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Genentech Master Plan Update, Draft EIR Page 4-1
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Approach to the Analysis
New Program EIR
Master Plans for the Genentech Campus have been the subject to two prior environmental documents: the
2007 Master EIR for the Genentech Corporate Facilities Research & Development Overlay District Expansion
and Master Plan Update Project, and the 2012 Supplemental Master EIR. Additional environmental review
was completed in 2002 for the Britannia East Grand Project EIR, addressing a separate development project
that has since been incorporated into the Genentech Campus. However, the City of South San Francisco has
determined that this environmental document is to be a new Program EIR, rather than an updated Master
EIR or a second Supplemental Master EIR. As such, each of the following environmental topics is fully
addressed in this document, beginning at Chapter 5:
● Aesthetics
● Air Quality
● Biological Resources
● Cultural and Historic Resources
● Geology and Soils
● Greenhouse Gas Emissions and Climate Change
● Hazards and Hazardous Materials
● Hydrology and Water Quality
● Land Use and Planning
● Noise
● Population, Housing and Employment
● Public Services and Recreation
● Transportation, Circulation and Parking
● Utilities
This new Program EIR is necessary to address changes that are part of the current Master Plan Update (e.g.,
increasing the maximum development potential on the Campus to 9 million square feet). This EIR also
addresses changes in baseline conditions, changes regulations, and other new information that has occurred
since certification of the prior 2007 MEIR and 2012 SMEIR.
The following chapters of this EIR provide information on the Project site’s existing conditions, the type and
magnitude of the Project’s potential environmental impacts, the applicable regulatory requirements that will
reduce or avoid environmental impacts, and feasible mitigation measures (as may be needed) to further
reduce or avoid such impacts.
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The existing settings for each chapter define the environmental conditions as exist on and near the Project
site. For certain environmental topics, the existing conditions and analyses addresses a larger area than is
defined by the boundaries of the Project Area, where appropriate to address resource topics not confined to
the site. In most chapters of this EIR, these existing conditions are as existed at the time of issuance of the
Notice of Preparation of this EIR (May 2017). For select chapters (e.g., the Project Description and the Land
Use chapter), these existing conditions reflect Campus development as existed at the end of 2017, to
appropriately capture the most recent development projects on the Campus.
Project impacts are defined as the Project’s effect on the existing physical environment. The purpose of these
sections of the document is to inform readers of the type and magnitude of the Project’s impacts on the
existing environment. A significant effect is defined by 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. An economic or social change by itself shall not be considered a significant effect on the
environment. A social or economic change related to a physical change may be considered in determining
whether the physical change is significant.” Additional information (not pursuant to CEQA thresholds) is
provided pertaining to certain conditions of the surrounding environment that may adversely affect the
Project.
EIR Baseline
The Notice of Preparation (NOP) for this Draft EIR was issued in May of 2017. CEQA Guidelines Section 15125
provides the following guidance for establishing the EIR baseline, “An EIR must include a description of the
physical environmental conditions in the vicinity of the project. This environmental setting will normally
constitute the baseline physical conditions by which a lead agency determines whether an impact is
significant. Generally, the lead agency should describe physical environmental conditions as they exist at the
time the Notice of Preparation is published. Where existing conditions change or fluctuate over time, and
where necessary to provide the most accurate picture . . . of the project’s impacts, a lead agency may define
existing conditions by referencing historic conditions or conditions expected when the project becomes
operational, or both, as supported with substantial evidence.”
In May of 2017, the Genentech Campus contained approximately 4,715,000 square feet of completed and
occupied building space. Consistent with CEQA Guidelines, this amount of building space represents the EIR
baseline of development in the Project site. This EIR baseline also corresponds with detailed data about
buildings on the Campus that was available from Genentech’s end of year 2016 Annual Report. However, as
an active and ongoing facility, new development within the Campus has occurred during the time between
issuance of the NOP and the publication date of this Draft EIR, including:
● The new Employee Center in the Upper Campus has completed construction (which was underway at
the time of the NOP) and is now open and operational.
