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CEQA Findings of Fact and
Statement of Overriding Considerations
South San Francisco General Plan Update Zoning Code
Amendments and Climate Action Plan
City of South San Francisco, San Mateo County, California
State Clearinghouse Number 2021020064
Prepared for:
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Date: September 6, 2022
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City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations Table of Contents
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Table of Contents
CEQA Findings of Fact and Statement of Overriding Considerations ............................................... 1
1.1 - Introduction ....................................................................................................................... 1
1.2 - Statement of Findings ....................................................................................................... 1
1.3 - Project Summary ............................................................................................................... 2
1.4 - Background ........................................................................................................................ 4
1.5 - Potential Environmental Effects Which are Not Significant or Less than Significant ........ 5
1.6 - Potential Environmental Effects Which Can Be Mitigated Below a Level of
Significance ............................................................................................................... 103
1.7 - Impacts Identified in the Draft Program EIR as Being Significant and Unavoidable
Even After the Incorporation of All Feasible Mitigation Measures .......................... 118
1.8 - Findings Regarding Alternatives .................................................................................... 130
1.9 - Findings Regarding Cumulative Impacts ........................................................................ 135
1.10 - Findings Regarding Growth Inducement ..................................................................... 135
1.11 - Findings Regarding Significant Irreversible Environmental Changes ........................... 136
1.12 - Findings Regarding Recirculation ................................................................................ 138
1.13 - Statement of Overriding Considerations ..................................................................... 139
Attachment A: Mitigation Monitoring and Reporting Program
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CEQA Findings of Fact and Statement of Overriding Considerations
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CEQA FINDINGS OF FACT AND STATEMENT OF OVERRIDING
CONSIDERATIONS
1.1 - Introduction
The State Guidelines (Guidelines) promulgated pursuant to the California Environmental Quality Act
(CEQA) provide:
No public agency shall approve or carry out a project for which an EIR has been
completed which identifies one or more significant environmental effects of the
project unless the public agency makes one or more written findings for each of
those significant effects, accompanied by a brief explanation of the rationale for
each finding. The possible findings are:
(a) Changes or alterations have been required in, or incorporated into, the project
which avoid or substantially lessen the significant environmental effect as
identified in the Final EIR (hereinafter referred to as “finding (1)”).
(b) Such changes or alterations are within the responsibility and jurisdiction of
another public agency and not the agency making the finding. Such changes
have been adopted by such other agency or can and should be adopted by
such other agency (hereinafter referred to as “finding (2)”).
(c) Specific economic, legal, social, technological or other considerations,
including provision of employment opportunities for highly trained workers,
make infeasible the mitigation measures or project alternatives identified in
the Final EIR (hereinafter referred to as “finding (3)”).
The required findings shall be supported by substantial evidence in the record. (CEQA Guidelines §
15091).
The Final EIR incorporates the Draft Program EIR. References to the “EIR” are to the collective
documentation contained in the Draft Program EIR and Final EIR. All acronyms used within this
document shall have the same meaning as defined in the Draft Program EIR.
1.2 - Statement of Findings
An Environmental Impact Report (EIR) pursuant to CEQA has been prepared by the City of South San
Francisco. The EIR for the City of South San Francisco General Plan Update, Zoning Code
Amendments and Climate Action Plan (proposed project) identifies significant effects on the
environment, which may occur as a result of the proposed project. Section 1.5 sets forth potential
environmental effects of the project which are not significant because of the design of the project,
or they can feasibly be mitigated below a level of significance. Section 1.6 sets forth those potential
environmental effects of the proposed project which are not significant because of the design of the
proposed project or because they can feasibly be mitigated below a level of significance. Section 1.7
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
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discloses the environmental impacts that remain significant and unavoidable even with the
incorporation of feasible mitigation. Section 1.8 summarizes the alternatives discussed in the EIR and
makes findings with respect to the feasibility of alternatives and whether the alternatives would
lessen the significant environmental effects of the proposed project.
The following sets forth all significant effects of the project and with respect to each effect, makes
one or more of the findings set forth in Section 1.1, Introduction, and provides facts in support of
such findings.
The EIR provides additional facts in support of the findings herein. The mitigation measures set forth
in the Mitigation Monitoring and Reporting Program (MMRP) (Attachment A) are incorporated by
reference in these findings, and the findings in Sections 1.6 and 1.7 refer to individual mitigation
measures as appropriate. In the event of any inconsistencies between the mitigation measures set
forth herein and the MMRP, the MMRP shall control.
1.3 - Project Summary
1.3.1 - Project Description
The proposed project includes the implementation of the South San Francisco General Plan Update,
Zoning Code Amendments, and Climate Action Plan. The General Plan Update anticipates
approximately 14,312 net new housing units and approximately 42,297 net new employment
opportunities by 2040. The Proposed Land Use Map designates the general location, distribution,
and extent of land uses within the Planning Area and identifies proposed land use designations for
each parcel within the City of South San Francisco and within the City’s Sphere of Influence (SOI).
The proposed project includes amendments to the Zoning Code necessary to implement the General
Plan Update. The Zoning Code Amendments also incorporate a number of major policies from
documents that were previously adopted.
The updated 2022 Climate Action Plan (CAP) includes a community-wide inventory of greenhouse
gas (GHG) emissions and identifies strategies and measures to reduce GHG emissions generated by
existing and future uses in the City.
The proposed project has been developed to be largely self-mitigating in that the policies, actions,
and strategies in the General Plan Update, Zoning Code Amendments, and CAP recognize the
importance of the natural environment and are designed to protect the environment and
environmental resources. In certain instances, mitigation is included to reinforce and enhance the
protections identified in the policies, actions, and strategies. However, even with implementation of
all available mitigation, the proposed project would result in significant unavoidable impacts related
to project-level vehicle miles traveled, project-level roadway safety, cumulative vehicle miles
traveled, cumulative roadway safety, project-level conflict with the 2017 Bay Area Clean Air Plan, and
cumulative criteria air pollutants.
1.3.2 - Project Objectives
The project objectives include:
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
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• Reflect the current goals and vision expressed by South San Francisco residents, businesses,
decision-makers, and other stakeholders.
• Address issues and concerns identified by South San Francisco residents, businesses, decision-
makers, and other stakeholders.
• Provide affordable, safe, attractive, amenity-rich neighborhoods, balancing housing options
with commercial and employment access.
• Ensure that high-quality and accessible services, facilities, and amenities are available for
residents at all stages of their lives, such as internet connectivity, parks and open spaces,
emergency response services, and educational and recreational opportunities.
