HomeMy WebLinkAbout16 Ch 6_Other CEQA Considerations DEIR 10 12 18.pdf6. Other CEQA Considerations
6 OTHER CEQA CONSIDERATIONS
Chapter 6, Other CEQA Considerations, discusses mandatory findings of significance regarding
cumulative impacts pursuant to California Environmental Quality Act (CEQA) Guidelines Section
15065(a); significant environmental effects which cannot be avoided as identified in the Environmental
Impact Report (EIR); significant irreversible environmental changes, including energy and consumption
of nonrenewable resources; and growth- inducing impacts pursuant to CEQA Guidelines Section 15126.2,
and areas of known controversy and issues to be resolve pursuant to CEQA Guidelines Section 15123.
6.1 Mandatory Findings of Significance
CEQA Guidelines Section 15065(a) requires a finding of significance if a project has the potential to
impact the quality of the environment, impact fish or wildlife species, impact historic resources, impact
long -term environmental goals, create cumulatively considerable impacts, or create substantial adverse
effects on human beings.
6.1.1 Quality of the Environment
CEQA Guidelines Section 15065(a)(1) requires a finding of significance if a project "has the potential to
substantially degrade the quality of the environment." In practice, this is the same standard as a significant
effect on the environment, which is defined in CEQA Guidelines Section 15382 as "a substantial or
potentially substantial adverse change in any of the physical conditions within the area affected by the
project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic
significance."
As described in Chapter 4, Environmental Setting, Impacts, and Mitigation, the proposed project would
have no impact or a less- than - significant impact associated with aesthetics, agriculture and forest
resources, geology and soils, hazardous and hazardous materials, mineral resources, population and
housing, public services, and recreation. Environmental impacts associated with air quality, greenhouse
gas emissions, biological resources, cultural resources, hydrology and water quality, land use and
planning, noise, and utilities and service systems are considered less than significant or less than
significant with mitigation. Certain environmental impacts associated with transportation and circulation
are considered significant and unavoidable, as discussed in Section 6.3 below.
6.1.2 Impacts on Species
CEQA Guidelines Section 15065(a)(1) states that a lead agency shall find that a project may have a
significant effect on the environment where there is substantial evidence that the project has the potential
to (1) substantially reduce the habitat of a fish or wildlife species; (2) cause a fish or wildlife population
to drop below self - sustaining levels; or (3) substantially reduce the number or restrict the range of an
endangered, rare, or threatened species. Section 4.3, Biological Resources, of this EIR fully addresses any
impacts that might relate to the reduction of the fish or wildlife habitat, the reduction of fish or wildlife
201 Haskins Way Project Draft EIR 6.1 October 12, 2018
6. Other CEQA Considerations
populations, and the reduction or restriction of the range of special - status species as a result of project
implementation. The proposed project would have either no impact, a less- than - significant impact, or a
less - than - significant impact with mitigation with respect to the potential to substantially reduce the habitat
of a fish or wildlife species, cause a fish or wildlife population to drop below self - sustaining levels,
threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or
endangered plant or animal.
6.1.3 Impacts on Historical Resources
CEQA Guidelines Section 15065(a)(1) states that a lead agency shall find that a project may have a
significant effect on the environment where there is substantial evidence that the project has the potential
to eliminate important examples of a major period of California history or prehistory. CEQA Guidelines
Section 15065(a)(1) amplifies Public Resources Code Section 21001(c) by requiring preservation of
major periods of California history for the benefit of future generations. It also reflects the provisions of
Public Resource Code Section 21084.1 in requiring a finding of significance for substantial adverse
changes to historical resources. CEQA Guidelines Section 15064.5 establishes standards for determining
the significance of impacts to historical resources and archaeological sites that are an historical resource.
Section 4.4, Cultural Resources, of this EIR fully addresses impacts related to California history and
prehistory, historic resources, archaeological resources, and paleontological resources. The proposed
project would have either a less- than - significant impact or a less- than - significant impact with mitigation
with respect to the potential to eliminate important examples of the major periods of California history or
prehistory.
6.1.4 Long -Term Impacts
CEQA Guidelines Section 15065(a)(2) states that a lead agency shall find that a project may have a
significant effect on the environment where there is substantial evidence that the project has the potential
to achieve short-term environmental goals to the disadvantage of long -term environmental goals. Section
6.2, Significant Environmental Effects, below, identifies all significant and unavoidable impacts that
could occur, thereby creating a long -term impact on the environment. Section 6.3, Significant Irreversible
Environmental Changes, below, addresses the short-term and irretrievable commitment of natural
resources to ensure that the consumption is justified on a long -term basis. Lastly, Section 6.4, Growth
Inducing Impacts, identifies any long -term environmental impacts caused by the proposed project with
respect to economic or population growth.
6.1.5 Impacts on Human Beings
CEQA Guidelines Section 15065(a)(4) states that a lead agency shall find that a project may have a
significant effect on the environment where there is substantial evidence that the environmental effects of
a project will cause substantial adverse effects on human beings, either directly or indirectly. As described
in Chapter 4, Environmental Setting, Impacts, and Mitigation, the proposed project would have no impact
or a less- than - significant impact associated with human beings such as seismic hazards (geology and
soils), and hazardous and hazardous materials. Environmental impacts associated with air quality, water
quality, noise, and utilities and service systems are considered less than significant or less than significant
201 Haskins Way Project Draft EIR 6.2 October 12, 2018
6. Other CEQA Considerations
with mitigation. Certain environmental impacts associated with transportation and circulation are
considered significant and unavoidable, as discussed in Section 6.3 below.
