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Genentech Master Plan Update, Draft EIR Page 6-1
6
Air Quality
This chapter of the Genentech Master Plan Update EIR evaluates the potential impacts of the Project related
to air quality. This chapter describes the existing air quality conditions and evaluates the extent to which air
quality conditions may be affected by development of the Master Plan Update as proposed. Setting and
regulatory information for air quality has been updated from that presented in the 2012 Supplemental MEIR
(SMEIR). Emissions estimates and analysis have been updated for this EIR using current data from the
following sources:
● Ramboll, Air Quality Technical Appendix, October 2018 (Appendix 6A)
● Ramboll, CalEEMod Output File for Construction (Appendix 6B)
● Ramboll, CalEEMod Output File for Project Operations (Appendix 6C)
● Genentech, inputs for air quality and greenhouse gas analyses (Appendix 6D)
● Ramboll, Analysis of Potential Health Impacts from Criteria Pollutants, May 2019 (Appendix 6E)
● BAAQMD, CEQA Air Quality Guidelines, May 2017
Environmental Setting
Climate and Air Pollution
The City of South San Francisco and the Project Area are located in San Mateo County, within the nine-county
San Francisco Bay Area Air Basin. Specifically, the Project Area is located within the Peninsula climatological
subregion of the Air Basin that extends from northwest of San Jose to the Golden Gate. The Santa Cruz
Mountains run up the center of the Peninsula, and tend to block the cool and foggy effects of the marine
layer experience in summer months along the coast. Two gaps in the Santa Cruz Mountains (the San Bruno
Gap extending from Fort Funston on the ocean to San Francisco International Airport, and the Crystal Springs
Gap between Half Moon Bay and San Carlos) permit cooler maritime air to pass across the mountains, and its
cooling effect is commonly seen in South San Francisco.
Annual average wind speeds range from five to 10 miles per hour throughout the Peninsula, with higher wind
speeds often found near the San Bruno Gap and the Crystal Springs Gap. Prevailing winds on the easterly side
of the Peninsula are generally from the west, although wind patterns are also influenced by local topographic
features.
The hills and mountains in the Air Basin contribute to high pollution potential in some areas. Inversion layers
affect air quality conditions because they influence the mixing depth for diluting air contaminants near the
ground. The highest air pollutant concentrations generally occur during inversions. Air pollution potential is
highest along the southeastern portion of the Peninsula, which is most protected from the high winds and
fog of the marine layer. Pollutant transport from upwind sites is common. In the southeastern portion of the
Peninsula climatological subregion, air pollutant emissions are relatively high due to motor vehicle traffic and
stationary sources.
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Stationary sources of air pollution include point and area sources. Point sources occur at an identified
location and are usually associated with manufacturing and industry. Area sources generally produce smaller
levels of emissions and these emissions are widely distributed. Examples of area sources include residential
and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills and consumer
products such as barbeque lighter fluid and hair spray. Mobile sources refer to emissions from motor
vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. Mobile
sources account for the majority of the air pollutant emissions within the Basin. Air pollutants can also be
generated by the natural environment such dust particles suspended in the air during high winds.
Air Quality Conditions and Pollutants
Criteria Pollutants
Ambient air quality standards have been established by State and federal environmental agencies for specific
air pollutants most pervasive in urban environments. These pollutants are referred to as criteria air pollutants
because the standards established for them were developed to meet specific health and welfare criteria set
forth in the enabling legislation. The criteria air pollutants include ozone, as modeled using the two major
ozone precursors: oxides of nitrogen (NOx) and reactive organic gases (ROGs), carbon monoxide (CO),
nitrogen dioxide (NO2), and suspended particulate matter (PM10 and PM2.5). Other criteria pollutants, such as
lead and sulfur dioxide (SO2), are primarily industrial pollutants that are emitted only in negligible quantities
by construction activities or traffic, and air quality standards for them are being met throughout the Bay
Area.
The Bay Area Air Quality Management District (BAAQMD) Air District maintains an air quality monitoring
networks consisting of over 30 stations distributed among the nine Bay Area counties. This network
measures concentrations of pollutants for which health-based ambient air quality standards have been set by
the U.S. Environmental Protection Agency and the California Air Resources Board. Pollutants measured by the
monitoring network include ground-level ozone, carbon monoxide, nitrogen oxides, sulfur dioxide/oxides,
particulate matter and hydrogen sulfide. Table 6-1 presents a summary of air quality conditions at the two
BAAQMD monitoring stations located closest to the Project Area – monitoring stations in San Francisco and
Redwood City, - indicating the number of days that measured air quality concentrations exceeded either
national or California standards for criteria pollutants. 1
As Table 6-1 indicates, ozone and fine particle pollution (PM2.5) are the major regional air pollutants of
concern in the San Francisco Bay Area. Ozone is primarily a problem in the summer, and fine particle
pollution in the winter. The year 2017 monitoring results for PM2.5, especially at stations in Napa, Sonoma
and Solano counties but also throughout the Bay Area, recorded the effects of smoke and ash from the
wildfires that occurred primarily in October of that year.
1 BAAQMD, Air Quality Standards and Attainment Status, available at http://www.baaqmd.gov/research-and-data/air-
quality-measurement/ambient-air-monitoring-network
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Table 6-1: Summary of Air Pollution Monitoring Data
Pollutant Standard Monitoring Site
Days Standard Exceeded
2014 2015 2016 2017
Ozone
State 1-hour
San Francisco 0 0 0 0
Redwood City 0 0 0 2
Total Bay Area 3 7 6 6
Federal 8-hour
San Francisco 0 0 0 0
Redwood City 0 1 0 2
Total Bay Area 5 12 15 6
State 8-hour
San Francisco 0 0 0 0
Redwood City 0 1 0 2
Total Bay Area 10 12 15 6
PM10
Federal 24-hour
San Francisco 0 0 0 0
Redwood City – – – -
Total Bay Area 0 0 0 0
State 24-hour
San Francisco 0 0 – 2
Redwood City – – – -
Total Bay Area 2 1 0 6
PM2.5 Federal 24-hour
San Francisco 0 0 0 7
Redwood City 0 0 0 6
Total Bay Area 3 9 0 18
Carbon Monoxide State/Federal 8-hour
San Francisco 0 0 0 0
Redwood City 0 0 0 0
Total Bay Area 0 0 0 0
Nitrogen Dioxide State/Federal 1-hour
San Francisco 0 0 0 0
Redwood City 0 0 0 0
Total Bay Area 0 1 0 1
San Francisco and Redwood City are the two active monitoring sites near the Project Area. Total Bay Area summarizes data from all Bay
Area Air Quality Management District monitoring stations.
PM10 and PM2.5 are measured every sixth day in San Francisco and other Bay Area sites, so the number of days exceeding the standard is
estimated.
While some stations also monitor SO2, there were no recorded instances of exceedances throughout the Bay Area during this period.
Source: Bay Area Air Quality Management District Air Quality Summary Reports, website accessed 9.26.18
Ozone
Ozone is a reactive pollutant, which is not emitted directly into the atmosphere, but is a secondary air
pollutant produced in the atmosphere through a complex series of photochemical reactions involving ROG
and NOx. ROG and NOx are known as precursor compounds of ozone. Motor vehicle exhaust and industrial
emissions, gasoline vapors, and chemical solvents are some of the major sources of ROG and NOx that help to
form ozone. Ozone is a regional air pollutant because it is formed downwind of sources of ROG and NOx
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under the influence of wind and sunlight. During summertime (particularly on hot, sunny days with little or
no wind), ozone levels are at their highest.
Short-term exposure to elevated concentrations of ozone is linked to such health effects as eye irritation and
breathing difficulties. Repeated exposure to ozone can make people more susceptible to respiratory
infections and aggravate pre-existing respiratory diseases. Long-term exposures to ozone can cause serious
respiratory illnesses. Ozone also damages trees and other natural vegetation, reduces agricultural
productivity, and causes deterioration of building materials, surface coatings, rubber, plastic products and
textiles.
The number of days the region experiences unhealthy ozone levels has fallen overall over the past few
decades. This improvement is due to the California Air Resources Board (CARB) regulations affecting motor
vehicle emissions and Bay Area Air Quality Management District (BAAQMD) regulations to reduce emissions
from industrial and commercial sources.
Carbon Monoxide
CO is an odorless and invisible gas. It is a non-reactive pollutant and a product of incomplete combustion of
gasoline in automobile engines. CO is a localized pollutant, and the highest concentrations are found near the
source. Ambient CO emissions generally follow the spatial and temporal distributions of vehicular traffic, and
concentrations are influenced by wind speed and atmospheric mixing. CO concentrations are highest in flat
areas on still winter nights, when temperature inversions trap the CO near the ground. When inhaled at high
concentrations, CO reduces the oxygen-carrying capacity of the blood, which, in turn, results in reduced
oxygen reaching parts of the body. Most of the Bay Area’s CO comes from on-road motor vehicles, although a
substantial amount also comes from burning wood in fireplaces.
Over the past 10 years, the Bay Area has not experienced any exceedances of either the national or the state
CO standard.2
Nitrogen Dioxide
The major health effect from exposure to high levels of NO2 is the risk of acute and chronic respiratory
disease. NO2 is a combustion by-product, but it can also form in the atmosphere by chemical reaction. NO2 is
a reddish-brown colored gas often observed during the same conditions that produce high levels of ozone
and can affect regional visibility. NO2 is one compound in a group of compounds consisting of NOx. As
described above, NOx is an ozone precursor compound.
Particulate Matter
Particulate matter includes dirt, dust, soot, smoke, and liquid droplets found in the air. Coarse particulate
matter, or PM10, refers to particles less than or equal to 10 microns in diameter (about one-seventh the
diameter of a human hair). PM10 is primarily composed of large particles from sources such as road dust,
residential wood burning, construction/demolition activities and emissions from on- and off-road engines.
Some sources of particulate matter, such as demolition and construction activities, are local in nature, while
others, such as vehicular traffic, have more of a regional effect because while larger particles do not travel
far, in the case of vehicle emissions, the source is moving. Fine particulate matter, or PM2.5, refers to particles
less than or equal to 2.5 microns in diameter, and contains particles formed in the air from primary gaseous
emissions. Examples include sulfates formed from SO2 emissions from power plants and industrial facilities,
nitrates formed from NOx emissions from power plants, automobiles, and other combustion sources, and
carbon formed from organic gas emissions from automobiles and industrial facilities.
2 Bay Area Air Quality Management District, Air Quality Summary Reports
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The Bay Area experiences its highest particulate matter concentrations in the winter, especially during
evening and night hours, due to the cool temperatures, low-wind speeds, low inversion layers and high
humidity. Specifically, PM2.5 is viewed as a significant component of the region’s total particulate matter
problem because the PM2.5 fraction of total particulate matter accounts for approximately 60 percent of the
PM10 during the winter and approximately 45 percent during the rest of the year. On days when the
particulate matter standards are exceeded, PM2.5 can account for as much as 90 percent of PM10.
Coarse and fine particulate matters are small enough to get into the lungs and can cause numerous health
problems, including respiratory conditions such as asthma and bronchitis, and heart and lung disease. People
with heart or lung disease, the elderly, and children are at highest risk from exposure to particulate matter.
Toxic Air Contaminants
Another group of substances found in ambient air is referred to as Hazardous Air Pollutants under the
Federal Clean Air Act, and Toxic Air Contaminants (TACs) under the California Clean Air Act. These
contaminants tend to be localized and are found in relatively low concentrations in ambient air. However,
they can result in adverse chronic health effects if exposure to low concentrations occurs for long periods.
They are regulated at the local, state and federal level. TACs may cause or contribute to an increase in
mortality or in serious illness, or that may pose a present or potential hazard to human health. TACs are less
pervasive in the urban atmosphere than criteria air pollutants, but are linked to short-term (acute) or long-
term (chronic and/or carcinogenic) adverse human health effects where they do occur.
For evaluation purposes, TACs are separated into carcinogens and non-carcinogens based on the nature of
the physiological effects associated with exposure to TACs. Carcinogens are assumed to have no safe
threshold below which health impacts would not occur. Cancer risk from carcinogens is expressed as excess
cancer cases per one million exposed individuals, typically over a lifetime of exposure. Non-carcinogens differ
in that there is a safe level in which it is generally assumed that no negative health impacts would occur.
These levels are determined on a pollutant-by-pollutant basis. There are many different types of TACs with
varying degrees of toxicity. TACs may also exist as particulate matter or as vapors or gases. Sources of TACs
include industrial processes, commercial operations (e.g., gasoline stations and dry cleaners), and motor
vehicle exhaust—particularly diesel-powered vehicles. Compared to other air toxics that CARB has identified
and controlled, diesel particulate matter (DPM) emissions are estimated to be responsible for about 70
percent of the total ambient air toxics risk statewide.
CARB has control measures for motor vehicles, consumer products and industrial source programs under
existing regulation, in development or under evaluation for most sources of TACs.
Diesel Particulate Matter
Diesel exhaust is the predominant TAC in urban air, and is estimated to represent about two-thirds of the
cancer risk from TACs (based on the statewide average), the majority of which, according to CARB, is a result
of Diesel Particulate Matter (DPM). The particles emitted by diesel engines are coated with other chemicals,
some of which, such as benzene and formaldehyde, have been previously identified as TACs by CARB, and are
listed as carcinogens either under State Proposition 65 or under the federal Hazardous Air Pollutants
programs. For this reason, CARB recommends utilizing DPM along with PM2.5 as an indicator for overall
emissions.
Health risks from DPM are highest in areas of concentrated emissions, such as near ports, rail yards,
freeways, or warehouse distribution centers. According to CARB, diesel engine emissions are responsible for
the majority of California’s known cancer risk from outdoor air pollutants. Those most vulnerable are children
whose lungs are still developing and the elderly who may have other serious health problems. Based on
numerous studies, CARB has also stated that DPM is a contributing factor for premature death from heart
and/or lung diseases. In addition, DPM reduces visibility and is a strong absorber of solar radiation that
contributes to global warming.
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According to CARB, levels of toxic air pollutants have decreased significantly with the adoption of airborne
toxic control measures, stringent vehicle standards, requirements for low emission vehicles, and cleaner
fuels. The risk from diesel particulate matter as determined by the CARB declined from 750 in one million in
1990, to 570 in one million in 1995. By 2000, the CARB estimated the average statewide cancer risk from
DPM at 540 in one million. Based on 2012 estimates of statewide exposure, DPM was estimated to increase
statewide cancer risk by 520 per million residents exposed over a lifetime. The calculated cancer risk value
from ambient exposure to DPM in the Bay Area can be compared against the lifetime probability of being
diagnosed with cancer in the United States from all causes. The lifetime probability of a cancer diagnosis in
the US is more than 40 percent (based on a sampling of 17 regions nationwide), or greater than 400,000 in
one million, according to the National Cancer Institute (National Cancer Institute, 2012).