● The building known as TO6 (formerly located between DNA Way and Allerton Avenue) has been
demolished, and Genentech’s new Cabot 2nd Generation childcare center at 342 Allerton has been
constructed on that site and is now operational.
● The building known as B54 (formerly located on the east side of Allerton Avenue near Forbes
Boulevard) has been demolished and replaced by a Genenbus Shuttle & Bus Depot Area with an
associated Operations Center (B59).
● A new building known as B40 (or the Connector Building) has been approved and is currently under
construction on the South Campus.
Each of these new developments was approved by the City pursuant to the still-effective 2007 Master Plan.
Although not part of the EIR baseline conditions, these new buildings are components of the Master Plan
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Genentech Master Plan Update, Draft EIR Page 4-3
Update’s buildout assumptions, and (except for the childcare facility, which is exempt) count toward the 9
million square-foot buildout potential as proposed under the Master Plan Update.1 The current (as of
publication of this Draft EIR) amount of completed and occupied building space on the Campus is
approximately 4.80 million square feet (inclusive of 124,000 square feet of childcare facility space that does
not count against FAR limitations), plus 166,000 square feet of building space under construction (B40).
Types of Environmental Impact Analyses
As of the baseline for this analysis, Genentech has approximately 4.7 million square feet of building space
within its Campus boundaries. The current Master Plan Update (the Project) proposes to increase
development within the Genentech Campus to just over 9 million square feet, or approximately 4.3 million
square feet of net new building space. The 9 million square-foot buildout potential of the Master Plan Update
establishes an upper limit on development that Genentech considers large enough to accommodate mid- to
long-term growth, but not specifically tied to buildout year.
Qualitative, Location-based Analysis
The Project Description identifies the most likely locations where new development or redevelopment will
occur within the Campus. These locations are identified in the Master Plan Update/Project Description as
Opportunity Sites. These Opportunity Sites generally include:
● development of new building space on existing surface parking lots (combined with a new structured
parking strategy)
● redevelopment of older, less efficient buildings with new buildings that are larger, taller and more
architecturally and functionally complex
● infill development at locations within the Campus where vacant or under-used infill sites exist, and
● new buildings and/or parking structures constructed into existing hillsides within the Campus, such
that these new buildings can also serve as “bridges” that link together the upper and lower
elevations of the Campus
These Opportunity Sites have been used to conduct analyses for a number of location-based environmental
topics (e.g., aesthetics, biological resources, cultural and historic resources, geology and soils, hazards, and
hydrology). These analyses are qualitative, providing an indication of whether new development (irrespective
of whether the development is an office, a lab or a parking garage) that may occur at these Opportunity Sites
would adversely affect any of these resources.
Quantitative, Aggregate Development Analysis
The Project Description also provides one potential detailed buildout scenario that meets the goals of the
Master Plan Update, and is used for quantitative analytical purposes for this EIR. This Project Description
scenario represents one scenario of the maximum development potential that could occur within the
Campus (i.e. Project Area) pursuant to the Master Plan Update, based on an estimate of projected
employment growth and future building space needs by land use type and/or function. This estimate includes
a forecast growth 4.3 million square feet of net new development, including:
● approximately 2.4 million square feet of net new office space
1 Pursuant to East of 101 Area Plan Policy LU-26, childcare facilities may be built as part of a commercial or industrial
development and shall not be counted as part of the Floor Area Ratio (FAR) of the project.
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Page 4-4 Genentech Master Plan Update, Draft EIR
● approximately 1.6 million square feet of new lab space, and
● approximately 0.3 million square feet of various types of employee amenity space
This scenario also assumes a net retention of the nearly 1.3 million square feet of manufacturing, warehouse
and distribution building space that is on Campus today, although that existing space may be reconfigured
from its current locations or building envelopes as part of new development activity.
This detailed buildout scenario has been used to generate employment estimates and land use projections
that drive analyses for a number of aggregate growth-based environmental topics (e.g., air quality emissions,
greenhouse gas emissions, land use and planning, noise sensitivity and noise generation, employment, public
services, transportation and utilities). These analyses are quantitative, providing an indication of whether
new growth within the Campus would have an adverse effect on any of these resource categories.