6.2 Cumulative Impacts
An EIR is required to examine cumulative impacts. California Code of Regulations Section 15130(a)(1),
defines a cumulative impact as consisting "of an impact which is created as a result of the combination of
the project evaluated in the EIR together with other projects causing related impacts." The analysis of
cumulative impacts need not provide the same level of detail as that for project- specific impacts, but it
shall "reflect the severity of the impacts and their likelihood of occurrence" (California Code of
Regulations Section 15130(b)).
CEQA Guidelines Section 15065 states that a lead agency shall find that a project may have a significant
effect on the environment where there is substantial evidence that the project has potential environmental
effects that are individually limited but cumulatively considerable. As defined in CEQA Guidelines
Section 15065(a)(3) , cumulatively considerable means "that the incremental effects of an individual
project are significant when viewed in connection with the effects of past projects, the effects of other
current projects, and the effects of probable future projects."
The cumulative impacts analysis in an EIR must analyze either a list of past, present, and probable future
projects or a summary of projections contained in an adopted general plan or related planning document.
A list of reasonably foreseeable future projects and projections used to analyze cumulative impacts is
provided in Section 4.A, Approach to Environmental Analysis. Cumulative impacts related to each
environmental topic are discussed in Chapter 4, Environmental Setting, Impacts, and Mitigation.
As described in Chapter 4, either there would be no cumulative impacts, cumulative impacts would be
less than significant, or the project would have a less than cumulatively considerable contribution (either
with or without mitigation) to significant cumulative impacts in the areas of aesthetics, air quality,
agriculture and forest resources, biological resources, cultural resources, geology and soils, greenhouse
gas emissions, hazardous and hazardous materials, hydrology and water quality, land use and planning,
mineral resources, noise and vibration, population and housing, public services, recreation, and utilities
and service systems are considered less than significant. However, Chapter 4 did identify significant and
unavoidable cumulative transportation and circulation impacts to which the project's contribution would
be cumulatively considerable, as detailed below.
6.3 Significant Environmental Effects that Cannot Be
Avoided
In accordance with Section 21067 of CEQA and with Sections 15126(b) and 15126.2(b) of the CEQA
Guidelines, the purpose of this section is to identify significant environmental impacts that could not be
eliminated or reduced to less- than - significant levels by implementation of mitigation measures included
in the proposed project or identified in Chapter 4, Environmental Setting, Impacts, and Mitigation. The
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6. Other CEQA Considerations
findings of significant impacts are subject to final determination by the City of South San Francisco City
Council as part of the certification process for this EIR.
The proposed project would result in significant and unavoidable project -level impacts and cumulatively
considerable contributions to significant and unavoidable cumulative impacts related to transportation and
circulation. No other environmental topics discussed in Chapter 4 would result in significant and
unavoidable environmental effects. As described in detail in Section 4.9, Transportation and Circulation,
these significant and unavoidable impacts are listed below.
TR -2 (Allerton/East Grand Avenue): Phase 1 or project buildout would cause the intersection of Allerton
Avenue and East Grand Avenue to exceed level of service (LOS) D operations during the PM peak hour
and would contribute more than 2 percent of total traffic through the intersection. Mitigation Measure
MM -TR -2 would reduce the impact by adding a traffic signal and a southbound right -turn lane. However,
the mitigation measure would remove a portion of the Class II bicycle lanes on Allerton Avenue,
disrupting an existing bicycle facility and resulting in a significant impact. To avoid the significant impact
of this mitigation measure, additional right -of -way would need to be acquired to widen the roadway.
Acquisition would require removal of parking spaces associated with adjacent business; these parking
spaces could not be replaced in alternative locations, such that the associated buildings would not be able
to be occupied. The City of South San Francisco has determined that causing businesses to be non - viable
due to lack of parking would reduce the city's tax base, and that funding sources for acquisition of
property for additional right -of -way are unknown and may not be available for the additional turn lane;
therefore, the mitigation measure is considered infeasible, While the mitigation measure could reduce the
traffic impact to a less- than - significant level, the mitigation measure is infeasible, the cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -3 (Airport Boulevard/Grand Avenue): Project buildout would contribute considerably to the
significant cumulative impact at the intersection of Airport Boulevard and Grand Avenue during the AM
peak hour. Mitigation Measure MM- C -TR -3 would compensate for the project's contribution to
cumulative traffic. However, the City does not have a mechanism for funding Mitigation Measure MM -C-
TR-3 and cannot guarantee that this mitigation measure will be implemented. Implementation of a
Transportation Demand Management (TDM) program would be required pursuant South San Francisco
Municipal Code Chapter 20.400; however, it cannot be guaranteed that the required TDM program would
reduce intersection traffic by the amount necessary to reduce the project's contribution to a significant
cumulative impact to a less- than - cumulatively considerable level. Therefore. the cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -4 (Dubuque Avenue and Grand Avenue): Project buildout would contribute considerably to the
significant cumulative impact at the intersection of Dubuque Avenue and Grand Avenue during the PM
peak hour. Mitigation Measure MM- C -TR -4 would compensate for the project's contribution to
cumulative traffic. However, the City does not have a mechanism for funding Mitigation Measure MM -C-
TR-4 and cannot guarantee that this mitigation measure will be implemented. Implementation of a
Transportation Demand Management (TDM) program would be required pursuant South San Francisco
Municipal Code Chapter 20.400; however, it cannot be guaranteed that the required TDM program would
201 Haskins Way Project Draft EIR 6.4 October 12, 2018
6. Other CEQA Considerations
reduce intersection traffic by the amount necessary to reduce the project's contribution to a significant
cumulative impact to a less- than - cumulatively considerable level. Therefore, the cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -5 (East Grand Avenue and Grand Avenue Overcrossing): The proposed project (Phase 1 or
buildout) would contribute considerably to a significant cumulative impact at the intersection of East
Grand Avenue and Grand Avenue Overcrossing during the PM peak hour. Mitigation Measure MM -C-
TR-5 would compensate for the project's contribution to cumulative traffic. However, the City does not
have a mechanism for funding Mitigation Measure MM- C -TR -5 and cannot guarantee that this mitigation
measure will be implemented. Implementation of a Transportation Demand Management (TDM) program
would be required pursuant South San Francisco Municipal Code Chapter 20.400; however, it cannot be
guaranteed that the required TDM program would reduce intersection traffic by the amount necessary to
reduce the project's contribution to a significant cumulative impact to a less- than - cumulatively
considerable level. Therefore, the cumulative impact would remain significant and the project's
contribution would remain cumulatively considerable.