Asbestos
Asbestos is also a TAC of concern, due primarily from demolition of older buildings and structures. Asbestos is
a fibrous mineral, which is both naturally occurring in ultramafic rock (a rock type commonly found in
California) and used as a processed component of building materials. Because asbestos has been proven to
cause serious adverse health effects, including asbestosis and lung cancer, it is strictly regulated based on its
natural widespread occurrence and its use as a building material.
Regulatory Framework
Federal Regulations
Federal Clean Air Act
The federal Clean Air Act, enacted largely in its current form in 1970 and amended in 1977 and 1990,
establishes the framework for federal air pollution control. The act directed the U.S. Environmental
Protection Agency (EPA) to establish the National Ambient Air Quality Standards (NAAQS) described in Table
6-1. An area that does not meet the federal standard for a pollutant is called a “nonattainment” area for that
pollutant. For federal nonattainment areas, the federal Clean Air Act requires states to develop and adopt
State Implementation Plans (SIPs), which are air quality plans showing how air quality standards will be
attained. The federal Clean Air Act Amendments of 1990 added requirements for states with nonattainment
areas to revise their SIPs to incorporate additional control measures to reduce air pollution.
The SIP is periodically modified to reflect the latest emissions inventories, planning documents, and rules and
regulations of the air basins as reported by their jurisdictional agencies. The EPA has responsibility to review
all State SIPs to determine conformation to the mandates of the Clean Air Act Amendments, and to
determine if implementation will achieve air quality goals. If the EPA determines a SIP to be inadequate, a
Federal Implementation Plan may be prepared for the nonattainment area that imposes additional control
measures. Failure to submit an approvable SIP or to implement the plan within the mandated timeframe may
result in sanctions being denied to transportation funding and stationary air pollution sources in the air basin.
In California, SIPs are prepared and adopted by the local or regional air districts (in the Bay Area, by the
BAAQMD) and are reviewed and submitted to the EPA by CARB.
Federal Hazardous Air Pollutant
The Clean Air Act Amendments required EPA to issue vehicle or fuel standards containing reasonable
requirements to control hazardous air pollutant emissions, applying at a minimum to benzene and
formaldehyde. Performance criteria were established to limit mobile source emissions of toxics, including
benzene, formaldehyde, and 1,3-butadiene. In addition, Section 219 of the Clean Air Act Amendments also
required the use of reformulated gasoline in selected U.S. cities (those with the most severe ozone
nonattainment conditions) to further reduce mobile-source emissions, including air toxics. To reduce
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emissions from on-road, heavy-duty diesel trucks, EPA established a series of increasingly strict emission
standards for new engines, starting in 1988. The EPA promulgated the final and cleanest standards with the
2001 Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements Rule,
more commonly known as the 2007 Highway Rule. This rule established a particulate matter emission
standard of 0.01 gram per horsepower-hour (g/hp-hr) for new vehicles beginning with model year 2007. NOx
and non-methane hydrocarbon standards of 0.20 g/hp-hr and 0.14 g/hp-hr, respectively, were phased in
together between 2007 and 2010.
Highway Diesel Fuel Sulfur Requirements
The 2007 Highway Rule also required refineries to begin producing highway diesel fuel that met a maximum
sulfur standard of 15 parts per million (ppm), known as Ultra Low Sulfur Diesel, by June 2006. All 2007 and
later model year diesel-fueled vehicles must be refueled with Ultra Low Sulfur Diesel. By integrating fuel
sulfur standards and advanced pollution control technologies, the 2007 Highway Rule reduces DPM and NOx
exhaust emissions of heavy-duty engines by more than 90 percent as compared to previous engine models.
In addition, Ultra Low Sulfur Diesel also enables emissions reductions from other diesel-powered highway
vehicles, including cars and sport utility vehicles, and light-duty trucks.
State Regulations
California Clean Air Act
The California Clean Air Act of 1988 focuses on attainment of the California Ambient Air Quality Standards
(CAAQS), which are more stringent than the comparable federal standards for certain pollutants and
averaging periods. Responsibility for achieving California standards is placed on the CARB and local air
pollution control districts through district-level management plans for air quality. The California Clean Air Act
requires designation of attainment and nonattainment areas with respect to CAAQS. The California Clean Air
Act also requires that local and regional air districts expeditiously adopt and prepare an attainment plan for
air quality if the district violates State air quality standards for CO, SO2, NO2 or ozone. No locally prepared
attainment plans are in place for areas that violate the State PM10 standards, because attainment plans are
not required for those areas. The California Clean Air Act requires that the State standards for air quality be
met as expeditiously as practicable, but unlike the federal Clean Air Act, does not set precise attainment
deadlines. Instead, the act established increasingly stringent requirements for areas that will require more
time to achieve the standards.
CARB is primarily responsible for developing and implementing air pollution control plans to achieve and
maintain the NAAQS. CARB is primarily responsible for statewide pollution sources and produces a major part
of the SIP. Local air districts are still relied upon to provide additional strategies for sources under their
jurisdiction. CARB combines this data and submits the completed SIP to EPA. Other CARB duties include
monitoring air quality, in conjunction with air monitoring networks maintained by air pollution control and air
quality management districts; establishing CAAQS, which in many cases are more stringent than the NAAQS;
determining and updating area designations and maps; and setting emissions standards for new mobile
sources, consumer products, small utility engines, and off-road vehicles.
Toxic Air Contaminant Regulations
TACs in California are primarily regulated through the Tanner Air Toxics Act (Assembly Bill [AB] 1807) and the
Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588, or the Hot Spots Act). AB 1807 sets
forth a formal procedure for CARB to designate substances as TACs. Research, public participation and
scientific peer review are necessary before CARB can designate a substance as a TAC. To date, CARB has
adopted EPA’s list of hazardous air pollutants as TACs and identified more than 21 additional TACS. Most
recently, environmental tobacco smoke was added to CARB’s list of TACs in 2007.
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Once a TAC is identified, CARB then adopts an Airborne Toxics Control Measure for sources that emit that
particular TAC. If there is a concentration below which health effects are not likely, the control measure must
reduce exposure below that threshold. If there is no safe concentration, the measure must incorporate Best
Available Control Technology for Toxics requirements to minimize emissions. CARB adopted a comprehensive
Risk Reduction Plan in 2000, after identifying DPM as a TAC. Pursuant to this Plan, CARB adopted diesel-
exhaust control measures and stringent emission standards for various on-road mobile sources of emissions,
including transit buses and off-road diesel equipment (e.g., tractors, generators). In 2001, CARB adopted the
Public Transit Bus Fleet Rule and Emissions Standards for New Urban Buses, which established emissions
limits for 1985, and subsequent model year heavy-duty bus engines and vehicles for NOx, CO, non-methane
hydrocarbons, particulate matter and formaldehyde. The emissions standards apply to all heavy-duty urban
buses, including diesel-fueled buses. Therefore, the rule limits the emissions of two TACs identified by
CARB—DPM and formaldehyde. In 2007, a low-sulfur diesel fuel requirement and tighter emission standards
for heavy- duty diesel trucks was put into effect, to be followed in 2011 by the same standards being applied
to off-road diesel equipment. Over time, the replacement of older vehicles will result in a fleet that produces
substantially lower levels of TACs than the replaced vehicles.
Mobile-source emissions of TACs (e.g., benzene, 1,3-butadiene, DPM) decreased significantly over the last
decade and will be reduced further in California through a progression of regulatory measures (e.g., Low-
Emission Vehicle/Clean Fuels and Phase II reformulated gasoline regulations), and control technologies. With
implementation of CARB’s Risk Reduction Plan, reductions in DPM concentrations of up to 85 percent from
the year-2000 levels are expected by 2020. As emissions are reduced, it is expected that risks associated with
exposure to the emissions will also be reduced.
In 2005, CARB published the Air Quality and Land Use Handbook: A Community Health Perspective, which
provides guidance concerning land-use compatibility with TAC sources. Although not a law or adopted policy,
the handbook offers recommendations for the siting of sensitive receptors (e.g., proposed residential units)
near uses associated with TACs to help limit the exposure of children and other sensitive populations to TACs.
Specifically, the Handbook identifies freeways and high traffic roads (100,000 vehicles per day for an urban
roadway or 50,000 vehicles per day for a rural roadway) as a source of TACs that could present a potentially
significant health risk to nearby sensitive receptors. CARB studies show that concentrations of traffic related
pollutants declined with distance from the road, primarily within the first 500 feet. Therefore, CARB
recommends avoiding the siting of new sensitive land uses within 500 feet of a freeway or high traffic
roadway.
Diesel buses are also subject to the CARB Statewide Truck and Bus Regulation. CARB adopted this regulation
in December 2008 and amended it in December 2011. The regulation requires heavy-duty vehicles to be
retrofitted with particulate matter filters beginning January 1, 2012, and requires older vehicles to be
replaced starting January 1, 2015. By January 1, 2023, nearly all trucks and buses must have 2010 model year
engines or equivalent.
2017 Clean Air Plan
The 2017 Clean Air Plan defines an integrated, multi-pollutant control strategy to reduce emissions of
particulate matter, TACs, ozone precursors and greenhouse gases. The proposed control strategy is designed
to complement efforts to improve air quality and protect the climate that are being implemented by partner
agencies at the state, regional and local scale. The control strategy encompasses 85 individual control
measures that describe specific actions to reduce emissions of air and climate pollutants from the full range
of emission sources. The control measures are categorized based upon the economic sector framework used
by the Air Resources Board for the AB 32 Scoping Plan Update.
In addition to fostering consistency with climate planning efforts at the state level, the economic sector
framework also ensures that the control strategy addresses all facets of the economy. The proposed control
strategy is based on four key priorities:
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Genentech Master Plan Update, Draft EIR Page 6-9
● Reduce emissions of criteria air pollutants and toxic air contaminants from all key sources.
● Reduce emissions of “super-GHGs” such as methane, black carbon and fluorinated gases.
● Decrease demand for fossil fuels (gasoline, diesel and natural gas) by increasing the efficiency of our
industrial processes, energy and transportation systems, and reducing demand for vehicle travel, and
high-carbon goods and services.
● Decarbonize our energy system by making the electricity supply carbon-free, and electrifying the
transportation and building sectors.
Key elements of the transportation-related control strategies seek to reduce motor vehicle travel by
promoting transit, bicycling, walking and ridesharing. Other strategies include implementation of pricing
measures to reduce travel demand, directing new development to areas that are well served by transit and
conducive to bicycling and walking, accelerating the widespread adoption of electric vehicles, and promoting
use of clean fuels and low- or zero carbon technologies in trucks and heavy-duty equipment.
Regional Regulations - Bay Area Air Quality Management District
BAAQMD attains and maintains air quality conditions in the San Francisco Bay Area Air Basin (SFBAAB)
through a comprehensive program of planning, regulation, enforcement, technical innovation and promotion
of the understanding of air quality issues. The clean air strategy of BAAQMD includes the preparation of plans
for the attainment of ambient air quality standards, adoption and enforcement of rules and regulations
concerning sources of air pollution, and issuance of permits for stationary sources of air pollution. BAAQMD
also inspects stationary sources of air pollution and responds to citizen complaints, monitors ambient air
quality and meteorological conditions, and implements programs and regulations required by the federal
Clean Air Act and Amendments and the California Clean Air Act.
Air Quality Plan
BAAQMD prepares plans to attain ambient air quality standards in the SF Bay Area Air Basin. In coordination
with the Metropolitan Transportation Commission (MTC) and ABAG, the BAAQMD has prepared both federal
and State air quality plans to bring the SFBAAB into attainment with federal and State ozone standards.
Several prior air quality plans have been prepared for the Bay Area. The 1994 Carbon Monoxide Maintenance
Plan primarily sought to ensure continued attainment of the national CO standard. The 2001 Ozone
Attainment Plan described the Bay Area’s strategy for compliance with the federal 1-hour ozone standard.
The 2005 Bay Area Ozone Strategy charted a course for future actions to reduce ozone and ozone precursor
levels in the Bay Area. The 2010 Clean Air Plan provided control strategies for reducing ozone, particulate
matter, air toxics and greenhouse gases. It specifically addressed non-attainment of the State ozone
standards.
The most recent 2017 Bay Area Clean Air Plan, known as “Spare the Air and Cool the Climate”, provides a
regional strategy to protect public health and protect the climate. To protect public health, the Plan describes
how the Air District will continue progress toward attaining all state and federal air quality standards and
eliminating health risk disparities from exposure to air pollution among Bay Area communities. To protect the
climate, the 2017 Clean Air Plan defines a vision for transitioning the region to a post-carbon economy as
needed to achieve ambitious reduction targets for greenhouse gases for 2030 and 2050, and provides a
regional climate protection strategy that will put the Bay Area on a pathway to achieve those GHG reduction
targets. The 2017 Clean Air Plan includes a wide range of 186 control measures. These control measures are
designed to decrease emissions of the air pollutants that are most harmful to Bay Area residents, such as
particulate matter, ozone, and toxic air contaminants; to reduce emissions of methane and other “super-
GHGs” that are potent climate pollutants in the near-term; and to decrease emissions of carbon dioxide by
reducing fossil fuel combustion. Key elements in the 2017 Clean Air Plan’s control strategy include:
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● Decrease emissions of GHGs and criteria air pollutants through a region-wide strategy to reduce
combustion and improve combustion efficiency at industrial facilities, beginning with the three
largest sources of emissions: oil refineries, power plants and cements plants
● Reduce methane emissions from landfills and from oil and natural gas production and distribution
● Reduce emissions of toxic air contaminants by adopting more stringent thresholds and methods for
evaluating toxic risks at existing and new facilities
● Reduce motor vehicle travel by promoting transit, bicycling, walking and ridesharing
● Implement pricing measures to reduce travel demand
● Direct new development to those areas that are well served by transit and conducive to bicycling and
walking
● Accelerate the widespread adoption of electric vehicles
● Promote the use of clean fuels and low- or zero carbon technologies in trucks and heavy-duty
equipment
● Expand the production of low-carbon, renewable energy by promoting on-site technologies such as
rooftop solar, wind and ground-source heat pumps
● Support the expansion of community choice energy programs throughout the Bay Area
● Promote energy and water efficiency in both new and existing buildings
● Promote the switch from natural gas to electricity for space and water heating in Bay Area buildings
Air District Regulations – New Source Review 3
New Source Review (NSR) is one of the primary elements of the Air District’s regulatory program to attain
and maintain the state and federal ambient air quality standards. It is a comprehensive permitting program
that applies to facilities in the San Francisco Bay Area when they install new equipment, or make
modifications to existing equipment, that will increase their air pollution emissions. When a facility wants to
install a new source or modify an existing source that will increase emissions above the specified applicability
thresholds, the facility is required to obtain a permit from the Air District and must implement the elements
of the NSR program in order to do so. The regulations governing how that permitting process works, and
what exactly a facility must do in order to obtain the NSR permit, are set forth in Air District Regulation 2,
Rule 2 (commonly referred to as Regulation 2-2). The NSR permitting program for new and modified sources
is intended to complement the Air District’s efforts to reduce emissions from existing sources in order to
achieve the Bay Area’s clean air goals. The NSR program aims to achieve this goal in two principal ways.
