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HomeMy WebLinkAbout06_Other CEQA 751 Gateway Boulevard Project 6-1 September 2020 ICF 0662.19 Chapter 6 Other CEQA Considerations This chapter discusses mandatory findings of significance pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15065(a). This chapter also discusses significant environmental effects that cannot be avoided as identified in this Environmental Impact Report (EIR); significant irreversible environmental changes, including energy and consumption of nonrenewable resources; and growth-inducing impacts pursuant to CEQA Guidelines Section 15126.2. 6.1 Mandatory Findings of Significance CEQA Guidelines Section 15065(a) requires a lead agency to find that a project may have a signficant effect on the environrment and thereby require an EIR if that project has the potential to have particular impacts, as described below. 6.1.1 Quality of the Environment CEQA Guidelines Section 15065(a)(1) requires a lead agency to find that a project may have a signficant effect on the environrment and thereby require an EIR if that project “has the potential to substantially degrade the quality of the environment.” This EIR, in its entirety, addresses and discloses all potential environmental impacts associated with construction and operation of the proposed project, including direct, indirect, and cumulative impacts. As described in Chapter 4, Environmental Setting, Impacts, and Mitigation, the proposed project would have no impact or a less-than-significant impact associated with aesthetics, agricultural and forest resources, energy, geology and soils (including seismic hazards), hazards and hazardous materials, hydrology, land use, mineral resources, population and housing, public services, recreation, utilties, and wildfire. Environmental impacts associated with air quality, biological resources, cultural resources (including tribal cultural resources), geology and soils (including paleontology), greenhouse gas (GHG) emissions (exept vehicle miles traveled [VMT] impacts), noise and vibration, and transportation and circulation (except VMT impacts) are considered less than significant or less than significant with mitigation. Transportation and circulation and GHG emissions impacts related to VMT are considered significant and unavoidable, as discussed in Section 6.3, Significant Environmental Effects that Cannot Be Avoided. Based on the potential impacts of the project related to transportation and circulation and GHG emissions, the proposed project would have the potential to degrade the quality of the environment, 6.1.2 Impacts on Species CEQA Guidelines Section 15065(a)(1) states that a lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR where there is substantial evidence that the project has the potential to (1) substantially reduce the habitat of a fish or wildlife species; (2) cause a fish or wildlife population to drop below self-sustaining levels; or (3) substantially reduce the number or restrict the range of an endangered, rare, or threatened City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-2 September 2020 ICF 0662.19 species. Section 4.3, Biological Resources, of this draft EIR addresses any impacts that might relate to the reduction of fish or wildlife habitat, the reduction of fish or wildlife populations, and the reduction or restriction of the range of special-status species as a result of project implementation. The proposed project would have no impact, a less-than-significant impact, or a less-than-significant impact with mitigation with respect to biological imapcts and, therefore, would not have the potential to substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or substantially reduce the number or restrict the range of a rare or endangered plant or animal. 6.1.3 Impacts on Historical Resources CEQA Guidelines Section 15065(a)(1) states that a lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR where there is substantial evidence that the project has the potential to eliminate important examples of a major period of California history or prehistory. CEQA Guidelines Section 15065(a)(1) amplifies Public Resources Code Section 21001(c) by requiring preservation of major periods of California history for the benefit of future generations. It also reflects the provisions of Public Resource Code Section 21084.1 in requiring a finding of significance for substantial adverse changes to historical resources. CEQA Guidelines Section 15064.5 establishes standards for determining the significance of impacts to historical resources and archaeological sites that are an historical resource. Section 4.4, Cultural Resources, of this draft EIR addresses impacts related to California history and prehistory, historic resources, archaeological resources, and tribal cultural resources. Section 4.6, Geology and Soils, of this draft EIR addresses impacts related to paleontological resources. The proposed project would have either no impact or a less-than-significant impact with mitigation with respect to cultural resources, tribal and cultural resources, and paleontological resources and, therefore, would not have the potential to eliminate important examples of the major periods of California history or prehistory. 6.1.4 Long-Term Impacts CEQA Guidelines Section 15065(a)(2) states that a lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR where there is substantial evidence that the project has the potential to achieve short-term environmental goals to the disadvantage of long-term environmental goals. Section 6.3, Significant Environmental Effects that Cannot Be Avoided, below, identifies all significant and unavoidable impacts that could occur, thereby creating a long-term impact on the environment. Section 6.4, Significant Irreversible Environmental Changes, below, addresses the short-term and irretrievable commitment of natural resources to ensure that the consumption is justified on a long-term basis. Lastly, Section 6.5, Growth-Inducing Impacts, identifies any long-term environmental impacts caused by the proposed project with respect to economic or population growth. 