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HomeMy WebLinkAboutEast Jaime Court Response to Comments Initial Study and MNDRESPONSE TO COMMENTS Initial Study and Mitigated Negative Declaration East Jamie Court Project City of South San Francisco Morehouse Associates RESPONSE TO COMMENTS Initial Study and Mitigated Negative Declaration East Jamie Court Project SCH #2002092042 Prepared for: City of South San Francisco Planning Division 315 Maple Avenue South San Francisco, CA 94080 Prepared by: Morehouse Associates Consultants in Urban Planning and Design Corte Madera, CA In association with: Dowling Associates, Oakland Don Ballanti, Certified Consulting Meteorologist, El Cerrito Andrew Leahy, Registered Civil Engineer, San Francisco Kennedy/Jenks Consultants, San Francisco Treadwell & Rollo, Oakland LSA Associates, Point Richmond November, 2002 TABLE OF CONTENTS Page 1. INTRODUCTION ......................................................................................... 1 2. LETTERS AND RESPONSES TO COMMENTS .....................................1 State Clearinghouse ,Acknowledgement of Receipt of Comments ..................... 2 State Clearinghouse, Terry Roberts, Director ..................................................... 3 State Clearinghouse Data Base, Document Details Report .................:............... 4 CalTrans, Timothy C. Sable, District Branch Chief ............................................ 5 CCAG, David F. Carbone, ALUC Staff .............................................................. 7 Department of Toxic Substances Control, Barbara Cook, P.E., Chief ................ 9 Department of Fish and Game, Robert W. Floerke, Regional Manager ........... 12 Givas, Dean, Oyster Development Corp. (Letter # 1) .................................... 15 Givas, Dean, Oyster Development Corp. (Letter #2) .................................... 28 H.T. Harvey &Associates .................................................................................49 Givas, Dean, Oyster Development Corp. (Letter #3) ........................................ 50 KC Engineering ................................................................................................. 55 Malcolmson, Niall, Dowler-Gruman Architects .............................................. 62 Pacific Gas and Electric Co., Alfred Poon, Land Agent ................................... 64 RESPONSE TO COMMENTS Initial Study and Mitigated Negative Declaration East Jamie Court Project ERRATA Nov. 1, 2002 The following minor errors in the Response to Comments document are corrected below. Page 11 The first paragraph under comment number 1 should be underlined. Page 14 The first paragraph under comment number 4 should be underlined. Page 17 Under response to comment number 2, the response should reference Comment #13 in Givas Letter #2, rather than Letter #1. Page 32 Response to comment number 5 was accidentally left out. The following response is inserted: "As per the prior responses to Fish and Game Department letter above, the comment is accurate. Based on the H.T. Harvey delineation, the Project will not cause any impacts to seasonal wetlands". Page 38 Comment number 15 was left out at the top of the page. The following comment is inserted prior to the response that begins "Comment acknowledged": "15. XVIb, p~. 63 -Please restate the mitigation measure to reflect the Project's `participation in an eventual wastewater program to be incorporated into the City's General Plan'." Morehouse Associates RESPONSE TO COMMENTS INTRODUCTION The California Environmental Quality Act (CEQA) requires that public comments on the potential impacts of proposed projects be considered by decision-makers (CEQA Guidelines 15088). This document contains written responses to comments on the Draft Initial Study and Mitigated Negative Declaration for the proposed East Jamie Court Project in the City of South San Francisco. The Draft document was released for public and agency comment on September 13, 2002, for a 30-day period, ending October 15, 2002. Agencies which received copies from the State Clearinghouse are listed in the Acknowledgement of Receipt letter dated October 16, 2002. The combination of the Draft Initial Study and Mitigated Negative Declaration, public comments, and responses to the comments by the authors of the report comprise the Final Initial Study and Mitigated Negative Declaration. No direct changes are made to the DRAFT as a result of comments received; however, this document references places in the Initial Study where the text "shall be assumed to be revised" based upon the authors' responses to comments. The purpose of the final report is to inform decision makers about potential impacts of the Project, and recommended mitigation measures that are made a part of the proposed Project.. The Council/Redevelopment Agency may deny the Project as proposed, approve it with certain mitigations, approve it with possible conditions, or approve an alternative project. LETTERS AND RESPONSES TO COMMENTS Letters received during the comment period are reproduced on the following pages. Comments in the letters which have a potential bearing on the impacts of the proposed project or recommended mitigation measures are assigned numbers. The numbered comments are then responded to, immediately following each letter. The responses may include specific modifications and additions to the text or figures in the Draft Initial Study and Mitigated Negative Declaration. City of South San Francisco, November 2002 -1- Final Initial Study, East Jamie Court Project .^`.°..`..r~ STATE OF CALIFOR\ IA Q' :: A~... .~• ~~° ~ ~) Governor's Office of Planning and Research ~;~~,~, ;, ~LIFOPP~' State Clearinghouse Gra}- Day-is ACKNOWLEDGEMENT OF RECEIPT GOVERNOR DATE: October 16, 2002 TO: Susy Kalkin City of South San Francisco 315 Maple Avenue South San Francisco, CA 94080 RE: East Jamie Court Project SCH#: 2002092042 o4E`OEOF~ •5 ~ O _* ~~ ~~~ OF L~IIFOP~~'. Tal Finney INTERI\i DIRECTOR RECE,~IED O C T 2 1 20Q2 PLANP~1l~G This is to acknowledge that the State Clearinghouse has I-eceived your- environmental document for state review. The review period assigned by the State Clearinghouse is: Review Start Date: September 13, 2002 Review End Date: October 15, 2002 We have distributed your document to the following agencies and departments: California Highway Patrol Caltrans, District 4 Caltrans, Division of Aeronautics Department of Conservation Department of Fish and Game, Region 3 Department of Parks and Recreation Department of Toxic Substances Control Department of Water Resources Native American Heritage Commission Regional Water duality Control. Ftoard, Region 2 Resources Agency San Francisco Bay Conservation and Development Commission State Lands Commission The State Clearinghouse will provide a closing letter with any state agency comments to your attention on the date following the close of the review period. Thank you for your participation in the State Clearinghouse review process. 1400 TENTH STREET P.O. BOl" 3044 SACRAMENTO, CALIFORNIA 95SI2-3044 916-qq5-0613 FAS qTF-vt-~o18 www.opr.ca.gov -2- .'`.~s`:°`r.,~, STATE OE CALIEOR\ IA P'~~). --i:'j Governor's Office of Planning and Research ~.,~ . ,~-;~ „,-'~ State Clearinghouse Gray Davis GovERNOR October 16, 2002 Susy Kalkin City of South San Francisco 315 Maple Avenue South San Francisco, CA 94080 Subject: East Jamie Court Project SCH#: 2002092042 Dear mousy Kaikln RECEIVEp ~ ~ T C ] Z~J02 PL~tNNiNG oFE``E OF A ~O c ~ R ~~ ~~~ OF CAUFOP~\'• Tal Finnev INTERIDI DIRECTOfi The State Clearinghouse submitted the above named Negative Declaration to selected state agencies for t review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on October 15, 2002, and the comments from the responding agency (ies) is (are) enclosed. If this comment package is not in order, please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly. Please note that Section 21104(c) of the California Public Resources Code states that "A responsible 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. Those comments shall be suppurted by specific documentation." These comments are forwarded for use in preparing your final environmental document. Should you need more information or clarification of the enclosed comments, we recommend that you contact the commenting agency directly. 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 the State C'.esringhouse at (916) 445-Ohl if you have any questions regarding the environmental review process. Sincerely, ------- Terry Roberts Director, State Clearinghouse Enclosures cc: Resources Agency 1400 TENTH STREET P.O. BOX 304q SACRAb1ENT0, CALIFORNIA 95812-3044 916-445-0613 FAX 916-323-3018 www.opr.ca.gov -3- Document Details Report State Clearinghouse Data Base SCH# 2002092042 Project Title East Jamie Court Project Lead Agency South San Francisco, City of Type Neg Negative Declaration Description Use permit to develop atwo-story office building and athree-story office building totaling 133,000 sf on a 6.13 acre filled site, adjacent to San Francisco Bay. Lead Agency Contact Name Susy Kalkin Agency City of South San Francisco Phone 650-877-8535 email Address 315 Maple Avenue City South San Francisco Project Location County San f~lateo City South San Francisco Region Cross Streets Haskins Way and East Jamie Court Parcel No. 015-102-250 Parcel 2 Township Range Fax State CA Zip 94080 Section Base Proximity to: Highways 82 Airports S.F.International Railways Waterways San Francisco Bay Schools Land Use P-1 Planned Industrial/Mixed Industrial/Coastal Commercial Project Issues AestheticNisual; Agricultural Land; Air Quality; Archaeologic-Historic; Drainage/Absorption; Flood Plain/Flooding; Geologic/Seismic; Minerals; Noise; Public Services; Schools/Universities; Sewer Capacity; Soil Erosion/Compaction/Grading; Solid Waste; Toxic/Hazardous; Traffic/Circulation; Water Quality; Wetland/Riparian; Wildlife; Landuse; Cumulative Effects Reviewing Resources Agency; Department of Conservation; Department of Fish and Game, Region 3; Agencies Department of Parks and Recreation; San Francisco Bay Conservation and Development Commission; Department of Water Resources; Caltrans, Division of Aeronautics; California Highway Patrol; Caltrans, District 4; Regional Water Quality Control Board, Region 2; Department of Toxic Substances Control; Native American Heritage Commission; State Lands Commission Date Received 09/13/2002 Start of Review 09/13/2002 End of Review 10/15/2002 -4- Note: Blanks in data fields result from insufficient information provided by lead agency. STATE OF CALIFORNIA-BUSINESS TRANSPORTATION AND HOUSING AGENCl GRAl DAMS Governor DEPARTMENT OF TRANSPORTATION P. O. BOX 23660 OAKLAND, CA 94623-0660 ~ ` ~ ~ ~ 4'~ (510) 286-4444 Flex your power! (510) 286-4454 TDD G' t ~' ~ 1 "!?n~ Be energy efficient! i L;;UL PLAi'i~iNG CALTRANS October 10, 2002 Ms. Susy Kalkin, Principal Planner Planning Division City of South San Francisco 315 Maple Avenue South San Francisco, CA 94083 Dear Ms. Kalkin: SM-101-R20.72 SM101358 SCH# 2002092042 EAST JAMIE COURT PROJECT - INITITAL STUDY/MITIGATED NEGATIVE DECLARATION Thank you for including the California Department of Transportation in the environmental review process for the above-referenced project. We have examined the Initial Study/1Vlitigated Negative Declaration (IS/MND), and offer the following comments. 1. Please provide for our review the 2003 and 2020 Intersection Operations analysis for the built and no-built conditions, and identify all impacted intersections on U.S. 101 with their calculations of fair-share contribution towards improvements. 2. There appear to be discrepancies in the Year 2020 With Project AM peak hour Levels of Service (LOS) between the Transportation Impact Analysis in this IS/MND and the City of South San Francisco's Traffic Z Impact Fee Study East of 101 Area. The IS/MND shows the LOS for the South Airport Boulevard/U.S. 101 Northbound intersection as D while the latter shows a LOS of F. This intersection's LOS inconsistency should be corrected and be identified as an impacted intersection. ._ Please call Rick Kuo of my staff at (510) 286-5988 if you have any questions regarding this letter. Sincerely, ~. TIMOTH C. SABLE District Branch Chief IGR/CEQA c: Katie Shulte Joung (State Clearinghouse) -5- "Caltrans improves mo6ilily across California" RESPONSE TO COMMENTS RESPONSE TO LETTER FROM TIMOTHY SABLE, DISTRICT BRANCH CHIEF, CALIFORNIA DEPARTMENT OF TRANSPORTATION 1. Please provide for our review the 2003 and 2020 Intersection Operations analysis for the built and no-built conditions, and identif a~pacted intersections on US 101 with their calculations of fair-share contribution toward improvements. Comment acknowledged. Copies of the 2003 and 2020 Intersection Operations analysis have been transmitted to the City of South San Francisco and to Rick Kuo at the California Department of Transportation. 2. There appear to be discrepancies in the Year 2020 With Project AM peak hour Levels of Service (LOS) between the Transportation Impact Analysis in this IS/MND and the Cit~f South Francisco's Traffic Impact Fee Study East of 101 Area. The IS/MND shows the LOS for the South Airport Boulevard/U.S. 101 Northbound intersection a D while the latter shows a LOS of F. This intersection's LOS inconsistency should be corrected and be identified as an impacted intersection. Comment noted. Morning (7:00-9:00 AM) peak period vehicle turning movement counts were conducted in July, 2002 at the intersection of South Airport Boulevard/LJ.S. 101 Northbound Ramps. These newer counts were lower on certain movements than the factored 1998 counts that were used in the previous studies in this vicinity. A consistency check was also performed with counts at adjacent intersections (intersection of Airport Boulevard/Gateway Boulevard and Utah Avenue/South Airport Boulevard) to assure the conservation of flows. Using the updated 2002 traffic counts as a base for analysis, this intersection would operate at LOS D with 2020+ traffic conditions and no mitigation is recommended. City of South San Francisco, November 2002 -6- Final Initial Study, East Jamie Court Project CCAG CITY/COUNTY ASSOCIATION OF GOVERNMENTS R ~ C /; ~ ; OF SAN MATED COUNTY l i/ ~{~ D ~'; ,'% J vt ` ' ! ° :. (/` t Atherton • Bebnonr • Brisbmte • Burlingame • Colnta • Dnly City • Enst Palo Alto • Fosrer Ciry • HnlJMoon Bap • Hillsbo+•ough = Menlo Pai~Ct~~ ~%jr;~'lbrne .:` Pacifica • Portola Valley • RedN~ood Ciry • San Brtuto • San Carlos • Smt Mateo • San ~Ylateo County • South Smt Francisco • YVoodside C/CAG September 30, 2002 Susy Kalkin, Principal Planner Planning Division 31 ~ Maple Ave. South San Francisco, CA 94083 Dear Susy: RE: C/CAG Airport Land Use Committee (ALUC) Staff Comments on an Initial Study and Draft Mitigated Negative Declaration -East Jamie Court Office_R&D Project The project site is located within the Federal Aviation Regulations FAR Part 77 Horizontal Surface for airspace protection at San Francisco International Airport. This imaginary surface is located 150 feet above the Airport elevation (11 feet above mean sea level (AMSL)). The Horizontal Surface _ elevation above the site is, therefore, 161 feet AMSL. The highest point of the two office buildings above mean sea level (top of Building No: 2) is 111 feet AMSL (89 feet plus 22 feet (site elevation). J This elevation is well below the Horizontal Surface Elevation' of 161 AMSL. Therefore, the project sponsors not required to officially notify the FAA for an airspace evaluation. No other airport/land use compatibility issues appear relevant to the proposed project. Thank you for the opportunity to comment on the above-referenced document. If you have any questions, please contact me at 650/363-4417. ,.