• Provide a safe, convenient, and accessible transportation network that is well-connected to
the region by ensuring that streets have accessible alternate transportation for all ages and
abilities.
• Build a resilient community that is prepared for the future effects of climate change and
natural disasters by prioritizing resources for the City’s most vulnerable residents and
investing in climate pollution reduction, efficient energy and water use, and clean air.
• Foster a prosperous downtown and local economy by supporting local businesses and
strengthening the City’s role as the worldwide hub of the biotech and life sciences.
• Make the downtown a destination for all by providing a diversity of uses as well as improving
walkability, safety, and visual interest.
• Embrace the City’s legacy as “The Industrial City” and maintain a core of middle-wage jobs in
the City.
• Identify strategies and measures to reduce GHG emissions generated by existing and future
uses in the City.
• Update the Zoning Code to reflect the shared vision of the new General Plan and implement
its new policies that reflect and preserve community character, respond to economic realities
and trends, facilitate reinvestment in the community and development of housing for all
segments, and encourage appropriate use of land.
• Address new requirements of State law.
1.3.3 - Required Approvals
While no Responsible Agencies or Trustee Agencies are responsible for approvals associated with
adoption of the General Plan Update, Zoning Code Amendments, and Climate Action Plan,
subsequent projects and other actions to support implementation of the proposed project would
require actions, including permits and approvals by Trustee and Responsible Agencies that may
include, but are not necessarily limited to:
• California Department of Fish and Wildlife (CDFW)
• California Department of Transportation (Caltrans)
• Regional Water Quality Control Board (RWQCB)
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
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• San Mateo Local Agency Formation Commission (LAFCo)
• United States Army Corps of Engineers (USACE)
• United States Fish and Wildlife Service (USFWS)
• San Francisco Bay Conservation and Development Commission (BCDC)
• San Francisco Public Utilities Commission (SFPUC)
• City/County Associations of Governments of San Mateo County (C/CAG)
1.4 - Background
In accordance with CEQA Guidelines Section 15082, the City circulated the original Notice of
Preparation (NOP) of a Program EIR for the General Plan Update for a 45-day review period from
February 3, 2021, to March 22, 2021, to Trustee and Responsible Agencies, the State Clearinghouse
(SCH), and the public. A scoping meeting was held on February 17, 2021, which was attended by
three members of the public. A revised NOP was circulated from January 14, 2022 to February 28,
2022, to provide the public with an opportunity to comment on changes that were made to the
Project Description related to net new housing units and net new employment opportunities
anticipated under the General Plan Update. An additional Scoping Meeting was held on January 31,
2022, which was attended by one member of the public. Comments received on the NOP circulated
from February 3, 2021 to March 22, 2021, as well as comments received on the revised NOP
circulated from January 14, 2022 to February 28, 2022, will be considered part of the administrative
record. The NOP and all comment letters received on the NOP are presented in Appendix A.
The Zoning Code was made available for public review and comments from June 8, 2022, through
August 10, 2022. The Housing Element was available for public review and comments starting on July
5, 2022. The Draft Program EIR was circulated and made available for public review and comments
from June 24, 2022, through August 9, 2022. During the public review period, the Draft Program EIR,
including the technical appendices, was made available for review at the following City of South San
Francisco offices:
• Planning Division at 315 Maple Avenue, South San Francisco, CA 94080
• Main Library at 840 West Orange Avenue, South San Francisco, CA 94080
• City Clerk at 400 Grand Avenue, South San Francisco, CA 94080
• Grand Avenue Library at 306 Walnut Avenue, South San Francisco, CA 94080
In addition, the Draft Program EIR, including technical appendices, Zoning Ordinance and Housing
Element were posted on the City of South San Francisco website at https://shapessf.com/plan-
feedback during the public review period. After the close of the public review period, the City of
South San Francisco prepared a Final EIR, consisting of the comments received on significant
environmental issues during the 46-day public review and comment period on the Draft Program
EIR, written responses to those comments, revisions to the Draft Program EIR, and an errata making
minor, non-substantive changes to the Final EIR. For these Findings, the “EIR” shall consist of the
Draft Program EIR, all appendices attached to the Draft Program EIR, and the Final EIR (consisting of
the Introduction, Errata, and Responses to Comments). The City of South San Francisco subsequently
considered all oral and written comments regarding environmental issues in the Final EIR and
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
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determined, based on all of the evidence presented, including but not limited to the Draft Program
EIR, written and oral testimony given at public meetings and hearings in connection therewith, and
the submission of comments from the public, organizations and regulatory agencies, as well as all
other relevant information in the administrative record, the following environmental impacts
associated with the proposed project are: (1) less than significant and do not require mitigation; or
(2) potentially significant but will be avoided or reduced to a level of insignificance through the
identified mitigation measures; or (3) significant and cannot be fully mitigated to a level of less than
significant but will be substantially lessened to the extent feasible by the identified mitigation
measures.
The City of South San Francisco concludes that implementation of the proposed project could result
in potentially significant and significant adverse environmental impacts. Accordingly, as discussed
above, the City of South San Francisco is required to make certain findings with respect to these
impacts pursuant to CEQA Guidelines Section 15091. Accordingly, the City of South San Francisco
hereby makes these required findings, as set forth in this document (“Findings”).
These Findings summarize the environmental determinations about the proposed project’s significant
impacts before and after mitigation and summarize the proposed project’s individual and cumulative
impacts. These Findings do not attempt to describe the full analysis of each environmental impact.
Instead, they provide a summary description of each significant impact and the applicable mitigation
measures identified in the Draft Program EIR and adopted by the City of South San Francisco and state
the conclusions regarding the significance of each impact after incorporation of the identified
mitigation measures. A comprehensive explanation of these environmental impact conclusions can be
found in the Draft Program EIR, as supplemented and explained in staff reports and materials
presented by the project applicant, the City of South San Francisco staff, and various project
consultants, and other relevant materials in the administrative record.
The Draft Program EIR contains substantial evidence to support all the conclusions presented in
these Findings.
The Draft Program EIR is incorporated into these Findings in its entirety. Without limitation, this
incorporation is intended to elaborate on the scope and nature of mitigation measures, the basis for
determining the significance of impacts, the comparative analysis of alternatives, and the reasons for
approving the proposed project in spite of the potential for associated significant and unavoidable
adverse impacts.