6.1.5 Impacts on Human Beings CEQA Guidelines Section 15065(a)(4) states that a lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR where there is substantial evidence that the environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly. As described in Chapter 4, Environmental Setting, City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-3 September 2020 ICF 0662.19 Impacts, and Mitigation, the proposed project would have no impact or a less-than-significant impact associated with aesthetics, agricultural and forest resources, energy, geology and soils (including seismic hazards), hazards and hazardous materials, hydrology, land use, mineral resources, population and housing, public services, recreation, utilities, and wildfire. Environmental impacts associated with air quality, biological resources, cultural resources (including tribal cultural resources), geology and soils (including paleontology), GHG emissions (exept VMT impacts), noise and vibration, and transportation and circulation (except VMT impacts) are considered less than significant or less than significant with mitigation. Transportation and circulation and GHG emissions impacts related to VMT are considered significant and unavoidable, as discussed in Section 6.3, Significant Environmental Effects that Cannot Be Avoided. 6.2 Cumulative Impacts An EIR is required to examine cumulative impacts. California Code of Regulations Section 15130(a)(1), defines a cumulative impact as consisting “of an impact which is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts.” The analysis of cumulative impacts need not provide the same level of detail as that for project-specific impacts, but it shall “reflect the severity of the impacts and their likelihood of occurrence” (per California Code of Regulations Section 15130(b)). CEQA Guidelines Section 15065 states that a lead agency shall find that a project may have a significant effect on the environment where there is substantial evidence that the project has potential environmental effects that are individually limited but cumulatively considerable. As defined in CEQA Guidelines Section 15065(a)(3), cumulatively considerable means “that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” The cumulative impacts analysis in an EIR must analyze either a list of past, present, and probable future projects or a summary of projections contained in an adopted general plan or related planning document. The cumulative impact analysis in this draft EIR generally employs either a list-based approach or a projections approach, depending on which approach best suits the individual resource topic being analyzed. A list of the reasonably foreseeable future projects used to analyze cumulative impacts under most topics is provided in Section 4.1.5, Approach to Cumulative Impact Analysis, and shown in Figure 4.1-1. For transportation, GHG emissions, air quality, and energy, a projections approach was used to analyze cumulative impacts. Cumulative impacts related to each environmental topic are discussed in Chapter 4, Environmental Setting, Impacts, and Mitigation. As described in Chapter 4, either there would be no cumulative impacts, cumulative impacts would be less than significant, or the project would have a less than cumulatively considerable contribution (either with or without mitigation) to significant cumulative impacts in the areas of: aesthetics, air quality, agricultural and forest resources, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology, land use, mineral resources, noise and vibration, population and housing, public services, recreation, utilities, and wildfire. However, Chapter 4 identifies significant and unavoidable cumulative GHG emissions impacts and transportation and circulation impacts to which the project’s contribution would be cumulatively considerable, as discussed below. City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-4 September 2020 ICF 0662.19 6.3 Significant Environmental Effects that Cannot Be Avoided In accordance with CEQA Section 21067 and with CEQA Guidelines Sections 15126(b) and 15126.2(b), the purpose of this section is to identify significant environmental impacts that could not be eliminated or reduced to less-than-significant levels by implementation of mitigation measures included in the proposed project or identified in Chapter 4, Environmental Setting, Impacts, and Mitigation. The findings of significant impacts are subject to final determination by the City of South San Francisco Planning Commission as part of the certification process for this EIR. The proposed project would result in significant and unavoidable project-level impacts and cumulatively considerable contributions to significant and unavoidable cumulative impacts related to transportation and circulation and GHG emissions. No other environmental topics discussed in Chapter 4 would result in significant and unavoidable environmental effects. As described in detail in Section 4.7, Greenhouse Gas Emissions, and Section 4.9, Transportation and Circulation, these significant and unavoidable impacts are listed below. • Impact GHG-1b: The proposed project would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during operation. The proposed project would result in a net loss of trees, reducing carbon sequestration in the land use sector. Implementation of Mitigation Measures GHG-2 would plant additional trees on existing surface parking lots but would still result in a net loss of trees. In addition, the proposed project would not achieve the 16.8 percent VMT per service population reduction target. The proposed project would be subject to regulatory