C -TR -6 (Gateway Boulevard and East Grand Avenue): The proposed project (Phase 1 or buildout) would
contribute considerably to a significant cumulative impact at the intersection of Gateway Boulevard and
East Grand Avenue during the PM peak hour. Mitigation Measure MM- C -TR -6 would compensate for
the project's contribution to cumulative traffic. However, the City does not have a mechanism for funding
Mitigation Measure MM- C -TR -6 and cannot guarantee that this mitigation measure will be implemented.
Implementation of a Transportation Demand Management (TDM) program would be required pursuant
South San Francisco Municipal Code Chapter 20.400; however, it cannot be guaranteed that the required
TDM program would reduce intersection traffic by the amount necessary to reduce the project's
contribution to a significant cumulative impact to a less- than - cumulatively considerable level. Therefore,
the cumulative impact would remain significant and the project's contribution would remain cumulatively
considerable.
C -TR -7 (Harbor Way /Forbes Boulevard and East Grand Avenue): The proposed project (Phase 1 or
buildout) would contribute considerably to a significant cumulative impact at the intersection of Harbor
Way/Forbes Boulevard and East Grand Avenue in both the AM and PM peak hours. Mitigation Measure
MM- C -TR -7 would compensate for the project's contribution to cumulative traffic. However, the City
does not have a mechanism for funding Mitigation Measure MM- C -TR -7 and cannot guarantee that this
mitigation measure will be implemented. Implementation of a Transportation Demand Management
(TDM) program would be required pursuant South San Francisco Municipal Code Chapter
20.400; however, it cannot be guaranteed that the required TDM program would reduce intersection
traffic by the amount necessary to reduce the project's contribution to a significant cumulative impact to a
less- than - cumulatively considerable level. Therefore, the cumulative impact would remain significant and
the project's contribution would remain cumulatively considerable.
C -TR -8 (Littlefield Avenue /East Grand Avenue): Phase 1 or project buildout would contribute
considerably to the significant cumulative impact at the intersection of Littlefield Avenue and East Grand
Avenue, in the AM peak hour. Mitigation Measure MM- C -TR -8 would improve operations and the
201 Haskins Way Project Draft EIR 6.5 October 12, 2018
6. Other CEQA Considerations
cumulative traffic impact after mitigation would be less than significant. However, the revisions to the
lane striping could impact the existing bike lanes on East Grand Avenue. This secondary impact of the
mitigation measure would be significant relative to the bicycle and pedestrian impact criteria. Mitigation
of the secondary impact would require the acquisition of additional right -of -way from adjacent property
owners so that East Grand Avenue could provide a third eastbound through lane and maintain bicycle
lanes on each side. The acquisition of property would require removal of parking spaces for properties
that do not have alternative locations for replacement parking, such that the associated buildings would
not be able to be occupied. Because the City of South San Francisco has determined that acquisition of
property for additional right -of -way would economically affect existing businesses that need parking to
remain viable, and that funding for the acquisition is not assured, the mitigation measure is considered to
be infeasible. While the mitigation measure could reduce the traffic impact to a less- than - significant level,
the mitigation is infeasible, the cumulative impact would remain significant and the project's contribution
would remain cumulatively considerable.
C -TR -9 (Allerton Avenue /East Grand Avenue): Phase 1 or project buildout would contribute considerably
to the significant cumulative impact at the intersection of Allerton Avenue and East Grand Avenue, in the
PM peak hour. Mitigation Measure MM- C -TR -9 would improve operations and the cumulative traffic
impact after mitigation would be less than significant. However, the revisions to the lane striping would
remove a portion of the Class II bicycle lanes on Allerton Avenue and could impact the existing bike
lanes on East Grand Avenue. This secondary impact of the mitigation measure would be significant
relative to the bicycle and pedestrian impact criteria. Mitigation of the secondary impact would require
the acquisition of additional right -of -way from adjacent property owners so that East Grand Avenue could
provide a third eastbound through lane and maintain bicycle lanes on each side, and so that Allerton
Avenue could provide an additional southbound lane and maintain bicycle lanes. The acquisition of
property would require removal of parking spaces that do not have alternative locations for replacement
parking, such that the associated buildings would not be able to be occupied. Because the City of South
San Francisco has determined that acquisition of property for additional right -of -way could affect existing
businesses, and that funding for the acquisition is not assured, the mitigation measure is considered to be
infeasible. While the mitigation measure could reduce the traffic impact to a less- than - significant level,
the mitigation is infeasible, and the cumulative impact would remain significant and the project's
contribution would remain cumulatively considerable.