1.5 - Potential Environmental Effects Which are Not Significant or Less than
Significant
The City of South San Francisco has heard, been presented with, reviewed, and considered all of the
information and data in the administrative record, including the Draft Program EIR and Final EIR, and
all oral and written evidence presented to it during all meetings and hearings. The Draft Program EIR
reflects the independent judgment of the City of South San Francisco and is deemed adequate for
purposes of making decisions on the merits of the proposed project.
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations
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Consistent with Public Resources Code Section 21002.1 and Section 15128 of the CEQA Guidelines,
the Draft Program EIR focused its analysis on potentially significant impacts, and limited discussion
of other impacts for which it can be seen with certainty there is no potential for significant adverse
environmental impacts. CEQA Guidelines Section 15091 does not require specific findings to address
environmental effects that an EIR identifies as “no impact” or a “less than significant” impact and for
which no mitigation is necessary. Nevertheless, based on its independent judgment and the entire
administrative record before it, the City of South San Francisco has determined that the following
potential environmental effects would not be significant and no mitigation is necessary for the
reasons stated below.
1.5.1 - Aesthetics
Potential Effect
Impact AES-1 The proposed project would not have a substantial adverse effect on a scenic
vista. (Draft Program EIR, Page 3.1-12.)
Findings: Less than significant impact (Draft Program EIR Page 3.1-14). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area which could alter existing
scenic vistas and views. Because South San Francisco is a fully built city, new development would
primarily occur on parcels that already contain some existing homes or businesses. Development
under the proposed project could alter existing views, including views of the South San Francisco
Hillside Sign, Sign Hill, San Bruno Mountain, the Coast Range, and the San Francisco Bay. The
proposed project promotes restoration of Colma Creek through General Plan Update Policy LU-8.7
and Action CS-3.1 of the Climate Action Plan, which would improve the visual character of the City.
Views of these features could be affected by future development under the proposed project.
Mandatory compliance with design review regulations and policies in the South San Francisco
Municipal Code Section 13.28.110 (Construction areas) and Chapter 13.30 (Tree Preservation);
Zoning Ordinance Chapter 20.480 (Design Review) and Section 20.480.006 (Design Review Criteria);
and General Plan Updates, including Policy LU-8.8, Policy SA-32.5, Policy LU-9.2, Policy SA-6.1, Policy
PR-3.2, Policy CR-4.3, and Action LU-9.1.4, would ensure that potential impacts related to scenic
vistas and views from new development under the proposed project would be less than significant
(Draft Program EIR Pages 3.1-12-14). The proposed project's impacts to aesthetics, light, and glare
would be less than significant or no impact with the implementation of applicable regulations,
including proposed project policies and implementing actions. No mitigation is necessary. (Draft
Program EIR, page 4-7.)
Potential Effect
Impact AES-2 The proposed project would not substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and historic buildings within a State
Scenic Highway. (Draft Program EIR Page 3.1-14).
Findings: Less than significant impact (Draft Program EIR Page 3.1-16). No mitigation required.
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations
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Facts in Support of Findings: Interstate 280 (I-280) is an officially designated State Scenic Highway
from the South San Francisco and San Bruno border until it reaches Stanford University in Palo Alto
and does not traverse the Planning Area. Distant views of the City of South San Francisco and San
Bruno Mountain are intermittently visible from the officially designated portion of I-280; however,
most of the views of the City and San Bruno Mountain are shielded by existing trees. The portion of
State Route (SR) 35 (Junipero Serra Freeway) that borders the western side of the Planning Area is
eligible for designation as a State Scenic Highway. Distant views of the City of So uth San Francisco
and San Bruno Mountain are intermittently visible from SR-35; however, most of the views of the
City and San Bruno Mountain are shielded by existing trees. Undeveloped grassland, shrubs, trees,
and rock outcroppings can be seen in the immediate vicinity of I-280 and SR-35, and San Francisco
Bay, San Bruno Mountain, and the Coast Range can be seen in the distance from I-280 and SR-35. As
discussed under Impact AES-1, all development under the proposed project would be subject to
development and design standards for each zoning district as well as any other sections of the South
San Francisco Municipal Code and Zoning Ordinance that protect scenic resources, thereby
minimizing potential impacts to existing views that can be seen from I-280 or SR-35. In addition,
future development would be required to comply with the General Plan Update policies and actions
that protect scenic resources. Historic buildings and other historic resources are discussed in in
Section 3.4, Cultural Resources and Tribal Cultural Resources. While future development could occur
in the vicinity of the I-280 and SR-35, those projects would be reviewed by the City to ensure that
impacts related to scenic resources remain less than significant. Moreover, subsequent
development, infrastructure, and planning projects would be subject to the General Plan Update
policies and actions, as well as the South San Francisco Municipal Code and Zoning Ordinance, to
reduce impacts related to scenic resources (Draft Program EIR, Pages 3.1-14 – 16). The proposed
project's impacts to aesthetics, light, and glare would be less than significant or no impact with the
implementation of applicable regulations, including proposed project policies and implementing
actions. No mitigation is necessary. (Draft Program EIR, page 4-7.)
Potential Effect
Impact AES-3 The proposed project is in an urbanized area and would not conflict with
applicable zoning and other regulations governing scenic quality. (Draft Program
EIR, Pages 3.1-16.)
Findings: Less than significant impact (Draft Program EIR, Page 3.1-17). No mitigation required.
Facts in Support of Findings: The City of South San Francisco is located in an urbanized area. As
discussed under Impacts AES-1 and AES-2, as the City receives development applications for
subsequent development under the proposed project, those applications will be reviewed by the
City for compliance with the policies and actions of the General Plan Update related to scenic quality
in urbanized areas, including scenic views and scenic resources. In addition, the South San Francisco
Municipal Code and Zoning Ordinance, which implements the City’s General Plan, would be
reviewed when development applications are received. The General Plan Update includes policies
and actions intended to reduce impacts to visual character in and around the Planning Area and
promote cohesive and visually appealing development consistent with the character of the City. For
example, Policy LU-2.2 requires development projects near transit centers to use architectural
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transitions, such as setbacks, transitions in building height, and landscaping when adjacent to lower-
density residential properties. Additional policies facilitate implementation of objective design
standards, require new development to be compatible and integrated with existing residential
neighborhoods, and provide for maintenance of high-quality design and development standards
(Policies LU-4.1, LU-4.5, LU-4.6, and LU-5.2). The Sub-Areas Element includes policies and actions to
provide for similar compatibility and high-quality architectural design specific to the identified sub-
areas. The Parks and Recreation Element includes Policy PR-3.2, which limits the construction of
facilities in open space areas and requires the design of necessary improvements, such as fire roads,
access roads, and parking facilities, to minimize environmental impacts and maintain the visual
qualities of the open space. Each of these policies aims to enhance the visual character of the City.