Best Available Control Technology
NSR requires facilities to use the Best Available Control Technology (BACT) on new and modified sources to
limit emissions to the greatest extent possible. The requirement to use the BACT to control emissions is set
forth in Section 2-2-301. It requires facilities to use the most current state-of-the-art pollution control
equipment on new or modified sources with the potential to emit 10 pounds or more of the criteria
pollutants subject to the requirement. The BACT requirement does not require facilities to retrofit existing
sources with new control equipment whenever there is any incremental improvement in technology. But
when a facility installs a new source or makes a modification to an existing source, it must use the best
control equipment (as defined in the regulations) available at that time.
3 Derived from BAAQMD, Complex Permitting Handbook for BAAQMD New Source Review Permitting, September 2016
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Genentech Master Plan Update, Draft EIR Page 6-11
Emission Offsets
For any new emissions that will occur even after applying the Best Available Control Technology, NSR
requires facilities to account for those emissions in order to ensure that they do not jeopardize the Air
District’s efforts to attain and maintain compliance with ambient air quality standards. This second step takes
two different forms, depending primarily on whether the Bay Area is in attainment or not in attainment of
the relevant standards for a particular pollutant.
● For pollutants for which the Bay Area is not in attainment, facilities are required to “offset” any new
emissions increases to ensure that there is “no net increase” in emissions region-wide. Facilities are
required to do so by providing “emission reduction credits” generated by shutting down or curtailing
emissions at other sources, in an amount equal to or greater than the new emissions increase.
● For pollutants for which the Bay Area is in attainment, facilities are not required to offset their new
emissions, as the region can accommodate a certain amount of new emissions growth without
exceeding the applicable standards for those pollutants. But facilities are required to evaluate what
the impacts of their new emissions will be, in order to ensure that the new emissions growth will not
result in a violation of any applicable standards or a significant deterioration in existing air quality.
The requirement for offsets of emissions are set forth in Section 2-2-302 and Section 2-2-303. Both provisions
require that for any facility over the respective applicability thresholds, emissions “offsets” must be provided
for the full amount of the facility’s “cumulative increase” in emissions, which is the cumulative total of all
increases in the facility’s potential to emit back to when the respective offset requirement was first
implemented. This mechanism ensures that all of the facility’s emissions, up to its maximum potential to
emit, are offset by corresponding emissions decreases (with an exclusion for “grandfathered” emissions that
preceded the beginning of the offsets program).
CEQA Guidelines
BAAQMD also publishes CEQA Air Quality Guidelines to assist lead agencies in evaluating air quality impacts
of projects and plans proposed in the Bay Area Air Basin. The Guidelines address evaluating, measuring, and
mitigating air quality impacts generated from land development construction and operation activities. The
Guidelines focus on criteria air pollutant, GHG, TAC and odor emissions generated by projects and plans. For
projects, the Guidelines provide Thresholds of Significance and Screening Criteria to determine the level of
analysis needed, and assessment methods and mitigation measures for operational-related, local community
risk and hazards, local CO, odors, and construction-related impacts.
The most recent version of the BAAQMD Air Quality Guidelines was published in May 2017. The 2017
Guidelines reflect revisions made to address the California Supreme Court’s opinion in December 2015 that
CEQA does not generally require an analysis of the impacts of locating development in areas subject to
environmental hazards unless the project would exacerbate existing environmental hazards. The 2017 CEQA
Guidelines supersede the BAAQMD’s previous 1999 CEQA guidance titled BAAQMD CEQA Guidelines:
Assessing the Air Quality Impacts of Projects and Plans). As indicated in the 2017 Guidelines, ‘The Guidelines
are intended to help lead agencies navigate through the CEQA process. The Guidelines for implementation of
the Thresholds are for information purposes only to assist local agencies. Recommendations in the Guidelines
are advisory and should be followed by local governments at their own discretion. These Guidelines may
inform environmental review for development projects in the Bay Area, but do not commit local governments
or the Air District to any specific course of regulatory action. The Guidelines offer step-by-step procedures for
a thorough environmental impact analysis of adverse air emissions due to land development in the Bay Area.”
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Local Regulations and Policies
South San Francisco General Plan
Local jurisdictions, such as the City of South San Francisco, have the authority and responsibility to reduce air
pollution through its police power and decision-making authority. Specifically, the City is responsible for the
assessment and mitigation of air emissions resulting from its land use decisions. The City of South San
Francisco is also responsible for the implementation of transportation control measures as outlined in the SSF
Clean Air Plan. Examples of such measures include bus turnouts, energy-efficient streetlights and
synchronized traffic signals.
City of South San Francisco environmental plans and policies recognize community goals for air quality.
Chapter 7.3 of the South San Francisco General Plan identifies goals and policies that help the City contribute
toward regional efforts to improve air quality, and are consistent with the SSF Clean Air Plan. These are
outlined as follows:
● Continue to work toward improving air quality and meeting all federal and state ambient air quality
standards by reducing the generation of air pollutants from stationary and mobile sources, where
feasible.
● Encourage land use and transportation strategies that promote use of alternatives to the automobile
for transportation, including bicycling, bus transit and carpooling.
● Minimize conflicts between sensitive receptors and emissions generators by distancing them from
one another.
● Cooperate with the BAAQMD to achieve emissions reductions for nonattainment pollutants and their
precursors, including CO, ozone and PM10, by implementation of control measures for air pollution as
required by federal and state statutes.
● Use the City’s development review process and the CEQA regulations to evaluate and mitigate the
local and cumulative effects of new development on air quality.
● Adopt the standard construction dust abatement measures included in BAAQMD’s CEQA Guidelines.
● Require new residential development and remodeled existing homes to install clean-burning
fireplaces and wood stoves.
● In cooperation with local conservation groups, institute an active urban forest management program
that consists of planting new trees and maintaining existing ones.
In accordance with CEQA requirements and the CEQA review process, the City assesses the air quality
impacts of new development projects, requires mitigation of potentially adverse air quality impacts by
conditioning discretionary permits and monitors and enforces the implementation of such mitigation. The
City does not have the expertise to develop plans, programs, procedures and methodologies to ensure that
air quality within the City and region will meet federal and state standards. Instead, the City relies on the
expertise of the BAAQMD and utilizes the BAAQMD CEQA Guidelines as the guidance document for the
environmental review of plans and development proposals within its jurisdiction.
The goals and policies outlined in the City of South San Francisco East of 101 Area Plan are consistent with
the General Plan, as well as the SSF Clean Air Plan.
Chapter 6: Air Quality
Genentech Master Plan Update, Draft EIR Page 6-13
Impacts and Mitigation Measures
Thresholds of Significance
Based on CEQA Guidelines and South San Francisco’s reliance on BAAQMD CEQA Guidelines, the Project
(Master Plan Update) would have a significant air quality impact if it were to:
1. Conflict with or obstruct implementation of the applicable air quality plan;
2. Violate any air quality standard or contribute substantially to an existing or projected air quality
violation;
3. Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or state ambient air quality standard
(including releasing emissions which exceed quantitative thresholds for ozone precursors);
4. Expose sensitive receptors to substantial pollutant concentrations; or
5. Create objectionable odors affecting a substantial number of people.
Assessing Consistency with Clean Air Plan
The 2017 BAAQMD CEQA Guidelines recommend that, for a plan (such as the Genentech Master Plan
Update) to be found consistent with the applicable air quality plan, it must:
● Support the primary goals of the 2017 Bay Area Clean Air Plan (CAP), which include: reducing
emissions of criteria air pollutants and toxic air contaminants from all key sources; reducing
emissions of “super-GHGs” such as methane, black carbon and fluorinated gases; decreasing demand
for fossil fuels (gasoline, diesel and natural gas); and decarbonizing our energy system; and
● Include applicable air pollution control measures from the CAP, and not disrupt or hinder
implementation of any CAP control measures
Projects that incorporate all feasible air quality plan control measures are considered consistent with the
CAP. If approval of a plan would not cause the disruption, delay or otherwise hinder the implementation of
any air quality control measure, it would be considered consistent with the CAP. Examples of how a plan or
project may cause the disruption or delay of control measures include a project that precludes an extension
of a transit line or bike path, or proposes excessive parking beyond parking requirements.
Quantitative Thresholds
The BAAQMD 2017 CEQA Guidelines suggest quantitative thresholds for evaluating construction-related and
operational emissions of criteria pollutants and precursors and TACs. These thresholds of significance are
meant to make the general thresholds presented above more specific and quantitative in relation to Bay Area
attainment plans for air quality. Pursuant to the 2017 BAAQMD significance thresholds (as relied on by the
City of South San Francisco), implementation of the Project would have a single-source significant effect on
air quality if:
● Average daily construction emissions would exceed 54 pound per day (lb/day) of reactive organic gas
(ROG), nitrogen oxides (NOx), or PM2.5, or 82 lb/day of fine particulate matter less than 10
micrometer in diameter (PM10), whereby the thresholds for PM10 and PM2.5 apply to exhaust
emissions only;
● Operational emissions would exceed 54 lb/day or 10 tons per year (t/yr) of ROG, NOx, or PM2.5, or
82 lb/day or 15 t/yr of PM10;
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● The Project’s construction or operation would cause an excess cancer risk level exceeding 10 in 1
million or a health hazard index greater than 1.0 at the maximally exposed sensitive receptor
(MEISR); or
● The Project’s construction or operational activities would generate annual PM2.5 concentrations
that exceed 0.3 micrograms per cubic meter (µg/m3)
Cumulative Thresholds
For criteria air pollutants, BAAQMD considers projects that result in significant project-level impact to result
in significant cumulative impacts for criteria air pollutants. For risks and hazards, implementation of the
Project would contribute to a cumulatively considerable health risk impact on air quality if it would result in:
● An excess cancer risk level of more than 100 in 1 million or a non-cancer (i.e., chronic or acute)
hazard index (HI) greater than 10 from all local sources within 1,000-foot zone of influence; or
● A concentration greater than 0.8 μg/m3 annual average PM2.5 from all local sources within 1,000-
foot zone of influence
Approach to the Analysis
Criteria Air Pollutants
The following air quality analyses provide an assessment of potential criteria air pollutants and ozone
precursor emissions that would result from construction and operation of the Project, consistent with
guidelines and methodologies from air quality agencies, specifically, the Bay Area Air Quality Management
District (BAAQMD), the California Air Resources Board (ARB) and the US Environmental Protection Agency
(USEPA). Consistent with CEQA requirements, this air quality analysis evaluates mass emissions of criteria air
pollutants from both construction and operational activities (including traffic generated from the Project).
Consistency with Clean Air Plan
Air Quality 1: Implementation of the Project would not conflict with or obstruct implementation of the
applicable air quality plan. (Less than Significant)
Consistency with 2017 Clean Air Plan Sector-based Control Strategies
The currently applicable air quality plan is the 2017 BAAQMD Bay Area Clean Air Plan (or 2017 CAP). To be
found consistent with the Plan, the Project must support the primary goals of Plan, must include applicable
control measures of the Plan for air pollution, and must not disrupt or hinder implementation of any control
measures of the Plan. The Plan’s control strategies are based on an economic sector framework that includes:
● Stationary Sources
● Transportation
● Energy
● Buildings
● Agriculture
● Natural and Working Lands
● Waste Management
● Water
● Super-GHG Pollutants
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Genentech Master Plan Update, Draft EIR Page 6-15
Beginning in 2004, Genentech has established company-wide sustainability goals pursuant to its privately
developed Sustainability Strategic Plan. Genentech’s sustainability goals address each of the key areas
included in the 2017 CAP, including transportation, energy, building efficiencies, waste to landfill, water and
wastewater use, and other key sustainability program areas. These sustainability goals have been developed
in multi-year cycles, including the now-current goals for year 2015 through 2020. These goals have evolved
over time to track performance and achievement, to build upon prior successes and overcome setbacks, and
to respond to science-based models that accurately capture Genentech’s overall environmental footprint.
Overall, Genentech’s Sustainability Strategic Plan demonstrates consistency with the 2017 CAP control
strategies for those sectors that apply to the Project, as discussed below. Many of the control strategies from
the 2017 CAP do not directly relate to the Project (e.g., agriculture, working lands, refineries, etc.), so the
following consistency discussion focuses on those strategies that do relate.
Transportation
The transportation measures included in the 2017 CAP are aimed at decreasing emissions of criteria
pollutants, TACs, and GHGs by reducing demand for motor vehicle travel, promoting efficient vehicles and
transit service, decarbonizing transportation fuels, and electrifying motor vehicles and equipment. The 2017
CAP prioritize actions to protect Bay Area communities that are disproportionately impacted by air pollution,
particularly including measures to reduce emissions of diesel PM to protect public health in these
communities.