C -TR -10 (Airport Boulevard/Produce Avenue /San Mateo Avenue): Project buildout would contribute
considerably to a significant cumulative impact at the intersection of Airport Boulevard /Produce
Avenue /San Mateo Avenue in the PM peak hour. Mitigation Measure MM- C -TR -10 would compensate
for the project's contribution to cumulative traffic. However, the City does not have a mechanism for
funding Mitigation Measure MM- C -TR -10 and cannot guarantee that this mitigation measure will be
implemented. Implementation of a Transportation Demand Management (TDM) program would be
required pursuant South San Francisco Municipal Code Chapter 20.400; however, it cannot be guaranteed
that the required TDM program would reduce intersection traffic by the amount necessary to reduce the
project's contribution to a significant cumulative impact to a less- than - cumulatively considerable level.
Therefore, the cumulative impact would remain significant and the project's contribution would remain
cumulatively considerable.
201 Haskins Way Project Draft EIR 6.6 October 12, 2018
6. Other CEQA Considerations
C -TR -11 (Gateway Boulevard/South Airport Boulevard/Mitchell Avenue): Project buildout would
contribute considerably to the significant cumulative impact at the intersection of Gateway
Boulevard/South Airport Boulevard /Mitchell Avenue in the PM peak hour. No feasible physical
mitigation has been identified. While a Transportation Demand Management (TDM) program would be
required to be prepared and implemented pursuant to City ordinance, it cannot be demonstrated that the
required TDM program would reduce intersection traffic by the amount necessary to reduce the project's
contribution to a significant cumulative impact to a less- than - cumulatively considerable level. The
cumulative impact would remain significant and the project's contribution would remain cumulatively
considerable.
C -TR -12 (South Airport Boulevard/U.S. 101 Northbound Hook Ramps/Wondercolor Lane): Project
buildout would contribute considerably to the significant cumulative impact at the freeway ramp
intersection of South Airport Boulevard and U.S. 101 Northbound Hook Ramps /Wondercolor Lane in the
AM peak hour. No feasible physical mitigation has been identified. While a TDM program would be
required to be prepared and implemented pursuant to City ordinance, it cannot be demonstrated that the
required TDM program would reduce intersection traffic by the amount necessary to reduce the project's
contribution to a significant cumulative impact to a less- than - considerable level. The cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -13 (South Airport Boulevard and Utah Avenue): Project buildout would contribute considerably to
a significant cumulative impact at the intersection of South Airport Boulevard and Utah Avenue in the
AM peak hour. Mitigation Measure MM- C -TR -13 would compensate for the project's contribution to
cumulative traffic. However, the City does not have a mechanism for funding Mitigation Measure MM -C-
TR-13 and cannot guarantee that this mitigation measure will be implemented. Implementation of a
Transportation Demand Management (TDM) program would be required pursuant South San Francisco
Municipal Code Chapter 20.400; however, it cannot be guaranteed that the required TDM program would
reduce intersection traffic by the amount necessary to reduce the project's contribution to a significant
cumulative impact to a less- than - cumulatively considerable level. Therefore, the cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -15 (Airport Boulevard /Grand Avenue): Phase 1 or project buildout would add more than I percent
of total traffic and therefore would contribute considerably to the significant cumulative impact on the
southbound left turn movement in the AM and PM peak hours and the westbound right -turn movement in
the PM peak hour at the intersection of Airport Boulevard and Grand Avenue without the project.
Mitigation Measure MM- C -TR -15 would compensate for the project's contribution to cumulative traffic.
However, the City does not have a mechanism for funding Mitigation Measure MM- C -TR -15 and cannot
guarantee that this mitigation measure will be implemented. Implementation of a Transportation Demand
Management (TDM) program would be required pursuant South San Francisco Municipal Code Chapter
20.400; however, it cannot be guaranteed that the required TDM program would reduce intersection
traffic by the amount necessary to reduce the project's contribution to a significant cumulative impact to a
less- than - cumulatively considerable level. Therefore, the cumulative impact would remain significant and
the project's contribution would remain cumulatively considerable.
201 Haskins Way Project Draft EIR 6.7 October 12, 2018
6. Other CEQA Considerations
C -TR -16 (East Grand Avenue /Gateway Boulevard): Phase 1 or project buildout would add more than 1
percent of total traffic and therefore would contribute considerably to the significant cumulative impact
on the eastbound and westbound through movements in the PM peak hour and the westbound left turn
movement in the AM and PM peak hours on East Grand Avenue at Gateway Boulevard without the
project. MM- C -TR -16 would compensate for the project's contribution to cumulative traffic. However,
the City does not have a mechanism for funding Mitigation Measure MM- C -TR -16 and cannot guarantee
that this mitigation measure will be implemented. Implementation of a Transportation Demand
Management (TDM) program would be required pursuant South San Francisco Municipal Code Chapter
20.400; however, it cannot be guaranteed that the required TDM program would reduce intersection
traffic by the amount necessary to reduce the project's contribution to a significant cumulative impact to a
less- than - cumulatively considerable level. Therefore, the cumulative impact would remain significant and
the project's contribution would remain cumulatively considerable.