The South San Francisco Municipal Code also contains rules and regulations related to visual
character, including Chapter 13.30 (Tree Preservation) and Section 13.28.110 (Construction areas).
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, contains architectural guidelines, design review criteria, lot and development
standards, landscaping requirements, and other regulations for various land uses in order to
promote aesthetic quality within the City and protect scenic views, including Chapter 20.480 (Design
Review) and Section 20.480.006 (Design Review Criteria).
The Climate Action Plan includes actions that would improve the visual character of the City.
Implementation of Action CS-3.1 would enhance Colma Creek as an ecological corridor, creating
transitional habitat zones to build resilience and ecosystem services that would improve the visual
character of the City. Implementation of Action CS-2.1 would expand the canopy cover to reach the
goals of the Urban Forest Master Plan, which would also improve the visual character of the City.
Compliance with General Plan Update and Climate Action Plan policies and actions, and adherence
to development and design standards in the South San Francisco Municipal Code and Zoning
Ordinance related to scenic views and scenic resources, would ensure that impacts remain less than
significant (Draft Program EIR, Pages 3.1-16-17). The proposed project's impacts to aesthetics, light,
and glare would be less than significant or no impact with the implementation of applicable
regulations, including proposed project policies and implementing actions. No mitigation is
necessary. (Draft Program EIR, page 4-7.)
Potential Effect
Impact AES-4 The proposed project would not create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area. (Draft Program
EIR, Page 3.1-17).
Findings: Less than significant impact (Draft Program EIR, Page 3.1-19). No mitigation required.
Facts in Support of Findings: The proposed project would not create a new source of substantial
light or glare that would adversely affect views. For example, the General Plan Update includes
policies and actions requiring the use of low intensity lighting to reduce the amount of light reaching
sensitive habitat, which would reduce light and glare impacts in and around the Planning Area. (See
Draft Program EIR, Section 3.3, Biological Resources.) Additionally, Policy ES-2.2 requires the use of
low intensity lighting for development within 150 feet of the San Francisco Bay. The South San
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations
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Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed
project, contains architectural guidelines, design review criteria, lot and development standards,
landscaping requirements, and other regulations for various land uses in order to reduce light and
glare impacts within the City, including Section 20.300.008 (Lighting and Illumination), Section
20.300.008 (C), which establishes general standards for outdoor lighting; Section 20.300.008 (D),
which prohibits the use of certain types of outdoor lighting; and Section 20.360.004 (General
Standards for All Signs). Applications will be reviewed by the City of South San Francisco for
compliance with the City’s Municipal Code and Zoning Ordinance. Potential issues related to glare
would be addressed by the Design Review Board pursuant to Chapter 20.480 (Design Review
Procedures). Projects for which signs are proposed would be reviewed for compliance with Sections
20.300.008 (revised) and 20.360.004 (revised) of the Zoning Ordinance (Draft Program EIR, Page 3.1-
17–19).
The proposed project's impacts to aesthetics, light, and glare would be less than significant or no
impact with the implementation of applicable regulations, including proposed project policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, page 4-7.)
Potential Effect
Cumulative Impacts: Cumulative impacts related to aesthetics and visual quality would be less than
significant. (Draft Program EIR, Page 3.1-19.)
Findings: Less than significant impact (Draft Program EIR, Page 3.1-20). No mitigation required.
Facts in Support of Findings: Future development would be subject to the design review processes
of the individual jurisdiction, and the applicable land use plans contain policies and implementing
actions to preserve visual character, land use compatibility, and views in those jurisdictions. As such,
the proposed project and cumulative development would be consistent with the character of the
surrounding area and would not obstruct current views. The proposed project and cumulative
development would be subject to specific regulations and guidelines related to building heights,
setbacks, undergrounding of utilities, landscaping, signage, and permitted land uses. These
regulations would ensure that visual character and viewsheds are maintained and/or enhanced.
Local regulations related to light and glare would be applicable to all cumulative development,
similar to the proposed project. Lighting and exterior building materials associated with the
proposed project and cumulative development would be subject to administrative design review by
the various jurisdictions. This process would ensure appropriate building materials are utilized,
building windows are tinted with anti-reflective material, and exterior lighting is designed so that it is
directed downward and away from adjacent properties. The proposed project and cumulative
development would increase light and glare compared to existing conditions. However, adherence to
the administrative design review process and standards of each applicable jurisdiction would
minimize the light and glare impacts for the proposed project and cumulative development (Draft
Program EIR, Pages 3.1-19-20).
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations
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The proposed project's impacts to aesthetics, light, and glare would be less than significant or no
impact with the implementation of applicable regulations, including proposed project policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, page 4-7.)
1.5.2 - Air Quality
Potential Effect
Impact AIR-4 The proposed project would not result in other emissions (such as those leading to
odors) adversely affecting a substantial number of people. (Draft Program EIR,
Page 3.2-57—58)
Findings: Less than significant impact. (Draft Program EIR, Page 3.2-58) No mitigation required.
Facts in Support of Findings: While odors could be generated during construction activities, the
proposed project consists of a General Plan Update, Climate Action Plan Update, and Zoning Code
Amendment and would not directly result in construction of any development project. Identification
of potential impacts to odor receptors resulting from construction-generated odors is not possible as
project-specific information of future individual land use development projects is unknown.
Consistent with the BAAQMD’s CEQA Air Quality Guidelines, a plan-level analysis must acknowledge
odor sources within the Planning Area and identify policies, goals, and objectives aimed at reducing
potential odor impacts to ensure that potential impacts would be less than significant.