~ Sincerely% ~ 1 David >~ . Carbone, ALUC Staff cc: C/CAG Airport Land Use Committee (ALUC) Members Richard Napier, CCAG Executive Director Nixon Lam, SFIA Planning susykletjamiect.doc -7- 555 COUNTY CENTER, 5TH FLOOR, REDWOOD CIrY, CA 94063 •650/599-1406 • 650/594-9980 (FRM00341.DOC) RESPONSE TO COMMENTS RESPONSE TO LETTER FROM C/CAG, CITY/COUNTY ASSOCIATION OF GOVERNMENTS, DAVID F. CARBONE, ALUC STAFF 1. The highest point of the two office buildings above mean sea level (top of Building No. 2) is 111 feet AMSL (89 feet plus 22 feet (site elevation). Therefore, the project sponsor is not required to officially notify the FAA for an airspace evaluation. No other airport/land use compatibility issues appear relevant to the proposed project Comment acknowledged. City of South San Francisco, November 2002 -8- Final Initial Study, East Jamie Court Project Winston H. Hickox Agency Secretary California Environmental Protection Agency Department of Toxlc Substances Control October 11, 2002 Edwin F. Lowry, Director 700 Heinz Avenue, Suite 200 Berkeley, California 94710-2721 DTSC Ms. Susy Kalkin Planning Division City of South San Francisco 315 Maple Avenue South San Francisco, California 94083 Dear Ms. Kalkin: ~~'~f~!hlI,~IG :'~~ •"~& ,° . ~ ~, ~,~ Gray Davis Governor Thank you for the opportunity to comment on the Draft Initial Study and Mitigated Negative Declaration for the East Jamie Court Project (SCH # 2002092042). As you may be aware, the California Department of Toxic Substances Control (DTSC) oversees the cleanup of sites where hazardous substances have been released pursuant to the California Health and Safety Code, Division 20, Chapter 6.8. As a Resource Agency, DTSC is submitting comments to ensure that the environmental documentation prepared for this project to address the California Environmental Quality Act (CEQA) adequately addresses any required remediation activities which may be required to address any hazardous substances release. DTSC has reviewed the Draft Initial Study and Mitigated Negative Declaration and the December 20, 2001 Report of Phase II Subsurface Investigation prepared by Environ for the project site. These documents discuss the occurrence of metals in soil at the site at concentrations that are within the published soil concentrations for naturally occurring background levels. However, these documents do not detail the concentrations of metals detected in site soil and the background metals concentrations to which the concentrations in site soil were compared. Without this information, we are not able to determine whether the metals in soil would pose an unacceptable risk to the on-site workers or the environment. The Background Concentrations of Trace and Major Elements in California Soil report that is referenced in the 2001 Report of Phase II Subsurface Investigation and which was used as the source of background metals concentrations includes Statewide averages. DTSC typically uses local background soil concentrations as a basis for comparison. The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our Web-site at www.dtsc.ca.gov. ® Printed on Recycled Paper -9- Ms. Susy Kalkin October 11, 2002 Page Two Please contact Patrick Lee at (510) 540-3847 if you have any questions. Thank you in advance for your cooperation in this matter. Sincerely, . _, ~~ J Barbara J. Cook, P.E., Chief Northern California -Coastal Cleanup Operations Branch Enclosures cc: without enclosures Governor's Office of Planning and Research State Clearinghouse P. O. Box 3044 Sacramento, California 95812-3044 Guenther Moskat CEQA Tracking Center Department of Toxic Substances Control P.O. Box 806 Sacramento, California 95812-0806 -10- RESPONSE TO COMMENTS RESPONSE TO LETTER FROM THE DEPARTMENT OF TOXIC SUBSTANCES CONTROL, BARBARA COOK, P.E., CHIEF DTSC has reviewed the Draft Initial Study and Mitigated Negative Declaration and the December 20,2001 Report of Phase II Subsurface Investigation prepared by Environ for the project site. These documents discuss the occurrence of metals in soil at the site at concentrations that are within the published soil concentrations for naturally occurring background levels. However, these documents do not detail the concentrations of metals detected in site soil and the background metals concentrations to which the concentrations in site soil were compared. Without this information we are not able to determine whether the metals in soil would pose an unacceptable risk to the on-site workers or the environment. The Background Concentrations of Trace and Major Elements in California Soil report that is referenced in the 2001 Report of Phase II Subsurface Investigation and which was used as the source of background metals concentrations as a basis for comparison. Comment noted. Prior studies for the site (Dames & Moore, 1990; Dames & Moore, 1993) were reviewed by the San Francisco Regional Water Quality Control Board (Board) and the Board issued an opinion stating that the soils contamination at the site was not of concern. Since the Board stated their lack of concern relative to soil contamination, it was felt that further investigation of soil contamination issues was not necessary and the 2001 studies and reports addressed only groundwater contamination issues. City of South San Francisco, November 2002 -11- Final Initial Study, East Jamie Court Project State of California -The Resources A enc ~ifi J~v~+f,3 9 Y DEPARTMENT OF FISH AND GAME _` http://www.dfg.ca.gov POST OFFICE BOX 47 YOUNTVILLE, CALIFORNIA 94599 (707)944-5500 October 1, 2002 FISH 8~ GAME Ms. Susy Kalkin, Principal Planner City of South San Francisco 315 Maple Avenue South San Francisco, CA 94080 Dear Ms. Kalkin: GRAY DAVIS, Governor `~-~. r .' :~::~~ r~ i ~` ~ ~ PL~ifVrf f(~;G Mitigated Negative Declaration East Jamie Court Project, San Mateo County SCH #2002092042 Department of Fish and Game (DFG) personnel have reviewed the Mitigated Negative Declaration for the proposed East Jamie Court Project. The project involves construction of two office buildings on a 6.13-acre site adjacent to San Francisco Bay. we offer the following comments for your consideration. The document cites potential jurisdictional wetlands on the site -I which would be affected by the project; however, formal delineation has not been done. Wetland impacts have not been quantified, nor has specific mitigation been described. This does not meet the California--~ Environmental Quality Act (CEQA) requirements for full disclosure and _~ informed public review. The wetland delineation needs to be done so wetland impacts, if any, can be quantified and specific mitigation proposals can be developed. Any environmental document not including this information must be judged inadequate. DFG recommends deferring consideration of this project until a revised document incorporating the requested information has been completed and circulated for public review. Thank you for the opportunity to review and comment on this project. If you have questions, please contact Jeannine DeWald, Associate Wildlife Biologist, at (831) 649-2934; or Scott Wilson, Habitat Conservation Supervisor, at (707) 944-5584. Sincerely, ~~1~~ ~~;~~.~~ ~obert Floerke Regiona Manager Central Coast Region cc: State Clearinghouse Sacramento, CA - - -12- .; ,...; . ,, 1 Z 3 4 RESPONSE TO COMMENTS DEPARTMENT OF FISH AND GAME, ROBERT W. FLOERKE, REGIONAL MANAGER 1.The document cites potential jurisdictional wetlands on the site which would be affected by the project• however formal delineation has not been done. A formal delineation has been performed. This delineation found that that the site supports less wetland than indicated in the Mitigated Negative Declaration (MND). The MND identified two areas of the property that may contain jurisdictional wetlands under Section 404 of the Federal Clean Water Act. The first area consists of two patches of possible seasonal wetlands that occur within a constructed Swale along the eastern and northern boundary of the site. The second area is a zone of upper salt marsh vegetation in the areas where the storm drain outfall will be replaced. Since the issuance of the Initial Study, the Project proponent has had a formal wetland delineation performed by H.T. Harvey and Associates in accordance with Corps of Engineers methodology (H.T. Harvey 2002). This delineation found that the Swale area does not contain potentially jurisdictional wetlands because it does not meet the technical criteria required by the Corps. The delineation found that the upper salt marsh area did meet the Corps delineation requirements and is likely to be jurisdictional. 2. Wetland impacts have not been Quantified, nor has specific mitigation been described. This comment is incorrect. The MND provides potential wetland impact quantities and describes wetland mitigation measures at a level that ensures adequate avoidance of wetlands and their replacement. Under the discussion for Impact 4c, the MND states that a total of approximately 2,800 square feet of potential seasonal wetland impacts will occur within the constructed Swale along the eastern and northern boundary of the site. As discussed above under Comment No. 1, the H.T. Harvey delineation has determined that the swale is not jurisdictional. Assuming that the delineation is accepted by the Corps, there will be no seasonal wetland impacts, and no mitigation requirement. However, if the Corps determines that the swale does contain jurisdictional wetlands, then the mitigation measures contained in Discussion IV c would be applicable. This mitigation measures state that impacted jurisdictional wetlands shall be replaced with new wetland habitat established within or adjacent to the Project site, with preference to placement of the wetlands in zones on either side of the Bay Trail. The mitigation requirement further states that the final designs, locations and extent of replacement wetlands should be made acceptable to the Corps and RWQCB. The MND states under Discussion IVa, that another approximate 350 square feet of temporary impacts to cordgrass marsh will occur for outfall pipe installation. This impact is deemed to be less than significant because the disturbed area is expected to recolonize with cordgrass, provided that the contractor restores submerged substrates to pre-project conditions. The MND also states that permanent wetland impacts from outfall installation will be approximately 400 square feet of upper salt marsh habitat. However, based on the results of the H.T. Harvey delineation, the Applicant has revised his plans so that all potential upper salt marsh and cordgrass wetlands will be avoided. The Applicant City of South San Francisco, November 2002 -13- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS specifically has revised the storm drain plan so that there will be no need to install a new outfall. This eliminates any permanent or temporary impacts to the upper salt marsh and cordgrass habitats. These plan changes are outlined in Givas letter No. 3, Comment #3 from Oyster Development Corporation, dated October 15, 2002. 3. This does not meet the requirement of the California Environmental Quality Act (CEQA) for full disclosure and informed public review. The potential wetland impacts and mitigation measures contained in the MND are based on a more detailed Biological Report in the appendix of the Initial Study, which provides a level of information and analysis consistent with a finding of a Negative Declaration. The level of detail is consistent with Section 15063 of the CEQA guidelines, and the same as conducted for other projects in the vicinity that have completed CEQA review and certification. 4. The wetland delineation needs to be done so wetland impacts, if any, can be quantified and specific mitigation proposals can be developed. Any environmental document not including this information must be judged inadequate. See prior responses to Comments 1-3. City of South San Francisco, November 2002 -14- Final Initial Study, East Jamie Court Project GIVAS #1 Subj: FW: Mitigated Negative Declaration Date: 9/20/2002 2:36:26 PM Pacific Daylight Time From: [email protected] (Kalkin, Susy) To: [email protected] (Richard Morehouse (E-mail)) Richard -Just thought I'd forward for your review. Susy -----Original Message----- From: Dean Givas [mailto:[email protected] Sent: Friday, September 20, 2002 12:24 AM To: [email protected] Cc: 'Stephen Richardson'; 'Vin Ciruzzi'; 'Niall Malcolmson' Subject: Mitigated Negative Declaration Susy, As I mentioned, I had some questions following my review of the MND for the Jaime Court property. Your response to the following questions will be helpful in formulating our formal comments to the document. My questions are as follows: Item IV c, pg. 35 - What is required by General Plan Policy 7.1-G2 ~ regarding restoration of the salt marsh? ~ " Item XI b, pg 53 -Does the site require monitoring during pile driving? Our geotechnical investigation has been completed and provided yet 2 the language in the document reads "Depending on geotechnical site conditions, pile driving shall be monitored..." "' Item XV -The traffic mitigations remain very confusing. Can we get an estimate of which intersections will be covered by payment of the East of 101 fee and which will require the applicant to contribute their proportionate share? We had previously discussed a total of 8 intersections 3 with only 3 not being covered by payment of the fee. The verbiage of the Summary, the Checklist and Appendix seem inconsistent and at time suggests that we will both pay a fee and contribute towards as many as 15 intersections. The conflicting language is as follows: Item XV a, pg 23 - "...and participate in a traffic improvement fee at eight ~j ~ impacted intersections in the East of 101 area." J Item XV a, pg 60 - "The Project would participate in the traffic improvement -' fee in the East 101 area and would contribute a proportionate amount of the cost of improvements at the eight impacted intersections..." Appx 26 - "The Project shall contribute a proportionate amount to the cost of improvements at these seven intersections." (Referring to Year 2003 ~ 6 conditions.) J Appx-27 - "The Project will participate in the traffic improvement fee in the East of 101 area and will pay a fair share of the cost of improvements 7 based on traffic generated and impacts on service levels." -15- Appx-28 - "The East Jaime Court Project shall participate in transportation improvement funding programs as approved by the City of South San Francisco in conjunction with the East of 101 T1P." Appx 28 - "The Project shall contribute a proportionate amount to the cost of improvements at these eight intersections." (Referring to Year 2020 conditions.) In addition, there are 2 intersections with the same improvements proposed for both 2003 and 2020 yet the applicants proportionate share differs. What are the correct allocations? * Item XVI b, pg 63 and XVII, pg 65 -The obligations on the applicant in the wastewater and sewer sections are also unclear. Mitigations are not clear whether they apply to the applicant or the City. If they apply to the applicant, what is the target for reduction. Pg. 63 states that "City should develop a program that encourages R&D facilities and pharmaceutical manufacturers to reduce the total volume of wastewater discharged to the collection system..." and refers to measures such as recycling and/or pretreatment, and alternative discharge patterns. The mitigation on the same page then states "Incorporation of these wastewater reduction measures as part of the Project should reduce ..." In comparison, the mitigation measure on Pg. 65 is "Encourage R&D facilities and pharmaceutical manufacturers to reduce wastewater discharged into the collection system, inv~olving...Develop a sewer collection model...ad require fair share contributions to benefiting property owners." Susy, we look forward to your help clarifying these matters. Please let me know if any of my questions are unclear. Thanks in advance. Dean Dean D. Givas President Cyster Development Corp. 2070 Vallejo Street, San Francisco, CA 94123 Telephone/Fax 415/447-8578 Mobile: 415/298-3326 E-Mail: <mailto:[email protected]> [email protected] -I 8 J9 10 -16- RESPONSE TO COMMENTS RESPONSE TO LETTER NUMBER I FROM DEAN GIVAS, OYSTER DEVELOPMENT CORP. 1. Item IV c, pg. 35 -What is required by General Plan Policy 7.1-G-2? The policy requires saltmarshes and freshwater wetlands to be protected where reasonable and feasible. However, mitigation of impacts to tidal and freshwater wetlands may not be necessary, because the scope of the Project has changed. The plan as described in the Initial Study included expansion of a storm drain outfall in waters of the Bay. The current plan eliminates the outfall, so there would be no impact of fill on the saltmarsh. Since the draft Mitigated Negative Declaration was released for public comment, the Applicant retained a biologist (J.T. Harvey & Associates) to prepare the "East Jamie Court Identification of Waters of the U.S". The proposed Bay Trail may not impact surveyed jurisdictional wetlands of the Corps. Also, there may be no impact to the freshwater wetlands described in the Initial Checklist (Biological Resources Discussion IVc). See response to comment No. 8, Givas letter Number 2, for discussion of the impact of the proposed Bay Trail on the saltmarsh. With these changes to the Project, General Plan Policy 7.1-G-2 may not be applicable. Therefore, the General Plan Policy on wetlands protection may not be relevant to the current Project description except for protection of the shoreline band during construction.. 