2-20-96
18. Blair Allen, Associate 18.01 In the absence of specific language describing the
Water Resources project and potential impacts, it appears that water
Control Engineer, quality concerns may not be adequately addressed.
California Regional
Water Quality Control 18.02 The comment explains NPDES program requirements.
Board, San Francisco
Bay Region; 8-10-95 18.03 The comment explains Regional Board certification
authority for wetland fill under Section 401 of the
Clean Water Act.
18.04 The comment recommends general stormwater
pollution prevention site planning concepts, as well as
construction period erosion and sediment control, and
chemical and waste management measures; and
post-construction measures.
19. Arthur Wong, City 19.01 The SEIR indicates that the Hillside/Chestnut
Engineer, City of South intersection will need to be signalized with Phase I in
San Francisco; 2-28-96 2010 to mitigate Supplemental Impact T-13.
However, the Heather Heights subdivision Initial Study
indicated that the intersection was already
experiencing unacceptable operation and required
signalization.
19.02 The SEIR identifies implementation of this mitigation
as the responsibility of the city and applicant. The
Terrabay development agreement identifies the cost
for this mitigation as the project sponsor's
responsibility at a prorated share; the cost is to be
shared with the applicant by other developers in the
area and not the city.
20. Josephine Coffey, San 20.01 Detailed information regarding the extent to which CA-
Bruno Mountain Watch; SMa-40 (Indian shell mound) will be disturbed should
2-29-96 be provided now so that appropriate measures to
preserve the site can be required. In the future, when
detailed environmental review is conducted for Phase
III, the city may have less authority and flexibility to
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20.02
21. John Lucchesi, Planning 21.01
Commissioner, City of
South San Francisco;
3-8-96
21.02
21.03
21.04
21.05
21.06
21.07
21.08
21.09
21.10
21.11
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require mitigation, and there may be fewer mitigation
options available.
The archaeological investigation performed for the
previous owner was not considered in SEIR.
Clarify conflicting statements that JUHSD boundaries
include all of project area and SSFUSD boundaries
include Terrabay Village, Terrabay Park and Terrabay
Pointe.
Clarify how project student generation has increased
by 30 percent while total project units have
decreased.
Will enrollment multipliers change in the future?
The project sponsor should fully mitigate project
school impacts.
What are walking distances from Phase II area to
Brisbane Elementary and Lipman Intermediate
School? What is the length of sidewalk needed along
Bayshore Boulevard?
Will Phases II and III require additional Supplemental
EIRs?
Clarify how mitigation (Le., capping) recommended for
CA-SMa-40 would not itself impact the resource.
Does use of the word "should" in mitigation measures
in Table 36 mean the mitigation is not mandatory?
Are mitigation measures in Table 36 accepted
practice for such archaeological sites?
Have mitigation measures been considered which
would preserve the area of CA-SMa-40 (Indian shell
mound) as a permanent study area and/or preserve
within which any grading or development is
prohibited?
Have preliminary grading and development plans for
Phase III been overlaid with accurate locations of the
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City of South San Francisco II. Responses to Comments on the Draft SEIR
October 23, 1996 Page 14
archaeological sites? What amounts of cutting/filling
are proposed in the areas of CA-SMa-40 and CA-
SMa-92?
22. Eric McHuron, President, 22.01 SEIR incorrectly identifies "continued downslope
McHuron Geosciences; movement" at Landslide D; there is no evidence that
geologic consultant to Landslide D is moving.
the city; 3-1-96
22.02 SEIR incorrectly refers to a "borrow" operation in
portions of Terrabay Commons and Terrabay Point.
Phase I grading generated a surplus of material.
22.03 Comments recommend minor wording changes for the
SEIR.
23. Phillip Badal, District 23.01 Will the recommended mitigation requiring widening of
Branch Chief, California Bayshore Boulevard be feasible without affecting the
Department of US 101 right-of-way or Phase III development? Is
Transportation; 3-6-96 there room for a four-lane southbound US 101 off-
ramp without traffic backing up onto the freeway? Will
(resubm ittal of letter #14) Oyster Point Boulevard between Airport and Dubuque
be overloaded even with signal coordination?
23.02 The note with two asterisks is missing from Table 10.
23.03 Has the two percent traffic volume increase
significance criterion for facilities that already exceed
unacceptable levels of service been approved by the
Congestion Management Agency?
23.04 The data in Table 15 should be depicted on a figure.
24. Foster City Rod & Gun 24.01 Phase I grading has resulted in significant sediment
Club; 3-13-96 discharge into, and caused siltation in, the Oyster
Point estuary. Grading for subsequent phases and
post-construction occupancy will result in additional
discharges of silt and pollutants to the estuary and
bay, affecting the bay ecosystem and fisheries. The
city should not proceed with this development.
25. Kent lightfoot, Professor 25.01 CA-SMa-40, one of only a few remaining large shell
of Anthropology, mounds, is a very significant and rare archaeological
University of California, site which may have been used over thousands of
Berkeley; 3-14-96 years and may contain the human remains of many
generations. Part of the site can be set aside for an
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innovative archaeological preserve in collaboration
with the proposed development.
26. Dana Dillworth, 26.01 The SEIR has not adequately considered drainage
President, Bay Area impacts and mitigations.
Mountain Watch, Inc.;
3-18-96 26.02 Known project-related siltation in the bay was not
analyzed in the SEIR. Without detailed measures or
proper implementation and enforcement, the SWPPP
cannot guarantee sufficient mitigation.
26.03 No reasonable mitigation has been identified for
geologic hazards of Landslide D.
26.04 Current state law requires that 20 percent of the units
in multi-family developments be affordable. The city
should require provision of this percentage or funding
of a housing pool.
26.05 The SEIR does not adequately assess cumulative
impacts.
26.06 References in the Initial Study checklist to the need to
"upgrade" or "reevaluate" mitigation measures make
the SEIR inadequate.
27. Perry Matlock, 300 27.01 The city should halt all new construction to prevent
Second Avenue #5; impacts to the Indian shell mounds and allow the
3-18-96 property to used for an Ohlone preserve.
28. Robert Carrillo, P.O. Box 28.01 Opposition to capping of CA-SMa-40 expressed. The
678, Daly City; 3-18-96 city should focus on this resource now rather than in
Phase III.
28.02 The archaeological investigation performed for
previous owner was not considered in the SEIR.
29. Francisco Vieira, Chair, 29.01 Commission is concerned about CA-SMa-40 (the
Historic Preservation Indian shell mound) and prefers that the site be left
Commission, City of undisturbed and accessible.
South San Francisco;
3-18-96 29.02 The archaeological investigation performed for the
previous owner was never presented as part of the
public record since that firm did not proceed with
development. This report could provide valuable
WPS1 \S48\FSEIRIF-II.548
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October 23, 1996
30. Carole Nelson, Planning 30.01
Director, City of
Brisbane; 3-19-96
30.02
30.03
30.04
30.05
30.06
31. David Schooley, Chair, 31.01
San Bruno Mountain
Watch; 3-19-96
32. Timothy Tosta, Baker & 32.01
McKenzie; 3-20-96
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 16
information regarding the adequacy of SEIR-proposed
mitigation. The city should delay any approvals until
all information regarding this site is available and
considered. The current owner should authorize
release of this report.
The SEIR cannot be certified as adequate until new
traffic analyses using counts from the now-open
Oyster Point Interchange are prepared.
The SEIR does not explain why the hook ramps are to
be installed in Phase III rather than before the Oyster
Point Interchange, as required by the Development
Agreement. Also, the Development Agreement
assigns full not "fair share," responsibility for the hook
ramps to the developer.
The assumptions from the East of 101 Area Plan
used for the SEIR traffic analysis are questionable
and result in an inaccurate assessment.
The proposed capping of CA-SMa-40 is inadequate
mitigation as it would not avoid damage to the
resource.
Potential impacts on CA-SMa-92 are unclear. No
mitigation is proposed in the SEIR; mitigation is left to
later studies.
Urges consideration of mitigations and alternatives
which, unlike proposed capping, would allow access.
The shell mound should be left undeveloped (except
for interpretive uses). Capping may destroy the site's
integrity and would not permit study.
Sunchase is proceeding with needed geotechnical
repairs and has completed some of the work
recommended as mitigations for small, localized
landslides, erosional gullies, "goat farm" cut slopes,
and Landslide D.
32.02 Sunchase response to comment 5.05 from Richard
Harmon regarding funding mechanism for on-going
geotechnical maintenance: Sunchase is completing
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Terrabay Project
City of South San Francisco
October 23. 1996
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Final SEIR
II. Responses to Comments on the Draft SEIR
Page 17
Master Homeowners Association Agreement which
specifies assessments and/or dues to fund
geotechnical repair and maintenance. A geologic
hazards abatement district (GHAD) is another option.
Sunchase has complied with all Regional Water
Quality Control Board (RWQCB) and city stormwater
regulations for Phase I and will continue to comply in
the future.
Sunchase has addressed issues pertaining to catch
basins and drainage ditches by cleaning and
monitoring and is addressing ongoing maintenance
funding and responsibility.
Sunchase response to comment 9.01 from Cheryl
Mitchell Wade: suggested changes to the SEIR
should be made; suggested change to refer to owner
rather than applicant is unnecessary.
Sunchase response to comment 18.02 from the
RWQCB regarding NPDES requirements: Sunchase
has obtained all required approvals for grading and
winterization work performed.
Sunchase response to generic comment 18.03 from
RWQCB regarding wetlands: Neither the original nor
the supplemental EIR identify wetland habitat on the
site.
Remediation of Phase I habitat restoration work has
been implemented in accordance with DSEIR-
recommended mitigation. Sunchase is committed to
monitoring for successful completion.
It is premature to conclude that the original habitat
restoration work, which was done in compliance with
the HCP, was unsuccessful as reclamation is a long-
term effort which will continue throughout the project.
Response to comment letters: all funding obligations
under the HCP have been met.
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II. Responses to Comments on the Draft SEIR
Page 18
Response to comment letters: the original habitat
restoration work was done in compliance with the
HCP and was subject to temporary problems due to
unfavorable weather. Sunchase has already
implemented the recommended remediation
mitigation.
Response to comment letters: all pages of the five-
page Pacific Open Space letter are included in the
DSEIR.
Response to comment letters: the HCP requires only
good faith implementation of an approved reclamati~n
plan implemented and monitored by the Plan
Operator.
Response to comment letters: the city is not
authorized under the HCP to delay approvals until
Phase I restoration is successfully established.
Response to comment letters: recommends that the
status of sensitive plant species be corrected in
DSEIR.
Response to comment letters: annual plant surveys
conducted by the Plan Operators have found no rare
plant species onsite; the Final SEIR should describe
the surveys.
Response to comment letters: the Final SEIR should
describe the floral plants located onsite.
Response to comment letters: plant surveys will be
conducted as part of project EIRs for future phase
precise plan approvals.
Response to comment letters: impact of human
habitation on wild areas was evaluated in original EIR
and does not require reevaluation in the supplemental
EIR.
Response to comment letters: the DSEIR describes
the onsite and surrounding ecosystem as well as
plants which benefit butterflies.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 19
Response to comment letters: the seed mix for the
restoration area contains butterfly larval food plants,
some of which have been successfully established.
Response to comment letters: regular monitoring, as
required by the HCP, has been and will continue to be
performed.
Response to comment letters: Sunchase has
prepared a grant deed to submit to the county for land
to be dedicated under the HCP and expects resolution
of outstanding issues in the near future.
Sunchase agrees that the primary mitigation for
school impacts is to pay the school impact fee and
that any payment beyond the maximum permitted by
law would be voluntary.
The DSEIR does not identify transportation to schools
as a significant impact and the recommended
mitigation requiring installation of a sidewalk along
Bayshore Boulevard is infeasible.
Onsite and off-site sewer systems inspections by
SunChase revealed no problems; resolution of this
issue and city acceptance of system dedication is
expected shortly.
Response to comment 7.01 from Janice Smith: It is
unclear whether the identified project-related costs to
the South San Francisco Unified School District
(SSFUSD) of $1.4 million is attributable entirely to the
project.
Re~ponse to comment 7.01 from Janice Smith: state
law establishes a maximum school impact fee and
limits the city from imposing additional mitigations
beyond the maximum school impact fees.
Response to comments from Sgt. Ron Petrocchi: the
homebuilder onsite provides onsite security during
evenings and weekends.
Response to comment 2.06 from Sgt. Ron Petrocchi:
Children will be able to safely walk to all SSFUSD
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Final SEIR
II. Responses to Comments on the Draft SEIR
Page 20
schools. Brisbane School District and Jefferson Union
High School District schools are too far for children to
walk.
Response to comment 2.01 from Sgt. Ron Petrocchi:
Since the DSEIR is a supplement to the original EIR,
only new mitigations were included in the summary.
Response to comment 11 .01 from John Costas: the
DSEIR noise mitigation measures address the
commentor's concerns.
Response to comment 5.03 from Richard Harmon:
the DSEIR noise analysis addresses impacts of Sister
Cities Boulevard, Bayshore Boulevard and US 101
traffic.
Response to comment 20.01 from Josephine Coffey:
analysis of CA-SMa-40 has not been deferred to
Phase III; the original EIR and DSEIR both address
the site's significance and recommend mitigation.
Moreover, since plans for Phase III have not yet been
established, impacts on the site cannot be
determined. Also, a Phase I II precise plan will be
subject to further environmental review and mayor
may not be approved by the city.
Response to comment 20.02 from Josephine Coffey:
the results of the referenced Caltrans survey should
be summarized in the DSEIR.
Response to comment 15.01 from Jerome Irwin: the
creation of an Ohlone Cultural Property Preserve is
not necessary to mitigate the potential significant
impact to a less than significant level and is
premature because there are no specific development
plans for Phase III.
Response to comment 15.02 from Jerome Irwin:
Preservation of the site recommended by the Society
for California Archaeology would be achieved by
proposed capping.
Response to comment 15.04 from Jerome Irwin:
Involvement of indigenous peoples recommended by
Terrabay Project
City of South San Francisco
October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 21
the International Indian Treaty Council is achieved by
DSEIR mitigation requiring consultation with a Native
American representative if human remains are
encountered during construction.
Response to comment 8.01 from Farnum Alston: the
original EIR evaluated a reasonable range of
alternatives; the DSEIR cannot reconsider the range
of alternatives because the project has not changed
and changes in circumstances do not affect the
original EIR alternatives analysis.
Response to comment 8.01 from Farnum Alston: the
original EIR and DSEIR considered two alternatives
that evaluate open space uses for Phases II and III:
the No Project Alternative and the Modified No Project
Alternative.
Response to comment 8.03 from Farnum Alston: the
DSEIR properly concludes that the impacts of the
alternatives have not changed from the original EIR.
Response to comment 8.03 from Farnum Alston: the
viability of and means to achieve implementation of
the Modified No Project Alternative is not discussed
because the alternative is infeasible.
Response to comments 8.02 and 8.04 from Farnum
Alston: since restoration has been conducted in
accordance with the HCP and is not required to be
fully established at this time, restoration difficulties do
not warrant reconsideration of development of Phases
II and III.
Response to comment 8.04 from Farnum Alston: if
phases II and III are not developed, the unavoidable
air quality impact would be avoided; however, since
no development of Phases II and III is infeasible, the
city may adopt a statement of overriding
considerations.
Response to comment 8.05 from Farnum Alston: the
DSEIR correctly identifies the Concept Plan
Alternative as the environmentally superior alternative
after the Modified No Project Alternative.
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October 23, 1996
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33. Ann Broadwell, Adams & 33.01
Broadwell; 3-20-96
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33.03
33.04
33.05
33.06
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 22
Response to comment 8.02 from Farnum Alston: the
DSEIR analyzes supplemental impacts of the Modified
No Project Alternative.
Response to comment 5.04 from Richard Harmon:
The DSEIR should be corrected to state that the
linear park will be maintained by the developer.
Response to comment 5.06 from Richard Harmon:
two copies of the three reports contained in the
geotechnical appendix will be filed with the city
Engineering Division.
The DSEIR does not state the proposed new
termination date of the Specific Plan or Development
Agreement.
The DSEIR must explain how the Development
Agreement was extended to 1997 given strict _
limitations on the duration of development agreements
contained in the South San Francisco Municipal Code.
The DSEIR must clarify which number of units (721 or
745) will be approved by proposed termination date
extension.
The DSEIR is not based on current, meaningful
information. The Oyster Point Interchange was in
service before the DSEIR was circulated. The DSEIR
traffic analysis must be revised to reflect new traffic
information for recommended mitigations to be
meaningful.
The map on DSEIR p. 67 "Existing Land Uses" does
not show land uses; land uses should be shown.
The DSEIR states that, where a facility already
operates at LOS F, a significant impact will not occur
unless traffic increases by at least 2 percent. The
courts have held this approach to be invalid because
the greater the overall problem, the less significant the
project's contribution. Instead, the DSEIR should
consider any contribution to a facility already at LOS F
to be a significant impact and mitigate.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 23
The DSEIR does not provide any information about
the LOS for the US 101 southbound off-ramp to
Bayshore Boulevard. If the off-ramp backs up to the
freeway mainline, that should be a significant impact.
The DSEIR should indicate that implementation of the
project itself, not just of mitigation measures, requires
approval from the city of Brisbane.
The DSEIR recommends that each project phase
provide a "fair share" contribution toward improvement
of the US 101 southbound off-ramp to Bayshore
Boulevard. However, the Development Agreement
assigns the Terrabay developer complete
responsibility for the "hook" ramps.
The DSEIR should require substitution of another
measure to mitigate Terrabay traffic impacts if other
projects are not available to share the cost of
expensive proposed mitigations.
The DSEIR must discuss the feasibility of traffic
mitigations (e.g., the flyover ramp) to provide for an
informed the decision on which measure to impose.
The DSEIR does not provide a summary of
projections contained in the planning documents on
which traffic projections are based so that it is
impossible to determine whether the traffic analysis
meets CEQA requirements for which projects are to
be considered in cumulative impact assessments.
The DSEIR should consider landslides and erosional
gullies as significant impacts, recommend mitigations,
and evaluate the feasibility of requiring homeowners
to pay for geotechnical repair and maintenance.
The DSEIR recommends a future study and required
implementation of any recommended mitigation
measures as mitigation for catchment basin/drainage
system failures. Since there is no assurance that this
impact can be mitigated, investigation and
consideration of mitigation cannot be deferred to the
future.
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Final SErR
II. Responses to Comments on the Draft SEIR
Page 24
The DSEIR should evaluate current water quality
impacts on San Francisco Bay and recommend
mitigations. The adequacy of the existing SWPPP to'
fully mitigate impacts should be evaluated.
While the original EIR, Initial Study and DSEIR
identified seasonal streams and riparian/vernal
vegetation, neither addressed potential impacts on
wetlands or riparian vegetation.
The DSEIR should indicate whether project activities
would affect watercourses or wetlands subject to U.S.
Army Corps of Engineers jurisdiction.
The DSEIR should indicate whether project activities
would require a streambed alteration agreement from
the California Department of Fish and Game.
The proposed Specific Plan and Development
Agreement extensions are legislative actions to which
the preemption of mitigation measures other than the
maximum permissible school impact fees identified in
the DSEIR does not apply. There is no assurance the
developer will agree to additional "voluntary" mitigation
or that the additional mitigation will reduce the impact
to less than significant. The city should require
additional mitigation or disapprove the project.
The DSEIR should evaluate school impacts beyond
1999-2000 (e.g., to 2010).
The potential harm to young students walking along
Bayshore Boulevard to Brisbane schools is a
significant impact requiring mitigation.
The derivation of project student generation and
calculation of impact fees should be explained.
Address additional impacts on high schools as
younger students grow.
Since there is no assurance that the identified
problem can be mitigated, the city should require
repair of the onsite and offsite sewer system before
any further work on the project.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 25
The DSEIR should indicate whether the project site
has been annexed to the California Water Service
Company service area.
The city Noise Element requires that a "development
proposal" include a noise analysis, and the current
Specific Plan and DSEIR do not.
The DSEIR presents 1990 information from the Noise
Element as if it were current. Current information
should be provided.
The DSEIR should measure current noise, and
estimate future noise using traffic projections. The
project proponent should submit a current noise
analysis prior to project approval, as required by the
Noise Element, and the analysis should be included in
the DSEIR.
Rather than simply recommending a future study, the
DSEIR should contain an analysis of airport noise and
recommend mitigation.
The DSEIR should discuss consistency with the 1994
Clean Air Plan.
The DSEIR should evaluate air quality impacts using
the BAAQMD proposed new standard of significance
for NOx.
The DSEIR should consider construction emission
control measures contained in the BAAQMD CEQA
Guidelines.
The DSEIR does not appear to consider cumulative
impacts on air quality.
The DSEIR should consider additional TSM measures
to reduce the project's impacts on air quality, such as
CalTrain station improvements or those listed in the
1994 Clean Air Plan.
There is no mention in the DSEIR (other than
potential future consultation as mitigation) that the
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 26
Native American Heritage Commission was consulted;
consultation should occur prior to project approval.
It is questionable whether capping of CA-SMa-40
constitutes required "avoidance" per CEQA Appendix
K, given the original EIR finding that it would
"unavoidably create some direct impact."
A definitive determination of the boundaries and
significance of CA-SMa-92 should occur prior to
project approval so that adequate mitigation can be
identified.
The DSEIR should address potential impacts on CA-
SMa-234 and needed mitigations.
Given the high potential for previously undiscovered
Native American sites, the site should be evaluated
for archaeological resources prior to project approval.
Mitigation measures for cultural resources should be
sufficiently detailed that funding guarantees can be
obtained per CEQA Guidelines Appendix K.
If any resources are eligible for National Register
listing, and a federal permit or state permit pursuant to
federal authority is required, National Historic
Preservation Act (NHPA) review would be triggered.
The DSEIR should discuss the need for additional or
amended federal permits and potential NHPA review.
The DSEIR should address impacts of proceeding
with a new specific plan with either a new
development agreement or no development
agreement.
The DSEIR should address project consistency with
the 1994 Clean Air Plan.
The DSEIR evaluation of consistency with adopted
plans should address the city Noise Element.
The city may not approve the project without first
finding that it complies with the HCP.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 27
The DSEIR should clarify whether the required offer of
dedication of open space required by the HCP has
already been made. Project approval cannot occur
until after such offer.
The DSEIR should confirm whether the required HCP
funding covenants have been recorded for Phase I.
The DSEIR should discuss whether HCP-required
covenants for fire buffers and restricting pesticide
were recorded with the final subdivision maps for
Phase I.
The DSEIR should discuss whether the Landslide D
repair scheme will require an HCP boundary
adjustment and amendment.
The DSEIR does not discuss the status of HCP
funding obligations.
The DSEIR states that the county will make HCP
compliance determinations. However, the city must
make an HCP compliance determination for any
discretionary action.
The DSEIR should indicate whether the new
landowner has signed the Agreement with Respect to
the San Bruno Mountain Area Habitat Conservation
Plan.
The DSEIR should explain the status of the 1989
precise plan and the need, if any, for a ne~ Phase I
precise plan.
The DSEIR should explain the status of the grading
permit.
The DSEIR should explain whether the Development
Agreement will be amended such that current city
rules and policies rather than rules and policies in
effect at the time the Agreement took effect shall
govern the project and, if not, the environmental
impacts.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 28
The DSEIR should state whether Development
Agreement provisions pertaining to financial
guarantees and agreements for participation in onsite
and offsite improvements have been complied with
prior to final map recordation.
The DSEIR should discuss whether the "hook" ramps
are still a feasible mitigation, whether there has been
agreement regarding project participation in the "hook"
ramp improvements, and whether the project sponsor
has initiated action to expedite the "hook" ramp
improvements and has prepared plans and obtained
Caltrans approval, as required by the Development
Agreement.
The DSEIR should discuss project compliance with
the Specific Plan and city municipal code requirement
to implement geotechnical recommendations prior to
issuance of building permits.
The DSEIR must state whether siltation and
catchment basins must be installed on the upper
slopes of San Bruno Mountain and whether county
consent and a Section 10(a) permit amendment have
been obtained.
The DSEIR does not discuss whether winterization
programs have been implemented each year, as
required by the Specific Plan.
The DSEIR should discuss the impacts of the failure
of the project drainage system to operate properly.
The project should not be approved nor building
permits issued until the system is operating properly.
The DSEIR should discuss whether the precise
grading and construction schedule, including needed
traffic improvements, required by the Specific Plan
was approved and, if so, describe the approved
schedules and address project compliance with the
schedules.
The DSEIR should state whether a Transportation
Systems Management (TSM) Plan has been
approved, as required by the Specific Plan.
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October 23, 1996
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II. Responses to Comments on the Draft SEIR
Page 29
The DSEIR should state whether the "hook" ramps
provisions of the Specific Plan have been complied
with.
The DSEIR should state whether CC&Rs, including
those prohibiting parking or storage of recreational
vehicles and implementing TSM actions have been
executed.
The DSEIR states that continued surficial instability
would be addressed as "part of the overall project
maintenance program." Continued surficial instability
will be chronic, requiring significant maintenance
beyond what would be considered routine.
Maintenance plans should be developed to ensure
proper functioning of slope drainage facilities under
continued surficial instability.
Given that the DSEIR states that roads will serve as
"buffer zones" for landslide debris, emergency access
should be addressed and mitigated.
The steep colluvial cuts appear to have been
inappropriately designed and should be analyzed
using appropriate colluvium strength parameters.
The DSEI R does not discuss the use of a geologic
hazards abatement district (GHAD) despite abundant
documentation in the project files. A GHAD would be
the most successful means of addressing long-term
maintenance.
The proposed Landslide D repair scheme is based on
an estimate of the depth of active landsliding in the
lower portion of the slope that may be too shallow and
contradicts earlier findings. This estimate should be
confirmed prior to the repair work and the repair
scheme revised as necessary.
The proposed Landslide D repair scheme would
create a 180-foot-high, unbenched 3:1 slope. This
slope should incorporate intermediate benches.
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II. Responses to Comments on the Draft SEIR
Page 30
"Buried valleys" and deep landslides encountered in
Phase I have caused significant site grading
problems. Mitigation should be developed, and slope
stability reanalyzed using colluvial soil properties, to
address potential slope stability and excessive or
differential settlement problems from similar deposits
in grading for future phases.
The DSEIR has not adequately addressed potential
adverse effects of differential fill movement on
buildings, utilities and roadways.
The debris basins may be undersized and should be
reevaluated to ensure they meet current state-of-the-
art technology and include a reasonable level of
conservatism.
The DSEIR should address monitoring, cleaning and
maintenance of debris basins.
The DSEIR should address installation of debris
basins as mitigation for future project phases.
The mitigation recommended in the DSEIR may not
adequately address long-term stability in disturbed
areas along the margins of the proposed development
within lands to be dedicated to San Mateo County.
The DSEIR understates project traffic generation from
restaurants and, in turn, project impacts and mitigation
needs, and should be revised using appropriate
generation factors.
The 2000 and 2010 base case traffic volume
projections were not prepared in accordance with
either of the methodologies described in the CEQA
Guidelines (e.g., land use projections from adopted
planning documents), making it impossible to
determine the relationship of the analysis to likely
development and, therefore, its validity.
The DSEIR traffic analysis uses 1993 information as
"existing conditions" even though conditions have
changed substantially (e.g., opening of the Oyster
Point Interchange).
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II. Responses to Comments on the Draft SEIR
Page 31
The DSEIR year 2000 baseline LOS projections,
which relied on 1993 data, indicate significantly better
conditions that the observable existing conditions at
some locations, completely undermining the credibility
of the analysis.
The DSEIR should recompute year 2010 impacts and
mitigation needs at the US 101 ramps/Dubuque
Avenue intersection and the Bayshore Boulevard/
Airport Boulevard/Sister Cities Boulevard/Oyster Point
Boulevard intersection rather than assuming an
impossible concentration of traffic at the new US 101
southbound ramps at the project's commercial access.
The DSEIR presents no indication that recommended
mitigation for project impacts on US 101 freeway
mainline operation (Le., TSM) would reduce the
impact to a less than significant level. This is
probably an unavoidable significant adverse impact.
The East of 101 Area Plan EIR assumed a 20-25
percent reduction in trip generation due to the
BAAQMD employer-based trip reduction rule, which
has since been invalidated by state legislative action.
The DSEIR traffic analysis should be recomputed to
adjust for this invalidation.
The five percent reduction in trip generation due to
transit ridership assumed in the East of 101 Area Plan
EIR traffic forecasts is unreasonable. The DSEIR
traffic analysis should be recomputed using adjusted
traffic forecasts.
The DSEIR cumulative traffic analysis used 2010 as a
base year rather than the stated project buildout year
of 2004, which understates project impacts, mitigation
needs and needed "fair share" contributions.
The intersection improvements mitigation option for
impacts at the Airport Boulevard-Bayshore Boulevard/
Sister Cities Boulevard/Oyster Point Boulevard
intersection is infeasible; the DSEIR should identify
the flyover option as the sole feasible mitigation.
Terrabay Project
City of South San Francisco
October 23, 1996
34. Julia Bott, Chapter
Director, Loma Prieta
Chapter, Sierra Club;
3-20-96
35. SamueIHe~be~,
Planner III, Planning
Division, County of San
Mateo; 3-20-96
WP51 \548 \FSEIR\F-II. S48
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 32
33.88
The triple left-turn lane proposed at the project
commercial access/Bayshore Boulevard intersection
may also be infeasible; its feasibility should be
demonstrated in the DSEIR (using scale engineering
concept drawings).
33.89
The DSEIR states that, where a facility already
operates at LOS F, a significant impact will not occur
unless traffic increases by at least 2 percent. The
DSEIR should consider a more stringent significance
criterion.
34.01
All remedial habitat restoration should be completed in
a timely manner and be evaluated according to
criteria, carefully monitored and reported on. Bonds
should be posted to ensure satisfactory completion.
34.02 The city should only approve Phases I and II. Phase
III is best suited and should be considered for public
ownership. The market may not support Phase III
commercial development. Approval of the
development agreement extension for Phase III could
lock in unneeded development and foreclose future
options for mitigation or alternative uses.
35.01
Required dedication of HCP Administrative Parcel 2-
04-02 will not be accepted until landslide, erosion and
restored habitat problems are resolved and the
county's standards for revegetation are complied with.
35.02 Concur that the recommended Landslide D repair
Alternative #4 is an appropriate fix.
35.03 The county will use the city's SEIR for environmental
review and will consider issuance of a grading permit
after SEIR certification and project approval.
35.04 Landslide monitoring instrumentation should remain in
place to monitor future conditions.
35.05 The Terrabay Village CC&Rs appear to address the
obligations of the homeowners association for slope
maintenance and landslide repair discussed in the
SEIR. The SEIR should also recognize the possible
use of a geologic hazards abatement district.
T errabay Project
City of South San Francisco
October 23, 1996
36. Jan Pont, 111 Belmont 36.01
Avenue and Don
Shattuc, 907 W. Cardinal
Drive, Sunnyvale;
3-20-96 36.02
36.03
37. Kathleen Dunning, 46
San Jose Avenue,
Pacifica; 3-18-96
37.01
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 33
Should the Planning Commission recommend
approval, request access to the property prior to City
Council meeting to consider recommendation.
Poor notice and availability of the SEIR for review and
comment. Most people assume that the project is
already approved.
Request an additional extension of the public
comment period.
Concerned about potential impacts to site CA-SMa-40
and lack of adequate mitigation.
37.02 Archaeological investigation performed for previous
owner was not considered in SEIR.
38. Jan Pont, 111 Belmont 38.01
Avenue and Don
Shattuc, 907 W. Cardinal
Drive, Sunnyvale; 4-7-96 38.02
38.03
38.04
38.05
38.06
38.07
38.08
WP51 \548\FSEIR\F-II.S48
The city must ensure proper implementation of all
mitigation.
The no project alternative (buildout of a part of Phase
I and no Phase II or III) is the best way to mitigate
identified impacts.
The DSEIR should analyze the significant cost to the
city of all the mitigation measures for which the city
will be responsible.
Does the project represent the best use of this
valuable open space area; has the city provided
sufficient parks/open space for its growing population?
The project site is subject to major earthquake
damage and geotechnical hazards.
Water that drains from San Bruno Mountain should be
preserved and used rather than merely discharged.
The DSEIR underestimates the volume of traffic
generated by the project.
The DSEIR traffic analysis does not consider the large
volume of truck traffic that causes congestion at the
Oyster Point interchange and in the project vicinity.
T errabay Project
City of South San Francisco
October 23. 1996
WP51 \548 IFSEIR\ F-II. 548
38.09
38.10
38.11
38.12
38.13
38.14
38.15
38.16
38.17
38.18
38.19
38.20
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 34
Project improvements and residents are subject to
ongoing problems and significant hazards from
landslides and continued slope instability.
The significant cost of ongoing maintenance of
erosion and sedimentation control facilities should be
borne by the applicant and/or city rather than the
project homeowners association.
The spring and wetlands that existed in the "Goat
Farm" area before Phase I grading may cause
significant future geotechnical problems.
The margin of safety provided by the Landslide D
repair scheme is too small.
Compaction that occurs in dry soil will be different in
wet soil and may cause problems during very wet
winters.
.
The DSEIR must consider potential earthquake
damage of the magnitude that occurred during the
1989 Loma Prieta earthquake.
Will project residents be able to obtain affordable
earthquake insurance?
Has the project storm drain system been inspected,
repaired and determined adequate to handle the high
runoff volume from this vast watershed?
The project will exacerbate the existing sedimentation
and pollution problem in San Francisco Bay.
Water that drains from San Bruno Mountain should be
preserved and used rather than merely discharged.
Native plants and grasses should be relocated to the
proposed botanical garden before grading for Phases
II and III.
No wetlands delineation was done for Phase I and
Phase I grading destroyed wetlands on the site. A
wetland delineation must be performed before grading
for Phases II and III.
T errabay Project
City of South San Francisco
October 23, 1996
WP51 \548\FSEIR\F-II.S48
38.21
38.22
38.23
38.24
38.25
38.26
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 35
Has project water consumption been analyzed?
Traffic, aircraft and construction noise will impact
project residents.
Phase I grading and construction period dust
emissions was a significant nuisance and health
concern for surrounding residents.
The identified significant unavoidable regional air
quality impact is just one reason why the no project
alternative should be adopted.
The Native American shell mound in the Phase III
portion of the project site should be preserved.
The no project alternative should be adopted and a
terraced lakes park should be developed on the site.
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 36
WP51 \5481FSEIR\F-II.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 37
C. PLANNING COMMISSION PUBLIC HEARING
COMMENTS AND RESPONSES
The minutes of the February 1, 1996 Planning Commission public
hearing are included in the following section, immediately followed by
the Lead Agency's response to substantive comments therein pertaining
to the adequacy of the DSEIR. Comments and responses are
correlated by code numbers added to the margins of the minutes.
WP51 \548\FSEJR\F-II.S48
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 38
WP51 \S48\FSEIR\F-II.S48
1
PUBLIC HEARING - AGENDA ITEMS
Terrabay Development - Hillside Boulevard, SunChase G.A. California I, Inc.
SP-96-012, Draft Supplemental EIR
Draft Supplemental Environmental Impact Report for Terrabay Specific Plan and Development Agreement
Exte~ion.
Vice-Chairman Romero opened the public hearing.
Project Planner, Lida Budko, presemed the staffrepon. She summarized the project history since the adoption
by City Council of the Specific Plan in December 1982, after certification of the project EIR. Ms. Budka
described the project and its three phases. She stated that the site for Phase I has been graded and most of the
i.nfrasaucwre improvements have been constrUcted, including a new fire station and Sister Cities Boulevard.
She ooted that the current developers, SunChase, are requesting a 10-year extension of the specific plan and
development agreemem to complete implementation of the approved plan. The City decided to update the EIR
before taking any action, and John Wagstaff & Associates were retained to prepare the Draft Supplemental
EIR (DSEIR). She ooted that the purpose of this meeting was to receive comments on the Draft Supplemental
EIR. At the cooclusion of the public bearing, and after the public review period ends, on February 18, 1996,
all verbal and wrinen comments received will be responded to and included in the Final EIR.
Applicants/Owner Representative:
Mr. Breen advised he was available for any
questions on this project, and introduced Mr.
Sweeney as Project Manager, also available for
questions from the Commission or the public.
Dennis Breen, SunChase, G.A.,
and
Jim Sweeney, Project Manager
Sterling Pacific Management Grp.
6001 No. 24th Street
Phoenix, AZ 85016
Draft Supplemental EIR Consultant:
Mr. Wagstaff reported on the scope of work
which was to prepare the environmental updates to
conform with current CEQA requirements. The
Specific Plan and Development Agreement
approvals are due to expire on February 14, 1997,
and the Developer is requesting a 10-year
extension. The DSEIR gives a detailed assessment
for Phase I where more information is available,
and h1cludes detailed mitigation. A broader
assessment is provided for Phases II & III as the
information is more conceptual for Phase II & m.
The 45-day review period on the DSEIR ends on
February 18, 1996.
John Wagstaff
Wagstaff and Associates
2512 Ninth Street, Suite 5
Berkeley, CA 94710
Page 2 of 9 Pages
PC Meeting of 211/96
Representing SSF Unified School District:
Janice Smith,
Assist. Supt. of School/Business Services
So. San Francisco Unified School District
400 "B" Street, So.San Francisco, CA
Speaking AJrclinst Terrabay DSEIR:
Josephine Coffey, SB Mtn Watch,
248 Dublin. San Francisco, CA
Speaking with Concern:
Frank Vieira, Chairman of the City's
Historical Preservation Commission
319 Spruce Avenue, SSF
Speaking with Concern:
Edna Harks, Past Chairperson of
Historical Preservation Commission
210 EucalyptuS Avenue, SSF
Ms. Smith submitted a lener dated January 29,1
1996. She mentioned that the ne3rby school is in
need of upgrades, and the State Architect is asking I at
for this school site be brought up to code.
-
Ms. Coffey spoke of the concern of Phase ill
Indian village sites, and noted Page 51 of the SEIR
states that there are goals to preserve the I 02
archeological site of the shell mounds. She noted .
that since the detail traffic mitigation for Phase II
and III are not clear, she is concerned of how the
City will know the impact on the shell mounds.
The City should ask for detail mitigation measures
for all phases of the development. The -
archeological investigation of the shell mounds 't
done for the previous owner, at the request of .O~
CaITrans, was not used in this repon and should
be made available.
-
-
Mr. Vieira expressed his concern on the
sensitivity that the plaMing of the commercial
phase, in regards to the shell mounds and the
increased traffic that will be needed to , . ~
accommodate the other phases of the project. As
a representative of the Historical Commission he
would like to be kept informed when future phases
becomes more detailed.
-
-
Ms. Harks noted the Historical Preservation
Commission was given the task of protecting
historic and archeological remains in this City and ,. O~
they were overlooked in these studies; they will be
sending in their written comments. She would
appreciate repons being sent directly to the
Commission; she had no comment at this time.
--J
Page 3 of 9 Pages
PC Meeting of 2/1/96
Speaking Against Terrabay DSEIR:
David Schooley, SB Mtn Watch,
P. O. Box AG, Brisbane, CA 94005
Speaking Against Terrabav DSEIR:
Fred Matthews
843 Easton Ave, San Bruno, CA
Mr. Schooley has been concerned with
development of San Bruno Mountain and
Shearwater area for many years. His main
concern:
-
.
the Habitat Conservation Plan, feels this
development needs to be very concerned r.C-'
in preserving native animal and plant
species.
-'
-
.
the Indian shell mounds need to be
preserved, wants Commission to be
careful of the growth on San Bruno
Mountain along Paradise Valley and
around the frontage of Hwy 101.
l.07
.,<
.
that as a gift from the owners, the Indian
shell mounds, should be kept as a place
for people to learn of endangered species
and A verian Indian history.
.-::
-
Mr. Matthews noted:
-
.
He uses the mountain for a peaceful place, l nQ..
feels this mountain should stay as open .v(7
space as much as possible.
-
-
.
Compromise, with respect to the Indian , nIA
shell mounds, don't take something that . "/
you can't get back; and
-
-
.
South San Francisco needs to be proud
and take care of this area, there are owls
in the canyons and development far up , ., fI
into the mountain will destroy this natural
area. He asked the Commission 10
redevelop areas in the City before "you
tread on sensitive areas like these".
_.
Page 4 of9 Pages
PC Meeting of 2/1/96
-
Speaking with Concern:
Mr. Sigg noted they have seen the DSEIR, they
are concerned with the project's compliance with
the Habitat Conservation Plan for San Bruno
Mountain. Specifically with the wild flower area
that was a home for hawks. now it has become a
weed patch; weeds are expanding from the
Terrabay site onto San Bruno Mountain.
l.ll
Jake Sigg, President of the
Yerba Buena Chapter of the California
Native Plant Society
338 Ortega, San Francisco. CA
-
-
Speaking Against Terrabay DSEIR:
Mr. Irwin spoke against the Draft SEIR because it
has not fully addressed the Indian shell mounds.
He distributed information on the Indian shell
mounds and information on some of the last
known Yelamu-Amuctuc people who lived on the
mountain. He stressed the importance of
preserving this unique area for future generations
to enjoy just as he did as a child. He will have a
slide presentation at the meeting of February 18th
of what a developer did in Vancouver. B.C.,
building a mall around the burial grounds.
LIt
Jerome Irwin
100 Alden Avenue, Colma, CA
-
-
Speaking with Concern:
Ms. Pont expressed concern with seepage, catch
basins, parking facilities specially for emergency
vehicles, eanbquake, and szeolosrical studies. She (12.
- - .'7
asked if all these items had been thoroughly
studied. The Chief Planner asked what she meam
by "seepage"'? She noted that underground
springs and drainage come down from the
mountain during the winter months, even with the
improvements done. She feels the drainage
problems have not been corrected.
Jan Pont
III Belmont Avenue, SSF
-
Vice-Chainnan Romero closed the public hearing.
-
Commissioner DeZordo commented on the vegetation and wildlife section. He tOO was concerned with the
native plams being replanted per the Habitat Conservation Plan and how it had been previously noted that the t. ~
plants needed to be irrigated, and it turns out now that these plants are dying due to lack of irrigation. Il5..
suggested that native plants be replanted instead of hydro seeding. Trail access parking and signage is non II'
mentioned in the DSEIR. -J .
-
Commissioner Barnett commented on the drainage erosion and soil erosion problem that could be handled , .'1,
withnormaI maintenance. He would like to see more detail on how this would actually take place.
-'
Motion-DeZordoISecond-Barnett: To direct staff to address all comments heard, and proceed to prepare a
Final Supplemental EIR. It was unanimously approved by voice vote.
Page 5 of9 Pages
PC Meeting of 211196
T errabay Project
City of South San Francisco
October 23. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 43
Responses to South San Francisco Planning Commission Public Hearing Comments:
Janice Smith
1.01 The comment notes that "the nearby school," presumably Hillside Elementary School,
needs upgrading to current building code standards. The comment pertains to existing
conditions at school facilities to be impacted by the project; these conditions will occur
with or without the project. The project itself would not create an additional impact with
respect to the existing need to upgrade the school to current building code standards.
1.02 As explained on DSEIR page 3, because the ultimate physical characteristics,
sequencing and timing of project Phases II and III are more conceptual, the
environmental documentation for these subsequent phases has been prepared at the
"program EIR" level under authority of section 15168 of the CEQA Guidelines. The
DSEIR text indicates that "When subsequent project Phase II and III are to be
developed and eventually come before the city for required approvals, in the future,
more specific information (precise plan, subdivision maps, etc., similar to what is now
available for Phase I) would be submitted and additional, more detailed environmental
review would be undertaken at that time." The program level assessment provided in
the DSEIR for these subsequent phases, including the assessment of shell mound
impacts and mitigation needs, is intended to, as indicated on DSEIR page 33, "provide
the basis for focusing any future project-level environmental documentation needs on
more direct impacts..." A further description of the "program EIR" intent, authority, and
approach is included in Appendix A of this Final SEIR attachment.
The commentor asks how impacts on the shell mounds in the Phase III portion of the
project can be determined if detailed traffic mitigations for Phase III are not clear. The
detailed roadway improvements that will eventually be needed for Phase III are not yet
certain because specific development plans have not yet been developed for this
subsequent phase of the project. Table 12 (p. 112) of the DSEIR, which summarizes
the 1982 EIR impact and mitigation findings, does note that redesign of the US 101
southbound "scissors" off-ramp would require relocation of Bayshore Boulevard slightly
west onto the project property to accommodate a redesigned hook off-ramp and new
hook on-ramp. The DSEIR findings also indicate that this realignment of Bayshore
Boulevard would be necessary to accommodate improvements recommended at this
location as mitigation for DSEIR Supplemental Impacts T-2, T-10 and T-12. Based on
this information, the DSEIR indicates at the "program EIR" level that the significant
impacts on site CA-SMa-40 identified in the 1982 EIR would still occur, and identifies a
mitigation approach.
At this writing, the precise design of the hookramps and realignment of Bayshore
Boulevard had not been determined. The City is currently conducting a feasibility
study on the potential locations of the hookramps. Associated impact and mitigation
details would be determined at the project-specific level when detailed development
WP51 \548\FSEIR\F-II.S48
Terrabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 44
plans for Phase III of the project are submitted and associated project-specific
environmental review is conducted.
The mitigation measure recommended in the 1982 EIR for the larger Indian shell
mound, site CA-SMa-40, requires capping the site with sterile fill and sealing it under
landscaping and/or parking areas. As noted in the 1982 EIR, the proposed capping
may result in some damage to the resource--e.g., compaction from the weight of
construction equipment. This potential for damage to CA-SMa-40 during construction
was identified in the DSEIR as Supplemental Impact CR-2. In response, the DSEIR
(pp. 246-247) recommends enhancing the capping mitigation measure by requiring that
an engineering fabric be placed over the site before fill is placed. The fill shall be at a
minimum of one foot deeper than the maximum depth of construction activities above
or near the site; and the capping should be supervised by a qualified archaeologist
with authority to recommend additional or different measures if necessary. These
DSEIR changes to the mitigation contained in the previous 1982 EIR were
recommended by the staff researcher at the State Historic Resource File System
Northwest Information Center.
Under the Terrabay Specific Plan, a precise plan must be approved before Phase II or
III of the project may be built. When Phase III is to be developed and eventually
comes before the city for required approvals in the future, more specific project
description information (precise plans, subdivision maps, etc., similar to what is now
available for Phase I) would be submitted and additional, and more detailed, "project-
specific" environmental review would be conducted, including formulation of more
detailed traffic and cultural resources mitigation particulars as necessary. The extent
and nature of the precise plan's impacts on site CA-SMa-40 and associated mitigation
details would be more precisely determined at that time, and the mitigation
recommended in the DSEIR could be supplemented as necessary.
Based on Appendix K of the CEOA Guidelines ("Archaeological Impacts" mitigation
standards), the DSEIR concludes and indicates on pages 39, 246, and 247 that these
capping measures would meet CEQA criteria for avoiding damaging effects on an
archaeological resource where avoidance is determined to be infeasible. Based on
CEOA Appendix K standards, the DSEIR indicates that the capping measures would
reduce the impacts to a level of insignificance. However, these DSEIR conclusions
does not preclude development of a future project-specific mitigation that may involve
excavation, or may involve avoidance if it is determined that Caltrans freeway
improvement and project phase III precise plans can be formulated to provide for such
avoidance. Any alternative mitigation measure proposed in the future must at least be
an equivalent measure to that proposed in the EIR, would have to satisfy the standards
of state law (CEQA Guidelines Appendix K), and would be subject to approval by the
City.
1.03 The comment refers to an archaeological investigation of site CA-SMa-40, the large
shell mound located in the Phase III portion of the project, which was performed by
WP51 \548 \FSEIR\ F.II. 548
Terrabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 45
Holman & Associates, consulting archaeologists, for the previous property owners. A
report on the Holman investigation was not completed, no related information was
submitted to the city, and no related record has been filed with the California Historical
Resources Inventory.
However, when Phase III is to be developed and eventually comes before the city for
required precise plan approval in the future, more specific information about the
development plan would be submitted and additional, more detailed environmental
review, possibly including formulation of more detailed cultural resources mitigation site
CA-SMa-40, will be undertaken at that time. (Please also see the first and fifth
paragraphs of response to comment 1.02.)
1.04 The city's Historic Preservation Commission will be notified and will have opportunity to
comment during future environmental review for subsequent project Phases II and III.
This public hearing commenter has submitted similar comments in writing. The written
comments of Francisco Vieira, Chairperson of the Historic Preservation Commission
are responded to later in this section. See responses to letter 29.
1.05 Please see response to comment 1.04.
1.06 Comment acknowledged. Numerous identified project impacts on vegetation and
wildlife are mitigated by project compliance with the conditions of the San Bruno
Mountain Habitat Conservation Plan (HCP) and the associated Section 10(a) permit
and Agreement with Respect to San Bruno Mountain Habitat Conservation Plan. The
status of project compliance with these conditions is addressed in response to
comment 13.01.
1.07 The mitigation measure recommended in the 1982 EIR for the larger Indian shell
mound, site CA-SMa-40, calls for capping of the site with sterile fill and sealing it under
landscaping and/or parking areas. As noted in the 1982 EIR, the proposed capping
may result in some damage to the resource--e.g., compaction from the weight of
construction equipment. This potential for damage to CA-SMa-40 during construction
has been identified in the DSEIR as Supplemental Impact CR-2. The DSEIR (pp. 246-
247) recommends that the city, as a condition of Phase III precise plan approval,
require the project applicant to finalize and implement, as necessary, a detailed
mitigation plan for potential impacts to site CA-SMa-40. The mitigation plan shall
adhere to the mitigation approaches, procedures, limitations and criteria specified in
Appendix K of the state CEQA Guidelines. As explained in paragraph five of the
response to comment 1.02 above, if appropriate, the future project-specific mitigation
plan for Phase III may recommend a mitigation approach other than the site capping
recommended in the 1982 EIR. If capping is selected as the preferred mitigation
approach, an engineering fabric shall be placed over the site before fill is placed; the
fill shall be at a minimum of one foot deeper than the maximum depth of construction
activities above or near the site; and capping shall be supervised by a qualified
archaeologist with authority to recommend additional or different measures if
WP511548\FSEIRIF-II.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 46
necessary. These changes to the site capping proposed in the 1982 EIR were
recommended by the staff researcher at the State Historic Resource File System
Northwest Information Center.
If warranted based on the results of recommended further subsurface investigation of
site CA-SMa-92, the DSEIR recommends capping site CA-SMa-92 in a similar manner.
While capping the site, possibly under project landscaping or parking areas, would
significantly limit access to the shell mounds during the life of the Terrabay project, the
measure would nevertheless "preserve" the sites for potential access, study and use in
the distant future. Capping is consistent with mitigation provisions for "important"
archaeological resources contained in Appendix K of the state CEQA Guidelines, which
requires (1) avoiding the sites altogether, (2) incorporating them into planned parks or
other open space, (3) deeding them into conservation easements, or (4):
'''Capping' or covering archeological sites with a layer of soil before building tennis
courts, parking lots, or similar facilities. Capping may be used where:
a. The soils to be covered will not suffer serious compaction;
b. The covering materials are not chemically active;
c. The site is one in which the natural processes of deterioration have been
effectively arrested; and
d. The site has been recorded.
The SEIR provides a program EIR-Ievel assessment for Phase III with a general
discussion of impacts and mitigations that is adequate under CEQA and appropriate
given that the specific development plans for Phase III are not known at this time.
Under the Terrabay Specific Plan, a precise plan must be approved before Phase III
may be built. Although the anticipated land uses and densities for Phase III are
generally described, the specific development plans will not be known until a precise
plan is approved. When Phase III is to be developed and eventually comes before the
city for required precise plan approval in the future, more specific information would be
submitted and additional, more detailed environmental review will be undertaken at that
time.
As explained in paragraph five of the response to comment 1.02 above, the capping
approach identified in the DSEIR does not preclude identification of an alternative
future mitigation approach which would provide less limited access. The response to
comment 1.02 explains the "program EIR" approach and how subsequent
environmental review for Phase III will include formulation of more detailed cultural
resources mitigation and could include further consideration of an archaeological
preserve on a portion of the site. If it is determined during subsequent environmental
review of the detailed Phase III development plans and preparation of the mitigation
plan required under mitigation for Supplemental Impact CR-2 that capping of the sites
could not be accomplished without damaging the resources, then an alternative
WP51 \S48\FSEIR\F-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 47
mitigation may be required, such as avoidance in a manner that permits access to the
site or a detailed excavation plan.
1.08 Approximately 200 acres of the 332-acre site are proposed to be developed. The
remaining 132 acres (about 40 percent of the site), consisting of the upper, more
steeply sloping and less disturbed portions of the property, are to be permanently
dedicated to the County of San Mateo for inclusion in the San Bruno Mountain State
and County Park, as required by the San Bruno Mountain Habitat Conservation Plan
(HCP) and associated Section 10(a) permit. In addition, the specific plan provides for
an additional six acres of open space within the developed areas of the project.
Although certain uses and densities are generally described for Phases II and III, the
specific development plans for these phases will not be known until the required
precise plans are approved. Additional open space may be provided within these
subsequent phases.
1.09 The comment refers to proposals to set aside part of site CA-SMa-40 for an innovative
archaeological preserve in collaboration with the proposed development (similar to
many other mitigation concepts described in many of the comment letters contained
herein). Please see response to similar comment 1.07.
1.10 The comment does not pertain to the adequacy of the SEIR. In any event, the HCP
and the project SEIR include a comprehensive and adequate vegetation and wildlife
impact mitigation program to prevent significant impacts on mountain habitats.
1.11 Please see responses to comments 10.01, 10.02 and 13.01.
1.12 The comment states that the DSEIR did not fully address the Indian shell mounds
located in the Phase III portion of the project site. The SEIR impact and mitigation
findings for site CA-SMa-40 can be found on DSEIR pp. 244-247. The DSEIR (pp.
243-244) provides a brief description of these sites based on information contained in
the 1982 EIR. In response to this and similar comments, revisions to these DSEIR
pages have been included in the errata (section III) of the FSEIR attachment to provide
the following additional information:
Site CA-SMa-40 is a large shell mound measuring approximately 80 to 90 meters in
diameter. The site is reportedly very significant and one of the few remaining
examples of such shell mounds in the Bay Area. Based on information from similar
Bay Area mounds, the site may have been used by local native peoples as a burial
ground, ceremonial place, and living site for hundreds or thousands of years and is
thought to possibly contain Native American human remains.
Additional information regarding the shell mounds can be found in several comment
letters, especially comment 25.01, by Professor of Anthropology Kent Lightfoot of U.C.
Berkeley. Please also see responses to comments 1.02 and 1.07.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 48
1.13 The comment is concerned about drainage, emergency access, earthquakes, and
geologic studies. Each of these general concerns in addressed below:
Drainage. Supplemental drainage impacts are discussed in DSEIR Section IV.E,
Drainage and Water Quality (pp. 173-182). That section discusses post-1982 storm
drainage improvements, including V-ditches and c~tchment basins, storm drain trunk
lines, and a box culvert and drainage channel within Caltrans right-of-way. All
necessary municipal storm drainage improvements for Phase I of the project have
been completed. The on-site drainage improvements for Phase II and Phase III have
not been completed. The box culvert under US 101 and the associated drainage
channel improvements were designed with capacity to serve buildout of all three
project phases.
In response to comments concerning the adequacy of the catchment basins in Phase I,
the City geotechnical consultant, Eric McHuron, conducted an extensive review of the
studies and records pertaining to the sizing and capacity of the catchment basins. The
results of this review were presented to City staff. On the basis of that review, the City
determined that the catchment basins for Phase I are adequately sized and properly
designed.
The applicant ("SunChase") has also indicated that the issue of catchment basin and
drainage ditch malfunctioning has been addressed (please see comment 32.04 by the
applicant's attorney):
"SunChase removed all the silt and debris from the v-ditches, catch basins, and
storm drains in the project area in the fall of 1995 prior to the rainy season.
Sun Chase also removed and replaced all of the rock and fabric filters in each
basin to ensure a dependable flow. The brush alongside the v-ditches was cut.
During the recent heavy rains, representatives of Sun Chase observed the
operation of the v-ditches, catch basins and storm drains and they were performing
very well. The rains, and particularly the violent storms of December, 1995, have
resulted in some silt and debris in the v-ditches. Sun Chase will continue to
monitor and clean these ditches on an as-needed basis... Sun Chase is in the
process of implementing an on-going funding and responsibility program to
maintain erosion and sedimentation control facilities after the project is built."
Emergency Access. All project public and private roadways would be constructed in
accordance with the roadway standards specified in the specific plan and development
agreement, and in the Terrabay Specific Plan District zoning (Section 20.63.070). The
emergency vehicle access aspects of these roadway standards have been reviewed
and deemed adequate by the city Engineering Division and Fire Department staff.
Comment letter no. 3 herein from Mr. Fred Lagomarsino, Fire Marshal and Chief
Building Official of the City of South San Francisco supports the DSEIR fire protection
services impact and mitigation findings. Please also see the response to comment
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 49
33.65 regarding concerns that emergency access routes may be blocked by landslide
debris.
Earthquakes. Earthquakes and other geologic hazards are discussed in DSEIR
Section IV.D, Soils and Geology. The project site is located in a region of high
seismicity and, like other sites in the project vicinity and the Bay Area generally, would
be subject to strong groundshaking in the event of a major earthquake on one of the
several faults in the region (e.g., the active San Andreas fault is located three miles
southwest of the site). There are no known active faults crossing the site, and no
portion of the site is located within an Alquist-Priolo Earthquake Fault Zone (zones
established by the California Division of Mines and Geology as having a potentially
significant risk of fault rupture and thus requiring special study prior to development).
A trace of the Hillside fault trends northwest across the site, and a second trace of the
Hillside fault has been mapped northwest of the site. Fault trenches excavated on the
site across these fault traces revealed no evidence of activity on the Hillside fault.
Geologic Studies. There have been several geologic and geotechnical reports
completed for the project since 1982 that have evaluated geologic conditions on the
project site before, during and after Phase I grading activities and have recommended
warranted repairs for any adverse conditions encountered. These reports have been
prepared by the applicant's and previous property owner's consultants, have been
reviewed by city staff and the city's geotechnical consultant, and have been
independently reviewed by the SEIR engineering geologic and geotechnical consultant.
Based on review of these reports and on new and revised geologic information
pertaining to the site, the SEIR geotechnical consultant identified those remaining
potentially significant impacts and associated mitigation measures discussed on DSEIR
pp. 168-172. In some cases, recommended mitigations call for additional geotechnical
studies to more thoroughly address specific issues of concern. Additionally, the
applicant has been formulating more detailed, design-level geotechnical studies for
completion of Phase I, in coordination with the city. Similar design-level geotechnical
studies would be prepared for Phases II and III when these subsequent phases are to
be developed in the future.
The remediation and repair plans for Area D were reviewed by City and County
officials, determined to be adequate, and approved. The City and County issued
grading permits authorizing work to proceed on Area D. The work is expected to be
completed by October 31, 1996.
1.14 Habitat restoration of temporary disturbance areas was performed in accordance with
the approved Terrabay Phase I Reclamation Plan. No irrigation is provided in the
restoration areas. The initial restoration work which failed was performed under very
unfavorable weather that included drought conditions. The remediation plan for the
previous restoration work provides for occasional watering by a water truck in the event
of drought conditions during the period in which plants are becoming established.
Please also see responses to comments 10.01 and 13.01.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 50
1.15 The DSE IR (pp. 207-208) notes that improvements at two trail heads providing access
to San Bruno Mountain County Park would be provided in Phases II and III. The
trailheads would connect to existing trails on the mountain. Parking for one of the
trail heads would be provided off of South San Francisco Drive adjacent to the
proposed Hillside Recreation Center. Parking for the second trailhead would be
provided in Phase III. The design details of the proposed trailheads, including parking
and signage, would be further developed in the required precise plans to be prepared
for subsequent Phases II and III.
1.16 The DSEIR (p. 179) identifies the uncertainty regarding ongoing maintenance
responsibilities for the catchment basins installed at the base of the ravines above the
Phase I portion of the project as a significant impact (Supplemental Impact 0-1). As
explained on DSEIR p. 176, a city/county Joint Powers Authority (JPA) was established
in 1983 to oversee construction of the catchment basins and, upon their dedication to
the JPA, to provide for their maintenance. The agreement that established the JPA
provides that the county will be responsible for funding all required maintenance and
administrative costs. Recently, however, the JPA has come to be perceived by the
county as a cumbersome entity for ongoing maintenance of the catchment basins.
County staff have propo~ed the possibility of disbanding the JPA and turning over
basin maintenance responsibilities to the county.
The DSEIR mitigation for Supplemental Impact 0-1 (DSEIR p. 181) recommends that if
the JPA is to be disbanded, the city shall: (1) work with the county and the project
applicant to ensure the catchment basins are in proper condition to allow their
dedication directly to the county as the county suggests; and (2) if the JPA is not
disbanded, continue to fulfill city responsibilities in accordance with the 1983 joint
powers agreement.
Continued ongoing maintenance of project geotechnical and drainage features,
including steep natural and cut slopes, erosion and sedimentation control facilities and
slope drainage facilities, could be accomplished by the county for features located on
the portion of the property to be dedicated to the county--i.e., HCP Administrative
Parcel 2-04-02), by the city, or by the project homeowners association. The project
Master Homeowners Association Agreement approved by the South San Francisco
City Council provides for ongoing repair and maintenance of geotechnical facilities and
programs (please also see comment 32.02). The associated Slope and DrainaQe
Maintenance Plan for Terrabay Master Association (June 19, 1996) prepared by the
applicant's geotechnical consultant (Exhibit C of the Homeowners Association
Agreement) clarifies the master homeowners association responsibilities and specifies
management, design and construction, monitoring, maintenance, repair, funding, and
reporting requirements. These requirements provide sufficient resources for and
assurance of continued drainage and slope maintenance.'
'Arthur Wong, City Engineer, memorandum to Lida Budko. Terrabay Project Planner, July 16, 1996.
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Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 51
D. WRITTEN COMMENTS AND RESPONSES
Reproductions of letters received during and after the DSEIR public
review period are included in the following section. Each letter is
immediately followed by the Lead Agency's response to substantive
comments therein pertaining to the adequacy of the DSEIR. Comments
and responses are correlated by code numbers added to the margins of
each letter.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 52
WP51 \S48\FSEIR\F-II.S48
2-
SOUTH SAN FRANCISCO POLICE DEPARTMEtJ E eEl V E
JAN D
INTER-OFFICE MEMORANDUM A 1 5 SsG
'LAIvNING
DATE: January 9, 1996
TO: Planning Division
SUBJECf: Draft Supplement E.I.R for the T errabay Development
FROM: Police Department
The Police Department has reviewed the January 1996 document draft and has the following
comments/concerns:
-
1. Summmy II. P3iC 31 - No impacts on police services has been included in the summary. This
is troublesome as frequently the summary section is the only section of such a document that
is reviewed. Therefore, mitigation necessary as described in Section IV G. should be added, 1- 01
or some notation in the summary should be made to indicate that mitigation necessary is the .
same as the 1982 E.I.R and people interested should reference the prior document. The
omission in this S.E.I.R tends to give the impression that there are no impacts on police
services which warrant mitigation.
-
2.
Transportation Sections -
L No traffic analysis or study of the intersections at HillsidelStonegate and
HillsidelLincoln was completed to determine if the current control at these
intersections is adequate or necessary with Project Development. Passing reference
is made to "sequencing the Hillside/Stonegate traffic signal with a new signal at
Hillside/Chestnut. Does this imply that the situation at HiUside/Stonegate is within
acceptable levels and merits no further mitigation? The stop signs at Hillside/Lincoln
were installed by San Mateo County while the Hillside extension was still under their
control. No local assessment has ever been done to determine if the stop signs are
necessary or adequate, or if they should remain during various steps of Project
Development.
2- .UL
-
-
b. There is concern as to how school age children in the project area will safely get to
schools they need to attend. Such an analysis is important for traffic pedestrian safety
purposes as an assessment needs to be made as to whether crossings of major
roadways adjacent to the project area are safe and adequately controlled for young
pedestrians, or whether other improvements such as pedestrian bridges or similar
improvements may be in order. In addition, if adequate safe crossings are not
provided, there may be an added burden on police services to provide adult crossing
"
(;t1HT.
guard services which are funded out of the Police Department budget.
ClINT.
J "J,.O'
c. IV C - Paie 100 - Makes the assumption that the County will extend the Hickey
roadway extension from Mission Road to Hillside Blvd. in a timely fashion. In our
review of the BART E.I.R City staffhas instructed the preparers of that E.I.R that
such an assumption cannot be made as the County cannot guarantee that the Hickey 2. ~
Blvd. extension will be constructed in a timely manner, or whether it wiD be
constructed at an. This S.E.I.R should further develop and clarify this point as Jack
of this roadway extension could have a significant impact on other roadways
connecting Hillside Blvd. with Mission Road.
-
-
d. Transportation - General- Some of the transportation issues list several mitigation
options for a single issue. Options are written and listed as if they would be equally
effective in mitigating a specific problem when in fact one option is superior to 2. os
another (i.e., southbound freeway flyover vs. triple left turn striping). It appears that
the quality of the document would be improved if an evaluation plus ranking of
options was also included.
-
-
3. Jrnpacts on Police Services Section IV G Paie 200 indicates that "The Police Department
expects to rely heavily on specific-plan required project on site security personnel to report
activity of concern". The applicant has taken a position that the specific plan does not
explicitly state that security is required to be provided on site during development non-
construction hours. and their representative indicates that they will not comply with the police 2.. OG
request for continuous on site security. If the developer takes this position there wiD be an
impact on police services during construction in that added police patrols will be necessary
to prevent theft, trespass, damage to the habitat conservation area, etc., in this very large
development area. The requirement for security patrols on site is a condition of the precise
plan for T errabay Park and Village and, in the opinion of the Police Department, is binding
for the first and subsequent phases of development. _
0~
--......... ---.,/
Sgt. Ron Petrocchi
Planning & Traffic
Terrabay Project
City of South San Francisco
September 17,1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 55
2. Sat. Ron Petrocchl. South San Francisco Police Department; January 9. 1996
2.01 The significant police service impacts of the project and associated mitigation
measures were identified in the 1982 EIR and are summarized in Table 26 of the
DSEIR (p. 206). The DSEIR (p. 205) concludes that "the impact findings in the 1982
EIR for project and cumulative effects on Police Department services remain generally
unchanged." Since the SEIR is merely a supplement to the 1982 EIR, the summary
chart on DSEIR pp. 11-40 summarizes only the significant supplemental impact and
mitigation findings of the DSEIR. In order to highlight the DSEIR-identified impact and
mitigation changes from the previous EIR, the DSEIR summary chart does not restate
the previous (1982) EIR impact and mitigation findings.
2.02 The DSEIR traffic analysis addresses the Hillside Boulevard/Stonegate Drive and
Hillside Boulevard/Lincoln Street intersections under the recommended mitigation for
base case and project impacts (Supplemental Impacts T-1 through T-4, T-6 and T-13)
at the Hillside Boulevard/Chestnut Avenue intersection. The mitigation recommended
for these impacts notes that "the monitoring (traffic counts) and associated engineering
evaluation necessary to determine when signalization [of Hillside Boulevard/Chestnut
Avenue] is warranted may also indicate that the Stonegate Drive signal (and
associated sequencing) is no longer needed and that instead of signal sequencing, the
Stonegate signal can be replaced with a stop sign on the Stonegate approach only
(i.e., if the new Chestnut Avenue signal will provide sufficient gaps in eastbound
Hillside Boulevard traffic flow to allow for safe stop sign-controlled turn movements
from Stonegate Drive). The monitoring/evaluation mayor may not also indicate that a
change in the nearby all-way-stop-sign-controlled Hillside Boulevard/Lincoln Street
intersection--i.e., removal of stop signs on the Hillside Boulevard approaches--may be
possible. "
The traffic signal at the Hillside Boulevard/Stonegate Drive intersection currently
operates at a'good level of service during the PM peak hour (based on the Heather
Heights Initial Study traffic analysis prepared by Crane Transportation Group in July,
1994). In 2010, this signal is expected to be operating at a better level of service than
the planned signal at the adjacent Hillside Boulevard/Chestnut Avenue intersection
because anticipated traffic volumes on Stonegate Drive would be much lower than on
Chestnut Avenue. When signalized, the Hillside Boulevard/Chestnut Avenue
intersection is projected to be operating at an acceptable LOS B in 2010 during the PM
peak hour with full buildout of project Phases I, II and III.
Removal of the signal at the Hillside Boulevard/Stonegate Drive intersection could
result in unacceptable operation for the stop sign controlled left turn movement from
Stonegate Drive. This potential impact would need to be considered should removal of
the signal be proposed.
In response to this and other DSEIR public review period comments, a PM peak traffic
period (4:00 PM to 6:00 PM) turn movement traffic count was conducted at the all-way-
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 56
stop-controlled Hillside Boulevard/Lincoln Street intersection by Crane Transportation
Group on Wednesday, June 12, 1996. During the PM peak traffic hour (4:45 PM to
5:45 PM), 1,455 vehicles were counted entering the intersection on the Hillside
Boulevard approaches and 11 vehicles were counted entering the intersection on the
Lincoln Street approach. Hillside Boulevard has two travel lanes on each of its two
intersection approaches, while Lincoln Street has a single lane approach.
No pedestrians or bicyclists crossed Hillside Boulevard at Lincoln Street during the
two-hour count period. However, the pedestrian overpass across Hillside Boulevard
just west of the intersection did have a minor level of pedestrian activity during the
traffic count.
Available sight lines were also evaluated for vehicles turning from Lincoln Street to
Hillside Boulevard. To the west, the sight line is less than 200 feet along Hillside
Boulevard, while to the east the sight line is greater than 1,000 feet along Hillside
Boulevard and the Hillside Boulevard Extension. Based on a prevailing vehicle speed
of 50 miles per hour on Hillside Boulevard (the posted speed is 40 miles per hour), a
stopping sight distance of 400 to 475 feet is required based upon standard traffic
engineering guidelines.'
Based upon Caltrans warrants,2 vehicular and pedestrian levels at the Hillside
Boulevard/Lincoln Street intersection do not come close to meeting criteria for provision
of all-way stop control. However, all-way stop control is warranted due to the less than
minimum acceptable sight lines to and from the west.
Should the city decide to eliminate the all-way stop at the Hillside Boulevard/Lincoln
Street intersection, only right turn movements from eastbound Hillside Boulevard to
Lincoln Street should be permitted. The signalized Hillside Boulevard Extension/
Jefferson Street intersection two blocks to the east provides the neighborhood served
by Lincoln Street with safe, controlled turn movements to and from the Hillside
Boulevard Extension. No new significant impacts would be expected if these changes
are made at the Hillside Boulevard/Lincoln Street intersection.
In conclusion, no mitigation is required for the Hillside/Lincoln intersection because the
intersection is operating at acceptable levels and the project traffic contribution to this
intersection will not change the level of service.
2.03 The project site is located within three school districts: the South San Francisco
Unified School District (SSFUSD), Brisbane School District, and Jefferson Union High
School District (JUHSD). The SSFUSD boundaries include Terrabay Village and
'A Policy on Geometric Design of Highways and Streets, AASHTO, 1990.
2Caltrans Traffic Manual.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 57
Terrabay Park (Phase I), and Terrabay Woods (Phase II) development areas. The
Brisbane School District and JUHSD boundaries include the Terrabay Commons and
Terrabay Point (Phase II) development areas.
South San Francisco Unified School District. Students in the SSFUSD would attend
Hillside Elementary School, Parkway Heights Middle School, and EI Camino High
School. Students attending Hillside Elementary School, which is located adjacent to
the project, could walk directly to school using on-site project sidewalks and pathways,
including the linear park which connects the Hillside Recreation Center with the school.
Older students walking to Parkway Heights Middle School and EI Camino High School,
located south of the project site, could first walk to Hillside School along the on-site
project sidewalks and pathways and then cross Hillside Boulevard via the pedestrian
bridge at Chestnut Avenue or could cross Hillside Boulevard at the signalized Hillside
Boulevard/South San Francisco Drive and Sister Cities Boulevard/South San Francisco
Drive intersections. They could continue to these schools just as other students in the
existing adjacent neighborhoods do.
The South San Francisco Police Department has noted that the signalized Hillside
Boulevard Extension/South San Francisco Drive and Sister Cities Boulevard/South San
Francisco Drive intersections appear to meet the following "warrants" (i.e., conditions)
for provision of an adult crossing guard:
(1) each intersection is more than 80 feet wide with no safe pedestrian intermediate
refuge area;
(2) traffic travels at high speeds, particularly during AM, noon and PM peak hours; and
(3) a high proportion of trucks use these routes.
The Department indicates that if 40 or more elementary school children cross within
any two hour period, an adult crossing guard would need to be provided.
Although the SSFUSD has indicated that all elementary school students would attend
Hillside Elementary School, in the event that some project elementary school students
attend SSFUSD schools other than Hillside Elementary School, an adult crossing
guard may also be needed.
The City shall conduct periodic monitoring of the crossings at the Hillside Boulevard/
South San Francisco Drive and Sister Cities Boulevard/South San Francisco Drive
intersections to determine if 40 or more elementary school children cross within any
two hour period. If the threshold is reached at either of these intersections, then the
Phase II project homeowners association shall be required to:
(1) fund the provision of an adult crossing guard at that intersection (including all
salary, background check, equipment, and training costs), and
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 58
(2) actively recruit candidates for the position and for an alternative part-time, back-up
fill-in position from among project residents. (Project residents are preferred
because of opportunities for more familiarity with students.)
Brisbane School District. Students in the Brisbane Elementary School district would
attend Brisbane Elementary School and Lipman Intermediate School, located north of
the project site in the city of Brisbane. In response to this comment, the SEIR has
been revised regarding its discussion of transportation to Brisbane schools.
The January 1996 DSEIR did not identify a separate significant impact specifically for
transportation to Brisbane School District. However, the DSEIR did include a
mitigation on p. 213 calling for installation of a sidewalk along Bayshore Boulevard for
access to Brisbane schools. The district has noted that, "The Brisbane School District
does not provide transportation for its students. As Brisbane and Lipman are within
walking distance from Terrabay, I anticipate the need for sidewalks to be placed along
Bayshore Road between the development and the current sidewalks. Otherwise,
additional funds may be needed for student transportation." Comments 21.05, 32.25
and 33.21 have also raised the issue of the safety of young students walking along
Bayshore Boulevard to Brisbane schools.
The DSEIR recommended mitigations for significant impacts on Brisbane School
District (Supplemental Impact PS-2) on DSEIR p. 213 include assignment to the project
applicant responsibility "for installing sidewalks along Bayshore Boulevard to allow
students from the project to walk to Brisbane Elementary School and Lipman
Intermediate SchooL" Approximately one mile of sidewalk would be need to be
constructed along Bayshore Boulevard.
In response to comments 2.03, 21.05, 32.25, and 33.21, further consideration has
been given to this school pedestrian access issue. Students walking to district schools
would have to walk along Bayshore Boulevard to Brisbane and then via local streets to
the schools themselves. Brisbane Elementary School is located approximately 1.9
miles and Lipman Intermediate School is located approximately 2.6 miles from the
furthest part of the project within the Brisbane School District. These distances may be
too great for young school children to walk to school. Also, Bayshore Boulevard is a
busy arterial roadway and vehicles travel at high speeds, making a sidewalk along this
busy roadway potentially unsafe for young schoolchildren. Portions of this segment of
the roadway also adjoin the steep slopes of San Bruno Mountain. The roadway right-
of-way may not easily accommodate a sidewalk in these areas. While there are
important safety concerns and engineering constraints, they may be able to be
adequately addressed by site-specific design measures.
The Brisbane School District has also indicated that other transportation options in
addition to a sidewalk along Bayshore Boulevard should also be considered to address
this impact and that development of the needed mitigation and selection of a preferred
solution should be coordinated with the district, the SSFUSD, and Samtrans (the local
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 59
transit district). The district will also need to consider transportation for students from
the Northeast Ridge development as well as students from Terrabay.
Because a sidewalk along Bayshore Boulevard may not be the most desirable solution
for transportation to Brisbane School District schools, the recommended mitigation on
DSEIR p. 213 has been revised in response to this and related comments to provide
more flexibility to the district, the applicant and the city in reducing the impact to a less-
than-significant level. (See errata in section III herein for DSEIR pages 210 and 213.)
In summary, finalization of school access sidewalk needs and associated design
details are properly deferred in the revised transportation chapter to the Phase II and
Phase III environmental documentation sequences, since the City currently does not
know what the actual configuration of these phases will be.
Jefferson Union High School District. The JUHSD does not provide transportation for
its students; students attending JUHSD schools would need to arrange their own
transportation. JUHSD schools, which are located in Daly City and Pacifica, would be
too far for students to walk to school; therefore, no pedestrian safety impacts would be
anticipated.
2.04 If Hickey Boulevard is not extended from Mission Road to Hillside Boulevard at the
same time that it is extended from EI Camino Real to Mission Road, then the following
project-related traffic impacts are likely:
· Some traffic currently using parallel routes, such as Chestnut Avenue and
Evergreen Drive, that the DSEIR traffic analysis projected would be diverted to the
Hickey Boulevard Extension, would continue to use the existing routes.
· Volumes on existing parallel routes, such as Chestnut Avenue and Evergreen
Drive, would increase due to traffic from new development in the local area, such
as the BART station proposed for construction at Hickey Boulevard between EI
Camino Real and Mission Road.
· A minor amount of existing local area or sub-regional traffic may be more likely to
use Evergreen Drive in combination with Hickey Boulevard (to travel between
Hillside Boulevard and EI Camino Real) rather than Chestnut Avenue.
If Hickey Boulevard is not extended all the way to Hillside Boulevard, the actual extent
and potential significance of the impacts to Evergreen Drive, Chestnut Avenue and
other parallel routes will depend on the extent of local and regional development
contributing traffic to the circulation network and on travel times for parallel routes. If,
at the time of precise plan processing for Phase II or III, there is (1) no extension of
Hickey Boulevard to Hillside Boulevard; or (2) no assurance that Hickey Boulevard will
be extended, then the supplemental environmental assessment for Phase II or III
should evaluate possible impact(s), related to Phase II or III, of the possible failure to
extend Hickey Boulevard.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 60
2.05 The SEIR need only describe feasible mitigations and alternatives that would avoid or
reduce identified significant impacts. A comparative evaluation and ranking of
alternative mitiQation options is not required. In addition to the environmental
considerations evaluated in the SEIR, when selecting a preferred mitigation approach,
the city must also weigh many different non-environmental factors not appropriate for
consideration in the SEIR (economic feasibility, etc.).
2.06 The Police Department maintains that on-site security is a condition of the specific plan
and the Phase I precise plan, and is required for all project phases. The Phase I
home builder now provides on-site security during evenings and weekends when no
construction activity is occurring on the site. Since submittal of this comment, the
Police Department has indicated to the EIR authors that the applicant has adequately
addressed the Department's concerns about onsite security. No additional response is
necessary.
WP51 \548\FSEIR\F.II.548
CXTY OF SOUTH SAN FRANCISCO
XNTER-OFFXCE MEMORANDUM
.DATE :
JanuarY 15, 1996
Steve Solomon
RECEIVED
JAil , 5 _
PLNvNING
'1'0 :
PROII:
Fred Lagomarsino
sUBJECT: DRAFT SUPPLEMEHTAL EIR - TBRRABAY
--
3
and froll Fire and Building "2 ,
;7.()
I have reviewed the above document
~~~~:::~:::iCial
-
.",'~ .. .
,- .-' .", ..
.~~)j~~~t~~-:~(~.._.... '"<
... . --.
!o" .
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 62
3. Fred Laaomarsino. Fire Marshal/Chief Buildina Official, City of South San
Francisco; January 15. 1996
3.01 Comment supports the DSEIR fire protection services supplemental impact and
mitigation findings; no additional response is necessary.
WP51 \5481FSEIR\F-II.548
STATE 01' CALIFORNIA. Tlo4E RESOURCES AGENCY
PETE WIlSON. Gowwnor 4'
DEPARTMENT OF FISH AND GAME
POST ClFACf BOX ~7
YCltlNTVUE. CALIFORNIA 94599
(707) 944..s5OO
January 18, 1996
RECEIVED
JAN 1 9 1996
PLANNING
@
Ms. Lida Budko
City of South San Francisco
400 Grand Avenue
South San Francisco, California 94080
Dear Ms. Budko:
Supplemental Environmental Impact Report (SEIR)
Terrabay Specific Plan
SCH 95092027
./
.-:..,
Department of Fish and Game personnel have reviewed the SEIR for
the proposed extension of the development agreement for the Terrabay
Specific Plan. The project site is located on the south slope of San
Bruno Mountain, and development of the site has been considered in the
San Bruno Mountain HCP and in an earlier EIR for the Terrabay project.
The current proposal does not involve changes which would alter th~
environmental impacts assessed in these earlier documents. The SEIR 4 0 (
calls for actions which would increase the success of revegetation .
required under the original EIR. We support this requirement.
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Thank you for the opportunity to review and comment on this
proj ect. If you have any questions, please contact Jeannine M.
DeWald, Associate Wildlife Biologist, at (408) 429-9252; or Carl
Wilcox, Environmental Services Supervisor, at (707) 944-5525.
Si~cer./.7Y ,
ir.i'~ @~-v7
Ken Aasen
Acting Regional Manager
Region 3
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 64
4. Ken Aasen, AcUna Reaional Manaaer, Reaion 3, California Department of Fish
and Game; January 18, 1996
4.01 Comment supports the DSEIR vegetation and wildlife supplemental impact and
mitigation findings; no additional response is necessary.
WP51I548\FSEIRIF-II.548
RECEIVED5
JAN 2 3 1996
PLANNING
DATE:
January 22, 1996
TO:
Steve Solomon, Chief Planner
FROM:
Richard Harmon, Senior Engineering Technician
f5~
SUBJECT: TERRABAY DEVELOPMENT - DRAFI' SUPPLEMENTAL ENVIRONMENTAL
IMPACT REPORT
':,
~
In accordance with your request of January 8, I have reviewed the suiject document dated January
1996 and offer the fonowing comments:
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1. I request that the mitigation measures contained in the "summary" (yellow section) be I; D(
numbered so that they can be readily identified and referenced. .
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-.
2.
Drawings or exhibits illustrating the traffic mitigation improvements described in the
mitigation ~lImmary would be very helpful in understanding the recommendations. This is '5.02-
particularly true for intersection channelization improvements that can be difficult to
descn1>e in towards and even more difficult for the reader to vi5I1ali~.
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3.
-
The report should discuss any noise impacts on the the Phase 2 and Phase 3 portions of the
project from the traffic along Sister Cities Boulevard, Baysbore Highway and Bayshore 5.D3
Freeway. _
4.
. -
Reference the last sentence of Page S6 and page 208, Section c(3): Exhibit G,
"Maintenance, ImprovementlResponsibilities" of the April 14, 1988 Terrabay Development
Agreement, states in Section C, that "the developer or, with approval of the City, a private
property owners association, shall maintain the linear park (Item A-3) and aD private lands,
buildings, landscaping, and improvements in the prqect area."
S.OIr
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S.
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On Page 170, within all sub-sections of Section 4, "Supplemental Mitigation Needs": there
is a discussion of future, on-going maintenance requirements and programs to address soil and geotechnical problems. Are there sufficient funds in the Terrabay property owner's
association monthly assessments to provide for this maintenance? If this information is not
s .(}If
V
"NT.