Consistent with the 2017 CAP, Genentech has developed a Transportation Demand Management Program
(TDM) to reduce energy and transportation requirements and emissions. Genentech’s TDM program provides
amenities and incentives to encourage non-single-occupancy vehicle transportation by employees and
visitors. Genentech’s TDM policies and programs are outlined in the Master Plan Update and the Project
Description of this EIR. As reported in the 2017 Annual Report, Genentech’s TDM program provides a variety
of flexible and convenient programs and services to get employees to and from work, as well as around
Campus. The objective of TDM program is to reduce vehicle trips by incorporating project components that
encourage increased transit use, carpooling, and providing facilities for bicyclists and pedestrians. Genentech
has made public transit access a priority through increases in GenenBus service and continued DNA shuttle
services to Caltrain and BART stations. Key elements of Genentech’s TDM program also include incentive-
based measures that encourage all forms of alternative mode use such as carpools, vanpools, transit and
shuttles, bicycling, walking, and telecommuting. Other measures include an expansive commuter and internal
shuttle program, a transit subsidy program, a Guaranteed Ride Home program, preferential carpool parking,
showers and bicycle facilities, commuter incentives and a number of on-site amenities designed to support
car-free employees. Participation in alternate transit modes has increased substantially since its inception –
from 25 percent alternative mode use in 2006, to a 35 percent alternative mode use in 2009, to between 41
and 43 percent alternative mode use in 2017. Genentech has committed through its Master Plan Update to
maintain and expand this TDM program to as much as 47 percent for Campus arrivals as necessary to meet
Trip Cap limits on total AM peak hour single-occupant vehicles, and to strive for a TDM performance goal of a
50 percent reduction in drive-alone Campus arrivals and a 57 percent total trip reduction rate inclusive of
flexible work opportunities, prior to buildout. The Project supports and implements applicable
transportation-based control measures of the 2017 CAP, and does not disrupt or hinder implementation of
any other transportation-based control measures.
Energy
The energy control measures included in the 2017 CAP seek to reduce emissions of criteria air pollutants,
TACs and GHGs by decreasing the amount of electricity consumed in the Bay Area, and decreasing the carbon
intensity of the electricity that is used by switching to less GHG-intensive fuel sources for electricity
generation. The strategies to decrease energy demand focus on promoting energy efficiency and
conservation.
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Genentech is now implementing numerous voluntary initiatives that will reduce GHG emissions and result in
significant energy savings:
● Genentech has initiated a solar panel installation program for the Campus that has the potential to
generate over 6 million watts of power during peak production. The program involves installation of
more than 16,000 solar power panels throughout the Campus, covering approximately 277,000
square feet of roof area. The solar panels system could produce up to 9.7 million kWh annually, and
as many as 36 electric car charging-stations could be connected to this system.
● Genentech has initiated construction of a Site Utility Project that incorporates the latest technologies
and high-efficiency system designs for industrial cooling and building air conditioning. This Site Utility
Project includes installation of a Campus-wide looped pipe system for refrigerated water
distribution, installation of new industrial chillers, and replacement of air conditioning equipment in
all buildings on Campus. The environmental performance goal of the project targets a 50% reduction
in energy used to produce refrigeration components of process cooling and air conditioning
throughout all Campus buildings.
● Genentech is exploring an option of installing a new combined heat and power (CHP) plant on
Campus. Potentially, this CHP would be a cogeneration plant that would use a natural gas power
station to generate electricity for Campus use and, rather than releasing by-product heat from this
facility into the environment, use the residual process to heat water needed for industrial
manufacturing and lab operations efficiently. Such a facility could substantially reduce direct
electrical consumption at the Campus, perhaps by as much as 70 million kw/year, and offset a
substantial portion of the electrical demands of new Campus growth.
These voluntary initiatives are supportive of, and implement certain energy-based control measures of the
2017 CAP. The Project does not disrupt or hinder implementation of any other energy-based control
measures.
Buildings
Control measures for the building sector included in the 2017 CAP seek to reduce emissions of air pollutants
and GHGs. These measures seek to improve the energy efficiency of existing and new buildings, promote use
of electricity and on-site renewable energy, and work to ensure that new construction is designed to achieve
zero net GHG emissions by 2020 (or the earliest possible date).
Genentech’s latest buildings on the Campus have implemented sustainability strategies from a variety of
sources. These sources include a Sustainability Design Checklist based on LEED4 New Construction, the U.S.
Green Building Council Northern California Building Health Initiative and the Department of Energy’s Facility
for Low Energy Experiments in Buildings (FLEXLAB) program, LEED Gold certifications and WELL Certification.
These most recent building additions to the Campus demonstrate Genentech’s commitment to a sustainable
campus environment that enhances health, comfort and performance, while minimizing resource
consumption. The Master Plan Update anticipates that every new building and Campus improvement will:
● be designed to respect the integrity and biodiversity of natural systems on the Campus
● employ architectural design methods aimed at controlling solar gain, including the use of solar
shading devices, white roofing materials and building orientation
● utilize high recycled-content building materials and integrate energy-efficient and water-conserving
systems
● utilize landscape with native and drought-tolerant plants
● include bio-swales or similar measures to control rainwater runoff
● be located on sites served by existing infrastructure; and
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Genentech Master Plan Update, Draft EIR Page 6-17
● will consider opportunities to support public and alternative transportation modes
As indicated in the Greenhouse Gas and Climate Change chapter of this EIR, the Project would not exceed the
service-based efficiency threshold for land use based GHG emissions by year 2020. Operation of the Project
would not exceed the threshold for GHG emissions per service population, and would result in a less than
significant impact. The Project supports and implements applicable building-based control measures of the
2017 CAP, and does not disrupt or hinder implementation of any other building-based control measures.
Waste Management
The Plan’s control measures for the waste management sector are focused on reducing or capturing methane
emissions from landfills and composting facilities, diverting organic materials away from landfills, and
increasing waste diversion rates through efforts to reduce, reuse and recycle.
The current waste reduction goal presented in Genentech’s Sustainability Plan is to target an 80% absolute
reduction in waste to landfill per employee by 2020, as compared to 2010 levels. Some of the individual
projects pursuant to this goal include:
● Increased recycling and composting
● Reduction and reuse efforts to minimize the amount of materials brought into Campus and to
maximize reuse
● Green Bio-Pharma program provides off-site recycling of materials used in Genentech’s
manufacturing processes and diverting bio-process lab waste (i.e., containers, lids and other plastic
products) from landfills by providing for their reuse on Campus and by offering excess equipment
and supplies to schools and nonprofits
Genentech expects to meet its 10-year goal of 80% absolute reduction in waste to landfill per employee by
2020. The Project supports and implements applicable waste management-based control measures of the
2017 CAP, and does not disrupt or hinder implementation of any other waste management -based control
measures.
Water and Wastewater
The 2017 CAP’s control measures for the water sector seek to reduce emissions of criteria pollutants, TACs
and GHGs by encouraging water conservation, limiting GHG emissions from publicly owned water treatment
works and promoting the use of biogas recovery systems.
Since 2004, Genentech has been committed to improving its water use efficiency, particularly through
efficiencies in its manufacturing operations. The current water conservation goal presented in Genentech’s
Sustainability Plan is for a 20% overall water reduction by year 2020, as compared to water use levels in 2010.
Some of the individual projects pursuant to this goal include:
● Irrigation savings by prioritizing native, drought tolerant planting for newly landscaped areas,
replacing some existing turfed areas with native, drought tolerant plants, and using high-efficiency
drip and spray irrigation system with weather controls
● Corporate awareness initiatives to increase employee awareness of water conservation strategies
● Continued commitment to use of, or preparation for use of, recycled water for a variety of non-
potable water needs, including installation of recycled water distribution lines (i.e., “purple pipes”)
throughout the Campus to enable reclaimed water to be transported for internal reuse as it may
become available in the future
● Continuation of pilot programs and solutions to reuse and recycle water internally (for example, as
make-up water in cooling towers), and expects that the expansion of such solutions will drive
significant water savings
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The Project’s water conservation and water recycling programs are in full compliance with the water-based
control measures of the 2017 CAP, and do not disrupt or hinder implementation of any other water-based
control measures.
Super-GHGs
Super-GHGs include methane, black carbon and fluorinated gases (F-gases). The compounds are sometimes
referred to as short-lived climate pollutants because their lifetime in the atmosphere is generally short.
However, their principal characteristic is that they have very high global warming potential on a per-unit
basis, in comparison to CO2. Reducing emissions of super-GHGs is a high priority control strategy of the 2017
CAP because this approach represents the best opportunity to slow the rate of global warming in the near
term.
The Genentech (Roche) Directive for Substances of Concern (Directive K6) provides a common basis for
complying with international and national regulations and conventions, and the gradual phasing-out of
concerned substances adversely affecting the ozone layer and the climate. Directive K6 requires eliminating
the use of substances that have a negative impact on the environment caused by ozone depletion, global
warming or persistence in the atmosphere with potential long-term negative effects. For Genentech, the K6
Directive requires that use of all chlorofluorocarbons (CFCs) and hydro-chlorofluorocarbons (HCFCs) be
eliminated by 2018, and use of all hydrofluorocarbons (HFCs) be eliminated by 2022.
Mitigation Measures
None needed. The Project supports the primary goals of the 2017 Bay Area Clean Air Plan, includes applicable
control measures from the 2017 CAP for air pollution, and does not disrupt or hinder implementation of any
control measures of the 2017 CAP.
The Genentech Master Plan Update (the Project) includes plans for infrastructure capacity to support future
Campus growth, but also recognizes that Genentech’s infrastructure demands can be reduced through
efforts to conserve and minimize the Campus’ environmental footprint. Many of sustainability initiatives that
Genentech has implemented or is implementing now are examples of the types of efforts that Genentech
may pursue towards meeting their own internal sustainability goals and objectives for future Campus growth.
Genentech is now implementing numerous initiatives that serve to decrease emissions of the air pollutants
that are most harmful to Bay Area residents such as particulate matter, ozone, and toxic air contaminants; to
reduce emissions of “super-GHGs” that are potent climate pollutants in the near-term; and to decrease
emissions of carbon dioxide by reducing fossil fuel combustion. Genentech anticipates re-evaluation and re-
assessment of its current sustainability goals for 2020, and development of successive multi-year goals and
implementation strategies based on prior successes and challenges.
Construction-Period Emissions of Criteria Pollutants
AQ 2: Throughout buildout of the Project, construction activities would result in emissions of criteria
pollutants for which the region is non-attainment, including releasing emissions of ozone precursors
and particulates. However, with implementation of Basic Best Management Practices (BMPs) for all
construction projects, construction emissions would be unlikely to exceed applicable thresholds. (Less
than Significant)
Fugitive Dust
The Project Description anticipates that the Project will include demolition of certain existing structures as
part of redevelopment of the Campus, as well as construction of new structures. Project related demolition,
grading and other construction activities at the Campus might cause wind-blown dust that could emit
particulate matter into the atmosphere. Fugitive dust includes not only PM10 and PM2.5, but also larger
Chapter 6: Air Quality
Genentech Master Plan Update, Draft EIR Page 6-19
particles as well that can represent a nuisance impact. Dust can be an irritant and cause watering eyes or
irritation to the lungs, nose and throat. Demolition, excavation and other construction activities can cause
wind-blown dust to add to particulate matter in the local atmosphere. California EPA has found that
particulate matter exposure can cause health effects. The current health burden of particulate matter
demands that, where possible, public agencies take feasible actions to reduce sources of particulate matter
exposure.
During construction, short-term degradation of air quality may occur due to the release of particulate
emissions generated by excavation, grading, hauling and other activities. Construction-related effects on air
quality from the Project would be greatest during the site preparation phases due to the disturbance of soils.
If not properly controlled, these activities would temporarily generate particulate emissions. Sources of
fugitive dust would include disturbed soils at construction site. PM10 emissions would vary from day to day,
depending on the nature and magnitude of construction activity and local weather conditions. PM10
emissions would depend on soil moisture, silt content of soil, wind speed, and the amount of operating
equipment. Larger dust particles would settle near the source, while fine particles would be dispersed over
greater distances from the construction site.
Off-Road Diesel Equipment
Construction activity will also generate air emissions from use of heavy-duty construction equipment. Mobile
source emissions, primarily NOx, will be generated from the use of construction equipment such as
excavators, bulldozers, wheeled loaders and cranes. During the finishing phase, paving operations and the
application of asphalt, architectural coatings (i.e., paints) and other building materials would release ROG.
The assessment of construction-period emissions of criteria air pollutants considers each of these sources,
and recognizes that construction emissions can vary substantially from day to day, and from project to
project, depending on the level of activity and the specific type of operation.
Criteria pollutant emissions from construction activities were calculated using the latest version of
CalEEMod.4 CalEEMod default values were used to generate an inventory of expected construction
equipment including details on the equipment type, quantity, assumed construction dates, and hours of
operation anticipated for each piece of equipment for each construction phase. Once the equipment
inventories were generated, CalEEMod utilized ARB’s 2011 Off-Road Equipment Model (OFFROAD2011)
methodology to estimate off-road diesel emissions.5
On-Road Haul Trucks, Vendor Trucks and Commuting Worker Vehicles
Construction activity will also generate air emissions from vehicle trips hauling materials and from
construction workers traveling to and from the site. On-road truck and commuting worker vehicle emissions
were calculated using the total number of expected trips, and emission factors from ARB’s EMission FACtor
model (EMFAC2014). The total number of haul truck trips was estimated based on anticipated levels of
demolition and soil excavation. To estimate soil import/export quantities, two separate average excavation
rates were used based on recent construction projects at the Campus. One excavation rate was developed
for projects on steep terrain and another excavation rate was developed for projects on flat terrain. Contour
and aerial maps were used to categorize the different Opportunity Sites as either flat or steep terrain, and
4 CalEEMod is a land use emissions computer model designed to provide a uniform platform for government agencies, land
use planners and environmental professionals to quantify potential criteria pollutant and GHG emissions associated with both
construction and operations from a variety of land use projects.
5 OFFROAD2011 incorporates statewide survey data to develop emission factors based on the fleet average for each year of
operation. The OFFROAD2011 model also identifies default horsepower and load factor for each type of equipment, which are
included in CalEEMod.
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each Opportunity Site area was multiplied by either the flat and steep terrain excavation rate to estimate
total excavation.
The total number of vendor trucks and worker commuting vehicle trips are estimated by CalEEMod. For haul
trucks, a 20-mile one-way trip length was assumed. For vendor trucks, a 7.3-mile trip length was assumed.
For worker cars, a 12.4-mile trip length was assumed. These trip lengths are based on CalEEMod default trip
lengths. The EMFAC2014 model was then used to generate emission factors from this construction fleet
based on vehicle weight classes.6
Architectural Coating Emissions
CalEEMod was also used to estimate ROG emissions from expected architectural coatings used during the
construction of new offices, laboratories and amenities. Compliance with BAAQMD regulations restricting the
volatile organic compound (VOC) content of commercial paints was assumed.
Construction-Period Criteria Air Pollutant Summary
Table 6-2 shows the total emissions of criteria air pollutants per day that could be expected to result from
buildout of the Project. Total construction emissions were annualized by assuming a 20-year construction
period, and then averaged across a full 365-day calendar year, to compare to the applicable daily CEQA
thresholds. As shown in Table 6-2, construction-period emissions for the Project do not exceed the average
daily emission thresholds.