Mitigation Measures and Regulatory Requirements
CEQA Guidelines Section 15126.4 requires that and EIR, “shall describe feasible measures which could
minimize significant adverse impacts.” This section further provides that the discussion of mitigation
measures shall, “distinguish between the measures which are proposed by project proponents to be included
in the project, and other measures that . . . the lead agency determines could reasonably be expected to
reduce adverse impacts if required as conditions of approving the project.” Recent (2019) additions to CEQA
Guidelines Section 15126.4(a)(1)(B), as underlined below, specifically provide that:
“Formulation of mitigation measures shall not be deferred until some future time. The specific details of a
mitigation measure, however, may be developed after project approval when it is impractical or infeasible
to include those details during the project’s environmental review provided that the agency:
(1) commits itself to the mitigation,
(2) adopts specific performance standards the mitigation will achieve, and
(3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard and
that will considered, analyzed, and potentially incorporated in the mitigation measure.
Compliance with a regulatory permit or other similar process may be identified as mitigation if
compliance would result in implementation of measures that would be reasonably expected, based on
substantial evidence in the record, to reduce the significant impact to the specified performance
standards.”
These recent changes to CEQA Guidelines were intended to implement a long line of case law from the past
20 years regarding, among other matters, the standards for deferred mitigation under CEQA. These case law
proceedings include but are not limited to:
● Tracy First v. City of Tracy, 177 Cal. App. 4th 912 (2009): The Court upheld energy impact mitigation
measures that required compliance with the California Building Energy Efficiency Standards designed
to promote energy efficiency. The court held that compliance with statutory provisions designed to
mitigate the very impact addressed in the EIR provide substantial evidence that such impacts would
be reduced to a less than significant level.
● Oakland Heritage Alliance v. City of Oakland, 195 Cal. App. 4th 884 (Cal. Ct. App. 2011): The Court
rejected the argument that the City did not have substantial evidence to support findings that
mitigation measures requiring compliance with state and local code requirements reduced seismic
impacts to a less-than-significant level. The court, in rejecting this argument, found that “compliance
with the Building Code and other regulatory provisions, in conjunction with the detailed geotechnical
investigation, provided substantial evidence that the mitigation measures would reduce seismic
impacts to a less than significant level.”
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Genentech Master Plan Update, Draft EIR Page 4-5
● Oakland Heritage Alliance v. City of Oakland, 195 Cal. App. 4th 884 (Cal. Ct. App. 2011): The Court
rejected the argument that the City did not have substantial evidence to support findings that
mitigation measures requiring compliance with state and local code requirements reduced seismic
impacts to a less-than-significant level. The court, in rejecting this argument, found that “compliance
with the Building Code and other regulatory provisions, in conjunction with the detailed geotechnical
investigation, provided substantial evidence that the mitigation measures would reduce seismic
impacts to a less than significant level.”
● Citizens Opposing A Dangerous Environment v. County of Kern, 228 Cal.App.4th 360 (5th Dist. July 25,
2014): As the court observed, “A condition requiring compliance with regulations is a common and
reasonable mitigation measure, and may be proper where it is reasonable to expect compliance.” In
this case, the Court of Appeal concluded that reliance on compliance with FAA regulations as a
mitigation measure to reduce impacts to air safety to less than significant levels is appropriate under
CEQA.
Accordingly, this EIR identifies a range of feasible mitigation measures that will minimize significant adverse
impacts of the Project. These mitigation measures include measures that are proposed by, and will be
implemented by Genentech as the Project applicant (e.g., Genentech’s voluntary partnership in the Climate
Action Reserve and Cap-and-Trade program to offset GHG emissions). These mitigation measures also require
compliance with regulatory permits or other regulatory processes, where compliance with performance
standards as specified in those regulations would be reasonably expected to reduce or avoid significant
impacts (e.g., compliance with FAA building height criteria to avoid flight safety hazards). Addition mitigation
measures as identified by the City of South San Francisco (as lead agency for this EIR) are also included,
where the City has determined that such additional mitigation measures are warranted, would be necessary
to reduce or avoid adverse environmental impacts, or would provide necessary detail or performance
standards as required by the City. Each of these types of mitigation measures are specifically identified
throughout this EIR, and will be required as conditions of approving the Project.