TERRABAY DEVELOPMENT -DRAFT SUPPLEMENTAL EIR
Jaf1uary 22. 1996
Page 2
"'18.
available, what would be a reasonable yearly budget to permit the homeowner's association
to implement these maintenance programs? Do the recorded association D.C.C.&R..'.
include these maintenance responsibilities in their provisions and requirements? The City
bas consideted and ~ec:ted the concept of forming a geologic hazards abatement district for
the Terrabay properties.
r;. O~
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6.
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The "Geoteclmic:al Appendix" contains reports (the two PSC reports dated July 24, 1995 and
the PSC report dated July 27, 1995) that we cannot locate in our permanent files. The IS. Db
prct eel sponsor should file, with the Engineering Division, two bound copies of these three
reports for our public records.
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R.CH:~
TERR.:DSEIR.2.R.CH
cc: John Gibbs, Director of Public Works
Arthur Wong, City Engineer
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 67
5. Richard Harmon, Senior EnaineerinQ Technician, City of South San Francisco:
January 22, 1996
5.01 The comment suggests that the mitigation measures in the DSEIR summary chart be
numbered. The DSEIR summary chart has been revised accordingly.
5.02 Figures 20, 21 and 24-26 are schematic representations of the new turn and through
lane and new signal locations recommended as mitigation at intersections for base
case (without project and with project) conditions. More detailed design-level
engineered drawings of the recommended intersection configurations are not
necessary at this EIR level to allow a reasoned judgment of the adequacy of the
proposed mitigation and are not appropriate for a program EIR-Ievel assessment of
improvements that are anticipated to be needed up to 10 years in the future. (The
specific development plans for Phase III are uncertain.)
5.03 The DSEIR (p. 222) notes that "Sister Cities Boulevard is a primary noise source for
portions of project Phases /I and III fronting this roadway..." and "Traffic noise from US
101 and, to a Jesser degree, Bayshore Boulevard and other local streets, continues to
be the primary noise factor affecting the eastern portion of the project site proposed for
commercial uses." The future noise contours presented in Figure 32 result primarily
from these noise sources. The compatibility of project Phases II and III with the
projected future noise environment due to traffic noise from Sister Cities Boulevard,
Bayshore Boulevard and US 101 traffic is discussed on DSEIR pp. 225-227 and is
identified as Supplemental Impact N-1. Mitigation for Supplemental Impact N-1 is
identified on p. 228.
5.04 The comment notes that the DSEIR (p. 208) incorrectly states that the linear park
along Hillside Boulevard connecting the playing fields at Hillside Elementary School
with the Hillside Recreation Center would be maintained by the city. The SEIR has
been revised 10 indicate that the linear park will be maintained by the project master
homeowners association. (See errata for DSEIR p. 208 in section III herein.)
5.05 The project Master Homeowners Association Agreement approved by the South San
Francisco City Council provides for ongoing repair and maintenance of geotechnical
facilities and programs. The Slope and DrainaQe Maintenance Plan for Terrabay
Master Association (June 19, 1996) prepared by the applicant's geotechnical
consultant (Exhibit C of the Homeowners Association Agreement) clarifies the master
homeowners association responsibilities and specifies management, design and
construction, monitoring, maintenance, repair, funding, and reporting requirements.
These requirements provide sufficient resources for and assurance of continued
drainage and slope maintenance.'
'Arthur Wong, City Engineer, memorandum to Lida Budko, Terrabay Project Planner, July 16, 1996.
WP51 \S48\FSEIR\F-II. 548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 68
5.06 The applicant has indicated that it will file two bound copies of the three requested
reports with the city's Engineering Division.
WP51 \548\FSEIR\F-II.S48
(p
CITY OF SOOTH SAN FRANCISCO INTER-OFFICB MEKORANDt1K
Date: January 25, 1996
TO: steve Solomon, Chief Planner
FROH: Dennis Chuck, Associate civil Engineer '/)"1\.c...
SUBJBCT: Draft Supplemental EIR for the Terrabay Development
I have reviewed the subj ect document and offer the followinq
comments:
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The Hillside/Lincoln intersection needs to be evaluated
regardinq the impacts Terrabay traffic. This all-way stop is
on a major corridor fronting Terrabay. The impacts to this ~.Ol
intersection by Terrabay vehicles need to be examined to
determine if the existing traffic controls need to be upgraded
to traffic signals.
-
The document indicates that a siqnal will be installed at
the intersection of Hickey Boulevard Extension and Hillside G;.~
Boulevard. Verify that the County will not just be installinq
a stop siqn.
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 70
6. Dennis Chuck, Associate Civil Enaineer, City of South San Francisco;
January 25, 1996
6.01 Please see response to comment 2.02. Signals should never be warranted at the
Hillside Boulevard/Lincoln Street intersection with or without the Terrabay project
because of the minor amount of side street approach traffic on Lincoln Street.
6.02 San Mateo County Department of Public Works traffic engineering staff has indicated
that when Hickey Boulevard is built from Mission Road to Hillside Boulevard, a signal
would probably be installed at the Hillside Boulevard/Hickey Boulevard intersection (Mr.
Bob Cambron, San Mateo County Department of Public Works personal
communication, June 12, 1996).
WP51 \S48\FSEIR\F-II.S48
SOUTH SAN FRANCISCO UNIFIED SCHOOL DISTRICT
7
AOMINISTRA TION
Or. Richard J. R190
S__
ADMINISTRATlON BUILDING. 398 'B' STREET
SOUTH SAN FRANCISCO. CAUFORNIA 94080
(4,5)8n-87OO
Fax . (4'5) 583...717
BOARD OF TRUSTEES
Romolo J. Bruelll
Shirl.. Hoell
Raymond Latllam
RIoI...1I O. M_
R E eEl V E 0 Victoria Yon Scllall
January 29. 1996
JAN 3 1 1996
PlANNING
Mr. Steve Solomon
Planning Department
City of South San Frapcisco
P.O. Box 711
South San Francisco, California 94083
Re: Draft Supplemental Environmental Impact Report
for the TerraBay Specific Plan and Development
Agreement Extension
Dear Mr. Solomon:
This letter is the South San Francisco Unified School District's response
to the above subject matter.
Pa~e 213 d. - Schools
7.01
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The impact of the TerraBay Project on the South San Francisco Unified
School District will be "less-than-significant" LS only if the City requires
the project - applicant to negotiate with the South San Francisco Unified
School District and provide sufficient additional funds necessary to
mitigate project impact on the schools.
The City has the authority to consider the adequacy of school facilities
and to impose additional mitigation measures. In addition to the law
that requires the payment of developer fees, there is also an independent_
requirement that cities address the impact of growth on school districts
pursuant to statutes and appropriate court decis ions. Any project wi th
the potential of having a significant impact must include mitigation
measures which reduce those impacts to a level of "less-than-significant".
The District requests the City condition approval of the development on
the completion of an agreement between the District and the developer
regarding sufficient additional funds or other measures necessary to
mitigate project impact on the schools.
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Pa~e 202 d. - Schools (1) Attendance Areas
7.0'2-
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The last sentence should read "The Jefferson Union School District
boundaries include all of the project area served by the Brisbane School
District.
-
~ry tr.u1y ,-lour" . ~
7fC'~ ?tL<-<-- - Id .~
'/Janice B. Smi th
Assistant Superintendent/
Business Services
sc
Attachments
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 72
7. Janice Smith, Assistant Superintendent, Business Services, South San Francisco
Unified School District; Januarv 29. 1996
7.01 As discussed on DSEIR pp. 209-210, based on current enrollment multipliers provided
by the districts and the revised number of project units (721), the project would
generate an estimated 370 additional K-12 students; 260 would attend SSFUSD
schools, 90 would attend Brisbane School District schools, and 20 would attend
JUHSD schools.
As explained on DSEIR pp. 211-212, the SSFUSD has estimated that the total
estimated cost to the district to provide relocatable classrooms to accommodate the
enrollment increase would be $1.4 million. Costs to add permanent classrooms would
be greater. Additional restroom and core classroom facilities may also be needed, at
additional cost. School impact fees accruing from the project to the SSFUSD
(estimated by the district at $1.372 million) may not be insufficient to cover the full cost
of serving the students generated by the project (Supplemental Impact PS-1).
The Brisbane School District has indicated that the project-related enrollment increase
would require additional classroom space as well as physical education and school
assembly space, lunch room, playground, restroom, kitchen and multi-purpose room
improvements at Brisbane and Lipman Schools. According to the district, the
estimated school impact fees accruing to the district (estimated by the district to be
$246,000) would cover the cost of providing additional portables but may not be
sufficient to fund the other necessary improvements (Supplemental Impact PS-2).
However, the school impact fees accruing from the project. as calculated by SSFUSD
and BSD, appear to have been underestimated because the estimated size of the
residential units used is smaller than the units actually being built. Thus, the fees paid
by the project may be sufficient to cover the districts' estimated costs.
School impact fees accruing to the JUHSD are expected to be sufficient to cover the
cost of providing additional portable classroom facilities.
As mitigation for SSFUSD and Brisbane School District impacts (Supplemental Impacts
PS-1 and PS-2), the DSEIR (p. 213) recommended requiring the applicant to comply
with the school impact fee requirements of the districts. If it is determined by the city
that the project fees would not be sufficient to mitigate the school impact to an
insignificant level, the DSEIR also recommends that the applicant voluntarily agree to
negotiate with each school district and provide additional funds and/or measures to
mitigate school impacts. The commentor feels that such "voluntary" mitigation does
not provide reasonable assurance that the identified impact would be mitigated to a
less-than-significant level and that project approval should be conditioned upon a
satisfactory agreement between the SSFUSD and the developer that fully mitigates
project school impacts.
WP511548\FSEIR\F-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 73
California Government Code Section 53080 authorizes school districts to levy fees and
other requirements on development projects. Section 65995 establishes fee limits and
prohibits local agencies from imposing any other fees or requirements on projects.
Section 65996 limits the types of mitigation that can be imposed to ensure adequate
school facilities and prohibits an agency from denying a project approval under CEQA
on the basis of inadequate school facilities.
The courts of appeal, however, have limited the restrictions in Sections 65995 and
65996 to apply only to adjudicative actions (e.g., variances, subdivision map approvals,
building permits, conditional use permits) and not to legislative decisions such as
specific plan adoption or amendment. The proposed project considered in the SEIR
consists of two legislative actions: amending the Terrabay Specific Plan and amending
the Terrabay Development Agreement. The decisions in the appeals court cases have
indicated that general plan policies requiring adequate school facilities should be in
place to provide the basis for the additional mitigation. The South San Francisco
General Plan Land Use Element includes the following such policy: "No development
proposal should be approved if supporting utility systems and public services are
inadequate to accommodate the proposed development (Policy 6, p. 3-2). Therefore,
the city is not constrained from considering and imposing additional mitigation
measures for school impacts.
Because the mitigation measures recommended on DSEIR p. 213 may not be
sufficient to reduce project school impacts to a less-than-significant level, the SEIR has
been revised as follows:
The city shall require the applicant, as a provision of the project development
agreement, to prepare and submit for city review and approval, a school financing plan
that includes:
(1) Payment of State-Mandated School Impact Fees. Require the applicant to comply
with applicable SSFUSD and Brisbane School District school impact fee
requirements. If it is determined by the city that the project fees would not be
sufficient to reduce project school impacts to a less-than-significant level, the city
may also:
(2) Additional Impact Fees. Require that the project applicant/developer pay additional
impact fees or some other additional in-kind contribution, or establish oth~r
financing mechanisms in consultation with the city and acceptable to the SSFUSD
and the Brisbane School District sufficient to cover the cost of providing classroom
space and ancillary school facilities needed to serve the increased enrollment
generated by the project, to the city's satisfaction.
7.02 The DSEIR (p. 202) incorrectly states that the JUHSD boundaries include all of the
project area when, in fact, the JUHSD would serve only Terrabay Commons and
Terrabay Point. The SEIR has been corrected. (See errata for DSEIR p. 202 in
section III herein.)
WP51 \548\FSEIR\F-II.548
:.2-:.21-1::r.-h ~:~L""'t.l -..U"
EMAX
Environmental Mitigation Exchange company
February 1. 1996
Mr. Steve Solomon
Chief Planner
City of South San Francisco
Planning Division
P.O. Box 711
South San Francisco. CA 94083
8llbjed:
Review of Draft SuppJemmtal EIR for the Terrabay SpedIk Plan aad
Develop.eat Agreement ExteDSioa
Dear Mr. Solomon:
8
The Environmen1al Mitigation Exchange Company (EMAX) has reviewed the Draft
Supplemental EIR for the Terrabay Specific Plan and Development Agreement Extension
~ by Wagstaff Associates for the City ofSoutbSan Francisco in January, 1996. EMAX
does not believe that the document provides an altcmatives evaluation in compliance with
California Envi:ronmemal Quality Act (CEQA) Guidelines Section 1512.'5(d).
An evaluation of a ''range of reasonable altematives" as required by CEQA Guidelines has :;1
been completed. Viable altemativcs that would promote open space uses in Phases n and m of
the Specific Plan area and that address sigDificant environmental issues have Dot been evaluated. ~. (;) I
1b.e Curret1t Em inCOIpOrates the discussion of four alt:cmatives from the 1982 EIR and
acknowledges the need to modify the No Project Altc:mative due 10 recent events. but provides
no updated evaluation of the environmental implications of ahematives under cuneot (1996)
cireumstances.
The alt~ves evaluated include the following:
(1) A Concept Plan Alternative 'With Pbase I and II uses similar to the proposed
Specific Plan. but less intensive commercial development in Phase m.
Ii \ALSTON\SOl.OMON.Ll1t
21 SUNNYSIDE AVENUE, CORTE MADERA, CA 9492S. Phone: (415) 927.2000. Fax: t415) 927-1008
--
2-21 -1 995 :,: :,~~'~, - ..U-1
Mr. Steve Solomon, Chid'PIanne:r
City of South San Francisco
February 1. 1996
Page 2
(2) An alternative designed to confoan with the Sphere of Influence Study mat actually
involves more intenSive land uses (39% more housing units) than the proposed
project.
(3) AfJ. alt.e:mati.ve designed to conform with the Gc:Dc:ral Plan Amendment which.
involves more dcvelopmBDt of both zesidentia1 and commercial uses than the
proposed project.
(4) A modified No Project Altcmarive that recognizes prior construction of on-site and
off-site improvements and involves partial development of Phase I with 00
initiation of development of Phases n and m.
-
The viability of the "'modified" No Project Alternative and means to achieve its implementation.
have not been dist'ussed. Since the altcmativc invotves 00. development in Phases n and m~ the
Final EIR should detmninc means to acbie'YC pIJlci1ase of the parcels for open spare and to allow
their management as open space uses into pcrpc:tuity. 'The potential fur use oftbese portiO.DS of
the Specific Plan area as open ~ is certainly teinforccd by findings in the Supplemental Draft
EIR. The SupplemeoDil EIR{pp. 196-197) discusses the 1ai]~ of30 acres of habitat restoration
efforts as part ofPbasc I construction. Tbe discussion acknowledges issues of "severe erosion, a
sparse cover '01' native plants, and vigorous spread of in.~ve pest plants in almost all
reclamation areas," and the suggested use of herbicides and other measures to rectify the B.ol..
situation bave environmental impliCations not !:Val discussed in the Supplemental ETR An
extrapolation of these failures beyond Phase I to encompass Phases II and ill which are also
scheduled for "restoration" to I'nnM\l',e eodangc~ species habitats, clearly was:ran1S a
~nsideration oftbe use of the Phase II and m areas as lkveiopment uses. The EIR also
co:aect1y identifies the air quality impact of the development of all tbree phases oftbe project as
a "significant unavoidable adverse impact" that would require a Statement of Overriding
Considerations by the lead agency to allow approval. of a developmem agreement extension. A
scenario of no development in Phases n and m of the Speci:fi.c Plan would clearly help to
mitigate this important environmental concem..
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The Supplemental EIR has also failed to correctly idemify the wcnviromneotally superior
alternative" as required by CEQA The au!hors of1he Supplemeotal EIR have agJCed with the
1982 EIR that the Concept Plan Altcmstive (of slightly l~ deveJopmcnt in Phase lII) is 1be
8.0~
'\.'
"'~
E:\Al..S'IQN\SOl.TR.
2-2 1 - 1 995 5: 53Pfo.1 =P.C;M
Mr. Steve Solomon. Chief Plmmer
City of South San Francisco
February 1, 1996
Page 3
cnviron.mentally superior altcmativc. without due consideration. of either the "modified" No
Project Alternative, the eDvir..nhwo.nt~l fi.DdiIIgs of their own docUlDC22%) or the lessoos to be
learned through the faulty implementation ofPbase 1. The CEQA 0uidc1iDcs do stI1e that. "if
the eoviroDmCDtally superior a.ltemati'YC is the 'no project' alt=nati~ the EIR. sba1l also identify
an environmentally superior altc:mative among the other alternatives," Ho'R'V'Br, the "'mod.ifiec:r'
No Project Alternative is not a No PJoject Alternative of DO development and, in fact. should be
~ as the envitouaueutally superior altemalivc, especially in light of1he bistoly oftbe
impat'ft to endangered species resulting from implement1dion to date ofPbasc I aDd the
significant unavoidable ad~ impacts identified with RSpeCt to development ofPbasc:s n aad
III of the Specific Plan.
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We urge the lead agency to further explore an alternative that allows cootinocd ~opmeat of
Phase 1, but removes the Phase n and III area from devclopme:zrt consideration and cnsm:s
mauaaement ofthesc areas for open space and habitat uses into perpetuity. Along 1bese fin=, ~
believe that this open specc site may have significant pote:ntial as an c:nviromaczJtal mitiptiCXl
bank. A3 such. we have identified funding sources who may make it possible for our
organization to finance porchase oftbis property for mitigation mnlring purposes.
Sincerely,
E:VJ.ST'ONISOL()J.L'lX
CONT.
~.o3
0.0~
Terrabay Project
City of South San Francisco
October 23. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 77
8. Farnum Alston. President. Environmental Mitiaation ExchanQe Company;
February 1. 1996
8.01 The comment states that the DSEIR does not evaluate a reasonable range of
alternatives, including alternatives with more open space in Phases II and III, and does
not evaluate the four 1982 EIR alternatives under current (1996) conditions, as
required by CEQA.
The Lead Agency has determined that the DSEIR does evaluate a reasonable range of
alternatives. The alternatives reevaluated in the DSEIR (pp. 259-261) are the same as
those considered in the 1982 EIR, which were determined to represent a reasonable
range of alternatives at the time the 1982 EIR was certified as adequate. In addition,
the DSEIR reevaluates the four 1982 EIR alternatives under current (1996) conditions.
The DSEIR alternatives section identifies any substantive changes in conditions since
1982 which may affect the findings of the 1982 EIR regarding the four identified
alternatives to the proposed project.
The comment also states that feasible alternatives that would promote open space
uses in Phases II and III and that would avoid identified significant adverse project
impacts were not evaluated. Comments 8.02 and 8.04 identify two alternatives in
particular that the commentor feels warrant further evaluation in the SEIR: a "modified
no project" alternative and an alternative that allows buildout of Phase-I, but preserves
the Phase II and Phase III portions of the project site as open space.
The "modified no project" alternative referred to in the comment is the same as the "no
project" alternative evaluated in the DSEIR, which consists of no extension of the
specific plan and development agreement and no development other than the limited
portion of Phase I that would be completed under the existing entitlements. The
comparative impact findings of this "no project" alternative are presented on DSEIR pp.
260-261 .
An alternative that allows buildout of the remainder of Phase I, but preserves the
Phase II and Phase II portions of the project as open space, would avoid the
unavoidable significant adverse regional air quality impact (Supplemental Impact AQ-2)
and traffic impact on the US 101 freeway mainline (Supplemental Impact T-15)
identified for the project, and would mitigate the following mitiQable significant impacts
identified for the project:
· compatibility between Phase II homes and existing electrical transmission lines
(Supplemental Impact LU-2);
· year 2010 Phases II and III traffic impacts at:
- the Hillside Boulevard/Chestnut Avenue (Supplemental Impacts T-3 and T-14),
- Oyster Point Boulevard/Dubuque Avenue/US 101 northbound on-ramp
(Supplemental Impact T-9), .
WP51 \548\FSEIR\F-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 78
- Sister Cities Boulevard/Oyster Point Boulevard/Bayshore Boulevard/Airport
Boulevard (Supplemental Impacts T-8 and T-12),
- Hillside Boulevard/Serramonte Boulevard (Supplemental Impact T-19),
- Bayshore Boulevard/US 101 southbound on- and off-ramp/project commercial
access intersections (Supplemental Impact T-11 and T-13),
- Dubuque Avenue/US 101 northbound off-ramp/US 101 southbound on-ramp
(Supplemental Impact T-10);
- the US 101 southbound off-ramp to Bayshore Boulevard (Supplemental Impact
T-16), northbound off-ramp to Dubuque Avenue (Supplemental Impact T-17);
and northbound on-ramp from Oyster Point Boulevard (Supplemental Impact T-
18).
· Brisbane School District impacts (Supplemental Impact PS-2);
· short-term construction impacts (Supplemental Impact AQ-1); and
· cultural resources impacts (Supplemental Impacts CR-1, CR-2 and CR-3).
Implementation of the "no project" alternative, or of an alternative that allows buildout
of the remainder of Phase I but preserves the Phase II and Phase III portions of the
project as open space, is not necessary to avoid most of the significant impacts
identified in the DSEIR. All of the significant impacts identified in the DSEIR can be
mitigated to a less-than-significant level by recommended mitigation measures with two
exceptions: project impacts on the US 101 freeway mainline would remain significant
and project impacts on regional air quality would remain significant even after
implementation of recommended mitigations. In considering whether to approve the
project as proposed, the city would be required to either adopt the "no project"
alternative or determine the no project alternative to be infeasible and adopt a
Statement of Overriding Considerations for unavoidable significant freeway mainline
traffic and air quality impacts.
8.02 The comment refers to a "modified no project" alternative, apparently referring to the
no project alternative discussed on DSEIR pp. 260-261. The DSEIR indicates that,
because a specific plan, development agreement, Phase I precise plan, and various
other entitlements have been approved for the project, and substantial on-and off-site
improvements have been constructed, the no project alternative now means no
extension of the specific plan and development agreement and no development other
than the limited portion of Phase I that would be completed under the existing
entitlements.
The commentor correctly notes that the "no project" alternative, because it would
involve no development of Phases II and III, would avoid several of the significant
impacts identified in the DSEIR. The DSEIR (p. 261) acknowledges that the "Impacts
identified for Phases /I and 11/ would be avoided with the no project alternative."
However, the "no project" alternative is not necessary to avoid most of the significant
WP51I548\FSEIRIF-II.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEtR
II. Responses to Comments on the Draft SEIR
Page 79
impacts identified in the DSEIR. All of the significant impacts identified in the DSEIR
can be mitigated to a less-than-significant level by recommended mitigation measures
with one exception: project impacts on regional air quality would remain significant
even after implementation of recommended mitigation. In considering whether to
approve the project as proposed, the city would be required to either adopt the no
project alternative or determine the no project alternative to be infeasible and adopt a
Statement of Overriding Considerations for unavoidable significant air quality impacts.
8.03 CEQA guidelines stipulate that, "If the environmentally superior alternative is the no
project alternative, the EIR shall identify an environmentally superior alternative among
the other alternatives." The DSEIR did not evaluate a "modified no project" alternative
separate from and in addition to the "no project" alternative; as explained in response
to comment 8.01 above, the "modified no project" alternative referred to by the
commentor is the no project alternative evaluated in the DSEIR. The DSEIR (p. 260)
correctly determined that, of the three alternatives evaluated in the 1982 EIR other
than the no project alternative, the Concept Plan Alternative, because it would be less
intensive than the other alternatives, would result in the least adverse combination of
environmental impacts and would therefore be the "environmentally superior"
alternative.
8.04 Please see response to comment 8.01.
WP51 \548 \FSElR\F-/I. S48
CITY OF SOUTH SAN FRANCISCO
INTER-OFFICE MEMORANDUM
frEe
t/v
PEe t D
..}
p~ ~96
1VhVG
,
DATE:
TO:
FROM:
SUBJECT:
February 7, 1996 cRj ~. ~ .'A A-.l D
Steve Solomon ~ vv",--.
Cheryl Mitchell Wade, Stormwater Program Coordinator
Draft SEIR- Terrabay Project .
I have reviewed the draft SEIR for the Terrabay Project and offer the following comments:
a. Page 29 - Summary
Stormwater Regulations - Mitigation Measure (3) should be modified to state: Prepare a
Storm Water Pollution Prevention Plan (SWPPP) for City approval (by the City Engineer and/or
Stormwater Coordinator).......to control pollutants. City approval is necessary prior to issuance
of grading or other permits.
-
Gf.O(
b. The Applicant is listed as the responsible party for mitigation, and the applicant and owner are
synonymous. In the event that the owner sells the property, will the new property owner retain
responsibility for mitigating stormwater quality issues? Perhaps the responsible party should be
listed as Property Owner for clarification purposes.
-
Thank you for your continued cooperation. Feel free to contact me at ext. 8634 should you have
any question or concerns.
c: Lida Budko
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 81
9. Cheryl Mitchell Wade, Stormwater Proaram Coordinator, City of South San
Francisco; February 7, 1996
9.01 The comment suggests additional language to clarify the recommended mitigation for
Supplemental Impact 0-3. Pages 29 and 181-182 of the DSEIR have been revised to
add the suggested language. (See errata for DSEIR pp. 29, and 181-182 in section III
herein.)
WP51 \548\FSEIR\F-/I.548
Cal/oY111a Native plal1t Societ~ 10
Planning Division
City of South San Francisco
P.O. Box 711
South San Francisco, California 94083
Yerba Buena Chapter
338 Ortega Street, San Francisco, California 94122
14 February 1996
RECEIVED
. .. ,.' ;:\96
r.:. ~.i I t'",
RE: SEIR for Terrabay Specific Plan
PLANNING
Dear SirslMmes:
Grading for the Terrabay development since 1989 destroyed a grassland which was a rich
foraging area for wildlife. The SEIR admits to failure of revegetation attempts. This loss is ,0.0 I
probably irreparable and permanent Various references to "permanent" versus "temporary"
(ie. restorable) disturbance are misleading and doubtless inaccurate.
-
-
The graded portions have not only severe erosion problems but are nurseries for weeds which
are spreading into adjacent wild areas: fennel, radish, mustard., bristly ox tongue, pampas
grass, etc. Although many of these were present before Terrabay development began, 0"
disturbance has favored their proliferation. If the intent of the San Bruno Mountain Habitat 10. ~
Conservation Plan is to be honored, fees from Terrabay development should finance
complete eradication of these noxious weeds so that the native biological community will be
compensatorily strengthened.
-
-
The impacts created by proximity of human habitations to wild areas should be noted Not
only is there likelihood of increased human visitation on adjacent wild lands, the presence of
dwellings and human activity is discouraging and disturbing to wildlife, which in turn affect
the composition and performance of the plant community. Pets, especially cats and dogs, can
have adverse effects which should be noted in assessments of environmental changes.
-
Although listed butterflies are the raison d'erre of the SBM HCP, we consider that there is-
perhaps too much emphasis on plants which are of direct benefit to butterflies and
insufficient attention given the ecosystem which must support those plants. The mission blue
butterfly-supporting lupines tend to be short-lived and transient pioneers, so success in their
regeneration may be temporary. We are disturbed that., although the destruction of callippe-
silverspot is stated to be a minuscule part of its range, there has been zero success in -
regeneration of its larval food plant., Vwla pedunculala. .
-
IO.~
I tJ. 01'
I (). 0'$
-
From our point of view, the Terrabay development has been ecologically severely damavng-:-
Any amends we can make should be done. The SBM HCP, both at the congressional and
county level, contained sufficiently loose language from a biological point of view that the
plan can violate the spirit of the HCP without violating the letter. The lack of provision for
monitoring and evaluation was in our view unfortunate.
10. 0'
,to
cob Sigg, President 7 )
erba Buena Chapter
../
.,/.
~ Dedicated to the preservation of california native f[ora
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 83
10. Jacob SiQQs, President, Verba Buena Chapter, California Native Plant Society;
Februarv 14, 1996
10.01 The SEIR uses the terms "permanent disturbance" and "temporary disturbance" as
they are used in the San Bruno Mountain Habitat Conservation Plan (HCP):
Permanent Disturbance--the portion of a development envelope designated for
buildings, paving or private landscaping; area permanently lost as habitat (pp. G-S,-
6).
Temporary Disturbance--the portion of a development envelope designated for
grading at the time of development, but which will become reclaimed habitat after a
reclamation program is complete; area temporarily lost as habitat (p. G-9).
Of the approximately 80 acres of the site that were graded between 1989 and 1995 to
prepare for Phase I development, 50 acres were permanently disturbed and 30 acres
were temporarily disturbed and underwent habitat restoration in accordance with the
Terrabay Phase I Reclamation Plan, approved in 1988. However, the restoration work
failed as a result of the shut-down of the project and sale of the property (HCP
monitoring of development activities occurs only when a project is active), as well as
the unusually cold weather and subsequent drought during this period. A detailed
evaluation of the habitat restoration work performed for the applicant by Pacific Open
Space in May 1995 is included in Appendix C of the DSEIR. The failure of habitat
restoration has been identified in the DSEIR as Supplemental Impact VW-1 (DSEIR p.
197) and mitigation is recommended on DSEIR p. 198.
San Mateo County has indicated that the open space areas that are to be dedicated to
the county in accordance with the provisions of the HCP (Administrative Parcel 2-04-
02) will not be accepted until the habitat restoration failure is resolved, i.e., remediated,
and the county's "Standards for determining successful revegetation especially for
disturbed areas being reclaimed for conserved habitat and to be dedicated to the
County of San Mateo in accordance with the San Bruno Mountain Habitat
Conservation Plan are complied with (please see comment 35.01).
The applicant has indicated that all of the recommended habitat restoration remediation
work, including control of invasive weed species, was completed by Pacific Open
Space in October 1995 and most of it has been successful. The applicant has stated
that it may also contract with Pacific Open Space to monitor the success of the
remediation work and to fertilize and plant infill plantings to ensure successful
establishment (please see comment 32.08).
The HCP also provides for continual monitoring of biological processes, development
and conservation activities by the Plan Operator (Thomas Reid Associates, the SEIR
biologist) through the Habitat Manager (San Mateo County) to ensure that the HCP
WP51 \548\FSEIR1F-I/.548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 84
conditions with respect to mitigation of development areas are being met and to keep
an ongoing record of the progress of implementation (see comment 32.22).
10.02 The SEIR biologist concurs with the comment that exotic invasive pest plants have
proliferated in areas disturbed by project grading. As discussed in the response to
comment 10.01, the applicant has completed initial remediation of the onsite habitat
restoration "failures" in the temporary disturbance areas and intends to continue to
monitor these areas to ensure successful establishment of native habitat species.
The evaluation of the "success or failure" of restoration efforts is intended to occur over
the long term. Therefore, past problems in implementing the restoration effort have not
been "failures," but rather have been part of the process of long-term restoration plan
implementation.
10.03 The impact of human habitation next to wild areas was discussed in the 1982 EIR (p.
112) and in the EIR for the HCP. The issue of human habitation next to wild areas is a
fundamental project concern addressed in these two previous EIRs, and in the DSEIR,
though its references to the HCP. It does not represent a new or changed
circumstance that requires reevaluation in the SEIR. The EIR for the HCP notes that,
"While development will introduce permanent residents with near access to the open
space and while there will be no permanent fencing to keep them out, it is anticipated
that there will actually be a net benefit to open space form the Plan because of
continued patrolling of all areas of the mountain. Currently, the open space on [the
mountain} is already subjected to significant vandalism and vegetation destruction..."
The project would provide a buffer against illegal entry from the south slope and make
patrolling the area easier. Trails in the county park above the project site are
deliberately kept steep.
Although not required to mitigate a significant impact, Thomas Reid Associates, the
SEIR biologist and the Plan Operator for the HCP, has recommended that project
residents be educated about the potential impacts of human habitation next to wild
areas through the homeowners associations meetings, pamphlets, newsletters, etc.
Information should be provided about exotic invasive pest plants and domestic animals,
as well as about the sensitive habitats and endangered species of San Bruno Mountain
and the purpose and programs of the HCP. Provisions for such education and
community involvement of project residents should be included in the project CC&Rs
(i.e., covenants, conditions and restrictions) for Phase II (no residential development is
anticipated for Phase III). (The CC&Rs for Phase I have already been adopted.) In
this way, the project may foster a group of caring residents who will take pride in
protecting the mountain. For example, the education and involvement of the
homeowners in the Pointe Pacific development in Daly City has led to a diligent exotic
pest plant eradication and lupine cultivation effort.
10.04 The SEIR biologist concurs that in past years, HCP revegetation efforts emphasized
reestablishing host plants of the endangered butterfly species, along with a few other
WP51 \S48\FSEIRIF-II.548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 85
native herbaceous plants. However, along with the development of the field of
restoration ecology and increasing emphasis in that field on restoration of complete
native communities, restoration work on San Bruno Mountain has also come to
emphasize plant communities rather than specific species. Also, the setting description
and impact and mitigation findings presented in DSEIR Section IV.F, Vegetation and
Wildlife, are not limited to a discussion of the endangered butterflies.
10.05 The comment states that, although only a very small area of the Callippe silverspot's
habitat would be eliminated, there has been no success in regeneration of its larval
food plant. The SEIR biologist concurs that Viola is difficult to establish and that
transplantation of Viola has been attempted with limited success. Preservation of the
Callippe silverspot must depend on preservation of existing habitat rather than on
habitat restoration.
10.06 The HCP does provide for ongoing monitoring of biological processes, development
and conservation activities by the Plan Operator (Thomas Reid Associates, the SEIR
biologist) through the Habitat Manager (San Mateo County) to ensure that the HCP
conditions with respect to mitigation of development areas are being met and to keep
an ongoing record of the progress of implementation. However, monitoring of
development activities occurs only when a project is active. The Terrabay project was
not subject to monitoring during the period when the project was not active, which
contributed to the failure of previous habitat restoration. Now that the project is active
again, monitoring and evaluation will continue in accordance with the provisions of the
HCP. The San Bruno Mountain HCP is probably one of the most actively monitored
and evaluated of all HCPs due to a high degree of local involvement and the attention
the plan receives as the first HCP ever developed.
WP51 \548\FSEIR1F-/I.548
Airports
CoIlllDlssloI
::ty ana County
Jt San Franosco
'N,llte l Brown Jr'
MayOr
_ Anorew Jeanpoerre
:>'eSloenr
'~a"e K BrookS
"'ce Pre5lOel1l
Mlcnael 5 SlrunSky
=ioana A. Ouan
~ry Mazzola
JOHN l. MARTIN
J,rector 01 Airports
San Francisco International Airport
V
CArtWAY TO ntE PACIFIC
February 15, 1996
Mr. Steve Solomon
Secretary to the Planning Commission
City of South San Francisco Planning Division
P.O. Box 711
South San Francisco, CA 94083
RECEIVED
fEe 2 0 19~o
PlANNING
Subject:
Comments on the DSEIR for the Terrabay Specific Plan and
Development Agreement Extension
Dear Mr. Solomon:
II
Thank you for providing the Airport an opportunity to comment on the Terrabay
Specific Plan and Development Agreement Draft Supplemental EIR
The Mitigation Measure for Supplemental Impact N-3 should be restated so ~t the -,
applicant retain a qualified acoustical engineer, familiar with aviation noise impacts.
to recommend methods of design and construction to comply with the applicable 11.01
portions of Uniform Building Code, Title 24, Appendix 35, Sound Transmission
Controls, and with FAA Part 150 Noise Compatibility Program which states that all
single-family dwelling units construction achieve an indoor noise level of 45 dBA, as
measured for an aircraft noise event.
We appreciate your consideration of our comments
JC:nl
cc: David Carbone, San Mateo Co. ALUC
SAN FRANCiSCO INT!:RNATIONAL AIRPORT. SAN :RANCSCO CALIFORNIA 94128 . TELEPHONE 14151 761.0800. F~X 14151 876-7875
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR,
II. Responses to Comments on the Draft SEIR
Page 87
11. John Costas, Administrator, Plannina and Environmental Affairs, San Francisco
International Airport; February 15, 1996
11.01 The comment suggests additional language to clarify recommended mitigation for
Supplemental Impact N-2. Pages 35 and 228 of the DSEIR have been revised to as
suggested. (See errata for DSEIR pp. 35 and 228 in section III herein.)
WP51 \548\FSEIRIF-II.548
CITY OF SOUTH SAN FRANCISCO
INTER-OFFICE MEMORANDUM
RECEIVED (2
FEB 1 6 1996
PLANNING
DATE:
February 15, 1996
TO:
Lida Budko, Terrabay Project Planner
FROM:
Director, Parks, Recreation & community Services
SUBJECT:
Terrabay Draft S.E.I.R.
Upon review of the Terrabay Draft S.E.I.R., I have the following
comments:
Page #56; section d. Common community Facilities. Recreation and
O~en S~ace provisions
-
paragraph #7 states:
The City would operate and maintain the public roadways, Fire
Station 5, Hillside Recreation C~nter, the linear park, and all
the public landscaping within these public areas (including
within public roadway rights-of-way).
Page #208; section c. Parks and Recreation
,~Ol
item #3 states:
A linear park along Hillside Boulevard connecting the playing
fields at the Hillside Elementary School with Hillside Recreation.
Center (to be dedicated to and maintained by the City).
Each of these statements are in direct contradiction with the approved
Development Agreement (Exhibit "I" March 10, 1983; Section c) which
states:
The Developer or, with the approval of the City, a private
property owners association shall maintain the linear park
(Item A-3) and all private lands, buildings, landscaping,
and improvements in the project area.
I strongly prefer that the maintenance responsibility of the linear
park remain with the Developer, or private homeowners association, as
per the approved Development Agreement.
Feel free to contact me if you have any questions or comments.
~~1
Director, Parks, Recreation and Community Services
-
BNjwdc
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 89
12. Barry Na~el, Director, Parks, Recreation and Community Services, City of South
San Francisco; February 15, 1996
12.01 Please see response to comment 5.04.
WP51 \5481FSEIR\F-II.S48
United States Department of the Interior R E eEl V E D
FEB 2 0 1996
PLANNING
13
IN UPLYREfDl TO:
FISH AND WlLDUFE SERVICE
Ecological Servlca
Sacramento Field 0tIke
2800 Cottale Way, Room E-l80J
Sacramento, CaUforaJa 958~
l-1-96-TA-4l4
February 15, 1996
City of South San Francisco
Planning Division, Attn: Steve Solomon
P.O. Box 711
South San Francisco, CA 94083
Comments on the Draft Supplemental Environmental Impact
Report for the Terrabay Specific Plan and Development
Agreement Extension, San Mateo County, California
This letter responds to the notice from the City of South San Francisco (City)
of the availability for comment of the Draft Supplemental Environmental Impact
Report (EIR) for the proposed Terrabay Specific Plan and Development Agreement
Extension, dated January 5, 1996.
Subject:
Development on the site is addressed in the San Bruno Mountain Area Habitat
Conservation Plan of November 8, 1982, as amended (HCP) , wherein it is
referred to as the South Slope Project, within the Southeast Ridge planning
area. Part of the property is designated for permanent disturbance
(development) and the remainder as "Conserved Habitat," to be transferred to
the fee ownership of the County of San Mateo upon issuance of initial grading
permits. Based in part on the mitigations required by the HCP and the
Agreement with Respect to the San Bruno Mountain Area Habitat Conservation
Plan (implementing agreement), the U.S. Fish and Wildlife Service (Service)
issued a permit, pursuant to section 10(a)(1)(B) of the Endangered Species Act
of 1973, as amended (Act), authorizing incidental take of mission blue
butterfly (Icaricia icarioides missionensis) and callippe silverspot butterfly
(Speyeria callippe callippe) and other species. The two butterflies are
federally listed and proposed as endangered species, respectively; and occur
on the project site. Incidental take due to the development was projected at
3.22% of the mission blue butterfly population on San Bruno Mountain, and
0.46% of the callippe silverspot butterfly population (HCP, p. VII-l65).
. -
To remain exempt from the Act's prohibition against take of endangered
species, the project proponent must comply with the provisions of the HCP.
Specifically, these obligations include (pages VII-l66 through VII-l68 of the
HCP) :
1. Dedicate fee ownership of the area identified in the HCP as
administrative parcel number 2-04-02 to the County of San Mateo, to
provide conserved habitat. Part of this dedication--identified as
Phase One Dedication in Figure 2-04 J of the HCP, page VII-l77b,
dated 10/05/84--should already have been completed. l~.(){
Provide various funds for the implementation of the HCP.
2.
Revegetate temporarily disturbed areas according to a Reclamation
Plan approved by the City of South San Francisco.
The Supplemental EIR should address whether the project is in compliance with
these and other obligations stated in the HCP. If it is not in compliance, it
may no longer be covered by the incidental take permit issued by the Service
to parties of the implementing agreement. In such case, the Service would
3.
v
CONi.
Steve Solomon, Planning Division, City of South San Francisco
(JJiJT.
2-
recommend that the City withhold all development approvals, authorizations,
and permits until the project proponent has either achieved compliance, if
possible, or has obtained a separate incidental take permit from the Service.
-
The objective of the aicigat10ns stipulated in the HCP for the project in ~
question was, and continues to be, to minimize abrupt and protracted loss of
habitat for the two butterfly species. Due to past failures in revegetation
efforts, the current condition of the site is inconsistent with this
objective. Between 1989 and 1995, suitable habitat and the endangered
butterflies occupying it were taken by the.grading of 30 acres designated for
.temporary disturbance.. According to the Draft Supplemental EIR, restoration
of this disturbed area has failed, and .butterfly observation data for the
period 1991 to 1995 show little use of the restoration areas. (p. 197).
r;.ol
l~. 02..
Thus, the revegetation failure represents a prolonged, continuing, and
potentially serious i~act on the butterfly populations. The Service
-recommends '~~a~ the Cicy aeiay all authorizations and approvals for the
project until the project proponent demonstrates that a successful habitat
restoration effort is established and that sufficient funding for its future
implementation is assured. The Supplemental EIR should state success criteria
for the restoration of the areas designated for temporary disturbance, and
address the status, progress, funding, and future plans of the restoration
effort.
-
-
On page 184, the Draft Supplemental EIR states that two California state-
listed plants, Arctostaphylos pacifica and A. imbricata, and a federally
listed endangered plant, Lessinga germanorum germanorum, potentially occur on
the site. It should be noted that Arctostaphylos imbricata has been federally
proposed as threatened. The correct federal status of Lessingia germanorum I
germanorum is Proposed Endangered; we also understand it to be state-listed~
It is unclear whether recent site-specific surveys for sensitive plant speci~
have been conducted. Information regarding area surveyed, dates of the plant
survey, methods used for surveying, and a complete species list of plants
found on the site are lacking fro. the Draft Supplemental EIR. Site specific
survey should be performed for the Terrabay Specific Plan; surveys performed
in 1982 for the San Bruno HCP are too old. ____
11.03
11.04
-
The Service recommends that complete botanical inventories be made during the
pre-construction phase for individual projects. Special attention should be
paid to searching for the species listed in Table 23 of the Draft Supplemental
EIR, but surveys should not be restricted to those species. To ensure that
adequate botanical surveys have been performed, the Service recommends the
following minimum guidelines:
1. r-f a listed or proposed plant is known to occur within the same habitat
and the area of the project is within the historic range of the special
status plant, the botanlst(s) performing the survey should:
a) check nearby reference sites to observe the phenology of known ~~
populations t 7.V;I
b) make multiple site visits during the year to ensure surveying at
the appropriate phenological stage for each plant.
Results should be documented by photographs and by a written description
of the reference site(s), including information on phenology and
microhabitat. The dates of the surveys should be included.
2. The surveys should be floristic. They should not be conducted solely to
determine the presence or absence of a single rare plant species. A
regional list covering several counties should be examined for plants
occurring in the appropriate habitat. The site should be surveyed and a
complete species list provided. Plants should be identified to the
extent necessary to determine whether they are rare or endangered: e.g.,
v
"'NT.
Steve Solomon, Planning Division, City of South San Francisco
it is not sufficient to identify to genus if there are any rare plants
occurring in that genus.
Methods used for the plant survey need to be detailed in the Draft
Supplemental EIR, including
a) how the habitat on the site was inspected;
b) the dates the survey was performed;
c) what reference sites, if any, were visited; and
d) the flowering condition of plants at the tae of the survey
If any federally proposed or listed plants are found during the surveys
the Service recommends avoidance.
3.
Detailed information should also be provided in the Draft Supplemental EIR on
any aitigation plan proposed. ~
The last page or pages of Appendix C of the Draft Supplemental EIR (letter
report from Pacific OpenSpace, Inc. to Sterling Pacific Management Services)
appears to be missing. This report is also incorrectly cited as Appendix E on
page 198.
Thank you for providing the opportunity for the Service .to comment on the
Draft Supplemental EnviroDlllental Impact Report for the proposed Terrabay
Specific Plan and Development Agreement Extension, dated January 5, 1996. If
you have any questions about these comments, please contact David Vright, at
(916) 979-2739 ext. 408, regarding butterflies, and Kirsten Tarp, at {9l6)
979-2120, regarding plants.
Sincerely,
-O~A /U~.
a:l A. M~d~n
Field Supervisor
cc: ES, Portland, OR
Carl Vilcox, EnviroDlllental Services Supervisor, CDFG
Roman Gankin, San Mateo County Planning Department
Thomas Reid Associates
Brian Gaffney, Bay Area Land Vatch
CDNr.
3
I'J.O~
11.~
--'
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 93
13. Joel Medlin, Field Supervisor, U.S. Fish and Wildlife Service; February 15, 1996
13.01 The comment does not pertain to the adequacy of the SEIR. The SEIR need not
analyze compliance of project Phase I (which has already been approved) with the
conditions of approval (Le., HCP compliance). Such compliance verification is not a
CEQA-identified EIR content requirement, but rather is a previous 1982 EIR
implementation monitoring issue. The SEIR is not required to analyze non-compliance,
except where non-compliance represents a significant new environmental impact under
one of the conditions specified in the CEQA Guidelines for preparation of a
supplemental EIR.
Thomas Reid Associates, who is both SEIR biologist and Plan Operator for the HCP,
has confirmed that the project is in compliance with the HCP and that the applicant is
current with all HCP funding obligations (please see comment 32.10).
The applicant has prepared a grant deed to submit to San Mateo County for the open
space areas that are to be dedicated to the county in accordance with the provisions of
the HCP (Administrative Parcel 2-04-02). The county has indicated that Administrative
Parcel 2-04-02 will be accepted when the habitat restoration failure, erosion and
landslide issues involving this parcel are resolved and the county's "Standards for
determining successful revegetation especially for disturbed areas being reclaimed for
conserved habitat and to be dedicated to the County of San Mateo in accordance with
the San Bruno Mountain Habitat Conservation Plan" are complied with (please see
comment 35.01).
The restoration of those habitat areas that were "temporarily disturbed" by grading for
Phase I of the project was performed by the previous property owner in accordance
with the HCP-required Terrabav Phase I Reclamation Plan ("reclamation plan").
However, the restoration work failed as a result of the shut-down of the project and
sale of the property, as well as the unusually cold weather and subsequent drought
which occurred during this period. A detailed evaluation of the habitat restoration work
and recommended remediation measures prepared for the applicant by Pacific Open
Space in May 1995 is included in Appendix C of the DSEIR. The failure of habitat
restoration has been identified in the DSEIR as Supplemental Impact VW-1 (DSEIR p.
197) and mitigation is recommended on DSEIR p. 198. The applicant has indicated
that the recommended remediation work was completed by Pacific Open Space in
October 1995 and most of it has been successful. The applicant has indicated that it
may also contract with Pacific Open Space to monitor the success of the remediation
work and to fertilize and plant infill plantingsto ensure successful establishment
(please see comment 32.08).
The fact that habitat restoration has not yet been completely established does not
represent non-compliance with the HCP. The HCP only requires that the applicant
implement the approved reclamation plan prior to granting the necessary final project
approvals, and that the Plan Operator monitor the results. Continued development of
WP51 \548 \FSEIR\ F-II. 548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 94
the project while the restoration work is being performed will not affect the success of
restoration activities.
13.02 Again, the fact that habitat restoration has not yet been completely established does
not represent non-compliance with the HCP. The HCP only requires that the applicant
implement the approved reclamation plan prior to granting the necessary final project
approvals, and that the Plan Operator monitor the results. Continued development of
the project while the restoration work is being performed will not affect the success of
restoration activities. As explained in the response to comment 13.01, the approved
Terrabav Phase I Reclamation Plan has been implemented. As explained in the
response to comment 10.06, monitoring of project development activities by the Plan
Operator will continue.
The success criteria applicable to the habitat restoration effort are those contained in
the approved reclamation plan and in the county's "Standards for determining
successful revegetation especially for disturbed areas being reclaimed for conserved
habitat and to be dedicated to the County of San Mateo in accordance with the San
Bruno Mountain Habitat Conservation Plan." The county has indicated that
Administrative Parcel 2-04-02 will not be accepted until the habitat restoration failure is
resolved and the county's revegetation standards are complied with (please see
comment 35.01). The success of the restoration effort is also evaluated as part of
ongoing HCP monitoring, evaluation and reporting activities.
The evaluation of "success or failure" or restoration efforts is intended to occur over
the long term. Therefore, past problems in implementing the restoration effort have not
been "failures," but rather have been part of the process of long-term restoration plan
implementation.
13.03 The comment notes changes in the listing status of sensitive plant species identified on
DSEIR p. 184. The SEIR has been revised to reflect the current listing status of these
plant species. (See errata for DSEIR p. 184 in section III herein.)
13.04 Sensitive plant surveys of the project site were not conducted specifically for the SEIR.
However, the discussion of sensitive plant species in the DSEIR is based on annual
surveys of sensitive plants on San Bruno Mountain and the project site conducted by
the Plan Operators--i.e., the SEIR biologists, including Mr. Lion Baumgartner. Mr.
Baumgartner, whose work on San Bruno Mountain is funded by the HCP, is an expert
on plant identification and particularly on the identification and distribution of the rare
plants of San Bruno Mountain. Mr. Baumgartner provided invaluable information on
plant distribution for the 1990 book A Flora of the San Bruno Mountains. He has
tracked known rare plant locations on the mountain for the past 14 years and has
performed a detailed count of Helianthella castenea populations for the HCP 1995
Annual Report. Mr. Baumgartner is familiar with the project site, having conducted rare
plant searches, butterfly monitoring studies, and bird surveys there throughout the
years. Mr. Baumgartner has searched the project site many times in the past and has
WP51 \548\FSEIRIF-II.S48
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 95
not seen any rare plants on or near the site.. Based on Mr. Baumgartner's experience
and knowledge of the mountain, detailed floristic surveys were deemed to be
unnecessary for the SEIR.
13.05 Please see response to comment 13.04.
13.06 The Pacific Open Space letter report is five pages long and all of the pages are
included in Appendix C. The incorrect reference to Appendix E on DSEIR p. 198 has
been corrected. (See errata for DSEIR p. 198 in section III herein.)
WP51 \548\FSEIR\F-II.S48
STATE OF CALlFORNIA-8USINESS. TRANSPORTATION AND HOUSING AGENCY
PETE WILSON. Go..mor
t+
DEPARTMENT OF TRANSPORTATION
sox 23660
OAKLAND. CA 9~23-0660
{S 1 0) 286-44U .
TOO (510) 2~
RECEIVED
FEB 2 2 1996
PLANNING
February 16, 1996
SM-101-23.39
SCH#9S092027
SM101212
Ms. Uda Budko
City of South San Francisco
Planning Division
400 Grand Avenue
South San Francisco, CA 94080
Dear Ms. Budko:
Re: Draft Supplemental Environmental Impact Report for the Terrabay
Specific Plan and Development Agreement Extension - The proposed project is a
phased residential and commercial/office development approved in 1982. Phase I,
currently under construction, consists of 125 single family units and 168 townhomes
and related community facilities and infrastructure.
Thank you for including the California State Department of Transportation
(Caltrans) in the environmental review process. We have reviewed the above
referenced document and forward the following comments:
~
-
. On Page 147, Figure 25, Year 2010 Base Case Plus Project Phases I, IT and ill
Mitigations Needs, shows that Bayshore Boulevard will require extensive widening
to accommodate the traffic volume. Is this feasible without any effect on State right- ILDf
of-way and/or on the development on the westerly side of it? Will there be adequate ,.
facility to accommodate a four-lane southbound Route 101 offramp without traffic
backing up onto the freeway? Will Oyster Point Boulevard between Airport .
Boulevard and Dubuque A venue be overloaded even though the signals are
coordinated?
-
Bu~/S~101212
February 16, 1996
Page 2
General Comments: -
. Page 109, Table 10 - The note with two asterisks are not indicated on this table. rtot
-
. It is stated both on Page 114, last paragraph and page 129, section f, second -
paragraph that, "A two percent increase in traffic volume due to project trip
generation was selected as the significance criterion for intersections or freeway (4- .0;
facilities that already exceed unacceptable levels of service (LOS)...." The following
statement should be made clear to the San Mateo County Congestion Man~gement
Agency (CMA). .....
. Page 119, Table 15 - Project Trip Distribution-PM Peak Hour, shows local streets 14-.0'\"
and freeways. This data, should be shown on a plot map which is easier to follow.
-
We appreciate the opportunity to work with you on this project and wish to
continue close correspondence on its development. Should you have any questions
regarding these comments, please contact Melinda Pagaduan of my staff at (510) 286-
5544.
Sincerely,
JOE BROWNE
District Director
By:
(lQ,,~~ ~
PHILLIP Bi;J'lL
District Branch Chief
IGR/CEQA
cc: Chris Belsky, SCH
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 98
14. Phillip Badal. District Branch Chief. California Department of Transportation;
February 16. 1996
14.01 The DSEIR recommended two optional mitigation approaches for traffic impacts at the
Sister Cities Boulevard/Oyster Point Boulevard/Bayshore Boulevard/Airport Boulevard
intersection (Supplemental Impacts T-5, T-6, T-B and T-12): (1) intersection
improvements or (2) a southbound flyover off-ramp from southbound US 101 to
eastbound Oyster Point Boulevard. The first mitigation option, which would require
extensive widening of Bayshore Boulevard, including triple left turn lanes at Oyster
Point Boulevard, has since been eliminated from consideration. The remaining
mitigation option, the southbound flyover off-ramp to eastbound Oyster Point
Boulevard, which was approved by Caltrans as part of the Oyster Point interchange
reconstruction EIR, has been retained as the only feasible mitigation for these impacts.
Using revised Base Case 2010 traffic volume projections (which, even after eliminating
trip reductions resulting from the BAAQMD employer-based trip reduction rule in
response to comment 32.82, are approximately the same as those presented in the
DSEIR), it will now not be possible to provide acceptable year 2010 operation at the
Oyster Point Boulevard/Dubuque Avenue intersection, even with the flyover ramp. In
turn, it will also not be possible to provide acceptable traffic flow between this location
and the Sister Cities Boulevard/Oyster Point Boulevard/Bayshore Boulevard/Airport
Boulevard intersection, even after mitigation. The flyover off-ramp represents the
maximum practical physical mitigation. However, as indicated in the revised
transportation section which was recirculated for public review on August 30, 1996 and
which is included in section III herein, the significant impact identified at this location
can be further reduced to less than significant levels through implementation of
voluntary transportation demand management measures (TDM).
With the southbound flyover off-ramp mitigation, only three lanes will be needed on the
new southbound button hook off-ramp connection to Bayshore Boulevard.
14.02 The footnote designated by two asterisks does not pertain to Table 10. The footnote
has been eliminated in the traffic analysis errata. (See p. 110 of the revised
transportation section in section III herein).
14.03 The City/County Association of Governments of San Mateo County, which is the
congestion management agency (CMA) responsible for the county's congestion
management program, does not provide significance criteria in their most recent (1995)
document for roadway segments projected to be operating at unacceptable levels in
the future.
14.04 Due to the large number of graphic figures already presented in the DSEIR traffic
analysis, percent distribution patterns were listed in a table, an approach which
represents common practice. Phase I and total project (phases I, II and III) AM and
PM peak hour volumes are shown distributed on the local roadway network in five
separate DSEIR exhibits (Figures 13, 15, 17, 19, and 23).
WP51 \548IFSEIR\F-II.548
h6 /~J2/~y~
RECE\'JEO l6"
FEB 2 01996
pLANN\NG
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~
SOCIETY for CALIFORNIA ARCHAEOLOGY
E. Breck Parkman
2560 Meier bad
Scbastopol, CA 9S~72
Fcbruuy 14, 1996
Jercune 1rwin
SID B1U1l0 Mountain Watch
I'? .02..
Dear Jerome:
As pcr our conversation today, 1 WIJIt to reiterate .t 1 said <:ODccming the significance of San Franciico
Day sheDmounds, mcluding archaeological sites CA-SMA-40, CA-SMA-92, IDd CA-SMA-234 on the lowa'
slopes of San Bruno Mountain.
Whereas there WCTC once severl1 hundred sheDmound.c; lining San FrlDclsco liay, the vast majomy of
these have been destroyed or severely iIllpacted by the dovc1opment of the area. Many of the sites were destrOyed
without the bencr1t of archaeological investigation, thus we are presented with an incomplete picture ofJocaJ
prehistory. However, even impacted si1cs uc capable of sbeddmg DCW light on the past. Therefore, it it.
imperative that an of tho remaining sheJ1mounds, rcgardlclS of their slatuS, bc preserved.
In addition to their great scientific significance, these llites constitute sacred burial groUDda which are
a1forded legal prolcctiOO. A. we both know, basic humID morality rnandal~ respect for the dead. Thus, there arc
scientific, legal, and moral reason. for why the sheDmounds should be protected.
Good luck to you and the San Bruno Mountain Watch in helping to protect the sheDmounds in your
COJnl11UDity .
Sincem.y,
/17
E. Breck Parkman
President-Elect
77te .,><<",,).jtJr (."Ili(fnmf'I/1rriHletHnf.v /. Mdlr_.d,I' IIw t'rJt_il. .tllp,rsltuHiillJ:. ,.,."'t""';OI\ tmd ;'''.ryo'''otl'''' t1f("uJlfnm/n" '''r:'-'''4!lr.nlIY''''..rr...
INTERNATIONAL INDIAN TREATY COUNCIL
I...OHMAIIUN OI-HCi
,. MINT $TREE'T,400 SAN rJ:V,NCloco. CA ~103
TEL!PMONf: (416) 51Z.1001
. fAX ("15) 512.1501
0Ml1. 'PEAC€ NFT. 1m':
Yebrulr')' 14, 1996
San Brunu YOWllain W ^ TC
P.O. Bol 040
BriabanA, CA 94005
c/o: .Jerome Irwin
JOO Alctr.r Avr.nue
Colma, CA 945015
Fax: 41~-467.1838
Dear Mr. Jrwln.
'Jbe Jntcrnatlunallndlan 'fRat)' Co~..dl(UTC), a llnlted Nations non-goVCrDlMntal
organlzatlon wft)\in the 'F.cunomlc and' Social Coundl with consultative status. - "..n."
catqury n since 1977.15 In lIUpporl oftbe San Bruno Muuntain Watcb proposal for ,';.V7
tb.. preservation or San Mateo 40, 92, and 234 Archaeological Sites on San KroDll
Muuntaln as the t'uclcull of an Ohlon,e Cultural Property Pre~n'e.
-
. -
Tbe shell mounds In South San YranclSco In particular have lun$t been recogni1.cd u
traditional cultural hcritagtl of IndlRCn(lu~ peopJ~ and of sp<'Cial in\er~t to
C.allfornia and naUullallndlan nations; and muth tonstemation C1prcssrd about the
thrE'8t to the sacred ~i~ because of t'n(.roachln$t "denlopment" and the lack of
rcliKiuus tolcranct' to tll(' traditional ~pirttual practices of Jndtgenous pcopll"S.
(?04t ~
-
Thi~ i!ll currcnUy a nlatter of Inte~st at the ,rnlted Nations who at this moment are
also c:nnducting 5tudies nn tb~ protection of the cu..~ural and Intellectua. pruperty o~
Indigenous Peopl~ of tbe 'World. It m:ms that tOclay Indigenous peoples continue to
tk' the only peopl~ In tht' way of" progn:.oc.""" and" "developmenl". It. Is an hononbl('
position bcaU5l' S3(rcd objects, !Stories and ceremonies or pa.~t and pn-sent .re a
C'omplctr lmowlcdR<' system and concepts ~th !lCienUne and logiral validity.
"Jbt' tbrust of tht' u.~. invulvement comes from the, principle that "t-very propl" has
the right and th(' duty to de\'elop Its culture". adupled by the Gt-nf'ral C.onferen<<"' of
l ~NJo~SCO In Artlde I of the l INl":SCO Declaration oft.hc Prin('ipt~ of International
Cultural anti Cn-operatlon (4 November 1966). Indigcnou5 peoples haw repeatfdly
l'xpressed their wtllingnt'SS to shll~ their usefullmowled~e with aU humllOity.
pro'\'idcd that. their fundamental rights to define and controi t.his knuwledgc are
protecttd by the inlcrnuliunal community.
~ ~t;.i;... ...en-'
^cl..unJill~11, th~ UTe calb on the South San FnndSC() Planning CcmlmlJSlon to
pro\o1dE' all the nKtsSal')" ",rrUN of Involvement of Indigenous poopleta In" pal1Mnhlp
with all deejsk)os .lTtdtna !Mlr IWelI ,,'Ith reg.rd to tho "nd on and around the .MlI
mound. of Sa.. Uruno. TIw JlTC further request. thero be . moratorium on ."~
fUrther dl!M;WlSlvn!l rCKardlng t.bis matter until tho lncllgcfto.... communlt1os.". prior
Inrormed and have C(m.'tented too tho pcnd1nc plan..
'J1I. n N. d~1ared "Intc.'maUonal Decade oriM World's lndAgenuus Peuplelt..
1lec;anber', '994 with the purpose or encouraginR lcn'CmmOllts and InltltuUoDS to
bcglu tu wurk. qether "in partDcnhlptt with Jndlacn.OWI poopIH on all ..u.r
an-edJog their llva With this In mind It l~ the desire urthe IITC. rep~ over
90 tradlt.ionaI Indlal'nous naUons In the Americas .nd PaclOc Jslands, the South Sin
JtranclKo PlannlDK Cummlsslon coIL"Jder the protec:tIun or the he~e of Indigenous
peoples.
If J n18Y be of further lLocsbtance please call me at your earliest cnnnnlcnee. Thank
you for )'Uur dtenUon.
Sincinly, ~
~
Antonio ("..0 es
UTe UN. UaLlCOD
c.c. United Nations Center for lJuman Rlabts-GeDel'a
UN~O-Paris
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T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 104
15. Jerome Irwin, 100 Alden Avenue, Corma: February 16, 1996
15.01 Comment acknowledged. Please see response to comment 1.07,
15.02 Comment noted. Please see response to comment 1.07,
15.03 Comment noted. Please see response to comment 1.07,
15.04 The DSEIR was circulated to the Native American Heritage Commission (NAHC) by
the State Clearinghouse. Please see comment letter 17 and the attached distribution
form. In addition, when Phase III is to be developed and comes before the city for
required precise plan approval in the future, more specific information about the
development plan would be submitted and additional, more detailed environmental
review, possibly including additional archaeological investigation of site CA-SMa-40
and formulation of more detailed cultural resources mitigation, will be undertaken at
that time (see response to comment 1.02).
There will also be additional opportunities for involvement of indigenous communities in
the process at public hearings and adequate notice and availability of the subsequent
environmental documents for review and comment. In the event of discovery or
recognition of any Native American human remains, the Native American Heritage
Commission would be coordinated with and a descendant identified, and all applicable
requirements of the state CEQA guidelines for notification and reinterment would need
to be complied with.
WP51 \548\FSEIRIF-I/.548
l(o
Planning Department
City of South San Francisco
P,O.Box 711
South San Francisco, CA 94083
RECEIVED
FEe 2 0 1996
PLANNING
February 18, 1996
Dear Planners.
I have read the Terraby Draft SEIR. and find the Supplemental Mitigation Needs and
remedies sections to be quite inadequate,
. -..
-
The reality of the T errabay situation for the last 4 years was stated fairly well in your
report. Restoration efforts there failed miserably: "severe erosion, a sparse cover
of native plants, and vigorous spread of invasive pest plants in almost all
reclamation areas." In other words. rare butterfly and plant habitat has been taken
away. as called for in the plan. putting endangered species at risk of extinction. But in
the same 7 years. plans to protect these species failed. This is the major weakness of
this plan: It is easy to destroy habitat and species but it is difficult, under the best
conditions. to restore or recreate it. Under normal or adverse conditions. its ".Or
impossible. The developers got what they wanted, in advance. and then could not
hold up their end of the deal to protect the species whose habitat they took.
Any new plan should have as a primary condition that the "remedies. be successfully
employed first. BEFORE new construction is begun. That is the model used in other
sensible. successful human endeavors. For example. before a new medicine is used I
on a patient. that medicine undergoes thorough testing. Before a new construction
technique is used to build a skyscraper. it undergoes testing on a smaller scale,
BEFORE ANY MORE HABITAT IS DESTROYED FOR THIS DEVELOPMENT. THE
MITIGATION MEASURES SHOULD UNDERGO A COMPLETE TEST TO SHOW THAT
THEY WORK. So far. ALL INDICATIONS ARE THAT THEY DO NOT.
Respectfully. \
~/tl~
Ken Mcintire
San Mateo County resident
T errabay Project
City of South San Francisco
October 23. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 106
16. Ken Mcintire; February 18, 1996
16.01 Please see responses to comments 13.01 and 13.02.
WP511548\FSEIR\F-II.548
,7ATE OF CALIFORNIA
PETE WILSON, Governor
February 20, 1996
RECEIVED
FEB 2 1 1996
PLANNING
.'""""".
J. ..
.
7
Governor's Office of Planning and Research
~ 400 Tenth Street
3acramento, CA 95814
LIDA BUDKO
CITY OF SOUTH SAN FRk~CISCO
400 GRAND AVENUE
SOUTH SAN FRANCISCO, CA 94080
Subject: TERRABAY SPECIFIC PLAN AND DEVELOPMENT AGREEMENT SCH #: 95092027
Dear LIDA BUDKO:
--.
The State Clearinghouse has submitted the above named draft Environmental Impact
Report (EIR) to selected state agencies for review. The review period is now closed
and the comments from the responding agency(ies) is (are) enclosed. On the enclosed
Notice of Completion form you will note that the Clearinghouse has checked. the
agencies that have commented. Please review the Notice of Completion to ensure that
your comment package is complete. If the comment package is not in order, please
notify the State Clearinghouse immediately. Remember to refer to the project's
eight-digit State Clearinghouse number so that we may respond promptly.
Please note that Section 21104 of the California Public Resources Code required
that:
"a responsible agency or other public agency shall only make substantive
comments regarding those activities involved in a project which are within
an area of expertise of the agency or which are required to be carried out
or approved by the agency."
11.0 I
Cowmenting agencies are also required by this section to support their comments with
specific documentation.
These comments are forwarded for your use in preparing your final EIR. Should you
need more information or clarification, we recommend that you contact the commenting
agency (ies) .
This letter acknowledges that you have complied with the State Clearinghouse review
requirements for draft environmental documents. pursuant to the California
Environmental Quality Act. Please contact Kristen Derscheid at (916) 445-0613 if
you have any questions regarding the environmental review process.
Sincerely.
~-tb4'Y~d.J~.dl:-;
)" - '. ..~
ANTERO A. RIVASPLATA
Chief. State Clearinghouse
E:lclosures
cc: Resources Agency
Terrabay Project
City of South San Francisco
October 23. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 108
17. Antero Rivasplata, Chief, State Clearinahouse, Governor's Office of Plannina and
Research; February 20, 1996
17,01 Administrative and procedural explanations; no response is necessary.
WP51 \548IFSEIRIF-I/.548
S7ATE OF CALIFORNIA
CALFQRNLA. REG~ WATER QUAUTY CONTROL BQt\RD
SAN FRANCISCO BAY REGION
2101 WEBSTER STREET. SUITE 500
OAKUHD. CA ~6'2
18
pm WILSON. Governor
.TEL: (SI0) 2&6-1255
'FAX: (S10) 2&6.1380
BSS: (S10) 2S6-~~
e....
.' "i
.,
,
.. '
Lida Budko
City of South San Francisco
400 Grand A venue
South San Francisco, CA 94080
August 10, 1995
File No. 2118.04 (pGS)
C PLAN AND DEVELOPMENT AGREEMENCSION
... '. 2 --). 0 - f 6
Dear Ms. Budko , J4N 12 .......
W ~ have received the captioned environmental ~ocuplent and offer. ~~followin~ guidance as :0 i~sues with (~. 0 I
which we are concerned. In the absence of speclfic language descnbmg the project and potenuallmpacts, .
we are assuming water quality concerns may not be adequately addressed.
General Comments
The San Francisco Regional Water Quality Control Board (Regional Board or RWQCB) is charged with the
protection of the Waters of the State of California in the San Francisco Bay Region, including Wetlands and
Storm Water Quality. The Regional Board is responsible for administering regulations established by the
Federal Clean Water Act. Additionally, the California Water Code establishes broad state authority for
regulation of water quality. The San Francisco Bay Basin Water Quality Control Plan (Basin Plan) explains
the Regional Board's strategy for regulating water quality. The Basin Plan also describes the range of
responses available to the Regional Board with regards to actions and proposed actions which degrade or
potentially degrade the beneficial uses of the Waters of the State of California.
NPDES
~
Water quality degradation is regulated by the Federal National Pollutant Discharge Elimination System
(NPDES) Program (established by the Clean Water Act), which controls and reduces pollutants to water
bodies from point and nonpoint discharges. In California the program is administered by the California
Regional Water Quality Control Boards. The Regional Board issues NPDES permits for discharges to If.02
water bodies in the San Francisco Bay Area, including Municipal (area- or county-wide) Stormwater
Discharge Permits. .
Projects disturbing more than five acres of land dUring construction must be covered under the State
NPDES General Permit for Discharges of Storm Water Associated with Construction Activity, This can b:
accomplished by filing a Notice of Intent. The project sponsor must propose and implement control
measures that are consistent with this State Construction Storm Water General Permit, and with
recommendations and policies of the local agency and the RWQCB.
!
f' r ,L(
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'-,
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(~f:) ..-
i
CPNT:
Projects that include facilities with discharges of Storm Water Associated with Industrial Activity must be
covered under the State NPDES General Permit for Discharges of Storm Water Associated with Industrial
Activity, This may be accomplLhed by filing a Notice of Intent. The project sponsor must propose control
measures that are consistent with this, and with recommendations and policies of the local agency and the
RWQCB. In a few cases, the project sponsor may apply for (or the RWQCB may require) issuance of an (8.02
individual (industry or facility specific) permit.
The RWQCB's Urban Runoff Management Program requires Bay Area municipalities to develop and
implement storm water management plans (SWMPs). The SWMPs must include a program for
implementing new development and construction site storm water quality controls. The objective of this
component is to ensure that appropriate measures to control pollutants from new development are considered
during the planning phase, before construction begins; implemented during the construction phase; and
maintained after construction throughout the life of the project.
-
--
IMP ACTS AND MITIGATION MEASURES
Wetlands
-
Wetlands enhance water quality through such natural functions as flood and erosion control, stream bank
stabilization, and filtration and purification of contaminants, Wetlands also provide critical habitats for
hundreds of species of fish, birds, and other wildlife, offer open space, and provide many recreational
opportunities. Water quality impacts occur in wetlands from construction of structures in waterways.
dredging, filling, and altering drainage to wetlands.
The Regional Board must certify that any permit issued by the U.S. AnDy Corps of Engineers pursuant to
Section 404 of the Clean Water Act (covering dredging or filling ofwetJands) complies with state water
quality standards, or waive such certification. Section 401 Water Quality Certification is necessary for all
404 Nationwide permits, reporting and non-reporting, as well as individual permits. (0.07
All projects must be evaluated for the presence of jurisdictional wetlands. Destruction or impact to wetlands
should be avoided. 401 Certification may be denied based on significant adverse impacts to "Waters of the
State", The goals of the California Wetlands Conservation Policy include ensuring "no overall net loss and
achieving a long-term net gaiu in the q\la1itit)', quality, and permanence of wetlands acreage and values."
In the event wetland loss is not unavoidable, mitigation will be preferably in-kind and on-site with no net
destruction of habitat value. Mitigation will preferably be completed prior to, or at least simultaneous to,
the filling or other loss of existing wetlands. ~uccessful mitigation projects are complex tasks and difticult
to achieve. This issue \\oill be strongly considered during agency review of any proposed wetland fill.
Wetland features or ponds created as mitigation for the loss of existing "jurisdictional wetlands" or "waters
of the United States~' cannot be used as storm water treatment controls.
Storm Water Quality Control
-
Storm water is the major source of fresh water to creeks and waterways. Storm water quality is affected by
aa .\t'l~tety ~f landbusthes ant d the Pfiollutadnts genlertated by these l~cti~'ities. Dewvelopment and construction 1.,*
c '. i ies cause 0 si e-speci IC an cumu a ive water qua Ity Impacts. ater quality degradation may
occur during construction due to discharges of sediment, chemicals and wastes to nearby storm drains or
creeks. Water quality degradation may occur after construction is complete due to discharges of petrokum
,r
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;
wW(.
hydrocarbons, oil, grease and metals from vehicles, pesticides and fertilizers from landscaping, and bacteria
from pets and people. Runoff may be concentrated and storm water flow increased by newly developed I
impervious surfaces, which will mobilize and transport pollutants deposited on these surfaces to storm drains
and creeks. Cumulatively, these discharges will increase pollutant loads in creeks and wetlands within the
local watershed, and ultimately in San Francisco Bay.
To assist municipalities in the Bay Area in complying with an area-wide NPDES Municipal Storm Water
Permit or to develop a Baseline Urban Runoff Program (if they are not yet a co-permittee with a Municipal
Storm Water Permit), the Regional Board distributed the Staff Recommendations for New and
Redevelopment Control for Storm Water Programs (Recommendations) in April 1994. The
Recommendations describe the Regional Board's expectations of municipalities in protecting stonn water
quality from impacts due to new and redevelopment projects, including establishing policies and
requirements to apply to development areas and projects; initiating appropriate planning, review, approval
and inspection procedures; and using best management practices (BMPs) during construction and for
post-construction.
-
Project impacts should be minimized by developing and implementing a Stonn Water Pollution Prevention
Plan (SWPPP). A SWPPP is required by the State Construction Storm Water General Permit The SWPPP
should be consistent with the terms of the State Construction Storm Water General Permit (if the site is l&Pt
greater than five acres), the Manual of Standards for Erosion & Sedimentation Control Measures by the
Association of Bay Area Governments (ABAG), policies and recommendations of the local urban runoff
program (city and/or county) and Recommendations of the RWQCB. SWPPPs should also be required for
projects that may have impacts but are not required to obtain an NPDES permit. Preparation of an SWPPP
should be a condition of development. Implementation of the SWPPP should be enforced during the
construction period via appropriate options such as citations, stop work orders or withholding occupancy
permits.
Impacts identified should be avoided and minimized by developing and implementing the following types of
controls.
Site Plannini
The project should minimize impacts from project development by incorporating appropriate site planning
concepts. This should be accomplished by designing and proposing site planning options as early in the
project planning phases as possible. Appropriate site planning concepts to consider include, but are not
limited to the following:
- Phase construction to limit areas and periods of impact;
- Minimize directly connected impervious areas;
- Preserve natural topography, existing drainage courses and existing vegetation;
- Locate construction and structures as far as possible from streams, wetlands, drainage areas, etc.;
- Reduce paved area through cluster development, narrower streets, use of porous pavement or retaining
natural surfaces;
- Minimize use of gutters and curbs which concentrate and direct runoff to impenneable surfaces;
- Use existing vegetation and create new vegetated ('.reas to promote infiltration;
- Design and layout communities to reduce reliance on cars;
"
3
COMT:
;
(pN'(:
- Inclupe green areas for people to walk their pets. thereby reducing build-up of bacteria, worms, viruses.
nutrients. etc, in impermeable areas (or institute ordinances requiring owners to collect pets' excrement):
- Incorporate low-maintenance landscaping;
- Design and layout streets and stomi drain o:ystems to facilitate easy maintenance and cleaning;
- Consider need for runoff collection and treatment systems; and
- Label storm drains to discourage dumping of pollutants into them.
Erosion
The project should minimize erosion and control sediment during and after construction. This should be
done by developing and implementing an erosion control plan, or equi....alent plan (which should be included
in the S\VPPP). The plan should specify all control measures which will be anticipated or used including.
but not limited to, the following:
- Limit access routes and stabilize access points;
- Stabilize denuded areas as soon as possible with seeding, mulching or other effective methods;
- Protect adjacent properties with vegetative buffer strips, sediment barriers or other effective methods;
- Delineate clearing limits, easements, setbacks, sensitive areas, vegetation and drainage courses by marking
them in the field;
- Stabilize and prevent erosion from temporary conveyance channels and outlets; and
- Use sediment controls and filtration to remove sediment from water generated by dewatering or collected
on site during construction. For large sites, stormwater settling basins will often be necessary, ~~
Chemical and Waste Mana2ement
The project should minimize impacts from chemicals and wastes used or generated during construction.
This should be done by developing and implementing a plan or set of control measures (that should be
included in the SWPPP). The plan should specify all control measures which 'will be anticipated or used,
including. but not limited to the following:
- Designate specific areas of the site, away from streams or storm drain inlets, for storage, preparation and
disposal of building materials, chemical products and wastes;
- Store stockpiled materials and wastes under a roof or plastic sheeting;
- Store containers of paints, chemicals, solvents, and other hazardous materials stored in containers under
cover during rainy periods;
- Berm around storage areas to prevent contact witil runoff;
- Cover open dumpsters securely with plastic sheeting, a tarp or other cover during rainy periods;
- ~esignate specific areas of the site, away from streams or storm drain inlets, for auto and equipment
parking and for routine vehicle and equipment maintenance;
- Routinely maintain all vehicles and heavy equipment to avoid leaks;
- Perform major maintenance, repair, and vehicle and equipment washing off-site, or in designated and
controlled areas on-site;
- Collect used motor oil, radiator coolant or other fluids with drip pans or drop cloths;
- Store and label spent fluids carefully prior to recycling or proper disposal;
- Sweep up spilled d:;.' materials (cement, mortar, fertilizers, etc,) immediately- do not use water to wash
them away:
4
\1
GOut
(OW(:
- Clean up liquid spills on paved or impermeable surfaces using "dry" cleanup methods (e.g., absorbent
materials, cat litter, rags) and dispose of cleanup materials properly; ;
- Clean up spills on dirt areas by digging up and properly disposing of the soil;
- Keep paint removal v..astes, fresh concrete, cement mortars, cleared vegetation, and demolition wastes OUi
of gutters, streams and the storm drains by using proper containment and disposal.
Post-Construction
The project should minimize impacts from other pollutants which may be generated by the project
post-constroction. These pollutants may include sediment, bacteria, metals, solvents, oil and grease or ~.ot
pesticides, all of which are typically generated during the life of a residential, commercial or industrial
project after construction has ceased. This should be done by developing and implementing a plan or set of
control measures (that should be included in the SWPPP). The plan should specify all control measures
which will be anticipated or used including, but not limited to the source controls and treatment controls
listed in the Recommendations. Appropriate control measures are discussed in the Recommendations, Table
2: Summa.ry of Residential Pcst.-ccnstruction BMP Selection, Table 3: Summary ofIndustrial Post-
construction BMP Selection, and Table 4: Summary of Commercial Post-construction BMP Selection.
Additional sources of information that should be consulted for BMP Selection include The California Storm
Water Best Management Practice Handboo/cs; The Bay Area Preamble to the California Storm Water Best
Management Practice Handboo/cs and New Development Recommendations; the BASMAA New
Development Subcommittee meetings, minutes and distributed information; and Regional Board Staff.
Aiency Participation
Regional Board Staff are available to provide "technical assistance as part of our regulatory oversight of
NPDES Municipal Storm Water Permit or the County's and City's Baseline Urban Runoff Programs. Our
staff may have additional comments on this project which will be transmitted in a separate letter.
-
If you have any questions, please call me at (510) 286-1309.
Sincerely,
tJt. ~
Blair Allen
Associate Water Resources Control Engineer
CC:State Clearinghouse
1400 Tenth Street
Sacramento, CA 95814
s-
T errabay Project
City of South San Francisco
October 25, 1996
Final SEtR
II. Responses to Comments on the Draft SEtR
Page 114
18. Blair Allen, Associate Water Resources Control Engineer, California Regional
Water Quality Control Board, San Francisco Bay Region; August 10, 1995
18.01 The comment states that, in the absence of specific language describing the project
and potential impacts, the Regional Water Quality Control Board ("Regional Board")
assumes that water quality concern may not be adequately addressed. Although this
letter was received by the city on January 12, 1996 during the publiC review period on
the DSEIR, the letter is dated August 10, 1995 and appears to have been written in
response to the Notice of Preparation and Initial Study which were circulated for review
on August 4, 1995. The purpose of the Initial Study was not to describe project
impacts in detail or to recommend mitigation measures, but rather to determine
whether any new potential significant impacts that were not considered in the 1982 EIR
may occur or whether any aspects of the 1982 EIR otherwise needed to be updated or
reevaluated in the SEIR. The DSEIR (Section IV.E, Drainage and Water Quality)
adequately reevaluates project water quality impacts and mitigation needs, including
the areas of concern noted in the comment letter.
18.02 The comment explains NPDES program requirements. A similar discussion of
pertinent NPDES program requirements and of local regulations adopted in accordance
with the program and the city's general NPDES permit issued by the Regional Board,
is contained in DSEIR Section IV.E, Drainage and Water Quality. That Section (pp.
181-182) also recommends additional, updated mitigation measures (mitigation for
Supplemental Impact 0-3) to ensure project compliance with these water quality control
regulations, which were adopted after the 1982 EIR was certified. In addition, the
applicant has indicated that it has complied with these provisions in all grading and
other activities related to Phase I of the project, including filing the required Notice of
Intent with the Regional Board, receiving coverage for project activities under the city's
NPDES permit, and implementing an approved 1995 Winterization Plan (Le., the
NPDES General Permit-required Stormwater Pollution Prevention Plan (SWPPP).
18.03 The comment explains Regional Board certification authority for wetland fill under
Section 401 of the federal Clean Water Act. The DSEIR (p. 184) notes that the ravines
traversing the portion of the property that is to be dedicated to San Mateo County as
permanent open space (Le., HCP Administrative Parcel 2-04-02) create a variety of
microclimates favorable for the growth of plants requiring greater moisture. Riparian
vegetation is also found in some of the project catchment basins which were installed
at the base of the ravines above the Phase I development area, The SEIR biological
consultant has noted that no jurisdictional wetlands exist on the Phases I and II
portions of the project site that are to be developed. However, jurisdictional wetlands
may exist in areas of the Phase III portion of the project that are to be developed,
Therefore. a jurisdictional wetlands delineation and, if warranted. compliance with all
procedures of Section 404 and 401 of the Clean Water Act, will be required as part of
subsequent detailed environmental review conducted when Phase III is to be
developed and eventually comes before the city for required precise plan approval in
the future (see explanation of the "program EIR" approach and subsequent project
WP51 \548IFSEIRIF-/l.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 115
activity environmental documentation in paragraph one of response to comment 1.02,
as well as Appendix A of this Final SEIR attachment and pp, 2-3 of the DSEIR),
The EIR biologist, Thomas Reid Associates, believes that some potential jurisdictional
wetlands may exist on the Phase III portion of the Terrabay Project on San Bruno
Mountain. They have observed that during wet years water collects in the flat portion
of the site near Bayshore Boulevard and it appears to be a "wetland," However, they
have not conducted any formal wetland delineations of this area, They suggest that
detailed surveys of this area be undertaken as part of future development processing.