Table 6-2: Construction Criteria Pollutant Emissions
ROG NOx PM10 PM2.5
Project Total Emissions (tons) 1 36 156 2.2 2.1
Construction Days (20 years, 365 days/yr)
Per Day Construction Emissions (lbs/day) 2 10 43 0.6 0.6
Average Daily Threshold (lbs/day) 54 54 82 54
Exceed Threshold? No No No No
1. Emissions estimated via CalEEMod® and the land use information provided in Project Description
2. Although CalEEMod®'s default construction phase length is 16 years for a 123-acre project, Ramboll annualized the total emissions
by assuming a 20-year construction period (duration of the Master Plan Update) to compare to the BAAQMD CEQA threshold.
Source: Ramboll, October 2018
Best Management Practices
Consistent with BAAQMD recommendations, the following BMPs shall be implemented by all construction
projects, regardless of itemized construction emission levels:
a) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved
access roads) shall be watered two times per day.
6 EMFAC2014 is an emission inventory model that was developed to determine emission rates from motor vehicles that
operate on highways, freeways and local roads in California and is commonly used by ARB to project changes in future emissions
from on-road mobile sources. The most recent version of this model, EMFAC2014, incorporates regional motor vehicle data,
information and estimates regarding the distribution of vehicle miles traveled (VMT) by speed, and number of starts per day.
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Genentech Master Plan Update, Draft EIR Page 6-21
b) All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
c) All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power
vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
d) All vehicle speeds on unpaved roads shall be limited to 15 mph.
e) All roadways, driveways and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders are
used.
f) Idling times shall be minimized either by shutting equipment off when not in use or reducing the
maximum idling time to 5 minutes (as required by the California airborne toxics control measure
Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided
for construction workers at all access points.
g) All construction equipment shall be maintained and properly tuned in accordance with
manufacturer’s specifications. All equipment shall be checked by a certified mechanic and
determined to be running in proper condition prior to operation.
h) Post a publicly visible sign with the telephone number and person to contact at the Lead Agency
regarding dust complaints. This person shall respond and take corrective action within 48 hours.
The Air District’s phone number shall also be visible to ensure compliance with applicable
regulations.
The analysis of construction-period emissions presented above assumes that construction activities would be
averaged across a 20-year buildout period, with an annual average of approximately 215,000 square feet of
construction occurring each year. However, it is possible (even likely) those variations to this construction
schedule will occur, resulting in construction of individual buildings exceeding the assumed annual average,
or that multiple buildings may be constructed across the Campus at the same time. Therefore, the following
requirement is recommended as a Condition of Approval for the Project, to address subsequent
development-specific circumstances:
Recommendation AQ 2: Project-Specific Construction Emission Analysis: A project-specific construction
emissions analysis is required for all projects that exceed the assumptions of this analysis, including:
● Annual construction exceeding 215,000 square feet a year.
● Construction projects that individually exceed 227,000 square feet in size (the lower of BAAQMD
screening sizes for either office parks or industrial parks)
● When two or more simultaneously occurring construction projects would exceed this screening size,
or construction projects include more than two simultaneously occurring construction phases
● Construction projects that would include demolition, that would involve extensive site preparation
(i.e., greater than default assumptions used by the URBEMIS model), or that involve extensive
material transport (in amounts greater than 10,000 cubic yards of soil import/export)
● If a project-specific emission analysis exceeds the per-day construction emissions thresholds
presented in Table 6-2, then a demonstration of consistency with the results in AQ-3 would also be
required.
Construction-Period Health Risk
AQ 3: During construction activities, the Project could expose sensitive receptors to substantial pollutant
concentrations from construction-related emissions. Specifically, the Project’s construction
Chapter 6: Air Quality
Page 6-22 Genentech Master Plan Update, Draft EIR
emissions could cause an excess cancer risk level exceeding 10 in one million at the maximally
exposed sensitive receptor. (Less than Significant with Mitigation)
The objective of the following health risk analysis is to evaluate the potential impacts of construction of the
Project on off-site and onsite sensitive receptors. Sensitive receptors evaluated in this analysis include
daycare receptors (both Genentech daycare and off-site Early Years Preschool), residential receptors to the
north (houseboats in the Oyster Point Marina) and recreational receptors on the San Francisco Bay Trail. The
criterion for whether or not the Project’s construction activities presents a significant air quality impact is if
the Project will “expose sensitive receptors to substantial pollutant concentrations,” expressed as excess
cancer risk exceeding 10 in 1 million, hazard index greater than 1.0 or annual PM2.5 concentrations that
exceed 0.3 µg/m3 at sensitive receptor locations.
Construction activities related to the Project will vary depending on a number of factors, so this analysis
estimates health impacts using conservative assumptions. This conservative analysis provides bounds within
which construction activity has been analyzed. Construction activity that falls outside of these conservative
assumptions does not necessarily imply a new or more significant impact. Rather, it indicates that a detailed
health risk analysis with refined project components should be conducted to evaluate impacts that may be
unique or particular to a specific construction project.
Construction Sources of TAC Emissions
The primary sources of toxic air emissions during construction is off-road equipment and on-road diesel
trucks used during construction activities. CalEEMod® is used to obtain the off- and on-road diesel equipment
list. Only off-road equipment and on-road diesel truck emissions are modeled. On-road construction worker
commuting vehicles are assumed a negligible source of diesel emissions. The cancer risk analysis is based on
diesel particulate matter (DPM) concentrations from diesel equipment and on-road vehicles. Diesel exhaust is
identified by the State of California as a known carcinogen. DPM is used as a surrogate measure of carcinogen
exposure for the mixture of chemicals that make up diesel exhaust as a whole, as recommended by Cal/EPA.
Only annual average concentrations of DPM were modeled to evaluate chronic health risks using the
California-developed cancer potency factor and chronic reference exposure level for DPM. This methodology
is consistent with BAAQMD guidance.7
BAAQMD also has a CEQA threshold for annual average PM2.5 concentration. PM2.5 is a complex mixture of
substances that includes elements such as carbon and metals; compounds such as nitrates, organics and
sulfates; and complex mixtures such as diesel exhaust and wood smoke. PM2.5 poses an increased health risk
relative to PM10 because the particles can deposit more deeply in the lungs and they contain substances that
are particularly harmful to human health. It can cause a wide range of health effects including aggravating
asthma and bronchitis, causing visits to the hospital for respiratory and cardiovascular symptoms, and
contributing to heart attacks and deaths. A separate analysis of potential health impacts of the Project’s
operational-based criteria pollutant emissions (including PM2.5) is included under Impact AQ-4.
Assumptions Used in HRA Modeling
Air dispersion modeling of DPM and PM2.5 from Project construction sources is conducted using the USEPA
atmospheric dispersion modeling (AERMOD) model, version 16216.8 For each receptor location, the model
generates average air concentrations that result from emissions from multiple sources. When site-specific
information is unknown, the analysis uses default parameters that are designed to produce conservative (i.e.,
overestimated) air concentrations.
7 BAAQMD. 2005. Guidance for Calculating Maximum Hourly Toxic Air Contaminant Emission Rates. Available online at:
http://www.baaqmd.gov/~/media/files/engineering/policy_and_procedures/hourlyemissionguidelines.pdf?la=en
8 AERMOD version 16216 was the most up to date model version at the time of the Notice of Preparation.
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Genentech Master Plan Update, Draft EIR Page 6-23
● Construction Period: Project construction is assumed over a twenty-year period. A longer assumed
buildout period would result in averaging total emissions over a longer period and resulting in lower
annual average concentrations. Maximum hourly concentrations were not modeled.
● Meteorological Data: This analysis utilizes the same meteorological data set that has been used for
previous Genentech modeling efforts, including the HRA in support of the recent air permit for the
Building 35 emergency generator.9 Upper air data from the Oakland International Airport was used.
Meteorological data was prepared for use in AERMOD with meteorological data preprocessor for
AERMOD (AERMET) (version 16216).
● Terrain Considerations: Elevation and land use data were imported from the National Elevation
Dataset (NED) maintained by the United States Geological Survey (USGS 2013).
● Emission Rates: Emitting activities were modeled to reflect the typical construction hours in a day.
Emissions were modeled such that each construction phase has unit emission rates, and the model
estimates dispersion factors. For annual average ambient air concentrations, the estimated annual
average dispersion factors are multiplied by the annual average emission rates. The emission rates
will vary day to day, with some days having no emissions. The model assumes a constant emission
rate during the entire year. TAC emission rates for this analysis are shown in Table 6-3.
Table 6-3: Construction TAC Emission Rates
Source Chemical Annual TAC Emission Rate (g/sec./acre) 2
Construction Diesel Emissions 1 Diesel PM (PM10) 2.4 E-05
PM2.5 2.2 E-05
1. Only diesel exhaust emissions (no fugitive emissions) were modeled for construction
2. Emissions from off-road diesel sources as well as on-road haul trucks and vendor trucks. One single emission rate was estimated for
the entire Project and the emissions were distributed to the different construction locations based on the areas of those locations
Source: Ramboll, October 2018
Sensitive Receptors
Offsite receptors and sensitive population locations evaluated for this study include:
● Daycare uses in the vicinity (both Genentech daycare and off-site Early Years Preschool)
● Residents (houseboats) in the Oyster Point Marina
● Recreational receptors using the San Francisco Bay Trail
Figure 6-1 shows the location of those sensitive receptors evaluated. Receptors were modeled at a height of
1.8 meters above terrain height, a default breathing height for ground-floor receptors.
9 The District has granted approval of the use of this meteorological data set, which was primarily collected at the San Francisco
International Airport during 2001 to 2005.
Figure 6-1Sensitive Receptor Locations Source: Ramboll, 2018 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User CommunitySensitive Receptor LocationsGenentech, Inc.South San Francisco, CaliforniaDRAFTED BY:DATE: 10/5/2018FIGUREAQ-3PROJECT01,000500FeetLegend1000-m BufferCampus BoundaryDaycare ReceptorResidential ReceptorRecreational ReceptorDRAFTPrivileged and Confidential Attorney Work ProductLegend:1,000 m BufferCampus BoundaryDaycare CenterResidential receptorRecreational Receptor
Chapter 6: Air Quality
Genentech Master Plan Update, Draft EIR Page 6-25
Average annual dispersion factors were estimated for each receptor location. An adjustment factor was
applied to air concentrations modeled with continuous averaging time (i.e., 24 hours per day, 365 days per
year) when the actual exposure occurs for less than 24 hours and/or less than one year. It is assumed that the
emissions from all construction sources occur only during a 10-hour operational day (7AM to 5PM),
compressing emissions that could potentially occur over a 24-hour period, 7 days per week into a 10-hour
period, 5 days per week. A modeling adjustment factor (MAF) is applied to certain populations with
exposures less than 24 hours in a day (i.e., childcare and recreational users). These adjusted concentrations
represent the concentrations over the operating period to which the daycare child or recreational receptor
might be exposed. Residents are assumed exposed to emissions 24 hours per day, so the annual average
concentration is not adjusted for this population.
Health Risk Maps
For the construction HRA, cancer risk, chronic HI and PM2.5 concentrations were mapped to identify where
construction activities are expected to occur that do, and do not exceed thresholds of 10 in a million, 1.0, and
0.3 µg/m3, respectively under an unmitigated scenario.
Figure 6-2 provides an overlay of the three concentration maps. The green areas in Figure 6-2 indicate
locations where construction activities could occur within a 20-year period without exceeding any health risk-
based thresholds. The blue areas of Figure 6-2 indicate those locations where construction activity during
that same 20-year period could contribute to a significant impact, and where refined health risk analysis for
individual projects would be necessary to ensure that cancer risk, chronic HI, and PM2.5 concentrations do
not exceed significance thresholds at all modeled receptor locations. Construction at those areas indicated in
blue does not necessarily result in a significant impact, but indicates that additional refined modeling will be
needed to show if impacts are significant. Figure 6-2 shows that 94% of the total Opportunity Site area can be
built without further refined construction-period health risk analysis. Cancer risk is the main driver for health
risk, and Figure 6-2 is solely dictated by where construction emission sources can be located without further
analysis and not exceed the 10-in-a-million threshold. Chronic HI and PM2.5 concentration thresholds would
not be exceeded even if construction occurred on all Opportunity Sites.
Table 6-4 shows the cancer risk, chronic HI, and PM2.5 concentration results at the maximum exposed
individual receptors (MEISRs) when construction activities (without mitigation) are limited to only those
locations (or those Opportunity Sites) that do not contribute to significant health risk impacts. As can be
shown, all impacts at 94% of the total Opportunity Site areas are below threshold levels under this
construction scenario.
Source: Ramboll, 2018Figure 6-2Construction Period Health Risk Map Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User CommunityUnmitigated Construction Scenario Combined MapGenentech, Inc.South San Francisco, CaliforniaDRAFTED BY:DATE: 10/10/2018FIGUREAQ-10PROJECT01,000500FeetLegendModeling BoundaryConstruction LocationsMay Contribute to Significant ImpactWould Not Contribute to Significant ImpactThe green areas represent locations where construction would not contribute to a significant impact if construction were to occur on all green areas within a twenty-year period.The blue areas represent locations where additional construction activity beyond the green areas within the same twenty-year period could contribute to a significant impact.Construction health risk analysis is based on conservative and generalized assumptions such as analysis of all construction occurring over a single twenty-year period and the equipment inventory. Project-specific assumptions and more realistic construction timeframes can result in lower health risk impacts.Figure Notes:DRAFTPrivileged and Confidential Attorney Work Product
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Genentech Master Plan Update, Draft EIR Page 6-27
Table 6-4: Construction Health Risk Assessment, MEIR (Unmitigated)
Receptor Type Cancer Risk (per million) 1 Threshold (per million)
Daycare (Genentech) 9.96 10
Daycare (Early Years) 1.7 10
Recreational (on Bay Trail) 1.2 10
Residential (Boathouses at Oyster Point Marina) 0.41 10
Non-Cancer Health Impacts 2 Value Threshold
Chronic Health Index 0.0026 1.0
PM2.5 Concentration 0.012 ug/m3 0.30 ug/m3
1. The impacts are estimated with construction on locations that would not contribute to significant impact, as shown in Figure 6-2
2. The maximum chronic HI and PM2.5 concentration occur at the Genentech Daycare
Source: Ramboll, October 2018
Mitigation Measures
A mitigated scenario has also been prepared which assumes that all construction off-road equipment used in
certain areas (identified in Figure 6-3, in pink) will have diesel particulate filters capable of reducing PM10
and PM2.5 emissions by as much as 85%. For this scenario, the off-road equipment inventories (i.e.,
equipment type, quantity, hours of operation and horsepower) are the same as the unmitigated scenario, but
the analysis uses reduced emission factors to estimate emissions.