The BAAQMD’s CEQA Air Quality Guidelines identify a screening distance of 1 and 2 miles for the
most common odor-generating land uses. Projects located outside of these screening distances
would be presumed to not be exposed to odors, while projects within these screening distances
present a potential to be exposed to odors. The City of South San Francisco contains several of the
land uses listed by the BAAQMD as potential odor sources, such as the Linden Stormwater Pump
Station 6, South San Francisco–San Bruno Water Quality Control Plant, and various coffee shops that
all have the potential to roast coffee beans on-site. The proposed project would facilitate future
development of sensitive receptors within the identified screening distances of existing odor
sources.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, contain several provisions with the goal to protect and promote the public
health, safety, peace, comfort, convenience, prosperity, and general welfare. Section 20.300.010
(Performance Standards) establishes regulations related to odors and restricts uses, processes, or
activities that produce objectionable odors that are perceptible without instruments by a reasonable
person at the lot lines of a site. Sections 20.410.004 (Indoor Commercial Cannabis Cultivation),
20.410.005 (Commercial Cannabis Manufacturing), and 20.410.006 (Cannabis Testing Operations)
require that operators install and maintain, in good working-order, air treatment or other ventilation
systems to prevent odors generated from the cultivation of cannabis from being detected within 10
feet of the structure in which commercial cannabis cultivation occurs. In addition, BAAQMD
Regulation 7 limits emissions of odorous substances within the Air Basin and would apply to any
odor source within the Planning Area (Draft Program EIR, Page 3.2-57-58).
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1.5.3 - Biological
Potential Effect
Impact BIO-2 The proposed project would not have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans,
policies, and regulations or by the California Department of Fish and Wildlife or
United States Fish and Wildlife Service. (Draft Program EIR, Page 3.3-22-23.)
Findings: Less than significant impact. (Draft Program EIR, Page 3.3-23.) No mitigation required.
Facts in Support of Findings:
Development under the proposed project, primarily adjacent to the San Francisco Bay, could result
in direct or indirect effects on estuarine habitat and other sensitive marine communities.
Subsequent development could also result in the direct or indirect effects on other sensitive habitats
as defined by the CNDDB or ecologically sensitive areas and habitat as described in the
Environmental and Cultural Stewardship Element. Any proposed activities that would divert or
obstruct the natural flow or change the bed, channel, or bank of any lake or stream, must obtain a
“Streambed Alteration Agreement” from the CDFW prior to any alteration of a lake bed, stream
channel, or their banks. Through this agreement, the CDFW may impose conditions to limit and fully
mitigate impacts on fish and wildlife resources.
The General Plan Update includes policies and actions designed to protect riparian habitat and other
sensitive natural communities. For example, Policy ES-2.1 requires the City to protect and expand
existing marsh and wetland habitat to improve water quality, adapt to climate change, and provide
habitat for wildlife. Policy ES-2.2 requires the City to maintain standards and guidelines for new
construction within 150 feet of San Francisco Bay that support the health of the Bay, such as
maintaining (or increasing) building setbacks to support habitat areas and requiring the installation
of bioswales to treat runoff before it enters the Bay. Policy ES-3.3 requires the City to maintain
development standards and guidelines for new construction within 80 feet of Colma Creek, such as
maintaining or increasing building setbacks to support habitat areas. Policy ES-6.3 requires that
permit applications for projects located within ecologically sensitive habitat areas prepare site-
specific biological assessments for review and approval by City Planning staff, and incorporation of
the recommended measures during construction to protect ecologically sensitive habitat areas.
Additionally, the South San Francisco Zoning Ordinance contains rules and regulations regarding
development in areas with sensitive habitats. Section 20.170.003 (Habitat and Biological Resource
Conservation Areas) (existing) requires a site-specific assessment of biological resources for all
development proposals in areas of the Special ES Overlay District that have been identified as
ecologically sensitive habitat (such as Sign Hill Park, San Bruno Mountain State Park, and the
saltmarshes along San Francisco Bay) as shown on a map or maps maintained by the City. Section
20.170.003 (existing) also requires that sensitive habitat areas be protected in the following order:
(1) avoidance; (2) on-site mitigation; (3) off-site mitigation; and (4) purchase of mitigation credits.
Lastly, Section 20.170.003 (existing) requires that approval of a development permit for a project on
a site located within an area identified as ecologically sensitive habitat shall not occur unless the
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applicable review body first finds that there will be no significant negative impact on the identified
sensitive habitat and the proposed use will be consistent with the biological continuance of the
habitat.
The CAP includes actions to enhance biological resources in the Planning Area. Implementation of
Action CS-3.1 would enhance Colma Creek as an ecological corridor, restoring 5 miles of creek
ecologies, and creating transitional habitat zones to build resilience and ecosystem services, which
would assist in enhancing riparian habitat in the Planning Area. Implementation of Action CS-2.1
would expand the canopy cover to reach the goals of the Urban Forest Master Plan and increase
environmental benefits, prioritizing connected wildlife corridors.
Future development under the proposed project would comply with adopted State, federal, and
local regulations for the protection of riparian habitat and other sensitive natural communities. In
addition, future projects would comply with requirements of the General Plan Update policies and
actions and the South San Francisco Zoning Ordinance related to the protection of these biological
resources (Draft Program EIR, Page 3.3-22—23). The proposed project's impacts related to biological
resources would be less than significant with the implementation of applicable regulations, including
new and revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact BIO-5 The proposed project would not conflict with any local policies or ordinances
protecting biological resources, such as a tree preservation policy or ordinance.
(Draft Program EIR, Page 3.3-27).
Findings: Less than significant impact (Draft Program EIR, Page 3.3-28). No mitigation required.
Facts in Support of Findings: Future discretionary projects facilitated by the proposed project would
be subject to all applicable local policies and regulations related to the protection of important
biological resources. Specifically, development would be required to comply with the City’s Tree
Ordinance, Chapter 13.28 of the South San Francisco Municipal Code. Section 13.28.110
(Construction areas) requires a tree removal permit for any construction activities on or adjacent to
public property that requires removal of a tree planted on the property. As a condition of permit
issuance, the applicant shall be required to replace the tree with one of the same size and species in
a location designated by the director. Chapter 13.30 (Tree Preservation) provides standards and
requirements for the protection of certain large trees and trees with unique characteristics; provides
standards and requirements for planting and maintenance of trees for new development; and
establishes recommended standards for planting and maintaining trees on property that is already
developed. Section 20.170.003 (Habitat and Biological Resource Conservation Areas) (existing) of
the South San Francisco Zoning Ordinance requires a site-specific assessment of biological resources
for all development proposals in areas of the Special ES Overlay District that have been identified as
ecologically sensitive habitat. Additionally, General Plan Update Policy ES-4.1 requires the City to
expand the tree canopy cover to increase environmental benefits, prioritizing disadvantaged
communities and connected wildlife corridors. Action ES-4.1.1 requires the City to implement the
City’s Urban Forest Plan. Policy ES-4.2 requires the avoidance of tree removal whenever possible,
and when removals are warranted, that each removed tree be replaced with three new trees.