18.04 The comment recommends site design and control measures to mitigate stormwater
quality impacts during project construction and after construction (during project
occupance), The NPDES General Permit-required Stormwater Pollution Prevention
Plan (SWPPP) that is included as part of recommended mitigation for Supplemental
Impact 0-3 would include such measures, An SWPPP has already been approved
and implemented for Phase I. The specific measures to be included in the SWPPP for
project Phases II and III are to be determined during post-EIR project design
finalization phases of development review for those phases, The suggested measures
should be considered by the applicant and city for inclusion in the component of the
SWPPP for Phase I that addresses water quality impacts of project occupancy, and in
similar components of the SWPPPs for Phases II and III.
WP51 \548 \FSEIRI F-/l. 548
INTER-OFFICE ~IE~IORANDUM
R E eEl V E D (~
FEB 2 9 1996
PLANNING
CITY OF SOUTH SAN FRANCISCO
DATE:
February 28, 1996
FROM:
Steve Solomon, Chief Planner
Arthur Wong. City Engineer ~
TO:
SUBJECT:
TERRABA Y DEVELOPMENT - DRAFT SUPPLEMENTAL
ENVIRONMENTAL IMP ACT REPORT (SEIR)
The following comments supersede our memorandwn of February 16, 1996.
We wish to add the following additional comment to our response regarding the
subject docwnent contained in Richard Harmon's memorandwn dated January 22,
1996:
-
The mitigation measures discussed in the supplemental EIR include an item
(Supplemental Impact T-13) for the installation of a traffic signal at the intersection
of Hillside Boulevard and Chestnut Avenue. The installation of this signal is required
for Phase 1, in 2010, when the signal is warranted by traffic count monitoring. Its cost
is described as being the responsibility of both the City and the applicant.
The mitigated negative declaration dated October 26, 1994 for the Heather Heights r~.OI
subdivision requires the installation of a traffic signal at the intersection of Hillside
Boulevard and Chestnut Avenue as a traffic safety mitigation measure for the project.
This signal is apparently needed now. The initial study docwnent for the Heather
Heights Project, dated July 7, 1994, (which is one of the negative declaration
docwnents) prepared by Wagstaff and Associates states in Impact T-2, Page 45, that
the intersection has an "existing unacceptable level of service for this turning
movement, and adding to the volume in excess of the signal warrant criteria." This
information was developed by the Crane Transportation Group, We therefore
conclude that the signal is needed now, not in the year 2010. -
-
Regarding the responsibility to construct the signal: Paragraph IOe of Exhibit "G" to
the Terrabay Development agreement dated. April 14, 1989 states that it is the
Terrabay sponsor's obligation to construct a traffic signal at Chestnut Avenue and
Hillside Boulevard. However Exhibit "E, Section II, Subsection (F), Paragraph (6)"
states that the developer shall pay a prorated share of the signal costs as determined
by the City Council. No mention is made of the City sharing in the cost of the Signal.I'tf.02.
I t is our intention that the signal costs will be shared by other developers in the area
and not the City.
We believe that the draft EIR should be revised in accordance with our comments
discussed above. The traffic signal discussion should be consistent with other studies
performed by Crane Transportation and the cost sharing should conform to the
requirements of the T errabay Development agreement.
113: T erTabay:doelr2....
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 118
19. Arthur Wong, City Engineer, City of South San Francisco; February 28, 1996
19.01 No new traffic counts were conducted at the Hillside Boulevard/Chestnut Avenue
intersection for the DSEIR traffic analysis because the Sister Cities Boulevard
connection to Bayshore Boulevard was closed for most of the time period during which
the traffic analysis was prepared in 1995, due to the Oyster Point interchange
reconstruction. Therefore, the traffic counts that were recorded for this location in the
DSEIR were unrealistically low. Previous 1993-94 traffic counts and analysis by Crane
Transportation Group for the Heather Heights subdivision Initial Study had indicated
that volumes at the Hillside Boulevard/Chestnut Avenue intersection were exceeding
peak hour signal warrant criteria levels. However, the city's standard procedure used
to determine whether volumes exceed peak hour signalization warrant criteria levels
changed just after the Heather Heights analysis (Le., left turn volumes from the major
street to the stop-sign controlled minor street could no longer be added to the minor
street approach volumes in the warrant calculations). Heather Heights traffic counts at
the Hillside Boulevard/Chestnut Avenue intersection were used to help project year
2000 and 2010 volumes at this location for the DSEIR traffic analysis. Projections for
year 2000 Base Case (without project) conditions showed that while left turn
movements from Chestnut Avenue to Hillside Boulevard would be operating at an
unacceptable level, volumes would be approaching, but not quite meeting signalization
warrant criteria levels. The addition of Phase I project traffic by the year 2000 would
then be expected to increase volumes to borderline warrant conditions (Supplemental
Impact T-1, DSEIR p, 118).
Subsequent to preparation of the DSEIR traffic analysis, Crane Transportation Group
conducted a new count at the Hillside Boulevard/Chestnut Avenue intersection on
January 9, 1996 as part of the traffic analysis for the Chestnut Estates subdivision. All
construction at the Oyster Point interchange had been completed by that time and
Sister Cities Boulevard was open and connected to the west side of the interchange,
The January 9 traffic count indicated enough of a traffic volume increase so that PM
peak hour volumes at Hillside/Chestnut slightly exceeded the revised (more stringent)
warrant criteria standards. Therefore, based upon the most recent findings, volumes
now exceed peak hour warrant criteria levels at this location and the addition of
Terrabay project traffic would increase volumes further above warrant criteria levels.
The revised Transportation chapter in the errata section herein (section III)
incorporates these changes.
19.02 The DSEIR summary chart (p. 23) incorrectly assigns responsibility for implementation
of mitigation recommended for Supplemental Impact T-13 (unacceptable traffic
operations at the Hillside Boulevard/Chestnut Avenue intersection) to the city and
applicant. The commentor notes that, as set for in the Development Agreement, the
project sponsor has financial responsibility for implementing this mitigation. The SEIR
has been revised to indicate that the applicant has financial responsibility for the
preparation of plans, construction, and associated costs for the needed signalization.
The SEIR has been clarified to remove from the city any responsibility to fund any
WP51 \548\FSEJR\F-II.548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 119
portion of the cost of mitigation at this intersection. (See errata for DSEIR pages 23
and 144,)
WP511548\FSEIR\F-/l.548
February 29, 1996
RECE/VED~
FEB 211996
PLANNING
To: South San Francisco Planning Commission
P,Q. Box 711
South San Francisco, CA 94083
Subject: Comments on the Draft Supplemental EIR for the Terrabay
Specific Plan and Development Agreement Extension Project
-
1. One of the basic objectives of this project is to "Preserve archaeological site CA-
SMa-40..." (p. 51 of the draft SEIR). I am concerned that this objective is jeopardized
by the methodology followed in the SEIR, where a detailed report was prepared for
Phase I , but only conceptual planning done for Phases II and III. The shell mound, site
CA-SMa-40, is in an area that will not be developed until Phase III. It is close to
Bayshore Boulevard and US 101. The draft SEIR notes that traffic impacts of the later
phases will require changes to these roadways. These changes may call for
.construction on the shell mound site itself. This will not be known until detailed
planning is done for Phase III. On the face of it, it would appear that this would be 'ZO.ol
taken care of when the detailed EIR is done for Phase III. The City could at that point
disapprove plans that threatened the integrity of CA-SMa-40. However, that assumes
that the three phases are independent, which they are not. Phase I can be expected to
be a financial burden on the City, a burden that will not be relieved until Phase III.
Once Phase I is approved, the City will have a strong financial interest in approving the
remaining phases, an interest that may well overwhelm its interest in preserving this
cultural and historical site. The City should have the information it needs now so that it
can know what it is approving with respect to this site.
-
2. The archeological review (in Section 7) is not complete. The previous owner of
Terrabay, in order to fulfill a Caltrans requirement, commissioned what is the most
extensive archaeological survey done of this site to date. This survey should have
been reviewed for this SEIR, but was not.
'ZD.o1-
-
J{1l4f~ 1,~
~
Josephine Coffey
San Bruno Mountain Watch
PO Box AO
Brisbane, CA 94005
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 121
20. Josephine Coffey. San Bruno Mountain Watch; February 29. 1996
20.01 Please see response to comment 1.02.
20.02 Please see response to comment 1.03.
WP511548IFSEIRIF-II.548
To:
Steve Solomon, Chief Planner
Planning Division
City of South San Francisco
March 1, 1996
page 1 of 2
'21
RECEIVED
MAR - 8 199s
PLANNING
From:
John Lucchesi
~
/'1 '~. ,.r: - ./
1....0".,4',..........'..... ~
Re:
Draft Supplemental EIR for Terrabay Specific Plan and Development Agreement t:xtenSlon
The following is a summary of personal canments I concerns I questions:
1, page 202, d, Schools (1) Attendance Areas :
a, Clarify apparently conflicting I overlapping statements that Jefferson High School District
boundaries would include 'all of the project area', and SSFUSD boundaries are to include
Terrabay Village, Terrabay Pari< and Terra Bay Point?
-
-z.1.D.1
-
-
2, page 209, d. Schools :
a. Clarify how the number of estimated K-12 public school students has increased 30%, nearly
one third, (286 to 370) as the number of total project units has decreased by approximately 3%
(745 to 721) ? --
b, Are the 'enrollment multipliers' expected to change (increase or decrease?) in the future, -
between Phase One and Phase Two?
'-,. Oz.
'Z.1.03
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-
3, page 213, d. Schools :
a. The community should not be expected to bear the impact created by the projected shortfall of 1. t .01-
school impact fees to the SSFSD. (needed to mitigate the increase in enrollment caused by the
project) , ~
-
4. page 213, d Schools:
a Regarding installation of sidewalks along Bayshore Blvd....,what are the walking distances from
the Phase II dwelling units to Brisbane Elementary School and Lipman Intermediate School? 2.1. Or;
What is the length of sidewalk expected to be installed along Bayshore Blvd. from the Project
Boundary to Brisbane City sidewalks?
March 1,1996
page 2 of 2
5. pages 243-247, J. Cultural Resources:
a, Will subsequent Phases II and III require additional Supplemental EIR's thereby allowing Z t. 01:,
comment and resolution of impacts particular to the detailed evolution of development in those
phases? ---
b, Impact summary under Table 36 notes that mitigation measll'e of .site burial" will involve 1
"scarification, earth moving and compaction" while also noting that 'disturbance of CA-SMa-40 U .07
during project construction would be a significant adverse impact", Clarify how mitigation
measures suggested for SMa-40 are not impact creating ?
-
-
c. Why are all mitigation measures of Table 36 noted as .shouJcr rather than .shall"? Does
.shoukf suggest that the mitigation measure is not mandatory?
2.1.0&
-
-
d. Are Mitigation Measures noted in Table 36 consistent with particular professional standards of 2..1 "ocr
practice in the preservation of Archeological sites of this nature?
-
e. Have any alternative mitigation measures been explored that exclude I omit site SMa-4Q from
being disturbed at all..,i.e, exduded from development and grading areas or made part of a
permanent study I rediscovery area ,sacred preserve?
~l. 10
-
-
f, Have development diagrams and preliminary grading plans for Phase III been overlayed with
accurate location surveys of the archeological sites of concern? According to preliminary I "l. \ \
schematic grading plans developed in the specific plan, what amounts of cutting and filling is
approximately expected to occur at sites SMa-40 and SMa-92 ?
-
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 124
21. John Lucchesi. PlanninQ Commissioner. City of South San Francisco; March 8.
1996
21.01 Please see response to comment 7.02.
21.02 As explained on DSEIR p. 209, according to the 1982 EIR, the 745-unit project
approved in the specific plan would generate an estimated 286 additional K-12 public
school students. The revised number of total project units addressed in the DSEIR
(721) would generate an estimated 370 additional K-12 students. Both of these
estimates are based on current enrollment multipliers provided at the time by the
school districts. The revised estimate included in the DSEIR is greater than the
estimate in the 1982 EIR because the district enrollment multipliers have changed.
21,03 It is possible that district enrollment multipliers will continue to be periodically revised to
account for demographic changes that affect the average number of students per
housing unit for different types of housing products (Le., the "student yield"). The
mitigation negotiations called for in the DSEIR errata address Supplemental Impacts
PS-1 and PS-2 (see errata for DSEIR p. 213 in section III herein).
21.04 Please see response to comment 7.01.
21.05 Brisbane Elementary School is located approximately 1.9 miles and Lipman
Intermediate School is located approximately 2.6 miles from the furthest part of the
project within the Brisbane School District. Approximately one mile of sidewalk would
be need to be constructed along Bayshore Boulevard for children from Phase II of the
project to walk to Brisbane School District schools. Please also see response to
comment 2.03.
21.06 Under the Terrabav Specific Plan, a precise plan must be approved before Phases II
and III may be built. The SEIR provides a less detailed, program EIR-Ievel
assessment for Phases II and III, since the specific development plans will not be
known until a precise plan is approved (see first paragraph of response to comment
1.02). When Phases II and III are to be developed and eventually come before the city
for required precise plan approval in the future, more specific information would be
submitted and additional, more detailed environmental review will be undertaken at that
time within the context of the program level evaluation contained in the SEIR. Such
subsequent environmental review will be simplified by the broad, program-level
assessment contained in the SEIR and, consequently, mayor may not require an EIR.
The city will make a determination that either: (1) the action is fully covered within the
scope of the SEIR and no further environmental review is required, or (2) preparation
of a mitigated negative declaration is warranted (under Section 15070 of the CEOA
Guidelines), or (3) preparation of a focused EIR limited to more direct, site-specific
impacts and any new effects is warranted (under Section 15063 of the CEOA
Guidelines).
WP51 \548IFSEIR\F-II.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 125
21.07 The mitigation measure recommended in the 1982 EIR for the larger Indian shell
mound, site CA-SMa-40, requires capping the site with sterile fill and sealing it under
landscaping and/or parking areas. This approach is consistent with Appendix K of the
state CEQA Guidelines, which provides for:
'''Capping' or covering archeological sites with a layer of soil before building tennis
courts, parking lots, or similar facilities. Capping may be used where:
a. The soils to be covered will not suffer serious compaction;
b. The covering materials are not chemically active;
c. The site is one in which the natural processes of deterioration have been
effectively arrested; and
d. The site has been recorded.
As noted in the 1982 EIR, the proposed capping may result in some damage to the
resource--e.g., compaction from the weight of construction equipment. The potential
for damage to CA-SMa-40 during construction was identified in the DSEIR as
Supplemental Impact CR-2. The DSEIR (pp. 246-247) recommends that the city, as a
condition of Phase III precise plan approval, require the project applicant to finalize and
implement, as necessary, a mitigation plan for potential impacts to site CA-SMa-40.
The mitigation plan shall adhere to the mitigation approaches, procedures, limitations
and criteria specified in Appendix K of the state CEQA Guidelines, If appropriate, the
mitigation plan may recommend a mitigation approach other than the site capping
recommended in the 1982 EIR (see response to comment 1,07),
If capping is selected as the preferred mitigation approach, then: an engineering fabric
shall be placed over the site before fill is placed, the fill shall be at a minimum of one
foot deeper than the maximum depth of construction activities above or near the site,
and capping shall be supervised by a qualified archaeologist with authority to
recommend additional or different measures if necessary. These changes to the site
capping proposed in the 1982 EIR were recommended by staff at the State Historic
Resource File System Northwest Information Center.
If it is determined during subsequent environmental review of the detailed Phase III
development plans and prepar.ation of the mitigation plan required by the DSEIR for
mitigating Supplemental Impact CR-2, that capping of the sites could not be
accomplished without damaging the resources, then alternative mitigation may need to
be considered, including avoidance or a detailed excavation plan for mitigating the
effect on the resource (see response to comment 1.07),
21.08 The use of the word "should" in Table 36 (p. 245), which summarizes the 1982 EIR
cultural resources impact and mitigation findings is not meant to imply that the 1982
EIR mitigations listed in the table are not mandatory. In response to this comment, the
SEIR has been revised to instead use the word "shall." (See errata to DSEIR page
245 in section III herein.)
WP51 \548\FSEIRIF-II.548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 126
21.09 The mitigation measures recommended in the 1982 EIR (summarized in DSEIR Table
36 on p. 245) generally conform to the mitigation guidelines contained in Appendix K of
the state CEOA Guidelines and represent common practice,
21.10 Because the mitigation measures contained in the certified 1982 EIR were generally
considered adequate and consistent with the mitigation guidelines contained in
Appendix K of the state CEOA Guidelines, and the SEIR was prepared as a
supplement to the 1982 EIR, new mitigation measures or alternatives which would
specifically preserve the area of CA-SMa-40 as a permanent study area and/or
preserve within which any grading or development is prohibited were not considered in
the SEIR. However, recognizing that capping may result in some damage to the
resource, mitigation for SEIR Supplemental Impact CR-2 requires that the project
applicant finalize and implement, as necessary, a mitigation plan for Phase III that may
recommend a mitigation approach other than the site capping recommended in the
1982 EIR. In addition, if capping is selected as the preferred mitigation approach, then
mitigation for Supplemental Impact CR-2 also recommends measures recommended
by staff at the State Historic Resource File System Northwest Information Center to
minimize any potential damage to the resource. Also, if it is determined during
subsequent environmental review of the detailed Phase III development plans that
capping the site could not be accomplished without damaging the resource, then
alternative mitigation may need to be considered, including further consideration of an
archaeological preserve on a portion of the site or a detailed excavation plan. Please
also see responses to comments 21.07 and 1.07.
21.11 Accurate locations of the archaeological sites were not overlaid with preliminary
grading and development plans for Phase III because the latter component, the
preliminary grading and specific development plans for Phase III of the project, are not
yet available, When such details are formulated during the precise plan and
subdivision map steps that will eventually be necessary for Phase III, such an overlay
exercise will be an appropriate aspect of associated environmental review. (Please
see the first paragraph of the response to comment 1.02 regarding the "program EIR"
approach.)
The specific plan currently identifies in conceptual terms the general type and density
of commercial development contemplated for the project site in 1982, as discussed in
Section III of the DSEIR, Project Description. The specific development plans for
Phase III (land use and circulation layout, etc.) are not yet known, When Phase III is
to be developed and eventually comes before the city for required precise plan
approval in the future, more specific information about the development plan would be
submitted and additional, more detailed environmental review, including additional
archaeological investigation of site CA-SMa-40 and formulation of more detailed
cultural resources mitigation, will be undertaken at that time,
In addition, the DSEIR-recommended supplemental mitigation for site CA-SMa-40
(SEIR Supplemental Impact CR-2) requires that the project applicant finalize and
WP51 \548 \FSEIRI F-/J. 548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 127
implement, as necessary, a CA-SMa-40 mitigation plan for Phase III that may
recommend a mitigation approach other than the site capping recommended in the
1982 EIR (please also see response to comment 1.07). In addition, if capping is
selected as the preferred mitigation approach, then mitigation for Supplemental Impact
CR-2 also recommends measures recommended by staff at the State Historic
Resource File System Northwest Information Center to minimize any potential damage
to the resource. (Please also see response to comment 21.07,) The state CEQA
Guidelines permit capping only in instances where the soils to be covered will not
suffer serious compaction and the site would not otherwise be damaged. If it is
determined during subsequent environmental review of the detailed Phase III
development plans that capping of the sites could not be accomplished without
damaging the resource, then alternative mitigation may need to be considered,
including avoidance or a detailed excavation plan for mitigating the effect on the
resource.
WP511548IFSEIRIF-II.548
McR uron Geosciences
1670 8th Avenue
San Francisco, CA 94122
415 - 564-1364
41 5 - 644-4041 fax
ENGliE~:-:~~:: :
Z2
MAR 0 1 ~SSS
RECEiV:;:0
RECEIVED
MAR - 4 1995
March 1, 1996
PLANNING
City of South San Francisco
400 Grand Avenue
South San Francisco, CA 94080
Attention: Mr. Arthur Wong, City Engineer
RE: Review Comments of the Geotechnical portions of the Draft
Supplemental Environmental Impact Report for the Terrabay
Development, South San Francisco
Dear Mr. Wong:
At your request, McHuron Geosciences reviewed the Draft Supplemental
environmental Impact Report for the subject project. My comments were
included on the edited te>..'t and faxed to your office on January 25, 1996.
Earlier this week, you called and indicated that you would like my comments
included in memo format. This letter is my response to that request.
-
Page 28
Seventh line under Impacts starts with 'continued downslope movement...
There is no evidence from over six years of geotechnical monitoring of 1.2- .01
Landslide D, that it is moving. It is an old landslide that has a lower factor of
safety than is required by the development. Recommend changing the word
'continued' to future.
-
-
Page 59, forth paragraph, third line.
Refers to a 'borrow' operation in portions of Terrabay Commons and Terrabay
Point. This is an incorrect statement. Any grading in the Terrabay Commons 1:J. .01.
and Terrabay Point areas were for development of Hillside E\.'tension Blvd. and
a temporary siltation basin. To my knowledge no borrow area is present.
Infact there was excess material generated from the Phase I grading and this
excess material was placed in Terrabay Woods area.
-
tvlr. Arthur Wong
March I, 1996
Page 2
Page 60, paragraph 2a, 2nd line. I
After 'water' remommend adding "underground utilities, street lighting".
Page 61, paragraph El a, second to last line.
Change 'dates' to "date" and 'are' to "is".
Page 67, paragraph la(2), line 6
"borrow" Same comment as on page 59 above.
Page 68, paragraph (5), line 5
'completed to date include the connection', remommend adding "by Cal Water
Service"
Page 169, paragraph (2), line 6
'expected to occur in the future' recommend adding "on the perimeter slopes
of the development". 2Z. 0;
Add to the end of paragraph (2),
"Two localized slides also occurred on the split level lot portion of the
development. These slides have been repaired and care must be taken to
control surface drainage to help minimize the potential of future slope
failures2."
Add footnote to bottom of the page
"2psc, 1995."
Page 170, paragraph 4a, line 2.
'localized landslides' add "along the perimeter of the development"
Page 174, paragraph (4)
Add to end of the paragraph. "Debris flows did traverse the site during the
January 4/5, 1982, storm."
-
McHURON GEOSCIENCES
1'-1r. Arthur Wong
March 1, 1996
Page 3
Should you have any questions regarding these comments, please
contact us.
Sincerely,
McHuron Geosciences
~~f
President
McHURON GEOSCIENCES
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 131
22. Eric McHuron, President, McHuron Geosciences; March 1, 1996
22.01 The comment notes that the DSEIR incorrectly identifies "continued" downslope
movement at Landslide 0 and that there is no evidence that Landslide D is moving.
Comment noted; p. 28 of the DSEIR has been corrected. (See errata for DSEIR p. 28
in section III herein.)
Remediation and repair plans for Area D were reviewed by City and County officials,
determined to be adequate, and approved. The City and County issued grading
permits authorizing work to proceed on Area D. The work is expected to be completed
by October 31, 1996.
22.02 The comment states that the DSEIR incorrectly refers to a "borrow" operation in
portions of Terrabay Commons and Terrabay Point, noting that Phase I grading
generated a surplus of material. Comment noted; p, 59 of the DSEIR has been
corrected, (See errata for DSEIR p. 59 in section III herein.)
22.03 Comments recommend minor wording changes for the SEIR, The SEIR has been
revised accordingly. (See errata for DSEIR pp. 60, 61, 67, 68,169,170, and 174 in
section III herein.)
WP51 \548\FSEIRIF-I/.548
2.3
DEPARTMENT OF TRANSPORTATION
&ox 23660
OAKLAND. CA 9~23~
(S10)2~
TOO (510) 280-40(54
PETE WILSON, Go~r
f\EeCIVCD
~
.
c ATE OF CALIFORNIA-BUSINESS. TRANSPORTATION AND HOUSING AGENCY
MAR - H 1996
PLANNING
March 6, 1996
SM-101-23.39
SCH#9S092027
SM101212 Rev. 1
Ms. Uda Budko
City of South San Francisco
Planning Division
400 Grand Avenue
South San Francisco, CA 94080
Dear Ms. Budko:
Re: Draft Supplemental Environmental Impact Report for the Terrabay
Specific Plan and Development Agreement Extension - The proposed project is a
phased residential and commercial/office development approved in 1982. Phase I,
currently under construction, consists of 125 single family units and 168 townhomes
and related community facilities and infrastructure.
Thank you for including the California State Department of Transportation
(Caltrans) in the environmental review process. We have reviewed the above
referenced document and forward the following comments:
-
. On Page 147, Figure 25, Year 2010 Base Case Plus Project Phases I, IT and ill
Mitigations Needs, shows that Bayshore Boulevard will require extensive widening
to accommodate the traffic volume. Is this feasible without any effect on State right- '2.~.O(
of-way and/or on the development on the westerly side of it? Will there be adequate-
right-of-way to accommodate a four-lane southbound Route 101 offramp without
traffic backing up onto the freeway? Will Oyster Point Boulevard between Airport
Boulevard and Dubuque A venue be overloaded even though the signals are
coordinated?
-
Budko/SMl0l212
March 6, 1996
Page 2
General Comments:
-
. Page 109, Table 10 - The footnote with two asterisks is not indicated on this
table.
~~.O2.
-
. Page 119, Table 15 - Project Trip Distribution-PM Peak Hour, shows local streets 2;.03
and freeways. This data should be shown on a plot map which is easier to follow.
-
We appreciate the opportunity to work with you on this project and wish to
continue close correspondence on its development. Should you have any questions
regarding these comments, please contact Melinda Pagaduan of my staff at (510) 286-
5544.
Sincerely,
JOE BROWNE
District Director
B~~~B"Q~
PHILLIP BADAL
District Branch Chief
IGR/CEQA
'~
cc: Chris Belsky, SCH
T errabay Project
City of South San Francisco
October 23. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 134
23. Phillip Badal, District Branch Chief, California Department of Transportation;
March 6. 1996
23,01 Comment letter 23 duplicates comment letter 14, which was received by the city on
February 16, 1996. Please refer to identical comment 14,01.
23.02 Please see response to identical comment 14.02.
23,03 Please see response to identical comment 14.03.
23,04 Please see response to identical comment 14.04.
WP51 \548\FSEJR\F-J/.548
.l\
~ . GU" c."
FOSTER CITY
ROD & GUN CLUB Z4
RECEIVED
MAR 1 '.
...", ~""""'V
PLANNING
City of San Francisco
City Planning Department
City Hall
South San Francisco, CA 94020
March 13, 1996
Dear Members of the City Planning Commission
We the members of the Foster City Rod and Gun Club did not
receive notice of the hearing for the massive Tarra Bay Housing
and Commerical development proposed for the South Slope and North
Face of San Bruno Mountain. At this time we would like to make
some brief comments regarding this project and be placed on your
mailing list regarding future updates on this vital natural
resource.
-
As fishermen, we see in our California Fishing Regulations,
that fish caught in the Bay have been found to have higher and
higher levels of undesirable chemicals, as specified in the
California Department of Fish and Game Regulations. We suggest
that this document be included in the SEIR as a supplemental
document, with reference to the significant discharge of asilt
hardened · water from this proj ect flowing into the Oyster Point 2.~ .Or
esturary system. Discharge into the Osyter Point esturary has
caused increasing siltation and pollutants over years, especially
since disruptions caused by first development attempts.
The San Bruno mountain is an important natural water shed
that supplies fresh water to the Bay. This supply has decreased
since the losses of wetlands, due to grading at the base of the
mountain. Futher development of this area will cause losses of
more water shed and wetlands.
V
GoNT.
P.O. Box 4513
Foster City, CA
94404
CPNT.
Fishing opportunities have greatly deminished, due to much
lower population levels of some fish species, i.e. striped bass,
halibut, herring, salmon, and other various bottom fish inhabiting
the Osyter Point esturary. It is now necessary to travel longer
distances to ensure a fresh unspoiled catch. Most of these fish
species, many as schools of fish, no longer inhabit the Osyter
Point esturary in the numbers they once did. The pollution levels 'Z4{.Ol
in the Osyter Point esturary have increased over recent years
causing the fish population to move to more distant and less
desirable locations. This area once was the desired sponing area
for many of these fish species.
It is our recommendation the City of South San Francisco does
not preceed with this development. To return this area to the
San Mateo Park system to protect this vital water shed so the
surrounding Eco System can return, over time, to the quality
necessary to restore the local fishery to a level environmently
reminiscant of the past, and benefit our future generations.
-
u. r /0~
(l)~~
'1;l ~...
;:.--
~ 4;"
I . ' ,
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~ .;)Vt/~ J 'M.i-.'V\.....-
C[J~:,;J D< /~~~
"
,'f~4.
COPIED
t
u.s. Senator Barbara Boxer
1700 Montgomery st, Ste 240
San Francisco, CA 94111
RECEIVED
MAR 1 9 1996
PLANN\h:'~
u.S. Senator Dianne Feinstein
1700 Montgomery St, Ste 305
San Francisco, CA 94111
u.S. Rep. Anna Eshoo
698 Emerson St
Palo Alto, CA 94301
u.S. Rep Tom Lantos
400 S. El Camino Real, Rm 820
San Mateo, CA 94402
State Senator Quentin L. Kopp
363 El Camino Real, Ste 205
South San Francisco, CA 94080
State Assembly
K. Jacqueline Speier
220 S. Spruce Ave, Ste 101
South San Francisco, CA 94080
Mr. Carl Wilcox
State Of California
Department of Fish and Game
P.O. Box 47
Yountville, CA 94599
Mr. Bruce Elliott
State of California
Department of Fish and Game
20 Lower Ragsdate Dr, Suite 100
Monterey, CA 93940
Ms. Fran Recht
Fish Habitat Education Program
Pacific States Marine Fisheries Commission
P.O. Box 221
Depoe Bay, Oregon 97341
Ms. Karen Firehock
Save Our Streams Program Director
Izaak Walton League of America
707 Conservation Lane
Gaithersburg, MD 20878-2983
Urban Creeks Council
2634 Grant St
Berkeley, CA 94703
Bay Keeper
Building A Fort Mason
San Francisco, CA 94123-1382
California Stripped Bass Association
P.O. Box 254487
Sacramento, CA 95865
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GLEN MARTIN
In the Field
Many Ocean
Fis , at Edge
O~ Extinction
LOCal anglers stunned at the precipi-
tous decline of salmon and striped
bass in the San Francisco Bay /Sacra-
mento Delta system will find no com-
fort in recent surveys that demonstrate
fisheries are in trouble all along the
North American coastline.
As covered in the New York Times a
couple of weeks ago, reports by a Massa-
chusetts state task force, the Center for
Marine Conservation and the National
Fish and Wildlife Foundation all reach-
ed the same conclusion: fisheries are
collapsing in all our offshore waters.
Nearly one-third of all spE:cies that
are significant to commercial or recre-
ational fisheries are in decline. If the
situation isn't redressed, many species
will become extinct within the next de-
cade.
While we wring our hands as Cali-
fornia's once stellar anadromous fisher-
ies are reduced to remnant runs, New
Englanders are finding that bluefish,
Atlantic salmon, haddock, cod and
flounder are vanishing.
The Disappearing Stock
Pollack once swarmed off Alaska;
not now. King mackerel and red drum
are disappearing from the Gulf of Mexi-
co, and the same is true for snapper and
grouper off Florida.
Bottom fish are depleted through-
out the Hawaiian Island chain, and
swordfish have plummeted in numbers
and size on both coasts.
The reasons behind the declines are
not profound: overfishing, pollution,
water diversions and development of
coastal wetlands.
Foreign drift-net fleets are implicat.
ed in the eradication of many ocean
fish species (such as swordfish and pol-
lock), but the reports made it clear that
domestic commercial fishermen are by
no means blameless,
More than any other cause, over.
fishing was identified as the prime cul-
prit in the decline of most species.
.A.....~..,. . .......1f ...... ."..."
. ..~ w"'.
"~~'.'
This excessive harvesting could be
stopped immediately by measures im-
posed by the National Marine Fisheries
Service, but the agency is notoriously
slow in responding to declining fish
stocks.
The reports charge that the Ser.
vice's eight regional councils are domi-
nated by local fishing interests; the
commercial fishing lobbies call the
tune and the Service dances to it.
Until the Service regulates rather
than kowtows to commercial fishing
groups, we can expect to see continued
declines in many crucial stocks.
Reducing commercial quotas would
have an immediate and salutary effect
on many species. though the reports
predict that it would take years for
many stocks to recover. even if all fisb.
ing ceased immediately. Complete clo-
sures are unlikely to happen, in any
event - not with the current line of
thinking in the Fisheries Service.
Destruction of Wetlands
Coastal wetland destruction was al-
so fingered as a prime culprit in the col.
lapse of the stocks, Estuarine wetlands
serve as nurseries for a vast array of
forage and game-fish species, Dredged
estuaries and drained coastal marshes
mean greatly diminished offshore
stocks - it's that simple.
As urbanization continues unabated
along the continent's coasts, pollution
of near-shore waters increases, poison.
ing spawn, fry and mature fish.
Our coastal waters are turning into
toxic dead zones. The fish that do man.
age to survive are doomed by excessive-
ly high commercial quotas fostered by
a compromised regulatory agency . It's
a tragedy equivalent to the passing of
the African elephant; but because fish
are harder to assign human cha:-acter-
istics to, their fate has not met with
comparable outrage.
Because fish populations respond
quickly to reduced pressure and im-
proved environmental conditions, we
could turn our declining stocks around
with relative ease.
Don't bet on it, though. With Bush
stripping protection from millions of
acres of wetlands and drift.netters con-
tinuing to plunder offshore, pessimism
is a reasonable position.
Look to our own situation for addi-
tional proof. Modest increases in the
amount of fresh water going down the
Delta could revitalize our salmon and
striper runs, Instead, the water irrigat-
es the subsidized cotton crops of
wealthy farmers in the San Joaquin
Valley. A publiC resource that belongs
to the 30 million people of this state is
sacrificed to line the pockets of the
very few - and very po ~erful.
\....-nLJ.l \.....11 \,,1. ,.U ,
SPORT FISHING REGULATIONS
~,
~
STATE OF CAUFORNlA
GEORGE DEUKMEJlAN,GOVERNOR
1
9
9
1
FISH AND GAME COMMISSION
-.'; ....-.....:
Aob<<t A.. 8ryaft't. PfeUOanC. Yuo. c...,
,Johft A.. Murdy. Ul" VIe. Pf",""'- ~ &tacf'l
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~ ,. "'-OVinl. ........ San FtarctlCO
AlbeIt Co TaueMe'......... t.DnQ a.ad'I
~
~~1 "'-Q'
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-, \ ,.
~ \.-----", .
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I' , C_"
~
DEPARTMENT OF FISH AHD GAME
1..1,,.,.,tnSlr..I.80Il9U209 Sac:t8lNl'\lC942"-2Oi1O
PETE BONTAOELU CWedCII
--.-- _..- -.-. .------
HEALTH WARNINGS
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, ..
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 141
24. Foster City Rod & Gun Club; March 13. 1996
24,01 The federal NPDES program and local regulations adopted in accordance with the
program and with the city's general NPDES permit issued by the Regional Board
require preparation of a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP
is included as part of recommended mitigation for Supplemental Impact 0-3 (DSEIR
Section IV.E, Drainage and Water Quality, pp. 181-182). The applicant has indicated
that it has complied with all applicable provisions of the NPDES program and local
regulations and has implemented an approved SWPPP for Phase I grading and
construction activities. (Please see response to comment 1,13.) The city has
indicated that Phase I grading and construction activities and implementation of the
associated SWPPP provisions were monitored by the city and inspected by the
California Department of Fish and Game (CDFG) and Caltrans and were found to be
functioning as planned and in conformance with all NPDES program requirements,
The specific measures to be included in the SWPPP for post-construction project
occupancy of Phase I and for project Phases II and III are to be determined during
post-EIR project design finalization phases of development review for those phases.
Potential project-related sediment and pollutant discharge into and siltation of the
Oyster Point estuary will be considered by the applicant and city in preparation of the
SWPPP for Phase I project occupancy and for project Phases II and III.
WP51 \548\FSEJRIF-II.548
aUKELEY . DAVIS' IRVI"E . LOS .."CELES . RIVERSIDE' SAN DIECD . S.." FRA"CISCO
(-'j
'-"'"
.. ,1,'5"
y::' '.... \
(~' .j
~ -!"'
UNIVERSITY OF CALIFORNIA, BERKELEY
,
SANTA I"RIAltA . S""'T,,, ('"
DEPARTMENT OF ANTIiROPOLOGY
510/642.3391
BERKELEY. CALIFORNIA 94720-3710
FAX: 510/643-8557
-:lC
,'"
.....,
. .
~. '
-
~
-:
Mayor Jack Drago
South San Francisco Council Members
P.O. Box 711
South San Francisco, CA 94083
RECEIVED
MAR 2 0 1996
E&CD DEPT.
1"
.,
~
.,.
-.
.
r...:::-
r:r:
3/14/96
Dear Mayor Drago and Council Members:
-
This letter concerns the prehistoric shell mound (CA-SMA-
40) that is located in the TerraBay Development Project in South
San Francisco. I am writing to express my concern that this
important archaeological site be protected if possible. CA-SMA-'
40 is a large mound measuring approximately 80 to 90 meters in
diameter located on several fingers of the lower slopes of the
San Bruno Mountain. While some areas of the mound may have been
disturbed in the past, a large portion of the site appears to be
intact.
The purposes of
that CA-SMA-40 is an
a few remain today.
consider the idea of
SMA-40 as part of an
San Francisco.
this letter are twofold. One is to stress
important archaeological site of which only
The other purpose is to ask that you
annexing or setting aside the area of CA-
innovative archaeological preserve in South
Z5:01
CA-SMA-40 is one of the few remaining large shell mounds
that once dotted the landscape of the greater San Francisco Bay
Area. Of the more than 400 large shell mounds recorded at about
the turn of the century, only a handful remain today. Most have
been destroyed by the urban expansion of the Bay Area, while
others were removed in the 1920s and 1930s as topsoil or for
materials used in the construction of tennis courts.
The Bay Area shell mounds, such as CA-SMA-40, are very
significant sites. The earliest known mounds have been dated to I
about 4000 years ago. In my opinion, most of these large mounds,-
appear to have been bayshore locations that were used extensivel~.
over hundreds or thousands of years by local native peoples as
long-term repositories for their dead, ceremonial places, and
residential places. I think some of these mounds were
intentionally constructed as places to bury the dead and to keep
villages well above high tides and winter storm surges. Graves
COAt(:
(,Om:
and ceremonial offerings (California condor burials, caches of
charmstones) were place in the basal deposits of the earliest
shell mounds, and subsequent residents continued to use the
mounds as burial grounds, ceremonial places, and domiciles. It
appears that native peoples continued to dwell on top of mounds
whose cores encapsulated the sacred remains of their ancestors
going back many generations.
While I recognize that many economic, political, and
environmental concerns are involved in the planning of any major
residential and commercial development today, I would greatly
appreciate any consideration you can give to preserving CA-SMA-
40 for future generations of Bay Area residents. Another shell
mound (CA-SMA-92) may also be located close to CA-SMA-40 in the
TerraBay Development Project. It may be possible to preserve a
small area of the proposed TerraBay Develpment Project containing
CA-SMA-40 (and possibly CA-SMA-92) as open space. The area may
be annexed as part of the adjacent San Bruno Mountain state and
County Park. This is an exciting plan, since it will link CA-
SMA-40 to at least two other shell mounds (CA-SMA-243 and CA-
SMA-234) protected in the adjacent parkland, making South San
Francisco one of the most significant archaeological preserves of
these distinctive Bay Area shell mounds in the country (along
with the Coyote Hills Regional Park).
I
z.~. Ol
,
"
.......
~
I appreciate the complex and varied decisions that are
involved in the planning of any major development. However, if a
small area of the proposed TerraBay Develpment Project can be
annexed or set aside as part of an archaeological preserve, then
a truly exciting open space plan can be implemented in full
collaboration with the proposed development.
--.oJ
Thank you for your consideration.
Sincerely,
'tt i.1fI
Kent G. L~ghtfoot
Professor of Anthropology
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 144
25. Kent LiQhtfoot, Professor of AnthropoloQV, University of California, Berkelev;
March 14, 1996
25.01 Comment had been carefully noted and considered in preparing the response herein to
comment 1.07. Please see response to comment 1.07.
WP51 \548\FSEIR\F-II.548
BAY AREA MOUNTAIN WATCH,lnc.
P.O. Box 874
Brisbane, California 94005
415--468.1533
RECEIVED
MAR 2 0 1996
PLANNING
March 18, 1996
TO: mE CITY OF SOUTH SAN FRANCISCO. PLANNING DEPARTMENT
FROM: DANA DILLWORTH, President BAMW
RE: DRAFT SEIR TERRA BAY SPECIFIC PLAN AND DEVELOPMENT AGREEMENT
EXTENStoN . SCH: 95092027
Thank you kar N 6ppotfUf~ily Iu QUfllrlltlnl Ufllhe Draft SEIR for the Terra Bay eomptex-
I oommend you on your recognition of new, significont impoc:ls since the passage of the
ecl'iit'ff 1982 fiR. t wili COmmMT-<)M -rour Qf'tltOS of ~m. jo. bOr-o~onizajjon:
Watershed 1SS'.Jes, Safety Issues, Housing Issues, anQ C~rnvt<rtive 'm~,
Wat.,.hed IuUM
The taxi identifies fhe groundwater issues in terms of being problemafic for slope
stability. It foils to fonow the mandate of fle State Public Resources Cede to identify
and protect ground water os a "significant public resource.. There is no indication It'd
the quan1ffy or quality of ftlis resource has been considered or evaluofed. As one wou1d
suspect: it is considerobly more clean thCl'l groundwater infittrated by hurnan-produced
toxina. Once it passes through this highly developed area, it will surely be degraded.
Through the proposed mitigation meosure of under-grounding and discharging this ---r
public resource, you have foiled to Identify any ofhar mitigafion measures which would
utilize this for the benefit of wllclife. irrigation. or even as a potentiol drinking water -z,b.t'r
re9OVt'Ce. In fact, there ore no details of this yet-to-be-determined-by-fhe-opplicant's-
seolschnlcol-consultant $ubdraln &yGtem, 50 on OI1a1yst5 ot me Impoct& C1l euch '"
system cannot bQ made- fuerefore this SEIR is inadeouate. (Additionafly your answe"
to the checklist 3.f, 3.g, and g.o appear to be unsubstantiated.) _
-
Peraonol observation of mud flows from this property onto Bayshore Boutevard and the
response of the Public Works department to meTlilly p10ce orange cones around !he
area, (leaving a mound of mud there for weeks and is still there to this present day,)
leads one to wonder whether the mitigation monitoring program la odequote. By
ossigning "Ci1ylCountyfApptlcanr responsibIRty over these issues mak&8 us wondef
whether theee parlies ar& gd~fely responsive to the task: 8nfon;ing existing lows
prohibiting discharging soils (fill) into public waterways.
u.oz,
M~ttly filing for a NPDES permit, wtll not ensure 11s compliance. AddItionally there has
not been due consideration of known offsite impacts such os the siltation occurring in
the Son Fronciooo Boy just ea$t of this project. Without reoognlzing nor anolyzing these
impacts, there will not be sufficient mitigation measures. While you may argue that
preparing Q SWPPP witl mitigate thege iBSUGs, 1he t~ of Gp9Clific detoi1$ renders an
onalysis of impoef$ ;nadequate, eepeclCllIy In fGnns of cumulative impacts,
~
.::2:.
-
Safety IMU":
You have no~ identified a reosanoble mitigcmon measure nor given od~uate
consideration to relaoating those units which are down-slope of the identified and
dangerous westgrn-mtN~ landslide area. lnadequato mitigation in this areo could be
~lIy il' "".".,..& of life ClIMe Iiobility ogoinct the City.
u,. O~
---
-
Affordable Housing Iou.:
You have presented a specious argument regarding meeting regional housing needs,ln
porticulor in the very-low to low-inoome housing ootegories. Just because current
figures are not published by ABAG, does not mean that you ore in compliance with
housing mandates. If is my understanding that current state law mandates t\'lat
developments of mulnpte units require developers 10 indude 20% of new housing to
serve the needs of these parti<;ulor under.served populations. By not requiring a
percentage of units (ar requiring the participation of funding Q housing pool to support
YDfY-low and low-income houAing) ynu have circuffiWntad the Rpirit of the Jaw, This
omission is unconscionable.
u.ot
-
CUmulative Impacts: -
This document foils io accul'Cltely quantify and assess the series of cumulative impacts,
both created by this project as well of thoae caused by other projects in the vicinity.
Only one portion of one phase of this project has been completed. In that time there cC
has been 0 substontiolland$fide and on five oecosioos you have allowed the alteration 21'.0./
of habitat boundario&. 01\ of which inctQosed imfmds to the t\4Jbi1of, none which reduced I
ihem. Impoct& from foiled revegetation efforts, impocts from two fairly major ~1dfire8.
impacts from oxolis-laden imported fill, impaci$ of 1000S of habiiot through multiP'e
projec1s and on-going ossaults fa the habitat of endangered species such as exotic
weed proliferation and the blind farth that these proposed mitigation mecwres VIIi" work
renders this cumulative impoc1s analysis inadequate.
-
-
In the c:heckflSt, constant references to 'may need upgrading", or 'mitigation measure
may need to be reooevaluated and revised to reduce or avoid proiect-related impaclB....
on pions often lacking detail, renders this SEIR wholly inodequote. These details
should be port of this document in order to make "informed decision-making"- such is
the purpose of an EIR.
~.~
-
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 147
26. Dana Dillworth, President, Bav Area Mountain Watch, Inc.; March 18, 1996
26.01 The comment suggests that groundwater on the project site be used for "wildlife,
irrigation, or even as a potential drinking water resource," As noted on DSEIR p. 174,
"groundwater" on the project site is considered to represent shallow seepage of
infiltrated surface water rather than a true water table and, as such, represents a storm
drainage issue. All necessary municipal storm drainage improvements for Phase I of
the project have been completed. The applicant has indicated that the issue of
catchment basin and drainage ditch malfunctioning has been addressed (please see
response to comment 1,13). The answers to checklist items 3.f and 3.g in the Initial
Study presented in Appendix A of the DSEIR appropriately indicate that no changes
have occurred in the project or in existing groundwater conditions on the project site
that would affect the findings of the 1982 EIR with respect to groundwater and,
therefore, project effects on groundwater do not require reevaluation in the SEIR. With
respect to checklist item 9.a, the characteristics of the project in regards to use of
natural resources are no different than any other conventional subdivision within the
city,
26,02 Please see response to comment 24,01.
26,03 As explained on DSEIR p, 170, a remedial repair plan for Landslide D was approved
by the city on October 6, 1995. The plan consists of removing the upper 10 to 20 feet
of the landslide mass, constructing a shear key at the base of the landslide mass, and
providing subdrainage improvements including two additional midslope keyways with
subdrainage. Repair of Landslide D has not yet been completed, The city's
geotechnical consultant and San Mateo County staff have concurred that the proposed
Landslide D repair scheme represents an appropriate fix. (Please see comment
35.02,)
26,04 Project impacts on local and regional housing needs are discussed on DSEIR p. 87.
Project housing units would be affordable to "above-moderate-income" households.
The project would further city achievement of its fair share of overall and above-
moderate-income regional housing needs, The project, however, would have no
impact on the city's achievement of its share of regional housing needs for very low-,
low-, and moderate-income households. There is no state law that requires that 20
percent of the units in multi-family developments be affordable.
26.05 The cumulative effects of the project and surrounding development are adequately
discussed where applicable in the findings described in Section IV for each
environmental topic--e.g., land use, population and housing, transportation, public
seNices, vegetation and wildlife, noise, and air quality. This point is also explained on
DSEIR page 266 under section 0, Cumulative Impacts.
26.06 The purpose of the Initial Study (included as Appendix A of the DSEIR), as set forth in
the CEQA Guidelines, was not to describe project impacts in detail or to recommend
WP511548IFSEIRIF-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 148
mitigation measures, but rather to conceptually determine whether any new potential
significant impacts that were not considered in the 1982 EIR may occur or whether any
aspects of the 1982 EIR otherwise needed to be updated or reevaluated in the SEIR.
The impact and mitigation findings identified in the Initial Study checklist as needing to
be "updated" or "reevaluated" are the areas that were then re-examined in detail in the
course of preparing the DSEIR.
WP511548IFSEIRIF-II.548
March 18, 1996
R E eEl V E D 1-?
MAR 2 0 1996
PLANNING
To the Planning Commission of the City of South San Francisco
I"'lanning LJMsion
Post Office Box 711
South San Francisco, Caufomic 94083
Deer Steve Solomon. Secretary to the Planning Commission,
-
I would like to cddress to the P!cnning Commission a most serious matter which
concerns the respect and integrity of the entire Bey Area. In the city ot South San
--"'-'--:Fiancisc3~ upon lFie"soufheost slO""pe of ttle""Soo BNno Moon1ain-eXiSlSlhe reinridl'lts
of on oncient Chione Indian commvnHy. This cree hos. been estimated to be at
least four to. five thousand years old ar.d was inhablled by the Urebure {6unburi} or
SiprlChiquin tribe until present times. Also, according to Breck Parkman, Presidef1t of
the Society fa California Archaeology, and Rosemary Cambra, the Tribal
Chairwomen of the Muwekma Ohlone, several shellmcunds jf) this area contain ~7. 0'
the remains or ten thOUSand people. The Terroboy projed :s flOW dev~()pin~ Ihe
southeast slope of San Bruno mountain. This new construction is encroaching upon
this site and there ore plans to build where an ancJenr ~h~llmound is located.
I request to the Planning Commission to recommend and introduce legisfation
W'hich would mandate an immediate moratorium regarding all new construction In
the T erraboy p-oject development. I hope the remaining ~,..operty might be
purchased by publj~ I sioie grunts, and ~'€rt-lQp5 private donations, so that the area
could be designated into 0 trust for local Ohtone tribal groups.
-
Thank you fer permftfing this opportunity of pubrlC review.
Very truly YOI..'TS,
f(~~
tvY. Perry Mctlock
3COSecond Avenue #5
San francisco, Caiifcmia 94118
(415) 221-4240
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 150
27. Perry Matlock, 300 Second Avenue #5: March 18, 1996
27.01 Please see response to comment 1.07.
WP51 \548\FSEIRIF-/l.548
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l.f-Gb s..~~~ ~ ~. S. \==. .
PLANNING
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T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 152
28. Robert Carrillo. P.O. Box 678. Dalv City; March 18. 1996
28.01 Please see response to comment 1.02.
28.02 Please see response to comment 1.03.
WP51 \548\FSEIRIF-II.548
R E eEl V E DZ~
MAR 1 9 1996
PLANNING
March 18, 1996
OffICe of the
Historic Pre5eIV8tion Commission
(415) 8n-3990
FAX 872-3269
City of South San Francisco
Planning Commission
400 Grand Avenue
South San Francisco, CA 94080
SUBJECT:
Terrabay Project. Draft EIR
Dear Chairman and Commissioners:
--...,
At the regular meeting of the Historic Preservation Commission on February 8, 1996, our
Commission discussed the draft EIR for the Terrabay Specific Plan public noticed on January 5,
1995, Of specific concern to our commission are the potentially significant Native American
archaeological sites within the area of proposed development under Phase III, particularly the site 1-t:!J.ol
designated SMa 40. This site, which is generally undisturbed, consists of a significant shellmound
or midden which may have been occupied for several thousand years. Our preference is that this
site be left in an undisturbed state. The no project altemative is the only proposed alternative that
currently meets this objective.
--
Our Commission is aware that a site investigation report for SMa 40 was prepared several years ago I
for W. W, Dean and Associates and never presented as part of the public record since that firm
decided not to proceed with further development. We are concerned that the information in this
report could provide valuable information in regards to whether the mitigation proposed in the Draft Zt:!).02.
EIR is sufficient to protect this important cultural resource, We recommend that no decision on site
disturbance in the are of site SMa 40 or adequacy of mitigation measures be made until all available
information is completed and reviewed. We request that the current owner (SunChase G, A.
California, Inc.) provide this report and authorize its release to the South San Francisco Historic
Preservation Commission for further study,
-
Attached are key points of the San Bruno Mountain Watch Proposal for the Preservation of San
Mateo 40. 92 & 234 Archaeological Sites on San Bruno Mountain as the Nucleus of an Ohlone
Cultural Property Preserve issued by Jerome Irwin, dated February 7th, 1996, for your review,
We appreciate the opportunity to provide our comments and look forward to being kept informed as
additional information becomes available,
~ltI~
Chair
FV:mr
cc: SSFHPC Members
400 Grand Avenue. South San Francisco, CA 94080
San Bruno Mountain Watch
Proposal
For
- The Preservation of San Mateo 40, 92 & 234 Archaeological Sites On San
Bruno Mountain as the Nucleus of an Ohlone Cultural Property Preserve -
Key Points:
#1 The Ohlone (Yelamu-Amuctuc) archaeological sites found within the TerraBay Development
Project in South San Francisco - said to be the oldest, most important cultural resources on
the Mountain, as well as being the largest existant undisturbed native hamlet and burial
ground site in San Mateo County - represent a resource of unprecedented cultural,
spiritual and economic value. Were they to become an Ohlone Traditional Cultural Property
(fCP) or Archaeological Preserve, it could become as culturally important and financially
lucrative an asset for the City of South San Francisco and San Mateo County Park and
Recreation systems as the Coyote Hills Interpretation Center within the East Bay Regional
Park System.
#2 The real preservation of the hamlet-burial mounds in question, rather than capping them
which would most certainly destroy forever their traditional cultural property value and
probably their archeological value as well, would be a sterling way for both the City of
South San Francisco and San Mateo County to prominently and fonnally honor the native
peoples of our area - past, present and future.
#3 These mounds are said to be anywhere from two to six feet in depth. According to John
Rick, Associate Professor of Anthropology at Stanford University, this would almost
certainly suggest that many people are buried somewhere within them. Rosemary Cambra.
Director of the Ohlone Family Consulting Services in San Jose, says the sparse amount of
shell material in relation to the size of the mounds suggests that the sites are indeed
"funerary mounds rather than shell mounds, with perhaps up to 10,000 bodies buried."
Thus the case could easily be made that these mounds constitute a traditional cultural
property of special spiriwal/religious interest to native peoples which richly lend themselves
to the further renewal of such interests.
#4 In decades and centuries to come, what the children of tomorrow will need for guidance and
solace, in a world we of this living time cannot even begin to imagine, is not yet one more
freeway 'scissors' offramp, hotel or commerical building, which no doubt will quickly
become obsolete and torn down in due course, but this sacred site left exactly as it has been
for 5,000 years or more. This may be the most profound legacy of hope we can possibly
leave them.
.....,
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 155
29. Francisco Vieira. Chair. Historic Preservation Commission. City of South San
Francisco; March 18. 1996
29,01 Comment noted. If capping is selected as the preferred mitigation approach, while it
would not permit convenient access to the shell mounds during the life of the Terrabay
project, it would "preserve" the sites (Le., beneath a cover of landscaping and/or
parking areas) for potential access, study and use in the future. Please also see
response to comment 1.07.
29.02 Please see response to comment 1.03.
WP511548IFSEIRIF-II.548
CITY OF BRISBANE
50 PARK LANE
Brisbane. California 94005
(415) 467-1515
FAX (415) 467-4989
RECE\VED
MAR 2 0 1996
PLANN\NG
'30
r ~\S8~~ ""'\
.-
L "':
"- CALFORNIAJ
March 19, 1996
Planning COmmiSSion
City of Soutt'} San Francisco
Planning DMsion
PO Box 711
South San Francisco. Ca 94083
Attention: Steve Solomon
SUBJECT: COMMENTS ON THE DRAFT SUPPLEMENTAL
ENVIRONMENTAL iMPACT REPORT FOR THE TERRA6AY SPECIFIC PlAN
AND DEVELOPMENT AGREEMENT TIME EXTENS10N
Ladies and Gentlemen,
Thank you for the opportunIty to comment on the Draft Supplemental
Environmental Impact Report for the Terrabay Specific Plan and Development
Agreemen! time extension. We will concentrate our comments on twO major
isSues. traffic and circulation and the preservation of cultural (archeological)
resources.
1. TRAFAC ~O CIRCULATION
In reviewing the DSE1R. we found the analysis based on outdated
assumptIOns as well as environmental conditions. and, therefore, believe that, in
order for this Supplementat EIA to meet the requirements of CEQA. new data
must be obtained and analyzed that reflects the completion of the Oyster Point
Interchange and updates tt'le assumptions that were used for the analysis from
the East of 101 Area Plan.
-
a. pvster Point Interchange. As we are all aware, this project was under
construction while the DSEIR was being drafted. and has now been completed.
Under ceOA it is simpty not appropriate to hypothesize about a physical situation
that is here before US, in real~y. on the ground. The abl1~Y ollhe Oyster Point '~.Ol
lnterchange to accommodate existing traffic can now be measured and shOuld be
before thiS DSE1R is certified. In regard to the new analysis. we would like to
point out that, even without Terrabay traffic, the interchange:s congested
especially in the AM peak hours. Southbound traffic on Bayshore Boulevard
regularly backs up to tne scissors ramps.h
--,
b. Hook R~rr:os and Bayshore 8ouleva~On page 2 of the Development
Agreement proposed for time extension, there is a sequence of improvements.
The Bayshors Boulevard Hookramps are to be constructed before the oyster
POInt Interchange, This sequence resulted from earlier studies which found that,
with the removal of the Linden on-ramp, the Hook Ramps were necessary for the
function of the lnterchange. They were an integral part of the project. There is no
explanation in the EIR as to wrry the Hookramps have new been separated and
proposed to be installed at a later phase of the T errabay development. The
DSEIR also formulates a "fair share" approach towards the installation of
improvements. However, the Development Agreement establishes the Terrabay
developer as the party completely responsible for the Hookramp installation,
unless another entity has aQr9ed to share the cost.
~ Assumotions from the East of 101 Area Plan. At the time we
commented on this Plan, we noted that there were many questionable
assumptions that resulted in underestimating the amount of traffic generated from
the project area. 1n order for this DSEIR to be adequate, those assumptions
should be corrected. I call your anention to incorrect trip generation counts, an
assum~ ridership reduction based on 8AAQMD Rule 13 which is no longer in
force, and an excessive. presumption of transit ridership.
2,CULTURALRESOURCES
The OSEIR identifies several archaeological resources on the project site:
a large shefl.mound located in the development area; a Somali shall midden in the
development area; and smaller midden deposit, near, but just outside of the
development area.
CEOA inciudes a preference tor leaving archeological resources in place,
undisturbed. Rather than excavating a resource on a development site, my
experience has been that the resource would be carefully covered with sand to
serve as a marker. then carefully covered with several feet of soil and finally
capped by compacted soil or hardscape SO that. at a later time, the resource
could be recovered intact.
In this DSEIR, the large shall mound in the project area is proposed to be
"capped." with plastic matting and a shallow soil covering. We are unconvinced
thai this apprcacn would not cause damage to the resource and therefore not
constitute avoidance of impact It is our contention that the proposal would not
serve as mitigation under CEQA.
for the smaller shell mound, no mitigation is proposed in the DSE1A.
Mitigation is laft ,0 later stud~. For the smaller midden deposit, it is not clear
whether the extensive construction and site modifications in the vicinity of the
resource would have potential for adverse impact. The DSEIR must address
these lssues acequateiy before it can be certmed.
-
";0.02-
-
-
~.o3
;,.-~...,
-
,0. ot
-.
.....
?p.rn
-
We ur..oerstand that these moundS and middens are potentially eligible for 1fJ oh
listing on the NatIOnal Register of Historic Places and are considered of great .
cultural and spiritual importance to many citizens, Given the inadequacy of the
~' ,/
GDAJf.
tDW.f.
mitigation measures identified in the DSE'R, we urge you to consider additional ,
alternatives to preservation that would allow them to remain and to be accessed \ ~.~
by persons who find inspiration and solace in their existence.
-'
--
TOTHL p,O:
Terrabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 159
30. Carole Nelson, Plannina Director, City of Brisbane: March 19, 1996
30.01 Existing traffic flow and observed AM congestion through the recently completed
Oyster Point interchange has been continually influenced during the course of this
SEIR preparation program by the part-time closure of the Grand Avenue interchange
northbound US 101 on-ramp. All traffic from industrial areas east and residential areas
west of the freeway that formerly used the Grand Avenue northbound on-ramp has had
to travel through the Oyster Point interchange to access northbound US 101. The
extra signal time allocated for these (temporarily) added vehicles tends to produce
longer than normal back-ups during the AM commute in the peak travel direction from
US 101 into employment areas east of the freeway. It should also be noted that
Caltrans has done minimal signal coordination during the AM peak between the Oyster
Point Boulevard/Bayshore Boulevard and Oyster Point Boulevard/Dubuque Avenue
intersections, and has done no signal coordination between the Oyster Point/Dubuque
and Dubuque/US 101 northbound off-ramp/southbound on-ramp intersections. As
indicated by Table 16 in DSEIR section IV.C (Transportation), these intersections are
projected to experience acceptable operation in the year 2000 in both the AM and PM
peak hours with or without the project. Therefore, existing operation with a fully
operational Grand Avenue interchange (and resulting lower traffic volumes at the
Oyster Point interchange) is expected to be acceptable,
30.02 With respect to the timing of construction of the US 101 hook ramps at Bayshore
Boulevard, project compliance with the provisions of the development agreement is a
separate, non-CEOA issue. With respect to the fair-share apportionment of the cost of
mitigation recommended in the DSEIR, the hook ramps were treated in the DSEIR not
as mitigation, but rather as part of the project--Le., they would be constructed as part
of project Phase III and the applicant/developer would be responsible for the full cost of
these improvements. Nowhere does the DSEIR discuss fair-share cost apportionment
for the hook ramps.
30.03 Comment acknowledged. In response, the SEIR year 2010 traffic analysis for the
Oyster Point interchange area has been revised to eliminate the assumed BAAOMD
employer-based trip reduction rule (Le., to eliminate the associated 20 percent
reduction assumption) in trip generation from employment areas east of US 101.
Gross trip generation projections from areas east of US 101 have now been reduced
by 6 percent to reflect a modest level of transit ridership (the rate of ridership currently
experienced by existing local employers). The DSEIR traffic analysis did not assume
any additional BAAOMD-related trip generation reductions for 2000 Base Case (without
project) or 2000 Base Case plus project Phase I analyses. Also, the DSEIR did not
assume any additional BAAOMD or transit trip generation reductions for any
component of the Terrabay development. The EIR authors and EIR transportation
engineer have also determined that, in addition to the TSM-based vehicular trip
reductions already reflected in the analysis (6 percent), an additional vehicular trip
reduction of at least 12 percent can be anticipated in the project/East-of-1 01 vicinity
WP51 \548\FSEIR\F-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 160
due to continued voluntary TSM activity in the future (see revised Transportation
chapterpp.146-147).
The revised traffic analysis was recirculated for a 45-day public review and comment
period on August 30, 1996 and is included in the revisions to the DSEIR Transportation
section (errata) presented in Section III of this Final SEIR.
30,04 Please see response to comment 21.07.
30.05 The DSEIR (Supplemental Impact CR-3 on p. 246) notes that site CA-SMa-92 is within
the area of proposed Terrabay development and, because the site has a high potential
for containing Native American resources, and because subsurface testing for the 1982
EIR was limited, there is a substantial probability of encountering and disturbing
cultural resources at this site. The DSEIR-recommended mitigation (p. 247) consists of
further testing prior to Phase III grading to accurately determine the subsurface
boundaries and significance of the site. If it is determined that the site meets the
criteria for an "important archaeological resource" specified in Appendix K of the state
CEOA Guidelines, then mitigations, including proper recording and possibly a sampling
program followed by capping in a manner similar to that proposed in the 1982 EIR for
CA-SMa-40, may be recommended. The recommended mitigation is adequate and
appropriate under CEQA (the SEIR provides a program EIR-Ievel assessment for
Phase III, and the identified mitigation would avoid damaging effects to the
archaeological resource), given that the specific development plans for Phase III are
not known at this time. When Phase III is to be developed and eventually comes
before the city for required precise plan approval in the future, the additional studies
can be undertaken and more detailed mitigation developed at that time.
30.06 Recognizing that capping may result in some damage to the resource, mitigation for
SEIR Supplemental Impact CR-2 requires that the project applicant finalize and
implement, as necessary, a mitigation plan for Phase III that may recommend a
mitigation approach other than the site capping recommended in the 1982 EIR (see
response to comment 1.07). In addition, if capping is selected as the preferred
mitigation approach, then mitigation for Supplemental Impact CR-2 also recommends
measures recommended by staff at the State Historic Resource File System Northwest
Information Center to minimize any potential damage to the resource. Also, the state
CEOA Guidelines permits capping only in instances where the soils to be covered will
not suffer serious compaction and the site would not otherwise be damaged. If it is
determined during subsequent environmental review of the detailed Phase III
development plans that capping the site could not be accomplished without damaging
the resource, then alternative mitigation may need to be considered, including
avoidance in a manner which would preserve access or a detailed excavation plan.
WP51 \548\FSEIRIF-II.548
..: .",.:fO D~.I"'-
Sa.n Bruno .1lfOllnta.in Watch
"31
RECEIVED
MAR 1 9 1996
PLANNING
~~~
~cfi.~;~ ~~the Planning Commission
City of South San Francisco
~larch 19. 1996
Dear Steve,
-
We are writing you because of our hope that the pre-historic indian
shellmound. threatened by Phase lIT of the Terrabay development, can be
pre5erved. This shellmound is the largest remaining archeological site left in
the Bay Area, Every other large indian midden has already been cover over by
asphault find buildings.
SBMW would like to see this site left undeveloped, with the possible
exception of a re-created indian village andl or a set of ed ucational kiosks
containing information about the mountain's flora and fauna, weather and
geology, etc.
~f.O I
The Sipliskin buried their dead on the mountain, There are 1,OOO's of
members of this pre-historic race of people laid to rest on tbis part oCtbe
mountain. There may come a time in tbe future when archP.Ologists would like
to excavate part of this site and do a careful study of the remains, Covering
the site 'with blacktop asphault will overheat the ground and destroy the
delicate remains.
-
People who hike up the shellmound bave the same view the Sipliskin indians
had, not so long ago. .'\1ter tbe European settlers began appearing, the indians
used that hillside as a refuge and as a lookout. The shelhnound is on the
border ofSSF and Brisbane, and also borders the county park.lfthis large
shellmound becomes part of the park than it will be only part. of the park tbat
is within SSF, by tbe bay.
Tbe shellmound site is botanically vel')' rich Franciscan habitat. It contains
many of the food plants for the rare and endangered butterflies; as well as
habitat for foxes, raccoons, possums, skunks and birds. There is also the food
plant of the mountain's former inhabitants, the Sipliskin's chief source of
carbohydrates, the acorn of Buckeye trees whicb grow near the creeks.
San Bruno Mountain Watch requests that this letter be part oC the official
Draft Supplemental ElK Thanks, David Scbooley, SB~lW Chair 467-6631
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 162
31. David Schoolev. Chair. San Bruno Mountain Watch: March 19. 1996
31.01 Please see responses to comments 1.02 and 1.07. With respect to the question of site
overheating due to the introduction of pavement, covering such a site with a blacktop
(asphalt) parking area represents a typical mitigation approach for such shell mound
sites (De Silva Island Condominium Project in Marin County, Dominican College
expansion in San Rafael, etc.). Any subsurface heat buildup due to the increased heat
absorbency of asphalt has not been an issue. The difference in temperature within a
few inches of the surface would not be expected to have a significant effect on the
subject shellmound, but should nevertheless be one consideration in implementing
SEIR-recommended mitigations for Supplemental Impacts CR-2 (CA-SMa-40), and CR-
4 (CA-SMa-92).
WP51 \548\FSEIRIF-I/.548
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March 20, 1996
RECEIVED
MAR 2 0 1996
PLAN~
steve Solomon
Planning Division
city of South San Francisco
P. O. Box 711
South San Francisco, CA 94083
Re: Comments on Draft Supplemental Environmental
Impact Report for Terrabay Specific Plan and
Development Agreement Extension Dated January 5,
1996.
Dear Mr. Solomon:
On behalf of the project applicant, SunCh~se G.A.
California, Inc. ("SunChase"), we submit this comments letter on
the Draft supplemental Environmental Impact Report for the
Proposed Terrabay Specific Plan and Development Agreement
Extension dated January 5, 1996 ("DSEIR"). The DSEIR supplements
information and analyses for the Terrabay Project contained in
the EIR for the Project which was certified in 1982 ("original
EIR"). This letter addresses issues raised in the DSEIR and in
comments letters submitted on the DSEIR on or before March 15,
1996. The issues are organized into the areas discussed in the
DSEIR: (1) Soils and Geology; (2) Drainage and Water Quality;
(3) vegetation and Wildlife; (4) Public Services; (5) Noise;
(6) Cultural Resources; and (7) Project Alternatives. The issues
relating to each of these areas is discussed below.
A. Soils and Geologv
1. Issues Raised in DSEIR
-
The DSEIR recommends certain mitigation measures
relating to the following: small localized, post-grading
landslides; erosional gullies; "goat farm" cut-slopes; and
landslide D. SunChase has taken various steps to address these
issues. Some of this work was completed prior to the release of
~~ .0 I
5153484.1JP
1
"
CDNf.
BAKER & MYKE~zIE
steve Solomon
Planning Division
March 20, 1996
Page 2
(JJ!Jr.
the DSEIR but was not reflected in the DSEIR. The completed work
has been performed consistent with the proposed mitigation
measures in the DSEIR.
Erosion and slumps on several slopes were repaired by
grading and hydroseeding. In several instances, the sites were
over-excavated to create benches and those benches were drained
and the soil was reinstalled to ninety percent (90%) compaction.
In certain cases, drains were built within the repair site to
mitigate possible areas of perched water. All restored slopes
were treated with hydroseeding and hydromulch to effect
restoration as rapid as possible. The actual seed mix was ~2..0'
devised by Pacific OpenSpace (the company that conducted the HCP
restoration work - see Sections C.l and C.2.b below) with the
concurrence of Thomas Reid and Associates (the Plan Operator
under the San Bruno Mountain Habitat Conservation Plan). All
work was performed under the supervision of SunChase's soils
engineer (PSC) and the City's soils engineer (Eric McHurron).
Work was completed last fall prior to the rainy season. The
success of this work will be evaluated at the end of the rainy
season around the beginning of May.
with regard to landslide D, a remediation plan has been
accepted by the City and SunChase is actively proceeding with the
proposed repair. SunChase has engaged a technical and soils
engineer to supervise both the civil work plan development and
the on-site repair work. SunChase has met with several civil
engineers to develop a proposal for a work plan which will be
used to perform the repairs. SunChase expects to commence work
on the repair of landslide D on or about May 1, 1996 with
completion of the repairs expected on or before September 1,
1996.
-
-
2. Issues Raised in Comments Letters
Richard Harmon, City Senior Engineering
Technician, raises the following issue relating to soils and
geology: the funding mechanism for on-going maintenance for ;~.O2.
soils and geotechnical programs and facilities. SunChase is in
the process of completing the Master Homeowners Association
Agreement ("Master Agreement") for the Project. Under the Master
Agreement, repair and maintenance of geotechnical facilities and
soils programs will be funded by homeowner association
5153484.WP
2
'I
CDNT:
BAKER & M<;:JU:~zIE
steve Solomon
Planning Division
March 20, 1996
Page 3
WAlf.
assessments and/or dues. Another option would be creating a
geologic hazard abatement district ("GRAD") for funding this
maintenance work. The decision as to which funding.mechanism ~Z.O~
works best for both the homeowners and the city and which
mechanism to implement will be made in the future. However, in
any event, an appropriate on-going funding mechanism to address
these issues will be implemented.
-
B. Drainage and Water Oualitv
1.
Issues Raised in DSEIR
-
The DSEIR contains mitigations measures which
require that, in performing any activities at the Project site,
SunChase: comply with all applicable provisions of the city's
"Stormwater Management and Discharge Control II program; file a
Notice of Intent with the state Water Resources Control Board
("SWRCB") in order to be covered by the city's General NPDES
Permit; and prepare a Stormwater Pollution Prevention Plan
("SWPPP") and a Stormwater Management Plan ("SWMpl) describing
measures and practices that will be undertaken to control
stormwater and related pollutants. 1,'2.03
SunChase has complied with these provisions in all actions
it has taken for grading and other activities relating to the
Project. All approvals required by the City were obtained for
the grading activities for Phase I. The 1995 Winterization Plan
complied with all applicable regulations and was approved by the
City on August 15, 1995. The entire Plan has been completed and
the finished work approved by the city. SunChase filed a Notice
of Intent with the SWRCB for project activities and the
activities are covered by the city's NPDES Permit. The permit \
was issued on August 15, 1995. As it has in the past, SunChase
will continue to comply with all regulations relating to
stormwater and pollution control applicable to the Project in the
future.
-
-
The DSEIR also discusses issues relating to catch basins and
drainage ditches on the Project site. (DSEIR, p. 177.) SunChase
has addressed these issues. SunChase removed all the silt and
debris from the v-ditches, catch basins, and storm drains in the
Project area in the Fall of 1995 prior to the rainy season.
SunChase also removed and replaced all of the rock and fabric
;2..0'1-
S1S3484.Io'P
3
"
GOUT:
BAKER & M9KExZIE
steve Solomon
Planning Division
March 20, 1996
Page 4
~
filters in each basin to ensure a dependable flow. The brush
alongside the v-ditches was cut. During the recent heavy rains,
representatives of SunChase observed the operation of the v-
ditches, catch basins and storm drains and they were performing
very well. The rains, and particularly the violent storms of ~.~
December, 1995, have resulted in some silt and debris in the v-
ditches. SunChase will continue to monitor and clean these
ditches on an as-needed basis. As discussed in Section A.2.
above, SunChase is in the process of implementing an on-going
funding and responsibility program to maintain erosion and
sedimentation control facilities after the Project is built.
-
2. Issues Raised in Comments Letters
Cheryl Mitchell Wade, city Storm Water Program
Coordinator, submitted a comments letter stating that the City
Engineer and/or Stormwater Coordinator should be designated as
the city official with authority to approve the SWPPP and that
the SWPPP must be approved prior to the issuance of grading or
other permits. We recommend that these changes be made to the
proposed mitigation measure in the Final SEIR. As stated above
in subsection 1, SunChase has complied with these provisions in ~~.~~
performing project activities in the past. Ms. Mitchell Wade
also suggested that the DSEIR should refer to the owner rather
than the applicant to make it clear that the provisions apply to
any subsequent owners of the property. This change is not
necessary because, under the terms of the Specific Plan and
Development Agreement, subsequent owners are bound by the terms
and conditions of those agreements and the mitigation measures in
the DSEIR which are adopted as part of the approval of the
extension of the project entitlements. ~
-
The State Regional Water Quality Control Board (llSRWQCBll)
submitted a letter stating that the Project should comply with
all applicable provisions of federal, state and local storm water
regulations. Specifically, the SRWQCB listed the following
requirements: filing a Notice of Intent for coverage by the city 7Z.~G;
NPDES permit; development of a SWMP; the development of a SWPPP
for the Project to address erosion control, chemical waste
management, post-construction pollution minimization and other
issues; evaluation of Project for presence of jurisdictional
wetlands; and review of Project by SRWQCB for compliance with
Section 404 of the Clean Water Act.
5153484.\JP
4
"
CDNr.
BAKER & MYKENZIE
Steve Solomon
Planning Division
March 20, 1996
Page 5
As stated above in subsection 1, SunChase has obtained all
approvals required by the city for the grading and winterization
work it has performed.
CPAtT:
~2..~
-
-
with regard to wetlands, the SRWQCB made a generic comment
that projects must be reviewed for the presence of jurisdictional
wetlands. Its comment was not based on any information that
indicated that any wetlands were likely to be located on the
Project site. The analysis of vegetation and wildlife in the
original EIR did not identify any wetland areas on the site.
(original EIR, p. 103-112.) The DSEIR also does not identify any
wetland habitat on the Project site. For this reason, the DSEIR
does not identify a section 404 permit as one of the approvals
needed for the Project.
3'2..07
-
C. Veqetation and wildlife
1. Issues Raised in DSEIR
-
The primary issue raised in the DSEIR is the
remediation of the habitat restoration activities for Phase I
under the San Bruno Mountain Habitat Conservation Plan ("HCP").
The proposed mitigation measure recommends following the
suggested remediation plan outlined in the letter from Pacific
OpenSpace to SunChase (Appendix C to DSEIR). All the remediation
under the mitigation measure has been completed. SunChase
contracted with Pacific OpenSpace to perform the work it
recommended after evaluating the site. All this work was
completed in October, 1995. Most of the revegetation has been
successful with a strong crop of habitat plants developing. Some
slopes required additional seeding and spraying to eliminate
exotic plants. SunChase plans to fertilize and infill the
restored areas during 1996 to ensure strong habitat plant
development. Pacific OpenSpace has submitted a proposal for
monitoring of the remediation measures which SunChase is
currently reviewing. SunChase is committed to monitoring the
remediation efforts to ensure successful completion of the
restoration program.
31.0&
I
--l
SunChase did not perform the original habitat restoration---
work that required remediation. The habitat restoration work was
performed by the prior owner. In any event, the habitat ~.~
restoration work was done in accordance with the Terrabay Phase I
5153484.\JP
5
\/
WAIT.
BAKER & M<xENZIE
steve Solomon
Planning Division
March 20, 1996
Page 6
(JJNf.
Reclamation Plan ("Reclamation Plan"), which was approved by the
city in 1988 as required under the HCP. Although the reclamation
work needed remediation, all work was done in compliance with the
Reclamation Plan and, therefore, in compliance with the HCP. It
is premature to reach conclusions on whether the restoration is
successful or unsuccessful. Under the HCP, the success of the
RThestoratliOnt~lan.isphto beId7termtined b~ adlOng-termtevdatluatbion. ~2.~
e rec ama 10n 1n ase 1S no requ1re or expec e 0 e 7
established during the buildout of Phase I. The HCP states:
"The HCP approach to the South Slope is to prevent sudden loss of
habitat all at once by phasing the project so that reclamation of
cut and fill slopes with host plant species can beqin in the
first phase before the final phase of development takes place."
(HCP, p. VII-165.) Under the HCP, reclamation is a long-term
project which will continue throughout the development of each
phase of the Project.
-
2. Issues Raised In Comments Letters
The following issues were raised in the comments
letters concerning vegetation and wildlife. The comments all
focused on the HCP. The issues raised are: funding of HCP;
revegetation of temporarily disturbed areas; establishment of
success criteria for HCP; city delay of all authorizations and
approvals for project until successful restoration established;
correction in DSEIR classification of plants; survey of plants;
impact of human habitation on wild areas; evaluation of project
impact on ecosystem of mountain as opposed to only plants which
benefit butterflies; regeneration of larval food plants for
butterflies; HCP provisions for monitoring and evaluation; and
dedication of land for conserved habitat. Each of these issues
is addressed below.
-
a. Fundinq of HCP. The HCP established three
stages of funding for activities under the Plan. For the pre-
development stage, each landowner/developer was required to
contribute a lump sum to the Plan fund. This initial lump sum
payment was made by the prior landowner, W.W. Dean. During
development, the developer is required to pay the Plan Operator ~Z.IO
(Thomas Reid and Associates) under a contractual arrangement.
SunChase currently pays its proportional share of the monthly
service charge for work by the Plan Operator (which is billed
through the Plan Administrator (i.e., the county)). An on-going
~153484.\IP
6
V
COAtr.
BAKER & M9KE~zIE
steve Solomon
Planning Division
March 20, 1996
Page 7
c&Nr.
funding mechanism for the RCP after development is completed and
lots sold to individual homeowners has been established. For all
of Phase I (Terrabay village and Terrabay Park), Collection ~ l~
Agreements requiring the payment of RCP fees by homeowners have 3.
been recorded. A monthly charge to cover the costs of continuing
work under the HCP will be paid by individual homeowners as part
of their HOA assessment. Therefore, all funding requirements
under the HCP have been met.
-
-
b. Reveaetation of Temporarilv Disturbed Areas.
As discussed above in subsection 1, SunChase has already
implemented the recommended remediation measures under the DSEIR
to address the problems with the restoration of disturbed areas
in Phase I. In addition, any temporary problems with the
restoration plan was not due to noncompliance with the RCP. The ,~.l(
prior restoration was done in accordance with the Reclamation
Plan approved by the city. The Plan Operator is the person who
designated the types of vegetation materials and is responsible
for monitoring the Reclamation Plan implementation. (HCP, p.
VII-167-VII-168.) As the DSEIR states, the restoration
difficulties were primarily due to unfavorable weather condition,
- cold temperatures and drought. (DSEIR, p.197.) -l
with regard to the comment on Appendix C, the letter from 3~.1~
Pacific OpenSpace is five pages long and all pages are included
in the Appendix. ---
-..
c. Success criteria For Restoration Plan. The
HCP sets forth the standards for determining whether the
restoration of disturbed areas is properly implemented. First,
the restoration must be done in accordance with the Reclamation
Plan approved by the responsible entity. This was done. Second, ~~.(~
the success of the restoration effort may only be evaluated from 7~ ~
a long-term perspective. Under the HCP, the reclamation in the
first phase of the project was only required to beain before the
construction of the final phase commenced (see discussion above
in Section C.l.). (RCP, p. VII-165.) So, the HCP requires only a
good faith implementation of an approved Reclamation Plan that is
implemented and monitored by the Plan Operator.
5153484.IJP
7
BAKER & M9KE~zIE
steve Solomon
Planning Division
March 20, 1996
Page 8
-
d. Suqqested Delav In Authorizations and
Approvals Bv citv Until Restoration Established. The city is not
authorized under the HCP to delay authorizations and approvals
for the Project until the Phase I restoration is successfully
established. In order to go forward with Phase I construction,
SunChase is only obligated to implement the approved Restoration
Plan and the Plan Operator must monitor the results. Both of
these steps have been accomplished. In addition, SunChase went ~~.'A
beyond the requirements of the HCP and obtained an independent 7~'
evaluation of the restoration and performed further work to
address problems that occurred with the implementation of the
Reclamation Plan. Under the HCP, the city is prohibited from
imposing additional mitigation measures beyond those contained in
the HCP relating to habitat preservation and restoration.
(Agreement Regarding San Bruno Mountain Habitat Conservation Plan
("AHCP"), Section V.B.2, p.13-14.) Therefore, the City is not
authorized to deny a Phase I approval based on the fact that the
restoration project has not been completely established.
e. Correction in Classification of Plants. The'
DSEIR states that the Arctostaphylos Imbricata is a California
state listed plant. In addition, the plant has been federally 3Z.I~
proposed as threatened. The DSEIR states that the Lessinga
Germanorum Germanorum is a federally listed plant. However, the
correct status of that plant is proposed endangered. We
recommend that these corrections be made in the Final SEIR.