Mitigation Measure AQ 3 - Diesel Particulate Filters: Construction activity that occurs in proximity to the
Genentech daycare center or the Early Years preschool on Allerton Avenue shall use off-road
construction equipment installed with diesel particulate filters capable of reducing PM10 and PM2.5
emissions by as much as 85%.
As indicated in Figure 6-3, the pink areas indicate where equipping all engines with diesel particulate filters is
required pursuant to Mitigation Measure AQ 3.
Resulting Level of Significance
Figure 6-3 shows areas (colored in pink) where equipping all engines with diesel particulate filters is required
for construction emissions to not contribute to a significant health risk impact. If all construction activity that
occurs in those areas identified in pink on Figure 6-3 uses off-road equipment installed with diesel particulate
engines as defined in Mitigation Measure AQ 3, construction activities can occur throughout the entire
Project Area without exceeding any health risk-based thresholds. Table 6-5 shows the mitigated cancer risk,
chronic HI and PM2.5 concentration results at sensitive receptors when engines that include diesel
particulate filters are used in these areas. As shown, all impacts are reduced to below thresholds even when
construction occurs on all Opportunity Sites.
Source: Ramboll 2018Figure 6-3Construction Locations Requiring Mitigation Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User CommunityConstruction Mitigation MapGenentech, Inc.South San Francisco, CaliforniaDRAFTED BY:DATE: 10/10/2018FIGUREAQ-10bPROJECT01,000500FeetThe green areas represent locations where a conservative risk analysis shows that construction activity without any mitigation would not contribute to a significant impact if construction were to occur on all the green areas within a twenty-year period.The pink areas represent locations where additional construction activity beyond the green areas within the same twenty-year period would require diesel particulate filter or cleaner technology to not contribute to a significant impact. The construction health risk analysis is based on conservative and generalized assumptions such as analysis of all construction occurring over a single twenty-year period and assuming a default equipment inventory. Project-specific assumptions and more realistic construction timeframes can resultin lower health risk impacts and reduce the area that would require mitigation.Figure Notes:LegendModeling BoundaryConstruction LocationsAreas Where Diesel Particulate Filter Reduction AppliedAreas Where Diesel Particulate Filter Reduction is Not RequiredDRAFTPrivileged and Confidential Attorney Work Product
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Genentech Master Plan Update, Draft EIR Page 6-29
Table 6-5: Construction Health Risk Assessment at Sensitive Receptors (with Mitigation)
Receptor Type Cancer Risk (per million) 1 Threshold (per million)
Daycare (Genentech) 9.96 10
Daycare (Early Years) 1.8 10
Recreational (on Bay Trail) 1.2 10
Residential (Boathouses at Oyster Point Marina) 0.41 10
Non-Cancer Health Impacts 2 Value Threshold
Chronic Health Index 0.0016 1.0
PM2.5 Concentration 0.0077 ug/m3 0.30 ug/m3
1. The impacts are estimated with construction at all Opportunity Sites, using engines with diesel particulate filters
2. The maximum chronic HI and PM2.5 concentration occur at the Genentech daycare
Source: Ramboll, October 2018
This analysis provides for two separate conclusions:
● Construction activities can occur on each of those Opportunity Sites as indicated on Figure 6-3 as not
contributing to construction-period health risks, without having to conduct further project-specific
analysis (i.e., impacts would be less than significant). Construction activities may not proceed on any
of those Opportunity Sites as indicated on Figure 6-3 as being contributors to construction-period
health risks until a project-specific construction health risk analysis is conducted and demonstrates
that the proposed construction activity would not contribute to a new or substantially more
significant health risk to sensitive receptors. This analysis may include alternate mitigation measures
that must be implemented.
● All construction activities pursuant to buildout of the Project may proceed on all Opportunity Sites
without further site-specific or project-specific analysis if diesel particulate filters are installed on all
diesel construction equipment used in areas shown in Figure 6-3 as areas where diesel particulate
filters are required. With implementation of Mitigation Measure AQ 3, construction health risk
impacts would be less than significant for construction activities in all Opportunity Sites.
Operational Criteria Pollutant Emissions
AQ 4: During operations, the Project would result in a cumulatively considerable net increase of criteria
pollutants for which the region is non-attainment, including emissions that exceed quantitative
thresholds for ozone precursors. Specifically, the Project’s average daily operational emissions are
projected to exceed 54 pound per day of reactive organic gas (ROG) and nitrogen oxides. (Significant
and Unavoidable)
Operational sources of criteria air pollutants include stationary sources, area source and mobile sources.
Emissions from each of these sources as would be generated by the Project are estimated as indicated below.
Stationary Sources
Based on information provided by the applicant, it is assumed that the Project will include 52 net new diesel-
fired emergency generators, increased use of natural gas, potentially a combined heat and power plant
(CHP), and 4 new natural gas-fired boilers.
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Page 6-30 Genentech Master Plan Update, Draft EIR
● Emergency Generators: The number of new diesel-fired emergency generators (52) was estimated
by comparing the current number of emergency generators (57) and current Campus building space
(approximately 4.7 million square) to the net increase in Campus building space pursuant to the
Project (approximately 4.3 million square feet). This is likely an unrealistically high (conservative)
estimate of the number of future new emergency generators, as future emergency generation
capacity is not expected to follow historical trends. Each new emergency generator is assumed to be
rated at 2 megawatts (MW), consistent with the rating for the more recent emergency generators
installed at the Campus. Emission of PM, TOG and NOx emissions from these diesel emergency
generators are estimated based on ARB-certified emission factors.
● Natural Gas Use: The net increase in use of natural gas pursuant to the Project was also based on a
proportion increase of existing natural gas use per square foot of existing building space, multiplied
by the net increase in building space pursuant to the Project. Emissions from increased use of
permit-exempt natural gas-fired boilers were estimated based on BAAQMD limits for NOx and AP-42
emission factors for the other pollutants.
● Combined Heat and Power Plant: The Project includes the potential construction of a new CHP for
the Campus. Installation of a new CHP is dependent on future needs as well as feasibility and cost
studies yet to be prepared. If ultimately proposed, a new CHP would also require permits from the
BAAQMD and would be required to comply with applicable Best Available Control Technology
(BACT), including BACT for toxics requirements. VOC emissions from a potential CHP are estimated
based on assumed AP-42 emission factors for natural gas turbines. NOx emissions were estimated
based on a BAAQMD Best Available Control Technology (BACT) limits. PM10 and PM2.5 emissions
were estimated based on emission factors obtained from EPA data.
● Miura Boilers: The Project assumes installation of four new Miura boilers. Emissions of ROG and PM
from the boilers are estimated based on AP-42 emission factors. The NOx emission factor and the
gas consumption rate for the Miura boilers were estimated from vendor's data.
Area Sources
The Project will include area sources of criteria air pollutants such as architectural coatings, and consumer
products and solvents used in the new offices and laboratories. Emissions from these area sources were
estimated using CalEEMod®, based on the type and size of land uses associated with the Project.
Mobile Sources
The Project will generate new vehicle trips from new employees and increased vehicle trips by vendors and
visitors. The number of estimated new daily vehicle trips generated by the Project was obtained from the
same Traffic Impact Analysis as used for the Transportation chapter of this EIR,10 and includes data such as
number of passengers per vehicle, and trip distances for drive alone, carpool, vanpool, GenenBus and
motorcycle transportation modes, as well as vehicle deliveries. These data were used to calculate the number
of new trips, the percentage of trips for each mode of transportation, and average trip length. Emissions from
each of these trip types were obtained using EMFAC2014, based on emission rates per trip type as derived
from the vehicle fleet mix in San Mateo County. Using the same trip data, fugitive PM10 and PM2.5 road dust
emissions were estimated in accordance with CARB-approved methodologies.
Total Criteria Air Pollutants
Operational emissions of criteria air pollutants from each of the Project’s operational sources were added
together to derive total emissions values. Table 6-6 shows the emissions of criteria air pollutants as
10 Fehr & Peers, Traffic Impact Analysis, October 2018
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Genentech Master Plan Update, Draft EIR Page 6-31
estimated for the Project, compared to the applicable significance thresholds. Emissions from those sources
that will be capped and offset through the BAAQMD’s stationary source permitting are not included in the
operational emissions. The incremental emissions for NOx, ROG and PM10 are above significance thresholds,
mostly due to NOx and PM10 emissions from mobile sources, and emission of VOCs from laboratory and
consumer products.
Table 6-6: Operational Criteria Air Pollutant Emissions
Emission Category 1 ROG (tons/yr) NOx (tons/yr) PM10 (tons/yr) PM2.5 (tons/yr)
Laboratory 9.7
Misc. natural Gas Combustion 0.88 6.0 1.2 1.2
Mobile Sources 7.9 12 15 3.5
Architectural Coatings 2.0 0 0 0
Consumer Products 15 0 0 0
Landscaping 0.003 0.0003 0.0001 0.0001
Total: 35 18 16 4.8
Threshold Level 10 10 15 10
Exceed Threshold? Yes Yes Yes No
Other Operational Emissions Requiring a Separate Permit
IPA Wipe Cleaning 13 0 0 0
Emergency Generators 1.0 19 0.062 0.062
Miura Boilers 1.1 2.2 1.5 1.5
CHP 13 5.8 0.1 0.1
Total: 28 27 1.7 1.7
1. Emissions from architectural coating, consumer products and landscaping are calculated by CalEEMod® using the building square
footage information provided in the Project Description
Source: Ramboll, October 2018
Emission Reductions Incorporated into the Project
Mobile Source Reductions
As part of the Project, Genentech is proposing to establish a “Trip Cap” equivalent to the number of drive-
alone vehicle trips that have been analyzed pursuant to prior Campus Master Plan approvals, while increasing
the underlying entitlement from approximately 6.8 million square feet, 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. Genentech proposes to implement TDM programs for all of its employees at levels that can reduce
drive-alone trips such that the Trip Cap is not exceeded. 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. The strategies included in Genentech’s
updated TDM Plan are designed to build upon the success of existing programs, provide for improvement
where needed, and to offer options for new measures that further increase employee travel choice and
improve the user experience. A brief summary of proposed TDM strategies includes:
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Page 6-32 Genentech Master Plan Update, Draft EIR
● Genentech will continue to operate commuter GenenBus routes for employees who live throughout
the San Francisco Bay Area, connecting employees from Alameda, Contra Costa, Marin, Santa Clara,
San Francisco, San Mateo and Solano Countries to the South San Francisco Campus
● Genentech will continue to operate the intra-campus DNA Shuttle routes for employees to travel
between Campus buildings, parking facilities and GenenBus stops
● Genentech has initiated, and will continue to offer a stand-alone ferry service to markets unserved
by public ferry operators, using private high-speed vessels to provide exclusive ferry service for
commuting employees
Genentech will continue to offer a suite of incentive-based TDM programs to encourage non-single
automobile travel. The TDM program includes, but is not limited to transit reimbursements, carpool and
vanpool incentives, car- sharing programs, a Guaranteed Ride Home program, flexible daily work schedules,
incentives for walking or biking to work, on-site bicycle facilities, funding for important bikeway
improvements, and offering preferred parking for vehicle types that reduce emissions as compared to
traditional autos.
These TDM Program strategies will substantially reduce emissions of criteria air pollutants from operational
mobile sources, as compared to emission levels that would be expected without such a robust TDM program.
Area Source Reductions
Pursuant to Genentech’s Sustainability Strategic Plan, ongoing sustainability initiatives include installing a
Campus-wide system for refrigerated water distribution, installation of new industrial chillers, replacement of
air conditioning equipment and other industrial process efficiencies that may reduce natural gas
consumption by as much as 700,000 therms per year, thereby reducing associated criteria pollutants as well.
Regulatory Requirements
Stationary sources that are subject to permitting by the BAAQMD are required to be offset per BAAQMD
Regulation 2-2: New Source Review, Section 302: Offset Requirements, if the facility emits or is permitted to
emit greater than 35 tons per year of NOx and ROGs. Genentech is permitted to emit greater than 35 tons
per year of both NOx and ROG, and is therefore required to submit emissions offsets for every new permitted
source or emissions modification that results in increased emissions. Offsets are established at a 1.15 to 1.0
ratio.
Regulatory Requirement AQ 4 - New Source Review Offset: Genentech shall purchase offset credits
pursuant to BAAQMD Regulation 2-2: New Source Review, Section 302: Offset Requirements for
each new permitted stationary source of NOx and/or ROG emissions, and for any modifications to
existing stationary emission sources that result in increased NOx and/or ROG emissions.
The BAAQMD's offset program is intended to ensure a no net increase of NOx and ROG emissions in the San
Francisco Bay Area. The purchase and retirement to the BAAQMD of offsets ensures that new emissions are
balanced by federally enforced emission reductions or emissions source removals.
Mitigation Measures
No additional measures are available or feasible.
Resulting Level of Significance
The Project incorporates numerous features in its design that will serve to reduce operational emissions of
criteria pollutants from that which would otherwise be generated, and the BAAQMD offset program will
ensure a no net increase of NOx and ROG emissions from stationary sources. Although these TDM measures,
energy efficiency features and regulatory requirements are incorporated into the Project, total emissions of
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Genentech Master Plan Update, Draft EIR Page 6-33
criteria pollutants from mobile sources and other sources not requiring separate permits form BAAQMD
would still exceed the thresholds of significance. There are no additional quantifiable and feasible mitigation
measures capable of further reducing these emissions, and this impact would remain significant and
unavoidable.
Potential Health Impacts of the Project’s Criteria Pollutant Emissions
A separate analysis was conducted to estimate the potential health impacts of criteria pollutants, specifically
oxides of nitrogen (NOx), volatile organic compounds (VOC), ozone, particulate matter smaller than 2.5
microns in diameter (PM2.5), and oxides of sulfur (measured as sulfur dioxide (SOx). As discussed further
below, the results of the analysis indicate that anticipated health impacts are vanishingly small.