C -TR -17 (Airport Boulevard/Produce Avenue): Phase 1 or project buildout would add more than 1
percent of total traffic and therefore would contribute considerably to the significant cumulative impact
on the westbound left turn movement on Airport Boulevard at the intersection of Airport
Boulevard/Produce Avenue during the AM and PM peak hours in 2040 without the project. Mitigation
Measure MM- C -TR -17 would compensate for the project's contribution to cumulative traffic. However,
the City does not have a mechanism for funding Mitigation Measure MM- C -TR -17 and cannot guarantee
that this mitigation measure will be implemented. Implementation of a Transportation Demand
Management (TDM) program would be required pursuant South San Francisco Municipal Code Chapter
20.400; however, it cannot be guaranteed that the required TDM program would reduce intersection
traffic by the amount necessary to reduce the project's contribution to a significant cumulative impact to a
less- than - cumulatively considerable level. Therefore, the cumulative impact would remain significant and
the project's contribution would remain cumulatively considerable.
C -TR -18 (Northbound U.S.101 Off -Ramp /South Airport Boulevard/Wondercolor Lane): Phase 1 or
project buildout would add more than 1 percent of total traffic and therefore would contribute
considerably to the significant cumulative impact on the eastbound left turn movement on the northbound
U.S. 101 off -ramp at South Airport Boulevard/Wondercolor Lane during the AM peak hour in 2040
without the project. Mitigation Measure MM- C -TR -18 would compensate for the project's contribution to
cumulative traffic. However, the City does not have a mechanism for funding Mitigation Measure MM -C-
TR-13 and cannot guarantee that this mitigation measure will be implemented. Implementation of a
Transportation Demand Management (TDM) program would be required pursuant South San Francisco
Municipal Code Chapter 20.400; however, it cannot be guaranteed that the required TDM program would
reduce intersection traffic by the amount necessary to reduce the project's contribution to a significant
cumulative impact to a less- than - cumulatively considerable level. Therefore, the cumulative impact
would remain significant and the project's contribution would remain cumulatively considerable.
C -TR -19 (Freeway Segments): Project Buildout would add more than I percent of total traffic to two
freeway segments during the PM peak hour which would operate at LOS F under cumulative conditions
without the project. While a TDM program would be required to be prepared and implemented pursuant
to City ordinance, it cannot be demonstrated that the required TDM program would reduce freeway traffic
201 Haskins Way Project Draft EIR 6.8 October 12, 2018
6. Other CEQA Considerations
by the amount necessary to reduce the project's contribution to a significant cumulative impact to a less -
than- cumulatively considerable level. The cumulative impact would remain significant and the project's
contribution would remain cumulatively considerable.
C -TR -20 (Freeway Ramps): Phase 1 or project buildout would add more than 1 percent of total traffic and
therefore would contribute considerably to the significant cumulative impact on the northbound U.S. 101
off -ramp at South Airport Boulevard/Wondercolor Lane during the AM peak hour in 2040 without the
project. While a TDM program would be required to be prepared and implemented pursuant to City
ordinance, it cannot be demonstrated that the required TDM program would reduce freeway ramp traffic
by the amount necessary to reduce the project's contribution to a significant cumulative impact to a less -
than- cumulatively considerable level. The cumulative impact would remain significant and the project's
contribution would remain cumulatively considerable.
C -TR -21 (Freeway Ramps): Phase 1 or project buildout would add traffic volumes which would cause
total traffic to exceed capacity and therefore would contribute considerably to the significant cumulative
impact on the southbound U.S. 101 off -ramp from Produce Avenue during the AM peak hour in 2040
without the project. While a TDM program would be required to be prepared and implemented pursuant
to City ordinance, it cannot be demonstrated that the required TDM program would reduce freeway ramp
traffic by the amount necessary to reduce the project's contribution to a significant cumulative impact to a
less- than - cumulatively considerable level. The cumulative impact would remain significant and the
project's contribution would remain cumulatively considerable.
6.4 Significant Irreversible Environmental Changes
In accordance with Section 21100(b)(2)(B) of CEQA, and Section 15126.2(c) of the CEQA Guidelines,
an EIR must identify any significant irreversible environmental changes that could result from
implementation of the proposed project. The EIR is required to consider whether "uses of nonrenewable
resources during the initial and continued phases of the project may be irreversible since a large
commitment of such resources makes removal or non -use thereafter unlikely" (CEQA Guidelines Section
15126.2(c)). "Nonrenewable resource" refers to the physical features of the natural environment, such as
land, waterways, etc. This may include current or future uses of non - renewable resources and secondary
or growth- inducing impacts that commit future generations to similar uses. According to the CEQA
Guidelines, irretrievable commitments of resources should be evaluated to ensure that such current
consumption is justified.
Chapter 4, Environmental Setting, Impacts, and Mitigation, discusses topics that could potentially be
affected by irreversible environmental impacts, such as agriculture and forestry, biological resources,
cultural resources, hydrology, and population and housing. None of these environmental topics were
found to have significant impacts as a result of the proposed project.
No significant irreversible environmental damage related to hazardous materials is anticipated to occur
with implementation of the proposed project. Compliance with federal, state, and local regulations related
to office /research and development (R &D) uses identified in Section 4.10.5, Hazards and Hazardous
201 Haskins Way Project Draft EIR 6.9 October 12, 2018
6. Other CEQA Considerations
Materials, would ensure that the possibility that hazardous substances from the demolition, construction,
and operation of proposed project would not cause significant and unavoidable environmental damage.
The proposed project would involve excavation of soils for grading and soil remediation. Grading would
be required for general site preparation and design of on -site stormwater flows, but the proposed project
would not substantially raise or lower the existing grade. However, grading would not be excessive or
greater than what is necessary to achieve stormwater goals.