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Future development under the proposed project would be subject to these mandatory tree
preservation requirements (Draft Program EIR, Page 3.3-27-28).
The proposed project's impacts related to biological resources would be less than significant with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact BIO-6 The proposed project would not conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved
local, regional, or State Habitat Conservation Plan. (Draft Program EIR, Page 3.3-
28).
Findings: Less than significant impact (Draft Program EIR, Page 3.3-29). No mitigation required.
Facts in Support of Findings: South San Francisco contains two areas set aside as habitat for the
conservation of threatened and endangered species, Sign Hill Park and San Bruno Mountain State
Park, the latter of which is governed by the San Bruno Mountain HCP and the San Bruno Mountain
HMP. Projects requiring a permit must comply with the requirements of the McAteer-Petris Act and
the San Francisco Bay Plan. Subsequent development under the proposed project within or adjacent
to Sign Hill Park, San Bruno Mountain State Park, or the San Francisco Bay could result in direct or
indirect effects on sensitive habitats within the Planning Area. Subsequent development under the
proposed project located within sensitive habitats or areas within the City must complete a site-
specific assessment of biological resources as part of the development review process as described
in Policy ES-6.3. The City’s environmental review process would be utilized to impose appropriate
mitigation measures on development to reduce impacts on sensitive habitats and special-status
species (per Policy ES-6-3).
Policy ES-6.2 requires wildlife and plant assessments for new development in areas that could impact
threatened or endangered species. Future projects that border San Francisco Bay and lie within
BCDC jurisdiction may require a permit and must comply with the requirements of the McAteer-
Petris Act and the San Francisco Bay Plan. Therefore, potential conflicts San Bruno Mountain HCP,
San Bruno Mountain HMP, and the San Francisco Bay Plan would be reduced to less than significant
levels and no mitigation is necessary. There are no other local, regional, or State HCPs that are
applicable to the South San Francisco Planning Area.
The proposed project's impacts related to biological resources would be less than significant with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Cumulative Impacts
The proposed project’s cumulative impacts related to biological resources would be less than
significant. (Draft Program EIR, Page 3.3-29-34).
Findings: Less than significant impact (Draft Program EIR, Page 3.3-34). No mitigation required.
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Facts in Support of Findings: The geographical scope of the cumulative impact analysis for Biological
Resources is the South San Francisco Planning Area as well as the surrounding cities of Brisbane, Daly
City, Pacifica, San Bruno, and Millbrae.
Special-status Species: A majority of the City of South San Francisco and the surrounding region is
highly urbanized and developed and contains little suitable habitat for special-status species aside
from a few areas including Sign Hill Park, San Bruno Mountain State Park as well as the remaining
pockets of saltmarsh habitat along San Francisco Bay. The cumulative geographic scope is largely
built out. Development of future projects within the cumulative geographic context, would be
required to comply with federal, State, and local laws and policies and all applicable permitting
requirements of the regulatory and oversight agencies intended to address potential impacts on
biological resources. Because cumulative development would be required to comply with the above
oversight and requirements, as well as the overall land use vision, design review regulations and
policies in local and regional plans, cumulative biological impacts would be less than significant.
The proposed project’s incremental contribution to these less than significant cumulative impacts
would not be significant with implementation of the policies and actions proposed in the General
Plan Update, including Policy ES-6.2 and Policy ES-6.3, in addition to MM BIO-1 analyzed above.
Other municipalities within the cumulative geographic context have adopted similar policies to
ensure that development within the region will not adversely affect special-status species found in
the region. Future development within the cumulative geographical context would also be required
to comply with the various federal and State laws and regulations that protect special-status plant
and animal species, including the Endangered Species Act and CESA. The General Plan Update
contains policies and actions to protect special-status species, and future development within the
cumulative geographic context would be required to comply with regulations set forth by local,
State, and federal agencies to protect biological resources.
Sensitive Natural Communities or Riparian Habitat: The geographic scope for analyzing potential
impacts to sensitive natural communities and riparian habitat includes the following sensitive natural
communities known to occur within 10 miles of the Planning Area: Northern Coastal Salt Marsh,
Northern Maritime Chaparral, Serpentine Bunchgrass, and Valley Needlegrass Grassland. In addition,
Colma Creek, San Bruno Creek, Navigable Slough of San Bruno Creek, Sign Hill Park, San Bruno
Mountain State Park, and the tidal marsh mudflats, ponds, and open water in San Francisco Bay are
considered ecologically sensitive areas. Development within the cumulative geographic context
would be required to comply with federal, State, and local laws and policies and all applicable
permitting requirements of the regulatory and oversight agencies intended to address potential
impacts on biological resources, as well as the overall land use vision, design review regulations and
policies in local and regional plans.
The proposed project’s incremental contribution to these less than significant cumulative impacts
would not be significant with implementation of the policies and actions proposed in the General
Plan Update. General Plan Update Policy ES-2.2 requires the City to establish standards and
guidelines for new construction within 150 feet of San Francisco Bay and Policy ES-3.3 requires the
City to maintain development standards and guidelines for new construction within 80 feet of Colma
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Creek. Policy ES-6.3 requires that permit applications for projects located within ecologically
sensitive habitat areas prepare site-specific biological assessments for review and approval by City
Planning staff, and incorporation of the recommended measures during construction to protect
ecologically sensitive habitat areas.
Other municipalities within the cumulative geographic context have adopted similar policies to
ensure that development within the region will not adversely affect sensitive natural communities or
riparian habitat found in the region. Future development within the cumulative geographic scope
would also be required to obtain a “Streambed Alteration Agreement” from CDFW prior to any
alteration of a lakebed, stream channel, or their banks. In addition, the General Plan Update contains
policies and actions to protect habitat, and future development within the cumulative geographic
context would be required to comply with regulations set forth by local, State, and federal agencies
to protect biological resources.