In order to estimate the potential health impacts of criteria pollutants emitted by the Project, a
photochemical grid model (PGM) known as CAMx was applied to estimate the small increases in
concentrations of ozone and PM2.5 in the region that would result from the emissions of criteria pollutants
from the Project. A USEPA-authored program known as the Benefits Mapping and Analysis Program
(BenMAP) was then applied to estimate the resulting health impacts from these small increases in
concentration. BenMAP uses concentration estimates along with population and health effect
concentration/response functions to estimate various health effects of the concentration increases. BenMAP
has a wide history of applications by EPA and others, including for local-scale analysis as needed for assessing
the health impacts of a project’s emissions. The details of this methodology and resulting calculations are
provided in Appendix 6E.
The incidences for assessing the health effect concentration/response (or endpoints) related to PM2.5
concentrations include mortality (all causes), hospital admissions (respiratory, asthma, cardiovascular),
emergency room visits (asthma) and acute myocardial infarction (non-fatal). The endpoints used to measure
the health effects for ozone are mortality, emergency room visits (respiratory) and hospital admissions
(respiratory).
The estimated PM2.5-related health outcomes for the Project are less than one additional incidence of
asthma-related emergency room visits, asthma-related hospital admissions, all cardiovascular-related
hospital admissions (not including myocardial infarctions), all respiratory-related hospital admissions,
mortality, and nonfatal acute myocardial infarction. The estimated ozone-related health outcomes are less
than one additional incidence for all respiratory-related hospital admissions, mortality, and asthma-related
emergency room visits for any age range. For all these health endpoints, the number of estimated incidences
is less than 0.0015% of the baseline number of incidences, where the “baseline incidence” is the actual
incidence of health effects as measured in the local population in the absence of additional emissions from
the Project (i.e., a 0.0015% increase in asthma induced emergency room visits for the 0-17 age group, above
what would occur in the absence of the Project). The health impacts estimated using this methodology
conservatively presume that health impacts seen at larger concentration differences can be linearly scaled
down to smaller increases in concentrations, such as those small concentrations that result from the Project.
This methodology of linearly scaling impacts is broadly accepted for use in regulatory evaluations and is
considered as being health protective. The health impacts associated with criteria pollutant emissions from
the Project are conservatively estimated, and the actual impacts may be zero.
Operational Health Risks
AQ 5: During operational activities, the Project could expose sensitive receptors to substantial health risk
from operational-related emissions if operational sources of TAC emissions are not limited in
location and operational parameters. (Less than Significant with Mitigation)
As was analyzed for construction emissions, sensitive receptors evaluated in this analysis include daycare
receptors, residential receptors to the north (houseboats in the Oyster Point Marina) and recreational
Chapter 6: Air Quality
Page 6-34 Genentech Master Plan Update, Draft EIR
receptors on the San Francisco Bay Trail. The criterion for whether or not the Project’s operations activities
presents a significant air quality impact is if the Project will “expose sensitive receptors to substantial
pollutant concentrations,” expressed as excess cancer risk exceeding 10 in 1 million, hazard index greater
than 1.0 or annual PM2.5 concentrations that exceed 0.3 µg/m3 at sensitive receptor locations.
Operational activities related to the Project may vary depending on a number of factors including varying site
locations for operational emission sources, so this analysis estimates health impacts using conservative and
present-day assumptions. These conservative assumptions are not meant to reflect actual anticipated
operations. Rather, these assumptions provide bounds within which operational activities have been
analyzed. Operations that fall outside of these assumptions do not necessarily imply a new or more
significant impact from air toxics. Rather, it indicates that a detailed health risk analysis with refined project
information should be conducted to determine whether air toxic impacts would be significant based on the
unique or particular aspects specific to an operation or emission source that is not addressed in this analysis.
Emission Sources
The potential sources of future additional emissions of toxic air contaminants (TAC) used in this analysis
include TAC emissions from laboratory operations, emissions from diesel emergency generators (DPM and
PM2.5), and emissions from natural gas combustion at the potential CHP and the four Miura boilers.
● Laboratory emissions encompass the list of all toxic chemicals that are emitted by current laboratory
operations, and their relative emission rates (see Appendix 6B).
● The TAC emissions from natural gas combustion at the potential CHP were calculated from the
emission factors provided in the California Air Toxic Emission Factor database (see Appendix 6A).
Installation of a new CHP is dependent on future needs, as well as feasibility and cost studies yet to
be prepared. If ultimately proposed, a new CHP would require permits from the BAAQMD and would
be required to comply with applicable Best Available Control Technology (BACT), including BACT for
toxics requirements.
● The TAC emissions from four Miura boilers are calculated based on the BAAQMD Permit Handbook
for non-PM2.5 emissions, and PM2.5 emissions were calculated based on AP-42 emission factors.
● DPM emissions from future emergency generators are calculated based on emission factors from
ARB engine certifications. Emissions of PM10 are conservatively assumed equal to emissions of DPM.
Figure 6-4 indicates the locations assumed for all TAC emission sources. Appendix 6D shows the emission
rates used for the operational health risk assessment.
On-road vehicle traffic will also contribute to the Project’s operational TAC emissions The BAAQMD Roadway
Screening Analysis Calculator was used along with Project-specific data to estimate PM2.5 emissions and
concentrations from on-road traffic. The Screening Calculator provides screening risk estimates for surface
roadways. Two roadways located within 1,000 feet of the Project Area are estimated to have average daily
traffic greater than 5,000 vehicles per day (East Grand Avenue and Forbes Avenue/Gull Drive). Contributions
to health risks (i.e., cancer risk and PM2.5 concentration) of sensitive populations were estimated from these
roadways, based on the distance to the closest sensitive receptor for each of the three population types.
Table 6-7 shows the results of the on-road traffic screening analysis.
Source: Genentech and Ramboll 2018Figure 6-4Modeled Toxic Air Contaminant SourcesNew Parking StructureGathering SpacePrimary Pedestrian ConnectionExisting BuildingNew BuildingPartial Street ClosureVertical CirculationMajor GatewayStreetscape ImprovementsLLLLLLLLLLLLLLLegend:Future Lab Locations New Miura BoilersPotential CHPEvaluated Roadway Emissions Emergency Generators, throughoutL
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Page 6-36 Genentech Master Plan Update, Draft EIR
Table 6-7 Roadway Screening Health Risk Analysis 1
Receptor Type Nearest Roadway Avg. Daily Traffic
Cancer Risk (per
million) PM2.5 (ug/m3)
Daycare (all) East Grand Ave. 11,101 1.2 0.046
Resident Gull Drive 1,881 1.05 0.019
Recreation Forbes Boulevard 11,101 0.47 0.10
1. Estimated using the BAAQMD Roadway Screening Analysis Calculator where the inputs are: distance from the roadway, side of
the roadway and ADT
Average daily trip rate as provided by Traffic Impact Analysis, Fehr & Peers
Source: Ramboll, October 2018
Assumptions Used in HRA Modeling
The modeling for near-field air dispersion TAC and PM2.5 emissions from the Project’s operational sources
was conducted using the USEPA AERMOD model. For each identified receptor location, the model generates
average air concentrations that would result from emissions from each of the multiple emission sources.
Maximum hourly dispersion factors were also estimated at each receptor location to estimate the acute
health index (HI). Air dispersion models such as AERMOD require a variety of inputs such as source
parameters, meteorological parameters, topography information, and receptor parameters. When site-
specific information was unknown, default parameters were used. These default parameters are designed to
produce conservative (i.e., overestimated) air concentrations.
Many of the assumptions for the air dispersion modeling of operational TAC emissions are similar to
assumptions used for modeling of construction-period emissions. These similar assumptions include
meteorological data, terrain considerations, the locations of sensitive receptors, modeling adjustment factors
based on exposure duration, exposure assumptions, intake factors for exposure pathways, age sensitivity
factors and intake exposure pathways. Assumptions specific to operational emission analysis include the
following:
● Emission Rates: In the operational model, all hours of the day are included. Although operational
emissions primarily occur during the daytime, emissions can theoretically occur at any hour of the
day.
● Source Parameters: The potential CHP and the four Miura boilers were modeled as point sources.
The prospective emergency generator sources were modeled a point source grid overlaying the
Opportunity Sites. The locations of the prospective laboratory stacks were identified, and the
modeling source parameters for the prospective laboratory stacks were determined based on the
most conservative set of parameters (e.g., lowest stack height, release temperature and velocity)
from representative laboratories (see Appendix 6A).
● Receptors: For the annual average impacts (i.e., cancer risk, chronic HI and PM2.5 concentration),
the same receptor locations used for the construction health risk was used for the operational health
risk. However, for the maximum hourly impact analysis (i.e., acute HI), sensitive populations can
theoretically be at any location for up to an hour. In addition to the locations modeled for the annual
analysis, two additional grids were added to the model, and used for the acute HI analysis. All
impacts evaluated for this analysis attribute outdoor air concentrations at all modeled receptor
locations. This is conservative because many of the modeled sensitive receptors are located indoors,
and indoor air concentrations are typically lower than outdoor air concentrations.
● Modeling Adjustment Factors: Modeling adjustment factors were applied to estimate the exposure
levels (based on annualized average concentrations of TAC emissions) to recreational and daycare
Chapter 6: Air Quality
Genentech Master Plan Update, Draft EIR Page 6-37
populations. These adjustments assume a typical operational workweek of 5 days, and a typical
operational workday of 12 hours, and represent the concentrations to which the daycare child or
offsite recreational receptor might be exposed to operational emissions over the operating period.
The operational parameters covered in this analysis are shown in Table 6-8. The assumed locations for future
laboratories, Miura boilers and the potential CHP are as indicated in Figure 6-4. The per-laboratory emission
rates were estimated by averaging the emission rates for all existing laboratory buildings that are known to
emit each chemical. This health risk assessment assumes that all new laboratory buildings will have at least
two stacks (conservative assumption based on existing laboratory characteristics), so the per-stack emission
rates were calculated by dividing the per-building emission rates by two.
Table 6-8: Operational Parameters for TAC Emission Calculations
Source # of Sources Stack Height (m) Stack Temp (k)
Stack Velocity
(m/s)
Stack Diameter
(M)
Labs 34 20 287 13 1
Generators 492 2.2 679 29 0.46
Miura Boilers 4 12 422 16 1.1
CHP 1 12 422 16 1.1
Notes:
1. The modeling source parameters for the prospective laboratory stacks were determined based on the most conservative set of
parameters (e.g., lowest stack height, release temperature and velocity) from representative laboratories (South Campus and FRC II
laboratory buildings). The locations and number of prospective laboratory stacks were provided per the Project Description
2. Modeling parameters for the emergency generators were determined based on the most conservative set of parameters from the
last 10 generators permitted at Genentech. The generator sources were placed 30 meters apart throughout all of the Opportunity
Sites.
3. The modeling parameters for the Miura boilers and the combined heat and power plant were obtained from Genentech (see
Appendix 6D)
Estimated Operational TAC Concentrations
The analysis of health risk concludes that as long as the emergency generators and laboratory stacks are
located in certain areas and operated within certain parameters, operational cancer risk, health index and
PM2.5 concentrations would not exceed health risk thresholds. The analysis considers operational
parameters and potential locations of emissions sources based on best available information at the time, but
it is possible that other variations could be proposed in the future. Therefore, mitigation measures are
included to address the potential for specific project changes outside the locations and operational
parameters identified.
Figure 6-5 identifies the locations where the modeling shows that laboratory stacks could be located such
that health risk would be below the significance thresholds at all sensitive receptor locations. Per Figure 6-5,
laboratory stacks could be located on 79% of all modeled locations (Opportunity Sites anticipated under the
Project Description as potential future lab locations) without the need for a separate health risk analysis.
Similarly, Figure 6-6 provides the analogous map for emergency generators laboratory stack locations. Based
on this figure, generators can be located on approximately 67% of all modeled locations (Opportunity Sites)
without the need for a separate, refined health risk analysis.
Source: Ramboll 2018Figure 6-5Laboratory Stack Locations, Health Risk Implications Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User CommunityOperational Scenario Laboratory Combined MapGenentech, Inc.South San Francisco, CaliforniaDRAFTED BY:DATE: 10/11/2018FIGUREAQ-15PROJECT01,000500FeetLegendModeling BoundaryPotential Future Laboratory LocationsWould Not Contribute to Significant ImpactMay Contribute to Significant ImpactThe green points represent locations where placing laboratory stacks would not contribute to a significant total operational impact (which also include contributions from Project laboratories, emergency generators, onroad traffic, the 4 Miura boilers, and the CHP) if laboratories were to be in operation on all green points in any given year.The blue points represent locations where additional laboratory activities beyond the locations with the green points in the sameyear could contribute to a significant impact.Operational health risk analysis is based on conservative and generalized assumptions such as laboratory stack's physical parameters and emissions. Project-specific assumptions can result in lower health risk impacts.Figure Notes:DRAFTPrivileged and Confidential Attorney Work Product
Source: Ramboll 2018Figure 6-6Emergency Generator Locations, Health Risk Implications Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User CommunityOperational Scenario Generator Combined MapGenentech, Inc.South San Francisco, CaliforniaDRAFTED BY:DATE: 10/11/2018FIGUREAQ-19PROJECT01,000500FeetLegendPotential Future Generator LocationsWould Not Contribute to Significant ImpactMay Contribute to Significant ImpactModeling BoundaryThe green points represent locations where placing emergency generator stacks would not contribute to a significant total operational impact (which also include contributions from Project laboratories, emergency generators, onroad traffic, the 4 Miura boilers, and the CHP) if emergency generators were to be in operation on all green points in any given year.The blue points represent locations where additional emergency generator activities beyond the locations with the green points in the same year could contribute to a significant impact.Operational health risk analysis is based on conservative and generalized assumptions such as emergency generator stack's physical parameters and emissions. Project-specific assumptions can result in lower health risk impacts.Figure Notes:DRAFTPrivileged and Confidential Attorney Work Product
Chapter 6: Air Quality
Page 6-40 Genentech Master Plan Update, Draft EIR
Figures 6-5 (Laboratories) and 6-6 (Emergency Generators) each take into account the health risks associated
with all other sources of TAC emissions, and include contributions of emissions from roadway sources, Miura
boilers and the potential CHP, if laboratories and emergency generators were to be in operation on all green
points in any given year. The results presented in these figures include only impacts from Project sources, and
do not include any impacts from cumulative sources (i.e., other sources within 1,000 feet of the Project). The
blue points represent locations where additional laboratory activities or emergency generators beyond the
locations with the green points, operating during the same year, may contribute to a significant impact based
on conservative assumptions. Operations in the blue areas does not necessarily result in a significant impact,
but does indicate that additional refined modeling will be needed to determine if impacts are significant.