2. Item XI b. Pg 53 -Does the site require monitoring during_pile drivin~geotechnical investigation has been completed and provided, yet the lan uage in the document reads "Depending on Geotechnical site conditions, pile driving shall be monitored ..." Different types of monitoring that may be required are discussed in response to Comment # 13 in Givas Letter # 1. 3. Item XV -The traffic mitigations remain very confusing. Can we get an estimate of which intersections will be covered b~payment of the East of 101 fee and which will require the applicant to contribute their proportionate share?... Comment noted. The mitigations at each of the study intersections are summarized below. The summaries also include the percentages of traffic added by the East Jamie Court project at each intersection as compared to traffic added by 2003 or 2020+ baseline development. The numbering for the intersections corresponds to Figures 3-1 to 3-18 on pages Appx-48 to Appx-65 in the Appendix of the Initial Study and Mitigated Negative Declaration. The following five scenarios are included: 1. Year 2003 Baseline (approved development) without the East Jamie Court project 2. Year 2003 Baseline plus the East Jamie Court project 3. Year 2020+ East of 101 Transportation Improvements Plan (TIP) City of South San Francisco, November 2002 -17- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS 4. Year 2020+ Baseline (approved, proposed and potential development) without the East Jamie Court project 5. Year 2020+ Baseline plus the East Jamie Court project Intersection 1: Airport Boulevard and U.S. 101 Southbound Off-Ramp Year Scenario Recommended Miti ation Project Contribution 2003 Without Project None re uired 2003 With Project None re uired 2020+ East of 101 TIP Widen the off-ramp and reconstruct retaining wall to provide a second left-turn lane. Re-stripe the existing off-ram throu h-left lane and a throu h lane. TIP Fee 2020+ Without Project East of 101 TIP 2020+ With Project East of 101 TIP The intersection of Airport Boulevard and U.S. 101 Southbound Off-ramp is included in the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. The additional traffic generated by the Project would not require any additional intersection improvements. Intersection 2: Airport Boulevard and Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project Widen EB Grand Ave. by 12 feet to provide one left- turn lane, one throu h lane and one ri ht-turn lane. 2003 With Project Same as Year 2003 without Project 8% of added traffic 2020+ East of 101 TIP Re-stripe the existing SB Airport Blvd. right-turn lane as TIP Fee a shared through-right lane and re-stripe the SB shared through-left lane as a left-turn lane. Widen EB Grand Ave to add two left-turn lanes, re-stripe the EB shared through-left lane as a through lane and the EB right- turn lane as a shared through-right lane. Provide a third WB left-turn lane. 2020+ Without Project East of 101 TIP 2020+ With Project East of 101 TIP The intersection of Airport Boulevard and Grand Avenue is part of the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. The additional traffic generated by the Project by year 2020 would not require any additional intersection improvements. City of South San Francisco, November 2002 -18- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Intersection 3: East Grand Avenue Overcrossing and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project Re-stripe NB approach on E. Grand Ave. to provide two ri ht-turn lanes and one left-turn lane. 2003 With Project Same as Year 2003 without Project 17% of added traffic 2020+ East of 101 TIP Intersection not included in East of 101 TIP 2020+ Without Project Same as Year 2003 with/without Project 2020+ With Project Same as Year 2003 with/without Project and Year 10% of 2020+ without Project added traffic The intersection of East Grand Avenue with the East Grand Avenue Overcrossing is not currently included in the East of 101 TIP. The same mitigation is recommended for 2003 and 2020+ without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute ten percent of the traffic added by all approved, proposed and potential development (2020+). Intersection 4: Gateway Boulevard and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project None re uired 2003 With Project None re uired 2020+ East of 101 TIP Re-stripe existing NB Gateway Blvd. shared TIP Fee through/right lane to a right turn lane and re-stripe existing EB E. Grand Ave approach to provide a separate left turn lane (mitigation for the approved Bay West Cove project). Add a second WB left-turn lane on E. Grand Ave. 2020+ Without Project East of 101 TIP improvements, plus widen NB Gateway Blvd to rovide a second ri ht-turn lane 2020+ With Project Same as Year 2020+ without Project 7% of added traffic The intersection of Gateway Boulevard and East Grand Avenue is included in the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute seven percent of the traffic added by all approved, proposed and potential development (2020+). City of South San Francisco, November 2002 -19- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Intersection 5: Harbor Way/Forbes Boulevard and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project None re wired. 2003 With Project Re-stripe EB approach on E. Grand Ave. to provide 17% of one right turn lane, two through lanes, and two left turn added traffic lanes. 2020+ East of 101 TIP Widen WB Grand Ave. to provide one additional TIP Fee through lane and one additional left-lane lane. Widen SB Forbes Blvd. to provide one additional through lane and change the existing shared through-right lane to a right-turn only lane. Widen NB Harbor Way to provide one additional through lane, one right-turn lane, and change the existing shared through-right lane to a throw h lane. 2020+ Without Project East of 101 TIP improvements, plus widen SB Forbes Blvd. to rovide a second throw h lane. 2020+ With Project Same as Year 2020+ without Project 5% of added traffic The intersection of Harbor Way/Forbes Boulevard and East Grand Avenue is included in the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute five percent of the traffic added by all approved, proposed and potential development (2020+). Intersection 6: Littlefield Avenue and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project Re-stripe NB Littlefield Ave. to provide one shared left- ri ht lane and one ri ht-turn lane. 2003 With Project Same as Year 2003 without Project 13% of added traffic 2020+ East of 101 TIP Intersection not included in East of 101 TIP 2020+ Without Project Widen NB Littlefield Ave. to provide one shared left- right lane and one right-turn lane. Widen E. Grand Ave. to rovide a third EB throw h lane. 2020+ With Project Same as Year 2020+ without Project 9% of added traffic The intersection of Littlefield Avenue and East Grand Avenue is not included in the East of 101 TIP. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 City of South San Francisco, November 2002 -20- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS TIP. The Project would contribute nine percent of the traffic added by all approved, proposed and potential development (2020+). Intersection 7: Allerton Avenue and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project None re uired 2003 With Project Signalize the intersection 14% of added traffic 2020+ East of 101 TIP Intersection not included in East of 101 TIP. 2020+ Without Project Signalize the intersection. Widen E. Grand Ave. to provide an EB left-turn lane in addition to the two throu h lanes. 2020+ With Project Same as Year 2020 without Project 9% of added traffic The intersection of Allerton Avenue and East Grand Avenue is not included in the East of 101 TIP. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute nine percent of the traffic added by all approved, proposed and potential development (2020+). Intersection 8: Grandview Drive and East Grand Avenue Year Scenario Recommended Miti ation Project Contribution 2003 Without Project None re uired 2003 With Project None re uired 2020+ East of 101 TIP Install a traffic signal. Add aright-turn lane on SB Grandview Drive. Re-stripe EB Grand Ave. to provide one left-turn lane and one shared throu h-left lane. TIP Fee 2020+ Without Project East of 101 TIP 2020+ With Project East of 101 TIP The intersection of Grandview Drive and East Grand Avenue is part of the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. The additional traffic generated by the Project would not require any additional intersection improvements. City of South San Francisco, November 2002 -21- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Intersection 9: Haskins Way and East Grand Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without None required Project 2003 With Project Signalize the intersection 20% of added traffic 2020+ East of 101 Intersection not included in East of 101 TIP TIP 2020+ Without None required Project 2020+ With Project Signalize the intersection 20% of added traffic The intersection of Haskins Way and East Grand Avenue is not included in the East of 101 TIP. Additional improvements are recommended with year 2003 or 2020+ traffic with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute 20 percent of the traffic added by all approved, proposed and potential development. The warrants for installing a traffic signal at the intersection of Haskins Way and East Grand Avenue are only met if traffic is generated by both the East Jamie Court Project and at least 50 percent of the approved Britannia East Grand project. Traffic generated by either development project alone would not meet the minimum criteria for installation of a traffic signal. Intersection 10: Airport Boulevard and San Mateo Avenue Project Year Scenario Recommended Miti ation Contribution 2003 Without Project None re uired 2003 With Project None re uired 2020+ East of 101 TIP Widen WB Airport Blvd. to provide one additional left- TIP Fee turn lane, and re-stripe the existing shared through-left lane as a left-turn lane for a total of three left-turn lanes. 2020+ Without Project East of 101 TIP improvements, plus re-stripe SB Airport Blvd. to provide one left-turn lane, two through lanes and one shared throu h-ri ht lane. 2020+ With Project Same as Year 2020+ without Project 4% of added traffic The intersection of Airport Boulevard and San Mateo Avenue is part of the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would City of South San Francisco, November 2002 -22- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS contribute four percent of the traffic added by all approved, proposed and potential development. Intersection 11: Gateway Boulevard and South Airport Boulevard Project Year Scenario Recommended Miti ation Contribution 2003 Without Project None re uired 2003 With Project Widen WB Mitchell Ave. to provide alert-turn lane, a 13% of throw h lane and a ri ht-turn lane. added traffic 2020+ East of 101 TIP Widen EB Airport Blvd to provide one additional right- TIP Fee turn lane, and re-stripe the existing shared through-left lane as a through lane. Widen WB Mitchell Ave. to provide two additional through lanes and aright-turn lane. Widen SB Gateway Blvd. to provide one additional right-turn lane, and change the existing shared throw h-ri ht lane to a ri ht-turn lane. 2020+ Without Project East of 101 TIP, plus re-stripe the NB approach on S. Airport Blvd. to provide one shared right-through lane and one ri ht-turn lane. 2020+ With Project Same as Year 2020+ without Project 2% of added traffic The intersection of Gateway Boulevard and South Airport Boulevard is part of the East of 101 TIP, and the Project is required to participate in the traffic improvement fee. Additional improvements are recommended with year 2020+ traffic without or with the East Jamie Court Project, and it is recommended that the Project contribute to the cost of the additional improvements not included in the East of 101 TIP. The Project would contribute two percent of the traffic added by all approved, proposed and potential development. Intersection 12: South Airport Boulevard and U.S. 101 Northbound Ramps Year Scenario Recommended Miti ation Project Contribution 2003 Without Project None re uired. 2003 With Project None re uired. 2020+ East of 101 TIP Intersection not included in East of 101 TIP 2020+ Without Project None re uired. 2020+ With Project None re uired. The intersection of South Airport Boulevard and U.S. 101 Northbound Ramps is not included in the East of 101 TIP, and no mitigations are recommended for any of the scenarios. Previous traffic studies in the area have identified a need for additional lanes at this intersection. However, no mitigation is currently recommended, based on the updated traffic counts and reassessments of best travel paths that were included in the traffic studies for the East Jamie Court Project. City of South San Francisco, November 2002 -23- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS 4. Item XVa, p~23 - "...and participate in a traffic improvement fee at ei h~pacted intersections in the East of 101 area." Comment noted. The Project would participate in the established fee program for the East of 101 Transportation Improvement Program that accounts for improvements at seven intersections and three street segments, as listed on page Appx-18. In addition, the Project would contribute to the costs of improvements beyond the TIP improvements at eight intersections, as listed on page Appx-28. 5. Item XV a, pg60 - "The Project would participate in the traffic improvement fee in the East 101 area and would contribute a proportionate amount of the cost of improvements at the eight impacted intersections..." Please see the response to Comment 2 above. 6. Appx-26- "The Project shall contribute a proportionate amount to the cost of improvements at these seven intersections." (Referring to Year 2003 conditions. Comment noted. The East of 101 TIP is based on 2020+ conditions, and to be consistent the City of South San Francisco would require applicants to contribute their corresponding share of intersection improvement fees based on the Year 2020+ traffic conditions only. 7. Appx-27- "The Project will participate in the traffic improvement fee in the East of 101 area and will pay a fair share of the cost of improvements based on the traffic generated and impacts on service levels." This statement verifies that the mitigation program for the Project will be consistent with the General Plan as revised by the East of 101 TIP. 8. Appx-28 -"The East Jamie Court Project shall participate in transportation improvement funding,~rograms as approved by the City of South San Francisco in conjunction with the East of 101 TIP." Participation in the East of 101 TIP represents one element of the mitigation program for the Project. 