programs related to fuel and vehicle efficiency as well as vehicle electrification. In addition, implementation of Mitigation Measure TR-1, as discussed in Section 4.9, Transportation and Circulation, would contribute a fair share toward funding the design and construction of off-site improvements to support the proposed project’s first- and last-mile transit connection strategies, which are necessary to support reductions in the number of trips made by automobile. These improvements include fair-share contributions toward the City’s cost of upgrading sidewalks, upgrading and extending bicycle and pedestrian pathways, providing a more direct connection to on-street shuttle stops, participating in first/last shuttle programs, striping unmarked crosswalks, and contributing to bicycle and pedestrian infrastructure. However, the lead agency cannot determine with certainty that implementation of Mitigation Measure TR-1 would reduce the proposed project’s VMT to a less- than-significant level because there are a range of GHG reductions associated with the measures in TR-1, making precise quantification of reductions difficult. Consequently, although emissions from the stationary-source, area, energy, waste, and water sectors would generally be consistent with the Bay Area Air Quality Management District’s (BAAQMD’s) stationary threshold or the scoping plan and regulatory programs, land use and mobile-source emissions from the proposed project would not be consistent with the scoping plan measures outlined to reduce GHG emissions consistent with the State’s goals. Therefore, operational GHG impacts would be significant and unavoidable with mitigation. • Impact GHG-2: The proposed project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Stationary-source emissions would be below BAAQMD’s stationary-source threshold. In addition, the proposed project would achieve U.S. Green Building Council Leadership in Energy and Environmental Design (LEED) Gold certification and implement sustainability measures, such as waste City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-5 September 2020 ICF 0662.19 diversion programs and water reduction measures, consistent with the 2017 scoping plan. This would reduce GHG emissions and associated impacts from area energy, water, and waste sources to less-than-significant levels. These reductions would help the State meet its GHG reduction goals. However, the proposed project would not be consistent with the scoping plan’s overall goal of avoiding losses in carbon sequestration, given the net tree loss despite implementation of Mitigation Measure GHG-2. In addition, implementation of Mitigation Measure TR-1 would reduce mobile-source emissions during operation but would not reduce emissions enough to meet the 16.8 percent VMT per service population reduction target developed by CARB. Therefore, the GHG impacts of the proposed project would be significant and unavoidable with mitigation because the project would not be consistent with State goals to reduce GHG emissions. • Impact TR-1: Existing home-based work (HBW) VMT per employee in the travel demand model transportation analysis zone (TAZ) that encompasses the project result in greater than 16.8 percent below the regional average HBW VMT per employee under existing plus project and cumulative plus project conditions. The project would generate approximately 16.2 HBW VMT per employee under existing conditions, which is greater than the per-employee significance threshold of 11.8 HBW VMT (based on a VMT rate of reduction of 16.8 percent below the regional average of 14.2 HBW VMT per employee). Therefore, the project would have a significant impact on VMT under existing plus project conditions. Under cumulative conditions, the project would generate approximately 14.0 HBW VMT per employee, which is greater than the per-employee significance threshold of 12.1 HBW VMT (based on a VMT rate 16.8 percent below the regional average of 14.6 HBW VMT per employee). Therefore, the project would have a significant impact on VMT under cumulative plus project conditions. Mitigation Measure TR-1 would support and enhance the effectiveness of the project’s last-mile transit connection strategies but would be unlikely to substantially reduce HBW VMT per employee, and would aid in reducing project auto travel demand. It is appropriate mitigation under both the existing plus project and cumulative plus project conditions; however, its effectiveness is unknown and is unlikely to reduce the project’s HBW VMT by 27 percent (i.e., the amount needed to reduce the project’s HBW VMT per employee of 16.2 to the 11.8 threshold, to reach a less-than-significant level). Therefore, this impact would be significant and unavoidable with mitigation. 6.4 Significant Irreversible Environmental Changes In accordance with CEQA Section 21100(b)(2)(B), and CEQA Guidelines Section 15126.2(c), an EIR must identify any significant irreversible environmental changes that could result from implementation of the proposed project. An EIR is required to consider whether “uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or non-use thereafter unlikely” (per CEQA Guidelines Section 15126.2(c)). “Nonrenewable resource” refers to the physical features of the natural environment, such as land, waterways, etc. This may include current or future uses of non- renewable resources and secondary or growth-inducing impacts that commit future generations to similar uses. According to the CEQA Guidelines, irretrievable commitments of resources should be evaluated to ensure that such current consumption is justified. City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-6 September 2020 ICF 0662.19 Chapter 4, Environmental Setting, Impacts, and Mitigation, discusses topics that could potentially be affected by irreversible environmental impacts, such as agricultural and forestry