Cumulative Analysis Assumptions
Each of the following topic-area chapters of this EIR conclude with an analysis of cumulative effects.
Depending on the topic, the cumulative context varies with the geography of cumulative implications. For
example, cumulative effects related to climate change are global in scale, and cumulative effects related to
air quality emissions of criteria air pollutants affect the entire San Francisco Air Basin. Conversely, some
cumulative effects are local in nature, such as cumulative water quality effects on those waters that are
tributary to the Project Area. However, the majority of cumulative effects discussed in this EIR (specifically
including traffic) are based on anticipated cumulative growth and development within the East of 101 Area of
South San Francisco.
The East of 101 Area has, and continues to emerge as a major biotechnology hub within the region.
Genentech is the largest biotechnology company in the area but, according to information presented on the
City website, there are over 200 biotechnology companies and approximately 11.5-million square feet of
biotechnology building space within the approximately 500-acre East of 101 Area.2 The growth of the
biotechnology industry has significantly changed land use in the East of 101 Area, which had historically been
an area of heavy industry, manufacturing facilities and warehousing. New land uses in the East of 101 area
are now principally modern, multi-story office and research and development (R&D) buildings, many in
campus-type settings. The City’s General Plan and East of 101 Area Plan, as well as on-going city economic
2 http://www.ssf.net/our-city/biotech/biotech-in-ssf
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development efforts, forecast a continuation of economic development activity in the East of 101 Area that
continues this trend in growth of the biotechnology and technology industries.
In 2017, the City initiated an update to its transportation planning for the East of 101 area, including an
update to the East of 101 Traffic Model. This update was intended to account for all recently approved new
development in the East of 101 area, and included a projection of cumulative buildout potential. Cumulative
buildout was projected to amount to approximately 33.4 million square feet of non-residential building
space, or an increase of nearly 12 million square feet over the 2016 baseline. In July of 2018, the City initiated
a further update to the East of 101 Traffic Model. Forecasts for year 2040 cumulative traffic demand
projections were estimated based on cumulative land use and trip generation assumptions. These cumulative
assumptions assumed no growth associated with the Genentech Campus. A summary of cumulative (without
Genentech) land use assumptions is provided in Table 4-1.
Table 4-1: 2016 Existing and 2040 Cumulative Baseline Land Use, East of 101 Area
Land Use
2016 Land Use
(square feet)
2040 Cumulative Land Use
(square feet)
Change per Cumulative Land
Use (square feet)
Commercial 609,000 1,248,000 639,000
Hotel 1,228,000 2,100,000 872,000
Industrial 7,560,000 7,591,000 31,000
Office/R&D 12,023,000 18,967,000 6,944,000
Other 40,000 487,000 447,000
Total 21,460,000 30,393,000 8,933,000
Note: Assumes 2016 baseline Genentech land use and no future Campus growth
Sources: City of South San Francisco Traffic Model, July 2018
As shown in Table 4-1, Tablethe total amount of non-residential land use within the East of 101 Area is
expected to increase by approximately 9 million square feet, from 21.5 million square feet as of 2016 to
approximately 30.4 million square feet by the 2040 cumulative horizon year. This cumulative growth
assumption also includes land use changes associated with the City of South San Francisco’s Downtown
Station Area Specific Plan to the west of US-101, including new housing and commercial development.
However, this cumulative growth assumption does not include any Genentech-related growth.
With the Project’s proposed increase in net new development of approximately 4.3 million square feet, total
cumulative growth in the East of 101 Area (also including the of Downtown Station Area Specific Plan) would
amount to approximately 13.2 million square feet of building space, resulting in a total of 34.7 million square
feet by the 2040 cumulative horizon year.
Project Proposal for Limits on Net New Traffic
As part of the Master Plan Update, Genentech is proposing to implement two strategies that work together
to limit the amount of traffic that may be generated at the Campus, irrespective of the land use mix and
ultimate buildout (in terms of total square feet or FAR). These strategies are a Trip Cap and an aggressive 50
percent TDM goal.