Construction and implementation of the proposed project would not result in a large commitment of
natural resources, require highway improvements to previously inaccessible areas; or irreversible damage
due to environmental accidents. No other irreversible permanent changes such as those that might result
from construction of a large -scale mining project, hydroelectric dam, or other industrial project would
result from development of the proposed project.
6.4.1 Energy and Consumption of Nonrenewable Resources
Section 21100(b)(3) of CEQA requires that EIRs include a discussion of the potential energy impacts of
proposed projects, with particular emphasis on avoiding or reducing any inefficient, wasteful, and
unnecessary consumption of energy. Implementation of the proposed project would commit future
generations to an irreversible commitment of energy resources in the form of usage of nonrenewable
fossil fuels due to vehicle and equipment use during demolition, construction, and operation of the
proposed project.
ENERGY AND NATURAL GAS AND LOCAL ENERGY SUPPLY
The estimated annual electricity demand associated with occupancy and operation of Phase 1 is
approximately 4.22 million kilowatt hours per year (MM kWh/yr) and 4.28 MM kWh/yr for project
buildout .Estimated natural gas demand associated with operation occupancy of Phase 1 is 6.26 billion
British thermal units (BBTU /yr) (62,598 therms) and 6.35 BBTU /yr (63,503 therms) for project buildout.
Electrical and natural gas service to the project site would be adequately provided by Pacific Gas and
Electric Company (PG &E).'
The proposed project would comply with CALGreen requirements for energy efficiency in new buildings
and would also be designed to meet Leadership in Energy and Environmental Design (LEED) v4
standards. For both electricity and natural gas, compared to the mix of other existing development in
South San Francisco and the region, compliance with the latest CALGreen and other requirements would
ensure that the proposed project would be more efficient than all but recent buildings built to the same
requirements, or buildings for which owners decided to exceed efficiency requirements.
1 Pacific Gas and Electric Company, 2018. 201 Haskins Way Will -Serve Letter from Tosin Ladeinde, Industrial Power Engineer,
September 5, 2018.
201 Haskins Way Project Draft EIR 6.10 October 12, 2018
6. Other CEQA Considerations
TRANSPORTATION FUEL DEMAND
Comparison of transportation fuel use and efficiency between the proposed project and the mix of other
existing development in the region is speculative; however, the proposed project includes a TDM plan to
discourage single- occupancy vehicle trips and encourage transit and other modes of transportation.
Table 6.1, Approximate Transportation Fuel Demand for Phase 1 and Project Buildout provides
estimated transportation- related gasoline and diesel demand for the proposed project.'
Table 6.1: Approximate Transportation Fuel Demand for Phase 1 and Project Buildout
Estimated Gasoline Demand Estimated Diesel Demand
(gallons / year) (gallons / year)
Phase 1
Phase 1 Total 36,488 6,420
Project Buildout
Project Buildout Total 37,207 6,794
Notes: CalEEMod estimates vehicle miles traveled (VMT) based on building square footage by type of use. Vehicle fuel efficiency figures (gasoline,
electric hybrid, electric only, and diesel) are rough approximations based on the EMFAC2014 model run.
Sources: Vehicle Miles Traveled from SWCA, CalEEMod model run (split is 88.9% gasoline and hybrid gasoline - electric, 6.4% electric -only, and 4.6%
diesel); (2) Composite MPG from ESA, EMFAC2014 (0.0.7) Emissions Inventory, San Francisco County, Calendar Year 2030 (annual), EMFAC2011
Vehicle Classification Categories.
Under the proposed project, the project applicant would develop and implement a TDM Plan and
pedestrian- and bicycle - serving features to achieve a 35 percent minimum alternative mode use as
required by the Zoning Ordinance. These design features would include secure covered bicycle parking
proportional to development as required by City bicycle parking standards. The TDM Plan would include
a parking reduction from the required parking standard of 1 space per 350 square feet of office use as
provided by the zoning ordinance for a Business Technology Park District, and would also include
electric vehicle parking spaces and charging stations. The proposed project would also provide designated
carpool and vanpool parking. The project sponsor would coordinate with the City and other private
landowners to continue and expand the Commute.org shuttle bus program to serve employees of the new
research and development office uses. TDM Plan measures and design features would be subject to
review and approval by the City Council. The proposed project TDM Plan would be subject to an annual
survey and triennial report to monitor and enforce alternative mode use goals. For these reasons, the
proposed project would have a less- than - significant impact on the use of transportation fuel energy and
would not result in the use of large amounts or in the wasteful use of energy as a result of operational
transportation.
2 Diesel fuel would also be used for periodic testing and infrequent running of emergency generators. Testing is generally limited
to 50 hours or less per year for each generator under BAAQMD air permits. It is difficult to forecast emergency use, as the events
are typically rare.
201 Haskins Way Project Draft EIR 6.11 October 12, 2018
6. Other CEQA Considerations
OTHER NONRENEWABLE RESOURCES
Consumption of nonrenewable resources includes increased energy consumption, conversion of
agricultural lands to urban uses, and loss of access to mineral reserves. No agricultural lands would be
converted and no access to mining reserves would be lost with construction of the proposed project.
Resources consumed during demolition, construction, and operation would include lumber, concrete,
gravel, asphalt, masonry, metals, and water. Similar to the existing uses on the project site, the proposed
project would irreversibly use water and solid waste landfill resources. However, the proposed project
would not involve a large commitment of resources relative to existing conditions and also relative to
supply, nor would it consume any of those resources wastefully.