resources, biological resources, cultural resources, energy, hydrology, and population and housing. None of these environmental topics were found to have significant impacts as a result of the proposed project. No significant irreversible environmental damage related to hazardous materials is anticipated to occur with implementation of the proposed project. Compliance with federal, state, and local regulations related to office/research and development (R&D) uses identified in Section 4.10.3, Hazards and Hazardous Materials, would ensure that the possibility that hazardous substances from the demolition, construction, and operation of the proposed project would not cause significant and unavoidable environmental damage. The proposed project would involve excavation of soils for grading and to accommodate utility trenches. Grading would be required for general site preparation and for proper on-site stormwater flows, but the proposed project would not substantially raise or lower the existing grade. Grading would not be excessive or greater than what is necessary to achieve stormwater goals. Construction and implementation of the proposed project would not result in a large commitment of natural resources, require highway improvements to previously inaccessible areas, or cause irreversible damage due to environmental accidents. No other irreversible permanent changes such as those that might result from construction of a large-scale mining project, hydroelectric dam, or other industrial project would result from development of the proposed project. 6.4.1 Energy and Consumption of Nonrenewable Resources Section 21100(b)(3) of CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing any inefficient, wasteful, and unnecessary consumption of energy. Implementation of the proposed project would commit future generations to an irreversible commitment of energy resources in the form of usage of nonrenewable fossil fuels due to vehicle and equipment use during demolition, construction, and operation of the proposed project. See Section 4.5, Energy, of this draft EIR, for a discussion of the project’s impacts related to electricity, natural gas, and transportation fuel demand. Consumption of nonrenewable resources includes increased energy consumption, conversion of agricultural lands to urban uses, and loss of access to mineral reserves. No agricultural lands would be converted and no access to mining reserves would be lost with construction of the proposed project. Resources consumed during demolition, construction, and operation would include lumber, concrete, gravel, asphalt, masonry, metals, and water. Similar to the existing uses on the project site, the proposed project would irreversibly use water and solid waste landfill resources. However, the proposed project would not involve a large commitment of resources relative to existing conditions or relative to supply, nor would it consume any of those resources wastefully. The proposed project would redevelop an existing surface parking lot on an infill site in an urbanized area that currently serves R&D and office uses with a new state-of-the-art R&D facility and office building, with the goal to continue to attract biotech and R&D, as well other life science City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-7 September 2020 ICF 0662.19 uses, as described in Sections 3.1.1, Project Objectives, 4.10.5, Land Use, and 4.10.7, Population and Housing. The project site is serviced by existing water, wastewater, stormwater, natural gas, electric, telecommunications, and waste and recycling services. New on-site facilities would be connected to new services through the installation of new, localized connections. Expansion of or an increase in capacity of off-site infrastructure would occur as required by the utility providers. Section 4.10.10, Utilities, describes the water supply and demand aspects of the proposed project. The proposed project includes several water conservation features. For example, the proposed project would achieve LEED Gold certification or equivalent and install low-flow fixtures. Outdoor water conservation measures would include the installation and maintenance of water-efficient landscaping with low-usage plant material to minimize irrigation requirements. Therefore, the proposed project would include the application of required water conservation measures and would be in conformance with policies addressing water efficiency. Compared to the mix of other existing development in South San Francisco and the region, compliance with the latest LEED Gold certification, International WELL and Fitwel Building Institute Standards, and other requirements would ensure that the proposed project would be more water efficient than all but recent buildings built to the same requirements, or buildings for which owners have chosen to exceed efficiency requirements. For these reasons, the proposed project would not result in the wasteful use of water. 6.5 Growth-Inducing Impacts As required by CEQ Guidelines Section 15126.2(d), an EIR must consider the ways in which the proposed project could directly or indirectly foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Growth-inducing impacts can result from the elimination of obstacles to growth; through increased stimulation of economic activity that would, in turn, generate increased employment or demand for housing and public services; or from the implementation of policies or measures that do not effectively minimize premature or unplanned growth. Growth-inducing impacts such as those associated with job increases that might affect housing and retail demand in other areas over an extended time period are difficult to assess with precision, since future economic and population trends may be influenced by unforeseeable events and business development cycles. Moreover, long-term changes in economic and population growth