-
-,
f. Survev of Plants. Surveys of plants on San
Bruno Mountain and the Project site have been conducted annually
by the Plan Operat.ors and, in 1994, by the California Native ~2..Il.
Plant Society. No rare species of plants have been found on the
Project site. We recommend that the Final SEIR contain a brief
description of how these surveys were conducted.
-
-
As described in the DSEIR, the primary types of plants found
on the Project site are grasses; however, substantial floral
diversity exists on the site. (DSEIR, p. 183-184.) We recommend
that the Final SEIR contain a brief description of the floral ~~.11
plants located on the site. However, none of these plants are
rare species. The finding in the DSEIR that no rare plants are
located in the Project area is consistent with the finding of the
original ErR. Since no rare plants occur on the site, no
mitigation measures are required.
-.
S1S3484.11P
8
BAKER & Mc:::KE~zIE
steve Solomon
Planning Division
March 20, 1996
Page 9
Future surveys of plants on Phase II and III will be -,
conducted as part of the Project EIR for approval of a precise ~~.(~
plan for those Phases.
-
-
g. Impact of Human Habitation on wild Areas.
This is an impact that was discussed in the original EIR.
(Original EIR, p.105-112.) It was also discussed in the HCP.
The fact that humans will be living close to the habitat ~.l~
conservation area is not a new or changed circumstance that
requires re-evaluation under the DSEIR. The impacts discussed in
the original EIR are the same because no circumstances relating
to this issue have changed since the time of the original EIR.
h. Description of Ecosystem Versus Focus on -,--
Plants Which Benefit Butterflies. The DSEIR discusses the
ecosystem of the Project area and surrounding habitat area. ~2 ~
Grassland and wildlife conditions are described in addition to 7'
sensitive plants. (DSEIR p. 183-193.) The evaluation and
description of impacts under the DSEIR is not limited to plants
which benefit the butterfly. (DSEIR, p. 183-186.) ___I
-
i. Reqeneration of Larval Food Plant. The
mix for the restoration area includes larval food plants, in
particular, the lupines. Some of these plants have been
successfully established in the restoration area.
seed
-;'2.. 2.1
--
-
j. Provisions for Monitorinq and Evaluation
Under HCP. The HCP contains provisions requiring the Plan
Operator to monitor the implementation of habitat conservation
and restoration plans. (HCP, p. 1II-19-111-22 and VII-169.) The
monitoring activities are continual. The Plan Operator produces
annual reports on the HCP providing information on the status of
butterfly populations, exotic plant species control work, ~~
development activities, and other information. The most recent ~~.~
annual report is dated January, 1996 covering calendar year 1995.
The information under the vegetation and wildlife section in the
DSEIR is based on recent evaluations done by the Plan Operator.
In addition, SunChase contracted with Pacific OpenSpace to
perform a special evaluation of the restoration program. This
evaluation was done in the spring of 1995 and its recommendations
have been implemented (See Section C.1. above). Monitoring is an
essential element of the HCP. It has been done regularly in the
past and will continue in the future.
-
5153484.\IP
9
BAKER & Mc;::KE~ZIE
steve Solomon
Planning Division
March 20, 1996
Page 10
-
k. Dedication of Land for Conserved Habitat.
SunChase has prepared a grant deed to submit to the County for
review and acceptance. The grant deed covers the land that is .,z.2-3
required to be dedicated under the HCP. SunChase expects issues
related to the dedication to be resolved in the near future.
-
D. Public Services
The DSEIR discusses supplemental impacts on public
services and mitigation measures relating to the following areas:
schools, and on-site and off-site sewer systems. The comments
letters address impacts in two areas: schools and police
services. Each of these issues is discussed below.
....;;,?'...
.;..-.,-
::
1. Issues Raised In DSEIR
-
SunChase agrees with the primary mitigation
measure for the impacts on schools which is to pay the school
impact fee. SunChase also agrees that, under state law, the
amount of the fee is limited and any payment beyond the maximum
amount permitted under state law would be "voluntary". (See
discussion below in subparagraph 2.)
~2. 2.~
-
SunChase objects to the mitigation measure requiring the
installation of sidewalks along Bayshore Boulevard to allow
students from the Project to walk to Brisbane Elementary School
and Lipman Intermediate School for two reasons. First,
transportation of students residing in the Project area to these
schools is not identified as a significant impact under the
original EIR or DSEIR. Second, the construction of the proposed
sidewalk is infeasible.
~2.. '2.~
The transportation of children residing in the Project area
to the Brisbane schools is not a significant impact on the
environment that requires mitigation. There is no analysis or
facts in the DSEIR that identifies transportation to schools as a
significant impact requiring mitigation. Additionally, this is
not a changed circumstance that requires reevaluation under the
DSEIR. The original EIR discussed the fact that a portion of the
Project would be in the Brisbane School District. (Original EIR,
P.134-136.) The original EIR stated that students living within
the Brisbane School District would have to travel longer
distances to attend schools outside of their own neighborhoods.
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(Original EIR, p. 136-137.) However, this was not identified as
a significant impact. Instead, the original EIR stated that
these issues may be addressed by interdistrict transfer
agreements which allow students to attend schools in other
districts, and, possibly, a change in school district boundaries.
(Original EIR, p. 136-137.) The original EIR did not require any
mitigation for this insignificant impact and did not require the
installation of a sidewalk along Bayshore Boulevard to address
this issue.
The construction of the proposed sidewalk is also
infeasible. The portion of Bayshore Boulevard between the ~Z.2~
Project and the Brisbane schools is the roadway running along the
east end of San Bruno Mountain. Portions of Bayshore Boulevard
run right up against the steep slopes on the edge of the
mountain. Therefore, in certain areas, there is no available
land between the mountain and the roadway on which to construct a
sidewalk. Furthermore, SunChase does not own the land on which
the proposed sidewalk would be built and the land is located in
the city of Brisbane. Bayshore Boulevard is also a busy arterial
roadway and a narrow sidewalk between the mountain and the
roadway would present safety issues for pedestrians. Based on
the foregoing, the proposed sidewalk is infeasible because:
there is little available land area between the mountain and the
roadway; SunChase does not own land on which the sidewalk would
be built; the land is under the jurisdiction of the city of
Brisbane; and the proximity of the sidewalk to Bayshore Boulevard
may be an unsafe condition for pedestrians.
-
-
with regard to on-site and off-site sewer systems, SunChase
has conducted a thorough inspection of the sewer collection
system by both television inspection and visual inspection by
removal of manhole covers. The visual inspection was conducted
under the supervision of officials of the City Public Works ~
Department. The inspections did not reveal any problems with the ~~.
on-site sewer system that would cause excessive infiltration.
However, the inspections did reveal that the firehouse is
connected to the on-site sewer system and is likely providing the
observed waterflows. Additionally, the flows may be caused by an
allowable degree of ground water infusion. SunChase has
submitted its inspection reports and information to the Director
of Public Works for his review and approval. SunChase expects
UINf".
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Planning Division
March 20, 1996
Page 12
this issue to be resolved shortly and the city to accept
dedication of the sewer systems.
&,gNT:
~2.U
--L
2. Issues Raised In Comments Letters
The South San Francisco Unified School District
submitted a comments letter requesting a new mitigation measure
in the DSEIR that requires SunChase to enter into an agreement
with the School District to provide sufficient additional funds
or other mitigation measures necessary to mitigate all project
impacts to a level of less than significant. The City Police
Department submitted a comments letter stating that: security
during non-construction hours should be provided on the Project
site; the safety of students in the Project walking to schools
should be evaluated; and that the mitigation measures for police
services in the original EIR should be included in the summary
section of the DSEIR. Each of these issues is addressed below.
-
a. Schools. The proposed additional mitigation
measure by the School District is not supported by the facts
relating to the impact of the Project on schools or the law
limiting the type and extent of mitigation measures for school
impacts. The School District estimated the costs of impacts of
the Project on its schools to be $1.4 million. (DSEIR, p. 209.)
Since the actual amount of the fees is'not known at this time,
the current fee amount may provide the $1.4 million that the
school district states is required. The school district's own ~~.~~
estimate of the value of the fees is $1.372 million, which is
only $28,000 less than $1.4 million. (DSEIR, p. 209.) In
addition, it is unclear whether the $1.4 million is related
solely to costs of impacts caused by the additional students
generated by the Project. The impact fees should only cover
costs directly caused by the students from the Project, not costs
relating to upgrades or facilities that the School District would
need regardless of whether or not the Project was built.
-
-
State law also limits the mitigation measures that may be
imposed on a project to address school impacts. The financing of
school facilities with development fees is preempted by state
lhaw. (~overnment C~de Section 65995(e).) ,state law establishes ~.~
t e max~mum school ~mpact fee that may be ~mposed on a 7v
development. (Government Code section 65995(b).) Government
Code section 65996 limits the methods of mitigating environmental
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effects relating to the adequacy of school facilities for a
project. Based on these Government Code sections, the courts
have held that, since the state has preempted the field of
financing school facilities, a local agency is prohibited from
imposing fees greater than the maximum amount established by
state law as a condition of approval of a project in order to
reduce the project's impact on schools. (Murrieta Vallev Unifiec~
School District vs. Countv of Riverside (1991) 228 Cal.App.3d
1212, 1233-1234; Goleta Union School District vs. Reqents of
University of California (1995) 37 Cal.App.4th 1025, 1033-1034.)
Additionally, a recent case has held that classroom overcrowding,
per se, does not constitute a significant effect on the
environment under CEQA requiring mitigation. (Goleta Union
School District, 37 Cal.App.4th at 1032.) Based on the state la~_
discussed above, the city is prohibited from imposing any
additional mitigation measures beyond the maximum school fees
already imposed on the Project. Therefore, the mitigation
measure proposed by the School District must be rejected and the
mitigation measure in the DSEIR should be retained.
~'Z.Z&
-
-
b. Police Concerns. The letter from the City
Police Department states that security should be provided during
non-construction hours. The home builder on the Terrabay site 3Z.~~
(Centex) does have on-site security on duty whenever the job is
shut down for evenings or weekends. Therefore, the Police
Department's concerns are addressed.
-
The Police Department also raises the issue of how children
living in the Project will safely walk to school. The children
will be able to safely walk to all schools in the South San
Francisco School District. Children attending Hillside
Elementary School, which is located adjacent to the Project, will
be able to walk directly to the school along a lighted path
located wholly within the Project area. Children attending ~~.~O
Parkway Heights Middle School and El Camino High School will be
able to safely walk to those schools by walking along the Project~
pathway to the Hillside School area and crossing Hillside
Boulevard via the pedestrian bridge at Chestnut Avenue. Once thE,
children are on the other side of Hillside Boulevard, they have
various options for walking to both the Parkway and El Camino
schools.
,f
CDN"( .
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Brisbane Elementary School and Lipman Intermediate School in
the Brisbane School District are located in the City of Brisbane,
several miles from the Project Area. It is unlikely that
children will walk this distance to school. Jefferson High ~:z.~
School and Westmore High School are in Daly city, located several
miles from the Project area. Again, this distance is too great
for children to walk. Therefore, pedestrian safety is addressed
for the only schools to which Project students will walk -- the
South San Francisco District schools.
-
-
The police Department also states that the summary of
impacts and mitigation measures should indicate that the Project
will have an impact on police services, but that the mitigation
measures in the original EIR address this impact. The DSEIR "?1~.~1
restates the impacts of the Project on police services discussed
in the original EIR and the required mitigations in the text of
the document. (DSEIR, p. 199-200.) Since the DSEIR is a
supplement to the original EIR, only new mitigation measures were
included in the summary to show the changes recommended by the
supplement. -
E. Noise
Two comments letters were submitted on noise. One was
from John Costas, San Francisco International Airport, stating
that the mitigation measure for a supplemental noise impact N-3
should be revised to specify noise compatibility standards under
the Uniform Building Code ("UBC"), Title 24, Appendix 35, Sound
Transmission Controls and FAA Part 150 Noise compatibility
Program for an aircraft noise event. It should be noted that the
mitigation measure that Mr. Costas is referring to is N-1, not
N-3. The DSEIR noise mitigation measures as written address the
concerns raised in Mr. Costas' letter. ~2~~
The noise analysis under mitigation measure N-1 is required
to include consideration of aircraft noise to achieve the FAA
single event noise standard (supplemental noise impact N-2).
(DSEIR p.35, 227.) The specification of the noise standards
under the UBC and FAA Part 150 are not necessary because these
standards are the same as the standards incorporated under the
mitigation measure. The mitigation measure is based on standards
established by the state and the City's noise element. The UBC
standard is the same as the state standard under Title 24 of the
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California Code of Regulations which is incorporated into the
mitigation measure. (DSEIR, p.221.) The standard under FAA Part
150 requires that residences with an exterior CNEL of 65 dBA or
above incorporate measures to reduce the interior noise to 45 dBA ~~
CNEL. This is the same standard contained in Policy N-1 of the
City'S General Plan Noise Element which is incorporated into the
mitigation measure. (DSEIR, p.218.) Therefore, the noise
mitigation measures in the DSEIR address the concerns raised by
Mr. Costas.
-
-
Richard Harmon, City senior Engineering Technician, stated
that the DSEIR should discuss any noise impacts on Phases II and
III from traffic along sister cities Boulevard, Bayshore
Boulevard and Bayshore Freeway. The noise analysis in the DSEIR
evaluates noise from both aircraft and traffic. (DSEIR, p. 221- ~Z.~3
225.) Specifically, the analysis of noise impacts included the
effect of traffic noise from sister Cities Boulevard, Bayshore
Boulevard and the Bayshore Freeway on Phases II and III. (DSEIR,
p. 222.) Therefore, the impacts raised by Mr. Harmon were
properly included and analyzed in the DSEIR.
-
F. Cultural Resources
Josephine Coffey and Jerome Irwin submitted comments
letters on cultural and archaeological resources located in the
Project area. These comments are discussed below.
--,
Ms. Coffey states that the analysis of CA-SMa-40 should not
be deferred to Phase III because once Phase I is complete, the
City will have a strong financial interest to approve Phase III.
The analysis of CA-SMa-40 is not deferred to the consideration of
the precise plan for Phase III, it is addressed currently. Both
the original EIR and the DSEIR analyze available data on the
archaeological significance of the CA-SMa-40 site and mitigation
measures to prevent its disturbance. Based on available
information, the significance of CA-SMa-40 for the cultural
heritage of the Ohlone people and cultural and archaeological
study has been acknowledged in the original EIR and DSEIR.
Therefore, both the original EIR and DSEIR recommend avoidance of
impacts to CA-SMa-40 by capping the area with an engineering
fabric and fill-soil prior to any construction activities above
or near the site. This capping is required to be monitored by a
~z..~~ ..
"
t:4~
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Planning Division
March 20, 1996
Page 16
qualified archaeologist. In addition, trenching activities
should be avoided on the site.
since the plans for Phase III have not been established at
this time, there is no way to determine whether the site will be
impacted by proposed development. However, the mitigation
measures in both the DSEIR and the original EIR provide
protection of the site from any construction activities located
on or adjacent to the site. In addition, the final plans for ~Z.~
development on Phase III will be subject to further environmental
review, and further mitigation measures to protect the site may
be imposed at that time, if necessary. Any prediction of whether
the City will or will not approve Phase III since it has already
approved a precise plan for Phase I is speculative. There is no
way of determining at this time whether or not the city will
approve Phase III. None of the existing project approvals
require the city to approve any precise plan that is presented
for Phase III.
-
Ms. Coffey also states that a survey performed on behalf of
CalTrans was not included in the DSEIR discussion of the CA-
SMa-40 site. We recommend that the consultant review the
Caltrans survey and summarize any relevant information about the
CA-SMa-40 site in the Final SEIR.
32-. ~'5"
Mr. Irwin states that the CA-SMa-40 site should be
considered for an Ohlone Cultural Property Preserve. He also
attached letters from the Society of California Archaeology and
the International Indian Treaty Council which recommend that the
site be preserved and indigenous people be involved in decisions
on land on or around CA-SMa-40.
-
-
The creation of a Ohlone Cultural Property Preserve is not
necessary to mitigate the potential significant impacts of the ~~.~
Project to less than significant. The capping of the site and
limitations on disturbance of the site are adequate to preserve
the significant resources of the site. The consideration of
designation of the site as a Cultural Preserve is also premature
at this time because there are no specific development plans for
Phase III. The creation of a preserve may be considered at the
time a precise plan is submitted for Phase III, if development of
that area is not proposed under the plans. However, the
recommended mitigation measures in the original EIR and DSEIR are
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Page 17
adequate to protect the site and the creation of a Preserve is
not necessary at this time.
UJAJT:
;~.~
The preservance of the site recommended by
California Archaeology is met by the mitigation
The requirement of capping will assure that the
preserved.
-
"-
the society of
in the DSEIR. ~2..~7
site is
-
-
The recommendation of the International Indian Treaty
Council that indigenous people be involved in decisions on the
land on CA-SMa-40 is required under mitigation measures in the ~~ ~
original EIR. The mitigation measures require that if .
construction earthwork disturbs the soils at CA-SMa-40 and human
remains are encountered, a Native American representative should
be consulted. (Original EIR, p. 155.)
G. proiect Alternatives
The Environmental Mitigation Exchange Company submitted
a comments letter on the alternatives considered in the DSEIR.
They raise the following issues relating to the alternatives:
the range of alternatives is inadequate; there should be an
alternative evaluating open-space uses for Phases II and III; the
DSEIR does not contain an updated evaluation of environmental
impacts of the alternatives under current conditions; the
viability of and means to achieve implementation of the Modified
No Project Alternative is not discussed (for example, purchase of
land and management as open space); failure of restoration
warrants reconsideration of development of Phases II and III; no
development of Phases II and III would eliminate unavoidable
impact on air; incorrect identification of environmentally
superior alternative; and further exploration and analysis of
Modified No Project Alternative. Each of these issues is
discussed below.
--
1. Ranqe Of Alternatives. The California
Environmental Quality Act (IICEQA") requires a reasonable range of
alternatives that would feasibly obtain the basic objectives of
t~e ~r~jectt, bfuft would tahvoid o~ sUtbstantialltlY les~en anYh ~~.~
s~gn~f~can e ects on e proJec. Two a ernat~ves, t e No
Project Alternative and the Concept Plan Alternative, would
lessen or avoid the impacts identified for the Project. The
other alternatives considered, Sphere Of Influence Study
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c,QMr'.
Alternative and General Plan Amendment Alternative, are analyzed
because they reflect existing plans for the area even though, in
some instances, they create greater impacts.
Furthermore"sincde the DSEIR dis a supplemen~al EIRb, the ?~.~
range of alternat~ves oes not nee to be recons~dered ecause ~
the Project itself has not changed from the project analyzed in
the original EIR. Additionally, the analysis of the impacts
created by the alternatives is not affected by any of the changed
circumstances considered in the DSEIR. Therefore, the adequacy
of the alternatives in the original EIR cannot be revisited in
the DSEIR under these circumstances.
~
2. Alternative Evaluatinq Open Space Uses For Phase---
II and III. The original EIR and DSEIR consider two alternatives
that evaluate open space uses for Phases II and III. The No
Project Alternative in the original EIR evaluates no development
on any of the Project site which would result in both Phase II
and III areas remaining undeveloped open space. The DSEIR
analyzes the effects of the Modified No Project Alternative which
would result in Phase II and III areas remaining undeveloped open
space.
~~. .ffO
-
-
3. Updated Evaluation Of Environmental Imoact Of
Alternatives Under DSEIR. The DSEIR properly concludes that the
analysis of impacts of the alternatives is the same as that
presented in the original EIR. The proposed project has not
changed. None of the changed circumstances resulting from the
passage of time from the adoption of the original EIR affect the
comparative analysis of the impacts of the alternatives. As
stated in the DSEIR, the No Project Alternative and Concept Plan
Alternative would still result in lesser impacts than the
Project. The Sphere of Influence study Alternative and General
Plan Amendment Alternative would still result in greater impacts
than the Project. (DSEIR, p.260.) The DSEIR analyzes the
impacts of a Modified No Project Alternative which includes the
buildout of Phase I and the substantial on and off-site
improvements constructed as part of Phase I, but no development
of Phases II and III. The DSEIR concludes that most of the
impacts identified in the DSEIR for development of Phase I would
occur under this alternative. However, the impacts identified
for Phases II and III would be avoided.
~2-.1-1
--r
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Page 19
----.
4. Viability Of And Means To Achieve Implementation
Of Modified No Proiect Alternative. The comments letter states
that the viability of and means to achieve the implementation of
the Modified No Project Alternative is not discussed; in
particular, the purchase and management of the land as open
space. The Modified No Project Alternative is properly rejected
in both the original EIR and DSEIR because it is infeasible. The
retention of land in Phases II and III as open space is part of
the No Project Alternative in the original EIR. This alternative
is rejected as infeasible. Similarly, the Modified No Project
Alternative is rejected as infeasible under the DSEIR. The ~Z.~
benefits of the Project to the city are derived from the Project
as a whole. The goals and objectives of the Project may only be
met if all phases are built. For example, if Phases II and III
are not built, the city objective of commercial development on
the site with its enhancement to City revenue would not be
achieved. Furthermore, the benefits under the HCP are based on
development of all three phases. Selling a portion of the land
as open space would reduce, and possibly eliminate, the
obligations of the developer under the HCP. Public amenities
required to be built as part of Phases II and III also would not
be constructed if Phases II and III are not built. Therefore,
since the Modified No Project Alternative does not accomplish
most of the objectives of the Project, it is rejected as
infeasible. ~
-
5. Failure Of Restoration Warrants Reconsideration Of
Development Of Phases II and III. As discussed in section C.l.
above, SunChase has implemented the remediation plan recommended
in the DSEIR to address the restoration difficulties. Initial
monitoring of the remediation plan shows that the plan is
working. However, success of the restoration may only be ~~.~3
determined by a long-term evaluation under the HCP. The
restoration in Phase I is not required to be established prior to
the commencement of construction of the final phase. Therefore,
it is premature to evaluate the success of the restoration
effort. Since the restoration has been conducted in accordance
with the HCP and is not required to be fully established at this
time, the restoration difficulties do not warrant reconsideration
of development for Phases II and III.
-
6. No Development ot Phases II And III Would
Eliminate Unavoidable Impact On Air. If Phases II and III are
1~. ff
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not developed, the unavoidable impact on air identified in the
DSEIR would be eliminated. However, as discussed above in
subparagraph 4 above, no development of Phases II and III is ~~
infeasible. Since this alternative is infeasible, the City may ~~~
adopt a statement of overriding considerations for the
unavoidable significant impact on air identified in the DSEIR for
the development of all three phases.
-
7. Identification Of Environmentallv Superior
Alternative. The DSEIR properly identifies the Concept Plan
Alternative as the environmentally superior alternative. Since
the Project under the DSEIR is the extension of existing
entitlements, the Modified No Project Alternative is the "No
Project Alternative" under CEQA because if the extension (i.e.,
Project) is not approved, Phase I may be built out by February
14, 1997, the current entitlement termination date. Under CEQA,
if the No Project Alternative is the environmentally superior
alternative, the DSEIR must pick the alternative with the next
least impacts as the environmentally superior alternative.
Therefore, the Concept Plan Alternative is the environmentally I
superior alternative under this analysis. --J
-
~2.~
-
8. Exploration And Analvsis Of Modified No proiect
Alternative. The DSEIR analyzes the Modified No Project
Alternative under its supplemental findings. (DSEIR, p. 260-
261.) The DSEIR concludes that, under this alternative, a
limited portion of Phase I residential development would be
complete and project contributions toward construction of sister ~~~
Cities Boulevard, Fire station 5, playfield improvements at
Hillside Elementary School, waste water collection system
improvements and other public improvements would be completed.
However, the impacts of development of Phases II and III would
not occur and further public improvements required under those
phases would not be built.
H.
Other Issues
-
-
Richard Harmon, City Senior Engineering Technician,
comments that the DSEIR states that the linear parks will be ~~~
maintained by the city in contradiction of prior approvals which
require that the linear park be maintained by the developer.
Mr. Harmon is correct. The linear park will be maintained by
developer and we recommend that the information be corrected in
-
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Planning Division
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Page 21
the Final SEIR~ Mr. Harmon also requests copies of the three PSC
reports contained in the geotechnical appendix to the DSEIR.
SunChase will file two bound copies of these three reports with
the city Engineering Division.
SunChase appreciates the opportunity to comment on the DSEIR
and certain comments letters on the DSEIR. If the city has any
questions about the information in this letter, please call us.
5153484 . lIP
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'JZ~
Terrabay Project ,
City of South San Francisco
October 23, 1996
Final SEIR
II, Responses to Comments on the Draft SEIR
Page 184
32. Timothy Tosta, Baker & McKenzie; March 20, 1996
32.01 The remediation and repair plans for Area D were reviewed by City and County
officials, determined to be adequate, and approved. The City and County issued
grading permits authorizing work to proceed on Area D. The work is expected to be
completed by October 31, 1996. The comment notes that the applicant is proceeding
with needed geotechnical repairs and has completed some of the work recommended
as mitigation for small, localized landslides, erosional gullies, "goat farm" cut slopes,
and Landslide D. Comment acknowledged; no additional response is necessary and
no SEIR revisions are warranted.
32,02 The comment suggests a response to comment 5.05 from Richard Harmon, Senior
Engineering Technician, City of South San Francisco regarding the funding mechanism
for on-going geotechnical maintenance, noting that the applicant ("SunChase") is
completing a Master Homeowners Association Agreement which specifies
assessments and/or dues to fund geotechnical repair and maintenance and that a
geologic hazards abatement district (GHAD) is another option, Please see response to
comment 5,05.
32.03 The comment notes that the applicant has complied with all Regional Water Quality
Control Board (RWQCB) and city stormwater regulations for Phase I and will continue
to comply iri the future. Comment noted; no additional response is necessary and no
SEIR revisions are warranted. Please also see response to comment 18,02,
32.04 The comment notes that the applicant has already addressed issues pertaining to
catch basins and drainage ditches by cleaning and monitoring and is addressing
ongoing maintenance funding and responsibility. Comment noted; no additional
response is necessary and no SEIR revisions are warranted, Please also see
responses to comments 1 ,13 and 1.16.
32.05 The comment responds to comment9.01 from Cheryl Mitchell Wade, Stormwater
Program Coordinator, City of South San Francisco, noting that the suggested changes
to the SEIR should be made but that the suggested change to refer to owner rather
than applicant is unnecessary. The referenced changes to the SEIR have been made,
including the addition of the reference to "owner" rather than applicant. (See errata to
DSEIR pp. 29 and 181-182 in section III herein.)
32.06 The comment responds to comments 18.02 and 18.04 from the RWQCB regarding
NPDES requirements, noting that the applicant has obtained all required approvals for
grading and winterization work performed. Comment noted; no additional response is
necessary and no SEIR revisions are warranted. Please also see responses to
comments 18.02 and 18,04,
WP51 \5481FSEIRIF-I/.548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses -to Comments on the Draft SEIR
Page 185
32.07 The comment responds to comment 18.03 from the RWaCS regarding wetlands,
noting that neither the original EIR nor the DSEIR identify wetland habitat on the site.
Please see response to comment 18.03.
32.08 The comment notes that remediation of Phase I habitat restoration work has been
implemented in accordance with DSEIR-recommended mitigation and that the applicant
is committed to monitoring for successful completion. Comment noted; no additional
response is necessary and no SEIR revisions are warranted, Please also see
responses to comments 10.01 and 13.01.
32.09 The comment notes that it is premature to conclude that the original habitat work,
which was done in compliance with the HCP, was unsuccessful; reclamation is a long-
term effort which will continue throughout the project. Comment noted; no additional
response is necessary and no SEIR revisions are warranted,
32.10 The comment responds to comment 13.01 from the U,S, Fish and Wildlife Service
(USFWS) regarding compliance with HCP requirements, noting that all HCP funding
obligations have been met. Please see response to comment 13.01, No additional
response is necessary and no SEIR revisions are warranted.
32.11 The comment responds to comments 10.01 from the California Native Plant Society
(CNPS), 13.01 from the USFWS, and 16.01 from Ken Mcintire, noting that the original
habitat restoration work was done in compliance with the HCP and had temporary
problems due to unfavorable weather, and that the applicant has since implemented
the recommended remediation mitigation. Comment noted; no response is necessary
and no SEIR revisions are warranted. Please also see response to comment 13.01,
32.12 The comment responds to comment 13.06 from the USFWS, noting that all pages of
the five-page Pacific Open Space letter are included in the DSEIR. The EIR authors
confirm that this response is correct. No response is necessary.
32,13 The comment responds to comments 13.01 and 13.02 from the USFWS and 16.01
from Ken Mcintire, noting that the HCP requires only good faith implementation of an
approved reclamation plan implemented and monitored by the Plan Operator. Please
see responses to comments 13.01 and 13.02. No additional response is necessary,
32.14 The comment responds to comments 13.01 and 13.02 from the U SFWS and comment
16.01 from Ken Mcintire, noting that the city is not authorized under the HCP to delay
approvals until Phase I restoration is successfully established, Please see responses
to comments 13.01 and 13.02, No additional response is necessary.
32.15 The comment recommends that the changes to the SEIR suggested in comment 13.03
from the USFWS regarding the listing status of sensitive plant species be made, The
noted changes to the discussion on DSEIR p. 198 have been made, (See errata to
DSEIR p. 198 in section III herein.)
WP51 \548 IFSEIRI F-/l. 548
Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 186
32,16 The comment responds to comment 13.05 from the USFWS, noting that annual plant
surveys conducted by the Plan Operators have found no rare plant species onsite and
recommending that the Final SEIR describe the surveys. Please see response to
comment 13.05 for information regarding these surveys.
32.17 The comment responds to comment 13.04 from the USFWS, suggesting that the Final
SEIR should describe the floral plants located onsite. Please see response to
comment 13,04. Also, a representative list of plants found on the project site can be
found in the Terrabav Phase I Reclamation Plan. No additional response is necessary
and no changes to the SEIR are warranted.
32.18 The comment responds to comment 13.05 from the USFWS and supports the DSEIR
vegetation and wildlife impact and mitigation findings, noting that plant surveys will be
conducted as part of project EIRs for future phase precise plan approvals. Please see
response to comment 13.04. No additional response is necessary and no changes to
the SEIR are warranted,
32.19 The comment responds to comment 10.03 from the CNPS and supports the DSEIR
vegetation and wildlife impact and mitigation findings, noting that the impact of human
habitation on wild areas was evaluated in the original EIR and does not require
reevaluation in the SEIR. Please see response to comment 10.03.
32,20 The comment responds to comment 10.04 from the CNPS and supports the DSEIR
vegetation and wildlife impact and mitigation findings, noting that the DSEIR describes
the onsite and surrounding ecosystem as well as plants which benefit butterflies,
Please see response to comment 10.04.
32.21 The comment responds to comment 10.05 from the CNPS, noting that the seed mix for
the restoration area contains butterfly larval food plants, some of which have been
successfully established. Please see response to comment 10.05.
32.22 The comment responds to comment 10.06 from the CNPS, noting that regular
monitoring, as required by the HCP, has been and will continue to be performed.
Please see response to comment 10.06.
32.23 The comment states that the applicant has prepared a grant deed to submit to the
county for land to be dedicated under the HCP and expects resolution of outstanding
issues in the near future. Comment noted; the comment does not pertain to the
adequacy of the SEIR and no response is necessary.
32.24 The comment notes that the applicant agrees with the DSEIR that the primary
mitigation for school impacts is to pay the school impact fee and that any payment
beyond the maximum permitted by law would be voluntary,
WP51 \548 \FSEIR\ F-II. 548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 187
As mitigation for SSFUSD and Brisbane School District impacts (Supplemental Impacts
PS-1 and PS-2) the DSEIR (p. 213) recommended requiring the applicant to comply
with the school impact fee requirements. Because this measure may not be sufficient
to mitigate identified school impacts to a less-than-significant level, the DSEIR also
recommended that the applicant voluntarily agree to negotiate with each school district
and provide additional funds and/or measures to mitigate school impacts.
However, based on comments received during the DSEIR public review period
(comments 7.01 and 33.19) and on the possibility that such "voluntary" mitigation does
not provide reasonable assurance that the identified impact would be mitigated to a
less-than-significant level, the mitigation for school impacts recommended on DSEIR p.
213 has been revised in this FSEIR as follows:
The city shall require the applicant, as a provision of the project development
agreement, to prepare and submit for city review and approval, a school financing plan
that includes:
(1) Payment of State-Mandated School Impact Fees. Require the applicant to comply
with applicable SSFUSD and Brisbane school impact fee requirements. If it is
determined by the city that the project fees would not be sufficient to reduce
project school impacts to a less-than-significant level, the city may also:
(2) Additional Impact Fees. Require that the project applicant/developer pay additional
impact fees or some other additional in-kind contribution, or establish other
financing mechanisms in consultation with the city and acceptable to the SSFUSD
and the Brisbane School District sufficient to cover the cost of providing classroom
space and ancillary school facilities needed to serve the increased enrollment
generated by the project, to the city's satisfaction,
It should be noted that the school impact fees accruing from the project, as calculated
by SSFUSD and BSD, appear to have been underestimated because the estimated
size of the residential units used is smaller than the units actually being built. Thus,
the fees paid by the project may be sufficient to cover the districts' estimated costs.
Please also see response to comment 7.01.
32.25 The comment notes that the DSEIR does not identify transportation to schools as a
significant impact and suggested that the recommended mitigation requiring installation
of a sidewalk along Bayshore Boulevard is infeasible. In response to comments 2.03
and 21,05 above, the SEIR has been revised to further discuss transportation to
Brisbane schools together with impacts on the Brisbane School District generally.
Although, the DSEIR does not identify a separate significant impact specifically for
transportation to Brisbane School District, the district has noted that, "The Brisbane
School District does not provide transportation for its students. As Brisbane and
Lipman are within walking distance from Terrabay, I anticipate the need for sidewalks
WP51 \548IFSEIRIF-II.548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 188
to be placed along Bayshore Road between the development and the current
sidewalks. Otherwise, additional funds may be needed for student transportation. "
The SEIR has been clarified to refer to transportation to schools as part of the
identified significant impact on the Brisbane School District (Supplemental Impact PS-
2),
The comment notes that the 1982 EIR stated that students living within the Brisbane
School District would have to travel longer distances to attend schools outside of their
own neighborhoods and that these issues may be addressed by interdistrict transfer
agreements and, possibly, a change in school district boundaries. The school districts
disputed the boundaries in 1991. The state Board of Education ultimately resolved the
issue by leaving the district boundaries intact.
The mitigation recommended for Supplemental Impact PS-2 in the DSEIR assigned the
project applicant responsibility for installing sidewalks along Bayshore Boulevard to
allow students from the project to walk to Brisbane Elementary School and Lipman
Intermediate School. Because a sidewalk along Bayshore Boulevard may not be the
most desirable solution for transportation to Brisbane School District schools, the
recommended mitigation on DSEIR p. 213 has been revised to provide more flexibility
to the district, the applicant and the city in reducing the impact to a less-than-significant
level. Provision of the required safe transportation may be accomplished by installing
a sidewalk along Bayshore Boulevard and/or other streets to allow students to walk to
Brisbane Elementary School and Lipman Intermediate School, or in some other
manner acceptable to the district, and by requiring the applicant to submit to the city an
official statement in writing from the Brisbane School District declaring that the needed
transportation has been adequately provided for to the satisfaction of the district.
Please also see responses to comments 2.03 and 21,05 and errata in Section III
herein for DSEIR pp. 210 and 213.
In summary, finalization of school access sidewalk needs and associated design
details are properly deferred to the Phase II and III environmental documentation
sequences, since the City currently does not know what the actual configuration of
these phases will be.
32,26 The comment notes that onsite and off-site sewer system inspections by the applicant
revealed no problems and that resolution of this issue and city acceptance of system
dedication is expected shortly. Comment noted. In addition, since release of the
DSEIR, the city has conducted its own inspections of off-site sewer system
improvements installed as part of the project and has determined the source of
observable flows. The city has accepted all off-site sewer system improvements and
all on-site sewer improvements within public roadway rights-of-way that were required
to be dedicated to the city. No additional response is necessary and no SEIR
revisions are warranted, Please also see response to comment 33.23.
WP51 1548 \FSElRI F-/l. 548
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 189
32.27 The comment responds to comment 7.01 from Janice Smith, Assistant Superintendent,
Business Services, SSFUSD, noting that it is unclear whether the identified project-
related costs to the SSFUSD of $1.4 million is attributable entirely to the project. The
DSEIR on p, 209 states that, "Based on an estimated cost of $140,000 per relocatable
classroom, the total estimated cost to the district to provide classrooms would be $1.4
million." The project-related costs were explained by the district as follows:
The cost of a relocatable classroom with plumbing installed on a permanent
foundation with appropriate landscaping, sidewalks, handicapped access and
furnishings, including architect and state and local fees, is estimated to be
$140,000 (Lee Kerney, VBN Architects).
The district should be prepared to serve 260 students from the project (Lapkoff
memorandum of 9/21/95). Assuming level distribution of students per grade is 29
students per class for elementary and 23 students per class for middle school and
high school (80% utilization) and a $140,000 cost per classroom, the estimated
cost to provide classrooms is $1,400,000.
(K-5) (6-8) (9-12)
Elementary Middle School HiQh School Total
Project Enrollment Increase 120 60 80 260
Students Per Room 29 23 23
Classrooms Needed 4 2,5 3,5 10
Cost Per Classroom $140,000 $140,000 $140,000
Total Classroom Cost $560,000 $350,000 $490,000 $1,400,000
Additional rest room facilities and core classrooms may be needed at Hillside
Elementary School and Parkway Heights Middle School for child care (before and
after school), ESL, Special Reading and Special Education.
Costs to add permanent classrooms, a more desirable option, would need to be
determined by an architect for each site.
It appears that developer fees will not generate sufficient revenue to provide
facilities in the area for new enrollment from the project and that additional revenue
from the development will be needed. 1
Please also see response to comment 7.01.
32,28 The comment responds to comment 7,01 from Janice Smith, suggests that state law
establishes a maximum school impact fee and limits the city from imposing additional
mitigations beyond the maximum school impact fees. The EIR authors believe that
because the project involves a legislative action, the city may elect to impose additional
1September 25, 1995 Memorandum from Janice 8, Smith, South San Francisco Unified School
District to Wagstaff and Associates Re: Terrabav Proiect--ReQuest for Information,
WP51 \548\FSEIR\F-II.548
Terrabay Project
City of South San Francisco
October 25. 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 190
mitigations, provided that an adopted general plan basis exists for such a requirement.
Please see response to comment 7.01 for additional explanation,
32.29 The comment responds to comment 2.06 from Sgt. Ron Petrocchi, South San
Francisco Police Department, noting that the Phase I homebuilder provides onsite
security during evenings and weekends. Since submittal of this comment, the Police
Department has indicated that the applicant has addressed their concerns about onsite
security, (Please also see response to comment 2.06.)
32.30 The comment responds to comment 2.03 from Sgt. Ron Petrocchi, noting that children
will be able to safely walk to all SSFUSD schools and that Brisbane School District and
Jefferson Union High School District schools are too far for children to walk. No
response is necessary. Please also see response to comment 2.03.
32.31 The comment responds to comment 2.01 from Sgt. Ron Petrocchi, noting that the
SEIR is a supplement to the original EIR and thus only new mitigations were included
in the summary. No response is necessary. Please also see response to comment
2.01,
32,32 The comment responds to comment 11.01 from John Costas, Administrator, Planning
and Environmental Affairs, San Francisco International Airport, noting that the DSEIR
noise mitigation measures address his concerns. The comment supports the DSEIR
noise impact and mitigation findings. Comment 11.01 suggests additional language to
clarify recommended mitigation for Supplemental Impact N-2, Pages 35 and 228 of
the DSEIR have been revised as suggested. (See errata for DSEIR pp. 35 and 228 in
section III herein.)
32,33 The comment responds to comment 5.03 from Richard Harmon, noting that the DSEIR
noise analysis does address impacts of Sister Cities Boulevard, Bayshore Boulevard
and US 101 traffic. The comment supports the DSEIR noise impact and mitigation
findings; no response is necessary. Please also see response to comment 5.03.
32.34 The comment responds to comment 20.01 from Josephine Coffey, noting that analysis
of CA-SMa-40 has not been deferred to Phase III. The original EIR and DSEIR both
address the site's significance and recommend mitigation. Moreover, since plans for
Phase III have not yet been established, impacts on the site cannot be determined.
Also, a Phase III precise plan will be subject to further environmental review and may
or may not be approved by the city. The comment supports the DSEIR noise impact
and mitigation findings; no response is necessary. Please also see response to
comment 1.02.
32,35 The comment responds to comment 20.02 from Josephine Coffey, noting that the
results of the referenced Caltrans survey should be summarized in the DSEIR.
Comment 20.02 refers not to a Caltrans survey, but to an archaeological investigation
of site CA-SMa-40, the large shell mound located in the Phase III portion of the project,
WP51 \548\FSEIR\F-II.548
Terrabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SErR
Page 191
which was performed by Holman & Associates, consulting archaeologists, for the
previous property owners. As indicated in the response to comment 1.03 above, a
report on the Holman investigation findings was not completed, no related information
was submitted to the city, and no related record has been filed with the California
Historical Resources Inventory.
32,36 The comment responds to comment 15.01 from Jerome Irwin, noting that the creation
of an Ohlone Cultural Property Preserve is not necessary to mitigate the potential
significant impact to a less than significant level, and suggests that such a measure is
premature because there are no specific development plans for Phase III. Please see
response to comment 1.07.
32,37 The comment responds to comment 15.02 from Jerome Irwin, noting that preservation
of the site recommended by the Society for California Archaeology would be achieved
by the proposed capping. Please see response to comment 1,07,
32,38 The comment responds to comment 15.04 from Jerome Irwin, noting that involvement
of indigenous peoples recommended by the International Indian Treaty Council is
achieved by the DSEIR mitigation requiring consultation with a Native American
representative if human remains are encountered during construction. Please see
response to comment 15,04.
32,39 The comment responds to comment 8,01 from Farnum Alston, President,
Environmental Mitigation Exchange Company (EMAX), noting that the original EIR
evaluated a reasonable range of alternatives and that the SEIR need not reconsider
the range of alternatives because the project has not changed and changes in
circumstances do not affect the original EIR alternatives analysis. Please see
response to comment 8.01.
32,40 The comment responds to comment 8.01 from EMAX, noting that the original EIR and
DSEIR considered two alternatives that evaluate open space uses for Phases II and III:
the No Project Alternative and the Modified No Project Alternative.
The comment is not entirely correct. The no project alternative evaluated in the DSEIR
did consist of the Phases II and III areas of the project site remaining as open space.
However, the DSEIR did not evaluate a "modified" no project alternative separate from
and in addition to the no project alternative; the "modified" no project alternative
referred to in the comment is the no project alternative evaluated in the DSEIR.
Please see responses to comments 8.01, 8.02 and 8.03,
32.41 The comment responds to comment 8,01 from EMAX, noting the SEIR properly
concludes that the impacts of the alternatives have not changed from the original EIR,
The comment supports the SEIR alternatives analysis,
WP51 \548\FSEIR\F-I/.548
Terrabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 192
32.42 The comment responds to comment 8.02 from EMAX, noting that the viability of a
means to achieve implementation of the modified no project alternative is not
discussed because the alternative is infeasible.
32.43 The comment responds to comment 8.02 from EMAX, noting that restoration has been
conducted in accordance with the HCP and is not required to be fully established at
this time, and that restoration difficulties do not warrant reconsideration of development
of Phases II and III. No response is necessary. Please also see response to
comment 13.01.
32.44 The comment responds to comment 8.02 from EMAX, noting that if Phases II and III
are not developed, the unavoidable air quality impact would be avoided but that, since
elimination of Phases II and III development is infeasible, the city may adopt a
Statement of Overriding Considerations. Please see responses to comments 8.01 and
32.42.
32.45 The comment responds to comment 8.03 from EMAX, noting that the DSEIR correctly
identifies the Concept Plan Alternative as the environmentally superior alternative after
the Modified No project Alternative. The comment supports the DSEIR alternatives
analysis. Please also see response to comment 8.03.
32.46 The comment responds to comment 8.03 from EMAX, noting that the DSEIR analyzes
supplemental impacts of the Modified No Project Alternative, Please see response to
comment 32.40.
32.47 The comment responds to comment 5.04 from Richard Harmon, concurring that the
DSEIR should be corrected to state that the linear park will be maintained by the
developer, The SEIR has been corrected as suggested.
32.48 The comment responds to comment 5.06 from Richard Harmon, noting that two copies
of the three reports contained in the geotechnical appendix will be filed with the city
Engineering Division. No response is necessary.
WP51\548\FSEIR\F-II.548
THOMAS R. AOAMS
ANN BROAOWEL-L-
OANIEL- L-. CAROOZO
MARC O. .JOSEP....
LIZANNE REYNOLDS
... PPO"[SSIO......t.. CO~POA...TIO...
R E eEl V E D ~?
MAR t. 0 1996
PLANNING
ADAMS 8 BROADWELL
ATTORNEYS AT L.AW
6:;1 GATEWAY BOUL-EVARO, SUITE gOO
SOUT.... SAN ~RANCISCO. CA 9"080
0" eOUNSEL
CARL- L-. Mc:CONNEL-L-
PACKARO, MEL-L-BERG
l> Mc:CONNEL-L-
TEL.EPt-tONE
1"'5) 589-'660
~...
~ACSIMIL-E
1"'51 589-5062
March 20, 1996
HAND DELIVERY
Lida Budko
Terrabay Project Planner
city of South San Francisco
Planning Division
400 Grand Avenue
South San Francisco, CA 94080
Re: Draft Supplemental Environmental Impact Report for the
Terrabay Specific Plan and Development Agreement
Extension
Dear Ms. Budko:
Enclosed are the comments of the Building and Construction
Trades Council of San Mateo County, Mary Huber, Aurelio (Ray)
Mendoza and Michael Swanson on the Draft SEIR for the Terrabay
specific Plan and Development Agreement extension. All of these
commenters object to approval of the project.
We very much apprecLate the courtesy of the City's staff in
helping us locate and obtain copies of documents which were
necessary for our review ~) the DSEIR.
Thank you for your consideration of these comments. six
copies are enclosed for your convenience.
Very truly yours,
~~
Ann Broadwell
AB:cwt
Enclosure
cc: Marcy Schultz
Gary Saunders
t' :/
Cl061.010
ft
\r,J onn..o Oo't 1'lK)lCI<<J lMI>>f
COMMENTS OF
THE BUILDING AND CONSTRUCTION TRADES COUNCIL
OF SAN MATEO COUN1Y
ON THE
DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
FOR THE
TERRABAY SPECIFIC PLAN
AND DEVELOPMENT AGREEMENT EXTENSION
March 20, 1996
Prepared by:
Ann Broadwell
Lizanne Reynolds
Adams & Broadwell
A Professional Corporation
651 Gateway Blvd., Suite 900
South San Francisco, CA 94080
(415) 589-1660
In consultation with:
William Lettis & Associates. Inc.
1777 Botelho Drive, Suite 262
Walnut Creek, CA 94596
(510) 256-6070
Daniel Smith Engineering & Management
5311 Lowry Road
Union City, CA 94587
(510) 489-9477
,//'
..1/"
TABLE OF CONTENTS
I. INTRODUCTION....
.........
II. PROJECT DESCRIPTION
.... .....
A.
Extension of Development Agreement and Specific
Plan . . . . . . . . . . . . . . .
B.
Number of Dwelling units to be Approved is
Unclear . . . . . . . . . . .
III. TRANSPORTATION .
V.
IV.
VI.
C1061.00S
A.
Traffic Counts Are Out of Date and Not Meaningful .
Standard of Significance
B.
.........
C.
Required Approvals
D.
"Hook" Ramps at Bayshore Boulevard
E.
Project Traffic Impacts .
F.
Feasibility of Mitigation Measures
G.
The CUmulative Impacts Discussion Does Not Comply
with CEQA . . . . . . .
SOILS AND GEOLOGY
DRAINAGE AND WATER QUALITY .
A.
Drainage Ditches and Catchment Basins .
B.
Storm Water Pollution Prevention Plan . . .
C.
Wetlands and Streambed Alteration
1.
Factual Background
2.
Federal Clean Water Act Permit May be
Required . . . . . . . . . . .
. . . .
3.
Streambed Alteration Permit May be Required
PUBLIC SERVICES - Schools
A.
Background
i
Paqe
1
2
2
2
3
3
4
6
6
7
7
8
8
9
9
10
10
11
11
12
13
13
TABLE OF CONTENTS
(cont'd)
B.
Statutory Limits on School Impact Mitigation
C.
Mitigation Measures
1.
The Mitigation Measures in the DSEIR are
Inadequate . . . . . .
The city has Failed to do All it Can to
Mitigate School Impacts
2.
D.
Attendance at Brisbane Schools
VII. PUBLIC SERVICES - Sewer Service
E.
Calculation of School Impact Fees .
IX. NOISE
VIII. PUBLIC SERVICES - Water Service
X.
AIR QUALITY
A.
Standards of Significance . .
B.
Construction Impacts
C.
Cumulative Impacts
D.
Transportation Systems Management
XI . CULTURAL RESOURCES . .
C1061.00S
A.
Introduction
B.
Factual Background
C.
Discussion
1.
Failure to Consult with the State Native
American Heritage Commission
2.
Inadequate CEQA Mitigation . . . . . .
a.
CEQA Section 21083.2 Requirements. .
ii
Paqe
14
17
17
17
18
18
19
19
19
21
21
22
22
22
23
23
23
23
23
24
24
TABLE OF CONTENTS
(cont'd)
b.
Terrabay EIR Compliance .
(1)
(2)
(3)
capping of #40 . .
Deferred Mitigation for #92
(4)
Insufficient Information and
Mitigation for #234 ....
Inadequate Mitigation for
Unidentified Resources . .
(5) Potential Noncompliance with
Funding Guarantee Requirement
3.
Potential Applicability of National Historic
Preservation Act . . . . . . . . . . .
a.
Property "eligible for inclusion" in
National Register . . . . .
b.
What Constitutes a Federal
"Undertaking" . . . . . .
c.
Applicability to Terrabay
XII. ALTERNATIVES .
...........
Paqe
25
25
25
26
26
26
27
27
28
29
29
XIII. PROJECT CONSISTENCY WITH ADOPTED PLANS AND POLICIES . . 30
C1061.00S
A.
1994 Bay Area Clean Air Plan
.........
B.
Noise Element of South San Francisco General Plan
C.
Habitat Conservation Plan . .
1.
Dedication of Open Space to County . .
2.
Recording of CC&Rs for Habitat Funding .
3.
Covenants For Fire Buffers and Restricting
Pesticide Use . . . . . . . . . . .
4.
Location of Proposed Landslide Repairs . .
iii
. ~
30
30
30
31
32
33
33
TABLE OF CONTENTS
(cont'd)
5. Funding of Habitat Maintenance . .
6. Compliance Determination . .
7. Application to New Owner. .
D.
Precise Plan
E.
Grading Permit
F.
Development Agreement
1.
Applicable Law .
2.
Compliance with Development Agreement
G. Specific Plan and Municipal Code
1.
Geotechnical Requirements
2. Drainage Requirements
3.
Construction Phasing .
4. Transportation Systems Management Plan.
5. Hook Ramps From Southbound 101 . . . . .
6. Covenants, Conditions & Restrictions . .
XIV. CONCLUSION. . . . .
C1061.00S
...............
iv
Paqe
33
34
34
34
35
35 .. . .
35
35
37
37
38
39
39
40
40
40
COMMENTS OF
THE BUILDING AND CONSTRUCTION TRADES COUNCIL
OF SAN MATEO COUNTY
ON THE
DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
FOR THE
TERRABAY SPECIFIC PLAN
AND DEVELOPMENT AGREEMENT EXTENSION
I. INTRODUCTION
The Building and Construction Trades Council of San Mateo
County submits these comments on the Draft supplemental
Environmental Impacts Report for the Terrabay specific Plan and
Development Agreement extension.
This project raises significant environmental issues, which
should be carefully considered before the city determines whether
to approve the proposed project. The Building Trades Council,
its affiliated construction unions and their members are
interested in sustainable economic development. Continued
environmental degradation may jeopardize future jobs by making it
more difficult and more expensive for business and industry to
expand in California, and by making it less desirable to live
here. continued degradation can, and has, caused construction
moratoriums and other restrictions on growth which, in turn,
reduce future employment opportunities.
Additionally, construction workers themselves live in the
communities which suffer the impacts of environmentally
detrimental projects. Union members breathe the same polluted
air that others breathe and suffer the same health and safety
impacts. Unions have an interest in enforcing environmental laws
to protect those workers.
Construction workers are concerned about projects which
cause serious environmental harm without providing countervailing
economic benefits such as decent wages and benefits. CEQA itself
provides a balancing process where economic benefits are weighed
against significant impacts on the environment. The
environmental issues posed by the Terrabay project are presented
in these comments.
C1061.00S
1
II. PROJECT DESCRIPTION
A. Extension of Development Aqreement and Specific Plan
--.
The proposed project is an extension of the life of the
Development Agreement and Specific Plan. (Draft Supplemental
Env ironmental Impact Report, "DSEIR," p. 9.) However, the DSEIR ~3.01
does not state the proposed new termination date of either the
Development Agreement or of the Specific Plan.
-
Nor does the DSEIR explain how the Development Agreement
could have been extended. The Agreement was originally
authorized by ordinance in 1983 and executed in 1988. (DSEIR, p.
1.) The Development Agreement states that it expires on December
1, 1992. (Dev. Agt., p. 212.) The city Council has extended
the expiration date to February 14, 1997.
However, at the time the expiration date was extended, the
South San Francisco Municipal Code did not contain any provisions
for tolling a development agreement. Instead, it contained
strict limitations on the duration of development agreements.
The Code provided that:
no development agreement entered into by the city shall be
of a duration to exceed ten years from the effective date of
the adopting ordinance; nor shall anv development aqreement
be extended so that it expires on a date which is later than
ten vears after the effective date of the original ordinance "!22..0'"
adopting said development agreement. (9 19.60.180; emphasis 77. ~
added. )
Under this provision, it appears that the Development Agreement
for Terrabay could not be extended for more than 10 years beyond
the effective date of the original ordinance.
The ordinance approving and adopting the Development
Agreement with W.W. Dean and Associates was adopted on May 18,
1983, with an effective date 30 days thereafter, or on June 17,
1983. Therefore, it does not appear that the Development
Agreement could have been extended beyond June 16, 1993. Yet, it
was extended to February, 1997.
The DSEIR should explain how the Development Agreement could
have been extended beyond ten years and what the proposed
termination date of the Development Agreement would be.
Amendment of the Development Agreement to extend its expiration
would be a legislative act, subject to referendum.
B.
Number of Dwellinq Units to be Approved is Unclear
.....
---r
Table 2 of the DSEIR refers to the number of dwelling units ~?";
approved in the 1982 Specific Plan. (DSEIR, p. 52.) However,
C1061.00S
2
w
(A,JAIf.
wm:
footnotes 1 and 2 explain that the number of dwelling units was
reduced slightly in the 1989 Precise Plan. Because the applicant
is seeking an extension of the 1982 Specific Plan, it appears
that the City is being asked to reinstate approval of the larger ~G);
number of units. However, in other places, the DSEIR proceeds as .
though the smaller number of units is the approved number (e.g.,
Initial study, p. 4-7). The DSEIR should make clear which number
of units will be approved if the Specific Plan approval is
extended. 1
III. TRANSPORTATION
Enclosed is a letter from Smith Engineering and Management
providing comments on the traffic impacts of the proposed
project. The following are in addition to those comments.
A. Traffic Counts Are Out of Date and Not Meaninqful
The turning counts for the Oyster Point interchange and
related intersections are not based on current meaningful
information. As stated in Appendix B to the DSEIR, the traffic
counts are based on 1993 and 1994 fragmentary information from
distant intersections. (DSEIR, App. B, p. 1.) The reason given
is that the oyster Point interchange had not been completed when
the DSEIR was prepared.
However, one of the most significant traffic impacts from
this project is the impact on the Oyster Point interchange and
other related roadways and interchanges. The Oyster Point
interchange was completed and opened for service before this
DSEIR was released for public comment. No reason is given for
the failure to obtain current traffic counts, and no meaningful ~3t)t
mitigation measures can be proposed or adopted in the absence of
current information.
The DSEIR should be revised to include current information
on traffic impacts, taking into account operation of the new
Oyster Point interchange. This is particularly important because
even without any Terrabay traffic, the interchange becomes
congested. Traffic southbound on Bayshore Boulevard often backs
up through two traffic light changes in the morning, sometimes
the backup reaches nearly to the southbound freeway exit.
Additionally, traffic exiting northbound 101 onto Dubuque backs
up through the first stop light in the mornings. This congestion
is shown in the photographs submitted with these comments.
-
The map on page 67 is entitled "existing land uses," but
it does not show any land uses. Instead, it is a street map. ;l.OS'
The existing land uses should be shown.
--
C1061.00S
3
B.
standard of Siqnificance
-
The DSEIR establishes a standard of significance for traffic
increases on freeways, ramps and at interchanges. Where the LOS
is already at level F, the DSEIR states that a significant impact
will not occur unless the traffic level increases by at least 2%.
(DSEIR, p. 114.)
That standard of significance is not appropriate when a
significant environmental impact has already occurred. LOS F
means that traffic is already suffering a significant impact.
When an environmental problem is already enormous, any additional
contribution may be significant.
The courts have held that it is a violation of CEQA to
compare the project contribution with the magnitude of the
existing problem to develop a ratio of significance. Focussing
on the ratio between the project's impacts and the overall
problem is contrary to the intent of CEQA. The result of such a
ratio is that the greater the overall problem, the less
significant are the project's contributions to the cumulative ~~
impacts. Instead, of dismissing the project's cumulative impacts
as small in comparison to the overall problem, the EIR must
assess the collective effect that this and other projects have
upon traffic. (Kings County Farm Bureau v. city of Hanford
(1990) 221 Cal.App.3d 692 [270 Cal.Rptr. 650].)
Instead of establishing a 2% level of significance, the
DSEIR should consider as a significant impact any contribution of
additional traffic to a freeway segment, ramp, or intersection
which is already functioning at LOS F. That impact should be
mitigated if feasible. If not feasible, then the City would have
to consider whether there are overriding considerations which
justify approval of the project.
According to the information in the DSEIR, the following
freeway segments, ramps and intersections would suffer a
significant environmental impact from this project, because they
are adding traffic to an LOS of F. The DSEIR states that the
following areas would be operating at LOS F, even without this
project.
'I
CaNT.
C1061.00S
4
Year 2000 (DSEIR, p. 105, 108)
co NT:
\
. US 101 southbound off-ramp/northbound Bayshore Blvd
intersection (AM)
. Hillside Blvd./Chestnut Ave. intersection (PM)
. US 101 segment north of Sierra Point (PM)
[. US 101 southbound off-ramp to Bayshore Blvd. (AM)2]
Year 2010 (DSEIR, p. 105, 108)
.
sister cities Blvd./Oyster Point Blvd./Bayshore
Blvd./Airport Blvd. intersection (AM)
~.o~
.
Oyster Point Blvd./Dubuque Ave./US 101 northbound on-
ramp (AM)
.
US 101 southbound Off-ramp/northbound Bayshore Blvd.
(AM)
.
sister Cities Blvd./Oyster Point Blvd./Bayshore
Blvd./Airport Blvd. intersection (PM) (LOS E
signalized)
.
Dubuque Ave./US 101 northbound Off-ramp/southbound on-
ramp (PM)
.
Hillside Blvd./Chestnut Ave. intersection (PM)
.
US 101 southbound off-ramp/northbound Bayshore Blvd.
(PM)
.
All US 101 southbound freeway segments near the project
(North of Sierra Point; Sierra Point to Oyster Point;
Oyster Point to Grand Avenue; Grand Avenue to South
Airport) (PM) (Table 7, p. 98.)
",
(.{)NT.
-
2 The DSEIR does not provide any information about the LOS
for this off-ramp in 2000, but it does say that the southbound
off-ramp/Bayshore Blvd. intersection would be operating at an
unacceptable AM peak LOS E and "it would be expected that the
off-ramp traffic would back up to the southbound freeway mainline-
unless additional lanes were provided on the intersection
approach or unless off-ramp detectors would control signal
operation and allow off-ramp traffic to clear whenever backups
approached the freeway mainline." (DSEIR, p. 108.) If the off-
ramp backs up to the freeway mainline, that should be considered
a significant impact.
~.07
-
C1061.00S
5
CPN;:
. US 101 southbound off-ramp to Bayshore Blvd. (AM)
. US 101 northbound off-ramp to Dubuque Ave. (AM)
Any impact on any of these areas should be considered a
significant impact, which must be mitigated if feasible.
For example, the DSEIR states that Phase I of the project
would not increase volumes by 2% or more along the freeway
segment north of Sierdrda'tP~intlitn efitf~er.2000tOr 2tOh10. (DSEIRt, p. ~.l)GP
129.) However, any a ~ ~ona ra ~c ~mpac on . ese segmen s
should be considered a significant impact, because they are
operating at LOS F even without the project.
similarly, the DSEIR states that in the year 2000, Phase I
of the project would not significantly affect any intersections
during the AM peak hour (DSEIR, p. 118), but the us 101
southbound Off-ramp/northbound Bayshore Boulevard intersection
will be functioning at LOS F in the year 2000 in the AM peak hour
unless signalized (DSEIR, p. 105). The project's impact on this
intersection is significant and it should be mitigated.
The same is true
segments listed above
those areas should be
mitigated.
for the intersections, ramps and freeway
in the year 2010. All project impacts in
considered significant and should be
-
C.
Required Approvals
--
The list of required approvals indicates that approval from
the City of Brisbane would be needed only for implementation of
any mitigation for traffic impacts involving Bayshore Boulevard.
(DSEIR, p. 62.) However, in several places, the project
description itself shows a left turn from northbound Bayshore ~~~
Boulevard into the commercial area. (E.g., DSEIR, Figure 13, 77
Figure 19, Specific Plan Exhibit S35.) Because Bayshore
Boulevard is divided at that point by a median, approval would be
needed from the City of Brisbane for such a left turn.
The DSEIR should therefore indicate that implementation of
the project itself requires approval from the City of Brisbane,
not just implementation of mitigation measures.
-
D.
"Hook" Ramps at Bayshore Boulevard
--,
The DSEIR recommends improvements to the US 101 Southbound
off-ramp to Bayshore Boulevard. It states that as a mitigation
measure, each phase of the Terrabay project should provide a
"fair share" contribution towards the recommended Base Case
improvements. (DSEIR, p. 152.) However, the Development
Agreement provides that:
~.~
C1061.00S
6
,}
COm-.
c;e,NT:
The developer of the Terrabay project shall be completely
responsible for the preparation of plans and the
construction of the following public improvements, unless by
prior agreement, another public or private agency or party
has agreed to share in the cost of said improvements ... 5. ~~
"Hook" on and off Highway ramps from Highway 101 to Bayshore 77."-;./
Boulevard in the vicinity of the Oyster Point
Boulevard/Highway 101 Scissors Ramps. (Dev. Agt., Exh. G.)
Therefore, it appears that the developer of the Terrabay project
must pay the cost of construction of the hook ramps, unless
another entity has agreed to share the cost.
---.J
E.
proiect Traffic Impacts
-
The DSEIR proposes that Terrabay pay its "fair share" of
intersection and LOS improvements, as mitigation for several of
the traffic impacts of the project. However, the DSEIR does not
address the appropriate mitigation if no other projects come to
fruition, so that there are no other projects with which to share
the cost of expensive mitigation measures.
For example, the flyover from southbound 101 to eastbound
Oyster Point Boulevard is undoubtedly expensive. If Terrabay is
the only project to be approved and built-out, it is unlikely ~3.1l?
that it could bear the entire cost of constructing that flyover.
Yet, without the flyover, the impacts of Terrabay traffic would
not be mitigated.
The DSEIR should require substitution of another measure to
mitigate Terrabay traffic if other projects are not available to
share the cost of expensive proposed mitigation measures. In the
absence of a substitute mitigation measure, and in the absence of
any guarantee that others will be available to share the cost of
expensive mitigation measures, the City would not have evidence
upon which to base a finding that the traffic impacts had been
mitigated.
-
F.
Feasibility of Mitiqation Measures
-
The DSEIR proposes several traffic mitigation measures
without discussing their feasibility. One example is the flyover ~ll
from southbound US 101 to eastbound Oyster Point. The DSEIR
should discuss whether such a mitigation measure is feasible, so
that the City will have adequate information before deciding
which mitigation measures should be imposed.
-
C1061.00S
7
G.
The Cumulative Impacts Discussion Does Not Comply Wit~
CEOA
The discussion of cumulative traffic impacts does not
provide the information required by CEQA. The CEQA Guidelines
state that a discussion of cumulative impacts shall include
either a list of past, present, and reasonably anticipated future
projects, or a summary of projections contained in an adopted
general plan or related planning document. (14 Cal.Code Reg. 9 ~;.r~
15130. )
Here, the DSEIR states that the projections of future
traffic volume are based on traffic volume projections in the
East of 101 Area Plan Dra~t EIR and the Brisbane General Plan
Circulation Element. (DSEIR, p. 90.) However, the DSEIR does
not provide a summary of the projections contained in those
planning documents. In the absence of that information, it is
not possible to determine whether the traffic analysis is
adequate.
(/~.... .
-
IV. SOILS AND GEOLOGY
Enclosed with these comments is a letter from William Lettis
and Associates, Inc., commenting on the geotechnical aspects of
the DSEIR. The following is in addition to those comments.
The DSEIR concludes that landslides and gullies have
occurred on the site since it was graded and that they will occur
in the future and should be considered a part of the homeowners'
association's maintenance responsibilities. (DSEIR, p. 169.) As
to slumping and erosion from the "goat farm" area, the DSEIR
concludes that the streets would function as a buffer for the
slumped and eroded material. (DSEIR, p. 170.) These landslides
and gullies appeared after the original approvals and after the
site was graded. (DSEIR, p. 1G8.)
-
The possibility of future landslides and gullies should be
considered a significant environmental impact. CEQA provides
that a project will normally have a significant effect on the ~.11
environment if it will "cause substantial flooding, erosion or
siltation." (CEQA Guidelines, App. G(q}.) The DSEIR states that
the landslides would be approximately 40' by 100'. (DSEIR, p.
169.) According to the DSEIR, gullies are up to four feet wide
and three feet deep. (DSEIR, p. 169.) Erosion would be on-going r
according to the DSEIR.
People who buy homes in Terrabay would certainly consider
periodic landslides onto their streets and erosion from gullies
to be significant events. In addition to the potential danger
due to lack of emergency access, the inconvenience of streets
blocked by landslides and the worry about the danger of
landslides, the homeowners would have to pay to repair and
C1061.00S
8
"
e()1/tJf:
maintain these landslides and gullies through their homeowners'
association, according to the DSEIR.
There is no discussion in the DSEIR of the feasibility of
requiring the homeowners to pay for repair and maintenance of
these landslides. The DSEIR should provide a cost estimate, and
estimate the level of reserves that would be necessary to meet
these expenses. According to the attached letter from William
Lettis & Associates, Inc., this issue was discussed during the I
preliminary stages of Phase I design, and no satisfactory
solution was found. (Lettis, p. 2.) Unless the need to repair ~~.I~
and maintain the landslides is addressed, the city would have no
basis for concluding that these impacts have been mitigated.
These landslides and gullies should be considered
significant environmental impacts, and the DSEIR should suggest
methods for mitigating the impacts prior to construction of any
homes. The City should consider reducing the density of the
project if it is necessary to protect residents from
landslides.3 If the impacts cannot be mitigated, then the city
would have to consider whether overriding considerations justify
approving the project.4
v. DRAINAGE AND WATER OUALITY
A. Drainaqe Ditches and Catchment Basins
-
It seems clear that the drainage ditches and catchment
basins are not functioning to mitigate the impacts of drainage
from the project site. The DSEIR itself notes that the drainage
ditches and catchment basins which were installed after the prior
approvals are not functioning properly. The DSEIR states that
they should be cleaned and repaired and that perhaps their design
should be reconsidered. (DSEIR, p. l77.)
Additionally, the South San Francisco Municipal Code
(Terrabay Specific Plan District) and the Specific Plan require a ~,~
storm drain system designed to handle runoff of an intensity 7~ 1
equal to the worst storm of record or one-hundred year return
period, whichever is worse (Municipal Code 9 20.63.080; specific
3 The specific Plan provides that, "The density of the
residential portion of the project may be modified or reduced by
the City if detailed geotechnical data and/or implementation of
city development requirements indicate that said modification or
reduction is necessary, provided, however, that the overall
density of the project is not exceeded." (Specific Plan
Amendment # 12.)
V
C4Nr.
The DSEIR should provide information about the
performance of the South Slope area during the 1989 earthquake.
C1061.005
9
ct>Hi.
Plan, p. 17). The catchment basin/ditch drainage system has not
withstood recent storms.
The DSEIR does not propose specific modifications in the
design of the system and does not provide any assurance that an
adequate system can be designed in light of the steep slopes.
Instead, the DSEIR proposes as a mitigation measure that the
applicant fund a study of the possible malfunctioning of the
catchment basin and ditch drainage system, and that the applicant
shall be required to comply with any recommended mitigation
measures before dedicating the system to the County. (DSEIR, p. ~.I~
181. )
In light of the failure of the previous system, a proposed
future study is not an adequate mitigation measure. There is no
assurance that this impact can be mitigated, and therefore
investigation and consideration of mitigation measures cannot be
deferred to the future. (Sundstrom v. County of Mendocino (1988)
202 Cal.App.3d 296 [248 Cal.Rptr. 352].) The study should be
performed prior to project approval, so that the City can
determine whether this impact can actually be mitigated. If this
impact cannot be mitigated, the City must decide whether the
project should be approved.
-
B.
storm Water Pollution Prevention Plan
,
Under the federal Clean Water Act, a Stormwater Pollution
Prevention Plan must be adopted to prevent pollution of the San
Francisco Bay from project run-off. The project site has been
partially graded and, according to the DSEIR, the catchment
basins and drainage ditches are not functioning. It is entirely
likely that silt and other pollutants are being washed into the
Bay in violation of the Clean Water Act, and possibly in ';.I~
violation of Municipal Code 9 l4.04.
The DSEIR should provide information about the current
environmental impacts on San Francisco Bay and should suggest
specific and effective mitigation measures. Additional grading
should not be allowed until the adverse impact is fully
mitigated. If a SWPPP has been adopted, its provisions should be
discussed in the DSEIR, so that its adequacy as a mitigation
measure can be assessed.
-
C.
Wetlands and Streambed Alteration
--,
The 1982 EIR and the DSEIR contain passing references to
seasonal streams and riparian/vernal vegetation. However, I
neither document discusses whether activities associated with the ~~. h
project will affect these areas and trigger permit requirements
under state and federal law. In particular, the project may
require a permit from the U.S. Army Corps of Engineers ("Corps")
under section 404 of the federal Clean Water Act, and a streambed
"
C1061.00S 10 COIJT.
CD At1:
alteration permit from the California Department of Fish and Game
("CDFG"). The DSEIR should discuss whether these areas will be
affected and whether these legal requirements will be satisfied.
1. Factual Backqround
The 1982 EIR and the DSEIR state that there are several
seasonal streams above or on the project site which have "cut
well-defined channels that appeared as ravines on steeper slopes,
and swales on shallower slopes." (DSEIR, p. 173; 1982 EIR, p.
70.) These ravines and water courses "create a variety of
microclimates favorable for the growth of plants requiring ~./~
greater moisture," (DSEIR, p. 184), and, thus, support "riparian-
like vegetation." (DSEIR, p. 183; 1982 EIR, p. 104.) In some
portions of the site, such as the northeastern segment, "abundant
moisture supports patches of vernally wet type vegetation."
(1982 EIR, p. 103.) There also are several springs and ponded
drainage areas above landslide areas at the western end of the
site. (DSEIR, p. 174; 1982 EIR, p. 71.)
The storm drainage system is intended to divert water that
normally runs off of upper slopes onto the lower slopes proposed
for development. (DSEIR, pp. 178, 180.)
Despite the presence of several streams and riparian areas
on the project site, the Initial study determined that there
would be no significant changes that would modify the channel of
a river or stream. (DSEIR, App. A, p. 12.) There was no mention
in either the Initial Studr or the DSEIR text of whether the
project would affect any wetland or riparian habitat.
-
-
2. Federal Clean Water Act Permit May be Required
If the project would disturb a watercourse or involve the
dredging or filling of wetlands, either during construction or
landslide stabilization, the project applicant may need a permit
from the Corps. The Corps has jurisdiction over all waters of ~.Ijr
the United States under section 404 of the Clean Water Act, 33
U.S.C. 9 1344. This jurisdiction has been broadly interpreted
and extends to intermittent streams and creeks. (Quivira Mining
Co. v. U.S. EPA (lOth Cir. 1985) 765 F.2d 126, 129-30; United
states v. Phelps Dodge Corp. (D. Ariz. 1975) 391 F.Supp. 1181,
....../
c.om:
5 The suggested Initial Study checklist in Appendix I of
the CEQA Guidelines lists "Wetland habitat (e.g., marsh,
riparian, and yernal pool)" as a potential environmental impact
to be evaluated. (CEQA Guidelines, Appendix I, 9 VII.d.) The
Initial Study for this project omitted this issue. (See DSEIR,
App. A.)
C1061.00S
11
CPNT:
1187.}6 The Corps has asserted jurisdiction over areas that
pond after rainstorms.'
Even if the disturbed area is small (i.e., less than 10
acres), the activity may be subject to the conditions of a
nationwide permit.s These conditions include the use and
maintenance of appropriate erosion and siltation control, no
actions jeopardizing endangered or threatened species or 2 17
adversely modifying their critical habitat, and no activities ~7.
affecting properties listed or eligible for listing in the
National Register of Historic Places. (33 C.F.R. Part 330, App.
A(e}.) The state also must issue a water quality certification
before the nationwide permit may be issued. (33 C.F.R. 9
330 . 4 (c), App. A (C) (9) . }
The DSEIR should clearly indicate whether any activities
associated with the project (e.g., activities affecting seasonal
streams and riparian areas) would affect any watercourses or
wetlands subject to the Corps' jurisdiction, and whether these
activities comply with the requirements of the federal Clean
Water Act described above. '
3.
streambed Alteration Permit May be Required
-,
Before a person may "substantially divert or obstruct the
natural flow or substantially change the bed, channel, or bank of
any river, stream or lake designated by the [CDFG]," CDF&G must
first be notified and its approval obtained. (Fish & Game Code 9
1603.)9
-;~ I~
V
~T:'
6 Most Corps districts interpret such streams to include
drainages that receive water only during rain events. (Want, Law
of Wetlands Regulation 9 4.04[2].) However, most districts will
not assert jurisdiction unless a drainage bed with an
identifiable high-water mark or ledge has been established.
(Ibid. )
, Want, supra, 9 4.04[3], fn. 45 (citing letter from
Charles Murray, Asst. Administrator, U.s. EPA, Region IX, to Col.
Fred Butler, Dist. Engineer, Corps L.A. District, regarding
jurisdictional determinations of the Ballona Creek land tract at
Playa Del Ray, CA (dated Feb. 17, 1987).}
8 See 33 U.S.C. 9 1344(e) (1) (establishing Corps authority
to issue general ("nationwide") permits authorizing activities
with minimal environmental impact); 33 C.F.R. Part 330
(nationwide permits).
9 CDFG has 30 days after receiving notification to
determine whether a fish or wildlife resource may be
substantially adversely affected and to submit proposed
C1061.00S
12
cPfo((":
For purposes of implementing section 1603, CDFG has
designated "all rivers, streams, lakes, and streambeds in the
state, including those with intermittent flows. . .." (14
Cal.Code Regs. ("C.C.R.") S 720.) "streams (Includes Creeks
Rivers)" are defined as follows:
and
[A] body of water that flows at least periodically or
intermittently through a bed or channel having banks
and supports fish or other aquatic life. This includes
watercourses having a surface or subsurface flow that
supports or has supported riparian vegetation. (14'
C.C.R. 9 1.72.)
~~I~
The DSEIR states that there are seasonal streams with well-
defined channels on or above the project site and that ravines
and water courses support riparian-like vegetation. (DSEIR, p.
173, 183.)
If activities associated with the project will substantially
divert or obstruct the flows of the seasonal streams identified
in the DSEIR, or substantially change their beds and banks, CDFG
should be notified so that appropriate mitigation measures can be
imposed. The DSEIR should also state that this is a required
goyernment approval for the project.
-
VI. PUBLIC SERVICES - Schools
The city has the authority to impose additional mitigation
measures or deny the request to amend the specific Plan based on
unmitigated school impacts. The DSEIR's conclusion that school
impacts have been mitigated to insignificance is not supported by
substantial evidence. Therefore, the City must either impose
additional mitigation measures, deny the specific Plan amendment,
or adopt a statement of overriding considerations stating that
project approval is warranted despite the significant,
unmitigated school impacts.
A.
Backqround
~3d~
The residential portion of Terrabay is to provide homes for
nearly four hundred school-age children. (DSEIR, p. 209.) These
children will be served by three school districts .10 Some of
mitigation measures to the applicant. (Ibid.) Unless CDFG fails
to act on the notice within 30 days, the affected person cannot
commence activities until mutual agreement is reached with CDFG
regarding mitigation of impacts. (Ibid.)
10 The three districts and the estimated additional
schoolchildren are the South San Francisco Unified School
District (260), the Brisbane School District (90), and the
"
C1061.00S
13
~.
cqvr:
the affected schools are already operating at or over capacity,
and all of the affected schools are expected to be operating over
capacity by 1999-2000. (DSEIR, pp. 202-03.)
The DSEIR states that increased enrollment generated by the
project will lead to insufficient classroom and ancillary school
facilities. (DSEIR, pp. 209-10.) Hence, it is foreseeable that
the project ultimately will lead to physical impacts on the
environment from school construction. overcrowding could also
lead to additional traffic impacts or an increased need for
public services such as buses. (Goleta Union Scb. Dist. v.
Regents of tbe Univ. of California (1995) 36 Cal.App.4th 1121, 44
Cal.Rptr.2d 110, 115.)
The General Plan for the city of South San Francisco
establishes the following policy:
No development proposal should be approved if
supporting utility systems and public services are
inadequate to accommodate the proposed development.
(General Land Use Policy 6, p. 3-2.)
According to the CEQA Guidelines, land use plan inconsistencies
are a presumptively significant impact. (CEQA Guidelines,
Appendix G (a) . }
~./~
The primary mitigation measure for school impacts which is
suggested in the DSEIR is a requirement that the developer pay
the statutorily required school impact fees. (See Gov. Code 99
53080, 65995.) However, these fees will not be sufficient to
cover the full costs of this overcapacity (e.g., additional
classrooms, restrooms, physical and special education facilities)
in two of the three affected school districts. (DSEIR, pp. 209-
10.) Therefore, the DSEIR recommends that the developer
"voluntarily agree" to negotiate with the school districts to
provide additional funds or implement other mitigation measures.
(DSEIR, p. 213.)
B. Statutorv Limits on School Impact Mitiqation
In 1986, the Legislature passed a set of laws aimed at
curbing fees and other requirements imposed on development
projects to remedy school impacts. (Stats. 1986, c. 8S7.)
Government Code section 5308011 authorizes school districts to
Jefferson Union High School District (20).
(DSEIR, p. 209.)
11 All further references in this discussion of school
impact mitigation measures are to the Government Code unless
otherwise indicated.
C1061.00S
14
,/
&ONT:
GQfY(:
levy fees and other requirements on development projects.12 But
section 65995 establishes fee limits and prohibits local agencies
from imposing any other "fee, charge, dedication or other
requirement" on development projects. (S 65995 (a).) 13
section 65996 establishes the "exclusive methods of
mitigating environmental effects related to the adequacy of
school facilities" when establishing mitigation measures or
considering whether to approve a development project under CEQA.
(9 65996(a}.)14 This section also prohibits an agency from
denying project approval under CEQA on the basis of inadequate
school facilities. (S 65996 (b) .)
In Grupe Devel. Co. v. Superior Court (1993) 4 Cal.4th 911,
917, 16 Cal.Rptr.2d 226, the court held that, with the exception
of special taxes levied under Mello-Roos,15 the Legislature
intended to preempt all other methods of imposing fees and other
requirements for school facilities on developers. (Ibid.)16
12 A "development project" is defined as: "[A]ny project
undertaken for the purpose of development, and includes a project
involving the issuance of a permit for construction or
reconstruction, but not a permit to operate." (9 53080(a) (2}.)
13 Special taxes under the Mello-Roos Community Facilities
Act ("Mello-Roos"), 99 53311-53317.5, are expressly excluded from ,,~./t?I
this prohibition. (9 65995(f).} ,r~ wi
Mello-Roos authorizes local government agencies, including
school districts, to form community facilities districts to
finance the purchase, construction, expansion, improvement or
rehabilitation of any real or tangible property. (9 53313.5.)
(99 53326, 53328.) To establish a Mello-Roos district, the
agency must adopt a resolution of intent and provide for public
notice and hearing. After a district is formed, the agency may
hold an election to authorize a proposed special tax (2/3 voter
approval required).
14 These methods include, in addition to impact fees
required under sections 53080 and 65996, school building lease-
purchases, emergency leasing of school facilities and portable
classrooms, issuing bonds, and establishing a Mello-Roos
community facilities district. (9 65996(a) (1}-(7).)
15
See, supra, footnote 13.
16 These limitations have even been found to preempt land
use planning and zoning consistency requirements. In Corona-
Norco Unified Sch. Dist. v. city of Corona (1993) 13 Cal.App.4th
1577, 1585, 17 Cal.Rptr.2d 236, the court held that, although
"the consistency doctrine is 'the linchpin of California's land
C1 061. 005
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Notwithstanding the strict court rulings on the preemption
issue, the courts of appeal have limited the restrictions in
sections 65995 and 65996 to adjudicative agency action (e.g.,
variances, subdivision map approvals, building permits,
conditional use permits) .17 The courts have reasoned that
sections 65995 and 65996 only apply to "development projects,nU
which are limited to adjudicative actions. (Ibid.) Hence, a
local agency can impose additional mitigation measures or deny
project approval based on inadequate school facilities as long as
the approval is legislative in nature (e.g., general/specific
plan adoption 'or amendment, zoning changes). (Ibid.)lt
Section 65996(b) 's project denial prohibition is also
inapplicable to legislative actions. In William S. Hart Union
High Sch. Dist. v. Regional Planning Comm'n (1991) 226 Cal.App.3d
1612, 1626-27, 277 Cal.Rptr. 645, the court held that a school
district could challenge a county's legislative approvals related
to a proposed development under CEQA on the grounds that the
county failed to do all it could to mitigate adverse school
impacts. (226 Cal.App.3d atpp. 1626-27 (e.g., county could have
denied requested zoning change); see also Mira Devel. Corp. v.
City of San Diego (1988) 205 Cal.App.3d 1201, 1216-1218, 252
Cal.Rptr. 825 (g 65995 does not limit city's ability to deny ~~.,~
zoning application).) ~:7. ~
The proposed Terrabay project consists of two legislative
actions: amending the Specific Plan and amending the Development
Agreement to extend their terms. Therefore, the limitations and
use and development laws,' . . . . the Legislature has clearly
mandated that development takes precedence to the adequacy of
school facilities."