The proposed project would introduce new office /R &D uses to the project site to serve existing and
projected demand for such uses as described in Section 3.1.1, Project Objectives, pp. 3.2 -3.3, Section 4.7,
Land Use, pp. 4.7.4- 4.7.6, and Section 4.11.6, Population and Housing, pp. 4.11.42- 4.11.45. The project
site is fully served by existing utilities and construction of new utility infrastructure would not be
necessary. The proposed project would not involve new or expanded water supply resources or
entitlements. Section 4. 10, Utilities and Service Systems, describes the water supply and demand aspects
of the proposed project. The proposed project would include required water conservation practices to
reduce the amount of water used. Water - efficient plumbing fixtures would be installed throughout the
new and renovated buildings, pursuant to CALGreen and building code requirements. Landscaping and
street trees would be water efficient. Therefore, the proposed project would include the application of
required water conservation measures and would be in conformance with policies addressing water
efficiency. Compared to the mix of other existing development in South San Francisco and the region,
compliance with the latest CALGreen and other requirements would ensure that the proposed project
would be more water efficient than all but recent buildings built to the same requirements, or buildings for
which owners decided to exceed efficiency requirements. For these reasons, the proposed project would
not result in the wasteful use of water.
6.5 Growth - Inducing Impacts
As required by Section 15126.2(d) of the CEQA Guidelines, an EIR must consider the ways in which the
proposed project could directly or indirectly foster economic or population growth, or the construction of
additional housing, either directly or indirectly, in the surrounding environment. Growth- inducing
impacts can result from the elimination of obstacles to growth; through increased stimulation of economic
activity that would, in turn, generate increased employment or demand for housing and public services; or
from the implementation of policies or measures that do not effectively minimize premature or unplanned
growth.
Growth- inducing impacts such as those associated with job increases that might affect housing and retail
demand in other areas over an extended time period are difficult to assess with precision, since future
economic and population trends may be influenced by unforeseeable events and business development
cycles. Moreover, long -term changes in economic and population growth are often regional in scope; they
201 Haskins Way Project Draft EIR 6.12 October 12, 2018
6. Other CEQA Considerations
are not influenced solely by changes in policies or specific development projects. Business trends are
influenced by economic conditions throughout the state and country as well as around the world.
Another consideration is that the creation of growth- inducing potential does not automatically lead to
growth. Growth occurs through capital investment in new economic opportunities by the private and/or
public sector. Investment patterns reflect, in turn, the desires of investors to mobilize and allocate their
resources to development in particular localities and regions. A combination of these and other pressures
serve to fashion policy. The regulatory authority of local governments serves to mediate the growth -
inducing potential or pressure created by a project or plan. Despite these limitations on the analysis, it is
still possible to qualitatively assess the general potential growth- inducing impacts of the proposed project.
6.5.1 Projected Growth
Section 4.10.7, Population and Housing, discussed population and employment growth as a result of the
proposed project and made the following findings. The proposed project does not include any new
housing units in either Phase 1 or project buildout and would not directly induce population growth. The
proposed project would construct new office/R &D uses on an existing infill site in an urbanized area.
Development of infrastructure could remove obstacles to population growth if it would allow for
development in an area that was not previously considered feasible for development because of
infrastructure limitations. The proposed project would not include the extension of area roadways or
expansion of infrastructure to areas lacking existing development. No indirect impacts related to
population growth as a result of expansion of infrastructure would occur.
The displacement of existing light industrial uses and employees, and the new employees introduced as a
result of new Business Technology Park land uses would, on the whole, increase the number of
employees in the City and the East of 101 Area. The existing light industrial uses support a total of
approximately 191 employees who would vacate the project site and be displaced or relocated. The 400-
450 East Jamie Court site hosts an existing business and technology park use that would remain under
both Phase 1 development and project buildout. The estimated number of jobs provided by the proposed
project is summarized in Table 4.11.1: Proposed Project Employment, on p. 4.11.44. The new 748
employees introduced in the City during Phase 1 and 1,506 during project buildout could result in an
increase in demand for housing. The City is primarily built out and any housing constructed within the
City limits would most likely be infill housing. South San Francisco is a job center that, overall, imports
employees and exports housing demand. Implementation of Phase 1 development or project buildout
would result in an increased unfavorable jobs/housing ratio in the City. The City of South San Francisco
General Plan (General Plan) Land Use Element, as amended in 2011, projects an employment of 80,600
jobs in the City by 2035 at buildout of the General Plan.3 The proposed project employees introduced
during Phase 1 and project buildout would represent 2.5 percent and 5.2 percent of the total job growth in
the City at General Plan buildout. The proposed project's new employees would not result in substantial
unplanned employment growth.
3 General Plan, Chapter 2, Table 2.4 -4, p. 2 -35.
201 Haskins Way Project Draft EIR 6.13 October 12, 2018
6. Other CEQA Considerations
The proposed project would create the need for up to 519 new units of housing in Phase 1 and 1,046 new
units of housing at project buildout. Although it is likely that some of the new employees on the project
site would be existing residents in the City or in the region, the employment increase would result in
indirect growth that may not be accommodated by existing or projected housing developments for the
City. However, the City recognizes that much of its land area, including the East of 101 Area, is not well
suited for housing development due to existing land use conflicts, including proximity to the San
Francisco International Airport and the historic and existing industrial uses of the East of 101 Area, as
well as the emerging office /R &D uses in the area. In that light, the City relies upon the greater San
Francisco Bay Area's regional jobs- housing balance.