9. Appx-28 - "The Project shall contribute a proportionate amount to the cost of improvements at these eight intersections." (Referring to Year 2020 conditions.) Mitigation of 2020+ conditions with the Project will require improvements at eight intersections beyond the improvements included in the East of 101 TIP. 10. "In addition, there are 2 intersections with the same improvements proposed for both 2003 and 2020 yet the applicant's proportionate share differs. What are the correct allocations?" City of South San Francisco, November 2002 -24- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS The proportiona±e share differs for 2003 and 2020+ because the 2003 shares are based on traffic contributed by previously approved developments, while the 2020+ shares are based on traffic contributed by all approved, proposed and potential developments. The East of 101 TIP is based on 2020+ conditions, and to be consistent the City of South San Francisco would require applicants to contribute their corresponding share of intersection improvement fees based on the Year 2020+ traffic conditions only. 11. Item XVI b, p~ 63 and XVII, p~ 65 -the obligations on the applicant in the wastewater and sewer sections are also unclear. Mitigations are not clear whether the~p~ly to the ~plicant or the City. If they apply to the applicant what is the target for reduction f~l _Pg. 63 states that "City should develop a program that encourages R&D facilities and pharmaceutical manufacturers to reduce the total volume of wastewater dischared to the collection system ... "and refers to measures such as recycling and/or pretreatment and alternative discharge patterns. The mitigation on the same pale then states "Incorporation of these wastewater reduction measures as part of the Project should reduce ..." In comparison, the mitigation measure on Pg. 65 is "Encourage R&D facilities and pharmaceutical manufacturers to reduce wastewater discharged into the collection system, involving ... Develop a sewer collection model and require fair share contributions to benefitin property owners." Comment noted. As stated by the applicant, the project specific and cumulative mitigation measures set forth for wastewater were not in complete agreement. These sections have been reworded in this response, so all wastewater mitigations are now discussed under the cumulative impacts heading (Section XVII), with the single treatment mitigation clearly identified as a City responsibility. In order to further clarify the project's expected effect on the City's wastewater system, two wastewater collection impacts are now also described in Section XVII, along with additional mitigation measures that would be the responsibility of the project sponsor. Two paragraphs are added, following the paragraph Discussion: XVII b: on page 65. The proposed project would have an impact on wastewater collection because wastewater generated on the site would be conveyed to the treatment plant through an existing sewer line and pump station that cannot accommodate additional flows from currently undeveloped or underutilized properties. This sewer line runs north on Haskins Way to Swift Avenue, then west on Swift to City Pump Station No. 3, at the intersection of Swift Avenue and Kimball Way. The pump station and the Swift Avenue sewer are scheduled to be upgraded by a recently approved development project at the end of East Grand Avenue, as part of a development agreement between that project's sponsors and the City of South San Francisco. Under the terms of this agreement, the City would require all new development that discharges wastewater to these facilities to contribute a proportionate share of the cost of the City of South San Francisco, November 2002 -25- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS upgrades. The City has also scheduled upgrades to Pump Station No. 4, located downstream of Pump Station No. 3, to correct existing deficiencies and to provide the capacity needed to accommodate continued growth East of 101. Higher flow rates and increased wastewater volumes would increase operational stresses on the station's existing pumps and controls, which could potentially result in backups or wastewater spills. The paragraph entitled Sewer Improvements at the bottom of Page 63 is replaced with the following paragraph: Water Conservation. Reduce water consumption by incorporating water conservation measures into the General Plan, pursuant to California Assembly Bill 325, which requires the use of low flow plumbing fixtures and drought-tolerant landscaping, and recycle water used in R&D and pharmaceutical manufacturing businesses. Finally, the following three paragraphs are added to provide the background on cumulative impacts and mitigations. The proposed project would help fund proposed improvements to the Swift Avenue sewer and to Pump Station No. 3, based on a contribution formula to be determined by the City Engineering Department. To ensure wastewater generated by the proposed project does not contribute to backups or wastewater spills at Pump Station, No. 4, the scheduled pump station upgrades should be completed before the proposed project is connected to the City's wastewater collection system. In addition, the project sponsor would pay a Sewer Improvement Fee, as adopted by the City, to help fund the pump station upgrade and an overall program of collection system improvements for the East of 101 area. In addition to the preceding mitigation measures for which the applicant would be responsible, the City would be responsible for controlling cumulative impacts to its wastewater treatment facilities resulting from continued development. As noted under XVIb, high rates of wastewater generation by new businesses in the East of 101 area are using up the City's treatment capacity more rapidly than anticipated when the recently completed treatment plant improvements were designed. To slow this utilization of available treatment capacity and help limit future discharges of treated wastewater into San Francisco Bay, the City should develop a program that encourages R&D facilities and pharmaceutical manufacturers to reduce the total volume of wastewater discharged to the collection system, in accordance with General Plan Policy 5.3-I-7. The program could include incentives to implement recycling and/or pretreatment and, where appropriate, provide assistance in planning these facilities so as to maximize the benefit to the City's wastewater system. In City of South San Francisco, November 2002 -26- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS addition, the City should encourage high volume wastewater dischargers to minimize their impact on peak wastewater flows by stretching the discharge of process wastes over longer periods of time or by scheduling them for off-peak periods (typically night time). Application of these mitigation measures throughout the East of 101 area, including on the proposed project site, should reduce area-wide cumulative impacts on local wastewater treatment capacity to a less than significant level. *Implementation of these mitigation measures should reduce area-wide cumulative impacts on local wastewater treatment capacity to a less than significant level. City of South San Francisco, November 2002 -27- Final Initial Study, East Jamie Court Project October 9, 2002 Ms. Susy Kalkin City of South San Francisco Planning Division GIVAS #2 P. O. Box 711 South San Francisco, CA 94083 RE: East Jaime Court Project Dear Susy, On behalf of Alexandria Real Estate Equities ("Applicant"), this letter details the project sponsor's comments to the Initial Study and Mitigated Negative Declaration prepared by Morehouse Associates and dated September 2002 regarding the above-referenced project. The following comments correspond in order to how they appear in the document. • Figure 5 -Applicant has provided current plans to both the City and its consultant, but the Preliminary Landscape Plan included in the document reflects 1 a prior design. _ • Figure 6 -See comment above regarding the Preliminary Grading and Drainage ~ Z Plan. • N a, p~. 33 -This section of the Initial Study/Mitigated Negative Declaration encourages the Applicant to consult with the U. S. Fish and Wildlife Service and California Department of Fish and Game. "Consultation" is a technical term under federal law, which requires a long and complicated process with each agency. At this time, it is not known whether consultation with these agencies will be necessary, since the habitat on the proposed project site is "extremely marginal," as stated in the document. Prior to construction on the proposed project, a detailed assessment of habitat suitability for the special-status species will be conducted by a qualified biologist, and the proposed project improvements 3 will be reviewed in light of their potential impacts to the salt marsh harvest mouse and California clapper rail. The Corps, USFWS, and CDFG will be contacted, as necessary, based on the results of this assessment. Actual "consultation" will only occur if required by law. Therefore, we request that the language be changed to state: "If the adjacent shoreline/tidal marshes are determined to be suitable habitat for special-status wildlife species, and if proposed project improvements related to the bike/pedestrian trail and/or stormwater outfall are shown to directly or indirectly impact these species, then the applicant must comply with requirements of the appropriate state and federal resource agencies as to appropriate habitat avoidance and precautions during construction." -28- • IV b, ng. 34 -One of the mitigation measures requires the City to engage a biologist to monitor construction activities. The Applicant requests that, as an option, it be allowed to engage a qualified biologist directly to coordinate the 4 required monitoring and reporting to the various agencies. • IV c, ngs. 34-5- Approximately 2,800 square feet of possible seasonal wetlands have been identified in the document. Based on detailed additional investigations and the preparation of a wetlands delineation, both prepared by H. T. Harvey & 5 Associates who is a qualified wetland biologist, those possible wetlands are believed to not be jurisdictional waters. It is expected that the Corps will disclaim jurisdiction. The aforementioned delineation has been submitted to the Corps for their review and concurrence. IV c, ngs. 34-5 -The Draft Initial Study/Mitigated Negative Declaration anticipates installation of a new storm drain pipeline (reference to this improvement also appears in IV (a)). Applicant has engaged consultant Sandis Humber Jones to perform a stone drain analysis of the basin area and identify (~ possible up-gradient improvement alternatives. At this point, replacement of the outfall is only one of the options, and may or may not be included in the Project. In lieu of the outfall, applicant might perform an up-gradient improvement to the storm system contingent upon City approval. • n' c=pg. 35 -One of the mitigation measures requires preparation of a wetlands delineation. The delineation has already been prepared by H. T. Harvey & ~ Associates and submitted to the Corps. A copy has also been sent to the City. IV c, n~. 35 -The aforementioned mitigation measure also requires that the limits of the shoreline marsh along the entire southern boundary be included in the delineation to ensure that construction does not intrude into the wetlands. Based on a completed delineation overlain with the Bay Trail improvements and the extent of grading, neither the trail nor construction would intrude into the wetland areas provided that the location of the Trail is modified slightly. Attached is a letter from H. T. Harvey & Associates confirming the absence of a future impact based on minor trail re-location. VI a ii), iii), ngs 39-40 -This section includes multiple references, including a mitigation measure, to the need to perform geotechnical investigations. Specific areas of investigation are liquefaction, ground failure and static and seismic slope stability. Such investigations have already been performed by our consultant, KC Engineering Company, and both the original and updated reports have been provided to the City. Among the requested studies, the only one that has not been performed is a detailed slope stability analysis, which was not performed since it was not deemed necessary based on the existing and proposed conditions. In addition, KC Engineering has reviewed this Section VI and has provided comments, which are attached. Please acknowledge that the aforementioned reports have been performed and all concerns have been adequately addressed. -29- PaQe 2 nf4 VI c & d, pis. 40-1 -Investigations of settlement, ground failure and rock dyke stability are also required in the Draft Initial Study/Mitigated Negative Declaration. As noted in the prior comment, these issues have been investigated and reports have been furnished. The report and the consultant's comment letter note that the perimeter dyke and the fill are considered stable under the existing 10 conditions. In addition, the buildings will be founded on piles deriving their support from the competent stratum at depth below the bay mud. Given the structural design, no loads are being added at grade and there will actually be an increase in stability from the lateral resistance of the piles. Please acknowledge that the aforementioned reports have been performed and all concerns have been adequately addressed. • VIII a & c, pg. 46 -The Draft Initial Study/Mitigated Negative Declaration states that 90% of the runoff from the site will be being routed through grassed, filtration swales. Please note that while the calculation of filtered run-off is 7 ~ accurate, the main filtration areas consist of grass on the perimeter of the Project and mostly gravel in the parking areas. • VIII d & e, pg. 47 -This section of the Draft Initial Study/Mitigated Negative Declaration requires replacement of the outfall is a mitigation measure. As noted ~ 1:. previously, applicant is evaluating alternative up-gradient improvements. Please modify the mitigation measure to reflect "replacement of the outfall pipe or an alternative up-gradient improvement acceptable to the City". - XI b, pg. 53 -Since information regarding the geotechnical condition of the site has already been provided to the City, please clarify whether monitoring is ~ 3 required. _ XV a, n~. 60 - In discussions with the City subsequent to the publication of the Draft Initial Study/Mitigated Negative Declaration, we have agreed that the Project would contribute a proportionate amount to the cost of improvements at 14. three impacted intersections (Littlefield/E. Grand, Allerton/E. Grand and Haskins/E. Grand) and participate in a traffic improvement fee for the other five intersections. Please revise the mitigation measure to reflect this understanding. XV b, ug. 63 -Please restate the mitigation measure to reflect the Project's 15 "participation in an eventual wastewater program to be incorporated into the City's General Plan". • XVI c, pL. 63 - Per an earlier comment, please change the mitigation measure to ~ 6 reflect incorporation of the outfall "or an alternative up-gradient improvement to the storm system acceptable to the City". -30- Pa.Qe 3 of 4 • XVII b, ng. 65 -Please change "Transportation Improvements" to specify the previously noted distinction between contributions for intersection improvements ~ and payment of traffic fees. • XVII b, n~. 65 -Please rephrase "Reduce water consumption by incorporating ~- water conservation measures into the General Plan" to "Reduce water consumption by complying with water conservation measures contained in the 1 ~ General Plan". • XVII b, n~. 65 -Please revise this section to state that "the Project will pay the Sewer Improvement Fee estimated to be $1.23 per square foot currently being ~~ processed by the City and participate in a wastewater reduction plan to be adopted by the City". In addition to the above comments, we would request that corresponding changes be made to the Summary Table (Table 1 on pg. 21). Specifically, the changes would be to (z~ IVa,VIc&d,VIIId&e,XIb,XVa,XVIbandXVIc. Thank you for your consideration of these items. Please let us know if there is a convenient time to discuss these issues in person. Sincerely, ~ ~~~~ Dean D. Givas President Oyster Development Corp. CC: Steve Richardson, Alexandria Real Estate Equities Vincent Ciruzzi, Alexandria Real Estate Equities Niall Malcolmson, Dowler-Gruman Architects -31- Paee 4 ~f4 RESPONSE TO COMMENTS RESPONSE TO LETTER NUMBER 2 FROM DEAN GIVAS, OYSTER DEVELOPMENT CORP. 1. Figure 5 -Applicant has provided current plans to both the Citv and its consultant, but the Preliminary Landscape Plan included in the document reflects a prior design. Comment acknowledged. The current Landscape Plan is attached. 2. Figure 6 -See comment above regarding the Preliminary Grading and Drainage Plan. The current Preliminary Grading and Drainage Plan is attached. 