Table 6-9 shows the additive impacts from those operational emissions attributed to all operational sources,
under a scenario where no emission sources are located in areas where they would individually exceed
threshold levels. As indicated, no health risk threshold levels are exceeded (i.e., impacts are below significant
thresholds) under this limited scenario.
Table 6-9: Operational Health Risk Assessment, at Sensitive Receptors 1
Receptor Type Cancer Risk (per million) 1 Threshold (per million)
Daycare (Genentech) 9.9 10
Daycare (Early Years) 1.3 10
Recreational (on Bay Trail) 7.6 10
Residential (Boathouses at Oyster Point
Marina) 8.6 10
Non-Cancer Health Impacts 2 Value Threshold
Chronic Health Index 0.28 1.0
Acute Health Index 0.94 1.0
PM2.5 Concentration 0.24 ug/m3 0.30 ug/m3
1. The impacts are estimated with operation from 4 Miura boilers, CHP, Project mobile sources, locations of laboratories that
would not contribute to significant impact (as shown in Figure 6-5), and locations of emergency generators that would not
contribute to significant impacts (as shown in Figure 6-6),.
2. The maximum chronic HI and PM2.5 concentrations occur on the San Francisco Bay trail next to Forbes Boulevard.
Source: Ramboll, October 2018
Mitigation Measures
The following Mitigation Measures define the limitations (or boundaries) applicable to the assessment of
operational health risk impacts as conducted for this EIR:
Mitigation Measure AQ 5A - Parameters for Operational Emissions: New operational sources of TAC
emissions (i.e., emergency generators, laboratories with emissions stacks, or natural gas combustion
at the Miura boilers or potential CHP) shall operate within the operational parameters as used in this
analysis (as shown in Table 6-9). For any operational source of TAC emissions that does not operate
within these parameters, a subsequent, project-specific health risk analysis shall be performed. Any
such subsequent, project-specific health risk analysis must be able to demonstrate that the proposed
operational source of TAC emissions would not contribute to new or substantially more significant
health risks to sensitive receptors than those health risks presented in this EIR. This conclusion may
Chapter 6: Air Quality
Genentech Master Plan Update, Draft EIR Page 6-41
account for any additional project-specific measures to reduce TAC emissions included as part of
such an emission source.
Mitigation Measure AQ 5B - Locational Restrictions on Future Operational Emission Sources: Emergency
generators and laboratories with emissions stacks shall be limited to those locations as shown on
Figure 6-5 (for laboratories) or Figure 6-6 (for emergency generators), where their operations have
been demonstrated to not exceed health risk thresholds. For any operational source of TAC
emissions that are located outside of these locations, a subsequent project-specific health risk
analysis shall be performed. Any such subsequent, project-specific health risk analysis must be able
to demonstrate that the proposed location would not contribute to new or substantially more
significant health risks to sensitive receptors than those health risks presented in this EIR. This
conclusion may account for any additional project-specific measures to reduce TAC emissions
included as part of such an emission source.
Resulting Level of Significance
This analysis provides for several significance conclusions:
● First, operational source of TAC emission that operate within the emission parameters used in this
analysis can be located on any of those Opportunity Sites shown on Figures 6-5 and 6-6 as not
contributing to operational-period health risks without having to conduct further project-specific
analysis. Health risk impacts resulting from such emission sources and sited at these locations would
be less than significant.
● Secondly, individual projects that include new sources of operational TAC emissions that would
operate outside of the operational parameters used in this EIR may only be initiated after
preparation of a subsequent project-specific health risk analysis. Only those projects that can be
demonstrated as not contributing to a new or more significant health risk to sensitive receptors
(potentially accounting for any additional project-specific measures to reduce TAC emissions) can be
considered as having been addressed in this EIR. Health risk impacts resulting from such emission
sources would also be less than significant, pending affirmative conclusions of subsequent project-
specific health risk analyses.
● Third, individual projects that include new operational sources of TAC emissions and that are sited at
locations not shown on Figure 6-5 (for laboratories) or Figure 6-6 (for emergency generators) may
only be initiated after preparation of a subsequent project-specific health risk analysis. Only those
projects that can be demonstrated as not contributing to a new or more significant health risk to
sensitive receptors due to their location (potentially accounting for any additional project-specific
measures to reduce TAC emissions) can be considered as having been addressed in this EIR. Health
risk impacts resulting from emission sources at these locations would also be less than significant,
pending affirmative conclusions of subsequent project-specific health risk analyses.
Operational source of TAC emissions that would operate outside of the emissions parameters used in this
analysis, or that would be located on any Opportunity Site shown on Figures 6-5 and 6-6 as contributing to
operational-period health risks have not been fully analyzed. Such operational sources should undergo
subsequent project-specific analysis and affirmatively demonstrate that no new or more significant health
risk to sensitive receptors would occur beyond those analyzed or considered in this EIR.
Cumulative Health Risk
AQ 6: The Project would not contribute at a significant level to a cumulatively considerable health risk
impact. Specifically, the TAC emissions generated by the Project, when added to TAC emissions from
all local sources within 1,000-foot zone of influence, would not result in an excess cancer risk level of
Chapter 6: Air Quality
Page 6-42 Genentech Master Plan Update, Draft EIR
more than 100 in 1 million, a hazard index greater than 10, or a concentration greater than 0.8
μg/m3 annual average PM2.5. (Less than Cumulatively Significant)
The following provides an analysis of cumulative health risks (cumulative cancer risk and cumulative PM2.5
concentrations) that would accrue to the nearest maximum exposed individual sensitive receptor (MEIR),
resulting from implementation of the Project (construction and operation) plus all nearby sources in the
surrounding area. Nearby sources in the surrounding area includes permitted stationary sources (e.g.,
emergency generators and boilers), roadway traffic sources, and truck idling emissions at the nearby UPS and
Blue Line Transfer, Inc. facilities.
Off-Site Stationary Sources
A number of stationary sources of TAC emissions are located off-site, but within 1,000 feet of the Project
Area. These existing off-site stationary sources were included in the cumulative TAC emissions analysis based
on:
● the BAAQMD Risk Analysis Tool, which lists permitted stationary sources, as well as their maximum
screening-level cancer risk, chronic HI, and PM2.5 concentrations
● data provided by the BAAQMD for facilities where maximum screening level cancer risk, chronic HI,
and PM2.5 concentrations were not readily available from the Risk Analysis Tool
● the contributions to PM2.5 concentrations specific to Blue Line Transfer Inc. facility were derived by
performing a screening model analysis using USEPA’s SCREEN3 model and emission rates for the
facility as obtained from BAAQMD
● adjustments for TAC emission concentrations from known gasoline dispensing facilities, based on the
distance from the facility to the MEISRs assessed in this analysis, using the BAAQMD’s Diesel Internal
Combustion (IC) multiplier tool,
● adjustments for TAC emission concentrations from known for gasoline dispensing facilities, based on
the distance from the facility to sensitive receptors was assessed in this analysis using the BAAQMD’s
Gasoline Dispensing Facility (GDF) Distance Multiplier tool, and
● additional adjustment factors relying on exposure assumptions for the different population types,
using recently developed 2015 OEHHA guidance
Existing Genentech Stationary Sources
The contribution to cancer risk from Genentech’s existing TAC emission sources was provided by Genentech,
as included in Appendix 6A.
Concentrations of PM2.5 emissions from existing emergency generators and boilers were derived from
emission rates for each facility, and concentrations were estimated based on the BAAQMD’s Beta calculator
tool (Version 1.3 beta) to estimate PM2.5 concentrations. Emissions from existing Genentech boilers were
obtained based on known emission rates per boiler, modeled using AERMOD to obtain the PM2.5
concentrations at all sensitive receptors.
Other Existing Sources
● Roadway Sources: The cumulative analysis includes vehicle TAC emissions from all roadways with
over 5,000 vehicles per day, or 500 trucks per day on roadways located within 1,000 feet from
sensitive receptors identified in this analysis. Similar to stationary sources, the screening risks for
roadway sources were adjusted to be consistent with 2015 OEHHA guidance.
● Truck Idling: Emissions from truck idling activities at the UPS and Blue Line Transfer Inc. facilities
were estimated using daily trip count information from the Traffic Analysis prepared for this EIR, an
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Genentech Master Plan Update, Draft EIR Page 6-43
assumed idling time of 5 minutes per trip (consistent with ARB’s limit on Diesel-Fueled Commercial
Motor Vehicle Idling), and a conservative dispersion factor using the SCREEN3 model.
Cumulative Analysis Results
Table 6-10 shows the cumulative (combined) cancer risk and PM2.5 concentration from all existing and
nearby sources, and all Project sources, compared against cumulative thresholds. As shown in this table:
● the cumulative cancer risks at all sensitive receptor locations analyzed are below the cumulative
threshold of 100 in a million, but
● the cumulative PM2.5 concentrations at all sensitive receptor locations are significantly above the
cumulative threshold of 0.8 µg/m3
Note that the Project’s maximum contribution to cumulative health risks at each sensitive receptor is
different under each type of analysis, or scenario. Under the operational scenario, the Project’s contribution
to cancer risk is greatest at the Genentech Daycare Center and the Project’s contribution to PM2.5
concentrations is greatest at the Bay Trail. Under the construction scenario, the Project’s contribution to
cancer risk is greatest at the Genentech Daycare Center and the Project’s contribution to PM2.5
concentrations is greatest at the Early Years preschool. For the construction scenario, all emissions are
greatest under the unmitigated scenario, and are improved with mitigation.
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Page 6-44 Genentech Master Plan Update, Draft EIR
Table 6-10: Cumulative Operational Health Risk Assessment, at Sensitive Receptors 1
Operational Scenario
Genentech Daycare
(Cancer Risk per million)
Bay Trail
(PM2.5 Concentrations (ug/m3)
Existing Off-Site Stationary Sources 21 1.20
Truck Idling 6.8 0.01
Surface Streets NA
Existing Genentech Sources 10 0.10
Plus Project Emissions 9.9 0.24
Total: 48 1.5
Thresholds: 100 0.8
Exceed Threshold? No Yes
Construction Scenario
Not Mitigated-
Genentech Daycare
(Cancer Risk per million)
Not Mitigated -
Early Years Daycare
(PM2.5 Concentrations (ug/m3)
Existing Off-Site Stationary Sources 23 1.20
Truck Idling 5.1 0.004
Surface Streets 0.038
Existing Genentech Sources 10 0.031
Plus Project Emissions 10 0.012
Total: 48 1.3
Thresholds: 100 0.8
Exceed Threshold? No Yes
Source: Ramboll, October 2018
The largest contribution to PM2.5 concentration in the surrounding area is from the Blue Line Transfer Inc.
transfer station (an existing off-site stationary source). By itself, this facility’s contributions are 1.2 to 1.5
µg/m3 depending on the locations of the measured sensitive receptor. All other sources combined (including
the Project) contribute to a concentration of less than 0.2 µg/m3. The PM2.5 concentrations from the Blue
Line Transfer Inc. facility were estimated using SCREEN3 methodology that includes many conservative
assumptions. The actual PM2.5 concentration values for this facility are likely much lower because the
reported concentrations represent total PM (i.e., all sizes of particulate matter) including particulate matter
greater than 2.5 microns in size, which likely drop out of the atmosphere well before mixing with other
source emissions at more distant sensitive receptor locations. Eliminating these conservative assumptions
from the modeling would likely have reduced the calculated PM2.5 concentration from the Blue Line Transfer
Inc. facility significantly.
The Project’s contribution to cancer risks and PM2.5 concentrations at all measured sensitive receptors,
when added to other cumulative sources, do not result in exceeding a cumulatively threshold that is not
already exceeded, and therefore are considered less than cumulatively significant.
Mitigation Measures
None needed, beyond those identified for the Project’s individual TAC emissions under both operations and
construction scenarios.
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Genentech Master Plan Update, Draft EIR Page 6-45
Cumulative Air Quality Effects
Other than the individual health risks from toxic air pollutants presented above, air pollution is largely a
cumulative impact. Emissions from past, present, and reasonably foreseeable future projects all contribute to
the region’s air quality on a cumulative basis. However, no individual project by itself is of sufficient size to
cause regional non-attainment of ambient air quality standards. Thresholds for air quality impacts as used in
this EIR are set such that projects meeting the thresholds are not considered to lead to cumulatively
considerable air quality impacts. Air quality emissions associated with the Project would make a cumulatively
considerable contribution to significant cumulative air quality impacts if they exceed these thresholds. As
indicated in the analyses above, the Project will result in a cumulatively considerable contribution to
significant cumulative impacts on air quality. These cumulative air quality impacts can adversely affect the
entire San Francisco Bay Area Air Basin.
Ambient Air Quality Standards
The San Francisco Bay Area Air Basin is currently designated as nonattainment for ozone, PM10 and PM2.5.
Since the Project’s emissions of criteria pollutants (i.e., PM10, PM2.5, and the ozone precursors NOx and
ROG) from construction and operation of the Project exceeds threshold levels, impacts of the Project due to
the emission of non-attainment pollutants is considered cumulatively considerable. The Project incorporates
numerous features in its design that will serve to reduce operational emissions of criteria pollutants,
including a TDM program that exceeds local requirements and implementation of energy efficiency features
in future building designs. The Project’s participation in the BAAQMD offset program will also ensure a no net
increase of NOx and ROG emissions from stationary sources. Although these TDM measures, energy
efficiency features and regulatory requirements are incorporated into the Project, total emissions of criteria
pollutants from mobile sources and other sources not requiring separate permits from the BAAQMD would
still exceed the thresholds of significance. There are no additional quantifiable and feasible mitigation
measures capable of further reducing these emissions, and the Project would make a substantial contribution
to cumulatively significant and unavoidable air quality impacts.
Construction-period Emissions
Throughout buildout of the Project, construction activities would result in emissions of criteria pollutants for
which the region is non-attainment, including releasing emissions of ozone precursors and particulates. These
construction-period emissions would combine with emissions from other cumulative construction project
and other cumulative operational emissions to affect regional air quality. However, with implementation of
Basic BMPs as identified in this EIR at all of the Project’s construction activities and additional BMPs for those
construction projects that exceed screening criteria, the Project’s construction emissions would be unlikely to
exceed applicable thresholds, and thus not considered cumulatively significant.
Objectionable Odors
Increased traffic, maintenance equipment operations and application of architectural coatings associated
with the long-term operations of land uses within the East of 101 area are unlikely to create objectionable
odors, such that more than five confirmed complaints per year averaged over three years would likely be
received. The Project would have a less than cumulatively considerable contribution to significant
cumulative odor impacts.