17 See Murrieta, 228 Cal.App.3d at p. 432, 434 (general
plan amendment approving 210,000-acre community plan was
legislative); William S. Hart Union High Scb. Dist. v. Regional
Planning Comm'n (1991) 226 Cal.App.3d 1612, 1626-27, 277
Cal.Rptr. 645 (approvals for CUP, zoning changes, local plan
amendment, development agreement and tentative subdivision tract
map were legislative; court's analysis focused on zoning change);
Mira Devel. Corp. v. City of San Diego (1988) 205 Cal.App.3d
1201, 1230-31, 252 Cal.Rptr. 825 (rezoning of 11 acres was
legislative). Compare Corono-Norco, 13 Cal.App.4th at p. 1586
(tentative tract map approvals were adjudicative).
18
See definition, supra, footnote 12.
It The courts have acknowledged that, for all practical
purposes, a legislative action may have the same effect on a
developer as an adjudicative action. (Hart, 226 Cal.App.3d at p.
1623-24 & fn. 12; Mira, 205 Cal.App.3d at p. 1218.)
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prohibitions in sections 65995 and 65996 do not apply to those
actions.
C. Mitiqation Measures
1. The Mitigation Measures in the DSEIR are
Inadeauate
The DSEIR imposes three mitigation measures to address
school impacts. First, the developer is required to pay the
school impact fees required by section 65995. Second, the
developer is to install a sidewalk along Bayshore Boulevard for
children walking to school. Third, the developer is to
"voluntarily agree" to negotiate with the school districts
regarding additional mitigation. (DSEIR, pp. 31-32.) No
information is provided regarding whether or when such a
voluntary agreement might take place. ~~~.J~
The DSEIR admits that the statutorily required impact fees
are inadequate to mitigate the project's school impacts to below
significance. (DSEIR, p. 31.) And there is no assurance that
the developer will agree to provide additional mitigation, or
that this voluntary mitigation will be sufficient to reduce these
impacts to insignificance. Yet the DSEIR concludes that school
impacts have been mitigated to a less than significant level.
(DSEIR, pp. 31-32.) There is no substantial evidence to support
this conclusion. (See, e.g., Murrieta Valley Unified Sch. Dist.
v. County of Riverside (1991) 228 Cal.App.3d 1212, at pp. 1234-
35; 279 Cal.Rptr. 421.)
Moreover, approving the project without ensuring that
adequate school facilities exist violates General Plan Policy 6,
discussed above. This land use inconsistency should be
identified as an additional significant impact of the project.
The city should either impose additional mitigation
measures, disapprove the project, or issue a statement of
oyerriding considerations justifying these impacts.
-
The DSEIR should also evaluate school impacts beyond 1999---'
2000, which is a mere 3-4 years into the future. An extended I
analysis may reveal much more significant impacts. When ;3.~
evaluating other impacts, the DSEIR forecasts to 2010 (e.g.,
traffic, water). (DSEIR, pp. 128, 204.) There is no reason why
school impacts should not be given similar treatment.
-
2. The city has Failed to do All it Can to Mitigat~
School Impacts
The developer has asked the City to extend the expiration ~;.l~
date of the Specific Plan. This constitutes an amendment to the
Specific Plan and, thus, is a leqislative action not subject to
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the limitations in sections 65995 and 65996. Thus, the City is
not constrained by sections 65995 or 65996 from considering and
imposing additional mitigation measures in the DSEIR, or from
denying the requested extension based on inadequate school impact
mitigation. (Murrieta, 228 Cal.App.3d at p. 1234.)
One mitigation measure the City could consider is phasing
the project until adequate school facilities are in place. The
city or the school districts could also create a Mello-Roos
district to levy a special tax to pay for additional school
facilities. The DSEIR should examine the possibility of other
mitigation measures.
~~.I~
---.J
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D. Attendance at Brisbane Schools
The DSEIR states that students from portions of the Terrabay
project will attend elementary and junior high schools in
Brisbane. The DSEIR asserts that these schools are within
walking distance of the project. (DSEIR, p. 203.)
The DSEIR should find that having students walk from the
Terrabay project to Brisbane schools could create a significant
adverse impact. These students can only walk to Brisbane by
walking along Bayshore Boulevard, which is a busy thoroughfare.
Further, when the project is fully built-out, the students will
have to walk past the commercial area, and Bayshore Boulevard
will have additional traffic.
~. z.r
CEQA provides that the local agency shall find that a
project may have a significant effect on the environment when it
will cause substantial adverse effects qn human beings, either
directly or indirectly. (Guidelines 9 15065(d).} The potential
harm to young students having to walk along Bayshore Boulevard '
from South San Francisco to Brisbane and back should be a
significant impact.
The DSEIR should suggest ways to mitigate this impact
(funding of school buses, installing a sidewalk with fencing
between the street and the sidewalk, installing street lights).
If the impact cannot be mitigated, the City would have to
consider whether overriding considerations justify extending the
project approvals.
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E. Calculation of School Impact Fees
The DSEIR calculates that 270 students will attend
elementary and middle schools (120 in City elementary schools, 60 ~~.Z~
in City middle schools, 90 in Brisbane schools), and that 100
students will attend high school (80 in City schools, 20 in
Jefferson schools). (DSEIR, p. 209.) The DSEIR should explain
how these figures were derived. It would appear that the 270
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elementary and middle school students will eventually attend high
school, causing additional impacts on the high schools.
71. 'a
The derivation of these figures and the calculation of the
impact fees should be further explained.
VII. PUBLIC SERVICES - Sewer Service
-
According to the DSEIR, both the on-site and off-site
wastewater systems "have problems" due to storm and/or
groundwater infiltration. (DSEIR, p. 211-213.) The DSEIR
proposes that those systems be inspected and repaired to the
city's satisfaction prior to city acceptance of any maintenance
responsibilities. (DSEIR, p. 214.)
--,
~~. 23
However, a more appropriate mitigation measure would be to
require the applicant to repair those -systems to the city's
satisfaction before any other'physical work is done on the
project site. It is by no means clear that this problem can be
satisfactorily mitigated, and the DSEIR does not set forth any
proposed repair measures. The City should not allow the project
to go forward until this problem is resolved. If the problem
cannot be resolved, approval of the project should be
reconsidered.
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VIII.
PUBLIC SERVICES - Water Service
The 1982 Specific Plan states that the portion of the ?3.~
project east of the PG&E easement was not within the service area
of the California Water Service Company, and would have to be
annexed. The DSEIR should state whether that annexation has
occurred.
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IX. NOISE
The 1990 Noise Element of the City's General Plan addressees
noise impacts from freeways and highways, and adopts the
following policy:'
Development proposals located within the 65 dB CNEL contour
due to traffic noise shall include analysis by a qualified
acoustical engineer so as to determine appropriate measures ~.~5
to mitigate traffic noise impacts. (Policy N-11.) ?7-
The Technical Appendix to the Noise element shows that parts of
the Terrabay project are within the 65 dB CNEL contour due to
traffic noise. (Noise Element, Technical Appendix, Map following
p. 7.)
The DSEIR does not indicate that a qualified acoustical
engineer has analyzed the noise impacts on the portions of
Terrabay that are located in the 65 dB contour due to traffic, as
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required by the Noise Element. The only noise measurements
mentioned in the DSEIR were taken in 1982. (DSEIR, p. 222.)
Because the Noise Element requires that a "development ~3Z5
proposal" include a noise analysis, and the current Specific Plan
does not include such an analysis, approval of an extension of
the Specific Plan without the required analysis would not be
consistent with the Noise Element of the General Plan.
-
Further, the information in the DSEIR is not current. The--'
DSEIR has taken a sentence from the 1990 Noise Element and
presented it as current information. Thus, the 1996 DSEIR
states:
Caltrans oro;ections for US 101 traffic volumes ranqe from
158.000 to 225.000 vehicles per day. as compared with the
current volume of 214.000 vehicles per day. As a result,
future changes in us 101 noise levels are also
unpredictable. (DSEIR, p. 222; emphasis added.)
The underlined sentence is virtually verbatim from the 1990 Noise
Element, which states:
Caltrans currently is revising their forecast for freeway
and highway noise in the South San Francisco area. The
current proiections for the Bayshore freeway (for instance)
are 158.000 to 225.000 vehicles per day. compared with the
current volume of 214.000 vehicles per day. Thus the
current Caltrans estimates for the Bayshore Freeway, for I-
280 or for El camino Real provide no basis for predicting
future noise exposure. Therefore, the best noise exposure
estimate for South San Francisco in the year 2005 is the
current noise exposure. (1990 Noise Element, Technical
Appendix, p. 6, emphasis added.)
The DSEIR should not present information which dates back at
least to 1990 as though it were current information. Instead,
the current information should be provided.
~.u.
Further, the DSEIR's statement that future noise levels are
"unpredictable" is contradicted by the city's 1990 Noise Element,
which states that current noise is the best predictor of future
noise. The DSEIR should measure current noise, analyze traffic ~~.~7
projections, and provide an estimate of future noise. 77
The information about future traffic projections is clearly
available, as is shown by the DSEIR itself, which projected
future traffic levels on US 101 in the "Transportation" section
of the DSEIR. For example, the DSEIR predicts that the segment
of US 101 southbound between Sierra Point and Oyster Point will
have a volume of 11,180 cars per hour in the year 2010 during the
PM peak hour. (DSEIR, p. 130.) Such estimates should have been
C1061.00s
20
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used to predict noise levels. There is no basis for the DSEIR's
conclusion that future noise levels are unpredictable.
The project proponent should submit a current noise analysis
conducted by a qualified acoustical engineer prior to approval of
the project, as required by the Noise Element. The analysis
should be submitted and considered as part of the DSEIR process,
so that adequate mitigation measures may be considered. If there
are no adequate mitigation measures, the city should consider
redesigning the portion of the project which is located within
the 65 dB CNEL contour.
Further, the DSEIR should contain an analysis of airport
noise, so that the city can consider whether there are adequate
measures to mitigate airport noise, or whether the project should
be redesigned. Instead, the DSEIR simply recommends a future
study. (DSEIR, p. 228.)
x. AIR QUALITY
A. Standards of Siqnificance
The DSEIR discusses the project's consistency with the 1991
Clean Air Plan adopted by the Bay Area Air Quality Management
District (DSEIR, p. 254). However, the BAAQMD adopted a "Bay
Area '94 Clean Air Plan" on December 21, 1994. The DSEIR should
discuss the project's consistency with the 1994 Clean Air Plan.
c.oNT:
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The DSEIR notes that after the original approval of the
Terrabay project, the BAAQMD established standards of
significance for criteria pollutants. (DSEIR, p. 237.) However,
those standards of significance were adopted in 1985, prior to
passage of the California Clean Air Act. (Health & Safety Code 9
40910, et seq.)
The BAAQMD is now proposing to reduce those standards of ~.~
significance in order to try to meet the goal of the California
Clean Air Act of a 5% per year reduction in emissions of
nonattainment pollutants. (Health & Safety Code 9 40913.)
Instead of a standard of 150 pounds per day for ROG, NOxand PM1o,
the BAAQMD is currently proposing a reduction to 80 pounds per
day of those pollutants. (BAAQMD CEQA Guidelines: Assessing the
Air Quality Impacts of Projects and Plans, DRAFT, December, 1995,
p. 16.) The DSEIR should consider whether, even with the
proposed mitigation measures, the project's emissions of NOx
would exceed this standard of significance.
C1061.00s
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B. Construction Impacts
The proposed BAAQMD CEQA Guidelines list various measures
control construction emissions. The DSEIR should consider
whether those measures should be imposed to mitigate such
emissions. (Id., Table 2.)
to
~~~1
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C.
Cumulative Impacts
The DSEIR does not appear to consider cumulative impacts on
air quality. The DSEIR should ,consider whether the project will
cause or contribute to a violation of state or federal air ;~ ~z.
quality standards. The San Francisco Bay Area is not in
attainment with the state standards for PM10 or for ozone.
Further, the Bay Area's Clean Air Plan does not meet the state
standard of a 5% annual reduction in emissions of nonattainment
pollutants. In these circumstances, it is particularly important
to evaluate the project's cumulative impacts on air quality.
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D.
Transportation Systems Manaqement
The DSEIR should consider additional TSM measures to reduce
the project's impacts on air quality. For example, the project
could include additional bike routes, pedestrian routes to bus
stops, and coordination of signals along arterials to improve
traffic flow. The developer could provide initial funds to
establish a ridesharing program (to be supported by homeowners
thereafter), provide some clean fuel school buses, and establish
shuttles to Cal Train and shopping centers.
The circulation Element of the City'S General Plan states ~~
that the Cal Train rail station "should be improved and expanded ·
into a community transportation center with provisions for bus,
rail, bicycle, jitney, and other mass transit modes." (Circ.
Element, p. 4-8.) The Circulation Element also notes that "[a]
significant portion of South San Francisco residents work in San
Francisco or south San Mateo County." (Id.)
Requiring the project sponsor to participate in funding to
improve and expand the Cal Train station would help mitigate
impacts on air quality, as well as impacts on transportation
systems.
The 1994 BAAQMD Clean Air Plan also lists possible TSM
measures. (Citation are to pages in the CAP.) All of the
following measures should be considered for the Terrabay project:
1.
2.
Contribute to local bus
Connect with Cal Train;
Cal Train (p. 28)
Improve bicycle and bus
service (p. 27)
shuttle from commercial to
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access to CalTrain (p. 28)
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3.
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4. Provide high occupancy vehicle (i.e., carpool)
lanes for freeways; provide bicycle lanes on
bridges (e.g., the Oyster Point overcrossing) (p.
29)
5. Provide clean fuel school buses (p. 29)
6. Provide car pool information at schools (p. 29) 33.~3
7. contribute to local signal timing programs; signal
preemption op arterials for buses; improve
arterials for buses (p. 30)
8. Sell transit passes at recreation center; fund
transit passes; arrange ridesharing at the
recreation center; provide vans for vanpooling
(p. 31)
9. Convert buses to clean fuels (p. 29).
--
XI. CULTURAL RESOURCES
A. Introduction
There have been several archaeological resources identified
on the Terrabay project site. The DSEIR must comply with CEQA's
requirements for archaeological resources, as well as other state
and federal laws that apply to such resources. In sum, it
appears that: (1) there has been no consultation with the State
Native American Heritage Commission, as required by state law;
(2) the DSEIR may not meet CEQA's requirements for identifying
and mitigating impacts to important archaeological resources; and
(3) federal permits issued for the project may trigger review
under the National Historic Preservation Act.
B. Factual Backqround
There are at least three identified archaeological deposits
on the Terrabay project site. Resource CA-SMa-40 ("#40") is a
large shell mound with significant archaeological value located
in the direct zone of development. (1982 EIR, p. 154.) Resource
CA-SMa-92 ("#92") is small shell midden also located in the
development area. (Ibid.) There have been oral reports of human
remains in #92. (Ibid.) Resource CA-SMa-234 ("i234") is a
smaller midden deposit "just outside" the zone of development.
(Ibid.) In addition, the staff at State Historical Resources
System has indicated that the entire site has a high potential
for previously undiscovered Native American sites. (DSEIR, p.
244. )
C. Discussion
1. Failure to Consult with the State Native American
Heritaqe commission
Public Resources Code section 5097.95 requires local
agencies to cooperate with the state Native American Heritage
C1061.00S
23
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Commission ("NAHC") to fulfill the NAHC's duties under Public
Resources Code section 5097.94. This cooperation includes, bu~
is not limited to, providing the NAHC with relevant sections of
EIRs where the EIRs relate to property identified by the NAHC to
be of special religious significance to Native Americans, or for
which it is reasonably foreseeable to be of such significance.2o
The Public Resources Code requires local agencies to help
the NARC fulfill its statutory duties, "including, but not
limited to" consulting with the NAHC on EIRs for properties with
special religious significance. The NARC!s duties include the
identification of places of special religious and social
significance to, and graves and cemeteries of, Native Americans.
(g 5097.94(a).)
The DSEIR does not indicate whether the NARC has identified '2.~'24
any of the resources on the site as places of special religious ?7.7~
or social significance to, or with known graves and cemeteries
of, Native Americans. (Pub. Res. Code 9 5097.94(a).)
Nevertheless, based on the information disclosed in the 1982 EIR I
and DSEIR, the existence of such resources is certainly
reasonably foreseeable. For example, the large shell mound (#40)
has been identified as potentially eligible for listing on the
National Register of Historic Places. (See National Historic
Preservation Act, 16 U.S.C. 9 470a.) (DSEIR, p. 244; 1982 EIR,
p. 154.) The staff at the State Historical Resources System has
indicated that the entire site has a high potential for
previously undiscovered Native American sites. (DSEIR, p. 244.)
There is no mention in the DSEIR that the NAHC was consulted
during the preparation of the EIR. (See DSEIR, p. 275.) Rather,
the documents state that the NARC is to be consulted only if
cultural resources are found or disturbed during construction.
(DSEIR, p. 246.) The relevant sections of the DSEIR should be
provided to the NAHC and its comments considered by the City
prior to project approval. ____
2.
Inadeauate CEOA Mitigation
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a.
CEOA section 21083.2 Reauirements
~~,S"
section 21083.2 of CEQA establishes standards for
determining whether a project may have a significant impact on
unique archaeological resources and prescribes methods for
,-I
20 See Environmental Protection Information Center v. GONT:
Johnson (1985) 170 Cal.App.3d 604, 216 Cal.Rptr. 502 (setting
aside approval of timber harvest plan because Department of
Forestry failed to consult with the NARC and provided inadequate
response to the NARC's comments regarding damage to culturally
significant site).
C1061.00s
24
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mitigating such impacts. (Pub. Res. Code 9 21083.2.) There is a
strong preference for leaving unique archaeological resources in
place or undisturbed, and the lead agency can require that
reasonable efforts be made toward this end. (g 21083.2(b).}
If avoidance is not feasible, the project applicant must
guarantee to pay 50% of the estimated mitigation costs up to a
certain percentage of the project cost. (~21083.2(c)-(e}.) If
the applicant does not agree to pay 100% of the costs of
mitigation identified in the EIR, the lead agency must provide a
60-day period after completion of the EIR and before project
approval for interested persons to provide voluntary funding
guarantees for the unfunded portion of the mitigation. (~
21083.2(C}.)
The lead agency also may make prov~s~ons for archaeological
sites accidentally discovered during construction. (g
21083.2(i).) These provisions may include immediate evaluation
of the resource, contingency funding, and construction delays to
sample the resource or develop avoidance measures. (Ibid.) (See
also, Appendix K of the CEQA guidelines.)
-
b.
Terrabay EIR Compliance
---r
According to the 1982 EIR, resource #234 is "just outside of
the proposed development activity," and resources #40 and #92
"are in the direct location of the development." (1982 EIR, p.
154.) Thus, avoidance or mitigation is required for resources
#40 and #92 if they are unique or important.
(1) Cappinq of #40
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Resource #40, the large shell mound, is to be capped with a
plastic matting and one foot of soil. "capping" qualifies as
avoidance of the resource if certain requirements are met (e.g.,
no serious soil compaction, chemically inactive covering
materialS). (g 21083.2(b) (3); Appendix K, 9 II.B.3.} The 1982
EIR noted that the capping activities would "unavoidably create
some direct impact" to the resource due to scarification and
movement of heavy equipment. (1982 EIR, p. 155.) Thus, it is
questionable whether the capping of #40 constitutes avoidance of
the resource. If not, the mitigation requirements of section
21083.2 and Appendix K must be followed.
~ ~?1. 3Cj'
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(2) Deferred Mitiqation for #92
According to the 1982 EIR, resource #92, the small shell
midden, "appears to be very rich and is assumed to be relatively
intact." (1982 EIR, p. 154.) There also are oral reports that
#92 contains possible human remains. (Ibid.) This resource "is
in the direct location of the development." (Ibid.) The only
mitigation measure specified for this resource is a determination
-~:~.... - ..~:.
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of its subsurface boundaries and significance before Phase III
grading commences. (DSEIR, p. 247.) Additional mitigation
measures "may be recommended" at that point. (Ibid.)
It is unclear why the boundaries and significance of this
potentially important site have not yet been identified in light
of the substantial delay that this project has experienced.
These activities should occur prior to project approval so that
adequate mitigation measures can be identified. ____
--
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(3) Insufficient Information and Mitigation
for *234
The DSEIR does not discuss whether resource #234, the
smaller midden deposit, is still "just outside" the zone of
development. (1982 EIR, p. 154.) The DSEIR should note whether ~.~7
the extensive grading and landslide repair work necessary to
stabilize the area has the potential to impact this resource. If
so, adequate mitigation measures should be incorporated in the
DSEIR. -----
----.
(4) Inadequate Mitigation for Unidentified
Resources
In addition to the specific resources identified, the staff
at the state Historical Resources System has indicated that the
entire site has a high potential for previously undiscovered
Native American sites. (DSEIR, p. 244.) The only mitigation
measure for this'potential significant impact is to stop work and
conduct an archaeological evaluation if cultural resources are ~~~
encountered during construction. (DSEIR, p. 246.) This is the 77.
mitigation measure CEQA specifies for archaeological resources
lIaccidentally discovered" during construction. (g 21083.2(i);
Appendix K, ~ IX.} It is difficult to understand how such
resources could be accidentally discovered when the project is
undertaken with the knowledge that the site has a high potential
for their discovery. The site should be evaluated for
archaeological resources prior to project approval and, if
necessary, appropriate mitigation measures identified.
(5)
potential Noncompliance with Funding
Guarantee Requirement
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---
The DSEIR does not require the developer to guarantee to
fund half of the required mitigation. The IIcapping" of resource
#40 may qualify as avoidance, not mitigation, if there is no
damage to the resource. However, m~t~gat~on may be required for ~..~
the other resources. Because the m~t~gat~on measures for these
other resources are so indefinite, it is difficult to estimate
the developer'S funding requirement or provide information to
interested persons to make voluntary funding guarantees. The
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mitigation measures for these other resources should be set forth
in detail so these funding guarantees can be obtained.
-l ;~:~
Potential Applicability of National Historic
Preservation Act
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3.
The National Historic Preservation Act ("NHPA"), 16 U.S.C. ~
470 et seq., provides for the listing of historical properties on
the National Register of Historic Places. The NHPA also requires
a federal agency to do the following before undertaking or
, assisting any action that may affect properties listed or
eligible for listing in the National Register: (1) consider the
effect of the project on such properties; and (2) provide the
Advisory Council on Historic Preservation a reasonable
opportunity to comment on the activity. (16 U.S.C. 9 470f.}21
Any Indian tribes that attach religious or cultural significance
to the affected properties must be consulted during this process.
(16 U.S.C. 9 470a(d) (6) (A) .}22
a.
Property "eligible for inclusion" in National
Reqister 'S",.1" .
Property "eligible for inclusion" in the National Register
is not limited to properties that have been officially determined
to be eligible, but includes properties that may qualify for
inclusion under the regulatory criteria. (Boyd v. Roland (5th
Cir. 1986) 789 F.2d 347, 349; Colorado River Indian Tribes v.
Marsh (C.D. Cal. 1985) 605 F.Supp. 1425, 1437; 36 C.F.R. 9
800.2(e), 800.3(f).) The determining factor is the inherent
historical and cultural significance of the property. (Ibid.)
Properties of traditional religious and cultural significance to
Native Americans may be determined to be eligible for inclusion
on the National Register. (16 U.S.C. 9 470a(d) (6) (A).)
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21 Although the state Historic Preservation Office is
primarily responsible for implementing the NHPA, (16 U.S.C. 9
470a(b)), both the state Office and the National Advisory Council
have extensive authority to comment on and delay permit
applications. (Kostka & Zischke, 2 Practice Under the California
Environmental Quality Act 9 20.111.)
22 The Secretary of Interior also has a general duty to
foster cooperation between Indian tribes and State Historic
Preservation Officers to ensure that interests in preserving
Native American historical properties are given due
consideration. (16 U.S.C. 9 470a(d) (l) (A}.)
C1061.00s
27
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b. What Constitutes a Federal "Undertakinq"
The Advisory Council has issued regulations broadly def.i.n.....':i
federal "undertakings" as follows:
Any project, activity, or program that can result in
changes in the character or use of historic properties,
if any such historic properties are located in the area
of potential effects. The project, activity, or
program must be under the direct or indirect
jurisdiction of a Federal agency or licensed or
assisted by a Federal agency. Undertakings include new
and continuing projects, activities, or programs and
any of their elements not previously considered under
section 106. (36 C.F.R. 9800.2(o).}
Federal courts have upheld this broad definition, finding
NHPA's consultation requirement applicable to projects subject to
ongoing federal licenses at any stage of the undertaking where
the agency has the ability to require changes that could mitigate
the project's impact on historic preservation goals. (E.g., ~.~
Vieux Carre Property OWners, Residents & Assoc., Inc. v. Brown
(5th Cir. 1991) 948 F.2d 1436, 1445.)
Here, the city and the developer are operating under an
ongoing federal permit under the federal Endangered Species Act.
Further, as discussed below, it does not appear that the
conditions of the permit are being fulfilled and therefore, the
U.S. Fish & wildlife Service would currently have the authority
to take action to enforce the permit conditions.
Additionally, other permits for new or continuing projects
directly issued by a federal agency would constitute an
undertaking subject to NHPA requirements. For example, a
nationwide permit issued by the Army Corps of Engineers for
dredging and filling of wetlands on the project site,23 or a
revision of the section 10(a) Endangered Species Act ("ESA")
permit by the U.S. Fish & Wildlife Service would constitute an
"undertaking." In addition, a permit issued by a state agency
with delegated authority to implement a federal law may qualify
as an undertaking. For example, a permit issued by the San
Francisco Bay Regional Water Quality Control Board under the
Clean Water Act (e.g., NPDES permit for stormwater discharges).
(See, e.g., Indiana Coal Council, Inc. v. Lujan (D. D.C. 1991) 774
F.Supp. 1385, 1400-03.)
V
e4Nr.
23 vieux Carre Property OWners, Residents & Assoc., Inc. v.
Brown (5th Cir. 1989) 875 F.2d 453, 465 (issuance of nationwide
permit may trigger NHPA review).
C1061.005
28
U7NT.
c. Applicability to Terrabay
Resource #40, the large shell mound, has been identified as
potentially eligible for listing on the National Register of
Historic Places. (DSEIR, p. 244; 1982 EIR, p. 154.) This
resource is "in the direct location of the development." (1982
EIR, p. 154.) Neither the 1982 EIR or the DSEIR discuss whether
resource #92, the small shell midden, or resource #234, the
smaller midden deposit, are eligible for listing on the National
Register. According to the 1982 EIR, #92 "appears to be yery
rich and is assumed to be relatively intact" and "is in the
direct location of the development." (1982 EIR, p. 154.) There .~~.~~
also have been oral reports that #92 contains possible human 7~~'
remains. (Ibid.) Additionally, the staff at the state ,
Historical Resources System has indicated that the entire site
has a high potential for previously undiscovered Native American
sites. (DSEIR, p. 244.)
Assuming that at least one of the above resources is
eligible for listing on the National Register (most probably
#40), the project almost certainly would qualify as an
"undertaking" triggering NHPA review and consultation if a
federal permit is issued in connection with the project, and may
trigger review if a state agency issues a permit pursuant to
federal authority. The DSEIR should discuss the necessity for
additional federal permits or an amendment to the ESA g10(a)
permit (e.g., for landslide repair). If NHPA review and
consultation is required, it should be identified in the DSEIR as
a required government approval.
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XII. ALTERNATIVES
The DSEIR does not discuss the "No Project" alternative of
disapproYing the requested extensions, but proceeding with a new
specific plan and either with or without a new development
agreement.
n.1-1
The DSEIR should discuss the environmental impacts of
proceeding with a new specific plan and proceeding either with a
new development agreement or without a development agreement at
all. _-
-
If the term of the Development Agreement is extended, then
the City cannot impose any requirements that were adopted after
the 1983 Development Agreement was approved. The DSEIR should
discuss the environmental impacts of agreeing in advance not to
impose any requirements that were adopted after the Development
Agreement was originally approved.
~~
'!fI
If the term of the Development Agreement is not extended,
then the city will be free to impose current up-to-date
requirements on the project. The DSEIR should discuss whether
C1061.00S
29
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there are any current requirements which could be imposed if the
term of the 1983 Development Agreement is not extended.
Additionally, if the project proceeds without a development
agreement, then the city will be free to impose new requirements
on the project in the future, so long as the developer has not
obtained vested rights. ~.~I
The DSEIR should discuss the environmental impacts of
proceeding with and without a development agreement.
XIII.
PROJECT CONSISTENCY WITH ADOPTED PLANS AND POLICIES
The DSEIR addresses the project's consistency with adopted
plans and policies. However, the discussion is incomplete.
-
A.
1994 Bay Area Clean Air Plan
As noted above, the DSEIR discusses the project's
consistency with the 1991 Clean Air Plan adopted by the Bay Area ~.~~
Air Quality Management District (DSEIR, p. 254), instead of the
more recently adopted 1994 Clean Air Plan. The DSEIR should
discuss the project's consistency with the 1994 CAP.
B.
Noise Element of South San Francisco General Plan
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The city adopted a Noise Element for its General Plan in
1990 which replaced the prior noise element. The DSEIR does not
mention the 1990 noise element in the discussion of consistency
with adopted plans. (DSEIR, p. 253.) It should discuss the
project's consistency with the 1990 noise element, particularly
because the project does not appear to be consistent with the
noise element, as discussed above.
-;~.+3
-
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C. Habitat Conservation Plan
The City of South San Francisco has received a permit under
section 10(a} of the federal Endangered Species Act. That permit
allows the city to authorize construction on designated areas of ~~
San Bruno Mountain, so long as the construction is in compliance .
with the provisions of the Agreement with Respect to the San
Bruno Mountain Area Habitat Conservation Plan ("HCP Agreement").
The permit states: "All aspects of the 'Agreement with Respect
to the San Bruno Mountain Area Habitat Conservation Plan' must be
complied with and completely implemented." (Permit, 1 11.D.2.)
The HCP Agreement contains several requirements which should
have been complied with prior to recordation of the final
u;>NT:
C1061.00s
30
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subdivision map for Phase I, as well as requirements which must
be complied with prior to issuance of building permits.24
The HCP Agreement provides that the city of South San
Francisco "shall take no ... discretionary action without first
finding that the action complies with this Agreement ..." (HCP
Agreement, p. 21.) Thus, in order to approve extension of the
Specific Plan or Development Agreement, the city must find that ~~
the project is in compliance with the HCP Agreement. ."
If the project is not in compliance, then the city cannot
approve the extension of the Specific Plan or Development
Agreement because it cannot make the required compliance finding.
Nor can the City issue building permits until the project is in
compliance with the HCP Agreement and section 10(a} permit. 25
1.
Dedication of Open Space to County
-
The HCP Agreement provides that designated open space
adjacent to the Terrabay project on San Bruno Mountain shall be
dedicated as conserved habitat to the county. The HCP Agreement ~.~~
provides that the offer of dedication shall occur with
recordation of the final subdivision tract map.26 The HCP
provides that the offer of dedication shall take place with the
first grading permit is received.27
24 The HCP Agreement provides that "Each local government
may issue grading permits and building permits upon satisfaction
of the applicable conditions of the Agreement and of the Section
10(a) Permit, and other local requirements unrelated to wildlife
conservation." (HCP Agreement, p. 17.)
The Development Agreement also acknowledges that building
permits may be issued only after "[a]ll applicable provisions of
the Habitat Conservation Plan for that phase, including the
dedication of open space to San Mateo County, have been complied
with to the sati~faction of the Planning Director." (Dev. Agt.,
Exh. E . )
25 Violation of the permit also carries penalties set forth
in federal law. (15 U.S.C. S 1540(a) (1) and (b) (1}.)
26 The HCP Agreement provides that "The offer of dedication
of Conserved Habitat may be phased at the option of the Landowner
but shall occur prior to or concurrently with the recordation of
the final subdivision tract map for the area to be dedicated."
(HCP Agreement, p. 16; emphasis added.)
27 The 1982 Habitat Conservation Plan provides that the
open space shall be offered for dedication to the county "at the
time of receipt of the first grading permit with respect to the
C1061.00s
31
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The Terrabay project has received its first grading permit.
In addition, the final subdivision tract map for Phase I has be
recorded.28 Therefore, the offer of dedication of the open
space should already have occurred.
The DSEIR does not state whether the offer of dedication has
been made. However, the DSEIR refers to dedication of open space
to the County in the future. (DSEIR, p. 51 ("...the remaining 2~~
132 acres ... are to be permanently dedicated to the County of .~
San Mateo for inclusion in the San Bruno Mountain State and
County Park.").} 29
If the offer of dedication has not been made, the DSEIR
should explain this failure of the project to comply with the
HCP, the federal Endangered species Act section 10(a) permit and
the HCP Agreement. The extension of the Specific Plan approval
and Development Agreement cannot be approved until after the
offer of dedication has been made. Nor can building permits be
issued.
2.
Recordinq of CC&Rs for Habitat Fundinq
-
The HCP Agreement provides that each Landowner must record a
covenant providing for funding of habitat activities and that the
covenant must be in the form attached as Exhibit G to the HCP
~.~
v
C()Aff.
parcel to which it pertains
"
(HCP, p. VII - 166.)
The 1982 EIR also refers to offering dedication when grading
permits are granted. It provides that: "The San Bruno Mountain
Habitat Conservation Plan (HCP) stipulates dedication of the
project's undeveloped open space area to the County at the time
the first grading permits are granted for the parcel of the
project to which it pertains. The undeveloped open space would
be, therefore, dedicated to the County in conjunction with the
two grading phases: upon completion of the residential portion
and upon completion of the commercial portion." (1982 EIR, p. 3-
4. )
28 The DSEIR states that a final subdivision map was
approved for Phase I in 1990 (DSEIR, p. 61), but does not state
when the map was recorded. However, the City planning department
has advised use that the map was recorded in 1990.
29 An offer with an inaccurate property description may
have been made, and rejected by the County. The HCP requires an
offer of Conserved Habitat. An offer of the wrong property would
not comply.
C1061.00S
32
Agreement. The covenant must be recorded with recordation of thp.
final subdivision tract map.30
The final subdivision map has been recorded for Phase I of
the Terrabay project. However, the DSEIR does not state whether
the required funding covenant has been recorded as to Phase I.
That information should be provided. If the covenant has not
been recorded, then the extension of the specific Plan and
Development Agreement cannot be approved. Nor can building
permits be issued.
~;.t,
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3. Covenants For Fire Buffers and Restricting
Pesticide Use
The landowner must record covenants (1) providing for a 30
foot buffer zone between the development and the habitat to
protect the development from fire, and (2) prohibiting the use of '2? 6:7
pesticides in the habitat area. This must be done when the final ~., I
subdivision map is recorded. (HCP Agreement, p. 16.)
The DSEIR does not state whether such covenants were
recorded when the final subdivision map for Phase I was recorded.
Unless such covenants have been recorded, the City and the
developer are not in compliance with the Section 10(a) permit.
The specific Plan and Development Agreement cannot be extended
and building permits cannot be issued.
-
---
4. Location of Proposed Landslide Repairs
The DSEIR does not state whether the proposed landslide
repairs will require an amendment to the Habitat Conservation ~~~
Plan Agreement and Section 10(a} permit. If the proposed 77.'~
landslide repairs require intrusion into the habitat to a greater
extent than currently allowed under the Section 10(a) permit,
then an amendment to the permit would be required. The DSEIR
should show the location and extent of the proposed landslide
repairs, and state whether a permit amendment is required.
5.
Fundinq of Habitat Maintenance
-
-
The Habitat Conservation Plan and HCP Agreement provide that
specified Landowners are to contribute to an interim habitat
fund. The Landowner of the South Slope is to pay $781.67 per
month. (HCP Agreement, p. 24.) The DSEIR does not state whether ~~
the required monthly payment has been made. .
30 "Such covenant shall be recorded ... prior to the
dedication of Conserved Habitat (or portion thereof), and
concurrently with (i) the recordation of the final subdivision
tract map ... creating lots or units for sale to the public
(HCP Agreement, p. 23.)
II
Cl061.00S
33
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c.oNr.
Additionally, permanent habitat funding was to come from
homeowner assessments based upon the number of approved dwelL;
units. The assessment was to be $20.00 per unit, based upon 74~
units, for a total annual assessment of $1,490.00 in 1983
dollars. (HCP Agreement, Exhibit G.) If the approvals are
extended, the assessment should be recalculated to reflect the
actual number of units approved (745 units in the Specific Plan
or 721 units in the Precise Plan).
If the failure of the habitat restoration efforts is related
to any failure to pay the habitat assessments, then the developer
should be required to fully fund the remedial habitat restoration
activities.
6. Compliance Determination
The DSEIR states that the County of San Mateo will make the
HCP compliance determinations for phases 2 and 3 of the Terrabay
project (p. 62.) However, the HCP Agreement requires the City of
South San Francisco to make HCP compliance findings prior to each
discretionary approval. (HCP Agreement, p. 21.) Therefore, the
City should make these compliance findings prior to approving the
project.
7. Application to New Owner
A new landowner is entitled to proceed under the federal
Endangered Species Act Section 10(a} permit only if he, she or it
has signed the Agreement with Respect to the San Bruno Mountain
Area Habitat Conservation Plan. (HCP Agreement, p. 17.) The
DSEIR should state whether the new landowner has done so, or
whether the new landowner will obtain its own separate Section
10(a) permit.
D.
Precise Plan
According to the DSEIR, the Precise Plan for the project was
approved in 1989. The South San Francisco Municipal Code
(Terrabay Specific Plan District) provides that a precise plan
expires after two years unless a building permit has been
obtained. (~20.63.240.) Therefore, it appears that the 1989
Precise Plan has expired.
The City's Municipal Code provides that no building permits
may be issued unless a precise plan has been approved by the City
Council (g 20.63.160). However, approval of a precise plan is
not on the DSEIR's list of future approvals which must be
obtained. (DSEIR, p. 61.) The DSEIR should explain the status
of the 1989 Precise Plan.
C1 061. 005
34
&DNr.
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--"
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~3.C;Z.
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~ONT.
The DSEIR should include the Precise Plan in the project
description and should discuss the environmental impacts of
adopting a new precise plan.
com:
I
~.sz.
Building permits cannot be issued until there is an approved
precise plan.
E.
Gradinq Permit
-
-
The DSEIR does not state whether the grading permit has
expired. The status of the grading permit should be explained.
~.~~
F.
Development Aqreement
-
-
1. Applicable Law
The DSEIR states that the project is an extension of the
Development Agreement for the Terrabay project, as well as an
extension of the Specific Plan. (DSEIR, p. 1.) However, the
DSEIR does not state whether the extension would preserve current
paragraph 17 of the Development Agreement. That paragraph
provides that the City rules, regulations and official policies
which were in effect at the time that the Agreement took effect
shall govern the project.
If the Development Agreement is to be extended, then the ~
City rules, regulations and official policies which govern the ~.~
project should be those in effect at the time the extension is
approved. For example, the City enacted a TSM ordinance after
the original Development Agreement was approved. (DSEIR, p.
134.) The DSEIR assumes that the TSM ordinance is applicable to
the project. (DSEIR, p. 134.) Similarly, the City subsequently
adopted a Storm Water Management and Discharge Control Program
(DSEIR, p. 178). The DSEIR states that all construction projects
are required to comply with this program (id.), and proposes
compliance as a mitigation measure (DSEIR, p. 181-182).
Unless the Development Agreement is amended to provide for
application of current law, however, these ordinances would not
necessarily apply. If the ordinances do not apply, then the
DSEIR must discuss the environmental impacts of the project in
the absence of compliance with these ordinances.
2. Compliance with Development Aqreement
-
-
The applicant is asking the City to extend the term of the
Development Agreement, which is dated April 14, 1988. However,
the DSEIR does not state whether the terms of the Development ~~S;
Agreement have been complied with. .
The Development Agreement provides that, prior to
recordation of a final subdivision map, financial guarantees
C1 061. 005
35
v
UNT.
related to the installation of subdivision improvements shall be
executed (p. 1). The Development Agreement also states that,
prior to the recordation of the initial final subdivision map for
the first phase, agreements shall be executed to satisfy the
requirements that the project sponsor participate in the cost of
the proposed Oyster Point Overcrossing, and the project sponsor
shall immediately initiate action to expedite construction of the
proposed Hook Ramp improvements and shall participate in the cost
of the proposed Hook Ramp improvements. The nature and total
participation was to be determined prior to approval of the
tentative subdivision map or precise plan. (Dev. Agt., p. 2;
Exh. E-l.)
The DSEIR does not state whether these provisions were
complied with prior to approval of the tentative subdivision map,
approval of the Precise Plan and recordation of the final
subdivision map.
The project has not proceeded as originally proposed. The
Oyster Point interchange has been partially constructed, but the
"hook" ramps called for in the Development Agreement have not
been constructed, nor has there been any improvement to the
scissors off-ramp at US 101 southbound and Bayshore Boulevard.
The Development Agreement envisioned completion of the
"hook" ramps either as part of the Oyster Point interchange or
prior to construction of the Oyster Point interchange. (Dev.
Agt., Exh. E-2, p. 2.) That has not occurred. Because the
Oyster Point interchange has been partially completed and no work
has been commenced on the "hook" ramps, the traffic impacts are
not the same as those considered in the 1982 EIR.
Several questions remain unanswered. Has the city
determined the nature and extent of total participation in the
cost of the "hook" ramp improvements, as required by the
Development Agreement? (Dev. Agt., Exhibit E-1.) Did the
project sponsor, immediately upon Specific Plan approval,
initiate action to expedite construction of the "hook" ramp
improvements? (Id.) Did the project sponsor prepare plans and
obtain approvals from CalTrans? (Id.) If not, are "hook" ramps
still feasible as a mitigation measure?
The DSEIR should provide an evaluation of the status of
compliance with the Development Agreement so the environmental
impacts of compliance or failure to comply can be evaluated, and
the feasibility of the proposed mitigation measures can be
analyzed.
C1061.00s
36
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G. Specific Plan and Municipal Code
The DSEIR does not state whether the requirements of the
Specific Plan and the Municipal Code (Terrabay Specific Plan
District) have been complied with.
--
1. Geotechnical Requirements
The section of the South San Francisco Municipal Code which
applies to Terrabay provides that geotechnical studies must be
prepared and their recommendations implemented before building
permits may be issued. (g 20.63.040.31) The Specific Plan
contains a similar requirement. (Specific Plan Amendment #
8.32) The Specific Plan also provides that, "The city shall
retain complete authority to determine the final build out
schedule of the project to insure that environmental... problems
do not occur in the future." (Specific Plan, Amendment * 4.)
Several geotechnical issues have come to light as a result
of the grading and the passage of time, and the EIR recommends
repairs which have not yet been implemented. Further, at least
31 "No buildinq permits shall be issued by the city for any
phase of construction within the Terrabay specific plan district
until the project sponsor obtains detailed soil and geotechnical
studies for each phase of construction and implements the
recommendations contained in said studies for each phase of
proposed construction. The project sponsor shall provide the
city engineer with satisfactory evidence that all grading and
drainage work was accomplished in accordance with the approved
soils and geotechnical studies." (g 20.63.040(a); emphasis
added. )
~.'~7
"Prior to approval of any precise plan or the issuance of
any building permit within the Terrabay specific plan district,
the project sponsor shall provide the city engineer with
satisfactory evidence that all elements of the project are
designed in accordance with the recommendations of the approved
soils and geotechnical studies relating to ground slippage and
landslides, erosion, and storm drainage." (g 20.63.040(b).)
32 "Detailed soil and geotechnical studies shall be
prepared and their recommendations implemented before buildinq
permits will be issued for each phase of the Specific Plan area.
The project sponsor shall pay the cost of such supplemental soil
and geology studies. The project sponsor shall provide the City
Engineer with satisfactory evidence that all elements of the
project are designed and engineered to preclude potential
problems relating to ground slippage and landslides, erosion, and
storm drainage within the City limits." (specific Plan,
Amendment # 8; emphasis added.)
C1061.00S
37
y
"'NT:
ePNr.
one proposed landslide repair is based on a study which differs
from the studies prepared in 1983, and results in implementatioL
of less protective measures. 33
Failure to implement the geotechnical recommendations prior
to issuance of building permits appears to violate the Specific
Plan, as well as the City's Municipal Code. The DSEIR should
discuss whether the project is in compliance with this
requirement of the Specific Plan. If it is not, the DSEIR should
discuss the environmental impacts of failure to comply,
especially the adverse effects on human beings (14 C.C.R. 9
15065 (d) ) .
~.t;7
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-,
Further, the DSEIR does not clearly state whether siltation
and catchment basins must be installed on the upper slopes of San
Bruno Mountain in order to minimize erosion and protect the
developed property from flooding and earth slides. If they are
required, then "no permits of any kind shall be issued for the
project until the project sponsor obtains the necessary approval
and agreement for the installation of said required
improvements." (Specific Plan Amendment # 9.) The DSEIR should
state whether such siltation and catchment basins are required,
and whether the consent of the County and, if necessary, an
amendment to the Section 10(a} permit, has been obtained.
~.S'9
-oJ
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Additionally, the Specific Plan, as set forth in the South
San Francisco Municipal Code (Terrabay Specific Plan District),
requires that winterization programs be put into effect for all
graded areas prior to October 15th of each year. (~20.63.040.) ~.~~
The DSEIR does not state whether winterization program were in
effect for each year after the project was graded. If not, the
DSEIR should discuss the environmental impacts of that failure to
comply with the specific Plan requirements.
2.
Drainaqe Requirements
--..
-
Further, both the Specific Plan and the Municipal Code
require a storm drain system designed to handle runoff of an
intensity equal to the worst storm of record or one-hundred year
return period, whichever is worse (Municipal Code ~ 20.63.080;
Specific Plan, p. ~7, and Specific Plan Amendment # 44).
The Municipal Code requires that before any building permits ~,~
are issued, the project sponsor "shall provide the city engineer
with satisfactory evidence that all elements of the project are
designed in accordance with the recommendations of the approved
33 See attached letter from William Lettis & Associates,
Inc., which comments that the more recent GeoResources study
estimates the depth of Landslide D at only 20 feet, while earlier
studies prepared for W.W. Dean estimated a deeper landslide.
C1061.00s
38
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G6Nr.
soils and geotechnical studies relating to ground slippage and
landslides, erosion, and storm drainage." (920.63.040(b);
emphasis added.}
The Specific Plan provides that, "The project sponsor shall
provide the city Engineer with satisfactory evidence that all
elements of the project are designed and engineered to preclude
potential problems relatinq to ground slippage and landslides,
erosion, and storm drainage with the City limits." (Specific
Plan Amendment # 8.) ~.60
The DSEIR states that the drainage system has been
installed, but is not operating adequately, and that San Mateo
County has requested that studies be performed to show that the
system was properly designed and installed. (DSEIR, p. 177~)
Failure of the system to operate properly appears to violate
the provisions of the Specific Plan and of the Municipal Code.
The DSEIR should discuss the environmental impacts of the failure
to comply with these requirements. until the system operates in
accordance with these requirements, the specific Plan should not
be extended. Nor can building permits be issued.
3.
Construction Phasinq
=
The Specific Plan required City Council approval of the
precise grading and construction phasing for the Terrabay project
prior to issuance of grading or building permits. (Specific Plan
Amendment # 4.) The DSEIR should state whether such approval was
obtained, and, if so, should set forth the specific grading and
construction phasing which has been approved. The DSEIR should
state whether that phasing has been complied with and, if not, .~ ~(
should discuss the environmental impacts of failure to comply. .
The Specific Plan also required that the construction
phasing schedule include a list of needed traffic improvements
and the required timing for installation of those improvements.
(Ibid.) The DSEIR should set forth that schedule and state
whether it has been complied with, and, if not, the environmental
impacts of failure to comply.
If the City Council has not approved the precise grading and
construction phasing for the project, the building permits and
grading permits cannot be issued.
-
4. Transportation Systems Manaqement Plan
--,
also ~~.~2-
The Specific Plan, as set forth in the Municipal Code,
requires that a Transportation Systems Management Plan be
approved prior to approval of a precise plan or tentative
subdivision map. (Municipal Code 9 20.63.060.) The DSEIR
should
C1061.00s
39
"/
"'AlT.
state whether such a plan has been approved. If not, the
environmental impacts of failure to comply should be discuss
G/JNT.
,
l ~." 2
5. Hook Ramps From Southbound 101 ~
Additionally, the Specific Plan requires that the "projec:-l
sponsor shall immediately, upon Specific Plan approval, initiate
action on behalf of the City to expedite construction of the
proposed Bayshore highway/Airport Boulevard/Commercial Access
'Hook Ramp' Improvements." The Specific Plan goes on to require
the project sponsor to-prepare plans and obtain CalTrans approval
for the ramps. (Resolution Approving Specific Plan, December 2,
1982, Amendment # 21.) "2..2. /2
77.'17
The Specific Plan Exhibits show the hook ramps being
constructed as part of the Oyster Point Overcrossing Project.
(specific Plan Exhibits Exhibit S35, sheet 3 of 3; see also, \
Exhibit S43, sheet 1 of 2, Exhibit S44, sheet 1 of 2 and Exhibit
S56. )
The DSEIR should state whether these and other provisions of
the specific Plan have been complied with and, if not, the
environmental impacts of failure to comply.
6.
Covenants. Conditions & Restrictions
-
.--,
The Specific Plan provides that CC&Rs must be executed and
recorded which prohibit the parking or storage of recreational
vehicles in residential areas. The CC&Rs were to be executed and
recorded as a condition of tentative subdivision map approval.34
The DSEIR should state whether this has been done.
'3;.~
The Specific Plan provides that at the time each precise
plan is prepared, CC&Rs shall be prepared to implement TSM
actions. (Specific Plan, p. 11.) The EIR should state whether
this has been done. If not, the EIR should discuss the
environmental impacts of failure to comply.
-
XIV. CONCLUSION
For the reasons set forth above, as well as in the attached
letters, the DSEIR does not meet the requirements of CEQA and
should be revised.
34 The approval of any Tentative Subdivision map for
residential development in Terrabay "shall be conditioned upon
the project sponsor executing and recording CC&R's which shall
include a provision prohibiting the parking or storage of
recreational vehicles in such residential area." (Specific Plan
Amendment # 11.)
Cl061.00s
40
,)YS:~;: ?-J::~~T =:I'!'==?::-i.;;:\.~=:
Ma:::::h 15, 1996
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March 19, 1996 8:02 a.m.
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William Lettis & Associates, Inc.
1m Botelho Drive, Suite 262. Walnut Creek, California 94596
Voice: (510) 256-6070 FAX; (510) ~76
March 19, 1996
Ann Broadwell
Lizanne Reynolds
Adams & Broadwell
651 Gateway Boulevard, Suite 900
South San Francisco, CA 94080
Dear Ms. Broadwell and Ms. Reynolds:
William Lettis & Associates, Inc. is pleased to submit this letter presenting the results of our
geologic/geotechnical review of the EIR and draft SEIR for the proposed Terrabay Development
in South San Francisco. The following scope of work was included in the review:
. examination of 1943 and 1991 stereo aerial photographs;
. compilation and review of existing U.S. Geological Survey maps and reports;
· field reconnaissance;
. evaluation of the EIRJdraft SEIR for the project;
. review of geologic/geotechnical reports on file with the City of South San
Francisco; and,
· preparation of this letter.
From our review of pertinent project reports, we were able to identify six areas of potential
concern that may not have been adequately addressed in the Setting and Impact sections of the
draft SEIR. These potential concerns additionally do not appear to have been fully or
appropriately mitigated in the draft SEIR or project development plans. The six identified issues
are outlined below.
--
I) "Maintenance" of roads and development improvements impacted bv slope instabilitv.
Steep natural and cut slopes along the margins of the proposed development have
experienced numerous small- to moderate-sized landslides, debris flows. and pervasive
erosion (surficial instability). Many of the slope failures and areas of accelerated erosion
have formed since completion of the Phase I grading. and some small slides and debris flows
appear to have occurred during recent rainstorms in January and February, 1996. Some of the
recent failures that we observed during our site reconnaissance are on the order of tens of feet
wide, one hundred feet long, and three-to-five feet deep. The draft SEIR also describes that
post-Phase I grading failures .....up to 40 feet wide by 100 feet long have occurred on cut and ~ I~
fill slopes throughout the graded area". Debris from recent slope failures and erosion has .
locally infilled and partially blocked drainage ditches and inundated roadways and graded
pads. The draft SEIR documents recent and post-grading surficial instability, and stated that
similar instability could be expected to occur in the furore. However, the draft SEIR did not
present specific mitigation measures to counter surficial instability, but rather stated that
"...their cleanup is expected to be part of the overall project maintenance program". Based on
our review, it appears that continued surficial instability will become a chronic problem that
will require significant maintenance and expense above what is typically classified as routine
maintenance. In our opinion, the following specific problems should be addressed:
-
Continued surficial instability will rapidly infill or block slope drainage facilitie~
Cleanout of slope drainage facilities may be required after each major rainstorm.
and often will have to be performed by hand due to difficult and restricted access
on steep slopes. If slope drainage facilities are not kept functional and clear of
debris, progressive instability and accelerated erosion could occur. In our opinion,
~l.~~
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March 19. 1996
WLAfferrabay Review
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maintenance plans should be developed to ensure that slope drainage facilities areJ
inspected and maintained at a functional level. ~?
The volume of material involved in recent "surficial" slope failures is cumulatively .~
substantial, and individual failures could involve enough material to partially or
fully block access to portions of the site until debris removal is performed. In fact,
the draft SEIR states that roads within the development will serve as "buffer
zones" for collection and clean-up of landslide debris. Since the probability for
extensive surficial slope failure is highest during or immediately after strong
earthquake shaking or periods of intense rainfall, temporary blockage of access ~ "7
routes could become an issue for emergency response. In our opinion, an .
emergency response plan should be developed that incorporates the possibility of
blocked access routes if these conditions are not mitigated. -
-
· Steep colluvial cuts, on the order of 1.5: I (horizontal to vertical) have undergone
pervasive erosion, and past erosion-control measures have not been effective. Past
cut slope performance indicates that the inclination of these slopes is excessive for
long-term stability. These cut slopes appear to have been designed assuming they
would be cut into bedrock, therefore, an inappropriate bedrock stability analysis ~~ ~
may have been applied to lower-strength colluvial slopes. In our opinion, these ·
slopes should be analyzed using appropriate strength parameters for colluvium.
-
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Inadequate documentation of the potential costs and scope of "maintenance"
associated with surficial instability may cause undue hardship to future property
owners within the development. Our past experience suggests that Home Owners
Associations or other mechanisms to provide site maintenance often are not
successful over the long-term. Project files indicate that this issue was discussed
extensively in the preliminary stages of Phase I design, and that a homowners
Association would have "difficulty providing adequate funding...since the
Department of Real Estate would not accept large dues payments for such
purposes. There was considerable discussion of the use of a GHAD (Geological ""12.,.D
Hazard Abatement District)" (Roger Foote memo, 1/22/91). Despite the ~.ffFf
abundance of documentation in project files about the need to finance a long-term
slope maintenance and restoration program, the draft SEIR does not mention the
need for an organization to implement one. The formation of a GHAD likely
would be the most successful means to address long-term maintenance within the
project. Development of a GHAD involves a Plan of Control Study that consists
of a comprehensive assessment of potential hazards, evaluation of associated risks,
and identification of appropriate mitigation measures. After the Plan of Control
Study is performed, a reserve fund is established for hazard monitoring and
mitigative/maintenance work. Substantial seed funding is typically required from
the project developer to initiate the GHAD and provide working funds until annual
dues or other income sources become sufficient to maintain the program. _
-
2) Landslide "D". Much previous work has been performed to characterize and develop a
stabilization scheme for Landslide D in the western portion of the development. The draft
SEIR-recommended mitigation scheme apparently was based on the most recent study
performed by GeoResources in 1995. The current repair plan consists of the removal of up to I ~ ~. 71/
20 feet from the surface of the slide, constructing a buttress keyed into bedrock at the toe, and
emplacement of two drainage keyways higher in the slide complex. It is significant to note
that GeoResources estimated a shallower depth of active landsliding in the toe area than
referenced in earlier studies by PSC and Leighton and Associates, Inc. This revision was
based on only two additional borings drilled by GeoResources in the toe area of the landslide
(the earlier conclusions were based on 12 borings), and evaluation of data from inclinometers
that were previously installed in the landslide mass. The GeoResources boring logs describe
the active landslide material to be underlain by "ancient debris flow/valley fill deposits" that
'J
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March 19. 1996
rIn A . i ili~>-c-
YYL~tIYl .
appear to be compositionally similar to the active slide debris. The draft SEIR identifies (,QAJ1:
similar material encountered in "buried valleys" within Landslide Area R that contains shears.
It is our opinion that the GeoResources estimate of the depth of active landsliding in the
lower portion of the slope may be too shallow, and has not been conclusively established.
The shallower depth of sliding proposed by GeoResources resulted in revisions to landslide
mitigation schemes developed by PSC and Leighton and Associates, Inc. Additionally, even
though the GeoResources report states that slope inclinometers do not show evidence of '2..'2. .A
active slide movements, our evaluation of inclinometer profiles suggests that active sliding is . -no '7"
occurring to depths of up to about 40 feet in the mid-portions of the slide mass, and possibly
deeper in the landslide toe area. It also is possible that slope movements are occurring at
deeper levels than monitored by the inclinometers because the inclinometer casings
apparently were not extended into in-place bedrock below surficial unconsolidated deposits.
It is critical that the buttress incorporated in the proposed landslide stabilization scheme be
extended entirely through landslide debris and socketed into competent, in-place material
below the lowest slide plane. GeoResources recommended excavation of test pits in the slide
toe during remedial grading work to confirm the results of their boring program. We suggest
that this additional investigation be completed prior to the completion of a mitigation plan,
rather than during the repair work, as it may expose conditions that could require revisions to
the repair scheme. We further recommend the use of large-diameter, downhole-logged
borings, to better define the depth of landslide debris. This technique is commonly used in
large landslide remediation investigations, and can significantly clarify the depth and extent
of slope instability. - .
-
The proposed slope regrading incorporated in the Landslide D repair scheme would create an
approximately 180-foot-high, unbenched 3: I (horizontal to vertical) slope. It has been our 'I'2. 71
experience that unbenched slopes of this length and inclination made in colluvium and "77.
landslide debris are prone to significant erosion and potential instability. We therefore
recommend that the regraded slope configuration be re-evaluated to incorporate intermediate
benches. -
3) "Buried Vallevs" and Deep Landslides. The draft SEIR reports that "buried valleys"
containing thick deposits of colluvium and alluvium and deep landslide deposits were
encountered during site grading in the following locations: (I) Landslide Areas C, D, and R;
(2) the "Goat Farm" cut slope; and, (3) Skypark Circle. The occurrence of thick
unconsolidated deposits or deeper-than expected landslide debris in these areas presented
"conditions substantially different than anticipated". The unexpected occurrence of these
thick deposits suggests that the subsurface exploration performed during the project
geotechnical investigation by PSC Consultants may not have been of sufficient density to
fully characterize possible hazards or adverse conditions of significance to site development. ~,,?
77.r ~
Thick "buried valley" deposits and landslide debris encountered to date have caused the
following site grading problems:
· Expanded grading efforts to excavate and remove loose or unsuitable "buried valley"
material
· Triggering of a large landslide in Area R during grading
More extensive landslide stabilization work (e.g., deeper buttress keyways and
subdrain excavations) to penetrate slide debris and reach adequate foundation materials
Furthermore, it is our opinion that the unexpected occurrence of these deposits has resulted in
the following inadequacies in project design:
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March 19. 1996
M,~ILl.o-
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Insufficient site characterization resulted in stability analyses for cut slope design that , tlPNr.
inappropriately assumed bedrock conditions for slopes underlain by lower-strength and
more erodible colluvial "buried valley" deposits in the "Goat Fann" and other areas
Possible placement of fill over compressible landslide debris or thick colluvium
Based on the previous site grading experience, it would be prudent to expect that similar thick "2.'2 ..,.,
unconsolidated colluvium in "buried valleys" and deep landslide deposits will be encountered 77.''-
during future development phases. Specific mitigation measures should be developed to
. address similar "buried valley" and deep landslide deposits that could be encountered during
future site grading. We recommend that the PSC slope stability analyses for proposed
bedrock cut slopes be reanalyzed using colluvial soil .properties in areas where "buried
valleys" could be encountered. For example, we note that the material strength values used
for analysis of Landslide Area D are lower than those used in the original PSC slope design
analyses, and may be more appropriate for colluvial slopes. In addition, existing fills should
be re-evaluated to determine if mitigation measures are required to prevent excessive or
differential settlements. -
-
4) Differential Fill Movement. Based on our review of the EIRIdraft SEIR, and review of
project geotechnical reports and plans, it appears that possible adverse effects from shrink,
swell, creep, and consolidation of thick fills within development areas may not have been
adequately characterized or mitigated. A basal rock fill layer was apparently incorporated in
some areas of thick fill to help counter adverse total settlement. However, fill thickness
varies substantially underneath many building pads, potentially as much as 20 to 25 feet.
Many lots are located on cut/fill transitions. The need to address these issues was highlighted
in the minutes of the 9/28/89 weekly Geotechnical Meeting, where Bill Enkeboll (consultant
to Roger Foote) expressed concern about the potential for differential settlement within deep
fills beneath houses. The possibility of special foundation considerations for affected houses "3~7~
was discussed at this meeting. No mention of specific foundation considerations is presented
in the draft SEIR.
In addition, it is possible that some fill has been placed over compressible landslide debris or
saturated "buried valley" colluvium. Documentation of site grading conditions on file at the
City of South San Francisco is not adequate to definitively evaluate adequate subgrade
preparation for fills. Long term saturation, cyclic moisture fluctuation. consolidation, and
hydrocompression could cause excessive differential movement of buildings, utilities, and
roadways constructed over varying fill thickness or fill placed over unsuitable foundation
materials. Standard measures to provide drainage of thick fills often are either insufficient to
prevent long-term water accumulation in the fill, or may degrade and become ineffective over
time (Brandon and others, 1990). Fill saturation is exacerbated by excessive landscape
irrigation on the surface of the fill. For future phases, grading should minimize differential
fill thickness under developed areas. This may require overexcavation of native materials in
some areas. Existing fills should be evaluated to determine if mitigation measures are
warranted. -
-
5) Debris flow catch basins. The significant volume of debris flow-susceptible colluvium
present in steep-sided, narrow drainages above the proposed development provides
opportunity for large and fast moving debris flows. Steeper portions of San Bruno Mountain
are zoned within the highest debris flow potential class in San Mateo County (Mark, 1992),
and we mapped numerous recent debris flows from 1995/1996 winter storms during our site ~ ~
reconnaissance. Individual worst-case debris flows could extend hundreds offeet beyond the .',
toe of the hill slope into development areas. Previous geotechnical assessments have
specifically addressed debris flow hazard, including analyses that have estimated the location
and possible volume of mobilized materials. Project development included construction of
five debris catchment basins within the Terrabay Village and Terrabay Park areas to intercept
and drain debris flow materials,
We examined the debris basins during our site review. and although the basins may be
appropriately sited, it appears in some cases that they may not provide sufficient storage for
......../
March 19. 1996~NT:
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WLAfferrabay Review
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- GlJNr.
large events, or filling by successive debris flows or surficial slope failure/erosion.
Comparison of the capacity of the Terrabay debris catch basins with the estimated debris flow
volumes that occurred in the City of Pacifica after very heavy rains in January 1982 suggests
the basins may be undersized. Post-storm investigations in Pacifica (Howard Donley and
Associates, 1982) estimated volumes for nine of the nearly 400 debris flows and landslides.
Most of the slope failures described in the Donley report are in excess of the capacities of the
debris basins at Terrabay. One debris flow in Pacifica was estimated at 3,000 cubic yards.
Debris flow catch basins at Terrabay were constructed in 1990-91, and are apparently
designed based on estimated volumes of between 241 and 507 cubic yards (as described in
the letter report of Dr. James Scholl dated 11/22/88). The relative susceptibility for debris
flow hazards is the same for Terrabay and Pacifica, although the source areas for debris flows
at Terrabay are greater than those studied in Pacifica. In addition, the initial debris flow
volume estimates for Terrabay drainages in the February IS, 1983 PSC report are much larger
than those used in the basin design. No documentation appears to exist between the 1983 and
1988 reports to justify the reduced volume estimates.
~.7t
In some instances, building pads are located directly below the basins, and would be in direct
impact path of debris flows if the basins do not provide adequate storage capacity. In these
cases, the design of the basin is critical. Since the basins were apparently designed in 1983,
we recommend re-evaluation of the basins to assess whether the existing designs meet current
state-of-the-art technology and include a reasonable level of conservatism. Furthermore,
several issues regarding the malfunction of catchment basins were raised by the County, and
we recommend follow-through on the suggested studies outlined in the draft SEIR. Th~
mechanisms to monitor, clean, and maintain debris basins need to be firmly established, and fI2"'2 7~
incorporated into the GHAD or other appropriate site hazard mitigation and maintenance 7? '7
program. __
-
There is no reference in the draft SEIR for plans to install debris basins in the remainder of '2..'2.. -,/
the development. Because a high debris flow hazard exists throughout the Terrabay -:/7.'"
development, it is our opinion that the draft SEIR should explicitly state the mitigation plans
for future project phases. -
-
6) Impact to lands proposed to be dedicated to the County pursuant to Habitat Conservation
Plan. The proposed extent of grading shown on the project grading plan (Figures 2-04 G; 2-
04 I; and 2-04 1) does not include several of the known landslides along the margins of the
development area that are shown on the draft SEIR Geologic Map (Figure 29). The draft
SEIR proposes that "all landslides and areas of weak soil in or near [the] proposed
development should be repaired" (page 161, 4th paragraph). In addition, pervasive erosion
and surficial slope failure has already occurred along the margins of the development within
the proposed land dedication zone since completion of the Phase I grading, even in areas that
were reportedly stabilized. Based on our review of project geologic/geotechnical issures, and
post-Phase I grading performance, we believe that the draft SEIR-proposed mitigation
measures may not adequately address long-term stability in the disturbed areas of the
dedicated land. It also is likely that additional unstable areas and adverse geologic conditions
(e.g., "buried valleys") will be encountered during the Phase II grading that may require even
more extensive grading and stabilization work in the dedicated land than proposed in the draft
SEIR and development plan.
The attached figure shows the locations of known landslides and unstable ground along the
margins of the proposed development that extend outside of the "Temporarily Disturbed by
Grading" zone shown on the 1984 Grading Plan. We believe that many, or most, of these
areas will require stabilization work to achieve adequate long-term stability and slope
performance. Possible stabilization measures could include: (I) extensive grading repair
work, (2) slope flattening, (3) installation of subsurface and surface drainage elements, and
(4) erosion mitigation. All of these measures will result in temporary andlor permanent
disturbance of natural slopes. The areal extent of required stabilization work may be
significantly greater than shown on the figures if additional landslides or unstable areas, such
as "buried valleys", are encountered during Phase II grading.
WLAfferrabay Review
5
March 19. 1996
,
~.77
. .
.. .
-
W'LA-4\~
It has been a pleasure to work on this interesting project. If you should have any questions or
comments, please do not hesitate to call our office. Thank you for the opportunity to assist you
on this project.
Respectfully,
7:Z&(!jltc
William R. Lettis, Ph.D., C.E.G.
Principal Geologist
/1Je"'!)~ ~
Jeff Bachhuber, C.E.G.
Senior Engineering Geologist
:~ :
WLAfferrabay Review
6
March 19, 1996
ifZ~I~~
REFERENCES
Brandon, T., Duncan, J .M., and Gardner, W., 1990, Hydrocompression settlement of deep
fills: Journal of Geotechnical Engineering ASCE, Vol. 116(10), 1536-1548.
Donley and Associates, 1982, Geological Investigation, Landslide Type and Distribution and
Mechanics Details of Nine Representative Failures, January 1982 Rainstorms, City of
Pacifica, CA. 100 pp. with appendices.
Environmental Impact Planning Corporation, 1982, Draft Environmental Impact Report for
the Terrabay Development Project. 231 pp. with appendices.
Wagstaff and Associates; 1996, Draft Suplemental Environmental Impact Report for the
Terrabay Specific Plan and Development Agreement Extension. 275 pp. with
appendices.
Wagstaff and Associates, 1996, Draft Suplemental Environmental Impact Report for the
Terrabay Specific Plan and Development Agreement Extension: Geotechnical
appendix.
We reviewed the following documents:
CarrolVResources Engineering and Management, 1989, Site Improvements and Grading
Plans for Terrabay Development- Stage I. 88 sheets.
Hengesh, J. V., and Wakabayashi, J., 1995, Quaternary Deformation between Coyote Point
and Lake Merced on the San Francisco Peninsula: Implications for Evaluation of the
San Andreas fault. U.S. Geological Survey NEHRP Annual Project Summaries:
XXXVI. pA17.
Leighton and Associates, 1992, Supplemental Geotechnical Investigation, Landslide D, Phase
I, Terrabay Project, South San Francisco, CA.
Mark, R.K., 1992, Debris Flow Probability, San Mateo County. U.S. Geological Survey Map
I-1257-M,I:62,500.
PSC Associates, Inc., 1983, Geotechnical Engineering Investigation Report, Grading Design
for the Proposed Terrabay Village and Terrabay Park, Neighborhoods A and B,
Terrabay Development, South San Francisco, California.
PSC Associates. Inc., 1983, Debris Flow, Potential Debris Flow Paths, and Estimated Volume
of Debris Materials in Storm Drainage Basins.
PSC Associates, Inc., 1984, Additional Slope Stability Analyses, Terrabay Development,
South San Francisco, CA A Development by W.W. Dean & Associates for Resources
Engineering and Management, Grading Design for Terrabay Village and Terrabay Park
(Neighborhoods A and B).
PSC Associates, Inc. , 1990, Interim Supplemental Report on Slope Stability Analyses for
Woods West and Woods East (formerly neighborhoods C and D) Portions of Terrabay
Development.
PSC Associates, Inc. , 1991, Foundation Investigation for Proposed Terrabay Village, South
San Francisco, CA.
WLAfferrabay Review
7
March 19, 1996
M~~~
PSC Associates, Inc. , 1995, Grading Report Showing Summary of Testing and Observation
Services During Mass Grading of Terrabay Village at Terrabay Development: South
San Francisco.
Thomson, I.M., and Everden, I.F., 1986. Map Showing Predicted Seismic-shaking.lntensities
of an Earthquake in San Mateo County, CA Comparable in Magnitude to the 1906 San
Francisco Earthquake. U.S. Geological Survey Map 1-1257-H. 1:62,500.
Aerial photographs:
1943 stereo pair, from National Archives (frames DDB-2B-133, -134). Scale =1:20.000
1991 steres pair, from Pacific Aerial Survey (frames A V-4075-6-16, 17 and A V-4075-7-16,
17)
WLlVferrabay Review
8
March 19, 1996
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WILLIAM R. LETTIS, Ph.D., R,G., C.E.G.
Principal Geologist
Seismic Hazard Assessment
Neotectonics
Engineering Geology
EDUCA TION
University of California, Berkeley, CA: Ph.D., Geology, 1982
University of California, Berkeley, CA: M.S., Geology, 1979
Humboldt State University, Arcata, CA: B.S., Forestry, 1977; B.S., Geology, 1977
REGISTRATION
Professional Geologist: Registered Geologist, California No. 4079, 1986
Certified Engineering Geologist, California No. EG 1296, 1986
PROFESSIONAL HISTORY
William Lettis & Associates, Inc., Oakland, CA, Principal Geologist, 1990-date
Geomatrix Consultants, Inc., San Francisco. CA, Senior Geologist, 1985-1990
Bechtel Civil and Minerals, Inc., San Francisco, CA, Geologist, 1982-1985
United States Geological Survey, Menlo Park, CA, Geologist, 1978-1982
University of California. Berkeley, CA, Teaching Assistant in Geology, 1978-1979
Humboldt State University, Arcata, CA, Teaching Assistant in Geology, 1976-1978
REPRESENTATfVEEXPERIENCE
Dr. Lettis is responsible for conducting regional and site investigations to assess the
seismotectonic setting and seismic and surface-faulting hazards in both active plate margin
and stable intraplate tectonic environments. These investigations typically involve the
deterministic and probabilistic characterization of seismic sources for hazard evaluations. A
major emphasis of Dr. Lettis' work has been the interpretation of soil profile development,
Quaternary stratigraphy, and geomorphology to assess regional neotectonics and the
character and age of local surface deformation and faulting. In stable intraplate regions, Dr.
Lettis has participated on studies to assess the regional seismotectonic setting and to identify
and characterize seismic source zones based on analyses of seismicity, tectonic features, and
tectonic provinces. He has conducted field and office studies for hydroelectric and nuclear
generating facilities, missile silos, nuclear waste repositories, and major oil and coal slurry
pipelines in the western and southeastern United States, and in southeast Asia, the Middle East,
the People's Republic of China, northern Africa, and South America.
SELECTED REFERENCES
Hanson, K.L., and Lettis, W.R., 1994, Estimated Pleistocene slip rate for the San Simeon Fault Zone,
South-Central California: Geological Society of America Special Paper, p.133-150.
Kelson, K.I., Lettis, W.R., and Lisowski, M., 1992, Distribution of geologic slip and creep along faults
in the San Francisco Bay region: Proceedings' of the Second Conference on Earthquake Hazards
in the Eastern San Francisco Bay Area, California Division of Mines and Geology Special
Publication 113.
Lettis, W. R., Kelson, K. I., Wesling, J. R., Hanson, K. L., and Hall, N. T., 1994, Quaternary
deformation of the San Luis Range, San Luis Obispo County, California, in Alterman, I. B.,
McMullen, R. B., Cluff, L. S., and Slemmons, D. B., eds., Seismotectonics of the Central California
Coast Ranges, Geological Society of America Special Paper 292, p. 133-150.
Lettis, W.R., and Hall, N.T., 1994, The Los Osos Fault Zone, San Luis Obispo County, California:
Geological Society of America Special Paper 292. p. 73-102.
Simpson, G.D., Lettis, W.R., and Kelson, K.I., 1992, Segmentation model for the northern Calaveras
fault, Calaveras Reservoir to Walnut Creek: Proceedings of the Second Conference on Earthquake
Hazards in the Eastern San Francisco Bay Area, California Division of Mines and Geology
Special Publication 113.
M~I~~
REPRESENT A TIVE PROJECTS
Seismic Ha:.ard Assessment
· Project Manager for seismotectonic evaluations of thirty-two U.S. Bureau of Reclamation
dams in the western United States. The project involves the geologic and seismologic
characterization of known and potential earthquake sources in specific geologic provinces
of the western United States, and the deterministic assessment of ground motions at
specific darn sites.
Project Manager for numerous seismic hazard evaluations for Pacific Gas & Electric
facilities throughout California. These projects included the assessment of earthquake
vulnerability to PG&E's entire gas supply and distribution system, including pipelines,
compressor stations, terminals, and pressure-limiting stations. The project involved
preparing liquefaction and slope stability hazard maps covering all of northern and
central California. site assessments of above ground facilities, and assessments of fault
activity at pipeline crossings. Dr. Lenis also is completing a comprehensive, seven-year
investigation of Quaternary faulting in central coastal California as part of PG&E's Long-
Term Seismic Program for the Diablo Canyon Power Plant. For this study, Dr. Lenis
directed a program of mapping, soil-stratigraphy, drilling, trenching, and age dating
studies to evaluate the capability and behavior of over 20 potentially capable faults
including the San Simeon, Hosgri, and Los Osos faults.
· Project Manager for a seismic vulnerability assessment of the Marin Municipal Water
District's backbone water supply system. Hazards assessed include liquefaction.
earthquake-induced slope failure, surface fault rupture, and strong ground motions from
three scenario earthquakes.
· Dr. Lettis has conducted several seismic hazard investigations in the eastern San Francisco
Bay area and San Joaquin-Sacramento Delta. For the Association of California Water
Agencies (ACW A), he evaluated the impact of seismic hazards to water systems in the
Delta. In addition, Dr. Lenis has characterized the activity, location and geometry of the
Coast Range-Sierra Nevada Boundary fault zone in the southwestern Sacramento Valley
for the U.S. Bureau of Reclamation and in the northwestern San Joaquin Valley for the
U.S. Geological Survey. He has also performed numerous research and consulting
investigations of fault activity along the Calaveras, Hayward, Ortigalita, Green Valley and
San Joaquin faults.
Research Investigations
· Dr. Lettis has been the Principal Investigator on sixteen research projects sponsored by
the U.S. Geological Survey and the National Science Foundation to assess earthquake
hazards in California. These studies include paleoseismic investigations of the San
Andreas, Calaveras, San Gregorio, and Shannon-Monte Vista faults in the San Francisco
Bay region, geomorphic analyses of the 1989 Lorna Prieta, 1987 Whittier Narrows, and
1994 Northridge earthquakes, and liquefaction mapping of the Napa, San Francisco, and
Stockton 1: 100,000 scale quadrangles. Dr. Lenis provided technical review for seismic
hazards assessments of the Los Alamos National Laboratory in northern New Mexico and
for the Shivta Nuclear Power Plant in Israel. As Co-Principal Investigator, Dr. Lenis also
completed an investigation sponsored by the U.S. Nuclear Regulatory Commission to
evaluate the late Quaternary history and seismotectonic sening of the Meers fault,
Oklahoma.
-... ..
Technical Peer Review
· Dr. Lenis provides technical peer review for seismic hazard investigations throughout the
United States and abroad. For PG&E, he has reviewed several paleoseismic investigations
conducted by the PG&E to assess seismic hazards to their hydroelectric facilities in the
northern and central Sierra Nevada. He also is providing technical review for seismic
hazards assessments of the Los Alamos National Laboratory and Sandia National
WLA---J,~~
Laboratory in the Rio Grande Rift. New Mexico, and for the Shivta Nuclear Power Plant
in the northern Negev Desert, Israel.
· Dr. Lenis has performed numerous technical reviews of proposed subdivisions and
construction projects for the cities of Orinda and Vallejo. These reviews have covered
projects involving complex geoloigc issues such as hillside mass grading and landslide
stabilization.
Expen Panels and Committees
· Dr. Lenis serves on several expert panels and committees related to seismic hazard
assessment. He is a continuing member of an expert panel sponsored by Lawrence
Livermore National Laboratory for the Department of Energy to assess earthquake
hazards in the southeastern United States for the proposed New Production Reactor at
Savannah River. In addition, he served as a member of the Geology/Seismology
Subcommittee of the California Seismic Safety Commission and the California Division
of Mines and Geology Committee on Liquefaction Hazards. Dr. Lettis also is a member
of the Board of Directors for CONCERT, the Coordinating Organization for Northern
California Earthquake Research and Technology.
Slope Stability Investigations
· Dr. Lettis has performed investigations of slope stability in a wide range of geologic
settings, studies have included surface mapping. subsurface drilling, sampling. and
instrumentation. large-diameter borehole logging, and static, pseudo-static. and dynamic
analyses of slope stability. Specific projects include evaluating the cause and failure
mechanism of the Sunrise Hill landslide in Orinda, CA; assessing native and cut slope
stability of the Altamont Landfill expansion area including the identification and
characterization of twenty-three landslides near Altamont Pass. CA; evaluating the cause
and failure mechanism of a large debris flow in Yuba County, CA; and providing peer
review for slope stability assessments for the Sky Valley development. Vallejo. CA. Dr.
Lettis also has evaluated rock slope stability for the MX-Missile Test tunnel and silo at the
Nevada Test site, and for the New Hogan Dam Powerhouse in the Sierra Nevada.
COMMITTEES AND EXPERT PANELS
Member, Board of Directors. Cooperating Organizations of Northern California for
Earthquake Research and Technology (CONCERT) 1993 to present
Member, Expert panel to assess earthquake hazards in the southeastern United States,
Lawrence Livermore National LaboratorylDepartment of Energy, 1990 to present
Member. California Seismic Safety Commission, Geology/Seismology Subcommittee, 1988 to
1990
Member. California Division of Mines and Geology Advisory Committee on Liquefaction
Hazards. 1991 to 1993
Member, NASA Science Committee. 1985
AFFILIATIONS AND A WARDS
American Geophysical Union
Association of Engineering Geologists
Geological Society of America
Earthquake Engineering Research Institute
Seismological Society of America
Geological Society of America, Penrose Grant, 1979
University of California Regents Fellowship. 1977-1978
M~I~~
JEFFREY L BACHHUBER, M.S., R.G., C.E.G.
Senior Engineering Geologist
Earthquake Site Response
Ground Failure Hazards
Engineering Geology
Slope Stability and Remediation
EDUCATION
San Jose State University, San Jose, CA, M.S., Geology, 1990
San Jose State University, San Jose, CA, B.A., Geology, 1984
REGISTRA TlON
Registered Geologist, California, No. 4909, 1990
Certified Engineering Geologist, CA, No. 1534,1990
PROFESSIONAL mSTORY
William Lettis & Associates, Inc., Oakland, CA, Engineering Geologist, 1993-date
Pacific Gas and Electric, San Francisco, CA, Contract Engineering Geologist, 1988-1993
Seidelman Associates, Inc., Pleasant Hill, CA, Project Geologist, 1987-1988
JCP Engineers and Geologists. Cupertino, CA, Project Geologist, 1984-1987
REPRESENTATIVE EXPERIENCE
Mr. Bachhuber is a Certified Engineering Geologist in California with over 11 years of professional
experience. He is specialized in the evaluation and remediation of stability problems in soil and rock
slopes, and assessment and design of foundations and grading to address potentially adverse geologic
conditions. His Masters thesis project was a study of the engineering geology and seismic and landslide
hazards of the city of Scotts Valley in Santa Cruz County, California. Brief descriptions of typical
projects conducted by Mr. Bachhuber are presented below.
Technical Peer Review
. Mr. Bachhuber has performed technical reviews for residential developments for the city of Orinda
and counties of Santa Clara and Santa Cruz. These reviews have included evaluation of geotechnical
and geologic data, reports. and onsite inspections of foundations, grading, and landslide stabilization.
Slope Stability Investigations
. Investigated landslides in soil and weathered rock slopes involving all types of failure modes, and
ranging in size from tens of feet, to over 1 square mile in area. Example projects include evaluations
of massive ancient landslide complexes reactivated by the 1989 Lorna Prieta earthquake, debris slide
and flow failures affecting PG&E's Mokelumne River Project (7 sites), over 20 landslides in the Santa
Cruz Mountains and Oakland Hills, a large block glide failure affecting PG&E's South Yuba Canal,
coalescing earthflow complexes in the California coastal ranges, and landslides within the over 50
square mile Marin Metropolitan Water District service territory. The scope of these investigations
included geologic mapping and aerial photograph interpretation, exploratory drilling and trenching
(including downhole logging), laboratory testing, pseudostatic stability analysis (UTEXAS3),
determination of slope failure mechanisms, assessment of potential future risks, compilation of
landslide hazard maps, and development of recommendations for remedial measures including graded
stabilization methods, drainage, and slope reinforcement. Performed mapping and stability
evaluations of steep rock slopes (rock mechanics) that required climbing and rope safety procedures.
These projects included the PCW A Ralston and French Meadows Penstocks, PG&E's Lost Canyon
Penstock portals, Balch Diversion and Afterbay Dam abutments, and sea cliff instability affecting
Point Bonita Lighthouse. Characterized rock mass properties, and evaluated slope stability using
kinematic and pseudostatic methods. Evaluated rockfall hazard by computer modeling (CRSP3).