Waters of the United States: Development within the cumulative geographic context would be
required to comply with federal, State, and local laws and policies and all applicable permitting
requirements of the regulatory and oversight agencies, as well as the overall land use vision, design
review regulations and policies in local and regional plans. The proposed project’s incremental
contribution to these less than significant cumulative impacts would not be significant with
implementation of the policies and actions proposed in the General Plan Update, as well as MM BIO-
3. As analyzed above, to protect jurisdictional features, General Plan Update Policy ES-2.2 requires
the City to maintain standards and guidelines for new construction within 150 feet of San Francisco
Bay and Policy ES-3.3 requires the City to maintain development standards and guidelines for new
construction within 80 feet of Colma Creek. Policy ES-7.1 requires the City to partner with regional
and local agencies to develop a comprehensive watershed management strategy that identifies
programs, partnerships, actions, and incentives that the City and partners can take to protect the
City’s water resources and aquatic areas. MM BIO-3 requires that a qualified Biologist/wetland
regulatory specialist conduct a site investigation and assessment for projects on sites where
potential jurisdictional wetlands or waterways are present. MM BIO-3 further requires that if a
feature is found to be jurisdictional or potentially jurisdictional, that the applicant shall comply with
the appropriate permitting process with each agency claiming jurisdiction prior to disturbance of the
feature.
Other municipalities within the cumulative geographic context have adopted similar policies to
preserve existing jurisdictional features. Future development within the cumulative geographic
scope would also be required to obtain permits from the USACE and RWQCB for any development
that involves disturbance to a wetland or waters of the United States and/or State to ensure that
there is “no net loss” of wetlands or jurisdictional waters, and to require that there be an equal
amount of wetland created elsewhere to mitigate any loss of wetland. In addition, the General Plan
Update contain policies and actions to protect habitat, and future development within the
cumulative geographic context would be required to comply with regulations set forth by local,
State, and federal agencies to protect biological resources.
Fish and Wildlife Movement Corridors: Future development within the cumulative geographic scope
would not substantially interfere with the movement of any fish or wildlife species because
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development would be required to comply with federal, State, and local laws and policies and all
applicable permitting requirements of the regulatory and oversight agencies intended to address
potential impacts on fish and wildlife movement corridors, as well as the overall land use vision,
design review regulations and policies in local and regional plans.
Moreover, the proposed project’s incremental contribution would not be significant with
implementation of the policies and actions proposed in the General Plan Update as well as MMs
BIO-1 and BIO-3. General Plan Update Policies ES-1.1, ES-1.2, ES-1.3, ES-1.4, ES-2.1, ES-3.1, and ES-
6.3 would ensure that habitats important to migratory wildlife such as creeks, parks, open space,
saltmarshes, and the San Francisco Bay would not be adversely impacted without adequate
mitigation measures put in place to offset any potential impacts.
Other municipalities within the cumulative geographic scope have adopted similar policies to
preserve habitats that are crucial for migratory wildlife. In addition, the General Plan Update
contains policies and actions to protect fish and wildlife movement corridors, and future
development within the cumulative geographic context would be required to comply with
regulations set forth by local, State, and federal agencies to protect biological resources.
Local Policies or Ordinances: Future development within the cumulative geographic context would
be required to comply with local laws and policies and all applicable permitting requirements of the
regulatory and oversight agencies intended to address potential impacts on biological resources, and
with the overall land use vision, design review regulations and policies in local and regional plans.
Moreover, the proposed project’s incremental contribution to these less than significant cumulative
impacts would not be significant with implementation of the policies and actions proposed in the
General Plan Update, as well as Chapter 13.28 of the South San Francisco Municipal Code, which
outlines City’s Street Tree Preservation Policy, and Section 20.170.003 (Habitat and Biological
Resource Conservation Areas) (existing) of the South San Francisco Zoning Ordinance. Additionally,
General Plan Update Policy ES-4.1 requires the City to expand the tree canopy cover to increase
environmental benefits, prioritizing disadvantaged communities and connected wildlife corridors
and Action ES-4.1.1 requires the City to implement the City’s Urban Forest Plan. Policy ES-4.2
requires the avoidance of tree removal whenever possible, and when removals are warranted, that
each removed tree be replaced with three new trees. All development facilitated by the proposed
project would be subject to these mandatory requirements.
Other municipalities within the cumulative geographic scope have adopted similar policies to
encourage the preservation of trees and other sensitive habitat. In addition, the General Plan
Update contains policies and actions to protect biological resources, and future development within
the cumulative geographic context would be required to comply with regulations set forth by local,
State, and federal agencies.
Habitat and Natural Community Conservation Plan Consistency: South San Francisco contains two
areas set aside as habitat for the conservation of threatened and endangered species, Sign Hill Park
and San Bruno Mountain State Park, the latter of which is governed by the San Bruno Mountain HCP
and the San Bruno Mountain HMP. The BCDC has jurisdiction over all areas of San Francisco Bay that
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are subject to tidal action. Future development within the cumulative geographic scope would not
substantially conflict with the San Bruno Mountain HCP, San Bruno Mountain HMP, and the San
Francisco Bay Plan because development would be required to comply with federal, State, and local
laws and policies and all applicable permitting requirements of the regulatory and oversight agencies
intended to address potential conflicts with these plans, as well as the overall land use vision, design
review regulations and policies in local and regional plans.
Moreover, the proposed project’s incremental contribution to these less than significant cumulative
impacts would not be significant with implementation of the policies and actions proposed in the
General Plan Update, including Policy ES-6.3. Future projects within the cumulative geographic scope
that lie within BCDC jurisdiction may require a permit and must comply with the requirements of the
McAteer-Petris Act and the San Francisco Bay Plan. Other municipalities within the cumulative
geographic context have adopted similar policies to encourage the preservation of sensitive habitat
and special-status species, and would similarly be required to obtain permits for development within
areas under the jurisdiction of the BCDC. In addition, the General Plan Update contains policies and
actions to protect sensitive habitat, and future development within the cumulative geographic
context would be required to comply with regulations set forth by local, State, and federal agencies
to protect biological resources (Draft Program EIR, Page 3.3-29-34).
The proposed project's impacts related to biological resources would be less than significant with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary
1.5.4 - Cultural and Tribal Cultural Resources
Potential Effect
Impact CUL-1 The proposed project would not cause a substantial adverse change in the
significance of a historical resource pursuant to CEQA Guidelines Section 15064.5.
(Draft Program EIR, Page 3.4-32—34).
Findings: Less than significant impact (Draft Program EIR, Page 3.4-34). No mitigation required.
Facts in Support of Findings: Known historic buildings, districts and resource sites are located
throughout the Planning Area. Additional undesignated sites, and potentially unidentified sites, exist
within the Planning Area as well. Because South San Francisco is a fully built City, new development
would primarily occur on parcels that contain existing homes or businesses, which could potentially
be historic resources, with the majority of potential growth occurring within the East of 101,
Lindenville, Downtown, and El Camino planning sub-areas. Additionally, the proposed project may
result in other private and public improvements throughout the City that have the potential for
environmental effects related to historic resources.