Trip Cap
The Trip Cap is a numeric limit on the net increase in traffic that can be generated at the Campus. The Trip
Cap applies irrespective of the amount of net new development, the types of land uses that occur within the
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Campus over time, or the effectiveness of TDM efforts. The definition of this Trip Cap is derived from the
prior 2007 Master EIR and the prior 2002 Britannia East Grand EIR. Those prior EIRs calculated the number of
total vehicle trips that would be generated during the morning commute period, concluding that buildout of
6.8 million square feet of building space would generate approximately 5,126 AM peak hour trips, as
indicated on Table 4-2.
Table 4-2: Increase in Single-Occupant Vehicle Trips as Calculated in the Prior Campus EIRs
Land Use 2007 Existing SF 2007 MEIR Buildout SF AM Trip Rate AM Trips at Buildout
Campus:
Office 1,008,801 2,629,395 0.95 2,498
Lab 970,173 2,002,482 0.59 1,181
Manufacturing 779,892 1,041,668 0.48 500
Amenity 69,500 322,000 0.0 0
Sub-Total 2,828,366 5,995,545 4,180
Britannia East Grand (South Campus) 804,530 1,037
Total: 6,800,075 5,126
Fehr & Peers, June 2018
The Trip Cap establishes the same number of total AM peak hour trips (5,216) calculated in these prior EIRs
as being generated by 6.8 million square feet of building space, but now applies that number of AM peak
hour trips as a limit for up to 9 million square feet of building space. This Trip Cap commitment is possible
based on a continuation and expansion of Genentech’s TDM program.
When the 2007 MEIR was prepared, the traffic analysis assumed (based on surveys available at that time)
that approximately 92 percent of all Genentech employees would commute via automobile and that
approximately 80 percent would commute via single-occupant vehicles, resulting in an assumed 20 percent
non single-occupant vehicle mode split. These assumptions were incorporated into the trip generation rates
used in the 2007 MEIR. However, during the past 11 years since certification of the 2007 MEIR, Genentech
has implemented the gRide program that has exceeded the expectations of the 2007 MEIR. Single-occupant
vehicle commuters now represent approximately 58 percent of all Genentech employees. Based on the
increased availability of private transit and other alternative-mode commute choices, only approximately
2,550 daily single-occupant vehicle trips (or approximately 60% of the total number of trips expected in the
2007 MEIR) currently arrive at the Campus, even though the current Campus contains approximately 80
percent of the MEIR’s assumed 6 million square foot buildout.
With approximately 2,550 daily single-occupant vehicle trips arriving at the Campus during the AM peak hour
commute period today, the Trip Cap limits net new trips generated by the Project to 2,667 more AM peak
hour trips. This Trip Cap would not be exceeded under any development scenario for many years, and not
until a substantial portion of the 9 million square-foot buildout potential is realized. It is intended as a
maximum not-to-exceed number of potential trips, and can easily be counted along the main ingress and
access points to the Campus.
50 Percent Transportation Demand Management (TDM) Rate
Working in tandem with the Trip Cap is Genentech’s Campus-wide TDM goal to achieve a 50 percent
reduction in drive-alone vehicle trips (or a minimum 50 percent alternative mode use), to be achieved by the
time of full buildout of the Master Plan Update. Pursuant to SSF Municipal Code section 20.400.003, those
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projects in the Business and Technology Park district at an FAR of between 0.51 and 0.69 (the Campus has a
current average FAR of 0.52) are required to achieve a 30 percent trip reduction. Those projects in the
Business and Technology Park district at an FAR of 0.81 to 1.0 (buildout of the Master Plan Update would
achieve an FAR of 1.0) are required to achieve a 35 percent trip reduction. Genentech’s proposed TDM
commitment of a 50 percent trip reduction rate substantially exceeds both of these Municipal Code trip
reduction requirements.