are often regional in scope; they are not influenced solely by changes in policies or specific development projects. Business trends are influenced by economic conditions throughout the state and country as well as around the world. Another consideration is that the creation of growth-inducing potential does not automatically lead to growth. Growth occurs through capital investment in new economic opportunities by the private and/or public sector. Investment patterns reflect, in turn, the desires of investors to mobilize and allocate their resources to development in particular localities and regions. A combination of these and other pressures serve to fashion policy. The regulatory authority of local governments serves to mediate the growth-inducing potential or pressure created by a project or plan. Despite these limitations on the analysis, it is still possible to qualitatively assess the general potential growth-inducing impacts of the proposed project. City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-8 September 2020 ICF 0662.19 6.5.1 Projected Growth Section 4.10.7, Population and Housing, discussed population and employment growth as a result of the proposed project and made the following findings. The proposed project does not include any new housing units and would not directly induce population growth. The proposed project would redevelop an existing parking lot on an infill site in an urbanized area that currently serves R&D and office uses with a new R&D facility and office building. Development of infrastructure could remove obstacles to population growth if it would allow for development in an area that was not previously considered feasible for development because of infrastructure limitations. The proposed project would not include the extension of area roadways or expansion of infrastructure to areas lacking existing development. No indirect impacts related to population growth as a result of expansion of infrastructure would occur. The existing office building on the project site at 701 Gateway Boulevard has approximately 450 employees. As stated in Chapter 3, Project Description, the existing office building would remain; no existing employees would be displaced as a result of the proposed project. However, the project would result in an increase of approximately 731 net new employees at the project site, and in the City, as a result of project development. As discussed in Section 4.10.7, Population and Housing, the proposed project’s net number of newly generated employees would represent approximately 6.1 percent and less than 10 percent, respectively, of the City’s total projected population and job numbers for 2040, and would not represent a substantial portion of the projected population and job growth planned for in the General Plan. Therefore, the proposed project would not result in substantial unplanned population and job growth. The project represents anticipated growth in the City. The net new 731 employees generated as a result of the proposed project could increase demand for housing and contribute to total overall housing demand citywide. While, it is assumed that most of the employees generated by the project would be existing residents in the surrounding area, a small portion of the new employees could potentially generate new demand for housing within the City. Therefore, the analysis conservatively assumes that all employees generated by the proposed project would be new to the City, would require housing, and would contribute to the City’s existing jobs/housing imbalance, which is already projected to be out of balance, according to the Association of Bay Area Government’s (ABAG’s) Projections 2040. According to the analysis, the proposed project would create the need for up to 475 new housing units upon completion. This conservatively-projected potential new housing demand resulting from the proposed project could cause indirect growth that the City may not be able to accommodate with existing and projected housing. As discussed in Section 4.10.7, Population and Housing, the City is primarily a jobs center that attracts employees who commute from other communities and cities to work there. This is partially because much of the land within City limits, including the project site, is not well suited for residential development because of City policy and land use designations intended to support the development of employment land uses, including office and R&D. Nonetheless, the City does not have an adopted jobs/housing ratio goal that would be applicable to development within the project site. However, to accommodate for the lack of developable residential land within the area surrounding the project site, as well as throughout the City, the City has adopted the Affordable Housing Commercial Linkage Fees in order to establish fees for non-residential development projects to address the effect they may have on the ratio of increased job opportunities and the demand created for affordable housing. The proposed project would be required to pay these fees, which would contribute to the development of affordable housing in other locations within the City. In addition, City of South San Francisco Other CEQA Considerations 751 Gateway Boulevard Project 6-9 September 2020 ICF 0662.19 the proposed project would promote greater regional balance between jobs and housing and woud be within an area with comptiable land uses, consistent with the General Plan and specific plan designations. Therefore, the proposed project would have a less-than-significant indirect impact on population growth. Overall, the proposed project would be an appropriate land use for the project site’s limitations, and the job growth that would occur under the proposed project would be within the projected employment growth of the City. The proposed project would not induce direct or indirect population growth.