3. IVa pg 33 -This section of the Initial Study/Mitigated Negative Declaration encourages the Applicant to consult with the U S Fish and Wildlife Service and the California Department of Fish and Game At this time it is not known whether consultation with these agencies will be necessary the applicant must comply with requirements of the appropriate state and federal resource agencies as to appropriate habitat avoidance and precautions during construction. This comment is now considered to be moot because the Applicant has revised his plans to avoid habitat for listed animal species that could potentially occur. However, the Applicant should still take reasonable precautions during and after construction to avoid indirect impacts to the avoided habitat, as described in the MND under Discussion IVa and IVb. 4 IVb pg 34 -One of the mitigation measures requires the City to engage a biologist to monitor construction activities The Applicant requests that as an option it be allowed to en ag~ge a qualified biologist directly to coordinate the required monitoring and reporting to the various a eg ncies. The proposed language change, allowing the Applicant to directly engage a qualified biologist to coordinate monitoring and reporting is acceptable, provide that the biologist's qualifications are first submitted to the City for review and approval. The biologist shall be experienced in construction monitoring in the vicinity of San Francisco Bay tidal habitats, as well as wetland mitigation and monitoring in the San Francisco Bay Area. (see also below response to Comment #3 in Givas letter number 3). 5. IV c ~s 34-5 -Approximately 2 800 square feet of possible seasonal wetlands have been identified in the document Based on detailed additional investigations and the preparation of a wetlands delineation both prepared by H.T. Harvey & Associates who is a qualified wetland biologist those possible wetlands are believed to not be jurisdictional waters. It is expected that the Corps will disclaim jurisdiction. The aforementioned delineation has been submitted to the Corps for their review and concurrence. City of South San Francisco, November 2002 -32- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS 6. IV c. pis 34-5 -The Draft Initial Study/Mitigated Negative Declaration anticipates installation of a new storm drain pipeline [reference to this improvement also appears in IV lal). Applicant has en~a~ed consultant Sandis Humber Jones to perform a storm drain analysis of the basin area and identify possible up-gradient improvement alternatives In lieu of the outfall, applicant might perform an u~gradient improvement to the storm s. stem contin ent upon City approval. Comment noted. The analysis of alternatives described in the comment has apparently been completed. The storm drain outfall has been eliminated in favor of an up-gradient improvement -replacement of the existing 48 inch pipe from the inlet at the intersection of Haskins Way and Jamie Court to the next inlet downstream with a 77 linear foot, 6-foot by 4-foot box culvert (see Givas Letter No. 3, comment No. 1). 7. IV c. P~ 35 -One of the mitigation measures re uires preparation of a wetlands delineation The delineation has already been pared by H T & Associates and submitted to the Corps A copy had been sent to the Cites Comment acknowledged. The report is "East Jamie Court, San Mateo County, California, Identification of Waters of the U.S." by H.T. Harvey & Associates, Oct. 1, 2002. IVc.pg 35 -The aforementioned mitigation measure also requires that the limits of the shoreline marsh alone the entire southern boundary be included in the delineation to ensure that construction does not intrude into the wetlands Based on a completed delineation overlain with the Bay Trail improvements and the extent of grading neither the trail nor construction would intrude into the wetland areas provided that the location of the Trail is modified slightly. See the letter from H T Harvey & Associates reconfirming the absence of a future impact based on minor trail relocation The comment states that, based on the H.T. Harvey delineation, neither the Bay Trail construction nor the project construction will intrude into Corps jurisdictional area along the shoreline (except within the outfall replacement area). However, a subsequent letter from H.T. Harvey to Niall Malcolmson of Dowler-Gruman Architects, dated October 11, 2002, states that proposed shoreline stabilization work associated with the Bay Trail construction will impact approximately 200 linear feet of Corps jurisdictional area. The letter further states that if the southern limits of the stabilization work is shifted northward between 2 and 10 feet, all such impact can be avoided. In a subsequent letter from Givas No. 2, dated October 15, 2002, Givas states that the project has agreed to shift the Bay Trail and associated shoreline stabilization work northward in this fashion. Therefore, based on the October 15, 2002 letter to the City, this comment is accurate. 9. VI a ii), iii), pis. 39-40 -This section includes multiple references includin a miti ag tion measure, to the need to perform ~eotechnical investigations Specific areas of investi ation are liquefaction, ground failure and static and seismic slope stability Such investi ations have already been performed by our consultant KC En ineering Company and both the City of South San Francisco, November 2002 -33- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS original and updated reports have been provided to the City. Among the requested studies, the only one that has not been performed is a detailed slope stability analysis, which was not performed since it was not deemed necessary based on the existing and proposed conditions. In addition KC Engineering has reviewed the Section VI and has provided comments, which are attached Please acknowledge that the aforementioned reports have been performed and all concerns have been adequately addressed. Comment acknowledged. Based on discussion with Mr. Richard Harmon of the City of South San Francisco, the geotechnical reports have been received, reviewed, and accepted for this project. Provided the minor issues listed in our response to comments in the KC Engineering letter dated 25 September 2002 are addressed, we believe the geologic and soils impacts have been properly addressed, and satisfy the mitigation measures included in the Initial Study Section VI Geology and Soils. 10. VI c & d pgs 40-1 -Investigation of settlement ground failure and rock dyke stability are also required in the Draft Initial Study/Mitigated Negative Declaration. As noted in the prior comment these issues have been investigated and the reports have been furnished. The report and the consultant's comment letter note that the perimeter duke and the fill are considered stable under the existing conditions In addition the buildings will be founded on piles and there will actually be an increase in stability from the lateral resistance of the piles Please acknowledge that the aforementioned reports have been performed and all concerns have been adequately addressed. Comment acknowledged. Based on discussion with Mr. Richard Harmon of the City of South San Francisco, the geotechnical reports have been received, reviewed, and accepted for this project. Provided the minor issues listed in our response comments to the KC Engineering letter dated 25 September 2002 are addressed, we believe the geologic and soils impacts have been properly mitigated, and satisfy the mitigation measures included in the Initial Study Section VI Geology and Soils. 11. Items VIII a & c ~g 46 -The Draft Initial Stud /mitigated Negative Declaration states that 90% of the runoff from the site will be routed through grassed filtration swales. Please note that while the calculation of filtered run-off is accurate, the main filtration areas consist of grass on the perimeter of the Project and mostlygravel in the parking areas. Comment acknowledged. The affected portions of text under VIII a & c are revised as follows: Discussion VIII a: As now proposed, runoff from almost 90 percent of the driveways and parking areas on the site would be routed through storm water treatment swales before entering the on-site storm drain system. It is estimated that approximately 60 percent of these areas would drain to grassed percolation/filtration swales around the perimeter of the parking area, and the remaining 40 percent would drain to gravel percolation swales in parking lot medians. Treatment swales are an accepted BMP for removing pollutants from paved area runoff, so their use should be consistent with the goals of the San Mateo County City of South San Francisco, November 2002 -34- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Urban Runoff Clean Water Program. However, gravel swales only treat runoff through direct percolation, so if the soils underlying these swales have low permeability, the level of treatment may be limited. Grassed swales also allow for percolation, but they additionally filter out some pollutants that are picked up and held by the blades of grass, so these areas would be expected to receive a higher level of treatment. For the remaining driveway/parking areas that would not drain to a treatment swale, the project engineer reports that some type of approved catch basin filters would be installed to provide an equivalent level of contaminant removal. Catch basin filters must be regularly cleaned and maintained throughout the life of a project in order to remain effective. Discussion VIII c: Existing drainage patterns on the project site would be significantly altered and total storm water runoff would be increased by the construction of impervious surfaces. However, runoff would be directed into either grassed or gravel treatment swales and underground storm drains, where there would be little chance of increased erosion. The only area within the site vicinity that might be subject to erosion is the existing slope where the high ground on the project site now drops sharply down into the wetlands at the edge of the bay. However, project plans indicate a significant portion of this offsite area would be regraded and landscaped as part of the Bay Trail construction, which should leave the ground surface far more stable and protected from erosion than in its current condition. 12 VIII d & e pg 47. This section of the Draft Initial Stud /Mitigation Negative Declaration requires replacement of the outfall as a mitigation measure Please modify the miti ation measure to reflect "replacement of the outfall pie or an alternative up-gradient improvement acceptable to the Cit. Comment noted. As discussed in response to comment No. 6 above, the proposed storm drain outfall has been has been eliminated from the Project, and replaced with an up-gradient box culvert. Therefore, the mitigation measure for Discussion VIII d on page 48 shall be changed from "Replacement of the outfall pipe is incorporated into the Project, so the storm drainage impact would be less than significant" to: * The outfall is eliminated from the project, so there would be no storm drainage impact. The proposed upland box culvert will be designed to increase the system's discharge capacity. Therefore, the mitigation measure for Discussion VIII e on page 48 shall be changed from "With incorporation of the outfall replacement as part of the Project the impact would be less than significant" to: * The proposed box culvert shall be designed to accommodate storm drainage generated by the project and areawide runoff, so there would be no storm drainage impact. 13. XI b, pQ. 53 -Since information re arding the ~eotechnical condition of the site has alreadx been provided to the Citesplease clarify whether monitorin is required City of South San Francisco, November 2002 -35- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Comment noted. Section XI b states, "...proposed groundborne pile driving may conceivably contribute to ground vibration, affecting the foundations of existing buildings in the vicinity of the Project site, or ground fill conditions. Depending upon geotechnical site conditions, pile driving shall be monitored for foundation movement of nearby existing structures." The monitoring discussed in this section is related to the potential for pile installation to cause either upward ground-surface displacement (heave) or ground vibration, which could adversely impact adjacent improvements. Monitoring for heave typically includes pre-construction crack surveys of adjacent improvements and surveying of existing improvements before and during construction. Monitoring is typically required for improvements within 50 feet of the project site, although structures further from the site may also require monitoring depending on the soil type, type and number of foundation piles, and depth of predrilling. Vibration monitoring is also sometimes necessary depending on the subsurface conditions and the sensitivity of adjacent structures or occupants. Limited vibration monitoring of adjacent sites can often be performed during the indicator pile program to evaluate whether further vibration monitoring is warranted during production pile driving. The need for both types of monitoring at adjacent sites should be addressed by the project geotechnical engineer, to the satisfaction of the City Engineer. 14. XV a p~. 60 - In discussions with the City subsequent to the publication of the Draft Initial Stud /~igated Negative Declaration, we have agreed that the Project would contribute a proportionate amount to the cost of improvements at three impacted intersections (Littlefield/E. Grand Allerton/E. Grand and Haskins/E. Grand and participate in a traffic improvement fee for the other five intersections. Please revise the mitigation measure to reflect this understanding. The Project would participate in the established fee program for the East of 101 Transportation Improvement Program that accounts for improvements at seven intersections and three street segments, as listed on page Appx-18. In addition, the Project would contribute to the costs of improvements beyond the TIP improvements at eight intersections, as listed on page Appx-28. Of these eight intersections, four are not included in the East of 101 TIP and the Project would only contribute a proportionate amount to the cost of the improvements. For the four intersections which are part of the East of 101 TIP, the mitigations recommended in this study are in addition to the improvements recommended in the East of 101 TIP. As a result, the Project would both participate in the traffic improvement fee for the East of 101 TIP and contribute to the cost of additional improvements at the following four intersections: • Gateway Boulevard and East Grand Avenue • Harbor Way/Forties Boulevard and East Grand Avenue • Airport Boulevard and San Mateo Avenue • Gateway Boulevard and South Airport Boulevard City of South San Francisco, November 2002 -36- Final initial Study, East Jamie Court Project RESPONSE TO COMMENTS Table 1 presents updated traffic contribution percentages for the East Jamie Court Project and the Britannia East Grand project at each of the impacted intersections. These percent contributions were calculated based on the additional traffic generated by each project compared to the total additional traffic at each location. The percent contributions for the East Jamie Court project have been updated at three intersections compared to the percentages listed on pages Appx-31 to Appx-32 of the Initial Study: • Haskins Way and East Grand Avenue revised from 12 percent to 20 percent • Airport Boulevard and San Mateo Avenue revised from 9 percent to 4 percent • Gateway Boulevard and South Airport Boulevard revised from 3 percent to 2 percent Table 1 Project Contributions to Intersection Improvements Britannia East Year East Jamie Court Grand Year 2020+ Year Year 2002 Year 2020+ Total 2020+ 2020 Intersection Peak* Hour Existing Volume Cumulative V l Added Added Year 2020+ Added Year 2020+ o ume Traffic Traffic % of Added Traffic % of Added E Grand Ave & E Grand Ave Overcrossin AM 2,823 4,311 1,488 152 10% 316 21 Gateway Blvd & Grand Ave AM 3,279 5,324 2,045 152 7% 324 16% Forbes Blvd & E. Grand Ave PM 2,355 5,747 3,392 172 5% 363 11 Littlefield Ave & E. Grand Ave AM 1,494 3,668 2,174 184 8% 795 37% PM 1,301 3,304 2,003 176 9% 706 35% Avera e _ - o 9 /° 36% Allterton Ave & E. Grand Ave AM 1,706 3,880 2,174 184 8% 794 37% PM 1,395 3,398 2,003 177 9% 705 35% Avera e - - 9% 36% Haskins Way & E Grand Ave PM 312 1,222 910 180 20% 720 79% Airport Blvd & San Mateo Ave PM 3,230 5,123 1,893 74 4% 24 1 S. Airport Blvd & Gatewa Blvd AM 2 ,233 4 ,098 1 ,865 2 8 2 % 1 57 8 % 'Peak hour requiring miti atio ns f 202 g or year 0+ with the East Jamie Court Project. City of South San Francisco, November 2002 -37- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Comment acknowledged. Refer to response to comment # 11 in letter number 2 from Dean Givas. The response to comment # 11 provides background on the cumulative impacts in Section XVII, and measures to reduce wastewater discharge. 