Developed stabilization repair schemes including rock bolts and deep anchors, drainage, and -Gable
netting for the Placer County Water Agency (PCW A) Ralston and French Meadows Penstock slopes,
and the NID Rucker Tunnel. Design and field testing of geotechnical instrumentation arrays that
included tiltmeters, inclinometers, extensometers, and piezometers connected to remote data
collection, control, and alarm systems.
WL~I~'~
Water and Gas Disrribution Systems
Performed geologic and geotechnical investigations for numerous gas and water pipelines including
the proposed WyCal Line 300 Expansion Project, McDonald Island Expansion Project, and Line 191
replacement through Briones Regional Park (Contra Costa County). Currently performing Marin
Metropolitan Water District Backbone Water System seismic vulnerability assessment including 16
tanks, 2 reservoirs, 3 treatment plants and transmission pipelines and pump stations. Assessed
hazards from liquefaction, earthquake-induced slope failure, surface fault rupture and ground motions
from several scenario earthquakes. Produced hazard zonation maps, ground motion attenuation maps,
and geotechnical characterization of tank and treatment plant sites.
Hydropower Generation and Conveyance Projects
. Geologic hazards evaluations of over 25 penstocks (vintage 1906 to 1993) for the PG&E Penstock
Safety Program, and PCW A that are founded on diverse geologic materials including soil and
colluvium, landslide debris, and steep rock slopes. Assessed hazards from slope instability,
foundation failure, volcanism, seismicity, fault rupture, and erosion. Engineering geology-
geotechnical discipline leader for Ensign & Buckley Consultants Steel Penstock Safety Assessment
Program.
. Performed geologic and foundation investigations of PG&E's Lyons, Kerkhoff Balch Diversion.
Balch Afterbay, and Spaulding No.1 Dams. Included geologic mapping, aerial photograph analysis,
exploratory drilling through the dams into the underlying foundation rock, laboratory testing of
recovered rock and dam-rock contact core samples, evaluation of abutment and foundation rock
stability and erosion resistance, and development of recommended foundation criteria for 3-D FEA
analyses.
.-/;("'....
. Geologic/geotechnical investigation and construction monitoring for the PG&E Grizzly Powerhouse
project that included a 23 MW concrete powerhouse, 12,OOO-foot-long TBM tunnel, and 4,5OG-foot-
long steel penstock. Studies included geologic mapping, direction and logging of exploratory borings
and test pits (40 borings in soil and rock), development of geologic cross sections, laboratory testing,
and general design recommendations. Assessed natural and cut slope stability for site excavations
and penstock alignment. Designed slope drainage and stabilization system for colluvial swale
penstock crossing, and assessed foundation conditions for pier-supported soft ground span section.
Evaluated tunnel muck disposal pile site, and developed recommendations for foundation preparation
and drainage control and inspection facilities. Perfonned construction monitoring and quality
assurance inspections during disposal pile construction, and mapped tunnel excavation. Perfonned
project start up inspections, including evaluation of geotechnical instrumentation. Acted as the
registered geologist representing PG&E to FERC and the USFS regarding geologic issues.
. Performed geologic and geotechnical investigations for the proposed PG&E Pit 2 Dam project, and
supplemental geologic and geotechnical investigation for the proposed PG&E New Centerville
Powerhouse. Work scopes included geologic mapping and aerial photograph analyses, exploratory
drilling and geophysical surveying, borehole packer testing and analysis, downhole geophysical
surveys, laboratory testing, evaluation of slope stability hazards, and development of excavation and
foundation design criteria. Assessed creek inflow into the powerhouse excavation.
Geotechnical Instrumentation
. Installed and evaluated geotechnical instrumentation to monitor slope movement, hydrogeologic
conditions, rock slopes, and structure/foundation perfonnance at over 50 sites throughout California.
. Instrumentation has included inclinometers, piezometers, survey networks, tiltmeters, crack gauges,
and extensometers. At some sites, automated data collectors were installed and connected to a
measurement and control unit that was connected to alann systems.
Foundation and Development Studies
Performed foundation investigations for microwave towers, wind turbines, canals, transmission line
towers, and commercial and residential developments. Foundations included spread footings,
concrete mats, combination retaining wall-footings, and friction and end-bearing piers/piles. Directed
and conducted exploratory mapping, geophysical exploration, and drilling/penetration testing of
U7Lz4--3JI~~
foundation sites. Prepared laboratory testing programs. Performed field inspections of foundation
excavations and pier borings.
Performed geologic and geotechnical investigations of hillside and mass grading projects throughout
the San Francisco Bay area involving placement of fills on steep slopes, and stabilization of landslides
and colluvial-filled hollows. Mapped and inspected keyways and drainage bench excavations, and
down-hole exploratory borings during landslide repair grading to ensure penetration of landslide
debris. Designed and inspected hillside drainage systems, including blanket and trench aggregate
drains, and horizontal drains.
AFFILIATIONS AND PROFESSIONAL DEVELOPMENT
Member, Association of Engineering Geologists
Slope Stability and Landslides Short Course, 1990, Univ. of Wisconsin, Denver
Stability and Performance of Slopes and Embankments, 1992, ASCE specialty conference, Berkeley
Rock Slope Stability, 1994, Association of Engineering Geologists Short Course
Advances in Earthquake Engineering Practice, 1994, University of California, Berkeley
Rock Slope Stability Short Course, 1994, Association of Engineering Geologists, Virginia
REFERENCES
Bachhuber. J., and Lowe, J.A., 1994, Ralston Penstock rock slope investigation and stabilization, Sierra
Nevada Mountains, Placer County, California: Association of Engineering Geologists 1994 Annual
Meeting, Williamsburg, Virginia.
Bachhuber, J., and Page. W.D., Evaluation of surface fault rupture hazard to a hydropower penstock using
the 40Ar/39Ar dating technique, in Noller, J.S., Lenis, W.R., and Sowers, J.M., eds., Quaternary
geochronology and paleoseismology: Nuclear Regulatory Commission Manual.
Bachhuber, J.. Page, W.D., Ahlgren, C.S., and McManus, R.A., 1995, Geologic Hazard Assessments of
PG&E Penstocks in the Sierra Nevada; Association of Engineering Geologists 1995 Annual Meeting,
Sacramento, CA.
Hengesh, J.V., Bachhuber, J.L., and Theisen, R., 1995, Seismic hazard mapping for an integrated system
vulnerability model, Marin County, California: Association of Engineering Geologists 1995 Annual
Meeting, Sacramento, CA.
S M I THE ~ G I ~ E E R I i': G (7' \ 1 .-\ ~ .-\ G E \ 1 E ~ T
I
March 18, 1996
Ann Broadwell
Lizanne Reynolds
Adams & Broadwell
651 Gateway Blvd, Suite 900
South San Francisco, CA 94080
Subject: Terrabay Draft Supplemental EIR: Review of Transportation Component. p96002xO
Dear Ms. Broadwell and Ms. Reynolds:
Per your request I have reviewed the transportation section of the above referenced DSEIR prepared
by Wagstaff and Associates and dated January, 1996. As part of the review I have also reviewed
source documentation cited to the DSEIR, especially the East Of 101 Area Plan EIR. Following are
our comments.
1. The trip generation analysis in the DSEIR significantly understates project traffic generati::-t
from restaurants. Understatement of project traffic leads to understatement of project impact
on capacity utilization and level of service computations at key intersections, freeway ramps and
freeway segments and consequent probability of failure to identify significant traffic impacts of
the project. The traffic generation analysis should be recomputed using appropriate trip
generation rates and all traffic capacity utilizationllevel of service assessments and impact
assessments based thereupon should be recomputed.
Tables 13 and 14 of the referenced report present the project trip generation analysis. The tables
identify a land use category of "Quality Restaurant" at a development level of 150 seats. They also
identify another category of "Restaurants" at a development level of SOD seats. Logically, the "2'2-?1/l.
category "restaurants" references the more specific land use type "high turnover, sit-down restaurants" "77- f V
since the DSEIR distinguishes it in the table from "quality restaurants" and since it could not refer to
"fast-food restaurants" which are not permitted in this area. However, the DSEIR calculates trip
generation for the SOD seats of "high-turnover, sit-down" restaurant use at the same low rate as
characteristic of "quality restaurants" rather than at the considerably higher rate for "high-turnover, '
sit-down" restaurants indicated for this land use in the trip generation reference source cited by the
DSEIR. As the result of this use of an inappropriately low rate, the DSEIR understates total
tripmaking for the entire project by 1850 daily trips. equivalent to 11.7 more trips than estimated for
the project. For the P.M. peak: period, inbound tripmaking would be 11 percent higher than estimated
in the DSEIR for the entire project and outbound tripmaking would be 8.5 percent higher. In the
A.M. peak hour, the DSEIR underestimates inbound tripmaking by 10.8 percent for the entire project
and outbcund tripmaking by 24 percent. These underestimates are of such scale as to probably alter
T R ~ IF: C . T R A " ,; p ~.., R 1 .~ T I ~':" . \. A " .A l; E \: E " T
V
Gl?ttff.
5.':': ~ Ll'\\~T R,ud. l"i.!\'!1 (-i:-\. C:\ I.)";~~- fl.'l: :;!\1.4~'"'.\1';~- :".1.\: 51l't.-t~I.'.\.)";-~
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 2
"tiNT.
the results of capacity utilization/level of service computations and the consequent findings of ~-22.
significant impact based thereon. All of the traffic analyses should be recomputed and reassessed 77.' U
based upon appropriate trip generation rate for the restaurant component. _
-..
2. The base case traffic volume projections for years 2000 and 2010 are not prepared iIi
accordance with either of the methodologies described in CEQA guidelines. As a result, the
ordinary citizen has no way of knowing whether these "base" forecasts, hence the entire analysis
of impacts and significance, have any realistic relationship to a particular stage of likely future
~ growth in the area. As a consequence, the transportation component of the DSEIR is critically
deficient as a document disclosing potential significant impacts of the project.
CEQA guidelines provide that future base traffic forecasts may be projected on either of two
approaches. One involves forecasting the increments to existing traffic from a specific list of known
likely land use development projects in the area. The other involves estimating the traffic from a
specific level of land use development as projected in an adopted general plan or related planning
document. The DSEIR transportation element takes neither of these fundamental approaches. Instead,
it synthesizes future base year traffic forecasts by blending the traffic forecast results, not the
underlying land use projections, of three independent and not necessarily consistent specific area plan
and general plan studies. Hence, the ordinary citizen (or the public policymaker faced with the
responsibility of certifying the DSEIR) has no clear way of understanding whether this mix of prior
traffic forecast results has any reasonable relationship to likely land use development in the area for
the base forecast years and hence whether there is any validity to the analysis and its conclusions. In
this sense the DSEIR fails to achieve its purpose as a disclosure document.
?,3.7~
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3. The DSEIR traffic analysis utilizes information compiled in 1993 as the representation of
"existing conditions". The DSEIR fails to disclose how the project and general traffic growth will
adversely affect the actual existing conditions on the major traffic improvements that the citizens
of South San Francisco and San Mateo County have recently completed in this area. Indeed,
the DSEIR fails to compute "existing" capacity utilization/level of service at any of the key
intersections in the vicinity of the Oyster Point Interchange. In this way the DSEIR is deficient
as a disclosure document.
The DSEIR explains that available 1993 traffic data and analyses were used as representative of ~.eo
existing conditions because, during the period of preparation of the DSEIR traffic study, the area street
network and traffic patterns were so disrupted by the construction activity that meaningful measures
of actual existing traffic conditions could not be taken. However, this DSEIR was released in January,
1996. The Oyster Point Interchange area roadway improvements were fully operational by September,
1995. The intervening period was ample time for the DSEIR preparers to have observed and
quantified real existing traffic conditions and included them in the document. Because the DSEIR
provides no capacity-level of service information on true existing conditions at the key intersections
in the vicinity of the Oyster Point Interchange, it provides no basis for the public and public
policymakers to judge how much project traffic will deteriorate level of service from existing
conditions at these locations. In this sense it is critically deficient in disclosing the project's impacts.
-.
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 3
-
4. The Year 2000 baseline level of senice/capacity utilization projections in tbe DSEIR indicate
significantly better conditions than the actual observable currently existing conditions at some
locations. This completely undermines the credibility of the level of service analyses which form
the basis for the transportation evaluations in the DSEIR. Actual 1996 conditions should be
counted and observed and all baseline projections and level of service computations should be
revised accordingly. · ~.~,
In Point 3 above we commented that the DSEIR should have counted and computed existing conditions
subsequent to full opening of the Oyster Point interchange in September, 1995. The importance of
that comment is reinforced by the subsequent observation that the intersection of Airport, Bayshore,
Oyster Point and Sister Cities Boulevards and the general area of the interchange currently experiences
lengthy standing traffic queues in the AM peak period. This observable reality is indicative of
conditions far worse than the DSEIR's projection of quite adequate LOS D-.72 conditions for Airport-
Bayshore-Oyster Point-Sister Cities or B-.52 for Oyster Point-Dubuque-101 NB On Ramp. Since the
baseline level of service projections are so clearly divorced from reality, the credibility of the entire
transportation analysis is undermined. The entire analysis should be redone based on an accurate
measurement, documentation and assessment of currently existing conditions. -.
-
S. The DSEIR fails to fully disclose the extent of likely Year 2010 project impact at the Bayshore
Boulevard-Airport Boulevard-Oyster Point Boulevard-Sister Cities Boulevard intersection and
the intersection of Dubuque Avenue with U.S. 101 nortbbound off and southbound on ramps.
Due to the lack of appropriate quantification of actual traffic impact, there is no assurance that
the mitigation measures the DSEIR identifies for these locations will satisfactorily mitigate the
impact.
The Year 2010 intersection level of service analysis presented on Table 16 (page 127) of the DSEIR
shows the superficially counter-intuitive result that implementation of all three phases of the project
would cause PM peak conditions at the intersection of Dubuque Avenue with the US 101 northbound '33 e2.
off and southbound on ramps to improve. The apparent explanation for this situation is that the I . .
DSEIR preparers assume that opening the new US 101 ramps at the project's Commercial Access
would draw off some of the traffic projected for the Dubuque ramp location under the "2010 Base"
and "2010 Base + Phase 1" scenarios. However, the DSEIR projects that with full Project
development at Year 2010, the intersection of Commercial Access, Bayshore Boulevard and US 101
southbound ramps would operate in the PM peak period at level of service F (129 % of capacity).
With the intersection operating at this severely deficient condition, much of the traffic forecast here -
would reasonably be expected to deviate to the routes it had been projected to use in the scenarios
where there are no freeway ramps at the Commercial Access point. This would increase the traffic
volume and the consequent capacity utilization and project impact at the intersection of Bayshore
Boulevard-Oyster Point Boulevard-Airport Boulevard-Sister Cities Boulevard and the intersection of
Dubuque Avenue with the US 101 ramps and would call into question the adequacy of proposed
mitigation measures at these locations. The DSEIR should recompute project impacts and mitigation
needs based upon a more reasonable pattern of traffic dispersal over the area street network rather than
presuming an impossible concentration of traffic at a single location.
-
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 4
---r
6. The DSEIR presents no indication that the proposed mitigation for the project's significant
impacts on freeway operations would have satisfactory mitigating effect. The DSEIR is deficient
in failing to disclose that the project's impacts on freeway operations may likely be a significant I
unmitigated adverse impact.
The DSEIR identifies Project Phases I, II and III as having significant adverse impact on US 101
freeway operations in peak commute periods. It identifies implementation of a Transportation System
Management Program as mitigation for this impact. However, it fails to estimate the reduction in
peak project tripmaking which could realistically be expected to result from a TSM program or to
demonstrate whether that likely level of trip reduction would be sufficient to successfully mitigate the
project's significant adverse impacts.
The actual dimensions of the project's impacts on freeway operations are estimated on Table 17 (page
130 of the DSEIR). The table shows that traffic from full development of all project phases would
increase traffic on the freeway in the pm peak by 2.96 percent (410 project trips added to a 2010 base
volume of 13,850) from Oyster Point to Grand Avenue and by 2.91 percent (390 project trips added
to a 2010 base volume of 13,390) between Grand Avenue and South Airport. The DSEIR's stated
level of significance criterion for circumstances where the freeway is already in level of service F
operation is a 2 percent change in volume (277 and 268 project trips at the above locations
respectively). The implication of these projections is that TSM would need to decrease total project
tripmaking by about 33 percent I to mitigate the identified significant project impact. Since TSM
operates best on commercial uses in peak periods, almost the entire effect of peak period TSM would
have to be realized from the project's commercial component. The project's commercial component
accounts for 71 percent of total project pm peak tripmaking (1305 commercial generated out of 1840
total project pm peak trips per DSEIR Table 13). Hence, to achieve a 33 percent overall reduction
in project tripmaking, TSM would have to achieve a reduction of nearly 46 percent of the project's
pm commercial traffic generation.2 TSM programs which achieve a 10 to 15 percent reduction in
commercial tripmaking are considered highly successful. Achieving a peak trip reduction approaching
46 percent in a commercial development of this character, or even approaching 33 percent of the
development taken as a whole, is highly implausible. Hence the DSEIR is deficient for failing to
~~
1 It takes a reduction of 134 trips to bring the forecast project increment of 410 on the Oyster
Point - Grand segment below the the 2 percent significance threshold level (277 trips at this location).
This is a 32.68 percent reduction in the forecast project trip total at this location. Since TSM
programs are not selective in targeting trips using a particular roadway external to the project site, this
percentage reduction of overall project tripmaking would be necessary to assure mitigating the freeway
impacts. The necessary reduction on the Grand-Airport segment is similar: a reduction of 123 from
390 - 31.54 percent - to get below the 2 percent significance threshold of 268.
2 The TSM trip reduction goal to avoid a finding of unmitigated significant adverse impact is
32.68 percent of the forecast 1840 total pm peak trips or a reduction of 601 trips. However, a 601
trip reduction, if actually drawn solely from the project's 1305 pm peak commercial trips, would
comprise a 46 percent reduction in that pm peak commercial trip component.
v
~
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 5
~NT.
disclose that the impacts of the project on freeway operations are probably unmitigated significant "'~..~
adverse impacts. -
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7. The traffic analysis in the subject document uses as the predominant basis for forecasts of
future background traffic in the project impact area the forecasts contained in the East of 101
Area Plan Environmental Impact Report (Brady & Associates and associated consultants, 1994).
Traffic forecasts in this reference document were significantly understated. Because the ~l"&
background traffic forecasts are significantly understated, capacity utilization and level of service ? ;V -. ..;.. '
computations at key intersections, freeway ramps and freeway segments are probably understated
and there is a consequent probability of failure to identify significant traffic impacts of the
project and related mitigation requirements. Tbe traffic analysis should be recomputed using
appropriate adjustment to background traffic estimated from the East of 101 Area Plan
Environmental Impact Report and all traffic capacity utilizationllevel of service assessments and
impact assessments and mitigation analyses based thereupon should be recomputed.
-
A. Changes Affecting Transoortation Demand Management/Average Vehicle Ridershio Assumotions~
In the East Of 101 Area Plan EIR, it was assumed that imposition of Bay Area Air Quality
Management District (BAAQMD) Regulation 13, Rule I, (which mandated an Average Vehicle
Ridership of 1.35 by 1999 compared to the present observed 1.18 Average Vehicle Ridership for the
area) would result in a 25 percent reduction in the nonnal trip generation for trips from/to the
Highway 101 corridor and a 20 percent reduction in trips from/to the west locally and along the 1-380
corridor. However. during the period of preparation of the subject T errabay EIR, as the result of state
legislative action, Regulation 13, Rule 1 was invalidated. Hence, there was no longer any basis for ~ A...I!::'
the 20 to 25 percent reduction in East Of 101 Area Plan traffic which had been assumed earlier. ,~Z77'
Preparers of the current EIR did not make any adjustments to take account of this fundamental change'
in conditions from the assumptions of the primary source document. An understatement of 20 to 25
percent in the traffic from the East Of 101 Area would have enormous consequences in the analysis
of the Terrabay project's impacts and mitigations, particularly at the key intersections and freeway
ramps along the Highway 101 corridor. The entire analysis should be recomputed with the
background volumes from the East of 101 Area Plan EIR adjusted to reflect the invalidation of
BAAQMD Regulation 13. Given the change in the law, the Terrabay SEIR should not rely upon the
high vehicle ridership estimated in the East Of 101 Area Plan unless there is evidence that such high
levels exist. ~
-
..-"'!:
B. Excessive Reduction of Traffic Assumed Due To Use Of Mass Transit
A further flaw in the traffic projections that has the effect of significantly understating background '3 J ~
traffic from the East Of 101 Area Plan (hence possible understatement of Terrabay project and .
cumulative impacts) is the traffic reduction assumed on the presumption of transit ridership. After
computing traffic generation in a normal way, authors of the East of 101 EIR assumed a blanket 5
percent reduction claimed to adjust for transit ridership to the area (East Of 101 Area Plan EIR, page
"
CA?NT.
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 6
&#NT:
193). Yet the trip generation rates originally used are ones which are characteristic of auto tripmaking
in suburban office and industrial parks and mixed use developments. While it would be reasonable
and expected to adjust these rates to reflect high transit use in a dense downtown or special transit ;l ~
hub, such a blanket adjustment in an area of the planned character East of 101 is highly questionable. .
The Tefrabay SEIR should not have continued to assume this 5 percent reduction in background traffic
generation from the East Of 101 Area. _
-
8. In the cumulative impact analysis of the full Terrabay Project, the DSEIR preparers use base
year 2010, a year far more distant than the stated expected bulldout date of the proposed
Terrabay project, 2004 (Terrabay DSEIR, P61). Inclusion of an analysis year at or reasonably
close to the expected bulldout date of the subject project provides a more reasonable basis for
understanding the actual impacts of the project, conditioning specific mitigation and its timing
and determining reasonable "fair share" contributions to cumulative mitigations. The DSEIR
transportation section should include a complete analysis on a base year of 2004 or some
reasonably close post-buildout year (say 2005).
Use of a forecast year far beyond the subject project's expected buildout date can have three
misleading effects which are contrary to the purposes of the enviromnentaI review process. First, use
of a far distant forecast year may make the subject project's contribution to mitigation need seem a
modest increment to mitigation need caused by cumulative development when in fact it is the early
maturing subject project which will cause conditions to cross the threshold where mitigation becomes
needed.
A case in point is the AM peak analysis of the intersection of Airport, Bayshore. Oyster Point and
Sister Cities Boulevards. In the DSEIR year 2010 analysis for this intersection it appears that
Terrabay just makes a bad situation worse, taking conditions from an already unacceptable Level of
Service (LOS) F-1.11 to LOS F-1.37. However, had the analysis been perfonned for year 2004, the
year Terrabay is expected to be built out, interpolation from the baseline forecast projections contained
on Table 16 (page 127) indicates year 2004 baseline conditions of LOS E-.87. Adding in the Terrabay
traffic contribution, the condition changes to LOS F-l.13. So it is actually the Terrabay project which
pushes this location over the threshold where mitigation becomes crucially warranted, contrary to the
impression given in the DSEIR that is just an additive factor to a situation that already needs
mitigation due to other events.
~~7
The second flaw in a far distant cumulative analysis forecast year is that it can appear that the project's
impacts will be rendered insignificant by implementation of cumulative mitigation measures when
those mitigation measures are in fact contingent on the less certain development of other projects at
a far more distant date. This means Terrabay's traffic impacts could go umnitigated for many years
or may never be mitigated if the other development projects do not take place as expected.
Third, if the project's "fair share" contributions to mitigations are determined by computing the
percentage its traffic constitutes in relation to the total traffic expected to be generated by development
over a far more distant future, the apparent "fair share" allocated to Terrabay will be far less than if
fair shares were computed by proportionate traffic contributions among those developments that create
V
a>NT.
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 7
e1NT.
an immediate mitigation need. Both of these flws would be avoided by including in the DSEIR el..:
transportation section a complete analysis at the project's buildout date (2004) or a year relatively soon ~.-u 7
thereafter (say 2(05). _
-
9. The DSEIR poses two alternative options for mitigating cumulative conditions at the
intersection of Airport, Bayshore, Oyster Point and Sister Cities Boulevards, a surface
intersection improvement and a "flyover" construction. However, the surface intersection
improvement is of doubtful operational functionality and questionable physical feasibility. The
DSEIR should identify the "flyover" as the sole appropriate mitigation treatment at this location.
The proposed surface intersection mitigation alternative for the intersection of Airport, Bayshore,
Oyster Point and Sister Cities Boulevards (for Supplemental Impact T-7) involves adding a third left
turn lane on the southbound approach of Bayshore Boulevard and an additional lane on the westbound
approach of Oyster Point Boulevard. This would bring the total number of southbound approach lanes
on Bayshore to six, the westbound approach lanes on Oyster Point to five while the eastbound
approach of Sister Cities and the northbound approach on Airport would remain at five and four
respectively.
Theoretical capacity/level of service calculations such as offered in the DSEIR may indicate
satisfactory conditions on such multi-laned configurations as this proposal. However, for actual
functional performance to come even close to the theoretical calculations at very complex intersections
involving this extraordinary number and complex configuration of approach lanes, the intersection and
the transitions to its approaches from upstream midblock segments must be constructed to ideal
geometric design properties. Triple left turn lanes require extraordinary geometric features to have
anL.kac~al o.peratio~l funcht~onah lity thapproanflching thatf reflectd~ in the thbeoreticaf I capacityh lcalculatiohns. ~~.~
I eWIse, mtersecuons w IC are e co uence 0 extror mary num ers 0 approac anes suc as
in this proposal require extraordinary geometric features to have an actual operational functionality
corresponding to the theoretical capacity/level of service calculations. This is especially true when
opposed approaches have an imbalance of lanes and asynmetry of lane configuration as is evident in
the 6 lane southbound, 4 lane northbound approaches in the subject mitigation proposal. Moreover,
when extraordinary numbers of lanes and ideal geometric features are necessary to gain functionality,
there is a high probability that the proposal will not fit within the confines of available right ot way
and structures (note that the freeway and crossing structure on Oyster Point may impose structural
limitations on feasibility).
In all probability the proposed intersection would not have an operational functionality nearly so
satisfactory as indicated in the theoretical capacityllevel of service computation the DSEIR presents
for the mitigation proposal. The DSEIR should demonstrate that it can indeed be constructed with
ideal geometric features and demonstrate that it will fit within the right-of-way and structural
constraints of the site. To so demonstrate, it is necessary to provide a scale geometric drawing of the
proposal including the full transitions from midblock to intersection approach configurations. The
"stick-diagrams" of lane configuration (such as Figures 21 and 25) are a completely inadequate basis
to demonstrate that the subject proposal for surface intersection improvements is operationally
.....-1
uJINT.
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 8
tdNr.
functional and feasible within right-of-way and structural constraints. Absent such a demonstration,
the DSEIR must conclude that the "flyover" proposal is the only suitable mitigation for this location.
;;.~
We note that the DSEIR also proposes a triple left turn lane at the intersection of Commercial Access
and Bayshore Boulevard to mitigate project traffic impact. For the same reasons as stated above, the
DSEIR should present scale engineering concept drawings to demonstrate that suitable intersection and
approach geometries can be developed and will fit on this site. _
-
10. The DSEIR's criterion for determining significant impact where baseline conditions already
exceed acceptable standards is not a generally accepted one as is implied in the DSEIR, is
considerably more lenient than the criterion used in some other communities and does Dot ·
provide reasonable separation between conditions that are "insignificant" and those that are
"significant" .
The DSEIR postulates as a criterion of impact significance where baseline conditions already exceed
acceptable nonos, the threshold of a project traffic contribution of 2 percent or more of base case
traffic. The DSEIR states that in the absence of any official significance standards adopted by the City
or the County Congestion Management Agency, the 2 percent threshold was postulated by the authors
because "a 2 percent increase is commonly considered by professional transportation planners as
noticeable to most drivers, whereas anything less than two percent would typically not be noticeable. "
//
Weare unaware of any authorative traffic and transportation engineering reference source which
suggests use of the 2 percent threshold in this manner or even documents that 2 percent is a threshold
ofnoticeability by drivers under such conditions. However, we are aware of many diverse and widely
separated communities that have adopted more rigorous criteria for these situations, such as, to cite
two communities where we have recently performed work, Santa Monica where a .005 LOS change
is considered significant or Corte Madera where a .01 LOS change is considered significant.
~.~
The lack of reasonableness of the criterion posited by the DSEIR is quite evident. It sets the
significance criterion at the noticeability level. If a condition or event is to be regarded as truly
insignificant, the threshold separating significance from insignificance should be set so that it takes
more than just a tiny variance, just a tiny understatement in estimate or just one unforseen and equally
insignificant event to constitute something that far surpasses a threshold of noticeability. There should
be a built-in tolerance for some reasonable margin of variance or error so that if estimates slightly
understate project traffic or fail to anticipate some other project making an equally small traffic
contribution, the threshold of noticeability will probably still not be exceeded. In this particular
instance, if the threshold of driver noticeability truly is 2 percent, the significance criterion threshold
should be set at I percent (that is, to be insignificant project traffic must not exceed 0.99 percent) so
that it takes more than one other equally insignificant event to exceed the noticeability threshold. We
suggest that the DSEIR authors subject this significance criterion to a more thoroughgoing assessment
and then reassess the project's impacts based on the revised criterion that results.
-'
Ann Broadwell
Lizanne Reynolds
March 18, 1996
Page 9
These conclude my comments on the transportation section of the DSEIR and the implications of the
primary source document from which it draws its background traffic projections. I will be pleased
to discuss these comments at your convenience.
Sincerely,
SMITH Engineering & Management
A California Co ion
kct<i
Daniel T. Smith, Jr. P.E.
President
S :\1 1 THE ~ (~ ] ~ E E R. ] ~ C -:.- \1:\ ~ ACE \1 E ;-...: T
s
DANIEL T. SMITH, Jr.
Principal
EDUCATION
Bachelor of Science, Engineering and Applied Science, Yale University, 1967
Master of Science, Transportation Planning, University of California, Berkeley, 1968
PROFESSIONAL REGISTRATION
California No. 21913 (Civil)
California No. 938 (Traffic)
Nevada No. 7969 (Civil) Washington No. 29337 (Civil)
Arizona No. 22131 (Traffic)
PROFESSIONAL EXPERIENCE
Smith Engineering & Management, 1993 to present. President.
DKS Associates, 1979 to 1993. Founder, Vice President, Principal Transportation Engineer.
De Leuw,Cather & Company, 1968 to 1979. Senior Transportation Planner.
Personal specialties and project experience include:
Urban Corridor Studies/Alternatives Analysis. Principal-in-charge for State Route (SR) 102 Feasibility Study,
a 35-mile freeway alignment study north of Sacramento. Consultant on 1-280 Interstate Transfer Concept Program,
San Francisco, an AAlEIS for completion of 1-280, demolition of Embarcadero freeway, substitute light rail and
commuter rail projects and TSM strategies. Principal-in-charge, SR 238 corridor freeway/expressway
design/environmental study, Hayward (Calif.) Project manager, Sacramento Northeast Area multi-modal transportation
corridor study. Transportation planner for I-80N West Tenninal Study, and Harbor Drive Traffic Study, Portland,
Oregon. Project manager for design of surface segment of Woodward Corridor LRT, Detroit, Michigan. Directed
staff on 1-80 National Strategic Corridor Study (Sacramento-San Francisco), US IOI-Sonoma freeway operations
study, SR 92 freeway operations study, 1-880 freeway operations study, SR 152 alignment studies, Sacramento RTD
light rail systems study, Tasman Corridor LRT AA/EIS, Fremont-Warm Springs BART extension plan/EIR, SRs 70/99
freeway alternatives study, and Richmond Parkway (SR 93) design study.
Area Transportation Plans. Principal-in charge for transportation element of City of Los Angeles General Plan
Framework, a program to shape nations largest city two decades into 21'st century. Project manager for the
transportation element of 300-acre Mission Bay development in downtown San Francisco. Mission Ray involve~
7 million gsf office:commercial space, 8,500 dwelling units, and community facilities. Transportation features include
relocation of commuter rail station; extension of MUNI-Metro LRT; a multi-modal tenninal for LRT, commuter rail
and local bus; removal of a quarter mile elevated freeway; replacement by new ramps and a boulevard; an internal
roadway network overcoming constraints imposed by an internal tidal basin; freeway structures and rail facilities; and
concept plans for 20,000 structured parking spaces. Principal-in-charge for circulation plan to accommodate 9 million
gsf of office/commercial growth in downtown Bellevue (Wash.). Principal-in-charge for 64 acre, 2 million gsf multi-
use complex for FMC adjacent to San Jose International Airport. Project manager for transportation element of
Sacramento Capitol Area Plan for the state governmental complex, and for Downtown Sacramento Redevelopment
Plan. Project manager for Napa (Calif.) General Plan Circulation Element and Downtown Riverfront Redevelopment
Plan, on parking program for downtown Walnut Creek, on downtown transportation plan for San Mateo and
redevelopment plan for downtown Mountain View (Calif.), for traffic circulation and safety plans for California cities
of Davis, Pleasant Hill and Hayward, and for Salem, Oregon. Projects involved traffic and parking surveys, travel
forecasts, modal split evaluation, regional and local transportation network assessment, freeway corridor location,
traffic operations evaluations and circulation plan improvements.
Special Event Facilities. Evaluations and design studies for footballlbaseball stadiums, indoor sports arenas, horse
and motor racing facilities, theme parks, fairgrounds lnd convention centers, ski complexes and destination resorts
throughout western United States.
I t-: ., I ! : t . T R .~ ~. " ;' '\' ~ ! ....: : \.'" . .\~,:".\ li !. \1 !'. ~ ;
5:~:: L,)\\"r'." Rl).1...~. l'IlI\'il Clt\". C:\ ~)-4-S~- tl'l: .'!\:~~..1"L;.-- f.i\: ~Il'l,";';,")."')";-~
Daniel T. Smith, Jr, / page 2
Transportation Centers. Project manager for Daly City Intennodal Study which developed a $7 million surface bus
tenninal, traffic access, parking and pedestrian circulation improvements at the Daly City BART station (including
successful negotiation for a state TCI grant to fund the improvements) plus development of functional plans for a new
BART station at Colma. Project manager for design of multi-modal tenninal (commuter rail, light rail, bus) at
Mission Bay, San Francisco.
Campus Transportation. Campus transportation planning assignments for UC Davis, UC Berkeley, UC Santa Cruz
and UC San Francisco Medical Center campuses; San Francisco State University; University of San Francisco; and
the University of Alaska and others. Also developed master plans for institutional campuses including medical centers,
headquarters complexes and research & development facilities.
Transportation System Management & Traffic Restraint. Project manager on FHW A program to develop
techniques and guidelines for neighborhood street traffic limitation. Project manager for Berkeley, (Calif.),
Neighborhood Traffic Study, which pioneered application of traffic restraint techniques in the U.S. Developed
residential traffic plans for Santa Cruz, Mill Valley, Oakland, Palo Alto, Piedmont, San Mateo County, Pasadena,
Santa Ana and others. Participated in development of photo/radar speed enforcement device. Co-author of Institute
of Transportation Engineers reference publication on neighborhood traffic control.
Parking. Prepared parking programs and facilities for large area plans and individual sites; also,resident preferential
parking programs.
Bicycle Facilities. Project manager to develop an FHW A manual for pi cycle facility design and planning. Project
manager on bikeway plans for Del Mar, (Calif.), the UC Davis and the City of Davis. Consultant to bikeway plans
for Eugene, Oregon, Washington, D.C., Buffalo, New York, and Skokie, lllinois. Consultant to U.S. Bureau of
Reclamation for development of hydraulically efficient, bicycle safe drainage inlets. Consultant on FHW A research
on effective retrofits of undercrossing and overcrossing structures for bicyclists, pedestrians, and handicapped.
Utigation Consulting. Provides consultation, investigations and expert witness testimony in highway design, transit
design and traffic engineering matters including condemnations involving transportation access issues; traffic accidents
involving highway design or traffic engineering factors; land use and development matters involving access and
transportation impacts; parking and other traffic and transportation matters.
MEMBERSHIPS
Institute of Transportation Engineers
Transportation Research Board
PUBLICA nONS AND AWARDS
Residential Street Design and Traffic Control, with W. Honnburger et af. Prentice Hall, 1989.
Co-recipient, Progressive Architecture Citation, Mission Bay Master Plan, with I.M. Pei WRT Associated, 1984.
Residential Traffic Management. State of the- Art Report, U.S. Department of Transportation, 1979.
Improving The Residential Street Environment, with Donald Appleyard et aI., U.S. Department of Transportation,
1979.
Strategic Concepts in Residential Neighborhood Traffic Control, International Symposium on Traffic Control Systems,
Berkeley, California, 1979.
Planning and Design of Bicycle Facilities: Pitfalls and New Directions, Transportation Research Board, Research
Record 570, 1976.
Co-recipient, Progressive Architecture A ward, Livable Urban Streets, San Francisco Bay Area and London, with
Donald Appleyard, 1979.
RJ294
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 267
33. Ann Broadwell, Adams & Broadwell: March 20,1996
33.01 The project applicant is requesting a ten-year extension of the termination dates of the
specific plan and development agreement from the present termination date of
February 14, 1997 to the proposed date of February 14, 2007.
33.02 The comment does not pertain to the adequacy of the SEIR; no response is necessary
and no revisions to the SEIR are warranted.
33.03 The Terrabav Specific Plan, which was adopted in 1982, and the subsequent
development agreement, provide for development of up to 745 homes, including up to
181 townhomes in Terrabay Village and 136 single-family detached homes in Terrabay
Park. The Phase I Precise Plan approved in 1989 allows up to 168 town homes in
Terrabay Village and 125 single-family detached homes in Terrabay Park. The
proposed extension of the termination date would not amend the total number of units
provided for in the specific plan and development agreement (745). However, the
Phase I Precise Plan reduction in the number of units provided for in the specific plan
and development agreement changes the total number of units that could be
constructed at full buildout of the project from 745 to 721. Therefore, the DSEIR
analyzes the impacts of project buildout of 721 homes.
33.04 Please see response to comment 30.01. A recently conducted AM peak period traffic
count at the Oyster Point Boulevard/Dubuque Avenue intersection (while the Grand
Avenue interchange US 101 northbound on-ramp was closed) showed volume levels
similar to those projected for year 2000 Base Case conditions in the DSEIR. These
minor increases were attributed to probable diversion of traffic from the Grand Avenue
interchange to the south. Recently conducted PM peak hour counts at the Oyster
Point interchange and along Hillside Boulevard during times when the on-ramp at
Grand Avenue was open did, however, show somewhat higher volumes for selected
movements than were projected for year 2000 Base Case conditions in the DSEIR.
For this reason, year 2000 PM peak Base Case and Base Case plus project
projections have been adjusted and recalculated. The revised 2000 traffic volumes
have not resulted in any additional impacts from Phase I of the Terrabay project.
However, unacceptable 2000 Base Case PM peak hour freeway operation is
anticipated on all segments near the project with one exception: the segment from
Sierra Point to Oyster Point would be in the acceptable LOS E range.
33.05 Figure 5 on DSEIR p. 67, "Existing Land Uses" does clearly convey the local land use
pattern and identify key areas of land use described in the text.
33.06 The DSEIR established a 2 percent increase in traffic volume as the standard for
determining the significance of project impacts on the intersections or roadways
operating at unacceptable levels of service without the project. The standard is based
on the professional opinion and experience of the traffic consultant and other
professional transportation planners, including City staff. The standard of significance
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 268
was established because it identifies the point at which incremental increases in traffic
volumes are likely to result in a perceptible change in traffic congestion noticeable to
most drivers. The establishment of a standard of significance for evaluating the
impacts of projects on intersections already operation at unacceptable levels of service,
is permitted under CEOA. (Citizens Action to Serve All Students v. Thornley, 1990,
22 Cal.App.3d 748, 755-756; standard of significance of 10 percent increase in delay
at the deficient intersection is valid.) (Schaeffer Land Trust v. San Jose City Council,
1989, 215 Cal.App.3d 612, 623-625; standard of significance of increase in traffic
volume by one or more percent at intersections operating at LOS E or LOS F is valid).
The comment suggests that this two percent criterion is not stringent enough and that,
at locations already experiencing unacceptable operation without the project, any
project-related increase in traffic should be considered significant. In response to this
comment, 25 Bay Area cities, counties and congestion management agencies were
surveyed for the traffic impact significance criteria they use in preparing planning and
CEOA environmental documents where a facility is projected to already experience
unacceptable operation without the addition of project traffic. None of the jurisdictions
surveyed use VIC ratio impact criteria for freeway ramp, freeway main line segment, or
unsignalized intersection operation, or for intersection signal warrant analysis. A few of
the jurisdictions surveyed have adopted criteria for signalized intersections: both the
Town of Corte Madera and the City of Mountain View use a change in VIC ratio of .01
(it should be noted that the two percent addition in traffic used as the significance
threshold in the DSEIR traffic analysis would typically result in an approximately .01
change in the VIC ratio at a signalized intersection, which is the strictest significance
standard used in any of the surveyed communities except for one city); other
jurisdictions vary the threshold depending on the project and its location. Surveyed
jurisdictions that have segments of a congestion management program (CMP) freeway
network within their boundaries typically specify a minimum acceptable freeway ramp
intersection operation the same as that of the associated freeway link. Although the
1995 San Mateo County Congestion Management Program specifies a minimum
acceptable operation for US 101 through South San Francisco of LOS E, all ramp
intersections at the Oyster Point interchange have been evaluated in this EIR using the
city's more stringent criterion of LOS D.
33.07 The DSEIR provides year 2000 information about the US 101 southbound off-ramp to
Bayshore Boulevard in Tables 10 and 18 (DSEIR pp. 109 and 131, respectively). The
off-ramp is projected to be operating well under capacity during the AM and PM peak
hours. Potential back-ups on the ramp to the freeway main line during the AM peak
hour would be due primarily to the operation of the US 101 southbound off-rampl
northbound Bayshore Boulevard intersection and not the off-ramp leading to the
intersection. The potential back-up of off-ramp traffic to the freeway main line is
considered as part of the significant impact identified under the finding of unacceptable
operation of the US 101 southbound off-ramp/northbound Bayshore Boulevard
intersection (Supplemental Impact T-2).
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City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 269
33.08 The DSEIR (p. 62) states that city of Brisbane approval would be required for
implementation of any mitigations for traffic impacts involving Bayshore Boulevard,
which is within the Brisbane city limits. The comment correctly notes that, in addition
to these recommended mitigations, some components of the project itself (e.g., the left
turn from northbound Bayshore Boulevard into the commercial area or realignment of
Bayshore Boulevard onto the project property to accommodate the new US 101 hook
ramps) would require city of Brisbane approval. The SEIR has been revised
accordingly. (See errata to DSEIR p. 62 in section III herein.)
33.09 The US 101 hook ramps at Bayshore Boulevard are to be constructed by the project
applicant/developer as part of subsequent project Phase III. The applicant/developer is
responsible for the full cost of the hook ramps; nowhere does the DSEIR discuss fair-
share cost apportionment for the hook ramps. The comment appears to refer to
Supplemental Impact T-2, pertaining to unacceptable operation of the US 101
southbound off-ramp/northbound Bayshore Boulevard intersection with year 2000 Base
Case plus proiect Phase I traffic. The DSEIR recommends a project Phase I fair-share
contribution towards the needed signalization of this intersection as mitigation for
Supplemental Impact T-2. The hook ramps to be constructed by the applicant/
developer as part of the project were assumed to be in place for purposes of the
DSEIR traffic analysis for year 2010 Base Case plus project Phases I, II and III.
33.10 The recommended mitigations are appropriate for the program EIR-Ievel assessment
provided in the SEIR for subsequent project phases II and III. When Phases II and III
are to be developed and eventually come before the city for required precise plan
approval in the future, more specific development plans would be submitted and more
detailed environmental review would be undertaken at that time (see paragraph one of
response to comment 1.02). Subsequent traffic analyses would consider the detailed
project development plans and up-to-date area traffic counts and projections to more
accurately determine Phase II and Phase III traffic impacts and mitigation needs. The
subsequent traffic analyses, mitigation recommendations and mitigation cost
apportionments would be able to account for the possibility of any currently anticipated
development in the area that may not proceed as planned. Also, if currently
anticipated projects do not proceed as planned, then there would be an expected
corresponding reduction in the magnitude of traffic impacts and the extent and cost of
needed mitigations.
33.11 The comment suggests that the DSEIR should discuss the feasibility of recommended
traffic mitigation measures; for example, the flyover off-ramp from southbound US 101
to eastbound Oyster Point Boulevard. The city may make findings on the feasibility of
recommended mitigations at the time of SEIR certification. With respect to the
southbound flyover off-ramp, the flyover off-ramp was considered as part of the Oyster
Point Interchanqe Reconstruction EIR prepared and certified by Caltrans.
33.12 The DSEIR discussions of cumulative impacts, including cumulative (Le., Base Case
plus project) traffic impacts, are based on land use projections and, in turn, traffic
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 270
volume projections in the East of 101 Area Plan and the Brisbane General Plan
Circulation Element. These documents describe in detail the projections on which the
DSEIR cumulative impact analyses are based. The DSEIR cumulative analysis
projections are based in part on land use projections for the East of 101 Area Plan's
Directed Growth Alternative. The land use allocations of the Directed Growth
Alternative at buildout are presented by Table 5 in the East of 101 Area Plan EIR,
which has been reproduced in Appendix B herein. Appendix B also presents Table
PD-7 of the Brisbane General Plan, which presents different land use alternatives for
different subareas of the city. The DSEIR cumulative analysis projections are also
based on the Brisbane General Plan's Scenario K development, which combines the
land use alternatives with the highest development intensity for the different subareas
presented in Table PD-7.
33.13 The comment states that the SEIR should consider landslides and erosional gullies as
significant impacts, recommend mitigations, and evaluate the feasibility of having
homeowners pay for geotechnical repair and maintenance. Please see responses to
comments 33.64,33.65 and 33.70, and DSEIR errata pp. 169-172 in section III herein.
Please also see response to comment 1.13 and DSEIR pp. 164-166 for information
pertaining to earthquakes and fault zones on the project site. With respect to the
adequacy of information about the performance of the South Slope area during the
1989 Loma Prieta earthquake (footnote 4 on p. 4), the various grading reports
completed for the project since 1989 (PSC, 1990; PSC, 1991; PC, 1995(a); PSC,
1995(b); Leighton & Associates, 1992; Geo/Resource Consultants, 1995(a); and Geo/
Resource Consultants, 1995(b)) inherently and adequately took into account the effects
of the quake on the South Slope and other areas of the site.
33.14 All necessary municipal storm drainage improvements for Phase I of the project have
been completed. The on-site drainage improvements for Phase II and Phase III have
not been completed. DSEIR Section IV.E, Drainage and Water Quality (pp. 173-182),
discusses post-1982 storm drainage improvements.
In response to comments concerning the adequacy of the catchment basins in Phase I,
the City geotechnical consultant, Eric McHuron, conducted an extensive review of the
studies and records pertaining to the sizing and capacity of the catchment basins. The
results of this review were presented to City staff. On the basis of that review, the City
determined that the catchment basins for Phase I are adequately sized and properly
designed.
The applicant ("SunChaselO) has also indicated that the issue of catchment basin and
drainage ditch malfunctioning has already been addressed (please see comment
32.04):
"Sun Chase removed all the silt and debris from the v-ditches, catch basins, and
storm drains in the project area in the fall of 1995 prior to the rainy season.
Sun Chase also removed and replaced all of the rock and fabric filters in each
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 271
basin to ensure a dependable flow, The brush alongside the v-ditches was cut.
During the recent heavy rains, representatives of SunChase observed the
operation of the v-ditches, catch basins and storm drains and they were performing
very well. The rains, and particularly the violent storms of December, 1995, have
resulted in some silt and debris in the v-ditches. Sun Chase will continue to
monitor and clean these ditches on an as-needed basis... Sun Chase is in the
process of implementing an on-going funding and responsibility program to
maintain erosion and sedimentation control facilities after the project is built."
33.15 Please see response to comment 24.01.
33.16 The DSE IR (p. 184) notes that the ravines traversing the portion of the property that is
to be dedicated to San Mateo County as permanent open space (Le., HCP
Administrative Parcel 2-04-02) create a variety of microclimates favorable for the
growth of plants requiring greater moisture. Riparian vegetation is also found in some
of the project catchment basins which were installed at the base of the ravines above
the Phase I development area. The SEIR biological consultant has noted that no
jurisdictional wetlands exist within areas of project Phases I and " that are to be
developed. However, jurisdictional wetlands may exist within, areas of Phase III that
are to be developed. The EIR biologist has observed that during wet years water
collects in the flat portion of the site near Bayshore Boulevard and it appears to be a
"wetland." However, they have not conducted any formal wetland delineations of this
area. They suggest that detailed surveys of this area be undertaken as part of future
development processing.
Under Section 404 of the federal Clean Water Act, the U.S. Army Corps of Engineers
administers a program to regulate discharges of fill into "waters of the United States,"
including wetlands. Under Section 401 of the act, the state Regional Water Quality
Control Board must 'certify that the permit issued by the Army Corps pursuant to
Section 404 complies with state water quality standards. A jurisdictional wetland
delineation and, if warranted, compliance with all Section 404 and 401 permit
procedures, will be required as part of subsequent detailed environmental review
conducted when Phase III is to be developed and eventually comes before the city for
required precise plan approval in the future. (Please also see paragraph one of
response to comment 1.02.)
33.17 Please see response to comment 33.16.
33.18 The response to comment 33.16 above explains the potential presence of jurisdictional
wetlands in Phase III and thus the potential applicability of the wetlands provisions of
Sections 404 and 401 of the federal Clean Water Act. The EIR biologist has observed
that during wet years water collects in the flat portion of the site near Bayshore
Boulevard and it appears to be a "wetland." However, they have not conducted any
formal wetland delineations of this area. They suggest that detailed surveys of this
area be undertaken as part of future development processing.
WP511548\FSEIR\F-/I.548
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 272
In addition, under Fish and Game Code Sections 1601-1603, the California Department
of Fish and Game (CDFG) may have jurisdiction over any proposed activities involving
riparian-like areas in Phase III and the execution of a Streambed Alteration Agreement
between the CDFG and the project applicant may also be required. A jurisdictional
wetland delineation and, if warranted, compliance with all Section 404 and 401
procedures and execution of a Streambed Alteration Agreement with the CDFG in
accordance with Sections 1601-1603 of the state Fish and Game Code, will be
required as part of subsequent detailed environmental review conducted when Phase
III is to be developed and eventually comes before the city for required precise plan
approval in the future.
33.19 Please see response to comment 7.01.
33.20 The schools impact analyses on DSEIR pp. 209-213 are based on information
provided by the districts regarding current enrollment and facilities, the numbers of
students generated by the project based on the districts' own generation factors,
school impact fees, additional facilities and improvements needed to accommodate
students from the project, and the costs of those facilities. An extended analysis of
school impacts beyond 1999-2000 is implicit in the districts' estimates of the numbers
of students that would be generated by the project that were used for the SEIR. For
example, the SSFUSD noted that:
"Initially, we would expect a student yield of .21 students per unit from the
Terrabay development. As these units age, we expect student yields to increase
to .53 students per unit. This means the district should initially expect only 104
students from the Terrabay development. In the long run, however, the district
should be prepared to serve 261 students from the development (.53 yield *493
units). "
In addition, the districts' assessments and the SEIR considered one-time physical
improvements that would be needed to accommodate students from the project into
the future. Potential project impacts on ongoing district operational costs over time
were not considered. This is consistent with the CEQA Guidelines (Section 15382)
which states that ':4n economic or social change by itself shall not be considered a
significant effect on the environment. A social or economic change [Le., a project-
generated enrollment increase] related to a physical change [Le., school facilities
construction to accommodate the increase enrollment] may be considered in
determining whether the physical change is significant. "
Also, a precise plan must be approved before Phase II of the project may be built.
Although the anticipated uses and densities are generally described in the specific
plan, the actual number of homes to be built will not be known until a precise plan is
approved. When Phase 1/ is to be developed and eventually comes before the city for
required precise plan approval in the future, more specific project information, updated
district student generation factors, and current information about the available capacity
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and improvement needs of district facilities can be considered as part of the more
detailed environmental review that will be undertaken at that time (see paragraph one
in response to comment 1.02).
33.21 Please see response to comment 2.03.
33.22 Approximately 493 homes would be located within the South San Francisco Unified
School District (SSFUSD): 168 in Terrabay Village, 125 in Terrabay Park, and 200 in
Terrabay Woods. Applying the district's generation factor of 0.53 students per unit
yields 261 students (0.53 x 493 = 261). The SSFUSD assumed an impact fee of $1.50
per square foot of residential development and the following average unit sizes: 1,800
square feet in Terrabay Village, 2,500 square feet in Terrabay Park, and 1,500 square
feet in Terrabay Woods.
The Brisbane School District calculated that, assuming 228 homes within the district
and one child per household randomly divided among ages zero to 21, approximately
10 students at each grade level or a total of 90 students would be added to the district.
Impact fees accruing to the Brisbane School District were calculated assuming an
impact fee of $0.90 per square foot of residential development and 228 units of an
average size of approximately 1,200 square feet.
Approximately 228 homes would be located within the Jefferson Union High School
District (JUHSD): 129 in Terrabay Commons and 99 in Terrabay Point. Applying the
district's generation factors of 0.08 students per unit for the terraced units in Terrabay
Commons and 0.10 students per unit for the condominium units in Terrabay Point
yields 20 students. The JUHSD assumed an impact fee of $0.60 per square foot of
residential development, 228 units and an average unit size of 1,200 square feet.
However, the school impact fees accruing from the project, as calculated by SSFUSD
and BSD, appear to have been underestimated because the estimated size of the
residential units used is smaller than the units actually being built. Thus, the fees paid
by the project may be sufficient to cover the districts' estimated costs.
Please also see response to comment 33.20.
33.23 The mitigation recommended in the SEIR has already been successfully implemented.
The applicant has conducted a thorough inspection of the on-site sewer system by
both television inspection and visual inspection by removal of manhole covers. The
visual inspection was performed under the supervision of representatives of the City of
South San Francisco Department of Public Works, According to the applicant, the
inspections did not reveal any problems with the on-site sewer system that would
cause excessive infiltration.
The city has conducted its own inspections of off-site sewer system improvements
installed as part of the project and has determined the source of observable flows.
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(Observable flows are caused by an allowable amount of groundwater infiltration and
by Fire Station 5, which is connected to the system.) The city has accepted all off-site
sewer system improvements and all on-site sewer improvements within public roadway
rights-of-way that were required to be dedicated to the city.
33.24 The SEIR has been revised to indicate that the project site is located within the
California Water Service Company (CWSC) service area. As explained on DSEIR p.
211, the CWSC has delivered a letter of assurance to the city that commits CWSC to
providing water service to the project. All needed water system improvements are in
place to serve the Phase I portion ofthe project except for the water pump station.
The remaining water system improvements are anticipated to proceed as originally
planned for the project.
33.25 Mitigation recommended for traffic noise impacts (Supplemental Impact N-1) on DSEIR
p. 228 requires the project applicant to retain a qualified acoustical engineer to prepare
and submit for city review and approval a detailed acoustical analysis of noise
reduction requirements and specifications for all project phases, as called for in the
Noise Element of the South San Francisco General Plan. The required acoustical
analyses will be completed prior to issuance of occupancy permits for Phase I homes,
consistent with condition #46 of the Terrabay Specific Plan Amendments which states
that, "Residential structures within the Specific Plan area shall be designed to assure
that interior noise levels do not exceed a Community Noise Equivalent Level (CNEL) of
40 dBA and maximum noise levels of 60 dBA. Said residential structures shall also be
so designed and constructed as to mitigate or suppress structural vibrations that are
harmonically responsive to low pitch noise emanating from aircraft climbing over San
Bruno Mountain on a northeast to southwest heading and emanating from aircraft
spooling up their engines for takeoff from Runway 10."
The regional acoustical analyses for subsequent phases will be completed as part of
subsequent environmental review that will be undertaken when the required precise
plans for Phases II and III eventually come before the city for approval.
Such acoustical analyses are common practice for developments in urban areas.
Common noise attenuation measures, including the construction of berms or
soundwalls and/or provision of fresh air supply systems or air conditioning and use of
sound-rated glazing in windows, would reduce noise levels on the project site to within
the land use/noise compatibility standards established by the state and set forth in the
Noise Element. Thus, there is reasonable assurance that the impact would be
mitigated to a less-than-significant level. Moreover, detailed acoustical analyses for
Phases II and III of the project would be inappropriate at this time because the specific
development plans for these subsequent phases have not yet been determined (see
paragraph one of response to comment 1.02).
33.26 The comment notes that the DSEIR (p. 222) is technically incorrect in identifying 1990
traffic volumes as current volumes. The SEIR has been revised to refer to 1990
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volumes. The use of 1990 information from the city's Noise Element is adequate and
appropriate because the projected traffic volumes in the FSEIR traffic and noise
analyses are within the range evaluated for the 1990 Noise Element. As explained in
the Noise Element and discussed in the DSEIR (pp. 222-225), traffic noise levels on
the project site are not expected to change substantially. Also, increases in traffic
levels are expected to be offset at least in part by replacement of current vehicles with
quieter vehicles.
In addition, needed noise attenuation measures would be determined based on
accurate and up-to-date noise levels determined by the detailed, site-specific acoustical
analyses required under the mitigation recommended for Supplemental Impact N-1.
33.27 The analysis suggested by the commenter (i.e, "measure current noise, analyze traffic
projections, and provide an estimate of future noise") is an accurate depiction of the
analytical approach that will be used in the analyses for Phase I homes conducted in
accordance with condition #46 of the Terrabay Specific Plan Amendments, and for
subsequent Phases II and III conducted as part of subsequent environmental review
that will be undertaken at the precise plan stage for Phases II and III. Please also see
response to comment 33.25.
33.28 As explained for Supplemental Impact N-1 in the response to comment 33.25, the
availability of common acoustical analysis procedures and common noise attenuation
measures provide assurance that aircraft noise impacts could be mitigated to a less-
than-significant level. Also, because of the nature and location of the noise source,
noise impacts from aircraft overflights must be mitigated through such measures as the
use of sound-rated glazing in windows rather than by site design modifications.
33.29 Pages 235 and 254 of the DSEIR have been corrected to refer to the 1994 Clean Air
Plan rather than the 1991 Clean Air Plan. As required by federal law, the Clean Air
Plan was updated in 1994 primarily to incorporate the Association of Bay Area
Governments (ABAG) 1994 projections of regional population and employment growth.
The changes between the 1991 Clean Air Plan and the 1994 Clean Air Plan are not
substantial with respect to project-related air quality control measures and do not affect
the DSEIR findings of project consistency with the Clean Air Plan. (See errata for
DSEIR pp. 235 and 254 in section III herein.)
33.30 The DSEIR supplemental impact and mitigation findings for regional air quality (pp.
237-242) used significance thresholds for reactive organic gases (ROG), oxides of
nitrogen (NOx) and fine particulate matter (PM-10) of 150 pounds per day or greater,
as established by the Bay Area Air Ouality Management District (BAAOMD) in the
1985 BAAOMD CEOA Guidelines. In April 1996, after circulation of the DSEIR for
public review, the BAAOMD adopted revised CEOA guidelines containing a more
stringent threshold for ROG, NOx and PM-10 of 80 pounds per day.
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The SEIR has since been revised to apply the new 80 pounds per day threshold (see
errata for pp. 237-242 in section III herein). Use of the new, more stringent threshold
does not change the DSEIR regional air quality impact and mitigation findings. Project
emissions for Phase I of the proposed development would not exceed 80 pounds per
day, and would therefore have a less-than-significant regional air quality impact.
However, the analysis indicates that project Phases I, II and III would generate new
regional emissions of ozone precursors and PM-10 exceeding 80 pounds per day
(Supplemental Impact AQ-2). The mitigation measures recommended for regional air
quality impacts would have the potential to reduce regional impacts of the project by
from five to 15 percent. This reduction would reduce project regional emissions of PM-
10 to below 80 pounds per day, but would not be sufficient to reduce emissions of
ROG and NOx to below the 80 pounds per day BAAQMD significance threshold. Even
after mitigation, the impact of buildout of project Phase I, II and III on regional air
quality would remain an unavoidable significant adverse impact. These impact and
mitigation conclusions are the same as those in the DSEIR using the old 150 pounds
per day significance threshold.
33.31 Mitigation for Supplemental Impact AQ-1 requires implementing construction dust
mitigation practices commonly in use today (listed on DSEIR p. 242) in place of the
construction period air quality mitigation identified in the 1982 EIR. The recommended
practices reflect the measures contained in the Bay Area Air Quality Management
District (BAAQMD) CEOA Guidelines. However, because of the large size of the
project construction area and the proximity of sensitive receptors, the recommended
mitigation for Supplemental Impact AQ-1 has been revised to specifically include all
basic, enhanced and optional construction period dust control measures contained in
the 1996 BAAOMD CEQA Guidelines. These revisions do not change the DSEIR
impact and mitigation conclusions.
33.32 The DSEIR reevaluation of project local and regional air quality impact and mitigation
needs represents a cumulative analysis. The analysis uses the current methodologies,
standards and thresholds of significance established by the BAAOMD. The local air
quality impact analysis contained in DSEIR pp. 238-240 adds the project traffic volume
increment to projected future without project traffic volumes to calculate carbon
monoxide concentrations and thus represents a cumulative analysis. The analysis of
regional air quality impacts calculates project emissions of pollutants that are of
concern at the regional level and compares project emissions to BAAOMD-established
thresholds. These thresholds are established by the BAAQMD at levels necessary for
attainment of state and federal ambient air quality standards, assuming the levels of
regional (Le., cumulative) population and employment growth projected by ABAG.
33.33 Recommended mitigation for Supplemental Impact AQ-2 (DSEIR p. 242) and
Supplemental Impact T-15 (see pp. 155 and 156 of the revised transportation section
included in section III, herein) requires the incorporation of a vehicle-trip reduction
requirement applicable to all land uses. The applicant is to adopt and enforce the
requirement with the advice of the BAAQMD, the city, and the local transportation
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management agency. Within this program, the applicant would be able to develop any
number of strategies, including those identified by the commenter.
The Transportation Control Measures (TCMs) for the 1994 Clean Air Plan listed in the
comment are all regional strategies that identify the Metropolitan Transportation
Commission, transit system operators, the BAAOMD, Caltrans, cities, counties, and
school districts as implementing agencies. These kinds of programs are too general
and regional in nature to be applied to a specific land use project like the Terrabay
development. However, the applicant would be free to consider similar strategies or
even contributing funds toward any of these programs within the trip reduction program
required to mitigate Supplemental Impact T-15.
33.34 The DSEIR was circulated to the Native American Heritage Commission (NAHC) by
the State Clearinghouse. Please see comment letter 17 and the attached distribution
form.
33.35 Mitigation for sites CA-SMa-40 and CA-SMa-92 must adhere to the mitigation
requirements of Appendix K of the state CEOA Guidelines. Capping would consist of
covering the site with fill soil a minimum of one foot deeper than the maximum depth of
construction activities above or near the site. In order to minimi~e the potential for
damage to the resource, the mitigation also allows for additional or different site
capping measures if recommended by the archaeologist monitoring capping activities.
If it is determined that capping cannot be accomplished without damaging the
resource, then alternative mitigation may need to be considered, including avoidance
or a detailed excavation plan. Please also see response to comment 30.04.
33.36 Please see response to comment 30.05.
33.37 There have been no changes to the area of proposed development contained in the
1982 specific plan. Site CA-SMa-234 is still located outside the area of proposed
development. Any future development of Phase III would generally occur within this
area. However, the specific plan and the San Bruno Mountain HCP do allow for minor
adjustments in the development area boundaries. If any grading or geotechnical repair
work becomes necessary outside of the current development area boundaries, such
work could potentially disturb site CA-SMa-234. Potential disturbance of site CA-SMa-
234 by any Phase III grading or repair work that may be needed outside the current
development area boundaries represents a significant adverse impact (Supplemental
Impact CR-4--see errata for DSEIR pp. 246 and 247 in section III herein). Future
detailed environmental review for subsequent project Phase III should further consider
site CA-SMa-234 to confirm that no impacts, including potential impacts from grading
and geotechnical repairs or from project occupancy, would occur and to recommend
mitigation, if warran~ed.
33.38 As explained on DSEIR p. 244 for Supplemental Impact CR-1, "Potential for Additional
Cultural Resource Discoveries," records at the state Historical Resources Information
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System Northwest Information Center indicate that 100 percent of the project site has
been studied for cultural resources (Anastasio, Garaventa, Gueden, Harmon, and
Schoenfelder 1988; Cartier 1982a and 1982b; Chavez and Holman n.d.; Majer 1988;
Pastron 1993; Weigel 1984). Nevertheless the staff at the state Historical Resources
Information System Northwest Information Center indicate that the project site as a
whole, which is located on the bay margins and at the base of hills near sources of
fresh water, has a high potential for previously undiscovered Native American sites,
which could be encountered during project grading. Grading could potentially reveal
sites which were not evident during previous surface reconnaissances. As an
additional precautionary measure, the DSEIR (po 24S, mitigation for Supplemental
Impact CR-1) recommends measures to be taken in the event that previously
undiscovered cultural resources are encountered during project construction.
33.39 Mitigation measures for site CA-SMa-92 and, if necessary, additional or different
measures for site CA-SMa-40, will be developed in greater detail as part of subsequent
project-level environmental review undertaken when specific Phase III development
plans are submitted to the city for required precise plan approval in the future. When
any necessary mitigation requirements for Phase III are developed in detail, funding
requirements can be calculated and funding guarantees obtained at that time. The
mitigation recommended in the DSEIR is adequate under CEQA and appropriate given
that the specific development plans for Phase III are not known at this time.
33.40 The comment correctly notes that, if sites CA-SMa-40, CA-SMa-92, or CA-SMa-234
are eligible for listing on the National Register of Historic Places and a federal permit
or state permit pursuant to federal authority is required, National Historic Preservation
Act (NHPA) review would be triggered. If it is determined, as part of subsequent
environmental review to be undertaken when Phase III eventually comes before the
city for required precise plan approval in the future, that the project would require a
federal permit or state permit pursuant to federal authority (e.g., a Section 404 permit
for fill of potential jurisdictional wetlands), then the review and consultation
requirements of Section 10S of the NHPA would apply (see paragraph one of response
to comment 1.02 regarding subsequent environmental analysis). The project would
need to comply with all procedures and requirements of Section 10S of the NHPA,
including establishment of a Memorandum or Agreement with the State Historic
Preservation Office that specifies the mitigation required for Section 10S compliance.
33.41 Evaluation of an alternative that involves disapproving the requested extensions but
proceeding with a new specific plan and development agreement, as suggested in the
comment, is not necessary to avoid most of the significant impacts identified in the
DSEIR. Through its approval of the specific plan and development agreement
extension, the city has full discretionary authority to impose any additional conditions or
requirements on the development that it deems desirable. Please also see responses
to comments 8.01 and 8.02.
33.42 Please see response to comment 33.29.
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33.43 The proposed project does not present any inconsistencies with the South San
Francisco General Plan Noise Element, The supplemental mitigation measures
recommended on DSEIR pp. 228-229 for noise impacts from traffic (Supplemental
Impact N-1), aircraft overflights (Supplemental Impact N-2), and project construction
activities (Supplemental Impact N-3) would reduce noise levels on the project site and
at adjacent residential areas to within the land use/noise compatibility standards
established by the state and set forth in the city's Noise Element.
33.44 Comment acknowledged. Before taking any discretionary actions on the project (Le.,
approving the proposed extension of the termination dates of the specific plan and
development agreement, or approving subsequent precise plans, grading and building
permits, etc.) the city must first make a written finding that the action complies with the
HCP and the associated Section 10(a) permit and Agreement With Respect to San
Bruno Mountain Area Habitat Conservation Plan. Compliance with the HCP, Section
10(a) permit and Agreement will be considered during the public hearings scheduled
by the city to consider the proposed specific plan and development agreement
extension and subsequent project actions.
33.45 Comment noted. San Mateo County recently approved an offer by the project
applicant, SunChase, to dedicate HCP Administrative Parcel 2-04-02 to the county.
The Gounty approved the offer after its concerns regarding landslides, erosion
problems and restored habitat on the property were resolved (please see comment
35.01). The applicant has performed repair and remediation work to address the noted
drainage and habitat restoration problems and has prepared a grant deed for county
acceptance.
In any event, the comment does not pertain to the adequacy of the SEIR; no additional
response is necessary.
33.46 The CC&Rs approved by the South San Francisco City Council and recorded with San
Mateo County for Phase I of the project include a covenant providing for funding of
habitat activities as required by the HCP agreement.
33.47 Compliance of the already approved specific plan, development agreement and Phase
I precise plan with the conditions of approval for those existing entitlements is not a
CEQA issue required to be analyzed in the SEIR. Nevertheless, the CC&Rs approved
and recorded for Phase I of the project include the covenants referred to in the
comment.
33.48 The proposed Landslide D repair scheme will not require an amendment to the HCP
agreement and Section 10(a) permit. In order to repair the landslide, an approximately
4.2-acre area and 110,860 total cubic yards of soil will need to be re-engineered, of
which 45,300 cubic yards (1.5 acres) are located on lands within the jurisdiction of San
Mateo County, and 65,560 (2.7 acres) are lo~ated on lands within the jurisdiction of the
city. None of this Landslide D repair work will occur within the HCP "conserved
habitat" area HCP administrative parcel 2-04-02. The city and county have determined
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that the repair scheme complies with the Section 10(a) permit, the Agreement to
Implement the San Bruno Mountain Habitat Conservation Plan, and the San Bruno
Mountain Habitat Conservation Plan, and have approved the required grading permits.
The remediation and repair plans for Landslide 0 were reviewed by City and County
officials, determined to be adequate, and approved. The City and County issued
grading permits authorizing work to proceed on Landslide D. The work is expected to
be completed by October 31, 1996.
33.49 The SEIR biologist has confirmed that the project applicant is current with all HCP
funding obligations. The applicant has indicated that the previous property owner
made the required initial lump sum payment. The current applicant has paid its
proportional share of the monthly service charges for work performed by the Plan
Operator. Collection agreements requiring the future payment of HCP fees by
homeowners have been recorded for Phase I of the project. A monthly charge to
cover the costs of continuing work under the HCP will be paid by individual
homeowners as part of their homeowners association assessment. Please also see
comment 32.10.
33.50 Please see response to comment 33.44.
33.51 The comment does not pertain to the adequacy of the SEIR. SunChase has signed
the referenced agreement.
33.52 The status of the already approved Phase I precise plan is not a CEOA issue required
to be analyzed in the SEIR. The comment does not pertain to the adequacy of the
SEIR. Nevertheless, the Phase I precise plan was to expire within two years only if no
building permits or construction activities were commenced in reliance on the precise
plan approval within that time. Building permits for Phase I activities were in fact
issued within the two-year period. The City Council approved a revised construction
and grading activity schedule in October, 1995.
33.53 The status of already approved Phase I grading permits is not a CEOA issue required
to be analyzed in the SEIR. The comment does not pertain to the adequacy of the
SEIR; no response is necessary. (Multiple grading permits rather than a single permit
have been issued for Phase I.)
33.54 The comment does not pertain to the adequacy of the SEIR; no response is
necessary. In any event, through its approval of the specific plan and development
agreement extension, the city has full discretionary authority to impose any additional
conditions or requirements on the development that it deems desirable.
33.55 Compliance of the already approved specific plan, development agreement and Phase
I precise plan with the conditions of approval for those existing entitlements is not a
CEOA issue required to be analyzed in the SEIR. In any event, the applicant has
complied with all provisions of the development agreement.
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33.56 The comment does not pertain to the adequacy of the SEIR. In any event, the
applicant has complied with all provisions of the development agreement.
33.57 Project compliance with the conditions of approval for existing entitlements is not a
CEQA issue required to be analyzed in the SEIR. The comment does not pertain to
the adequacy of the SEIR. In any event, the applicant has complied with all provisions
of the specific plan related to geotechnical studies and the issuance of building
permits.
33.58 The basins needed for Phase I of the project have already been approved and
installed. Four catchment and debris basins were constructed at the foot of ravines
above the developed areas of Phase I of the project (DSEIR p. 175), one at the upper
limit of grading in the western swale in Terrabay Village and three at the upper limit of
grading in the three swales in Terrabay Park (DSEIR p. 163). Also, siltation basins
were constructed in the lower portions of the three swales in the central, Phase II
portion of the site. The county has consented to the construction of the catchment
basins, as evidenced by the "Joint Exercise of Powers Agreement for Maintenance of
Catchment Basins on San Bruno Mountain" adopted by the city and county in 1983,
which is discussed on DSEIR p. 176. Additional basins that may be needed for _
subsequent project phases would be approved and constructed in a similar manner.
Also, the comment does not pertain to the adequacy of the SEIR; no additional
response is necessary.
33.59 The applicant has indicated that the 1995 Winterization Plan (Le., the NPDES General
Permit-required Stormwater Pollution Prevention Plan for Phase I construction and
grading activities), approved by the city on August 15, 1995, was implemented. The
comment does not pertain to a CEQA issue required to be analyzed in the SEIR. No
additional response is necessary.
33.60 In response to comments concerning the adequacy of the catchment basins in Phase I,
the City geotechnical consultant, Eric McHuron, conducted an extensive review of the
studies and records pertaining to the sizing and capacity of the catchment basins. The
results of this review were presented to City staff. On the basis of that review, the City
determined that the catchment basins for Phase I are adequately sized and properly
designed. Please also see response to comment 33.14 and comment 32.04.
33.61 Compliance of Phase I of the project with the conditions of approval of the already
approved specific plan, development agreement and Phase I precise plan entitlements
is not a CEQA issue required to be analyzed in the SEIR. In any event, the South San
Francisco City Council approved the construction and grading schedule for the
development in October 1995.
33.62 The comment refers to Section 20.63.060 of the South San Francisco Municipal Code
(Terrabay Specific Plan District zoning) which requires that, "Prior to approval of any
precise plans or tentative subdivision or parcel map for develooment within the
Terrabav commercial district, the project sponsor shall obtain ...approval of a
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transportation systems management plan" (emphasis added). No precise plan has yet
been prepared and no approvals have yet been sought for the Phase III commercial
portion of the project. Also, compliance of the already approved specific plan,
development agreement and Phase I precise plan with the conditions of approval for
those existing entitlements is not a CEQA issue required to be analyzed in the SEIR.
No additional response is necessary,
33.63 It is possible that the Sister Cities Boulevard/Bayshore Boulevard/Airport Boulevard/
Oyster Point Boulevard intersection could not be improved to operate acceptably (even
with the flyover mitigation) without the new southbound on-ramp part of the hook
ramps. The lack of hook ramps would not affect year 2000 conditions. Compliance of
the already approved specific plan, development agreement and Phase I precise plan
with the conditions of approval for those existing entitlements is not a CEQA issue
required to be analyzed in the SEIR. The comment does not pertain to the adequacy
of the SEIR; no additional response is necessary.
33.64 The comment does not pertain to the adequacy of the SEIR. The recorded CC&Rs for
Phase I included a prohibition on parking or storage of recreational vehicles.
33.65 The SEIR geotechnical consultant concurs that future surficial instability is likely to
occur in Phase I graded areas as stated in the DSEIR ("Small, Localized, Post-Grading
Landslides", p. 169, paragraph 2). The city has found it acceptable for continued
future surficial instability to be considered as a long-term maintenance issue that can
be adequately addressed as a part of the overall continued, ongoing project
maintenance program needed for the project (Eric McHuron, McHuron Geosciences,
city geotechnical consultant, city of South San Francisco, personal communication,
November 6, 1995).
The need for an overall, long-term project maintenance program was recognized in the
DSEIR ("Supplemental Mitigation Needs", p. 170, paragraph 3). A number of
mechanisms for continued, ongoing maintenance of project geotechnical features,
including future surficial slope instability, have been considered by the city (Roger Foott
Associates, 1991). The project Master Homeowners Association Agreement approved
by the South San Francisco City Council provides for ongoing repair and maintenance
of geotechnical facilities and programs. The Slope and Drainaqe Maintenance Plan for
Terrabay Master Association (June 19, 1996) prepared by the applicant's geotechnical
consultant (Exhibit C of the agreement) clarifies the master homeowners association
responsibilities and specifies management, design and construction, monitoring,
maintenance, repair, funding, and reporting requirements. These requirements provide
sufficient resources for and assurance of continued drainage and slope maintenance.'
33.66 Surficial instability has locally infilled or blocked slope drainage facilities in the past,
and will likely continue to do so in the future as stated in the DSEIR ("Supplemental
'Arthur Wong, City Engineer, memorandum to Lida Budko, Terrabay Project Planner, July 16, 1996.
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II. Responses to Comments on the Draft SEIR
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Impact Findings", p. 169, paragraph 2). In addition, the DSEIR recognized the need
for a maintenance program to periodically inspect and maintain erosion and
sedimentation control facilities ("Supplemental Mitigation Needs", p. 171, paragraph 3).
This issue is addressed by the Slope and DrainaQe Maintenance Plan described in
response to comment 33.65.
33.67 The likelihood of continued surficial instability was previously recognized in the DSEIR
("Small, Localized, Post-Grading Landslides", p. 169, paragraph 2). It is important to
note that the only location for which use of the adjacent street as a "buffer" area for the
collection and clean-up of landslide debris was proposed by PSC Associates, Inc.
(PSC) was the "Goat Farm" cut slopes ('''Goat Farm' Cut Slopes", p. 171, paragraph
4). This approach is considered acceptable to the city (John Gibbs, Director of Public
Works, city of South San Francisco, personal communication, April 4, 1996). The
SEIR geotechnical consultant agrees with the comment that, since the probability for
extensive surficial slope failure is highest during or immediately after strong earthquake
shaking or periods of intense rainfall, temporary blockage of the adjacent street may
impair or block emergency access to several single family homes.
The SEIR has been revised to require the applicant to prepare an emergency response
plan that identifies measures and procedures to ensure adequate emergency access in
the event of temporary blockage due to surficial slope instability at the "Goat Farm" cut
slopes. (See errata for DSEIR page 171 in section III herein.)
33.68 Steep cuts in colluvium in Phase I, on the order of 1.5:1 (horizontal:vertical), are
reportedly limited to the "Goat Farm" cut slopes (Eric McHuron, McHuron Geosciences,
city geotechnical consultant, city of South San Francisco, personal communication,
April 4, 1996). The planned inclinations and anticipated long-term stability of the cut
slopes were apparently based on shallow bedrock conditions as suggested in the
comment and discussed in the DSEIR n3edrock Geology Encountered During
Grading", p.164, paragraph 1). This issue was recognized and a subsequent
geotechnical reevaluation of the cut slopes was prepared by PSC (1991) and
summarized in the DSEIR. PSC (1991) performed a Qualitative engineering
assessment of the cut slopes after final grading, but did not provide supporting test
data or stability analysis using appropriate strength parameters for colluvium. Their
report concluded that the completed cut slopes were acceptable from a geotechnical
point of view. This report was reviewed by the city's geotechnical consultant and
judged acceptable (Eric McHuron, McHuron Geosciences, city geotechnical consultant,
city of South San Francisco, personal communication, April 4, 1996).
Based on the PSC report, on an independent review of the report by Roger Foott
Associates (RFA), and on PSC responses to RFA comments, the city's geotechnical
consultant (Eric McHuron, McHuron Geosciences), has concluded that minor slumping
on the cut slope may continue to occur but poses no significant hazard to downslope
.residential development and is appropriately considered a maintenance problem. A
summary of the reevaluation of the "Goat Farm" cut slopes by the city's geotechnical
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consultant. which includes copies of the PSC report, the RFA review and the PSC
response, is presented in Appendix D herein,
Future cut slopes excavated in unconsolidated materials should be no steeper than
1.5:1, unless otherwise recommended by the geotechnical consultant of record and
approved by the city geotechnical consultant.
33.69 The need for an overall project maintenance program was previously recognized in the
DSEIR ("Supplemental Mitigation Needs", p. 170, paragraph 3). The project Master
Homeowners Association Agreement approved by the South San Francisco City
Council provides for ongoing repair and maintenance of geotechnical facilities and
programs. The Slope and Drainaqe Maintenance Plan for Terrabav Master Association
(June 19, 1996) prepared by the applicant's geotechnical consultant (Exhibit C of the
agreement) clarifies the master homeowners association responsibilities and specifies
management, design and construction, monitoring, maintenance, repair, funding, and
reporting requirements. These requirements provide sufficient resources for and
assurance of continued drainage and slope maintenance.1 The scope of anticipated
maintenance and repairs is considered to be acceptable to the city (Eric McHuron,
McHuron Geosciences, city geotechnical consultant, city of South San Francisco,
personal communication, November 6,1995). (See errata for DSEIR p. 170 in section
III herein.)
33.70 Landslide D was discussed previously in the DSEIR ("Updated Landslide Information",
p. 166, paragraph 6, and "Supplemental Impact Findings", p. 170, paragraph 2).
Studies by Leighton and Associates, Inc. (LA) and Geo/Resource Consultants, Inc.
(GRC) culminated in a repair/design concept approved by the city and the city's
geotechnical consultant, as stated in the DSEIR ("Supplemental Mitigation Needs", p.
171, paragraph 5). In developing the "approved" repair plan, the SEIR authors
understand that GRC reinterpreted the depth of active landsliding near the landslide
toe based on two additional soil borings drilled after the completion of the LA report.
The "approved" repair plan was subsequently reviewed by LA who judged that the
repair will increase the factor of safety of the landslide to greater than 1.5 (LA, 1995).
The SEIR geotechnical consultant concurs that the buttress should be founded in
competent, in-place material below the lowest landslide plane. As noted in the
comment, GRC (1995) has recommended excavation of test pits in the landslide toe to
confirm that the recommended keyway depth is adequate. It is unclear when the
exploration pits are recommended to be excavated, only that they be completed "in
advance" of the keyway excavation (GRC, 1995). Large-diameter borings, as
described in the comment, are possible supplements/alternatives to the test pits.
Deferral of such confirmatory exploration to the construction phase would not increase
the potential for geologic hazards, although it may involve significant additional cost if
1Arthur Wong, City Engineer, memorandum to Lida Budko, Terrabay Project Planner, July 16, 1996.
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the design must be revised due to changes in anticipated geologic conditions
encountered during grading.
33.71 The remediation and repair plans for Area D were reviewed by City and County
officials. determined to be adequate, and approved. The City and County issued
grading permits authorizing work to proceed on Area D. The work is expected to be
completed by October 31, 1996. (See errata for DSEIR p. 171 in section III herein.)
33.72 The issue of "buried valleys" and deep landslides was previously addressed in the
DSEIR ("Bedrock Geology Encountered During Grading", p. 163. paragraph 4, and
"Updated Landslide Information", p. 166, paragraph 4). The first part of the comment
deals with cut slope analysis and design for steep cuts within colluvial "buried valley"
deposits. As discussed under response to comment 33.66. steep cuts in colluvium in
Phase I, on the order of 1.5:1, are reportedly limited to the "Goat Farm" cut slopes
(Eric McHuron, McHuron Geosciences, city geotechnical consultant, personal
communication, April 4, 1996). A supplemental report by PSC (1991) concluded that
the completed cut slopes were acceptable from a geotechnical point of view, and this
report was subsequently reviewed and judged acceptable by the city (Eric McHuron,
McHuron Geosciences, city geotechnical consultant, personal communication, April 4,
1996). Based on the PSC report, on an independent review of the report by Roger
Foott Associates (RFA), and on PSC responses to RFA comments, the city's
geotechnical consultant has concluded that minor slumping on the cut slope may
continue to occur but poses no significant hazard to downslope residential
development and is appropriately considered a maintenance problem. A summary of
the reevaluation of the "Goat Farm" cut slopes by the city's geotechnical consultant,
which includes copies of the PSC report, the RFA review and the PSC response, is
presented in Appendix D herein.