If the project application is not deemed complete by January 1, 2019, the proposed project would require
payment of the commercial linkage fee under Chapter 8.69 of the Municipal Code which would
contribute to the development of affordable housing to serve the indirect demand generated by
commercial development. Although affordable housing could eventually be developed through this fee,
the resulting number of residential units would be small in relation to the total number of households in
the City. Therefore, any indirect population growth impacts would be less than significant, as described in
Section 4.11, Less - Than - Significant Impacts, in Section 4.11.6, Population and Housing.
Overall, the proposed project would be an appropriate land use for the project site's limitations, and the
job growth that would occur under the proposed project would be within the projected employment
growth of the City. The proposed project would not induce direct or indirect population growth.
6.6 Areas of Known Controversy and Issues To Be
Resolved
The Planning Division published a Notice of Preparation of an EIR (NOP) on April 18, 2018, announcing
its intent to prepare and distribute an EIR (the NOP is included in this EIR as Appendix A).The public
review period began on April 18, 2018, and ended on May 18, 2018. During the NOP public review
period, four comment letters were submitted to the Planning Division by public agencies and other
interested parties. On May 3, 2018, a public scoping meeting was held and no speakers contributed
comments at this meeting.
Comments on the NOP raised the following issues:
Transportation and Circulation
• Compliance with the San Mateo County Congestion Management Program (CMP) Traffic Impact
Analysis (TIA) Policy and Land Use Guidelines as provided by the City /County Association of
Governments (C /CAG), including preparation of a forecast and discussion of the expected
impacts of the project on the Congestion Management Program roadway network, the immediate
project area, and other areas.
• Project - related traffic generation and mitigation measures should the project generate a net of 100
or more peak -hour trips on the CMP roadway network. Inclusion of potential mitigation strategies
documented in the C /CAG Land Use Guidelines policy such as reducing project scope, building
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6. Other CEQA Considerations
roadway and /or transit improvements, collecting traffic mitigation fees, and requiring project
sponsors to implement TDM programs.
• C /CAG consultation regarding the scope and parameters of the analysis, and C /CAG review and
comment on the TIA, EIR, and TDM plan.
• Project - related construction traffic impacts on the existing 451 East Jamie Court uses, and
mitigation measures to minimize construction traffic during construction of the 201 Haskins Way
Building and parking garage.
• Traffic and circulation impacts on Haskins Way, East Grand Avenue, Littlefield Avenue, and the
northbound U.S. 101 on -ramp from East Grand Avenue during PM peak hours as a result of
operation of the project, and mitigation measures to improve traffic and circulation.
• Analysis of implementing a TDM program as mitigation for VMT impacts, including design
features, programs, and monitoring.
• Cumulative regional transportation impacts and mitigation through fair share contributions
toward multi -modal and regional transit improvements.
• Project - related impacts on transit, pedestrians, bicycles, and disabled travelers, including analysis
of mitigation for increased VMT, and design features that encourage the use of alternative
transportation modes including transit and shuttles, such as improvements to shelters or benches,
as well as pedestrian and bicycle design features.
Project Description
• Confirmation of where the project would occur within the San Francisco Bay (Bay) or the San
Francisco Bay Conservation and Development Commission (BCDC) 100 -foot shoreline
jurisdictional band.
• Confirmation of the proposed public access to the Bay Trail and Bay shoreline per existing
BCDC permits on -site and BCDC public access requirements.
Greenhouse Gas Emissions
• Analysis of implementing a TDM program as mitigation for greenhouse gas emission impacts,
including design features, programs, and monitoring.
Noise
• Project - related construction noise impacts on the existing 451 East Jamie Court uses and
mitigation measures to minimize construction noise during construction of the 201 Haskins Way
Building and parking garage.
Land Use
• Project - related impacts on the continuation of existing business operations of parcels within the
project site, including future property and building maintenance under the proposed rezoning.
• Project - related impacts on the potential for future development of parcels in the Phase 2 area as
separate and individual parcels in compliance with the proposed rezoning, and the implications of
development alternatives for each parcel not currently owned by the developer.
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6. Other CEQA Considerations
Recreation
• Project - related impacts on shoreline access due to an increased on -site worker population, and
whether the proposed public access areas would be adequate to accommodate these additional
users, in recognition of existing BCDC permits and BCDC public access requirements.
Aesthetics
• Project - related impacts on scenic views of the Bay in consideration of the height of the proposed
buildings and parking structure.
• Project - related shadow on the existing 451 East Jamie Court Building and existing and planned
roof solar photovoltaic systems.
• Project- related impacts on existing wind hazards and whether the project includes mitigation
measures to reduce project- related wind impacts.
Hydrology and Water Quality
• Whether project impacts related to sea level rise would occur on transportation facilities in the
project area due to higher water levels, including increased erosion, changing environmental
characteristics that affect material durability, increased groundwater levels, change in sediment
movement along shorelines, and soil pore pressure at dikes and levees on which transportation
facilities are constructed.
6.6.1 Issues to be Resolved under Design Review
The City does not have codified standards or thresholds regarding wind and shadow impacts and these
issues are not treated as environmental impacts for the purposes of CEQA. However, a discussion of these
issues in relation to the design review standards set forth under the City Municipal Code is provided in
response to the NOP comment and pursuant to CEQA Guidelines Section 15128 in Section 4.11, Less -
than- Significant Impacts, under "Aesthetics"
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