16. XVI c P~ 63 Per[letter No 121 please change the mitigation measure to reflect incorporation of the outfall "or an alternative up-gradient improvement to the storm system acceptable to the CitY'. Comment noted. As discussed in response to comment No. 6 above, the proposed storm drain outfall has been has been eliminated from the Project, and replaced with an up-gradient box culvert. Therefore, the mitigation measure for Discussion XVI c page 63 shall be changed from "Incorporation of the outfall is made a part of the Project, so the impact would be less than significant." to: * The upland box culvert is incorporated as part of the project, so environmental effects to the Bay would be less than significant. 17. XVII b p~ 65 Please change "Tran~ortation Improvements" to specify the previously noted distinction between contributions for intersection improvements and payment of traffic fees. Comment noted. The phrase should be edited as follows: "Transportation Improvements. "'` ' +' ~" ' "' ..-~ =:~ c==d contribute to the funding of transportation improvements pregrams according to the Transportation Improvements Program (TIP) in the East of 101 Area as approved by the City and contribute to the funding of additional transportation improvements at impacted locations beyond those included in the TIP;" 18 XVII b ~~ 65 Please rephrase "Reduce water consumption by incorporating water conservation measures into the General Plan" to "Reduce water consumption by complvin~ with water conservation measures contained in the General Plan." Comment acknowledged. As detailed under a response to an a-mail dated September 20, 2002 from Dean Givas to Suzy Kalkin, the referenced cumulative impacts mitigation measure has been reworded. 19. XVII b pgL65 -Please revise this section to state that "the Project will pay the Sewer Improvement Fee estimated to be $1 23 per square foot currently being processed by the City and participate in a wastewater reduction plan to be adopted by the City." City of South San Francisco, November 2002 -38- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Comment acknowledged. Refer to discussion of the wastewater reduction plan in response to comment # 1 1 in Givas letter # 1 20. Please modify the Summary Table (Table 1 on pg 21 of the checklist) summarizin Chan es to mitigation measures. Comment noted. See table on the following page: "Table 2" (revised Table 1 in checklist). City of South San Francisco, November 2002 -39- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Table 2 (Formerly Table 1 in Draft Initial Study Checklist) Summary of Mitigation Measures Incorporated into the Project Which Would Reduce the Impacts To Less Than Significant Levels Issue Checklist Question * Mitigation Measures -Bold Italics indicate changes from the Initial Stud I Aesthetics a) Comply with policies of the East of 101 Area Plan (Policies DE-1, DE-5, DE-17, DE-24, DE-52, DE-54, DE-56, DE-58) to take advantage of bay views and view corridors. d) Comply with East of 101 Area Plan Design Element Policy DE- 29, regulating levels of security lighting. III Air Quality a) Comply with of BAAQMD CEQA Guidelines to reduce the impact of construction emissions (dust). IV Biological Resources a) Apply appropriate precautions during construction to avoid indirect impacts to avoided Habitat. This should include ittstallatiot: of protective constructiat fencing as far as possible landward from the edge of wetland habitat. r - ~« 'ft. at, r t c t' ~- d ii vFtlfift Q-ii -~ - = iT r' im S ~ . i iccicrr rc cu Ci v -r a - - 1 b) Protect mudflat and tidal salt marsh habitats from intrusion during construction and operation, by compliance with measures listed under section IV b) of the checklist discussion, including preparation of a Storm Water Pollution Prevention Plan (SWPPP). A qualified biologist s{:ould be /tired, subject to t{:e approval of the City, to monitor construction activities to ensure compliance with Biological Resources n:itigatiotr n:eastrres. c) If the seasonal wetlands are determined to be Corps and RWQCD jurisdictional, provide replacement wetlands on-site or in the immediate vicinity of the site, and comply with requirements of Sections 401 attd 404 of the Clean Water Act. ,.,~ ~` Note: Mitigation measures in this table are also identified with an asterix (*) in the text of the checklist City of South San Francisco, November 2002 -40- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Issue Checklist Question ~ Mitigation Measures -Bold Italics indicate changes from the Initial Study VI Geology and a) ii, iii To mitigate for seismic impacts, comply with policies of the East Soils of 101 General Plan (GEO-1, GEO-2, GEO-3, GEO-7, GEO-10, GEO-11, GEO-12) and the Uniform Building Code. Since the Initial Study has been released, the City has received, reviewed and accepted the geotechnical reports that comply with the General Plan Policies and satisfy the mitigation measures defined in the Draft Initial Study. b) The landscape architect shall minimize erosion from precipitation or irrigation through accepted erosion control measures. c), d) Conduct a geotechnical investigation to assess the potential for settlement and subsidence and comply with policies of the East of 101 General Plan (GEO-1, GEO-2, GEO-3, GEO-7, GEO-10, GEO-11, GEO-12) and the Uniform Building Code. Since t1:e Initial Study has been released, the City has received, reviewed and accepted the geotechnical reports that comply with tl:e General Plan Policies and satisfy the mitigation measures defined in the Draft Initial Study. VII Hazards and a) Comply with all applicable regulations for the storage, use and Hazardous handling of hazardous substances, as established by federal Materials (EPA), state (DTCS), (RWQCB), California OSHA, California EPA, local (County of San Mateo), and City of South San Francisco regulations. VIII Hydrology a) Comply with NPDES, SWPPP, the San Mateo County Urban and Water Runoff Clean Water Program, BMPs, erosion control and Quality filtration of runoff to reduce non-point source pollutants entering San Francisco Bay. d) Install and up gradient box culvert that will reduce potential off- site flooding, based upon a drainage study prepared by the applicant's Project Engineer and approved by the City. e) Install an up-gradient box culvert acceptable to the City Engineer that will provide adequate capacity and reduce the potential for polluted runoff, f) Implement the water quality control measures required under Discussion VIII a). ~` Note: Mitigation measures in this table are also identified with an asterix (*) in the text of the checklist. City of South San Francisco, November 2002 -41- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Issue Checklist ~ Mitigation Measures -Bold Italics indicate changes from the Question Initial Study IX Land Use and b) Allow a Base Floor Area Ratio up to 1.0 FAR to accommodate the Planning Project proposal for 0.50 FAR, consistent with General Plan Table 2.2-2. c) Comply with requirements and guidelines of the Bay Conservation and Development Commission (BCDC) related to any land alteration within the "Shoreline Band", and consistent with potential habitat impacts discussed in checklist issue Section IV Biolo ical Resources. XI Noise a) Comply with General Plan noise mitigation policies NO-2 and NO-4, related to loading and auxiliary equipment areas. b) Comply with measures to minimize noise and vibration from pile driving, based upon ground conditions discussed in checklist Section VI Geology and Soils, and responsive to concerns about noise from people in the area by the City Engineer (Jim Kirkman, Building Official) XIII Public a) Comply with building and fire codes, use of keyed entry (Knox Services Boxes) during construction, and key pad digital equipment when the project is operational, for fire and police accessibility. b) Submit a "Security and Safety Plan" making provision for private security guards and provision for Knox Boxes to be on-site, commencing with the construction phase, and key pad digital equipment when the project is operational. XIV Recreation b) Coordinate improvements within and adjacent to the BCDC Shoreline Band, to minimize the potential for physical impact to the environment. * Note: Mitigation measures in this table are also identified with an asterix (*) in the text of the checklist. City of South San Francisco, November 2002 -42- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Issue Checklist Question * Mitigation Measures -Bold Italics indicate cha~ages from the Initial Study XV Transportation/ a) Prepare a TDM Plan -pursuant to the City TDM Ordinance - Traffic implementation of relevant General Plan Policies, and participate in the TIP for 7 intersections and 3 street segments listed on pg. Appx-I8. In addition, the Project would contribute to the costs of improvements beyond the TIP at 8 intersections, on Appx-28. 4 ..: 1.4 4 .~ - a r C t.l~llC n,...4..cini See also revision to XVII b, pg.65: "Transportation Improvements ;funding responsibilities [Response to Comment #17, Civas letter No.2J. b) Prepare a TDM Plan pursuant to South San Francisco TDM Ordinance (Schedule 20.120.030-B). ~ Reduce the amount of parking required by the Zoning Ordinance (Chapter 20.74), pursuant to relevant policies of the General Plan (4.3-I-11 to 4.3-I-13), and action by the Planning Commission in determining that the amount of parking is supported by the overall TDM Plan for the Project. XVI Utilities and b) Reduce the total volume of wastewater generated and minimize Service peak discharge rates by the Project by such measures as Systems recycling, pre-treatment and off-peak discharge. c) Install an up-gradient storm drainage box culvert ~l-ti-Ie XVII Mandatory b) See measures to mitigate cumulative impacts to intersections Findings of Si nificance (XV), vehicular trips (XV), water conservation (XVI), wastewater i s g capac ty (XV 1). Note: Mitigation measures in this table are also identified with an asterix (*) in the text of the checklist. city of South San Francisco, November 2002 -43- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS This page intentionally left blank. City of South San Francisco, November 2002 -44- Final Initial Study, East Jamie Court Project ,. 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HARVEY & ASSOCIATES ECOLOGICAL CONSULTANTS 11 October 2002 Mr. Niall Malcohnson Dowler-Gruman Architects 550 Ellis Street Mountain View, CA 94303 650.943.1660 SUBJECT: East Jamie Court: Bay Trail Improvements Dear Mr. Malcolmson: I have reviewed the proposed alignment of the Bay Trail Improvements overlain onto our wetland figure (Figure 5, H.T. Harvey & Associates, 1 October 2002, East Jamie Court, Identification of Waters of the U.S~. As you are awaze, we extended the mapping of Corps-regulated habitats beyond the parcel boundaries to the south to include the Mean High Water Mark, High Tide Line and tidal salt marshes of the adjacent San Francisco Bay. For clarification, the most landward limit of potential jurisdictional waters, as shown on Figure 5 from our report, is the "Section 404 High Tide Line". The work along the southern boundary of the pazcel related to the Bay Trail Improvements, as prepared by Stevan Nakashima, is identified as "Area of Slope Stabilization." There is an apparent overlap of the slope stabilization work into Corps-regulated habitats (Section 404 High Tide Line) for approximately 200 linear feet. This overlap starts around 220 from the eastern parcel boundary and continues west to azound 400 feet from the eastern parcel boundary. If the southerly limit of slope stabilization work is shifted north (or up slope), between 2 and 10 feet, in this vicinity I am confident that work related to the Bay Trail Improvements will avoid all direct impacts to Corps-regulated habitats. If you have any questions regarding this work please feel free to contact me. Sincerely, Cr~ Patrick J. Boursier, .D. Principal, Botany, Wetlands & Permitting Division 3150 Almaden Expressway, Suite t45 • San Jose, CA 95118 • (408) 448-9450 • Fax: (408) 448-9454 -49- October 15, 2002 Ms. Susy Kalkin City of South San Francisco Planning Division P. O. Box 711 G I VAS #3 South San Francisco, CA 94083 RE: East Jaime Court Project Dear Susy, At our meeting on October 11`h, which also included the City Engineer and the civil engineers for the project, we agreed upon an alternative up-gradient improvement to the storm drainage system in lieu of replacement of the storm outfall. On behalf of Alexandria Real Estate Equities ("Applicant"), this letter provides the proposed substitute language for those mitigation measures which include replacement of the outfall per the Initial Study and Mitigated Negative Declaration prepared by Morehouse Associates and dated September 2002 regarding the above-referenced project. We propose the following language: "To prevent the worsening of existing flooding conditions, the City would require the Project sponsors to increase the system's discharge capacity by replacing the existing 48-inch pipe from the inlet at the intersection of Haskins Way and Jamie Court to the next inlet downstream with a 77 linear foot, 6 foot by 4 foot box culvert." The language would be inserted in VIII (d) on page 48. Mitigation measures for VIII (d), - VIII (e) and XVI (c) would need to be changed to reflect the new scope of work. In 2 addition, references to the outfall replacement in IV (a) and IV (c) should be deleted. Lastly, given the lack of any work in the wetland areas on account of (i) elimination of the outfall as part of the project, (ii) the shifting of the Bay Trail and related grading away from the shoreline marsh and (iii) the likelihood that the potential seasonal wetlands will be disclaimed by the Corps., we request that the City remove the requirement of hiring a biologist to monitor construction activities (one of the mitigation measure in IV (b)) upon dismissal of item (iii) by the Corps. -50- Thank you again for your continued cooperation. The drainage analysis completed by Sandis Humber Jones will be sent separately to your attention. Sincerely, f~y~~ Dean D. Givas President Oyster Development Corp. CC: Steve Richardson, Alexandria Real Estate Equities Vincent Ciruzzi, Alexandria Real Estate Equities Niall Malcolmson, Dowler-Gruman Architects -51- Pa~e 2 of 2 RESPONSE TO COMMENTS RESPONSE TO LETTER NUMBER 3 FROM DEAN GIVAS, OYSTER DEVELOPMENT CORP. 1. jItem VIII d, p~J The City Engineer no longer plans to require the project sponsor to replace the storm drain outfall to San Francisco Bay at the end of Haskins Way. Instead, a section of storm drain located farther upstream on Haskins Way would be increased in size as part of the proposed project to increase the system's overall flow capacity. The discussion and mitigation measure under VIII d should be revised accordingly. Comment acknowledged. Based on the change in project requirements described above, and also on additional information regarding existing flooding conditions along Haskins Way, Discussion VIII d is revised as follows: Discussion VIII d. As currently proposed, the project's storm water runoff would be directed away from all on-site buildings and other improvements that might be adversely affected by flooding. In addition, the ground surface in the project vicinity generally slopes toward the bay, so, in the event that runoff overflows the perimeter of the site (if the on-site storm drain system becomes blocked), it would flow away from neighboring properties. The only area that might be subject to worse flooding following project development is the intersection of Swift Avenue and Haskins Way. According to a representative of the City Engineering Department, the storm drain line the project would tie into does not have sufficient capacity to accommodate the runoff from its existing drainage area, which can result in localized flooding up to one foot in depth under existing runoff conditions around a low point at the Swift Avenue intersection. The storm drain's drainage area extends north past East Grand Avenue, encompassing approximately 56.5 acres (excluding the 6 acre project site). It appears the westerly 80 percent (±) of the project site now drains toward Haskins, while the remainder drains to a pair of storm drain inlets near the easterly site boundary that discharge through a pipe to the edge of the bay. The portion that drains to Haskins Way does not do so directly, though. Runoff is detained behind a low perimeter dike and overflows through a small diameter pipe to the corner of Haskins and East Jamie Court, where it then runs downhill to a catch basin at the south end of Haskins. It is expected this arrangement significantly slows storm water discharges from the site and increases on- site percolation, limiting the property's effect on existing conditions in the Haskins Way storm drain. Project development would route runoff from the entire site toward Haskins Way, increase the total amount of runoff through the construction of impervious surfaces, and significantly reduce the site's existing storm water detention time. These changes would increase the rate and total volume of runoff discharged to the Haskins Way storm drain, and potentially increase the depth of flooding at Swift Avenue during a 10 year recurrence interval storm by approximately 5 inches (according to hydraulic calculations prepared by Sandis Humber City of South San Francisco, November 2002 -52- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS Jones Engineers, engineers for the proposed project). To prevent this worsening of existing flooding conditions, the City would require the project sponsors to increase the system's discharge capacity by replacing a 77 foot section of the 48 inch diameter Haskins Way storm drain, between the intersection of East Jamie Court and the next downstream inlet, with a 6 foot by 4 foot box culvert. The previously mentioned hydraulic calculations indicate the provision of additional flow capacity in this one pipe section should allow the system to accommodate the increased runoff from the project site and reduce the existing depth of flooding at Swift Avenue by approximately one inch (as compared with predevelopment conditions). City policy stipulates that a project not worsen existing flooding conditions by discharging its runoff into a public storm drain, so construction of the proposed pipe replacement as a condition of project development would be consistent with this requirement. * Replacement of the 77 foot length of existing Haskins Way storm drain is incorporated into the Project, so the storm drain impact would be less than significant. 