The second part of the comment deals with possible fill placement over compressible
landslide debris or colluvium. Fill was reportedly not placed during Phase I grading
over compressible landslide debris or colluvium (Eric McHuron, McHuron Geosciences,
city geotechnical consultant, city of South San Francisco, personal communication,
April 4, 1996). Grading recommendations provided by PSC (1983a) call for the
removal of incompetent materials in areas to receive fill. In addition, the 1982 EIR
contained a mitigation measure recommending that weak or unstable soils be
overexcavated and replaced with properly compacted and keyed material (1982 EIR p.
85, paragraph 8 and DSEIR Table 21, pp. 160-161). Eric McHuron, the city's
geotechnical consultant, indicated during a meeting on April 4, 1996 that incompetent
materials encountered were removed prior to placement of fill. Soils encountered in
"buried valleys" were reportedly often cemented, and typically "bulked up" when
excavated and recompacted as engineered fill, indicating in-place density of the natural
material was at least equal to or greater than that of engineered fill. A representative
of PSC, the geotechnical consultant of record at the time of grading, observed and
tested grading operations. In addition, a representative of Roger Foott Associates
(RFA), the city's geotechnical consultant at the time of grading, was present on a
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full-time basis during grading operations (PSC, 1995a and 1995b). All grading
operations were completed to the satisfaction of RFA (Eric McHuron, McHuron
Geosciences, city geotechnical consultant, personal communication, April 4, 1996).
The SEIR geotechnical consultant concurs that similar "buried valleys" and deep
landslide deposits may be encountered during future development phases. As the
changes in anticipated geologic conditions became apparent during Phase I grading,
RFA recommended that reassessment of the Phase II design be performed while
changes could still be made without unnecessary problems (RFA, 1991). PSC has
completed some supplemental reports on potential geologic hazards and slope stability
analyses for the Woods West and Woods East (formerly known as neighborhoods C
and D) portions of the Terrabay development. Similar design-level studies should be
completed by the geotechnical consultant of record to adequately characterize the
remainder of the Terrabay development prior to the start of qradinq. All geotechnical
documents should be reviewed and approved by the city's geotechnical consultant
prior to issuing grading permits.
33.73 The issue of cut/fill transition lots was previously addressed in the DSEIR ("1982 EIR
Soils and Geology Impact and Mitigation Findings",.p. 161, paragraph 3). According to
the grading notes provided on the Phase I grading plans (CREM, 1988), lots located
on cut/fill transitions ("transition" lots) were to be overexcavated by a minimum of three
feet and recompacted with engineered fill. In a foundation investigation report for
Terrabay Park, PSC confirmed that the "transition" lots were overexcavated by up to
three feet in cut areas and uniform fill was placed across the entire lot during Phase I
grading operations, and included a list of transition lots (PSC, 1990). Representatives
of the city similarly confirmed during a meeting on April 4, 1996 that all lots with cut/fill
transitions were mitigated by this approach.
We concur that there is a potential for differential fill settlement to occur in areas of
deep fill in Phase I. This issue has recently been addressed by the current
geotechnical consultant of record for the Phase I residential development, Berlogar
Geotechnical Consultants (BGC). BGC encountered "reasonably compacted
engineered fill" in two soil borings recently drilled in Terrabay Park (BGC, 1995). BGC
also noted that the engineered fills have been in place for approximately six years and
concluded that the majority of settlement resulting from fill placement has likely already
occurred (BGC, 1996). Based on their findings, BGC provided design-level foundation
criteria for the Terrabay Park development.
Design-level geotechnical reports should be prepared by the geotechnical consultant of
record for other areas of existing fill in Phase I and areas of future fill in Phase II, and
should similarly evaluate the potential for differential fill settlement and provide
recommendations as needed to mitigate potential fill settlement, including foundation
type. The reports should be reviewed and approved by the city's geotechnical
consultant prior to issuing building permits.
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Final SEIR
II. Responses to Comments on the Draft SEIR
Page 287
As discussed under response to comment 33.70, it is the SEIR geotechnical
consultant's understanding that fill was reportedly not placed during Phase I grading
over compressible landslide debris or colluvium (Eric McHuron, McHuron Geosciences,
city geotechnical consultant, personal communication, April 4, 1996). All grading
operations were completed to the satisfaction of RFA, the city's geotechnical consultant
at the time of Phase I grading (Eric McHuron, McHuron Geosciences, city geotechnical
consultant, personal communication, April 4, 1996).
33.74 In response to comments concerning the adequacy of the catchment basins in Phase I,
the City geotechnical consultant, Eric McHuron, conducted an extensive review of the
studies and records pertaining to the sizing and capacity of the catchment basins. The
result of this review were presented to City staff, On the basis of that review, the City
determined that the catchment basins for Phase I are adequately sized and properly
designed and no reevaluation is warranted,
33.75 As discussed under response to comment 33.64, the need for a maintenance program
to periodically inspect and maintain erosion and sedimentation control facilities was
recognized in the DSEIR ("Supplemental Mitigation Needs", p. 171, paragraph 3). The
comment supports the DSEIR mitigation requiring the establishment of a long-term
maintenance program to monitor, clean, and maintain the debris basins, and
recommends that a GHAD be established to implement the maintenance program. As
discussed in responses to comments 1.16, 5.05, and 33.63, the project Master
Homeowners Association Agreement approved by the South San Francisco City
Council provides for ongoing repair and maintenance of geotechnical facilities and
programs. The Slope and Drainaqe Maintenance Plan for Terrabav Master Association
(June 19, 1996) prepared by the applicant's geotechnical consultant (Exhibit C of the
agreement) clarifies the master homeowners association responsibilities and specifies
management, design and construction, monitoring, maintenance, repair, funding, and
reporting requirements. These requirements provide sufficient resources for and
assurance of continued drainage and slope maintenance.'
33.76 The comment states that the SEIR should address installation of debris basins as
mitigation for future project phases. The SEIR authors agree that the potential for
debris flows should be reevaluated for subsequent project Phases II and III based on
current knowledge and practice. PSC (1983) discusses debris flow potential and
provides recommendations for use in design for the Phases II and III portions of the
project site as well as for Phase I (please see response to comment 33.72). The
sizing and siting of the debris basins should be based on the recommendations
provided by the geotechnical consultant of record, and reviewed by the city's
geotechnical consultant. The DSEIR (p. 172) has been revised accordingly. (See
errata for DSEIR p. 172 in section III herein.)
'Arthur Wong, City Engineer, memorandum to Lida Budko, Terrabay Project Planner, July 16, 1996.
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II. Responses to Comments on the Draft SEIR
Page 288
33.77 As a general rule in any development, grading plans should reflect recommendations
of the geotechnical consultant of record in areas where slope repair is required. As
stated in the DSEIR, this should include all landslides and areas of weak soil in or near
proposed development ("1982 EIR Soils and Geology Impact and Mitigation Findings",
p. 161, paragraph 4).
Areas of gullying and surficial slope failures in the dedicated lands should be repaired
to the satisfaction of the county. The geotechnical consultant of record should
evaluate the need for supplemental recommendations to address the long-term stability
of disturbed areas in the dedicated lands.
The SEIR geotechnical consultant concurs that, as is the case for any large grading
project, the extent of grading and stabilization work required on portions of the property
that are to be dedicated to San Mateo County (Le., HCP Administrative Parcel 2-04-02)
may be greater than shown on the grading plans, depending on geologic conditions
encountered. As discussed in the response to comment 33.70, design level studies
shall be completed by the geotechnical consultant of record to adequately characterize
the areas to be graded for subsequent project phases before the start of grading, and
any supplemental recommendations shall be reflected in the final grading plans. All
geotechnical documents shall be reviewed and approved by the city's geotechnical
consultant prior to issuing grading permits.
33.78 All restaurant uses proposed for project Phase III were considered to be "quality" rather
than "high turnover-sit down" restaurant uses in the 1982 EIR traffic analysis. Since
the project applicant has not indicated any change in the characteristics of the
proposed restaurant uses in the Phase III component of the project, all restaurant uses
have continued to be calculated as "quality" restaurant uses for trip generation
purposes.
33.79 The three primary sources of future traffic information used in the DSEIR year 2000
and 2010 Base Case (without project) traffic forecasts--the 1993 Brisbane General
Plan Circulation Element, the East of 101 Area Plan EIR, and the EI Camino Corridor
Redevelopment ProQram EIR--provide: a detailed list of projects considered in their
projections; regional traffic modeling projections used as a component of future
freeway volume projections (East of 101 Area Plan EIR only); and, in the East of 101
Area Plan EIR and the Brisbane General Plan analyses, indication of what
development in adjacent jurisdictions was not considered. Knowing this information, it
was possible to develop a conservative "worst case" set of future traffic projections. It
is true that, due to the minimal assumption that future Brisbane traffic projected to be
traveling to and from South San Francisco may have been some of the same traffic
projected in previous South San Francisco analysis to be traveling to and from
Brisbane, an overall subregional traffic analysis of the future land uses proposed for
both Brisbane and South San Francisco may have produced a slightly lower set of
volumes for the Bayshore Boulevard and US 101 connections between the two cities
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II. Responses to Comments on the Draft SEIR
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than was developed for the OSEIR traffic analysis, by the blending of traffic forecast
results.
33.80 Please see responses to comments 30.01 and 33.04. These responses explain that
recently observed congestion at the Oyster Point interchange is due to the construction
period diversion to the Oyster Point interchange of Grand Avenue interchange traffic
bound for northbound US 101. The Grand Avenue interchange US 101 northbound
on-ramp has been closed most of the day and, in particular. during the AM peak
commute traffic period due to construction. In response to this and similar comments
pertaining to conditions at the Oyster Point interchange. existing and projected traffic
volumes at the Oyster Point interchange were recounted and re-analyzed. The revised
findings pertaining to this interchange are described on pages 89. 96, 100, 102-105,
106,108.109,126-133,135.137,138.140-145,147. 150-154, and 156 of the revised
Transportation chapter.
33.81 Please see response to comment 33.80.
33.82 Traffic analysis projections used for the OSEIR traffic analysis, as well as for previous
analyses in the area, were developed using distribution patterns based on the most
logical (and potentially the shortest by distance) travel routes. The commenter notes
that once this initial distribution pattern had been developed, and before mitigation
measures were tested, a second iterative step using capacity constraint as a
controlling factor should have been used to redistribute traffic. Since proposed
mitigations (Table 20 on OSEIR p. 138) were shown to result in acceptable operation
at the intersection in question (Bayshore Boulevard/US 101 southbound ramps/project
commercial access) for the most logical travel route scenario, the SEIR traffic
consultant sees no reason why a capacity constrained analysis would be warranted at
this interim, pre-mitigation step.
33.83 The SEIR traffic consultant agrees that successful implementation of the transportation
demand management (TOM) measures recommended as mitigation for Supplemental
Impact T-15 would not reduce the identified significant project impact on US 101
freeway operation to a less than significant level. Based on recent surveys of
employers and commuters in the region (following the invalidation of BAAQMO
Regulation 13. Rule 1), including a 1996 telephone survey by RIOES for Bay Area
Commuters, Inc.,1 a vehicular trip reduction of at least 12 percent can be anticipated
due to voluntary TOM activity. Nevertheless, even after mitigation. the impact of
buildout of project Phases I, II and III on US 101 freeway operation would remain an
unavoidable significant adverse impact. This finding has been included in the revised
Transportation section recirculated for public review on August 30, 1996 and included
in section III herein.
1RIDES for Bay Area Commuters. Inc., Commute Profile '96, July 1996, MTSMA Reqion
Supplement, based on an April 1996 telephone survey of commuters,
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October 25, 1996
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II. Responses to Comments on the Draft SEIR
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33.84 In response to this comment, the SEIR 2010 traffic analysis for the Oyster Point
interchange area has been revised and now assumes no implementation of BAAQMD
Regulation 13, Rule 1--the employer-based trip reduction rule. The 20 percent
reduction in trip generation incorporated into the East of 101 Area Plan EIR 2010 traffic
projections have been eliminated. An approximately six percent reduction due to
anticipated transit use (the same level of transit use currently experienced by
employers in the East of 101 area) has been retained in the projections. The EIR
authors and EIR transportation engineer have also determined that, in addition to the
TSM-based vehicular trip reductions already reflected in the analysis (6 percent), an
additional vehicular trip reduction of at least 12 percent can be anticipated in the
project/East-of-101 area due to continued voluntary TSM activity (see revised
Transportation chapter pp. 146-147).
It should be noted that the East of 101 Area Plan EIR year 2000 projections used in
the DSEIR traffic analysis did not include a 20 percent reduction for the BAAQMD trip
reduction rule. Thus, there has been no change to the DSEIR year 2000 Base Case
and Base Case project Phase I traffic analysis.
33.85 Please see response to comment 33.84.
33.86 Please see response to comment 33.84.
33.87 The year 2010 was selected as a logical and reasonable ultimate horizon year for the
DSEIR traffic analysis considering the uncertainty of the timing of buildout of
subsequent project phases. An economic slow-down as evidenced over the past three
to four years may dampen the market for commercial space and thus delay buildout of
the project beyond the anticipated completion date presented in DSEIR Section III,
Project Description. Such a developing trend could be adequately considered in the
subsequent environmental review required for the precise plan stages of project
Phases II and III.
33.88 With respect to mitigating cumulative conditions at the intersection of Airport, Bayshore,
Oyster Point, and Sister Cities Boulevards, the southbound flyover off-ramp has been
retained in the revised Transportation chapter as the only feasible long-term mitigation
alternative. With respect to the mitigation proposed for the Commercial Access/
Bayshore Boulevard intersection, the revised Transportation section proposes a double
rather than a triple left at the north- and southbound approaches to the intersection.
Future more detailed traffic planning and mitigation design for project Phase III will
include preparation of engineering drawings, and identification of any additional right-
of-way acquisition needs, if any, to implement this mitigation.
33.89 Please see response to comment 33.06.
WP51 \548 IFSEIRI F-II. 548
MAR-20-1996 10:17
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SIERRA CLUB · LOMA PRIETA CHAPTER
San Mateo · Sa1\{':i Clard · San Benito Counries
RECEIVED
MAR 2 0 1996
PLANNING
March 20, 1996
Uta Budke
City of South San Francisoo
RE; Terrabay Specific: Plan and Development Agreement
Draft Supplemental ElR
Dear Ms. Bud.ko; .
The Loma Prieta Chapter of the Sierra Club has followed the development
proposals for San Bruno Mountain for many years. We did participate in the
scoping meeting to solicit comments for the supplemental EIR.. Our ooncems ue
limited to two areas: 1) concern over the timing and effectiveness of remediation
and restoration of conserved areas and 2) concern over the impacts of the phase 3
development.
~
R.emediation and RestoTation of Conserved. Areas
While we have had general concerns about the proposed development, we have
been quite concerned over the recent state of the property. We are pleased to see
the efforts currently underway to clean up and remediate problems caused by
the abandoned construction. The degradation of the area has been in violation of
the HCP agreements and, if not addressed immediately, could lead to long term
severe impacts.
We urge that ~ remedial activities be cotnp1eb!d ina timely manner. We believe \
that these activities should be closely sautinized and urge frequent reporting ~()(
and review. Specific goals for erosion control, revegetation and the control of
invasive exotic plants should be developed. In addition, bonds should be po6ted
to ensure that such operations are completed to the satisfaction of the Oty and
RCP trustees.
We also urge a long-term effort by the developers or hom.eowners to maintain
the conserved areas. This effort should include an education and community
involvement component. The education and involvement of the homeowners in
the Pointe Pacific development in Daly Oty has led to a locally based eradication
and lupine cultivation effort. Such community involvement will help all
involved to meet: the goals of the RCP.
--
~
~)
3921 Ea~: Bar.;hore Road Suite 204
Palo A]w. CA 94303
415.390-8411
FAX <U5.390-R497
(i)
I .,...,.... e,;,...-' . _ _....... .....J.. -'
Phase 3
We believe that the City of South San Franc.isco should only approve a
development agreement for phases 1 and 2 We are ooncemed that the
commercial development in phase 3 will severely impacfsensitive archaeological
resources and future recreational opportwUties. We believe that the approval of
this phase should be given more C01'ISideration and that there should be more
effort to get this parcel into public ownership in a manner that wiII compensate
the landowner. We do have concerns that there may be more commercial
development in the East of 101 Specific Plan area than the market can support. If
this is shown to be the case, this parcel would best be suited for open space. This
open space could actually be an amenity to both the residential and commercial
oommunities. By approving an exrensian of the development agreement, the
City could be locldng in development that may not be needed or foreclosing any
opportunity for future mitigations to address the archeological and recreational
concerns.
Respectfully submitted,
~~
direct line 415/390-8414
-
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-
,
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~
TOTI=L P. 03
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 293
34. Julia Bott. Chapter Director. Lorna Prieta Chapter. Sierra Club; March 20. 1996
34.01 Please also see responses to comments, 10.01, 10.03, 10.06 and 13.01.
34.02 Comment noted. The specific plan and development agreement identify the general
type and density of commercial development contemplated for project Phase III in
1982, as discussed in section III of the DSEIR, Project Description. However, the
development plans contained in the specific plan are unlikely to actually be developed
if the level and type of development cannot be supported by the market. The actual
specific development plans for Phase III are not yet known. When Phase III is to be
developed and eventually comes before the city for required Phase III precise plan
approval, a more detailed development plan would be submitted and additional, more
detailed environmental review would be undertaken, possibly including formulation of
more detailed cultural resources mitigation and consideration of preserving a portion of
the site as open space in collaboration with the proposed development. Please also
see responses to comments 1.02 and 1.08.
WP51 \548 I FSEIR I F-/I. 548
1.tHl-.:-~"t:l- ~ ::'':'t .1.":-.1.:.,1_'
.LMI1 ., 11 '4Ll .;>" ....'_' I '-I..' 11 '\.1
Planning and Building Division
County of San Mateo
Mail Crop P:..N~ 22. 590 H~miItD'1.slraet - 2nd Flcor' ReoNood City
Califomia 94063 . :ele-;:hone 415/36::-4161 . Fax 415/363-4849
Board of Supervisors
r<L;b~r. 8::c::1I;::; ?~
Mary Grittln "7
Tom hup.n'f''J
Tlld LQmpgrt
MiChae! U Ncvr.
Environmental Services Agency
Director of
Enllironmanlal Servil;:e$
P:l'.J! M Kccn,g
Planning Admlni5trator
Terry L &:CMS
March 20. 1996
Lida Budko
South San Francisco Planning Department
400 Gr.md Avenue
. South San Francisco, CA 94080
RECEI'.
MAR 2 0 .
PLANNli
Dear Ms. Budko:
1 am writing in regard to several issues that have arisen during the County Planning and Building
Division's review of the Draft Supplemeolal Environment.allmpact Report (DSElR) for the
Terrabay Specific Plan and Development Agreement Extension. The County Planning and
Building Division's concerns regard geologic hazards, erosion. am revegetation associated with
-lands that are currently owned by the CoUIJty and lands that will be offered for dedication to the
County Parks and Recreation Division as couserved habitat in accordance with the San Bruno
-Mountain Area. Habitat Conservation Plan (HCP).
-
Per Volume n of the HCP (pages VII-l66 through VTI-168), the property owner bas the obliga-
tion to offer to dedicate fee ownership of the area identified as Admini!i.trative Parcel 2-04-02 to
the Counry of San Mateo. to provide conserved habitat. In the past, the furmer developer
W. W. Dean did sign documents offering conserved habitat to the County. These documents
require some minor revisions am will need to be re-executed. Further, at that time we exp1.ained
to the developer and representatives of the City of South San Francisco that the offer would not ~f)l
be accepted until concerns regarding landslides, erosion problems, aDd restored babi1al: on those
lands are resolved. We presented the developer and the City of South San Francisco with a
document entitled: "Standards for determining successful ~vegetation especially for disturbed
areas being reclaimed for conserved habitat and (0 be dedica1ed to the County of San Mateo in
ac;cordcmce 'Nith the San Bruno Moumain Area Habitat Conservation Plan." Tbese 5taDdards llJC
expectt:d to be complied wilh before we can recommend that the Board of Supervisors accept the
conserved habitat. _
-
In the DSEIR. a landslide is identified in Area "D" above the area proposed for development. In
the future. this area will be offered by the developer ro the County as conserved habitat. In the
DSEIR, a number of remediation methods are proposed to repair this landslide. The Engineering ~.Oz...
Geologist who prepared the Geotechnical Appendix recommended Alternative 14 as the besr way
to repair the la.nd&lide. We concur that Alternative #4 appears to be an appropriate fix in
,/
GlJNr.
r1AR- 21Z1-1 '39E 1':: : (15
FU:N~ [~~G 3. EU 1 LD 1 ~~
415 363 484'~ P. 0::
Lida Budko
-2-
March 20, 1996
GONr.
.
accordance with current geotechnical engineering standaTds. Any final selection of an alternative
will depend on the outcome of future detailed geotechnical inves~oations. Our understanding is "*". (1Z,
d1.1t the landslide repair and all incidental work will be located within the e.ri~ting fence lines of
the HCP development area boundaries. _
. On March 14, 1996, representatives from the County and City met to cIMify issues and
procednres to ensure efficient permitting. The la0d8iide is located on lAnds under the jurisdiction
of both the City and the CouDly; therefore, Grading Permits wiD. be required from both
jurisdictions. It is our opinion that a cooperative review of the Gf'ading Ptans is appropriate by
City and County staff. The County ~i11 consider approval of issuaDCe of a Grading Permit for
landslide remediation after the City approves lhe project and certifies me DSEIR. The Connry
will use the City's SEIR for enviroDlUental review puIpOSeS.
J
~.o~
---
-
There are currently landslide monitoring instrumentlrioos put in place to assess current
movement of d1e landslide. It is our opinion that those monitoring iJ1Stt1.uDenrs shoold remain in
place to assess future conditions.
~.of
-
We have reviewed me DecIMation of CovenantS, Conditions, and Restrictions (CC&Rs) of the
Terrabay Village Association. Conditions 16 and 17 of the CC&R.s appear to address the
obligations of the Homeowners Association for slope main!enance and laDdslide repair should it ~C:. Ot:
be necessary to do any future work on tbe existing Jand.s1ide following the proposed remediarion "7 J. V/
discussed in the DSEIR. We believe that the DSEIR should also recognize the possible use of a
Geological Hazards Abatemenf: District as a vehicle to ensure future maintenance of the repairs.
-
Thank you for the opportunity to comment on the DSEIR. for the T errabay Specific Plan and
Development Agreement Extension. Ptease feel free to conrnct me at 415/363-1823 if you have
any qnestioos.
Sincerely.
W~
Samuel Herzberg
P1anncrm
SH:fc - SFHG0372.6FN
cc: Paul Koenig, Director of Environmental Services
Terry Burnes, Planning Administrator
Bill Rozar, Development Review Manager
Mike Murphy, Deputy Coonty Counsel
Pete Bentley, Senior Engineer
Jay Mazzetta. Geotechnical Engineer
Joel Medlin. U.S. Fish and Wildlife Service
TOT~ P.B3
T errabay Project
City of South San Francisco
October 25, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 296
35. Samuel Herzbera, Planner III, Plannina Division, County of San Mateo: March 20,
1996
35.01 The county has recently approved the applicant's (SunChase) offer to dedicate HCP
Administrative Parcel 2-04-02, based on its determination that erosion and restored
habitat problems have been resolved and the county's standards for revegetation have
been complied with. The comment does not pertain to the EIR adequacy.
35.02 The comment concurs that the recommended Landslide 0 repair Alternative #4 is an
appropriate fix.
35.03 The comment notes that Landslide 0 will require both city and county grading permits.
The county will consider issuance of a grading permit after SEIR certification and
project approval and will use the city's SEIR for environmental review. Comment
acknowledged. Since receipt of this comment letter, the City and County have issued
grading permits authorizing work to proceed on the repair of Landslide D. The work is
underway and is expected to be completed by October 31, 1996.
35.04 The DSEIR (mitigation for Supplemental Impact G-2 on p. 172) recommends
implementation of a long-term monitoring plan for Landslide 0 that makes use of
selected existing piezometers and slope inclinometers.
35.05 The DSEIR (mitigation for Supplemental Impact G-1 on p. 171) recommends a
Geologic Hazards Abatement District (GHAD) for continued ongoing geotechnical
maintenance and repair. Maintenance could also be accomplished by the project
master homeowners association. The project Master Homeowners Association
Agreement approved by the South San Francisco City Council provides for ongoing
repair and maintenance of geotechnical facilities and programs. The Slope and
DrainaQe Maintenance Plan for Terrabav Master Association (June 19, 1996) prepared
by the applicant's geotechnical consultant (Exhibit C of the agreement) clarifies the
master homeowners association responsibilities and specifies management, design
and construction, monitoring, maintenance, repair, funding, and reporting requirements.
These requirements provide sufficient resources for and assurance of continued
drainage and slope maintenance.'
'Arthur Wong, City Engineer, memorandum to Lida Budko, Terrabay Project Planner, July 16, 1996.
WP51 \548\FSEIR\F-II.548
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RECEIVED
MAR 2 0 1996
PLANNING
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Biodl\lC:~lly Res(xm:c CCQ'cr
CalifOrni2 AC3dem\" of Scieoces
Golden Gilte Park .
Sao FrancIsco, CA 94118-459c
(4!!) 7~fl.1~~ 1 '
WILDFLOWER CONSERVATION GUIDELINES.
1. Let your acts reflect your respect for wild
native plants as integral parts of biological com-
munities and natural landscapes. Remember that
if you pick or Jisturl- wildflowers, your action af-
fects the natural worlJ, anJ that the cumulative
effects of the actions of many people can he particu-
larly harmful.
2. Do not Jig or take cuttings from native plants'
in the wild except as part l,f rescue or S<llvage
operations SP( msoreJ by resl'onsi ble organizations.
3. Encourage the llse of regional native phmts
in home and public landscapes, but before obtain-
ing wildflower plams or seeds for your home land-
scape, learn enough about their cultural re4uire-
ments to he su;e Y~IU em provide a suitable habitat.
4. If you collect seeJs from the wild, collect a
few seeds or fruits from each of many plants and
only from common s/)ccics fhal'a1/: locally abundant.
Purcha5e wilJf10wer seeds only from companies
th:lt collect responsihly.
:;. Purchase li....e wilJflower plants only from
suppliers or organi:atioos that propagate their own
plants or th:lt pllfchase tht:ir material from those
who rn'l'a~:lIe them. Ask ~.cIlers ahout the origin
of t h~ plants YlllI aft: consillering huying. If there
is any doubt abuut a plant's origin, do not purchase
it.
6. Be caut ious anJ k nl lwledgeahle in t he use of
cxotic wildfll.wers. \Vhile many of these non-
native wilJflower species GlIl be attractively useJ
in g;uJens and IanJscapes, sOllle species are overly
aggressi\'e and these weeJs lIl;ly ~lisplace native
species. Recume aware of Yl'ur sratc's Jloxious we ell
I;lWS hy cont;lcting your state Department of Ag.
riculture or Agricultural Extensioll Service.
'AJal'ted fur hwaJer apl'licahility fcum the Virgina;.
WIldflower rrescrvalion SocielY's "Wildflower C(Jn~ec"ati('l\
Guidelines. .
7. When pb~)tographing wildflowers, or inspe~t-
ing them closely, be careful not to trample plants
nearhy.
8. If you pick wildflowers, dried seed stalks, or
greens for hume decoration, use only common
species that are :Ibundant at the site. Leave enough
flowers or seeds to allow the plant population to
reseeJ itself. Avoid picking herbaceous perennials
such as wilJ orchids. jack-in-the-pulpits. or gen-
tiam; that, like J;lffoJils, need to retain their veg-
etative parts W store energy for nelCt year's develop-
ment. AvoiJ cutting sluw-growing plants, such as
running cedar, club mosses, or partridgeberry, for
Christmas wreaths or other decorations.
9. Become familiar with your state's wildflower
prorection laws. If your state does not have laws
protecting wildflowers, or if the existing laws are
weak, support the passage and enforcement of
strong and effective legislation for the preservation
uf native plants. Report unlawful collection of
plallt s to proper authorities and, when necessary,
reminJ others th:lt collecting plants or disturbing
a natlltal area is illegal in parks and other public
places.
10. If you learn that an area with wildflowers is
scheJult:d for dt:velol'mem, notify :i native plant
society in your region. Discuss with the developer
the pussibilities of colllpatible development alter-
natives or of C(l"Juctillg a wilJflower rescue or
salv;lgc operation.
I \. It is importaJlt to protect information about
the locatilll1s of rare species. If you discover a new
site Uf;l plant species that you know is rare, report
it to responsible conservation officials, such as your
state's Natural Heritage Program, a native plant
society, Nature Conservancy chapter, or the U.S.
Fish anJ Wildlife Service,. as soon as possible and
before discussing it with others.
I"~
d
I'
..,/~
TilE WILDFLOWER GARDENER'S GUIDE
~~~1:.:i."~ .' ....""t'"~_..~lL.#~u..>-'" ~'i.'.'oiI.<l!-;:rJil,fi;.iBL.;hP"'~'llhS..nL....-mm:':: ,~~.t!~6~.iCii..~. ~~
Ge8.
4p
VOLUME 5 . ISSUE 3 . FALL 1994
3~V=~O~Y~~~~A~..
R3V=3\\,
TREES PLANTED AT FREMONT'S MATTOS
~LEMENTARY TO COMMEMORATE NUMMI'S
iEN YEARS OF PARTNERSHIP WITH THE LOCAL
COMMUNITY
A small "grove" of Evergreen Pear trees was planted on
the campus of Mattos Elementary School in the lower
San Francisco Bav Area city of Fremont, California, to
commemorate the 10th aIuuversary of New United Motors
\1anufacturing, Inc. and its partnership with the community.
Known far and wide by the acronym "NUMJvll," it's the
place where Geo Prizms are built. The trees were purchased
through a grant from Chevrolet/Geo Envirorunental.
Superintendent of Schools Ralph Belluomin, Mattos
Principal Barbara Sims, L)TIn Palos, coordinator of the
Partners in Education Program for the Fremont School
District, and student representatives
from Mattos all took part in the planting CAN'T FIND AN
-:eremony. "These trees represent the ENVIRONMENT AL GROUP. . .
partnership that NUMM:I has had with WHY NOT START YOU R
;.ne community here in Fremont," OWN?
3€lluomin stated. "The trees will stand W hen AI Grubbs, administra-
as a ~minder of what that ~1e~ ~ot~ ,t~. ' th'e assistant to the general
our aty and to our school dlStnct. manager of Three-'Way
A tenth tree was planted on April 15, Ch~vrolet/G~o, in Bakersfield, Cal.ifornia,
1994, on the grounds of Nl..,~1.\11 by decided that .It ~'ou.ld be a go~ thmg for
Chevrolet/Geo General Manager Jim the commuruty If his dealership took an
Perkins. During that ceremony Perkins active role in the Gee Tree Program, he
said, "As you all know, it's traditional to started looking around for a non-profit
give a gift on the occasion of an anniver- environmental group. He could not
sary so, in celebration of our first ten locate one. Undaunted by this fact,
years, we are planting ten new trees in Grubbs did some research, t:1lkN:! to some
Fremont: one ceremo.nial tree here at the people and helped form a completely
~UM..\11 plant, and rune at Mattos new non-profit orO'anization called "Tree
Elem~ntary. Our ~f~, these trees, :viii be Foundation of Ke~." Named for the
a rerrunder of the livmg partne~hip .
which !\lUMMI represents, as well as
the commitment that we have made to
this community."
A special plaque installed at Mattos
School reads: 'Tnese Trees Ha\e Been
Planted by Chenolet/Geo To
Commemorate Ten Years Of Quality,
Teamwork & Commitment To The .
Community Bv !\;ew United \.lotors
\lanufacturing, lne. - April 1.5, 1994,
Fremont, California."
~~D~__~JF":"~.:Kl'UI~""''':'''':~,;,u;:;
-
.._....~..K................
county of whi;:h Bakersfield is the seat,
the "Tree Foundation" is a private-public
partnership made up of community, gO\"
emment and business leaders who are
vitally interested in Kern County's envi-
ronment.
Less than one year after its birth, Tree
Foundation of Kern volunteers were hard
at work. On Arbor Day 1994 they plantec
a grove of honey locust trees at the
entrance to Meadows Field (Bakersfield's
airport). The event drew active support
from the community as well as from the
local media, which was on hand for what
promised to be the first of many conunu-
nity-based environmental projects for the
Geo Tree Program's newest partner.
r....b.Ol'WI:C' i.~~.~----
:OJ;. ;:0,' ~
NEW "LIVING CLASSROOM"
PROJECT OFF TO A STRONG
START
:\ imnicht Chenolet/Geo in
Jacksonville, Florida, recently
_ became the first Chevrolet de.ll-
ership to participate in a new and excit-
ing hands-on environmental education
program called "Uving Classroom." To
start, a trained historian pro\'ides the
class with an overview of local historic
figures and events.
ThE' second phase of the program is
an actual tree-planting ceremony using
seedling trees grafted from famous and
historic trees related to the people and
events studied in the classroom. The
beautiful, oxygen-giving, shade-provid-
L"1g trees, \\'rjch 3.150 serve as ~ piece of
living history, make for a truly unique
and very memorable learning exp~ri-
ence.
In Jacksonville, through the efforts of
Bill Nimnicht, and his association with
the Gee Tree Program, some 400 school
chilcren became a little closer to history
,:lid .1 I' 't .', "'l'r t" \ 1,ltlwr E,lrth, Tlw
\(IUIl~ :':'.i.knb ni \l'nt'tiil Elcmentarv
~"'ili~i~,,'kd in the Li\ing CI"ssrnomOby
pl.1t1t;n~ :1 bl'Jutiful Tid,d B.lsin Cherry
Trl"::', Thl'se historic treL':' \\'ere dchlallv
i~r,lH('d fn1n1 trL'l'~ prL'~l'ntL'd to the US:
by the Em~"'\eror of Japan in the nine-
lL'enth ct'!'1rurvo
The f(<lowing poem was written and
recited h' the students of Venetia
Elementarv School:
We get these seedlings frQm
across the nation.
Planted here for our education.
These trees 811 come from
famous piaces,
V-lith stories that bring smiles to
our faces.
As we watch our seedlings grow,
We'd like to thank our sponsor
... Geo!
~
19S4 Geo
AWARD FOR
ENVIRONMENTAl
EXCELLENCE
FOR URBAN
FORESTRY
GROUPS
Top Participating
Chevrolet/Geo Dealer
To Be Honored As Well...
T n its three years of existence, the G" ,
; Award for Environmmtal E.xcellen;
~ has become one of the most presti-
giOllS awards among volunteer non-prl '
~m'ironmental groups. Any non-prori!
SOl(c)3, volunteer-based tree-planting
organization that has been in operati(.r. '
at kast r,\o years ~ eligible for nomin.:'-
non.
for 199-1, a.'1 additional "Gee'"
slated to be presented to the
ChcHolet/Geo dealer who is
deemed to have made the most
outst;mding contribution to the
Ceo Tree Program for the year,
In the words of Jeff Hurlbert,
general marketing manager oi t:-
Chevrolet/Ceo Division of Genl
Motors: "The recognition and
prestige will mean a great deal tc
the dealer who is awarded the f.~
'Gee'. Our dealer bodv has 00..':-
very helpful in contributing to !:
success of the Geo Tree Progr,:rr,
It's most appropriate that we
honor them as well."
CHEVROLET/Geo
VOLUNTEERS,GUESS?AND
TREEPEOPLE COMBINE TO
REPLANT BURNED-OUT
CIRCLE X RANCH AREA,
MALIBU, CA
Scars from the Malibu/ll1ousand
Oaks fires of last October
recehoed a healing planting on
the morning of Saturday, May 7, 1994,
from 200 volunteer "foresters"
(employees, families, and fnends)
fn)m GUESS?, Chevrolet \tIotor
Di\'ision in Thousand Oaks and
TreePeople. led by Chevrolet/Geo
Regional \1anager \lei] Perkins,
Assistant Regional Manager Jim Chester
and their wives, Sherrie and Norine,
the volunteers all "truckpCX'led" up to
the Circle X Ranch campground in the
Santa \10nica Mountains Natilmal
Recreation .-\rea to take part in a combined
tr~-pl.1ntins effort.
The t::ager vohmteers planted some 350
natin: trees in a public use area near the
center (If the original firestonn. This was an
.1rea frt'\'iously covered by non-native trees.
"Tne ste,,'ards!1ip of GUESS? and
Chc\wlet/Ceo Em-irnnmental in both
lind, :\\ritins thlOl'\'ent ,1nd bringing their
l'm~,,,l:-'ees ,md families to join with our vol-
llnk...'r~ in this ~.I,1ntiI1b puts a human face
,In t:,cir C()t11p,lnic~' dc't'j... and Lmgoing com-
mitment to the l'J1\oironment," stilted
Tred\'ople illunder ;\ndy lipkis.
Six regional dealer finc1lists J..r,
their guests will be flown to ,
Washington, D.C., on Novemb\.::
3rd to take part in the awards Ct"
mony. Each of those dealers \\'i:
receive a $1,000 grant to bI? gin::'
that dealer's non-profit emoirOI,-
mental partner groupo
!1) 1994 THE PEARLMAN GROUP INCORPOP..
~~..~.z-..:;o.....o:.A ila_.~"=W;.a.
, -
-~ ozo_.~ns;~~'_:~~~"'$~~.;";..L"~-='~"Il""""'=-'''~''-'''''.:_'W''''oW!!"'~;' ,.'.. R..:cyclcJ Paper . ~
... .
'. - ---_.-/
T errabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 305
36. Jan Pont. 111 Belmont Avenue and Don Shattuc. 907 W. Cardinal Drive.
Sunnyvale; March 20. 1996
36.01 The city does not have authority to grant access to the property. Access to the
property must be obtained from the property owner, SunChase G.A. California I, Inc.
36.02 The commenter feels that there was inadequate notice and availability of the DSEIR for
review and comment. Opportunities for public involvement in the SEIR process have
included an initial public scoping meeting on August 4, 1995 and a Planning
Commission public hearing on February 1, 1996. Each property owner within 300 feet
of the proposed project and every individual and organization which has expressed.
interest in the project and has been placed on the project mailing list has also been
mailed notice of the public scoping meeting and the public hearings. Notice of the
public scoping meeting and the public hearings were published once a week for four
weeks in, the local newspaper. The DSEIR was circulated for public review and
comment on January 5, 1996. Before the required 45-day review period on the DSEIR
ended, the City Council extended the public review period by 30 days to March 20,
1996.
36.03 The City Council had already extended the original 45-day review period by 30 days, to
March 20, 1996. The commenters additional written comments were submitted on
April 8, 1996 and are included herein as comment letter no. 37.
WP51 1548 IFSEIRI F-II. 548
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Terrabay Project
City of South San Francisco
October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 307
37. Kathleen S. Dunnina. 46 San Jose Avenue. Pacifica; March 18. 1996
37.01 Please see responses to comments 1.02 and 1.07.
37.02 Please see response to comment 1.03.
WP51 \548\FSEIRIF-II,548
1~
RECEIVED
APR - 8 1996
PLANNING
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T errabay Project
City of South San Francisco
. October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 330
38. Jan Pont, 111 Belmont Avenue and Don Shattuc, 907 W. Cardinal Drive.
Sunnyvale; April 7, 1996
Note: This comment letter was received by the city on April 8, 1996, after the close of the
public review period. (The City Council had already extended the original 45-day review
period by 30 days, to March 20, 1996.)
38.01 Most of the environmental mitigation measures recommended in the DSEIR will be
subject to effective monitoring through the city's normal development review
procedures, including precise plan and subdivision applications, design review
approval, building permit approval, and associated plan check and construction period
field inspection procedures. In addition, to satisfy CEOA Section 21081.6, a
documented record of implementation will be necessary. Section VIII (pp. 269-271) of
the DSEIR contains a mitigation monitoring checklist that includes spaces for
identifying: (1) each mitigation measure included in the SEIR; (2) the party responsible
for implementing that mitigation measure and any related requirements with respect to
the timing of implementation; and (3) the party responsible for performing mitigation
monitoring plus information on the type and required timing of the monitoring
procedures.
38.02 Please see responses to comments 8.01 and 8.02.
38.03 With respect to the costs to the city of the mitigation measures recommended in the
DSEIR, the costs of mitigating the identified significant impacts of the project will be the
responsibility of the project applicant, either directly or through normal cost recovery
procedures used by the city. Many mitigation measures recommended in the DSEIR
(e.g., land use, soils and geology, drainage and water quality, vegetation and wildlife,
cultural resources, noise, etc.) require on-site improvements and/or project design
provisions that would be the implementation and full cost responsibility of the applicant,
developer, builder or future project homeowners association(s). Other recommended
measures (e.g., traffic mitigations) require off-site improvements in the project vicinity
that will require implementation and full funding or a proportionate fair share cost
contribution by the applicant.
With respect to the fiscal impacts (municipal cost-revenue implications) of the project,
Section 15131 (a) of the CEOA Guidelines states: "[e]conomic or social effects of a
project shall not be treated as significant effects on the environment." CEQA Section
15131 (c) allows the Lead Agency to present economic or social information in
whatever form the agency desires to allow such factors to be considered in reaching a
decision on a project. Therefore, the fiscal effects of the proposed project represent
non-environmental issues which are not identified in the EIR. The fiscal effects of the
proposed project (Le., revenues and capital benefits, service issues and costs, and
conclusions as to whether the project would "pay its own way") were initially evaluated
in 1981 during preparation and consideration of the specific plan. Please refer to the
San Bruno Mountain: South Slope Fiscal Impact Study, September, 1981, by Recht
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 331
Hausrath & Associates, available at the City of South San Francisco, Department of
Economic and Community Development.
38.04 The open space impacts of the project are described on DSEIR p. 74. As determined
by the previous 1982 EIR, the project-related conversion of 200 acres of open space
on the 332-acre project site would constitute a less-than-significant impact which would
be offset by dedication of the remaining 132 acres to San Mateo County as permanent
open space for inclusion in the San Bruno Mountain State and County Park. The
project would also contribute to cumulative reductions in the amount of local and
regional open space. These cumulative impacts would be mitigated by the provisions
of the HCP for dedication of open space.
. The parks and recreation impacts of the project are discussed in DSEIR Section IV.G.
The city currently provides about one acre of traditional developed city parkland for
every 1,000 residents, and 3.15 acres per 1,000 population if existing school grounds
are added to the developed parkland. This is substantially below the national standard
of five acres per 1 ,000 residents and below the amount provided by other nearby
younger cities. The project would make considerable contributions to city parks and
recreation facilities. In addition to the open space dedication provisions described
above, the project parks and recreation improvements are summarized in Table 26 on
DSEIR p. 207.
38.05 The potential supplemental impacts of the site's geologic/geotechnical conditions on
project structures and improvements are reevaluated in Section IV.D of the DSEIR (pp.
155-172) and warranted supplemental mitigations are recommended.
38.06 Please see response to comment 26.01.
38.07 The trip generation projections for each of the three project phases presented on
DSEIR pp. 115-118 are based on trip generation rates from the 1991 and 1995
Institute of Transportation Engineers (ITE) Trip Generation manual, 5th Edition. The
trip generation projections represent a conseNative, "worst case" scenario which
assumes no use of transit by project residents, employees and visitors, and no
application of transportation demand management measures to the project (e.g., the
carpool, carpool preferential parking, flex-time, and limousine seNice provisions
contained in the specific plan or other trip reduction measures).
38.08 The future traffic projections used in the DSEIR traffic analysis, which are based on
projections contained in the East of 101 Area Plan EIR, the 1993 Brisbane General
Plan Circulation Element and the EI Camino Corridor Redevelopment Proqram EIR, do
take into account truck traffic. Also, as traffic volumes and related congestion on the
project vicinity roadway network increase over time, truck trips will become a smaller
component of the overall traffic volumes because trucks can be expected to change
the time of their trips to not be delayed by the increased congestion. It is also worth
noting that the congestion and a portion of the truck volumes obseNed in the recent
WP511548\FSElRIF-II.548
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 332
additional traffic counts performed by the SEIR transportation planning consultant at
the Oyster Point interchange are due to the construction period diversion to the Oyster
Point interchange of Grand Avenue interchange traffic bound for northbound US 101.
The Grand Avenue interchange US 101 northbound on-ramp has been closed most of
the day and, in particular, during the AM peak commute traffic period due to
construction.
38.09 Section IV.D Geology of the DSEIR (pp. 155-172) addresses small, localized, post-
grading landslides, erosional gullies, and other forms of continued surficial instability.
Please also see responses to comments 33.63, 33.64, 33.65, 33.66, 33.76 and 33.75,
and DSEIR errata pp. 169-172 in Section III herein.
38.10 Ongoing operation and maintenance of private facilities and common areas within the
project, including maintenance of project geotechnical features, would properly be the
responsibility of future project property owners (e.g., through the master homeowners
associations and individual residential neighborhood homeowners associations). The
project CC&Rs contain such maintenance provisions. These provisions would be
disclosed to potential purchasers of project homes.
38.11 As noted on DSEIR p. 174, "groundwater" on the project site-- and the "natural spring
and marsh wetland area" referred to in the commentnare considered to represent
shallow seepage of infiltrated surface water rather than a true water table. A
catchment basin has been installed at the base of the ravine referred to in the
comment to catch runoff from the slopes above this "Goat Farm" portion of the project
site. The catchment basin drains runoff into storm drain trunk lines which extend
through the project site and under Sister Cities Boulevard to US 101. The catchment
basin and storm drain trunk lines are expected to adequately drain the "Goat Farm"
area.
38.12 Please see response to comment 26.03.
38.13 Slope stability and engineered fill are addressed in project geotechnical documents on
file with the city and summarized in the DSEIR (pp. 155-172). Please also see
responses to comments 33.72,33.73 and 33.77.
38.14 Please see response to comment 1.13.
38.15 Please see response to comment 1.13.
38.16 Please see response to comment 1.13.
38.17 Please see response to comment 24.01.
38.18 Please see response to comment 26.01.
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 333
38.19 The comment refers to a botanical garden that is to be developed at the entrance to
San Bruno Mountain State and County Park off of Guadalupe Parkway. Existing native
plants in the Phase II and Phase III portions of the project site are already being used
to collect seeds to use in the Phase I reclamation effort. Seeds from sensitive native
plant species in these areas could also be used for the proposed botanical garden, as
suggested by the comment. Transplantation of the plants themselves, however, is
impractical and has proven unsuccessful in previous attempts on the mountain.
38.20 Please see response to comment 18.03.
38.21 The 1982 EIR (p. 116) notes that the project would consume an average of about
320,370 gallons of water per day, or approximately 0.32 million gallons per day (mgd).
The DSEIR (p. 211) notes that the water service impacts described in the 1982 EIR
(i.e., water consumption rate, etc.) remain generally unchanged, The California Water
Service Company (CWSC) has delivered a letter of assurance to the city that commits
CWSC to providing water service to the project.
38.22 The noise impacts of the project are described on DSEIR pp. 215-230. The
supplemental mitigation measures recommended on DSEIR pp. 228-229 for noise
impacts from traffic (Supplemental Impact N-1), aircraft overflights (Supplemental
Impact N-2), and project construction activities (Supplemental Impact N-3) would
reduce noise levels on the project site and adjacent residential areas to within the land
use/noise compatibility standards established by the state and set forth in the city's
Noise Element.
38.23 Please see response to comment 33.31.
38.24 Please see response to comment 8.02.
38.25 Comment noted. Please see response to comment 1.07.
38.26 Please see responses to comments 8.01 and 8.02.
WP511548IFSEIRIF-/J_548
T errabay Project
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October 23, 1996
Final SEIR
II. Responses to Comments on the Draft SEIR
Page 334
WP51 \548\FSEIR\F-II_548
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October 23, 1996
Final SEIR
III. Revisions to the Draft SErR (Errata)
Page 335
III. REVISIONS TO THE DRAFT SEIR (ERRATA)
The following section includes all revisions to the Draft SEIR made in response to public and
Lead Agency comments received during the Draft SEIR public review period. The section
incorporates by reference the separate revised Transportation section that was recirculated.
and is included in a separate document' with its own additional responses to public review
comments.2
All text revisions in the following errata section are indicated by an "r" in the left margin next to
the revised line. All of the revised pages supersede the corresponding pages in the Draft
SEIR. None of these changes represent a significant increase in impact or a significant new
impact or mitigation need not already discussed in the Draft SEIR (with the exception of
revisions to the separate Transportation section).
'Final Supplemental Environmental Impact Report for the Proposed Terrabav Specific Plan and
Development Aqreement Extension--Revised Transportation Impact and Mitiqation Findinqs; Responses
to Comments on the Revised Findinqs; October 1996.
2A revised DSEIR transportation analysis was performed in response to comments received during
the public review period on the DSEIR. The revised traffic analysis identified one unavoidable
significant adverse impact--Le., an impact for which no mitigation is available--and three new mitigable
significant impacts, that were not identified in the DSEIR. Therefore, in conformance with Section
15088.5 of the CEQA Guidelines, the revised Transportation section was recirculated for a 30-day
public review and comment period on August 30, 1996.
WP5115481FSEIRIF-I/I.548
Terrabay- Project
City of South San Francisco
October 23. 1996
Final SEIR
III. Revisions to the Draft SEIR (Errata)
Page 336
WP51 \548\FSEIRIF-/II.548
Terrabay Project
City of South San Francisco
October 25, 1996
Table 1
PROJECT SUMMARY DATA
Final SEIR Errata
Table 1
Page ii
PROJECT NAME:
SITE LOCATION:
SITE AREA AND
r PARCELlZATION:
CURRENT GENERAL
PLAN DESIGNATION:
CURRENT ZONING:
EXISTING LAND USE:
PROPOSED LAND USE:
CIRCULATION:
REQUESTED
APPROVALS:
APPLICANT:
PROPERTY OWNER:
Terrabay Specific Plan and Development Agreement Extension
On the lower southeastern slopes of San Bruno Mountain west of
Bayshore Boulevard and north of Hillside Boulevard and Sister
Cities Boulevard in the city of South San Francisco.
Assessor's Parcel Numbers Approximate Acreaqe
Book 007; Blocks 590, 600, 611, 332 (total)
612,620,630,641,642,650; all
parcels inclusive
Planned Commercial, Low-Density Residential, Medium Density
Residential, and Open Space
Terrabay Specific Plan District
Primarily open space, partially graded with some improvements
installed.
The applicant is proposing phased residential and commercial
development in accordance with the approved Terrabay Specific
Plan and development agreement. Phase I, currently under
construction, consists of 125 single family detached homes, 168
townhomes and related community facilities and infrastructure. The
ultimate characteristics and timing of subsequent phases II and III
are more conceptual. The specific plan provides for Phase II
development of up to an additional 428 residential units and Phase
III development of up to 44 acres of commercial uses.
Access to Phase I is provided via one connection to Hillside
Boulevard opposite Jefferson Street. Phase I internal circulation is
via one public street and several private roads. Phase II access
would be at one connection to Sister Cities Boulevard; internal
circulation would be via one public street and several private roads.
Phase III access would be at Bayshore Boulevard; Phase III internal
circulation would be expected to be served by a single private road.
The applicant is requesting extension of the termination dates of the
Terrabay Specific Plan and development agreement to allow for
completion of Phase I development of 125 single family detached
homes, 168 townhomes and community facilities. and eventual
development of specific plan Phases II and III.
SunChase G.A. California I, Inc.
SunChase G.A. California I, Inc.
SOURCE: Wagstaff and Associates, November 1995.
WP51\548\FSEIRI TABLE1-R,548
T errabay Project
City of South San Francisco
October 25. 1996
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Page 26
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II. Summary
Page 32
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(/):J<(
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City of South San Francisco
October 25, 1996
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Page 33
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City of South San Francisco
October 25, 1996
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II. Summary
Page 34
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T errabay Project
City of South San Francisco
October 25, 1996
Table 2
TERRABAY SPECIFIC PLAN LAYOUT CHARACTERISTICS
Final SEIR Errata
III. Project Description
Page 52
Number of
Acreaqe' Dwellinq Units
Residential
Terrabay Village
Townhomes 27.8 1812
Terrabay Park
Single Family Detached 38.8 1362
T errabay Woods
Townhomes (west) 11.1 57
Townhomes (east) 21.1 143
Terrabay Commons
Terraced Units (west) 9.3 58
Terraced Units (east) 7.0 71
Terrabay Point
Condominium Units -1.!A 99
Subtotal 126.5 745
Community Facilities Areas
Child Care Center & Tot Lot 0.5
Recreation Center Complex 3.2
r Public Street 20.13
Linear Park 1.3
Linear Greenbelt ~
Subtotal 29.6
Commercial
Office Condos & Health Club 11.3
Hotel 17.3
Tech Trade Center ~
Subtotal 43.8
Subtotal Developed Acreage 199.9
Open Space to Be Dedicated to
the Habitat Conservation Area 132.1
TOTAL PROJECT SITE 332.0
Dwelling Units
per Acre
6.5
3.5
5.1
6.8
6.2
10.1
8.7
5.9
r SOURCE: Terrabay Specific Plan Working Document, January 1984.
r 1 Acreages presented are from the 1984 Terrabav Specific Plan Workinq Document. Some acreages
r were corrected in the subsequent Phase I Precise Plan (1989). Similar additional corrections in
acreage may occur with future approval of precise plans for subsequent project phases.
2 The specific plan (1982) and development agreement (1988) allow up to 181 townhomes in Terrabay
Village and 136 single-family detached homes in Terrabay Park. The subsequent Phase I Precise Plan
approval (1989) allows up to 168 townhomes and 125 single-family detached homes_
r 3 Includes rights-of-way for Hillside Boulevard Extension and South San Francisco Drive.
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The master and/or neighborhood homeowners associations would be responsible for all
landscape maintenance, except for landscaping within the linear park, at Fire Station 5 and
the Hillside Recreation Center, and within public roadway rights-of-way, which would be
maintained by the city.
i. Overall Gradinq Approach. The project grading concept would include stepped building
pads up the swales, leaving the knolls intact or preserving their distinct land form as much as
possible. Earth slopes would generally be graded at two horizontal to one vertical (2:1).
Exceptions include the Sister Cities Boulevard cut near Terrabay Point and several other small
areas where steeper slopes are proposed to preserve existing land forms. The plan states
that these graded areas are located adjacent to private roads, driveways, and buffer areas
where structures are not proposed. Slopes would be terraced and drainage ditches provided
to control debris fall and surface drainage.
Approximately 1,870,000 cubic yards of cut and 1,900,000 cubic yards of fill are proposed,
requiring approximately 50,000 cubic yards of imported fill.
Rough grading operations for Phase I and a portion of Phase II have been completed,
including grading of Terrabay Village, Terrabay Park, and a portion of Terrabay Woods on the
r west end of the project. The grading for Sister Cities Boulevard and rough grading of South
San Francisco Drive were included in this completed grading phase.
It is anticipated that the second phase of the rough grading operations would encompass the
remainder of the residential and commercial development areas. Winterization and erosion
control provisions are proposed to protect graded areas during the phased grading period.
j. Drainaqe. Runoff from slopes above the project site, as well as from the project's on-site
drainage system, is to be intercepted and transported in three separate storm drain trunk lines
(one collecting runoff from residential portions of the project which has already been
constructed; one from the offices and health club complex; and one from the hotel and trade
center complex) and directed under US 101 to the existing drainage ditch which parallels the
freeway, and on to the bay.
k. Water. Water service is to be provided by California Water Service from the San
Francisco Water District water main in Bayshore Boulevard at a point near the Sister Cities
Boulevard/Bayshore Boulevard intersection. Booster pumps will lift water to the higher
elevations of the project and to a new 1.5-million-gallon storage tank, which has been
constructed at the 400-foot elevation near Terrabay Park. California Water Service will
assume maintenance of the water tank and service mains.
I. Sewer. A new off-site parallel sewer interceptor has been constructed along a segment
of Airport Boulevard between Sister Cities Boulevard and North Canal Street to carry project
wastewater flows. On-site gravity sewer mains and interceptors have been constructed for
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'". Project Description
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Phase I, and will be constructed for Phases II and III, connecting to the city sewer system in
Airport Boulevard.
2. Phase I Development
The currently proposed completion of Terrabay Phase I will consist of continued development
to completion of the Terrabay Village and Terrabay Park neighborhoods at the western end of
the site.
a. Phase I Components Already Completed. Grading has been completed and most sewer,
r water, underground utilities, street lighting and storm drainage improvements have been
installed for Phase I. Sister Cities Boulevard has been constructed and the segment of
Hillside Boulevard fronting the site has been widened. South San Francisco Drive has been
constructed to full city standards through Terrabay Park, and as an interim paved construction
vehicle roadway for the remainder of its length. Fire station 5 has been constructed and is in
operation. Playfield improvements have been installed at Hillside Elementary School.
b. Proposed Lot Layouts and Home Desiqn Characteristics. The precise plans approved for
the Terrabay Village and Terrabay Park neighborhoods specify the following:
(1) Terrabay Villaqe. The approved Terrabay Village precise plan consists of 168
townhouse lots developed at densities of approximately 6.5 units per acre at the westernmost
end of the project site adjacent to Hillside Elementary School. The lots would be laid out in
hillside tiers along five branching cul-de-sacs. There are to be five townhouse building types
with two, three or four units each ranging in individual floor area from 1,520 square feet to
1,964 square feet, in a mix of five floor plan types with two or three bedrooms. Downslope
units would vary from upslope units. All units would feature small private yards or decks.
(2) Terrabav Park. The approved Terrabay Park precise plan consists of 125 single-family
detached residences arranged in clusters of three and four at densities of approximately 3.5
units per acre. The lots are laid out in hillside tiers along five branching cul-de-sacs. Four
floor plans are proposed ranging in size from 2,292 to 2,677 square feet, with three or four
bedrooms.
D. PHASING AND CONSTRUCTION SCHEDULE
1. Phase I
Phase I construction began in 1989. Between 1989 and 1995, most Phase I rough grading
and infrastructure improvements were completed. The project sponsor has stated that
construction of the Phase I residential units is expected to commence in 1995 and to be
completed in 2000.
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III. Project Description
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2. City of Brisbane
r City of Brisbane approval would be required for implementation of any elements of the project
r including any mitigations for traffic impacts involving Bayshore Boulevard, which are within the
Brisbane city limits.
3. San Mateo County
Because the project site was located within unincorporated San Mateo County prior to city
annexation in 1983, the county acting as "Lead Agency" certified the 1982 EIR and jointly
adopted the Terrabay specific plan with the city. The county also issued the grading permits
and encroachment permits for Phase I grading operations and geotechnical repairs in 1988.
Grading and encroachment permits would be required from San Mateo County for any grading
activities for subsequent phases which may occur within county jurisdiction. As the HCP
operator, the county will also make compliance determinations for each subsequent phase
precise plan.
4. South San Francisco Unified School District
In 1988, the South San Francisco Unified School District approved play field improvements at
the Hillside Elementary School site. No additional school district approvals would be required
for implementation of Phase I or subsequent phases.
5. Joint Powers Authority
In 1988, the city and county also adopted an agreement establishing a joint powers authority
(JPA) to oversee construction and maintenance of catchment basins on the project site and
access roads (see section IV.E of this SEIR, Drainage and Water Quality). The JPA has
approved the design of the catchment basins for Phase I and has overseen their construction,
but has yet to accept them and assume ongoing maintenance. The JPA (or the county, if the
JPA is disbanded and its responsibilities turned over to the county) must also approve design
and construction, and accept responsibility for, catchment basins proposed as part of
subsequent project phases.
6. Local AQency Formation Commission
The San Mateo County Local Agency Formation Commission (LAFCo) approved city
annexation of the project site in 1983. No additional LAFCo approvals would be required for
implementation of Phase I or subsequent phases.
7. ReQional Water Quality Control Board
The U.S. Environmental Protection Agency's National Pollution Discharge Elimination System
(NPDES) has been established to control the discharge of pollutants into water bodies. The
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IVA Land Use
Page 67
A. LAND USE
This section of the SEIR addresses the various land use compatibility issues raised by the
proposed project. Existing on-site and surrounding land use and open space patterns are first
described and updated, followed by a summary of the land use impact and mitigation findings
of the 1982 EIR. To the extent necessary, the section then reevaluates (1) on-site land use
impacts; and (2) project compatibility with the adjacent single family residential neighborhoods
to the south, major arterials and the freeway, and with nearby commercial and school uses.
1. SETTING
a. Onsite Land Uses
(1) Existinq Uses and Easements. Existing on-site and surrounding land use characteristics
are presented in Figure 5. The 332-acre project site consists of gently rolling to steeply
sloping grassy terrain. Most of the site remains undeveloped, although substantial site
modifications, including substantial grading have been completed since 1982 in preparation for
Phase I.
Three billboards and two San Francisco Water department easements containing Crystal
Springs Water Mains NO.1 and NO.2 are located on the site along Bayshore Boulevard. A
Pacific Gas and Electric Company (PG&E) easement traverses the site in a southeast to
northeast direction near the South San Francisco Drive/Sister Cities Boulevard intersection
(see Figure 2). The easement contains three electrical transmission Iines--the Standard 60kV,
the Sierra 115kV and the San Francisco 115kV Iines--which serve San Francisco and deliver
power from the city and county of San Francisco's Hetch Hetchy system. The easement also
contains a natural gas transmission line (Line 101).
(2) Phase I Gradinq and Habitat Restoration. Between 1989 and 1995, approximately 80
acres of the site were graded and site improvements constructed to prepare the site for Phase
I development. Modifications completed since 1982 consist of all grading needed for Terrabay
Village and Terrabay Park, including all building pads and roadways, except .for finish grading
of individual home sites. Limited grading has also occurred in the Phase II areas of the
r project site in conjunction with construction of Sister Cities Boulevard and South San
Francisco Drive, grading of the promontory knoll near the Sister Cities Boulevard/Bayshore
Boulevard intersection.
Substantial slope stabilization and geotechnical repair work has also been completed (see
section IV.E, Soils and Geology, for a more complete description of Phase I geotechnical
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repairs). Of the 80 acres of the site that have been graded, approximately 30 acres have also
undergone habitat restoration activities in accordance with the Terrabay Phase I reclamation
plan approved in 1988 (see section IV.G, Vegetation and Wildlife, for a more complete
description of those habitat restoration activities).
(3) Boundary Adiustment. During grading for Phase I, a minor boundary adjustment was
made in the area of the site to be dedicated to San Mateo County as permanent open space.
The area of the project site proposed to be permanently disturbed was increased by 0.38-acre
to accommodate needed geotechnical repairs encountered during Phase I grading.
(4) Phase I Roadway Improvements. Site roadway improvements constructed since 1982
include construction of Sister Cities Boulevard between its intersections with Hillside
Boulevard and Bayshore Boulevard, and widening of Hillside Boulevard and creation of a local
traffic frontage road between Sister Cities Boulevard and Lincoln Street (the segment fronting
the project site). South San Francisco Drive has been constructed to full city standards within
the Phase I portion of the project, and as a paved construction vehicle roadway for the
remainder of its length.
(5) Other Infrastructure Improvements. Drainage improvements installed since 1982 include
four large catchment basins needed to intercept drainage from the slopes of San Bruno
Mountain above the project, the on-site drainage system serving Phase I, and the trunk line
which will intercept drainage from Phases I and II and from the catchment basins. Onsite
r water improvements completed to date include the connection by the California Water Service
r Company to the San Francisco Water Department pipeline, construction of the main water
transmission line and water distribution lines for Phase I, and construction of the 1.5-million-
gallon water storage tank above Terrabay Park. Sewer improvements installed since 1982
include all wastewater collection and interceptor lines needed to serve Phase I.
Fire station 5 has also been constructed on South San Francisco Drive near the project
entrance at Jefferson Street, and is now operational.
b. SurroundinQ Land Uses
The relationship of the project site to surrounding land uses is illustrated on Figure 5, and
described below.
(1) North. San Bruno Mountain State and County Park, a 2,064-acre regional park, is
located immediately north of the project site. Although under both state and county
ownership, the park is operated by San Mateo County as one facility. The county owns 1,766
acres, including the southeast ridge above the project. Improvement plans for the southeast
ridge area are limited to trails. The park, like the site and all of San Bruno Mountain, is also
part of the San Bruno Mountain Habitat Conservation Plan (HCP) area. The city of Brisbane
is located on the north side of the southeast ridge.
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IV.C. Transportation
c. TRANSPORTATION
Because of the substantial nature of the revisions, the revised Transportation chapter was
recirculated for additional public review and comment on August 30, 1996. The revised
transportation chapter plus associated responses to all comments received on the revisions
during the additional 45-day review period, is included in a separate document, entitled Final
Supplemental Environmental Impact Report for the Proposed Terrabay Specific Plan
and Development Agreement Extension, Revised Transportation Impact and Mitigation
Findings/Responses to Comments on Revised Findings, which is available for public
review at the offices of the City of South San Francisco Department of Economic and
Community Development, 400 Grand Avenue, South San Francisco, CA (phone: 415-877-
8535).
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IV.D. Soils and Geology
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(b) Aspects of the existing project site identified since release of the 1982 EIR, such as
additional underlying geologic soils conditions, or regional seismic conditions, that may expose
people and improved property to significant hazards or would present significant engineering
or construction limitations.
r (2) Phase I Supplemental Impacts
r (a) Small, Localized, Post-Gradinq Landslides. In the period since grading for Phase I was
completed, some small, localized landslides up to 40 feet wide and 100 feet long have
occurred on cut and fill slopes throughout the graded area. Some of these landslides blocked
or damaged downslope improvements, including v-ditches and catchment basins. These
slides and affected downslope areas have been recently repaired. However, similar, small,
r localized landslides can be expected to occur in the future on the perimeter slopes of the
r project. Such small, localized slides are not considered to be a significant hazard to proposed
downslope residential development; rather, their cleanup is expected to be part of the overall
r project maintenance program.1 Two localized slides have also occurred on the split level lot
r portion of the development. These slides have been repaired and care must be taken to
r control surface drainage to help minimize the potential for similar future slope failures.2
r (b) Erosional Gullies. Numerous erosional gullies, some up to four feet wide and three feet
deep, have formed on cut and fill slopes throughout the Phase I grading area, resulting in
downslope sedimentation of v-ditches and the storm drainage system. Repairs to date, as
prescribed by the applicant's geotechnical consultant, have consisted of over-excavation of
slope materials below the depth of the gullies, and rebuilding the slopes to original grade
using engineered fill. The repaired slopes have then been hydroseeded and surface water
has been directed away from the slope. However, based on EIR geotechnical consultant
observations and discussions with the city's geotechnical consultant, it is evident that this
problem persists on the cut slopes. Seepage was not apparent at the time of our field
investigation. Observations of the city's geotechnical consultant suggest that the problem is
related to perched groundwater daylighting in the cut slopes, causing piping and erosional
gullies. Gullying persists on some fill slopes due to surface water flow over the slope. The
threat to downslope improvements presented by the continued erosion of the cut and fill slope
faces and the formation of gullies is considered to be a potentially significant adverse impact
(Supplemental Impact G-1).
r (c) "Goat Farm" Cut Slopes. Standard geotechnical practice recommends cut slope
inclinations no steeper than 2H:1 V within alluvial or colluvial materials, and shallower slopes
are commonly recommended. Phase I grading cut slope inclinations in alluvial and colluvial
materials at the "Goat Farm" cut slopes are as steep as 1.5H:1 V (horizontal to vertical).
1 Eric McHuron, McHuron Geosciences (city's geotechnical consultant), personal communication;
November 6, 1995.
r 2pSC, 1995.
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Relatively shallow, localized "earthflow-type" failures have occurred on the "Goat Farm" area
cut slopes and will likely continue to occur. There is also a 10- to 15-foot-thick wedge of
granular material near the catchment basin which has been installed at the base of the "Goat
Farm" cut slopes, which could slump if it were to become saturated or were subjected to
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strong seismic groundshaking.' However, a geotechnical evaluation by the applicant's
geotechnical consultant to address the consequences of the Phase I "Goat Farm" cut slopes
within alluvial and colluvial materials concluded that the completed cut slopes are acceptable
r from a geotechnical point of view.2 Debris could reach the street and catchment basin at the
base of the cut slopes. The applicant's geotechnical consultant concluded that if such minor
slumping and erosion occurs in the future, the existing street will provide an adequate "buffer"
area for collection and clean-up of debris, and such collection and clean-up should be
r considered as part of an overall project maintenance program.3 The city's geotechnical
r consultant concurs that minor slumping on the cut slope may continue to occur, but poses no
r significant hazard to downslope residential development and is appropriately considered a
r maintenance problem. However, temporary blockage of the adjacent street due to potential
r slumping or erosion may impair or block emergency access to several single family homes.
r (d) Landslide D. As previously explained, lower and weaker shear surfaces discovered at
Landslide D during the Phase I grading suggests a larger and deeper landslide. Recent
evaluation of Landslide D suggests that the landslide is only marginally stable in its present
configuration. A remedial repair plan for Landslide D was approved by the city on October 6,
1995.4 The plan consists of removing the upper 10 to 20 feet of the landslide mass,
constructing a shear key at the base of the landslide mass, and providing subdrainage
improvements including two additional midslope keyways with subdrainage.5 Repair of
Landslide D has not yet been completed. If Landslide D is not successfully repaired,
continued downslope movement could expose project residents and improvements to geologic
hazards and would be considered a significant adverse impact (Supplemental Impact G-2).
r (3) Phases II and III Supplemental Impacts. In some areas of phase I, geologic conditions
r were substantially different from those anticipated and have required subsequent additional
r geotechnical reevaluation, mitigations and repairs. Similar "buried valleys," deep landslide
r deposits, and other unconsolidated materials may be encountered during grading for Phases II
r and III and will need to be addressed as part of detailed design-level geotechnical
r investigations for these subsequent project phases.
'PSC, 1991.
2lbid.
3pSC, 1991.
4City of South San Francisco, 1995.
5Geo/Resource Consultants, Inc., 1995(b).
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IV.D. Soils and Geology
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4. SUPPLEMENTAL MITIGATION NEEDS
r a. Phase I Supplemental MitiQation Needs
r (1) Small, Localized Landslides. The small, localized landslides occurring in the Phase I
graded (cut and fill) areas have been recently repaired. Similar small, localized landslides
r along the perimeter of the development can be expected to occur in the future. These
landslides are not considered to be a significant hazard to proposed downslope residential
r development and can be appropriately addressed as a maintenance problem.' Include the
clean-up and repair of small, localized landslides occurring in the Phase I and future project
phase graded areas as a specific part of the overall project maintenance program.
, Eric McHuron, McHuron Geosciences (city geotechnical consultant), personal communication;
November 6, 1995.
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r (2) Erosional Gullies. (Supplemental Impact G-1) Repair erosional gullies on cut and fill
r slopes. Such repairs should be completed pursuant to City approval after submission of
r studies and plans by the applicant. The applicant is currently working with the City to repair
r certain erosional gullies under plans approved by the City. The applicant should complete all
r repairs to erosional gullies in accordance with the plans approved by the City.
r Also, remove silt and debris from v-ditches and storm drains. Assign responsibility to the city
r or the project homeowners association to periodically inspect and maintain erosion and
sedimentation control facilities.
r (3) "Goat Farm" Cut Slopes. A geotechnical reevaluation of the Phase I "Goat Farm" cut
slopes which has been conducted by the applicant's geotechnical consultant to address the
consequences of steep cut slopes within alluvial and colluvial materials concluded that the
completed cut slopes are acceptable from a geotechnical point of view.' However, some
minor slumping and erosion has occurred, and can be expected to occur in the future. The
applicant's geotechnical consultant has concluded that if minor slumping and erosion occurs in
the future, the existing street will provide an adequate "buffer" area for collection and clean-up
of debris, and that such collection and clean-up should be considered as part of an overall
project maintenance program.2 The city's geotechnical consultant concurs that minor
slumping on the cut slope will continue to occur, but that it poses no significant hazard to
proposed downslope residential development and is appropriately considered a maintenance
problem.3 Include the clean-up and repair of such minor slumping on the "Goat Farm" cut
slopes as a specific part of the overall project maintenance program.
r In addition, require the applicant to prepare an emergency response plan that identifies
r measures and procedures to ensure adequate emergency access in the event of temporary
r blockage due to surficial slope instability at the "Goat Farm" cut slopes. Emergency access
r shall be maintained at all times to all homes located downslope of the "Goat Farm" cut slopes
r by providing physical barriers at the base of the slopes or in some other manner acceptable to
r the city.
r (4) Repair of Landslide D. (Supplemental Impact G-2) Remediation and repair plans for
r Landslide 0 were reviewed by City and County officials, determined to be adequate, and
r approved. The City and County issued grading permits authorizing work to proceed on
r Landslide D. The approved repair plan shall be implemented by the applicant. (The work is
r expected to be completed by October 31, 1996.)
'PSC. 1991.
2pSC. 1991.
3Eric McHuron. McHuron Geosciences (City geotechnical consultant), personal communication,
November 6, 1995.
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IVD. Soils and Geology
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r A summary report of the observation and testing services provided during the landslide repair
should be prepared and submitted to the city. The report should include an as-built geologic
map. A long-term monitoring plan of selected existing piezometers and slope inclinometers
should also be proposed, reviewed by the city, and implemented by the applicant's
geotechnical consultant.
r b. Phases" and III Supplemental Mitiaation Needs
r (1) Detailed, Desiqn-Level Geotechnical Investiqations. As provided for in the 1982 EIR
r mitigations (see Table 21), require applicants for subsequent project Phases II and III to
r submit for city review and approval detailed, design-level geotechnical investigations for each
r subsequent project Phases II and III. These design-level investigations shall include
r characterization of specific hazards, warranted detailed site-specific mitigations, design criteria
r for project grading, grading limitations to minimize grading in unstable areas, and provisions
r for grading progress and completion reporting. The necessary detailed investigations shall
r also include evaluation of the geologic conditions encountered during grading for Phase I, the
r specific areas of concern identified in previous geotechnical investigations performed for the
r applicant to date, and those considerations identified in this SEIRuadequate design and siting
r of erosion/sedimentation control facilities and debris flow basins, the potential presence of
r "buried valleys" and deep landslide deposits, potential fill placement over compressible
r landslide debris of colluvium, and the potential for differential fill settlement.
r Future cut slopes excavated in unconsolidated materials should be no steeper than 1.5:1,
r unless otherwise recommended by the geotechnical consultant of record and approved by the
r city geotechnical consultant. The subsequent detailed geologic/geotechnical investigations
r shall be completed prior to approval of precise plans for Phase II or Phase III, and shall
r address all Phases II and III areas proposed for grading and development, including areas to
r be dedicated to the county into which some grading may extend.
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IV.E. Drainage and Water Quality
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(3) Groundwater. Several springs and ponded drainage areas above landslides were
identified in the 1982 EIR at the western end of the site. Standing groundwater levels
reported in various onsite bore holes varied considerably, and were considered to represent
shallow seepage of infiltrated surface water rather than a true water table.
(4) Local Floodinq. In 1982, no part of the project site was within a designated 100-year
flood zone, although much of the nearby area east of US 101 and north of Oyster Point
r Boulevard was in a 1 OO-year flood zone. However, debris flows did traverse the site during
r the January 4-5, 1982 storm.
b. Chanaes in Settina - 1982 to 1995
(1) Overview. Since the 1982 EIR was prepared, the following changes have occurred that
have affected hydrologic conditions on the project site and in the vicinity:
· on- and off-site project-related municipal storm drainage system improvements have
been constructed;
· the city of South San Francisco and county of San Mateo have adopted a joint powers
agreement for maintenance of catchment basins on San Bruno Mountain;
· the county of San Mateo has indicated that a portion of the San Bruno Mountain storm
drainage system (i.e., the catchment basins and ditches on the southern slope of San
Bruno Mountain) is not functioning adequately; and
· federal and local regulations have been adopted to more stringently control water quality
in local storm drainage systems.
These changes are discussed below.
(2) Floodinq and Groundwater Conditions. No recorded changes in flooding conditions have
occurred since 1982,' and no changes have occurred in the project that would affect its
relationship to the 100-year flood zone as described in the 1982 EIR. Similarly, no changes
have occurred in the project or in existing groundwater conditions that would affect the 1982
EIR's conclusion that the project would not have a significant impact on groundwater quantity
or flows.2 Flooding and groundwater conditions described in the 1982 EIR are therefore
assumed to be unchanged for purposes of this SEIR analysis.
(3) Post-1982 Storm Drainaqe Improvements. Since 1982, all storm drainage improvements
associated with Phase I, and the Phase II storm drain trunk line, have been installed. These
'Telephone conversation with Ray Towne, Interim Public Works Director, city of South San
Francisco, September 1, 1995. The most recent Federal Emergency Management Agency (FEMA)
Flood Insurance Rate Maps for the project site and vicinity were prepared in 1981.
2City of South San Francisco, Initial Study for the Terrabay Specific Plan and Development
Aqreement Extension, prepared by Wagstaff and Associates, August 1995, items 3(f) and (g), page 15.
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IV.E. Drainage and Water Quality
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existing city storm drains; rather, the project drainage system would instead transport runoff
directly to San Francisco Bay, thus helping to alleviate existing capacity problems along
Hillside Boulevard and Randolph Avenue. The project applicant was to be responsible for
constructing the system to meet city of South San Francisco standards. Upon acceptance of
the system, it was intended that the city would assume maintenance responsibilities for the
portions of the system dedicated to the city as municipal facilities. The remainder of the
onsite system was intended to be maintained by a private homeowners association or group
of homeowners associations.
The drainage and water quality impact and mitigation findings of the 1982 EIR are
summarized in Table 22.
3. SUPPLEMENTAL IMPACT FINDINGS
a. Storm DrainaQe Improvements
The post-1982 installation of storm drainage improvements in accordance with approved plans
for the project does not, in itself, present any new significant adverse environmental impacts
that were not evaluated in the 1982 EIR; with the exception of identified new system
maintenance needs which are described under sections band c below.
b. Joint Powers AQreement
As discussed under the Setting subsection above, the county of San Mateo has recently
raised questions regarding the effectiveness of the 1983 city-county joint powers agreement in
adequately maintaining of project-related catchment basins on the south slope of San Bruno
Mountain, and has proposed disbandment of the Joint Powers Authority. This uncertainty
regarding ongoing maintenance responsibilities for the catchment basins represents a new
potentially significant adverse impact of the project storm drainage system (Supplemental
Impact D-1).
c. Catchment Basin and Ditch MalfunctioninQ
r As discussed under the Setting subsection above, the county of San Mateo has identified past
malfunctioning in the project-related catchment basins and constructed ditches on the south
r slope of San Bruno Mountain. These catchment basins have been in place for approximately
r six years and function well, with ordinary maintenance and repair. In response to concerns
r regarding the adequacy of the catchment basins in Phase I, the City conducted an extensive
r review of the studies and records pertaining to the sizing and capacity of the catchment
r basins. On the basis of that review, the City determined that the catchment basins for phase I
r are adequately sized and properly designed.
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d. Stormwater Requlations
Amendments to the federal Clean Water Act and the city of South San Francisco's adoption of
a "Storm Water Management and Discharge Control" program as Chapter 14.04 of the
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Municipal Code do not present any new significant project-related water quality impacts that
r were not addressed in the 1982 EIR (see SEIR Table 22). The new stormwater regulations
do suggest a revision to the water quality-related mitiqation measures recommended in the
1982 EIR, however (see section 4, Supplemental Mitigation Needs, below). If these new
mitigation standards are not met, the project could result in a potentially significant adverse
r water quality impact (Supplemental Impact 0-2).
4. SUPPLEMENTAL MITIGATION NEEDS
a. Storm Drainaqe Improvements
No new mitigation required.
b. Joint Powers Aqreement
(Supplemental Impact 0-1). Consider disbandment of the Joint Powers Authority for
catchment basin maintenance, as proposed by the county of San Mateo. If the Joint Powers
Authority is to be disbanded, work with the county and the project applicant to ensure that the
catchment basins are in proper condition to allow their dedication directly to the county as the
county suggests (see item c, "Catchment Basin and Ditch Malfunctioning," below). If the Joint
Powers Authority is to be maintained, continue to fulfill city responsibilities in accordance with
the joint powers agreement of June 21, 1983.
c. Catchment Basin and Ditch Malfunctioninq
r No new mitigation required.
d. Stormwater Requlations
r (Supplemental Impact 0-2). In addition to the measures recommended in the 1982 EIR for
r water quality impacts (see Table 22), require the project applicant/property owner to:
(1) Comply with all applicable provisions of the City of South San Francisco "Storm
Water Management and Discharge Control" program (Chapter 14.04 of the
Municipal Code) and five year management plan;
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(2) As required for projects involving construction on sites of more than five acres, file a
Notice of Intent with the State Water Resources Control Board, in order to be
covered by the city's general NPDES permit; or apply to the State Water Resources
Control Board for an individual NPDES permit;
r (3) Prepare a Storm Water Pollution Prevention Plan (SWPPP) for city approval (by the
r City Engineer and/or Stormwater Program Coordinator) and filing with the NPDES
permit, detailing construction activities that could cause pollutants and describing
r measures/practices that will be undertaken to control the pollutants. City approval is
r necessary prior to issuance of grading or other permits. The SWPPP should, at a
minimum, include activities that will:
· stabilize areas denuded due to construction with temporary or permanent
seeding, mulching, vegetative buffer strips, plastic covering, and/or other
measures;
· address the use of sediment controls and filtration measures;
· protect adjacent properties and storm drains by use of vegetative buffer strips,
sediment barriers or filters, mulching, and other appropriate measures;
· address the use of proper construction material and construction waste
storage, handling, and disposal practices; and
· include detailed Post Construction Treatment Controls Best Management
Practices (BMPs) to protect the storm drains and water quality after
construction is completed.
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(b) Native Mixed Grasslands. The upper slopes and ridges of the project site provide a
variety of different grassland habitats with substantial native plant components. The dominant
vegetation here is valley needle Qrassland, which typically occurs on dry, south slopes.
Purple needlegrass (stipa pulchra) predominates; other species include California melic grass
(Melica Californica), blue wild rice (Elymus glaucus), June grass (Koeleria macrantha), big
squirrel-tail grass (Sitamion jubatum), foothill needlegrass (Stipa lepida), San Francisco blue
grass (Poa unilateralis), coast iris (Iris longipetala), mule ears (Wyethia angustifolia), soap
plant (Chlorogalum pomeridianium), Ithuriel's spear (Triteleia laxa), blue dicks (Sisyrinchium
bellum), and Helianthella castanea.
(c) Soft Chaparral. On some onsite slopes, a variety of shrubby plants typical of soft-
chaparral, mostly Coyote brush (Baccharis pilularis), are mixed with the grassland at low
densities. This shrubby element is best developed on the steep slopes above the
northeastern and western portions of the site.
(d) Riparian-Like Areas. The ravines traversing the site's upper slopes create a variety of
microclimates favorable for the growth of plants requiring greater moisture.