Currently, Genentech is operating a TDM program (known as gRide) that is achieving a Campus-wide trip
reduction rate of approximately 42 percent (already exceeding the City’s requirement). This program uses a
variety of strategies including but not limited to Genentech-provided Genenbuses, the on-Campus DNA
Shuttle system, private Genentech ferry service, and reimbursements for carpooling and public transit use by
employees. Genentech proposes to expand the capacity of its gRide program commensurate with new
development, and to increase program capacity and use incrementally over time, achieving the 50 percent
trip reduction goal prior to buildout.
As a means of tracking progress towards the 50% TDM commitment, Genentech proposes to measure TDM
performance relative to this goal at intervals that correspond with net new development milestones. The
proposed correspondence between TDM performance and net new development is as follows:
● Up to 5 million square feet of development on Campus: 40 percent TDM trip reductions Campus-
wide
● By 5 million square feet of development on Campus: 42 percent TDM trip reductions Campus-wide
● By 6 million square feet of development on Campus: 44 percent TDM trip reductions Campus-wide
● By 7 million square feet of development on Campus: 46 percent TDM trip reductions Campus-wide
● By 8 million square feet of development on Campus: 48 percent TDM trip reductions Campus-wide,
and
● By 9 million square feet of development on Campus (i.e., buildout): 50 percent TDM trip reductions
Campus-wide
Pursuant to SSF Municipal Code section 20.400.008, Genentech will continue to prepare annual reports on its
compliance with City-mandated TDM rates and its trip reduction plan. However, the relationship between
TDM rate and building square footage of development will only be reported at the specified development
intervals.
The increments of growth between monitoring and reporting periods toward the 50% goal are large enough
to accommodate expected fluctuations in TDM performance over time. New, currently unimagined TDM
strategies may be developed or invented over time, but it is likely that the more significant increments of
increased TDM performance will continue to correspond with major investments in Genentech’s transit fleet
(e.g., more Genenbuses and ferries) and, to a lesser extent, employee incentive programs. These investments
may not correspond with more frequent annual, or per development-project increments. Similarly, a TDM
rate improvement may lag behind the opening of a large new building, as the new square footage is
introduced all at once and TDM improvements occur more gradually.
The methodology for measuring TDM performance will be a series of cordon counts that count Genentech
employees as they arrive on Campus, and record their mode of transportation. Transit use data will also be
provided by the gRide Program for the same times and dates, used to validate the cordon count records for
transit mode share. This is the same methodology that has been used to generate Genentech’s prior annual
reports on Commuter Mode Share.
The TDM program works as an incentive for Genentech to realize the greatest development potential
permissible under the limits of the Trip Cap. The monitoring schedule is intended to provide the City and
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Genentech Master Plan Update, Draft EIR Page 4-9
Genentech with means for assessing how progress is being made toward the 50 percent trip reduction goal,
while allowing new development to occur as dictated by Genentech’s business needs, but regulated by the
Trip Cap.
Trip Cap and TDM Effectiveness
The Trip Cap and the TDM program work together, allowing for flexibility in the buildout of the Campus,
while also providing certainty about traffic growth. For example, if buildout of the Campus were to match
precisely to the land use mix assumed in the EIR Project Description, an approximately 47 percent TDM trip
reduction ratio would be required to meet the Trip Cap limit. If buildout of the Campus occurs in a different
manner that assumed in the EIR Project Description, the same Trip Cap limit would apply, but a higher (or
potentially lower) TDM ratio would be necessary to remain within the Trip Cap. Without the full effects of
TDM, buildout under the Trip Cap could be less than the 9 million square feet assumed. Only by increasing
TDM effectiveness (thereby lowering trips) can the development potential of the Campus be maximized.
Working together with the Trip Cap, the TDM program goal serves as an incentive for Genentech to realize
the greatest development potential for the Campus.
This EIR applies the Trip Cap limit as the metric for defining the maximum net new trips that can be
generated pursuant to the Project. The Trip Cap has been used to adjust the trip generation rates of the
Project that underlie calculations of intersection levels-of-service, vehicle miles travelled, mobile source of
GHG and air quality emissions, and traffic noise. If buildout of the Campus occurs in a different manner than
assumed in the EIR Project Description, the Trip Cap would apply and regulate (or restrict) the maximum
number of net new trips to that same Trip Cap limit.