2. [Items VIII e &XVI c, pis. 48 & 631 Mitigation measures for VIII (e) and XVI (c) would need to be changed to reflect the new scope of work. Comment acknowledged. The referenced sections are revised as follows: Discussion: VIII. e As discussed under VIII d, replacement of one section of the existing Haskins Way storm drain should provide adequate capacity to accommodate unattenuated storm water runoff from the developed project site, and reduce the project impact to a less than significant level. * With incorporation of the storm drain replacement as part of the Project, the impact would be reduced to a less than significant level. Discussion XVI c.: As discussed under VIII d, development of the proposed project would require replacement of one section of the existing City maintained Haskins Avenue storm drain, which should reduce the project's impact on existing storm drain facilities to a less than significant level. * Incorporation of the storm drain replacement is made a part of the Project, so the impact would be less than significant. 3. Lastlygiven the lack of any work in the wetland areas on account of (i) elimination of the outfall as part of the Project, (ii) the shifting of the Bay Trail and related radin awa f the shoreline marsh and (iii) the likelihood that the potential seasonal wetlands will be disclaimed by the Coms, we request that the City remove the requirement of hiring a biologist to monitor construction activities (one of the mitigation measure in IV (b) upon dismissal of item (iii) by the Corps). City of South San Francisco, November 2002 -53- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS The comment suggests that there is no longer a need for a biologist to monitor construction activities due to the revised site plans which fully avoid all delineated wetlands. However, even under the revised plans, these will be a potential for indirect impacts to adjacent wetland and the associated potential habitat for listed species. For example, construction equipment could mistakenly intrude into the wetlands, or filling or grading of the wetland habitat could mistakenly occur. Therefore, a biologist is still required to monitor construction activities, albeit at a reduced level, to ensure compliance with mitigation conditions under Discussion 1 Va and Discussion IV b. City of South San Francisco, November 2002 -54- Final Initial Study, East Jamie Court Project ~1Gp`I' El~r G~ Cj~<t, Fri - ~ 865 Lotting Lane, Suite .A w z' Vacaville, California 95688 ~ t~ C'~ (707) 447-4025, fax 447-4143 8798 Airport Road Redding, California 96002 (530) 222-0832, fax 222-1611 Cp~ KC ENGINEERING COMPANY A SUBSIDIARY OF MATERIALS TESTING, INC. Project No. VV830-O1 KC ENGINEERING 25 September 2002 Mr. Steve Richardson Alexandria Real Estate Equities, Inc. 2929 Campus Drive, Suite 400-A San Mateo, California 94403 Subject: Proposed Office/Laboratory Buildings APN 015-102-250 Jamie Court and Haskins Way South San Francisco, California GEOTECHNICAL REVIEW Reference: 1) Updated Geotechnical Investigation Report Prepared by KC ENGINEERING CO: Dated 3 September 2002 2) Draft Initial Study and Mitigative Negative Section'VI (Pages 38 to 41) Prepared by Morehouse Associates _ Dated September 2002 3) Topography Map Prepared by Robert A. Karn & Associates, Inc. Dated June 2002 (rev. 8/22/02) Dear Mr. Richardson: In accordance with your authorization, KC ENGINEERING CO. has reviewed Section VI of the Initial Study and Mitigative Negative Declaration, Reference 2, and. the Reference 1 report and Reference 3. plan prepared for the subject project. In addition, we have performed a site visit on 20 September 2002 with Niall Malcolmson of Dowler-Gruman Architects and Steven Nakashima, consulting Civil Engineer. The purpose of our review and site visit was to provide comments to the items discussed in Reference 2. Based on our review and site visit, the following comments and recommendations are provided which correspond to the section numbers in the Reference 2 document: Section VI a ii) and iii) The shoreline slopes on the south side of the site have existing inclinations of 2:1 to 2.5:1 (horizontal to vertical). Portions of the slopes are covered with large broken concrete pieces, 1 asphalt; boulders and debris. A total- of 5 borings were completed along and near the shoreline slopes. There are no indications of existing slope instability, weak soils, or accelerated erosion _ ~ - -55- ,, , Project No. VV830-01 Geotechnical Review/Jamie Court 25 September 2002 within the limits of the site. However, the lower portions of the slopes outside the limits o£the site and along the tideland have shallow soil slumps and signs of significant erosion. These slopes aze located on the southeast portion of the site and extend approximately 400 feet along the shoreline. It appears that attempts have been made to mitigate, the continued erosion by placing asphalt and ! concrete fragments over the slope face. ! 1 The proposed buildings will be located 40 to 60 feet from the top of the upper slopes. and will be founded on deep piles deriving support from the competent bearing materials which underlie the site at depth. Therefore, it is our opinion that the proposed buildings will~not be adversely impacted by erosion or instabilities of the tidal slopes provided the recommendations of the Reference 1 report are incorporated into the design and construction of the project. However, the proposed project includes the extension of the existing trail system along the southern portion of the site. Some minor grading is required to construct the trail where it extends from the upper pad area on the southeast corner of the site down to the shoreline. The transition area will require that a fill slope be .constructed over an area that has already experienced some soil movement. The fill slope will require that a keyway be established at the base of the fill slope into competent soils and the fill placed while benching into competent materials as the filling progresses. Atypical detail of the required grading is attached to this letter. It is also recommended that the finished slope and other portions of the shoreline slopes that are not graded be provided with erosion protection. The erosion protection should consist of placing rip-rap material from the flat portiori of the tideland to at least 1 foot above the 100 yeaz tideline. The slopes should be graded such that they aze no steeper than 2:1. A 5 feet wide key should tie trenched at the base of the slope that extends at least 2 feet below the tideland. A geotextile filter 2 fabric, Type A as specified in CalTrans ~Standazd Specifications Section 88-1.04, should be placed along the sides and bottom of the key and extended up the slope in accordance with Section 72.2025. The rip rap material should then be placed in the key and up the slope to provide a thickness of at least 2 feet. The rip-rap may consist of the numerous sandstone boulders which line the perimeter of the site provided some of the boulders are broken down to provide a graded material and to minimize voids to the satisfaction of the Soils Engineer. -~ Discussions of liquefaction and lateral spreading potential are provided in the Reference 1 report on pages 10 and 11. In summary, the in-situ penetration resistance of the subsurface granulaz soils susceptible to liquefaction generally indicates a relative density which is medium dense to very 3 dense and not considered liquefiable. However, a liquefiable layer of gravelly sand was encountered in Boring 2 at a depth of 15 feet and is conservatively estimated to be 10 feet thick. ,Potential settlement of this layer due to liquefaction was estimated at 3 inches. It was noted that this " layer is within the fill.and is discontinuous across the site. Furthermore, due to the'discontinuity and depth of the layer in respect to the adjacent free slope face, the potential foi• lateral spreading is expected to be low. ~ - Section VI c and d As discussed in the Reference 1 report, the subject site was created by hydraulic filling in the San Francisco. Bay. The filling. operation began in 1968, under the .observation of Woodwazd-Clyde • - -56- KC ENGINEERING CO. Page 2 of 3 . ,: Project No. VV830-01 Geotechnical Review/Jamie Court 25 September 2002 __ Consultants, with the construction of a perimeter dike consisting of dry fill. The interior of the cell was then gradually filled until the current grades were achieved. It is our understanding that the filling was completed in the, late 1970's. The fill consists of variable layers of moderately expansive silty clay, clayey sand, sandy clay, gravelly sand, and sandy gravel. Provided the recommendations of the Reference 1 report are followed, the negative impacts of any expansive soils should be minimized. A further discussion of the fill along with laboratory test results of samples collected within the fill are provided in the Reference 1 report. The perimeter dike and the interior fill have been present for over 20 years and have been subjected to seismic accelerations during the 1989 Loma Prieta earthquake. Seismic related failures such as slope instability, liquefaction and lateral spreading did :not- occur on the site. Based on the information obtained during our field and laboratory investigation and on studies completed by Woodward- Clyde Consultants as contained in the Declaration of Covenants, it is our opinion that the perimeter dike is stable under its existing conditions. In addition, since minimal grading is proposed on the site and the buildings will be supported on deep pile foundations, the stability of the perimeter dike will not be adversely affected. 4 It is noted that the Reference 2 document does not make reference to our Geotechnical Investigation. It is recommended that the consultants who prepared the Initial Study and Mitigative Negative Declarations• be allowed to review the Reference 1 report to note the site specific subsurface conditions and the conclusions and recommendations provided accordingly. Should there be any questions or should you 'require any additional information, please contact our office at your convenience. - QPpFESS/p ~o k9~ Respectfully Submitted, Revi ed y: _ h~QQJS~EVEN'0gs `cy~ KC ENGINEER/I~NG CO. sc' EXP.-~~w!°n- David V. Cy ski, P.E.. s ~ ~P ~ Jerry S. Pascoe, P.E. , ~qr eiv-t P~' pro ect En ineer Principal Eng eer FOFCa,~~F~ ~ g Attached: ,Typical Fill Slope Detail Copies: 2 to Addressee 2 to Niall Malcolmson, DGA - KC ENGINEERING CO. _5']_ Page 3 of 3 .. TYPICAL FILL SLOPE CROSS-SECTION (Not to Scale) it ~- Engineered Fill at 90% Tideland rift 100yr Line_ ~- / 1,.C"~ ~-Geotextile ft. min. f ~ 5% ~ / /r- Existing Ground Sft I S ft min. NOTES: 1. This is a typical cross-section for fill slope construction. Variations may be encountered during grading. 2. Dimensions of keyways and benches are subject to approval in the field by the Soil Engineer. KC ENGINEERING COMPANY 865 Lotting Lane, Suite A Vacaville, CA 95688 (~o~) aa~-ao2s -58- Project No. VV830-O1 Proposed Office/Laboratory Buildings Jamie Court and Haskins Way South San Francisco, California FIGURE NO. 1 "FILL SLOPE DETAIL" RESPONSE TO COMMENTS RESPONSE TO LETTER FROM KC ENGINEERING COMPANY (TO STEPHEN RICHARDSON, ALEXANDRIA REAL ESTATE EQUITIES, INC.) Reference Documents Cited in the Letter from KC Engineering: 1) Updated Geotechnical Investigation Report Prepared by KC Engineering Co. Dated 3 September 2002 2) Draft Initial Study and Mitigated Negative Declaration Section VI (pages 38 to 41) Prepared by Morehouse Associates Dated September 2002 3) Topography Map Prepared by Robert A. Karn & Associates, Inc. Dated June 2002 (rev. 8/22/02) Section Via ii and iii, page 39 The shoreline slopes on the south side of the site have existing inclinations of 2:1 to 2.5:1 (horizontal to vertical). Portions of the slopes are covered with lame broken concrete pieces, asphalt, boulders and debris. A total of 5 borings were completed along and near the shoreline slopes. There are no indications of existing slope instability, weak soils, or accelerated erosion within the limits of the site. However, the lower portions of the slopes outside the limits of the site and along the tideland have shallow soil slumps and si ns of significant erosion. These slopes are located on the southeast portion of the site and extend approximately 400 feet along the shoreline. It appears that attempts have been made to mitigate the continued erosion b~placing asphalt and concrete fragments over the slope face. The proposed buildings will be located 40 to 60 feet from the top of the upper slopes and will be Founded on deep piles deriving support from the competent bearing materials which underlie the site at depth. Therefore...the proposed buildings will not be adversely impacted by erosion or instabilities.... However, the proposed project includes the extension of the existin t~ystem along the southern portion of the site. Some minor rg ading is required.... The transition area will require that a fill slope be constructed over an area that has alread~xperienced some soil movement. The fill slope will require a keyway.... A typical detail of the required grading is attached to this letter. Comment noted. The potential for significant damage to the proposed improvements due to erosion of new or existing soil slopes appears to have been addressed by the project Geotechnical Engineer. However, the typical grading detail does not include any subdrains to prevent the build-up of hydrostatic pressures behind the new fill slopes; build-up of these pressures could lead to future instability of the fill. Subdrains are typically required at the City of South San Francisco, November 2002 -59- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS toe key and at the back of one or two of the intermediate keys. In this case, a subdrain in the toe key may not be required if the toe is below the groundwater table. The need for subdrains should be addressed by the Geotechnical Engineer, to the satisfaction of the City Engineer. Although not stated in the comment above, the civil plans will also likely include measures to mitigate the potential for off-site erosion from astorm-water control standpoint. 