(2) Sensitive Plants. There are several rare plant species found on San Bruno Mountain,
r including three California state-listed endangered plants, Arctostaphylos pacifica, A. imbricata,
rand Lessingia germanorum germanorum. A. Imbricata is also federally proposed as
r threatened and Lessingia germanorum germanorum is federally proposed as endangered.
These rare plants, their current status (which for some species has changed since 1982), and
their occurrence on San Bruno Mountain are presented in Table 23 and described below,
based largely on information from the California Native Plant Society (CNPS). Botanical
surveys have been conducted throughout San Bruno Mountain to document the occurrences
of these plants. No occurrences of any of these plants have been documented on the project
site.
. Arabis blepharophylla (Coast Rock cress) is endemic to the San Francisco Bay Area
from Sonoma County south to Santa Cruz County. It is rare, but not endangered. On
San Bruno Mountain, A. blepharophylla is mostly found on rock outcroppings and
occasionally on the surrounding grassy slopes and areas of thin soil.
. Collinsia franciscana (San Francisco collinsia) is endemic from San Francisco to the
Monterey Peninsula. It is an occasional annual found in level grassland and on shaded
slopes. On San Bruno Mountain, it has been located from Colma Canyon to the west
and on the north-facing slopes above Brisbane.
. Arctostaphylos imbricata imbricata (San Bruno Mountain manzanita) is endemic to
San Bruno Mountain. It is common in grassy ridges and slopes with shallow rocky soils
from Kamchatka Point to Powerline Ridge. The population appears to be slowly
increasing with two new plants now growing with a colony of A. uva-ursi forma coactilis
along the San Bruno Mountain ridge trail just east of the summit parking lot.
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· Arctostaphylos imbricata montaraensis (Montara Mountain manzanita) is endemic to
Montara Mountain and San Bruno Mountain. On San Bruno Mountain, it occurs on rocky
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or shallow soil in coastal scrub near Pacific Rock. This area continues to be the only
remaining population. The San Bruno Mountain population is stable and is composed of
an even-aged stand with all individuals being approximately 26 years old.
· Arctostaphylos pacifica (Pacific manzanita) is endemic to San Bruno Mountain. It is
found only on a sandstone outcrop near Pacific Rock close to the mountain's summit.
· Erysimum franciscanum spp. franciscanum (Franciscan wallflower) is endemic to the
San Francisco Bay Area from Sonoma County to Santa Cruz County. It is a biennial to
short-lived perennial which is occasional on grassy, rocky slopes and in open coastal
scrub communities.
· Grindelia maritima (San Francisco gumplant) is endemic to San Francisco and San
Mateo Counties. It is occasionally found on open hillsides and in open coastal scrub
communities. The taxonomy of this plant is currently being examined by botanists to
determine if it should be lumped with other species of Grindelia.
· Helianthella castanea (Diablo helianthella) is endemic to the San Francisco Bay Area
with occurrence limited to a few restricted populations. On San Bruno Mountain,
populations of this plant are only found in the hills above Brisbane.
r · Lessingia germanorum germanorum (San Francisco lessingia) is listed as a proposed
endangered species by the U.S. Fish and Wildlife Service. It is endemic to San
Francisco and northern San Mateo County. It is associated with sandy soils and is found
only in the San Francisco Presidio and on the west side of Reservoir Hill on San Bruno
Mountain.
. Silene verecunda verecunda (San Francisco campion) is found on San Bruno Mountain
on the south side of the southeast ridge at the telecommunications property site. It is
associated with rocky outcrops just below the radio towers.
b. Wildlife
(1) Habitat Quality and Wildlife Use. Wildlife use of the project site is typical of annual
grassland and brush land areas throughout the San Francisco Bay region, except for the
presence of certain rare and endangered species, most notably grassland butterflies.
Although the home range and habitat requirements of certain small mammals and birds may
be contained entirely within the project boundaries, many local animals would be expected to
range more widely, taking advantage of the open space and additional resources available
offsite.
Since completion of the 1982 EIR, habitat quality and wildlife use of the project site have been '
diminished by grading of approximately 80 acres between 1989 and 1995 to prepare the site
for Terrabay Phase I.
The expansive grasslands of the site afford prime foraging habitat for raptorial birds which
may hunt but probably do not nest within the project boundaries. A variety of resident
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agreement and permit would fulfill the city's obligation under CEQA to assess project impacts
and mitigation needs regarding species of concern.
No new significant impacts or changes in the severity of previously identified significant
impacts have been identified; no new or additional mitigations are necessary. However, the
following minor changes in mitigation are needed to correct the failure of habitat restoration
work performed to date:
a. ReQuired Remedies for Habitat Restoration Failures
(Supplemental Impact VW-1) The 1995 evaluation report completed in compliance with the
HCP mitigation monitoring program identified several recommendations for remedying the
failure of the Terrabay Phase I Reclamation Plan habitat restoration work, including certain
regrading measures which would correct erosion and restoration problems without significantly
affecting the Mission blue or callippe populations. The 1995 evaluation report is included in
r Appendix C and the report recommendations are summarized below:
· Prior to retreatment of the failed slopes, conduct soil tests to determine the need to use
soil amendments.
· Use a combination of emergent and pre-emergence herbicides to eliminate "weedy" non-
native plants in the restoration areas.
· Use more native grasses, which have proven to be very successful in restoration sites
around the mountain, in the seed mixes; and
. Make erosion control a high priority. Use Soil Guard hydromulch or tackified straw in the
hydroseed mixes to ensure better cover of hydro seeded material. Use erosion blankets
in especially erosion prone areas.
r Note: As this SEIR was in the process of preparation, City staff reports that the applicant
r implemented the proposed mitigation measures to correct habitat restoration deficiencies.
r This mitigation implementation will be reflected in the project conditions of approval, Statement
r of Findings, and Mitigation Monitoring checklist.
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facilities such as tennis courts, community centers and baseball fields, and improvements in
the location of facilities.'
(3) Park and Recreation Chanqes Since 1982. Park and recreation facilities have been
added throughout the city since 1982. In addition, the City of South San Francisco adopted a
Park, Recreation and Open Space Master Plan in 1990. The plan identifies the project site as
"Planning Area #4," and notes that:2
This area is a planned neighborhood development and will include one baseball and one
soccer practice field at Hillside School, an indoor swimming pool, community center, four-
acre neighborhood park, and linear park along Hillside Boulevard. These facilities will
serve the new neighborhood, the adjacent Sign Hill neighborhood, and will also serve the
entire community.
As part of project Phase I improvements, one baseball and one soccer practice field have
been installed at Hillside Elementary School in accordance with the Park, Recreation and
Open Space Master Plan.
d. Schools
(1) Attendance Areas. The project site is located within three school districts: The South
San Francisco Unified School District (SSFUSD), Brisbane School District, and Jefferson
Union High School District. The SSFUSD boundaries include Terrabay Village, Terrabay Park
and Terrabay Woods, which together would include a total of 125 single family houses and
r 368 townhomes. The Brisbane School District and Jefferson Union High School District
boundaries include Terrabay Commons and Terrabay Point, which include 493 multi-family
r units.
(2) South San Francisco Unified School District. Students in the South San Francisco
Unified School District would attend Hillside Elementary School, Parkway Heights Middle
School, and EI Camino High School. All district schools operate on a ten-month basis.
Current Enrollment. During the 1994-1995 school year, Hillside Elementary School had an
enrollment of 343 students, Parkway Heights Middle School had 867 students, and EI Camino
High School had 1,351 students. Hillside Elementary School and Parkway Heights Middle
School are currently operating at capacity.
Future Enrollment. The enrollment in the 1999-2000 school year is projected to be 392
students at Hillside Elementary School, 906 at Parkway Heights Middle School, and 1,187 at
'Ibid.
2City of South San Francisco, page 21.
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EI Camino High School. There are no imminent plans for new schools or school closures in
the district.
(2) Brisbane School District. Students in Brisbane School District would attend Brisbane
Elementary School and Lipman Intermediate School. Both schools currently operate on a ten-
month basis.
Current Enrollment. During the 1994-95 school year, Brisbane Elementary School had an
enrollment of 209 students, with three available classrooms and a capacity to serve 285
students, including one special education classroom. Lipman Intermediate School had an
enrollment of 150 students, with capacity to serve 300 students.'
Future Enrollment. The Brisbane School District does not currently plan to increase the
capacity of its schools (e.g., by adding portables), and does not anticipate any school
closures. It is expected that when the Northeast Ridge project is fully developed, enrollment
will increase by 120 students at Brisbane Elementary School and by 60 students at Lipman
Intermediate School. A change in grade configuration may be required to accommodate this
enrollment increase. As enrollment at Brisbane School grows, its lunch and physical
education facilities will become increasingly inadequate.2
r Transportation. Brisbane School District does not provide transportation for its students. The
r district considers Brisbane Elementary School and Lipman Intermediate School to be within
walking distance of the project site.3
(3) Jefferson Union HiQh School District. Students in the Jefferson Union High School
District would attend Jefferson High School and Westmore High School in Daly City, with most
students expected to attend Jefferson High School. Both schools operate on a ten-month
basis.
Current Enrollment. During the 1994-1995 school year, Jefferson High School had an
enrollment of 1,615 students and a capacity to serve 1,655 students. There are currently
"portable" classrooms in use at Jefferson High School, although these have been in use at the
school for some time and are considered permanent classrooms by the District. Westmore
High School had an enrollment of 1,571 students, with capacity to serve 1,625 students.4
, Letter from Stephen J. Waterman, Esq., Superintendent, Brisbane School District, to Ricardo
Bressanutti, Wagstaff and Associates, reo "Terrabay," September 13, 1995.
2lbid.
3lbid.
4Telephone conversation with AI Pucci, Associate Superintendent, Jefferson Union High School
District, September 21, 1995.
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Future Enrollment. The Jefferson Union High School District does not currently plan to
increase the capacity of its schools and does not anticipate any school closures. Enrollment
at Jefferson High School in the 1999-2000 school year is projected to be 1,720, and 1,890 at
Westmore High School.'
e. Water Service
The California Water Service Company (CWSC), a privately owned utility, provides water
r service to South San Francisco. The project is located within the CWSC South San Francisco
r service area. Approximately 90 percent of the water supply for CWSC's South San Francisco
service area comes from the City of San Francisco Water Department; approximately 10
percent is from CWSC wells. The current CWSC contract with the San Francisco Water
Department, which is in effect through the year 2009, entitles the CWSC to 47,400 acre-feet of
water per year, or 42.3 million gallons per day (mgd). Up to an additional 1,530 acre-feet per
year can be pumped from groundwater. Thus, the total supply of water currently available to
the city is 48,500 acre-feet per year, or 43.3 mgd. The CWSC projects a demand of 37,300 to
41,800 acre-feet in the year 2010. Assuming no modification of the San Francisco Water
. Department contract, current supply would exceed projected high demand for the year 2010
by more than 10 percent.2
Water mains in the vicinity of the project site are located along Bayshore Boulevard, Hillside
Boulevard, Randolph Avenue and Airport Boulevard.
f. Sewer Service
Wastewater services for the project site would be provided by the City of South San
Francisco. The project site is located within Basin 6 of the city's wastewater collection
system. The main interceptor for Basin 6, located on Airport Boulevard, joins a main
interceptor that follows Colma Creek and terminates at the San Mateo Pump Station, from
which wastewater is pumped to the South San Francisco-San Bruno Water Quality Control
Plant.
The city has recently completed a study of wastewater treatment capacity of the South San
Francisco-San Bruno Water Quality Control Plant. The study found that the plant may be
operated with a reasonable factor of safety at 9.0 mgd with the completion of the interim
improvements which are currently under design. It is now treating an average of
approximately 8.0 mgd. A subsequent study, to be completed in 1996, will determine the
treatment plant expansions necessary to accommodate development over the next 20 years.
, Pucci.
2Telephone conversation with Eugene Gravelle, California Water Service Company, September 12,
1995.
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officers, based on the Department's current goal of providing 1.35 officers per 1,000
population.' One new police vehicle would be needed to accommodate three new officers.2
r In addition, the Police Department has identified a potential impact on police services if it
r becomes necessary to provide adult crossing guards to ensure the safety of crossings and
r pedestrian routes to school for school age children. The Police Department is currently
r required to provide adult crossing guards at four other school crossings. Although the South
r San Francisco Unified School District (SSFUSD) has indicated that all elementary school
r students within the district would attend Hillside Elementary School, in the event that some
r project elementary school students attend SSFUSD schools other than Hillside Elementary
r School, an adult crossing guard would be needed at the signalized Hillside Boulevard
r Extension/South San Francisco Drive and Sister Cities Boulevard/South San Francisco Drive
r intersections if 40 or more elementary school children cross within any two hour period. The
r possible need to fund, recruit, train and equip crossing guards represents a potential impact
r on police services.
b. Fire Protection
As stated in the 1982 EIR, the substantial new project population would increase calls for Fire
Department service and would increase fire hazards associated with the site's proximity to
San Bruno Mountain. These anticipated impacts of the project remain generally unchanged.
The possible fire fighter shortage at Station 1 discussed in the 1982 EIR has been resolved,
however, and is no longer a potential impact of the project.3
c. Parks and Recreation
The park and recreation aspects of the project have also not changed substantially since
1982. As noted in the "Setting" subsection above, one baseball and one soccer practice field
have been installed at Hillside Elementary School as part of project Phase I improvements, in
accordance with the city's Park, Recreation and Open Space Master Plan adopted in 1990.
Additional improvements to be installed as part of Phase I would include:
(1) the Hillside Recreation Center, which would serve community-wide as well as project
needs (to be dedicated to and maintained by the city);
'2,156 people (project population) divided by 1,000 = 2.156 x 1.35 officers = 2.91 officers needed
to serve project.
2The Police Department's current ratio of officers per marked unit is 2.7 officers per unit (cited in
"Estimated Police Department Expense Impacts Per Officer," attachment to letter from Sgt. Ron
Petrocchi, Planning LiaisonlTraffic, city of South San Francisco Police Department, July 31, 1995).
3Telephone conversation with Fred Lagomarsino, Fire Marshal/Chief Building Official, City of South
San Francisco, September 14, 1995.
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(2) a child care center with tot lot (to be operated and maintained by the project
homeowners associations); and
(3) a linear park along Hillside Boulevard connecting the playing fields at the Hillside
r Elementary School with Hillside Recreation Center (to be maintained by the project
r homeowners association).
A series of "in-tract parks" (Le., small undeveloped areas covered with grass turf) would be
included in Phases I and II and trailhead improvements (providing trail access to San Bruno
Mountain State and County Park) would be added in Phases II and III. These in-tract parks
and trailhead improvements would be maintained by the project homeowners' associations.
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d. Schools
Changes in impacts identified in the 1982 EIR would consist of the following:
According to the 1982 EIR, the 745-unit project approved in the specific plan would generate
an estimated 286 additional K-12 public school students; 224 would attend South San
Francisco Unified School District schools, 45 would attend Brisbane School District schools,
and 17 would attend Jefferson Union High School District schools. Based on more current
enrollment multipliers provided by the districts, and the revised number of total project units
(721), the 721-unit project would now be expected to generate an estimated 370 additional K-
12 students; 260 would attend SSFUSD schools, 90 would attend Brisbane Elementary School
District schools, and 20 would attend Jefferson Union High School District schools.
It should be noted that these total enrollment increases would be expected to occur
incrementally over the proposed six-year project buildout period.
(1) South San Francisco Unified School District. The project would be expected to generate
approximately 260 new students attending South San Francisco Unified School District
schools; 120 attending Hillside Elementary School, 60 attending Parkway Heights Middle
School, and 80 attending EI Camino High School. Hillside Elementary School and Parkway
Heights Middle School are already operating at capacity.
Based on an estimated cost of $140,000 per relocatable classroom, the total estimated cost to
the district to provide classrooms would be $1.4 million. Costs to add permanent classrooms,
a more desirable option, are undetermined but would be greater. Additional restroom facilities
and core classrooms may be needed for child care and special education classes at Hillside
Elementary School and Parkway Heights Middle School.
r According to the South San Francisco Unified School District, school impact fees accruing
r from the project to the district may not be sufficient to cover the cost of providing additional
classroom capacity and associated facilities to serve the additional students generated by the
r project. The school impact fees accruing to the district from the project have been estimated
r by the district at $1.372 million in today's dollars. This amount appears to have been
r underestimated because the estimated size of the residential units used is smaller than the
r units actually being built. Nevertheless, the project can be expected to have a significant
adverse impact on SSFUSD capacity (Supplemental Impact PS-1).
(2) Brisbane School District. Another major development in the project vicinity, the
Northeast Ridge project, would contribute 120 students to Brisbane School and 60 students to
Lipman School, causing Brisbane School to exceed its capacity. It is likely that students
would be transferred to Lipman School to accommodate this enrollment increase. In addition,
a local ballot measure (Measure E, on the November 1995 ballot) would, if passed, require the
School District to reduce classroom sizes. Based on these factors, the School District
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anticipates that enrollment of students from the Terrabay project would cause both schools to
exceed capacity.'
The project-related enrollment increase is expected to generate a need for two new portables,
which would most likely be located on the Brisbane School site. In addition, physical
education, school assembly, and lunch space at Brisbane Elementary School would be
inadequate to serve the expected number of additional students from the project, and a multi-
purpose room and playground upgrade would be needed. The facility would also require
upgrading to meet fire code and disabled access requirements. Lipman Intermediate School
would require upgrading restrooms, one portable, a remodeled school yard, and a functioning
kitchen for food preparation in order to accommodate the additional enrollment.2
r According to the district, school impact fees accruing to the Brisbane School District from the
r project (estimated by the district to be $246,000 in today's dollars)3 would cover the cost of
providing two additional portables, but would not be sufficient to fund other necessary
r improvements at Brisbane and Lipman Schools.4 (The school impact fees accruing to the
r district from the project may have been underestimated because the estimated size of the
r residential units used is smaller than the units actually being built.)
r Also, the district does not provide transportation for its students. Brisbane School is located
r approximately 1.9 miles and Lipman School is located approximately 2.6 miles from the
r furthest part of the project within district boundaries. This distance may be too great for young
r students to walk to school. There are no sidewalks along Bayshore Boulevard between the
r project and Brisbane. Also, Bayshore Boulevard is a busy arterial roadway and vehicles travel
r at high speeds, making it potentially unsafe for young school children.
r Because the state-mandated school impact fees may not be sufficient to cover the total cost
r of accommodating the project-generated enrollment increase, and because the needed
r transportation to school has not been adequately provided for, the project could be expected
r to have a significant adverse impact on the Brisbane School District (Supplemental Impact
PS-2).
, Letter from Stephen J. Waterman, Esq., Superintendent, Brisbane School District, to Ricardo
Bressanutti, Wagstaff and Associates, reo "Terrabay," September 13,1995, pages 1-2; telephone
conversation with Stephen J. Waterman, Esq., Superintendent, Brisbane School District, September 14,
1995.
2Letter from Stephen J. Waterman, Esq., Superintendent, Brisbane School District, to Ricardo
Bressanutti, Wagstaff and Associates. reo "Terrabay," September 13,1995, pages 1-2.
3Current school impact fees are set at $1.50 per square foot of habitable residential area. Of this
amount, the Brisbane School District receives $0.90, and the Jefferson Union High School District
receives $0.60.
4Letter from Stephen J. Waterman, Esq., Superintendent, Brisbane School District, to Ricardo
Bressanutti, Wagstaff and Associates, reo "Terrabay," September 13, 1995, page 2.
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(3) Jefferson HiQh School District. Applying estimated project student generation rates
provided by Jefferson Union High School District, the project would be expected to generate
approximately 20 additional students at Jefferson High School and Westmore High School, at
which future enrollments are already anticipated to exceed capacity.' This enrollment
increase would contribute to a need for new portables, and would place additional demands
on other school facilities. School impact fees accruing from the project to the Jefferson Union
High School District are estimated at $164,000 in today's dollars. This amount would be
expected to be sufficient to cover the cost of providing additional portable classroom activity.
'0.08 students per unit for Terrabay Commons and 0.1 students per unit for Terrabay Point.
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Avenue, west to Linden Avenue, and south to the colma Creek trunk line, where flows are
diverted to the San Mateo Pump Station. However, as with the onsite wastewater
improvements, the City of South San Francisco has not accepted maintenance responsibility
for this offsite system due to apparent infiltration problems.' Until mitigated, these problems
represent a potentially significant adverse impact of the project (Supplemental Impact PS-4).
(I. RecyclinQ ProQram Collection Services
Under the city's new recycling program, project single family residences and townhomes in
project Phase I would receive recycling containers and be provided with individual curbside
collection service. Similarly, depending on their physical characteristics, residences and
commercial uses in project Phases II and III could either receive individual (curbside) or
centralized (dumpster) recycling containers and collection services.
Because recycling services are provided on an "enterprise" fee-for-service basis, it is expected
that the project will generate adequate additional revenues to meet the increased demand for
recycling services.
State law requires provision of adequate space for recycling in multiple family residential
projects with five or more units and all new commercial developments.2 Future project
phase multi-family residential and commercial development may not include adequate
provision for collection of recyclable materials. This situation would represent a significant
adverse project impact (Supplemental Impact PS-5).
4. SUPPLEMENTAL MITIGATION NEEDS
a. Police Protection
r In order to provide the new fully staffed beat recommended in the 1982 EIR, (1) require the
project applicant to fund acquisition of one new Police Department vehicle,3 and (2) monitor
project build-out over time to assess when the new beat should be established and new
officers hired.
'Telephone conversation with Mike Rozzi, Senior Construction Inspector, city of South San
Francisco, September 15, 1995.
2California Public Resources Code Division 30 Part 3 Chapter 18 section 42905.
3The cost of a new police vehicle is estimated at $21,320 (cited in "Estimated Police Department
Expense Impacts Per Officer," attachment to letter from Sgt. Ron Petrocchi, Planning LiaisonlTraffic,
city of South San Francisco Police Department, July 31, 1995).
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r The City shall conduct periodic monitoring of the crossings at the Hillside Boulevard/South
r San Francisco Drive and Sister Cities Boulevard/South San Francisco Drive intersections to
r determine if 40 or more elementary school children cross within any two hour period. If the
r threshold is reached at either of these intersections, then the Phase II project homeowners
r association shall be required to:
r (1) fund the provision of an adult crossing guard at that intersection (including all salary,
r background check, equipment, and training costs), and
r (2) actively recruit candidates for the position and for an alternative part-time, back-up fill-in
r position from among project residents. (Project residents are preferred because of
r opportunities for more familiarity with students.)
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IV.G. Public Services
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b. Fire Protection
Construction of a new fire station has been completed, as recommended by the 1982 EIR.
The potential fire fighter shortage at Station 1 has also been resolved, and no mitigation is
required. Remaining 1982 EIR recommended mitigations, which require installation of a fire
buffer and compliance with additional development design measures recommended by the
City of South San Francisco Fire Department, are unchanged.
c. Parks and Recreation
The mitigation need identified in the 1982 EIR remains unchanged; no new mitigation
required.
d. Schools
(Supplemental Impacts PS-1 and PS-2). As mitigation for SSFUSD and Brisbane School
r District impacts, the city shall require the applicant, as a provision of the project development
r agreement, to prepare and submit for city review and approval, a school financing plan that
r includes:
r (1) Payment of State-Mandated School Impact Fees. Require the applicant to comply with
r applicable SSFUSD school impact fee requirements. If it is determined by the city that the
r project fees would not be sufficient to reduce project school impacts to a less-than-significant
r level, the city may also:
r (2) Additional Impact Fees. Require that the project applicant/developer pay additional
r impact fees or some other additional in-kind contribution, or establish other financing
r mechanisms in consulation with the city and acceptable to the SSFUSD and the Brisbane
r School District sufficient to cover the cost of providing classroom space and ancillary school
r facilities needed to serve the increased enrollment generated by the project, to the city's
r satisfaction.
r Also require the applicant to provide for safe transportation to Brisbane School District schools
r for students from the project. This may be accomplished by installing a sidewalk along
r Bayshore Boulevard and/or other streets to allow students to walk to Brisbane Elementary
r School and Lipman Intermediate School, or in some other manner acceptable to the district.
r Require the applicant to submit to the city an official statement in writing from the Brisbane
r School District declaring that the needed transportation has been adequately provided for to
r the satisfaction of the district.
r Finalization of school access sidewalk needs and associated design details are properly
r deferred to the Phase II and III environmental documentation sequences since the City
r currently does not know what the actual configuration of these phases will be.
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IV.G. Public Services
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e. Water Service
As called for in the 1982 EIR. ensure that a water pump station for the project is under
construction prior to construction of Phase I single-family detached units. No other changes to
the mitigation suggested in the 1982 EIR are required.
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IV.H. Noise
Page 228
4. SUPPLEMENTAL MITIGATION NEEDS
a. Compatibility of the Proposed Residential Development With the Future Onsite
Noise Environment
(1) Traffic Noise Impacts. (Supplemental Impact N-1) Retain a qualified acoustical
engineer to prepare and submit for city review and approval a detailed acoustical analysis of
noise reduction requirements and specifications for all project phases, in accordance with the
land use/noise level compatibility standards established by the state and set forth in the city's
Noise Element (see Tables 28 and 29 herein). The identified noise reduction requirements
and specifications shall then be included in the project site or individual home designs or hotel
designs.
Various combinations of methods could be used to mitigate onsite noise levels. These could
include the construction of berms or soundwalls and/or provision of fresh air supply systems
or air conditioning, and use of sound-rated glazing in windows.
(2) Aircraft Noise Exposure Impacts. (Supplemental Impact N-2) The noise analysis
r requirement described for Supplemental Impact N-1 shall also recommend methods of design
r and construction to comply with the applicable portions of Uniform Building Code Title 24,
r Appendix 35, Sound Transmission Controls, and with the FAA Part 150 Noise Compatibility
r Program, which requires that all single-family dwelling unit construction achieve an indoor
r noise level of 45 dBA, as measured from an aircraft noise event. The qualified acoustical
r engineer retained to prepare the analysis shall be familiar with aviation noise impacts.
b. Construction Noise
(Supplemental Impact N-3) Reduce construCtion period noise impacts associated with
Terrabay project residential and commercial development to acceptable temporary levels by
implementation of the following measures. These mitigations should be required as a
condition of any development approval within the project area, and should be included in the
work agreement with the construction contractor(s).
(1) Construction Schedulinq. Limit noise generating construction activities including truck
traffic going to and from a site for any purpose. and maintenance and servicing activities for
construction equipment, to the hours stipulated in the City's Noise Ordinance (Chapter 8.32 of
the South San Francisco Municipal Code, Noise Regulations, Section 8.32.050 dated 2-91).
(2) Construction Equipment Mufflers and Maintenance. Properly muffle and maintain all
construction equipment powered by internal combustion engines.
(3) IdlinQ Prohibitions. Prohibit unnecessary idling of internal combustion engines.
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IV. I. Air Quality
Page 235
non attainment areas develop plans and strategies that will reduce pollutants by certain
increments or face imposition of sanctions (e.g. withholding of highway project funding).
Concentrations of federal nonattainment pollutants have been gradually declining in the Bay
Area over the past decade. The Bay Area was recently redesignated by the U.S.
Environmental Protection Agency as a "maintenance area" for ozone, and a request for
redesignation to "maintenance area" for carbon monoxide has been submitted to the U. S.
Environmental Protection Agency.
With the enactment of the California Clean Air Act of 1988 regional air quality planning has
shifted emphasis from the federal ambient standards to meeting the state ambient air quality
standards. This legislation empowers regional air quality management districts with new
authority to design, adopt, implement, and enforce comprehensive plans for attaining and
maintaining both the federal and the more stringent state air quality standards by the earliest
practical date. Among its provisions, the California Clean Air Act provides districts with the
authority to establish new controls on mobile sources of pollution.
The area-wide plan required by the California Clean Air Act was adopted by the BAAQMD in
r October 1991 and updated in 1994.' The 1994 Clean Air Plan imposes controls on stationary
sources (factories, power plants, industrial sources, etc.) and Transportation Control Measures
(TCMs) designed to reduce emissions from automobiles, including indirect sources. Since the
Plan does not provide for a five percent annual reduction in emissions, it proposes the
adoption of "all feasible measures on an expeditious schedule."
r The Bay Area '94 Clean Air Plan forecasts continued improvement in regional air quality. An
analysis of carbon monoxide trends shows attainment of the standards throughout the Bay
Area by the mid-1990s. However, implementation of the Plan would not provide for attainment
of the State ozone standard even by the year 2000.
2. 1982 EIR IMPACT AND MITIGATION FINDINGS
Air quality impacts and mitigation measures identified in the 1982 EIR are summarized in
Table 33.
The 1982 EIR identified air quality impacts of three types: short-term construction-related dust
impacts, increases in carbon monoxide concentrations along streets providing access to the
site, and increases in regional pollutant emissions. An updated reevaluation of project short-
term construction impacts, long-term local and regional air quality effects is provided below.
r 'Bay Area Air Quality Management District, Bay Area '91 Clean Air Plan (CAP), 1991, and Bay
r Area '94 Clean Air Plan (CAP), 1994.
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IV. I. Air Quality
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3. SUPPLEMENTAL IMPACT FINDINGS
Methods used for predicting and analyzing air pollutant emissions are constantly being revised
and updated to account for changing technology and emissions control programs. Since
1982, new analytical tools have been developed that enable a more precise prediction of
project air quality impacts. The following updated discussion of local and regional air quality
impacts also describes the criteria and methodologies used in this SEIR that differ from those
used in the 1982 EIR.
a. Chanqes in SiQnificance Criteria
Appendix G of the CEQA Guidelines establishes that a project will normally have a significant
impact on air quality if it will:
violate any air quality standard, contribute substantially to an existing or projected air
quality violation, or expose sensitive receptors to substantial pollutant concentrations. '
Since certification of the 1982 EIR, the Bay Area Air Quality Management District (BAAQMD)
has established revised thresholds of significance for use in local and regional air quality
impact assessments of projects. A significant impact on local air quality is defined in this
SEIR as a predicted violation of these revised carbon monoxide ambient air quality standards
due to project-related traffic increases on the local street network. For regional air quality, a
significant impact is defined as an increase in emissions of reactive organic gases (ROG),
r oxides of nitrogen, (NOx) or fine particulate matter (PM-10) of 80 pounds per day or greater.
b. Short-Term Construction Impacts
Project construction activities such as clearing, excavation and grading operations,
construction vehicle traffic on unpaved ground, and wind blowing over exposed earth would
generate dust and particulate matter. Construction dust would affect local and regional air
quality at various times during the build-out period of the project. The dry, windy climate of
the area creates a high potential for dust generation.
Construction dust impacts are extremely variable, being dependent on wind speed, soil type,
soil moisture, the type of construction activity, and the number of acres affected by
construction activity. A rough estimate of uncontrolled construction PM-10 (Particulate Matter,
10 microns) emissions is 0.6 tons per month per acre of active construction.
The effects of construction activities would be increased dustfall and locally elevated levels of
PM-10 near the area of construction activity. Depending on the weather, soil conditions, the
amount of activity taking place, and the nature of dust control efforts, these impacts could
'CEQA Guidelines, Appendix G, item x.
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II and III) would increase concentrations by up to 0.3 PPM for the 1-hour averaging time and
0.2 PPM for the 8-hour averaging time. These concentrations would remain below the state
and federal standards. The project impact on local air quality is therefore still considered less-
than-significant.
(2) Reqional Air Quality Impacts. Trips to and from the project would result in air pollutant
emissions affecting the entire San Francisco Bay air basin. Regional emissions associated
with project vehicle use have been calculated using EMFAc7F emission factors. The
EMFAC7F emissions program is now typically used instead of the EMFAC7C emissions
program used in the 1982 EIR. The EMFAc program has been updated every few years to
reflect current control programs and emissions control technology. In general, the EMFAc7F
program yields lower emission estimates because it reflects the most current emission
standards for vehicles and considers the effects of a variety of emission programs
(reformulated fuels, for example) not considered in the EMFAC7C program. The methodology
used in estimating vehicular emissions is described in Appendix D.
The estimated incremental daily emissions associated with project-related traffic are shown in
Table 35 for reactive organic gases and oxides of nitrogen (two precursors of ozone), and PM-
10.
Daily ROG and PM-10 emissions associated with proposed residential uses are also shown in
Table 35. Residential uses contain a number of dispersed and intermittent sources of
pollutants such as space and water heaters, household paints and solvents, fireplaces and
woodstoves, lawn mowers. and other equipment.
Project emissions shown in Table 35 for Phase I of the proposed development would not
r exceed 80 pounds per day, and would therefore have a less-than-significant regional air
quality impact. However, similar to the 1982 EIR findings, the updated analysis indicates that
buildout of Phases I, II and III would generate new regional emissions of ozone precursors
r exceeding 80 pounds per day. Unless the most current mitigation methodologies
r recommended by the BAAQMD are incorporated in the project, this would be considered a
significant adverse impact on regional air quality. (Supplemental Impact AQ-2)
4. SUPPLEMENTAL MITIGATION NEEDS
a. Construction Impacts
(Supplemental Impact AQ-1) The 1982 EIR recommended twice-daily watering for dust
control. However, under current practice, this recommendation may not be sufficient to
r reduce construction dust impacts to a less than significant level. The applicant shall comply
r with current city standards pertaining to construction dust mitigation practices in place of the
r construction period air quality mitigation identified in the 1982 EIR. The required measures
r may include the following:
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r · Water all active construction areas at least twice daily.
r . Cover all trucks hauling soil, sand, and other loose materials or require all trucks to
r maintain at least two feet of freeboard.
r . Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved
r access roads, parking areas and staging areas at construction sites.
r . Sweep daily (with water sweepers) all paved access roads, parking areas and staging
r areas at construction sites.
r . Sweep streets daily (with water s'yVeepers) if visible soil material is carried onto adjacent
r public streets.
r . Hydroseed or apply (non-toxic) soil stabilizers to inactive construction areas (previously
r graded areas inactive for ten days or more).
r . Enclose, cover, water twice daily or apply (non-toxic) soil binders to exposed stockpiles
r (dirt, sand, etc.)
r . Limit traffic speeds on unpaved roads to 15 mph.
r . Install sandbags or other erosion control measures to prevent silt runoff to public
r roadways.
r . Replant vegetation in disturbed areas as quickly as possible
r . Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and
r equipment leaving the site.
r . Install wind breaks, or plant trees/vegetative wind breaks at windward side(s) of
r construction areas.
r . Suspend excavation and grading activity when winds (instantaneous gusts) exceed 25
r mph.
r . Limit the area subject to excavation, grading and other construction activity at any o~e
r time.
b. LonQ Term Air Qualitv Impacts
(1) Reqional Air Quality Impacts. (Supplemental Impact AQ-2) In addition to the
transportation system management (TSM) requirements identified as mitigation in the 1982
EIR, the following measures should be implemented:
. The project should incorporate a vehicle-trip reduction requirement applicable to all land
uses. Specific trip reduction goals should be adopted and enforcement procedures
developed by the applicant in consultation with the BAAQMD.
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In addition, require the project sponsor to submit to the city a mitigation plan that includes
these types of measures to reduce residential emissions:
· Restrict the number of fireplaces in residences, or require residential use of EPA-certified
woodstoves, pellet stoves or fireplace inserts. The use of natural gas fired fireplaces
should be encouraged.
· Require outdoor outlets at residences to allow use of electrical lawn and landscape
maintenance equipment.
· Make natural gas available in residential backyards to allow use of natural gas-fired
barbecues.
Adoption of these measures would have the potential to reduce regional impacts of the project
r by from five to 15 percent. This reduction would reduce project regional emissions of PM-10
r to below 80 pounds per day, but would not be sufficient to reduce emissions of NOx or ROG
r to below the 80 pounds per day BAAQMD significance threshold. Even after mitigation, the
impact of buildout of project Phase I, II and III on regional air quality would remain an
unavoidable significant adverse impact.
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IV.J. Cultural Resources
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d. 1982 Evaluations of SiQnificance
Although the 1982 EIR indicated that a determination of the significance of the prehistoric
sites was not possible due to the limited available knowledge and understanding of the sites,
the EIR did state that cA-SMa-40 could possibly be eligible for listing on the National Register
r of Historic Places. Site cA-SMa-40 is a large shell mound measuring approximately 80 to 90
r meters in diameter. The site is reportedly very significant and one of the few remaining
r examples of such shell mounds in the Bay Area. Based on information from similar Bay Area
r mounds, the site may have been used by local native peoples as a burial ground, ceremonial
r place, and living site for hundreds or thousands of years and is thought to possibly contain
r Native American human remains. With respect to the fourth identified onsite cultural resource,
the historic mine shaft and water distribution system, the remnants were determined to have
minimal local significance, not sufficient for National Register listing.
No significant new information or substantive changes in the circumstances under which the
project is undertaken from those described in the 1982 EIR have been identified with respect
to cultural resources.
2. 1982 IMPACT AND MITIGATION FINDINGS
Cultural resources impacts and mitigation measures identified in the 1982 EIR are
summarized in Table 36.
3. SUPPLEMENTAL IMPACT FINDINGS
a. Potential for Additional Cultural Resource Discoveries
Records indicate that 100 percent of the project site has been studied for cultural resources.
The 1982 EIR impact evaluation was limited to evaluation of project impacts on four specific
cultural resource sites identified in these studies. However, the staff at the State Historical
Resources System, Northwest Information Center indicate that the project site as a whole,
which is located on the bay margins and at the base of hills near sources of fresh water, has
a high potential for previously undiscovered Native American sites, which could be
encountered during project construction (Le., grading).' Such disturbance would represent a
potentially significant adverse impact. (Supplemental Impact CR-1)
'August 18, 1995 letter from Lynn Compas, Researcher II, Historical Resources Information
System, Northwest Information Center, to Ricardo Bressanutti, Wagstaff and Associates, re: Terrabay
Specific Plan and Development Agreement Extension Supplemental EIR.
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b. Adequacy of 1982 EIR Site-Specific MitiQations
(1) CA-SMa-40. To mitigate identified potential project impacts to site CA-SMa-40, the 1982
EIR recommended capping the site with a minimum of one foot of sterile fill and sealing the
site under landscaping or parking areas. However, in its recent review of this mitigation
recommendation, staff at the Northwest Information Center or the California Archaeological
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Table 36
1982 EIR CULTURAL RESOURCES IMPACT AND MITIGATION FINDINGS
Impact Summary
r The historic mine shaft and water distribution
system, and prehistoric site CA-SMa-234, are
located outside areas of proposed
development.
r CA-SMa-40 is rich and relatively intact and
could possibly be eligible for National Register
listing. Disturbance of CA-SMa-40 during
project construction would be a significant
r adverse impact.
r CA-SMa-92 is in the direct location of
development but has been so disturbed that its
integrity is substantially minimized.
r
r
r
r
Mitiqation
A minimal research program shall determine
the historical background of the mine shaft
(age, builder, period of use).
A minimum of one foot of sterile fill shall be
placed over CA-SMa-40 and the area sealed
under landscaping and/or parking areas. A
small-scale program of surface collection and
minor sampling shall be conducted prior to
placement of fill. Scarification, earth moving
and compaction for site burial shall be
monitored by a qualified archaeologist.
Trenching activities for underground utilities and
subsurface drainage shall be avoided.
Subsurface utilities and drainage plans shall be
inspected by a qualified archaeologist to verify
site avoidance.
Should construction earthwork disturbance of
native soils at CA-SMa-40 be unavoidable, a
five percent sample of the affected area shall
be hand-excavated, and construction activities
monitored and specific mitigation recommended
by a qualified archaeologist. If human remains
are encountered, a Native American
representative shall be consulted.
SOURCE: EIP Corporation, 1982. Draft Environmental Impact Report for the Terrabay Development
Proiect. San Mateo County, California.
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Inventory' determined that the recommended one foot of fill soil may not be sufficient to avoid
damage to this resource during construction. As a result, potential damage to CA-SMa-40
during project construction under the 1982 EIR mitigation program may still result in a
significant adverse impact. (Supplemental Impact CR-2)
(2) cA-SMa-92. The 1982 EIR indicated that site cA-SMa-92 was revealed to have been
seriously compromised by prior underground construction, although a determination of its
significance was not possible due to the limited available knowledge and understanding of the
site. While site CA-SMa-92 is also within the area of proposed Terrabay development
activities, the 1982 EIR recommended no mitigation. However, because the project site does
have a high potential for containing Native American resources, and because subsurface
testing for the 1982 EIR was limited, there is a substantial probability of encountering and
disturbing additional cultural resources at site CA-SMa-92 during Terrabay construction,
representing a potentially significant adverse impact. (Supplemental Impact CR-3)
r (3) CA-SMa-234. There have been no changes to the area of proposed development
r contained in the 1982 specific plan. Site cA-SMa-234 is still located outside the area of
r proposed development. Any future development of Phase III would generally occur within this
r area. However, the specific plan and the San Bruno Mountain HCP do allow for minor
r adjustments in the development area boundaries. If any grading or geotechnical repair work
r becomes necessary outside of the current development area boundaries, such work could
r potentially disturb site CA-SMa-234. Potential disturbance of site CA-SMa-234 by any Phase
r III grading or repair work that may be needed outside the current development area
r boundaries represents a significant adverse impact. (Supplemental Impact CR-4)
4. SUPPLEMENTAL MITIGATION FINDINGS
a. Potential for Additional Cultural Resource Discoveries
(Supplemental Impact CR-l) In the event that subsurface cultural resources2 are
encountered during project construction, work in the immediate vicinity should be immediately
stopped and alteration of the materials or their context should be avoided until the resources
and their significance can be properly evaluated by a qualified archaeologist. The discovery
or disturbance of any cultural resources should also be reported to the California
Archaeological Inventory and the Native American Heritage Commission, and recorded on
appropriate Department of Parks and Recreation archaeological site records forms (DPR 422).
'Ibid.
2Such "subsurface cultural resources" could include prehistoric resources such as chert or obsidian
flakes, projectile points, mortars or pestles, and dark friable soil containing shell and bore dietary debris,
heat affected rock, or human burials: or could include historic resources such as stone foundations or
walls, structural remains with square nails, old wells, etc.
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Mitigation measures prescribed by these groups and required by the city should be
undertaken prior to resumption of construction activities.
b. Adequacy of 1982 EtR MitiQation Recommendations
(1) CA-SMa-40. (Supplemental Impact CR-2) In addition to mitigations recommended in
r the 1982 EIR (Table 36), as a condition of Phase III precise plan approval, require that the
r project applicant finalize and implement, as necessary, a mitigation plan for potential impacts
r to site CA-SMa-40. The mitigation plan should adhere to the mitigation approaches,
r procedures, limitations and criteria specified in Appendix K of the state CEQA Guidelines. If
r warranted, the mitigation plan may recommend a mitigation approach other than the site
r capping recommended in the 1982 EIR. If capping is selected as the preferred mitigation
r approach, CA-SMa-40 should be capped with fill soil at a minimum of one foot deeper than
the maximum depth of construction activities above or near the site. An engineering fabric,
such as polypropylene matting, should be placed over the site before fill is placed. The
capping
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should be supervised by a qualified archaeologist familiar with prehistoric archaeology in San
Mateo County so that the boundaries of the site will be properly defined. The site should be
r recorded ~n form DPR 422. Additional or different measures for site capping, a sampling
r program/test excavations prior to capping, and other recording and/or protection measures,
may be recommended by the monitoring archaeologist.
(2) CA-SMa-92. (Supplemental Impact CR-3) Prior to commencement of grading for
project Phase III, the subsurface boundaries and the significance of site CA-SMa-92 should be
properly determined through further subsurface testing by a qualified archaeologist familiar
with prehistoric archaeology in San Mateo County. Mitigations, possibly including a sampling
program followed by capping in a manner similar to that proposed for CA-SMa-40, may be
recommended. The site should be recorded on form DPR 422.
r (3) CA-SMa-234. (Supplemental Impact CR-4) Future detailed environmental review for
r subsequent project Phase III should include further consideration by a qualified archaeologist
r of site CA-SMa-234 to confirm that no impacts, including potential impacts from grading and
r geotechnical repairs or from project occupancy, would occur and to recommend mitigation, if
r warranted.
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IV. Appendices
IV. APPENDICES
APPENDIX A: PROGRAM EIR AUTHORITY (CEQA SECTION 15168)
As indicated on DSEIR page 3, the DSEIR includes "program EIR" level assessment for
subsequent project phases (Phase II on), under authority of section 15168 of the cEQA
Guidelines. Section 15168 explains that a program EIR is an EIR which may be prepared on
a series of actions that can be characterized as one large project and are related either:
(1) geographically; (2) as logical parts in the chain of contemplated actions; (3) in connection
with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a
continuing program; or (4) as individual activities carried out under the same authorizing
statutory or regulatory authority and having generally similar environmental effects which can
be mitigated in similar ways.
The proposed subsequent project phases, and the series of actions that will be required for
their implementation, are characterized by all four of these relationships. One, they are
geographically related because the project, including all of its implementing actions, would
occur in the same specific plan area. Two, the various local, state, and federal governmental
approvals, entitlements, and permits that may be required for development of the project are
all logical parts in the chain of actions contemplated by the specific plan program. Three,
development of the project area would be undertaken in connection with the issuance of rules,
regulations, plans, and other general criteria set forth in the specific plan. Four, the future
development activities would be comprised of various individual activities carried out under the
statutory authority of the city and the Terrabay Specific Plan and development agreement that
would generally have similar environmental effects that could be mitigated in similar ways.
Use of a program EIR for the still conceptual subsequent phases of the specific plan provides
the following advantages. The program EIR: (1) ensures consideration of cumulative impacts
that might be slighted in a future case-by-case project analysis process; (2) avoids duplicative
reconsideration of basic policy considerations; (3) allows the Lead Agency to consider broad
policy alternatives and program-wide mitigation measures at an early time when the agency
has greater flexibility to deal with basic problems or cumulative impacts; and (4) allows
reduction in paperwork.
Subsequent project development phases must be examined in the light of this program
EIR to determine whether an additional environmental document must be prepared. If a
later activity would have effects that were not examined in this program EIR, a new Initial
Study would need to be prepared leading to either a project-specific EIR or a Negative
Declaration. If the Agency finds that pursuant to section 15162, no new effects could occur or
no new mitigation measures would be required, the Agency can approve the activity as being
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IV. Appendices
within the scope of the project covered by this program EIR, and no new environmental
document would be required. Under cEQA section 15168, an Agency shall incorporate
feasible mitigation measures and alternatives developed in the program EIR into subsequent
actions in the program. Where the subsequent activities involve site-specific operations, the
Agency should use a written checklist or similar device to document the evaluation of the site
and the activity to determine whether the environmental effects of the operation were covered
in the program EIR.
A program EIR will be most helpful in dealing with subsequent activities if it deals with the
effects of the program as specifically and comprehensively as possible. With a good and
detailed analysis of the program, many subsequent activities can be found to be within the
scope of the project described in the program EIR, and no further environmental documents
would be required.
A program EIR can be used to simplify the task of preparing environmental documents on
later parts of the program. The program EIR can: (1) provide the basis in an Initial Study for
determining whether the later activity may have any significant effects; (2) be incorporated by
reference to deal with regional influences, secondary effects, cumulative impacts, broad
alternatives, and other factors that apply to the program as a whole; and (3) focus an EIR on
a subsequent project to permit discussion solely of new effects which had not been
considered before.
WP51 \548IFSEIRIF-IV.548
T errabay Project
City of South San Francisco
September 18, 1996
Final SEIR
IV. Appendices
APPENDIX B
SEIR CUMULATIVE DEVELOPMENT ASSUMPTIONS
East of 101 Area Plan and Brisbane General Plan land use projections referred to in response
to comment 33.12.
WP51 1548\FSEIR\F-1 V. 548
T errabay Project
City of South San Francisco
September 18.1996
Final SEIR
IV. Appendices
WP51 \548\FSEIRIF-1V.548
EAST OF 101 AREA PLAN
DRAFT ENVIRONMENTAL IMPACT REPORT
PROJECT DESCRIPTION
JANUARY 19C
Table 5
DIRECfED GROWTH ALTERNATIVE
LAND USE BREAKDOWN
Total
Existi.ag Potential Building Area
Allowed Area Building Area New Building at Buildout
Category FAR- (Acres) (Sq.Ft.) (Sq.Ft.) (Sq.Ft.)b
Planned Commercial .60 92 1,685,760 887,131 2,572,891
Ught Industrial 50 213 4,634,457 912,824 5,547,281
Planned Industrial .45 520 8,801,189 3,231,665 12,032,854
Coastal Commercial .60 61 714,060 1,190,073 1,904,133
Gateway Specific Plan 1.25 96 1,211,570 4,003,700 5,215,270
Airport Related N/A 116 N/A N/A N/A
Mixed Planned CommerciaV .60 120 649,623 2,584,038 3,233,661
Planned Industrial
Mixed Coastal CommerciaV .60 25 378,710 114,204- 492,914
Planned Industrial
Mixed Coastal CommerciaV .60 21 0 549,379 549,379
Ught Industrial
Open Space .00 66 22,100 0 22, 100
Total 1,330 18,097,469 13,473,014 31,570,483
b
These maximum Floor Area Ratios can be exceeded with provision of a master plan, or
the addition of retail services and child care centers, as provided in Area P\an Policies
LU-16, LU-23, and LU-25. However, for environmental review purposes it is assumed
that these maximum densities will generally apply.
Because buildings in the area with F ARs above those allowed under the P\an are
grand fathered, the Total Building Area at Buildout is greater than the FAR times the
acreage in most \and use categories.
a
majority of open space is along the bayshore. In addition, the Gateway
Specific Plan, as descnbed in Chapter 4.1, will continue to apply to the
Gateway properties.
The land use designations on identified key sites are as follows:
· Koll Site (Sierra Point). Planned Industrial.
. ShealWater. Mixed Planned Commercial/Planned Industrial.
. Gateway. Gateway Specific Plan.
. Oyster Point Marina Southern Area. Coastal Commercial.
. Haskins/Fuller-O'Brien. Mixed Coastal CommercialJLight Industrial.
. GatewaylHarbor Transitional Area. Planned CommerciallPlanned
Industrial.
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T errabay Project
City of South San Francisco
September 20, 1996
APPENDIX D
SUPPLEMENTAL GEOTECHNICAL INFORMATION
July 19, 1996 Memorandum from Eric McHuron, McHuron
Geosciences to Arthur Wong, City Engineer, re: Summary of
Re-evaluation of Goat Farm Cut Slopes, Terra Bay South San
Francisco, CA.
July 20, 1996 Memorandum from Eric McHuron, McHuron
Geosciences to Arthur Wong, City Engineer, re: Summary of
Debris Basin Design, Terra Bay South San Francisco, CA.
WP511548\FSEIRIF-/V.548
Final SEIR
IV. Appendices
McHURON GEOSCIENCES
1670 8th Avenue
San Francisco, Ca 94122
415 564-1364
,~ E C E ; 'J :: ~,
July 19, 1996
City of South San Francisco\..-,
P.O. Box 711 .
South San Francisco, CA 94083
Attention: Mr. Arthur Wong, City Engineer
RE: Summary of Re-evaluation of Goat Farm Cut Slopes, Terra Bay
South San Francisco, CA.,
JUl-2 5 1996
PLANNING
Dear Arthur.
Per our discussion during the conference call on July 17, I am inclosing
the 'paper trail' and what I recall of the discussions regarding the 1991-92
Supplemental Geotechnical Evaluation of the completed Goat Farm cut slopes.
The original evaluation was prompted by the City's reviewer, Roger
Foott Associates (RFA), when it became clear during grading that the exposed
material included cover materials (Pliestocene and Recent) overlying the
weathered bedrock that was originally anticipated. These slopes had various
degrees of steepness from 2:1 to 1.5:1. The grading plans called for 2:1 cuts in
cover materials and 1.5:1 in bedrock.
The Geotechnical Consultant for the Developer, PSC, presented their
supplemental evaluation dated November 29, 1991. This evaluation included
the geologic model of the cut slopes, anticipated ground water conditions,
results of inclinometers (four) at the top of the slopes and disucsses the deep-
seated faulure analyses. The report also indicated that portions of the western
slope had failed by small earth flows, and made recomendations for repairing
the failures. RFA reviewed this report and met with PSC and the City to discuss
their comments. I was present at that meeting and I summarized RFA's
comments in a letter dated February 28, 1992 (attached). As stated in the
February 28, letter, RFA generally agreed with the geologic model of the
slopes, (RFA had provided PSC with geologic maps they prepared and photos
they took during grading).
As stated in the model, some of the slopes met the original design
criterion and the slope that deviated most from the criterion was the
westernmost portion of the Goat Farm cuts (see Plates 1A & 2C of PSC report,
attached). This slope contained a wedge of cover material that overlay a
diping bedrock. PSC said that they had analyzed this slope for potential deep-
seated failures. The important factors in the slope stability model include:
orientation and location of the bedrock surface, presence or absence of
landslide shear surfaces, strenght of materials, orientation of rock defects, and
water level fluctuations. As stated in RFA's responce letter, they did have some
questions regarding the geotechnical parameters used to analyze the slope
stability of the "Goat Farm" cuts. They expressed concern about a potential
wedge- or block failure. RFA presented their concerns to PSC in a meeting at
City on February 24, 1992. The results of this meeting and PSC's responce to
our review comments were included in a PSC letter dated February 26, 1992
(attached).
Mr. Arthur Wong
Goat Farm Cut Slopes
July 19, 1996
Page 2
It is clear from the meeting and their response letter that PSC "had not
performed new analyses (sliding block/wedge) on the slopes in the western
portion of the area, taking into account post-1983 findings regarding buried
valley geometries, bedrock shears, and shear strengths of clay-rich soil
mantles." Instead they directed their attention to evaluating what would
happen in the event of a wedge failure of this slope. As PSC stated in their
original report and in their response, the wedge failure would tend to "flow
into the existing basin or collect onto the level area adjacent to the cuI de sac."
"Based on this assumption our November report recommended construction of
a berm or wall to deflect any soil debris away from the street and toward the
basin." They go on to indicate that their "recommendation was intended to
mitigate only relatively small, periodic slumps and on-going erosion so that
maintenance would not involve clean-up of the street except for the
exceptionally large events."
RFA requested and was an active reviewer of the supplementary
evaluation of the Goat Farm cut slopes. As the record shows, both slope
stability analyses and engineering judgement was used to evaluate these
slopes. An important factor in RFA's accepting the recommendations and
conclusions of the PSC evaluation was the performace of similar slopes in the
immediate vicinity and at Terra Bay. Steeoer (near 1:1) cut slopes in these
Pleistocene cover sediments are present in the road cuts along Hillside Blvd,
near Chestnut. These slopes have existed for over 30 years, with no major
wedge, nor deep-seated failures. In addition, natural slopes of similar
steepness (1.5: 1) existed along the drainage immediately adjacent the westenn
portion of the Goat Farm Cut slopes (see Plate lA). A portion of this slope still
remains after the Goat Farm slope grading. Both of these slopes have
e>.:perinced rainfall periods far in excess (including the January 4-5, 1982) of
what the Goat Farm cut slopes have e>"'Perienced. The presence and history of
these slopes was and is very compelling evidence to the long-term
performance of these Pleistocene cover sediments. It was RFA's opinion at the
time and continues to be my opinion that this information should carry
significant weight in applying engineering judgement to the future
performance of these slopes. It also carries significant weight compared to a
range of input parameters for quantative slope stability analyses.
Even given the past performance of these cover sediments in the area,
PSC and RFA felt that it was purdent to evaluate the consequences of a failure
of the wedge of Pleistocene cover materials. RFA concured with PSC that a
large wedge failure could enter the Debris Basin and spill onto the cuI de sac.
Neither PSC nor RFA felt that such a failure would block access to homes along
Parkridge Circle. RFA also agreed that the possibility of such a failure did not
constitute a "project threatenin~" potential. (PSC, Feburuary 26,1992).
At the time of the 1992 discussions, the cut slopes had undergone some
lower than normal winter rainfall, the "March Mirale", some normal and a
fairly wet winter. None of these wet periods triggered a large-scale slope
failure on any of the Pleistocene cover sediments at the site or immediate
vicinity. Small earth flow failures in the eastern portion of the westermost
"Goat Farm" cuts were triggered during the first winter after the slopes were
cuts. These earth flows were triggered in Holocene colluvial ravine fill above
McHuron
Geosciences
Mr. Arthur Wong
Goat Fann Cut Slopes
July 19, 1996
Page 3
the weathered bedrock. In the fall of 1995, these flows were excavated,
benched, filter fabric and filled with riprap, per the recommendations of PSC
and observed by McHuron Geosciences. No further movement was observed
during the last winter rains.
As I stated during the conference call, I would be happy to lead a site
visit to the site to examine these cover materials and discuss this history. I
hope that this summary helps clarify the record. Please call if you have any
questions regarding this recap or need further clarification of this matter.
Sincerely.
McHuron Geoscie
~~~on.CEG#1023
President
cc Mr. Reid Fisher, Harlan Tait
Attachements
Plates lA and 2C of PSC's Supplemental Evaluation of "Goat Fann" Cut
Slopes, dated November 29, 1992.
RFA's Review of Supplemental Geotechnical Evaluation of Completed
"Goat Farm" Cut Slopes, dated February 28, 1992.
PSC's Responses to City Reviewer's Questions, dated February 26, 1992.
McHuron
Geosciences
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RUGER FUU I I A~~UliIA I't:::s, IN\,;.
530 Howard Street, 4th Floor
San Francisco, CA 94105
Tel: (415) 7n-1262
Fax: (415) n7-9427
February 28, 1992
City of South San Francisco
Office of the City Engineer
400 Grand Avenue
South San Francisco, CA 94080
Attention: Mr. John Gibbs
RE:
Review of Supplemental Geotechnical Evaluation of
Completed "Goat farm" Cut slopes, Terrabay
Development Phase I, "South San Francisco,
California. November 29, 1991, for Terrabay
Development.
Dear John:
Per your request we have reviewed the referenced report and our comments are
included in this letter. Our comments were presented to you and PSC in a meeting on
February 24, 1992. In general, the report provides a geologic model of the site, presents
the results of the inclinometer readings and water level readings, references a 1983
report for the slope stability analysis and makes recommendations for helping to prevent
debris slides from reaching Parkridge Circle. Our general comments are presented
below.
Geologic Model
We are in general agreement with the overall geologic model of the site. We have
some differences of opinion regarding the width, location and age of movement of the
major tectonic shear zone (fault). Our field observations indicate that it is a wide band
and includes the location mapped by Bonilla (1971). This fault has moved a considerable
distance in the geologic past as evidenced by the blue-schist and green-schist facies on
either side of the fault in the vicinity of the PG&E cuts. Slickensides on the shear
surfaces and orientation of sheared tectonic inclusions within shear zones indicate a
Mr. John Gibbs
February 28, 1991
Page 2
strike-slip motion. Detailed examination of microstructures adjacent several of the
shears within the fault zone indicate that the last movement was right-lateral. These
observations and the fact that the major deformation in t~e Coast Ranges was Plio-
Pleistocene, suggests that the last movement on the fault is considerably younger than the
70 million years ago stated by PSC. Our observations during grading did not reveal any
evidence to suggest that fault movement displaced sediments that are believed to be Late
Pleistc:;>cene in age. Thus, because there is no evidence of fault movement in the last
10,000 years, fault movement does not need to be considered under the Alquist-Priolo
Act.
We agree that the important factor regarding the fault is that it acts as a
groundwater barrier because it juxtaposes relatively permeable fractured sandstone
(graywacke) on the uphill side against relatively impermeable sheared shale melange on
the downhill side.
As noted by PSC, no landslide shear zones were observed within the cuts during
excavation. However, shear zones were observed within the bedrock, and we concur with
PSC's conclusion that these shears could contribute to local slipouts.
Another important factor in the geologic model is the slope and thickness of the
highly weathered bedrock at the base of the buried valley fill. This layer tends to impede
groundwater flow and trap water with the cover sediments. The significance of this is
discussed later.
Inclinometer Measurements
The inclinometer monitoring results indicate that the deflections are very small
"noise" level and PSC feels that they are not considered significant other than normal
downhill creep. As presented, the data suggests that the "creep" movement is in the
uphill direction except for the upper 4-6 ft of SI-5.
Ground Water Monitoring
The groundwater monitoring is presented as 'Depth to Water in Inclinometer
Casings'. We agree that the inclinometer casings were not intended to be used to
monitor groundwater fluctuations, but they may provide information on general trends.
The inclinometer casings all extend into bedrock and the water level readings and any
ROGER FOOTI ASSOCIATES, INC.
Mr. John Gibbs
February 28, 1991
Page 3
fluctuations in the bedrock may be significantly different from those in the overlying
cover materials, especially where there is a thick weathered mantle on the bedrock
surface.
The water level in the cover sediments significantly effects the slope stability
analysis. The PSC report notes that the overlying cover materials are granular and
apparently assumes that groundwater will not build up in the exposed slopes. However,
observations during and after significant periods of rains indicate that substantial
portions of the cut slopes form seeps and bleed water. The jute netting is also stained by
water running down the cutslopes. These observations suggest that the areas above the
weathered bedrock contain a lot of water after periods of significant rainfall (such as
March, 1991 and mid-February, 1992), especially on the westernmost 1.5:1 cut (between
debris basins 2A & 2C.)
Slope Stability Analysis
To evaluate the slope stability of the "Goat Farm" cuts, PSC refers to their
11/15/83 report that addresses the overall stability of the slopes, and reproduces the
results of those slope stability analyses in Appendix D (November 29. 1991 report) .
These analyses were completed over eight years ago and state very clearly on the title
"FOR GENERAL REFERENCE PURPOSES" , "FOR EVALUATION PURPOSES
ONLY, NOT A RECOMMENDATION", etc. We do not understand the logic for
directly applying these analyses to the Goat Farm slopes, without considering the
additional information gained during Phase I construction.
We have the following specific questions on the geotechnical parameters used to
analyze the slope stability of the "Goat Farm" cuts:
1) What shear strength was used for the weathered melange?
2) What shear strength was used for the cover materials?
3) Where was the water level assumed to be?
It is also unclear whether all failure modes suggested by the geologic model shown
in Sections C-C' and B-B' been evaluated. Specifically, these sections suggest the
ROGER FOOTT ASSOCIATES, INC.
Mr. John Gibbs
February 28, 1991
Page 4
potential of a block glide slippage. Such a failure would be more significant than the
shallow slump failures that have already occurred.
These concerns were raised in the February 24 meeting and PSC indicated that on
page 10 of their report they indicate "..the wedge of granular material is 10 to 15 feet
thick and may slump in the event that it becomes saturated and/or is subjected to strong
earthquake loading." We agree that this slippage could occur and the City of South San
Francisco and the owners of the development need to be aware of this possibility and
have funds in place and a plan of action to clean up the debris and repair the
improvements when a failure occurs.
Recommendations
PSC has analyzed the potential for deep seated landslides. However, shallow
slipouts have occurred last winter and this winter on the 1.5:1 slope between debris
basins 2A & 2C, indicating that water is saturating portions of the cover sediments and
that the slope is too steep to prevent failure. The most recent slippage caused a debris
flow that crossed Parkridge Circle. If the slumping continues, and we have no indication
to think that it will not, it will progress up the slope and jeopardize the "V'-ditch and
eventually the HCP property line.
In their November 1991 report, PSC recommends that the steep headwalls of
these slipouts be graded back and a 2-3 foot high wall be constructed along the north side
of Parkridge Circle to help deflect any soil debris away from the street and direct the
material into Debris Basin 2A (Note that the footing for such a wall would have to be
engineered to avoid the drains that were installed at the base of the cut slopes.) Such a
wall would catch some of the debris, just as the chain-link fence has caught some of the
past debris slides. However, much of the debris slide that presently crosses Parkridge
Circle flowed down the access ramp to Debris Basin 2C. These recommended measures
do not provide any proactive mitigation to the conditions that have caused the slipouts
(Le. saturated cover soils or an oversteepened slope) or to protect the 'V'-ditch and HCP
property line. Based on our discussions in the meeting, PSC will prepare a letter that will
recommend a more proactive approach. We will be happy to review the letter when it is
finalized.
ROGER FOOTT ASSOCIATES, INC.
Mr. John Gibbs
February 28. 1991
Page 5
At present, the status is that questions remain regarding the geologic model but
these differences do not affect the suitability of the goat farm cuts. We concur with PSC
that the wedge of granular cover sediments that overlie bedrock (especially in the
westernmost cut) could fail in mass if it becomes saturated and or due to seismic loading.
During the meeting we also formally requested that PSC return the photos and
negatives that we provided them on the history of the Goat Farm cuts. Should you have
any questions regarding these comments please contact us.
Sincerely,
ROGER FOOlT ASSOCIATES, INC.
~Jd~
Principal, Chief Geologist
EJM4:13-4RLA
ROGER FOOTT ASSOCIATES, INC.
mmIJlJlI3LI
Geotechnical Consunanls
Malerials Engineering
P.O. Box 695
Peart City, Honolulu
Hawaii 96782-9998
PH: (BOB) 526-3828 (Office)
(BOB) 677-0616 (Fie/d)
FAX: (BOB) 671.2341
W. W. DEAN AND ASSOCIATES
Terrabay Development Corporation
901 Mariners Island Boulevard
San Mateo, CA 94401
February 26, 1992
Job No: 89140.25
Addendum 1
Attention:
John Ochsner
Subject:
RESPONSES TO CITY REVIEWER'S QUESTIONS
Goat Farm Cut Slopes fN~t, ,-, "r. ''': PT'.'
Terrabay Development
South San Francisco, California
r:' I, { I , , . )
Reference:
Supplemental Geotechnical Evaluation
of Completed -Goat Farm - Cut Slopes,
Terrabay Development - Phase I,
South San Francisco, California
(dated November 29, (991)
R.et..tI ii~O
Dear Mr. Ochsner:
At the City's request, we met with the City's Geotechnical Reviewer (Eric
McHuron of Roger Foott Associates) and the City's Resident Engineer (John
Gibbs) at City Hall on February 24, 1992 regarding our referenced report.
The comments from RFA were discussed and verbal responses were provided by
PSC. These responses were satisfactory to the City and RFA. In general, the
discussions concluded with the acceptance of the -Goat-Farm Cut-Slopes- report
by RFA. This was based on the understanding that the comments by RFA and
responses by PSC would be documented in an addendum letter. The purpose of
this letter is to satisfy this requirement. No new issues are discussed in this
letter.
In order to simplify the final review and acceptance of this letter, we have
paraphrased RFA's comments in the first paragraph and have provided the
comments in the following paragraphs.
REVIEWER'S OUESTIONS AND OUR RESPONSE<i
Age of Faultine -
There was no major disagreement regarding our explanation of the geologic
model. However, a question was asked regarding the 70 million year old -age
of faulting- which seems to be implied in our report.
Branch Offices: Pacheco, CA San Francisco. CA Honolulll. Hawaii
W.W. Dean' - Terrabay
Review of Goat Farm Cut Slopes
Job No.: 89140.25
February 26, 1992
Page 2
Although it was not our intent, the text of our report might be misconstrued to mean that there
has not been any movement on this fault since 70 million years ago. We recognize that
additional movements may have occurred along this fault since it originated. Striated, slicken
sides have been observed which suggest that there has been right lateral strike slip movement
along the fault since the time it was originally created by subduction 70 million years ago. The
age of last movement has not been determined. However, the key is recognition that the fault
has an absence of evidence of any Holocene age movement. Therefore, it poses no primary
surface rupture hazard and is not subject to the provisions of the Alquist-Priolo Act.
Creel> iudicated in Inclinometer Plots -
Regarding the inclinometer measurements, we were asked for clarification of our comment regarding
downhill wcreepw.
We explained that only very small adjustments (Winstrumental noiseW) were observed in the
inclinometer data and these were taken into consideration when we wrote our report. Our reference
to the exception that downhill .creep. was indicated applies to the upper 4 to 6 feet of SI-5 only.
R~pair of Slumps and Role of Seepaee -
Regarding the clean-up of the existing slumps above Basin 28, we were asked if our recommended
Wtrimming back. the edges of the existing scars would address seepage through the soil mantle above
the bedrock interface.
We noted that the clean-up work we had recommended in our November report has not been done
and that the latest rainfall Waggravated. the existing scars and caused additional slumping. The soil
debris pushed over a portion of the chain link fence and deposited on the driveway into the basin
and on the street below it. Therefore, we are now modifying our recommendation for cleaning-up
and repair work in this area. Clean-up and repair work should include installation oC subdr.ains
and/or placement or nIter fabric and rock nn to support the remaining soil and provide a
"relief mechanism" Cor the seepage. Should the client choose to do so, the debris material can be
removed, a drain can be installed, and slope can be laid back at a flatter inclination in the affected
area. This will require realignment and reconstruction of the existing V-ditch and permission from
the HCP for such modification. This can be left as an option to the client since either option should
provide the positive drainage system necessary to relieve the seepage. It is hoped that such work
will help prevent, or at least limit the extent of, such failures.
W. W. Deari - Terrabay
Review of Goat Farm Cut Slopes
Job No.: 89140.25
February 26, 1992
Page 3
Post-1983 Analyses of Slope Stability -
We were asked why we had not performed new analyses (sliding block/wedge) on the slopes in the
western portion of the area, taking into account post-1983 findings regarding buried valley
geometries, bedrock shears, and shear strengths of clay-rich soil mantles.
We explained that the approach we took for this study was to assume that such unknown factors
make it likely that .the wedge of granular material (above Debris Basin 2A) ... may slump in the
event it becomes saturated and/or is subjected to strong earthquake loading.. and that the debris
would tend to flow into the existing basin or collect onto the level area adjacent to the cui de sac..
Based on this assumption our November report recommended construction of a berm or wall to
deflect any soil debris away from the street and toward the basin.
We pointed out that the intent of our recommendation was not to prevent deposition of soil debris
on the street in the event of a single, large failure. Rather, our original recommendation was
intended to mitigate only relatively small, periodic slumps and on-going erosion so that maintenance
would not involve clean-up of the street except for the exceptionally large events. In those cases,
we would anticipate the need to remove a substantial amount of soil deposited in the street.
However, we did not consider the possibility of such effects to constitute a .project threatening-
potential. It was on that basis that we did not recommend, and continue to not recommend,
complete removal of the soil which remains in the cut slope at the western end of the Goat Farm
cut slope area.
Existine Subdrain near Debris Basin 2A -
We were asked if any new construction activities would be planned and performed in the area of
a shallow subdrain which was previously installed along the toe of the cut slope above Basin 2A.
The concern is that the drain not be damaged accidently during new work.
In response, we recommend that all of the existing improvements, including the existing
subdrain, be included in the plans for any changes in that area. All buried d....lios, utilities,
etc. should be located, flagged, and avoided during con~h'Uction.
W. W. Dean - Terrabay
Rcvicw of Goat Farm Cut Slopes
Job No.: 89140.25
February 26, 1992
Page 4
CONCLUSIONS
Our meeting concluded with the understanding that we would document our responses to the
reviewer's comments and questions, in this letter, prior to the formal acceptance of the report.
We trust that this addendum letter provides the required response. Please contact us immediately
if you have any questions regarding the information presented in this letter.
By this writing, the modified recommendations for slope repairs contained in this letter are made
a part of our November report.
Sincerely,
PSC Associates, Inc.
~
ary Parikh, GE
Principal Geotechnical Engineer
GE 666
~
ames B. Baker, CEG
Chief Engineering Geologist
CEG 1021
cc: I copy to John Ochsner
I copy to John Gibbs (City)
I copy to Eric McHuron (RFA)
I copy to Ed Steiner (L&A)
Me HURON GEOSCIENCES
1670 8th Avenue
San Francisco, Ca 94122
415 564-1364
~\EC~~.~~~~:
JUl 2 5 1996
PLANNING
July 20, 1996
City of South San Francisco
P.O. Box 711
South San Francisco, CA 94083
Attention: Mr. Arthur Wong, City Engineer
RE: Summary of Debris Basin Design, Terra Bay
South San Francisco, CA.,
Dear Arthur:
Per our discussion during the conference call on July 17, I am
enclosing the 'paper trail' and what I recall of the design of the Debris Basins.
Questions have been raised about the difference in the estimated volume of the
debris material presented in PSC's 1983 report and the capacity of the as-built
Debris Basins. The work on estimating the capatity of the basins was
completed by the developers Geotechnical (PSC) and Civil (C/REM) consultants.
The first geotechnical reviewer for South San Francisco was Harding Lawson
, followed in May of 1984 by Dames & Moore (D&M), Roger Foott Associates _(RFA)
in May of 1988 and McHuron Geosciences in November of 1995. Wilsey & Ham
(W&H) has been the Civil reviewer since 1984. D&M, RFA and W&H were also
the reviewers for the County of San Mateo.
Documents related to the design of the debris basins are contained in a
file entitled "Updated Compilation of Documents Pertaining to Terrabay
Development Catchment Basins, dated January 9, 1989. A copy of the Table of
Contents is attached to this letter. I have reviewed this compilation and other
, documents that were in the City files pertaining to the Debris basins. The
remainder of this letter presents these documents and attempt to summarizes
the rationale behind the design of the basins.
The first document related to estimation of the volumes of Debris Flow
material was by PSC (dated February 15, 1983). The volume estimate relied
heavily on the debris flows that occurred during the January 4-5, 1982 intense
rainstorm. PSC used air photos (taken after the storm) and field mapping to
estimate the volume of material that has entered the various drainages at
Terra Bay. PSC's estimates are included in a Table. They indicated in their
report (page 9) that these volumes are estimates, and "more quantitative data
probably can be provided by engineers qualified in erosion and sedimentation
practices, by adding appropriate fluid factors in their design". The report
concludes on page 12, that "in our opinion, only a small fraction of the total
debris volume reported for a particular stream would enter a catchment basin
during anyone runoff season."
The ne>.'t document is entitled "Report on Debris Flow Control Facilities
for Terrabay Residential Development (C/REM, February, 1984, revised). This
report is further referenced in a C/Rfl..lletter to W&H (dated December 27,
1988; REVISED, January 9, 1989). As stated in the letter, C/REM based their
volume estimates for the Debris Basins requiring capacity for 125% of the
Existing Debris Flow estimates provided in the fi rst section of the PSC 1983
Mr. Arthur Wong
Debris Basin Volumes
July 20, 1996
Page 2
report, plus 50% of the Extreme Event Erosion( 40% of Normal year from USGS),
plus 100 cubic yards. C/REM assumes those 125% of the 1982 debris flow
volume enters the debris basin. Over and above this amount they have an
Excess capacity in excess of 75 yards for all basins but 3C. It is important to
note that both PSC estimated that 10% of the existing 1982 debris flow material
will be released into the debris basins each year.
In D&M's Geotechnical Review: W.W. Dean and Associates, Terrabay
Development, (June 10, 1984) it is stated that the "sizing details have not been
reviewed." W&H (November 8, 1988, see attached) indicated that they were
authorized to review the submittals by C/REM for the debris basins under
contract (dated 10/19/88) with the Director of Public Works, San Mateo
County. W&H state that the "data furnished meets the criteria established by
the JPA with the exception of the items commented on in the attached
memorandum." They "recommend that the JPA approve the design of the
debris basins subjected to the accommodation of these comments being
included in the final working drawings."
The final document that I found regarding this matter was in RFA's
letter report, entitled Geotechnical Review of Proposed Terrabay Development
Stage I Grading, (February 1989). In this document, they state that "The
holding capacities of these debris basins have been based on estimates made
by PSC Associates, Inc. of the volume of debris which might be generated
during particularly heavy rainfall. We have not evaluated these estimates
which we understand had been agreed to prior to our involvement."
It seems that the overall confusion regarding the capacity of the Debris
Basins is related to people comparing the maximum estimated volumes in the
final column of the PSC table (which includes all potential sources in each
drainage basin), with the design capacity estimated by C/REM. As indicated in
the PSC text, it is not e:>..-pected that this volume would enter the basins at once
and that the estimate be reviewed by an engineer. C/REM did formulate the
final estimate using the sources indicated above (including 125% of the 1982
debris flow material measured by PSC).
As I stated during the conference call, it is interesting that over the
past six winter seasons that the amount of material retained in the basins has
been far below the annual estimate calculated by C/REM. The amount
entering this last winter season is estimated to be less than 1-2 cubic yards per
debris basin. I hope that this summary helps clarify the record. Please call if
you have any questions regarding this recap or need further clarification of
this matter.
Sincerely.
McHuron Geosciences
Dr. c J. McHuron, CEG# 1023
Presiden t
McHuron
Geosciences
January 9, 1989
TERRABA Y DEVELOPMENT
CA TCHMENT BASINS
UPOA TED COMPILATION OF DOCUMENTS
TABLE OF CONTENTS
SECTION
I J.P.A. Agreement for Maintenance of Catchment Basins on
San Bruno Mountain
II Terrabay Specific Plan Zoning Ordinance
III Terrabay Specific Plan Amendments
IV Basin Hydrology, Weir Length and Headwater Calculations _
1/7/89 (C/REM)
V Correspondence C/REM to Wilsey and Ham - Revised 1/9/89
- Summary Discussion of Catchment Basins _
VI Correspondence C/REM to Wilsey and Ham - 11/1/88
- Supplement to Original "Compilation of Documents" _
VII Report on Debris Flow Control Facilities for Terrabay
Residential Development, February, 1984 (Revised)
VIII Terrabay Development
Projection of Annual Maintenance Costs for Sedimentation
and Debris, Catchment Basins, February 1983
IX Debris Flows, Potential Debris Flow Areas,
Debris Flow Paths, Potential Debris Flow Paths, and
Estimated Volume of Debris Materials in Stream Drainage
Basins, South Slope San Bruno Mountain, San Mateo County,
California, January 31, 1983
Revised February ) 5, 1983
X Debris Basin Drawings DB-I through DB -4
REFERENCES
Section V
Revised Surface Erosion Calculations - C/REM
Volume Distribution Chart
Basin Cross-Sections
Basin Stage/Volume Curves
Section VI
PSC Associates Letter Re: Geotechnical Issues - 10/31/88
United States Geological Survey Letter Report, 1/17/83,
to San Mateo County, Department of Public Works
"Erosion and Sediment Control Handbook", 5/81 _
State of California
r... .
. .~.~ ..
. .
r
WILSEY & HAM
~~"EFJUNG A.~ ~NG smvJa:S
Pltlllie IlIIpfo_ . l..uId De ., I. . 1NI*-' .
622-1.503-12
1035 East Hillsdale Boulevard
Foster City. Calilornia 94404
(415) 349-2151
November 8, 1988
Mr. Robert Sans
Director of Public Works
San Mateo County
80.5 Veterans Blvd.
Redwood City, CA 94063
Dear Mr. Sans:
As authorized by Olr contract with you dated 10/19/88 we have reviewed the
submittals made by C/REM for the debris basins at Terrabay.
We find that the data furnished meets the criteria established by the JP A wi th the
exception of the items commented on in the attached memorandum.
We recommend that the JP A approve the design of the debris basins subjected to
the accommodation of these comments being included in the final working
drawings.
Very truly YOlrS,
WlljEY &: HAM
;} J/!/' .
(//~4J
LEE E. HAM
President
Attachments
LEH/kmg-S:2
cc: Richard Harmon
Robert Eppler
Peter Rathati
Ron Calhoun
n~_..._ "_ roo_,., . " .
-
It
1-622-1'03-12
Novem ber 3, 1988
COMMENTS ON TERRABAY DEVELOPMENT,
DEBRJS BASIN FAOLITIES
Qu- comments are based on the revised "Criteria for Review of Debris Basins for
Ter-rabay Residential Development", Job No. 622-1'03-14 prepared by Wilsey c!c
Ham. The revision was made per Robert Sans' (Director of Public Works, San
Mateo County) request, on October 20, 1988. According to Robert Sans' direction,
the debris basins shall not be designed as sediment basins. Dependent on the
accumulated sediment (debris) volume in the basins, a significant part of the
sediment er~ded from areas above the basins will not be trapped by the basins.
A. Comments of PSC's Letter (October 31, 1988)
I. Before the final submittal, PSC Associates, Inc. shaU certify that
applicable portions of the plans have been prepared in accordance
with the recommendations contained in the Geotechnical Reports,
Debris Flow Report and the I:ICriteria for Review of Debris Basins
for Terrabay Residential Development", prepared by Wilsey c!c Ham.
1
2. PSC ".....would like to co..ent on .everal items
which .ay not be available for review at this time"
(see PSC's letter). Before the final submittal one
copy of the catchment basin docu.entation shall be
given to PSC for comments.
3. PSC'. letter (dated October 31, 1988) shall be
attached to the final submittal.
B. g!~!r!! ~2~~!~1! (Based on the Latest Submittal of the
Applicant, Dated October 12, 1988)
1. The current design does not provide debris
rack/security fencing at the inlet channels. "Fence
to .pan channel allow 1'-6" clear between fence and
. .
channel bottom" note is shown on the plans. JPA
should give recommendations for the fencing issue.
2. The road grade between the street and debris basins
shall not exceed 15'. Provide 2-inch A.C. Paving
for access roads. Where grades are steeper then
lO~t 3-inch A.C. Pavine shall be provided.
3. The slopes of the basins shall be paved with ainimum
6-inch reinforced concrete sleb.
2
.
~
4. The hydraulic calculation of the outflow weirs shall
be submitted. In the calculation the trashrack
losses and end effects shall be taken into account.
5. HydrololY calculation for Basin Ho. 2C and 3A sball
be sub.itted to verify runoff.
6. Hydraulic calculation aball be .ub.itted for tbe
required headwater in the outlet boxes of Basin 2C
and 3A.
7. Give note for tbe construction joints.
8. Floor slabs sball have a aini.u. thickness of 9
incbes. Steel clearances shall Dot be less than
2 1/2 inches at the botto. of tbe botto. slabs.
9. The freeboard for overflow outlets shall be 12
inches ainiaum.
3
,
~
(
~
C. ~~~~~D!!
1. Pr!~jDg P~:l
a. Provide uniform slope between the inlet channel
and the outlet structure.
b. Provide adequate space f~r the debris flow
between the outlet structure and the side inlet
channel.
c. The exterior wall top elevation of Basin Mo. 2A
shall not be less than 326.00.
d. The 6" x 6" - W2.9 x W2.9 WWF should not 10
throu,b the construction joints. (see Slope
Protection Detail 3/BD-l).
e. The available headwater in the outlet box of
Basin Mo. I is not acceptable. The distance
between the weir elevation and water aurface in
the outlet box shall not be less than 12 inches.
2. Pr!~iDg p>>:~
a. Show the pipe data for all stor. drains.
b. Check the slope above cul-de-sac for atability.
The soils engineer shall approve the bei,ht of
the slope.
c. For the better drainage provide adequate slope
for the botto. slab of Basin No. 2A.
4
-
e
3. ~r~~jEg ~!=~
a. Show the slab elevation of Basin Ho. 3C.
b. Provide uniform slope from the inlet channel to
to the outlet box.
c. The 12' slope width, which is ShOWD on the plan
of Basin No. 3A, is Dot correct.
d. Is the available area ade~uate for the
aaintenance equipment?
e. The proposed trade between the access road of
Basin No. 3A and bench is too steep.
f. Submit storage volume calculation for Basin No.
3A. If the proposed voluae is less than the
required volume .odify the plans of the basin.
4. Rr~~iE. ~!=~
a. The "proposed trade behind wall" ahall be
.odified OD the elevations of the walls, because
the freeboards are not shown.
b. Retaining walls will be checked separately.
5
T errabay Project
City of South San Francisco
September 18,1996
Final SEIR
IV. Appendices
WP51 1548IFSEIRIF-1 V. 548