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HomeMy WebLinkAbout04 - Approach to the Analysis Genentech Master Plan Update, Draft EIR Page 4-1 4 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. Chapter 4: Approach to the Analysis Page 4-2 Genentech Master Plan Update, Draft EIR 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 Chapter 4: Approach to the Analysis 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. Chapter 4: Approach to the Analysis 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.” Chapter 4: Approach to the Analysis 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 Chapter 4: Approach to the Analysis Page 4-6 Genentech Master Plan Update, Draft EIR 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 Chapter 4: Approach to the Analysis Genentech Master Plan Update, Draft EIR Page 4-7 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 Chapter 4: Approach to the Analysis Page 4-8 Genentech Master Plan Update, Draft EIR 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 Chapter 4: Approach to the Analysis 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.