2. It is also recommended that the finished slope and other portions of the shoreline slopes that are not graded be provided with erosion protection. The erosion protection should consist of placing rip-rap material from the flat portion of the tideland to at least 1 foot above the 100 year tideline. The slopes should be graded such that they are not steeper than 2:1. A 5 feet wide key should be trenched at the base of the slope.... The rip rap should then be placed in the ke amp the slope to provide a thickness of at least 2 feet. The rip-rap may consist of the numerous sandstone boulders which line the perimeter of the site.... Comment acknowledged. Rip-rap will provide adequate erosion protection to the lower portion of the slopes. Erosion protection of the upper portion of the slopes will be addressed in the civil and/or landscaping plans. Discussions of liquefaction and lateral spreading_potential are provided in the Reference 1 report.... In summary, the in-situ penetration resistance of the subsurface granular soils susceptible to liquefaction eg nerally indicates a relative density which is medium dense to very dense and not considered liquefiable. However, a liquefiable layer of rev sand was encountered in Boring 2.... Potential settlement of this layer ... was estimated at 3 inches. It was noted that this layer is ... discontinuous across the site... and the potential for lateral ~readin is expected to be low. Comment acknowledged. Evaluation of liquefaction and lateral spreading potential by the project Geotechnical Engineer complies with the East of 101 Area Plan EIR policies GEO-10 and GEO-11 and reduces this concern to a "Less than Significant Impact with Mitigation." Section V is and VI d, ppage 40: 4. As discussed in the Reference 1 report, the subject site was created by hydraulic filling in the San Francisco Bay. The filling operation began in 1968, under the observation of Woodward-Clyde Consultants, with the construction of a perimeter dike consistin off drX fill. The interior of the cell was then rag dually filled until the current grades were achieved. It is our understanding that the filling was completed in the late 1970's. The fill consists of variable layers of moderately e~~ansive silty clay, clay sand, sandy clams ray sand, and sandy gravel. Provided the recommendations of the Reference 1 report are followed the negative impacts of any expansive soils should be minimized. A further discussion of the fill along with laboratory test results of samples collected within the fill are provided in the Reference 1 report. The perimeter dike and the interior fill have been present for over 20 years and have been subjected to seismic accelerations during the 1989 Loma Prieta City of South San Francisco, November 2002 -60- Final Initial Study, East Jamie Court Project RESPONSE TO COMMENTS earthquake. Seismic related failures such as slope instabilit~quefaction and lateral spreading did not occur on the site. Based on the information obtained during our field and laboratory investigation and on studies completed by Woodward-Clyde Consultants as contained in the Declaration of Covenants, it is our opinion that the perimeter dike is stable under its existing conditions. In addition, since minimal rading is proposed on the site and the buildings will be supported on dee~pile foundations, the stability of the perimeter dike will not be adversely affected. Comment acknowledged. Implementation of appropriate geotechnical recommendations presented in the geotechnical report will mitigate any potentially adverse impacts related to the possible presence of moderately expansive surficial soil. Comment noted. The absence of visible indications of liquefaction at the site following the 1989 Loma Prieta earthquake does not preclude the possibility for future liquefaction, liquefaction-induced ground failure, or seismic slope instability at the site. Because of the distance from the site to the epicenter of the Loma Prieta event, the peak ground acceleration (PGA) at the site in 1989 may have been significantly less than the PGA that may occur at the site during a future seismic event on a nearby fault. The PGA used for the liquefaction and seismic slope stability analyses should be consistent with the minimum acceleration recommended by the 1997 Uniform Building Code, including the appropriate allowances for near-source effects. Provided the geotechnical engineer evaluated the potential for liquefaction and seismic slope instability using the appropriate PGA and generally accepted analysis procedures, we take no further issue with this statement. 5. It is noted that the Reference 2 document does not make reference to our (Reference 11 Geotechnical Investigation. It is recommended that the consultant who prepared the Initial Study and Mitigated Negative Declarations be allowed to review the Reference 1 report to note the site specific subsurface conditions and the conclusions and recommendations provided accordingly. Comment noted. At the time these responses were prepared, the Geotechnical Investigation had not been provided for review. However, the purpose of the Initial Study and Mitigated Negative Declarations is to ensure the appropriate measures are identified and implemented such that potentially significant impacts related to the development are mitigated to a "less than significant" level during design of the proposed improvements. Therefore, it is not necessary and/or appropriate for the consultant to review and/or approve the project documents. Acceptance of the Geotechnical Investigation by the City is sufficient to show the impacts related to geology and soils have been mitigated to a "less than significant" level. City of South San Francisco, November 2002 -61- Final Initial Study, East Jamie Court Project MALCOLMSON Subj: East Jamie Court Date: 10/3/2002 2:03:53 PM Pacific Daylight Time r -n: [email protected] (Niall Malcolmson) [email protected], [email protected] CC: [email protected], [email protected], [email protected], [email protected] Richard & Andy, In regards to the Initial Study and Mitigated Negati~,e Declaration we wish to confirm that the discussion of "Filtration", beginning at the top of page 46, is based on the filtration areas in and around the parking areas. And does not include or refer to the original plans which included open detention basins, planted with grass, which were located on the south side of the buildings. The open detention basins were deleted from the project, and the existing outfall will be replaced instead of proHding on-site retention. Please confirm Thanx, Niall Malcolmson, AIA Dowler-Gruman Architects 550 Ellis Street Mountain View, CA 94043 Phone: (650) 943-1660 ext. 206 Fax (650) 943-1670 -62- RESPONSE TO COMMENTS RESPONSE TO LETTER FROM NIALL MALCOLMSON, DOWLER-GRUMAN ARCHITECTS In regards to the Initial Study and Mitigated Negative Declaration, we wish to confirm that the discussion of "Filtration" be inning at the top of page 46 is based on the filtration areas in and around the parking areas and does not include or refer to the on final plans which included open detention basins, planted with grass, which were located on the south side of the buildings. The open detention basins were deleted from the project and the existing outfall will be replaced instead of providing on site-retention. The comment about filtration is acknowledged. However, the Applicant has eliminated the outfall as part of the project and replaced it with an upgradient box culvert. City of South San Francisco, November 2002 -63- Final Initial Study, East Jamie Court Project Pacific bas and E/ect~ic Company 1~~ Land Services October 14, 2002 Planning Division City of South San Francisco P.O.Box 711 South San Francisco, CA 94083 Attn: Susy Kalkin PG8~E Land Services Fr~`~V~D (/jf~r 4 ~ , ~ "~~`~~~~~`i,~~~ 111 Almaden Boulevard San Jose, CA 95115 RE: Notice of Availability of an Initial Study and Draft Mitigated Negative Declaration (IS&DMND) Project Title: East Jamie Court Office/ R&D Project APN 015-102-250 One mile ease of Hwy. 101 via East Grand Avenue At SE corner of Haskins Way and E. Jamie Ct., SSF PG&E File :40149096-02-MR-119 Dear Ms. Kalkin: Thank you for the opportunity to review the Notice of Availability of an Initial Study and Draft Mitigated Negative Declaration (IS&DMND) with Project Title: East Jamie Court Office/ R&D Project at above said location. PG&E has the following comments to offer: PG&E owns and operates gas and electric facilities which are located within and adjacent to the proposed project. To promote the safe and reliable maintenance and operation of utility facilities, the California Public Utilities Commission (CPUC) has mandated specific clearance requirements between utility facilities and surrounding objects or construction activities. To ensure compliance with these standards, project proponents should coordinate with PG&E early in the development of their project plans. Any proposed development plans should provide for unrestricted utility access and prevent easement encroachments that might impair the safe and reliable maintenance and operation of PG&E's facilities. The requesting party will be responsible for the costs associated with the relocation of existing PG&E facilities to accommodate their proposed development. Because facilities relocation's require long lead times and are not always feasible, the requesting party should be encouraged to consult with PG&E as early in their planning stages as possible. Relocations of PG&E's electric transmission and substation facilities (50,000 volts and above) could also require formal approval from the California Public Utilities Commission. If required, this approval process could take up to two years to complete. Proponents with development plans which could affect such electric transmission facilities should be referred to PG&E for additional information and assistance in the development of their project schedules. We would also like to note that continued development consistent with City's General Plans will have a cumulative impact on PG&E's gas and electric systems and may require on-site and off- site additions and improvements to the facilities which supply these services. Because utility facilities are operated as an integrated system, the presence of an existing gas or electric transmission or distribution facility does not necessarily mean the facility has capacity to connect new loads. '.rn, i1~~~~ -64- RESPONSE TO COMMENTS RESPONSE TO LETTER FROM PACIFIC GAS AND ELECTRIC CO. ALFRED POON, LAND AGENT 1. Andproposed development Mans should provide for unrestricted access and preventeasement encroachments that mi hg t impair the safe and reliable maintenance and operation of PG&E facilities. The requesting_party will be responsible for the costs associated with the relocation of existing PG&E facilities to accommodate their proposed development. Because facilities relocations require long lead times and are not always feasible, the requesting_party should be encouraged to consult with PG&E as early in their planning sta e~ s as possible. The Land Agent notes that there is no gas transmission nor electric transmission facilities on East Jamie Court, Haskins Way or that portion of East Grand Ave., north of the Project site. There is a Distribution Feeder Main (Gas) on East Grand Ave. ~ None of these gas or electrical transmission facilities will require relocation as a result of this Project. The applicants will be required to consult with PG&E subsequent to CEQA approval of the Project by the City and Redevelopment Agency. 2. Relocations of PG&E's electric transmission and substation facilities (50,000 volts and above) could also require formal approval from the California Public Utilities Commission. If required this approval process could take up to two years to complete. Proponents with development plans which could affect such electric transmission facilities should be referred to PG&E for additional information and assistance in the development of their project ~checlule~_ According to PG&E there are no gas or electric transmission near the Project site that will require relocation. It does not appear that any approval from the PUC will be required. 3. The environmental documents should address cumulative impacts to gas and electric systems The Mitigated Negative Declaration Initial Study found no significant Project impact to electrical and gas facilities. Therefore, there was no discussion of cumulative impacts. 4. The Mitigated Negative Declaration should note the existence of Electrical and Ma ng etic Fields (EMF) associated with electricity on the Project Site. There is no scientific consensus on the actual health effects of EMF exposure, but it is an issue of public concern. Comment acknowledged. There is no evidence that exposure to magnetic fields on the site is a significant impact. Documentation by PG&E of current research on EMF and their possible effects on humans is on file for this Project in the Planning Department of the City of South San Francisco. Contact Susy Kalkin, Principal Planner (650)877-8535. ~ Alfred Poon, Land Agent, PG&E, correspondence Oct. 24, 2002. City of South San Francisco, November 2002 -66- Final Initial Study, East Jamie Court Project Expansion of distribution and transmission lines and related facilities is a necessary consequence of growth and development. In addition to adding new distribution feeders, the range of electric system improvements needed to accommodate grow±h may include upgrading existing substation and transmission line equipment, expanding existing substations to their ultimate buildout capacity, and building new substations and interconnecting transmission lines. Comparable upgrades or additions needed to accommodate additional load on the gas system could include facilities such as regulator stations, odorizer stations, valve lots, distribution and transmission lines. We would like to recommend that environmental documents for proposed development projects include adequate evaluation of cumulative impacts to utility systems, the utility facilities needed to serve those developments and any potential environmental issues associated with extending utility service to the proposed project. This will assure the project's compliance with CEQA and reduce potential delays to the project schedule. We also encourage the Department of City Planning of City of South San Francisco to include information about the issue of electric and magnetic fields (EMF) in the Preliminary Negative Declaration. It is PG&E's policy to share information and educate people about the issue of EMF. Electric and Magnetic Fields (EMF) exist wherever there is electricity--in appliances, homes, schools and offices, and in power lines. There is no scientific consensus on the actual health effects of EMF exposure, but it is an issue of public concern. If you have questions about EMF, please call your local PG&E office. A package of information which includes materials from the California Department of Health Services and other groups will be sent to you upon your request. PG&E remains committed to working with City of South San Francisco to provide timely, reliable and cost effective gas and electric service to the planned area. We would also appreciate being copied on future correspondence regarding this subject as this project develops. The California Constitution vests in the California Public Utilities Commission (CPUC) exclusive power and sole authority with respect to the regulation of privately owned or investor owned public utilities such as PG&E. This exclusive power extends to all aspects of the location, design, construction, maintenance and operation of public utility facilities. Nevertheless, the CPUC has provisions for regulated utilities to work closely with local governments and give due consideration to their concerns. PG&E must balance our commitment to provide due consideration to local concerns with our obligation to provide the public with a safe, reliable, cost-effective energy supply in compliance with the rules and tariffs of the CPUC. Should you require any additional information or have any questions, please call me at (408) 282- 7401. Sincerely, ~~~~ ~ ~~r~s-~.J Alfred Poon Land Agent South Coast Area- San Jose -65-