The General Plan Update includes policies and actions specifically designed to address the
conservation and protection of historical resources. Policy SA-2.2 requires the City to protect historic
buildings and the local building fabric in the Downtown through adaptive reuse and other strategies.
Policy SA-6.1 requires that new buildings are developed at a scale and in a character compatible with
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Downtown’s existing historical and physical context. Policy SA-33.3 requires the City to preserve the
federally designated Sign Hill historic site. Policy ES-9.1 requires the City to maintain and update a
Historic Resources Inventory to promote awareness of these community resources and as a tool to
further their preservation. Action ES-9.1.1 requires the City to explore the feasibility of establishing a
Downtown South San Francisco Historical Commercial District and Action ES-9.1.2 requires the City
to prepare Downtown urban design guidelines and require design review of developments in the
proposed Downtown South San Francisco Historical Commercial District to ensure that the height,
massing, and design of buildings furthers Downtown’s character. Policy ES-9.3 requires the City to
promote the adaptive use of historic resources, particularly as inns, vacation rentals, light
commercial use, museums, educational facilities, or visitor-serving uses, when the original use can
no longer be sustained. Policy ES-9.4 requires the City to protect and preserve historic sidewalk
stamps, street signs, lampposts, street trees, and other hardscape and cultural landscape elements,
in addition to designated historical buildings, structures, and sites that contribute to the historic
character of a neighborhood, and the City. Finally, Policy ES-9.5 requires the preparation and
submittal of historic reports and surveys as part of the environmental review process. There are no
actions identified in the Climate Action Plan related to historic resources.
The South San Francisco Municipal Code contains rules and regulations that protect historical
resources. Section 2.56.080 of the Municipal Code requires the identification, protection,
enhancement, perpetuation and use of structures, sites and areas that are reminders of past eras,
events and persons important to local, State or national history, or which provide significant
examples of architectural styles of the past or are elements in the history of architecture. Section
2.56.110 grants the responsibility for designating historic resources to the Planning Commission and
establishes criteria for historic designation. Section 2.56.130 requires a Certificate of Alteration prior
to issuance of a building permit for any projects impacting a designated historic resource. In
accordance with Section 2.56.130, all proposed work must be reviewed for conformance with the
Secretary of Interior’s Guidelines for Rehabilitation.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations related to historic resources. Chapter 20.080
Downtown Residential Districts (existing) promotes and maintains the Downtown’s historic role as
the City’s center by developing a variety of residential types and densities consistent with the
policies of the General Plan and complementary to the goals and policies of the Downtown Station
Area Specific Plan District. Chapter 20.090 Downtown Station Area Zoning Districts (existing) focuses
new improvements on Grand Avenue to return this historic corridor to once again being the focus of
the community and encourage the retention of existing and local businesses to the Downtown and
protect existing historic building fabric. Section 20.360.008 (Nonconforming Signs) (revised) states
that signs which reflect the unique historical characteristics of the development and heritage of
South San Francisco may remain, subject to continued maintenance, until the use of the site on
which the sign is located changes, subject to Planning Commission approval.
Development applications will be reviewed by the City of South San Francisco for compliance with
the policies and actions of the General Plan Update related to the protection of historical resources.
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The City’s Municipal Code and Zoning Ordinance, which implement the City’s General Plan would be
reviewed when development applications are received.
Consistent with the South San Francisco Municipal Code Section 2.56.130, any projects impacting a
designated historic resource requires a Certificate of Alteration prior to issuance of a building permit
and all proposed work is to be reviewed for conformance with the Secretary of the Interior’s
Guidelines for Rehabilitation. Lastly, individual development projects which propose to alter a
building or structure greater than 45 years of age at the time an application is deemed complete
would be required to undergo project-specific environmental review in compliance with CEQA
Guidelines Section 15064.5 (Draft Program EIR, Page 3.4-32-34). Accordingly, the proposed project's
impacts related to cultural resources and tribal cultural resources would be less than significant with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact CUL-2 The proposed project would not cause a substantial adverse change in the
significance of an archaeological resource pursuant to Section 15064.5. (Draft
Program EIR, Page 3.4-34-36).
Findings: Less than significant impact (Draft Program EIR, Page 3.4-36). No mitigation required.
Facts in Support of Findings: Known archaeological resource sites are located within the Planning
Area. Some of South San Francisco’s known archaeological resources are located within areas
undergoing development, such as Terrabay and El Camino Real. Additionally, undiscovered
archaeological sites could exist in the Planning Area. Development under the proposed project could
affect known archaeological resources or previously unidentified or undesignated archaeological
resources.
The potential for additional archaeological sites to be present within the City exists but varies by
location. Prehistoric habitation sites, such as those known to be present within the City, tend to be
situated along creeks and other areas with a reliable water supply, whereas task-specific sites or
resource procurement sites can be situated in almost any environment conducive to human activity.
Buried prehistoric archaeological sites tend to be found on Holocene-age landforms, particularly
alluvial fans, floodplains, and areas along rivers and streams. As such, within the Planning Area, the
waterfront and the areas around Colma Creek and San Bruno Creek have the greatest potential for
buried prehistoric archaeological resources to be present.
The General Plan Update includes policies and actions specifically designed to address potential
impacts to archaeological resources. For example, Policy ES-10.1 requires the City to maintain formal
procedures for minimizing and mitigating impacts to archaeological resources and Policy ES-10.2
requires the City to support educational efforts that increase community awareness, appreciation,
and support for South San Francisco’s archaeological resources. Policy ES-10.3 requires that
development proposals be referred to the NWIC of the California Archaeological Inventory, NAHC,
and local Native American tribes, for review and recommendations regarding supplemental field
investigation. Policy ES-10.4 requires a records review for any development proposed in areas of
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known archaeological resources. Lastly, as required by Policy ES-10.5, if construction or grading
activities result in the discovery of significant historic or prehistoric archaeological artifacts, then all
work within 100 feet of the discovery shall cease, the Economic and Community Development
Department shall be notified, and the resources shall be examined by a qualified archaeologist for
appropriate protection and preservation measures. As stipulated by Policy ES-10.5, work may only
resume when appropriate protections are in place and the protections have been approved by the
Economic and Community Development Department. There are no actions identified in the Climate
Action Plan related to archaeological resources.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations related to archaeological resources. Section
20.110.004 (Supplemental Regulations) (existing) states that open space uses allowed within the
Terrabay Preservation Parcel must be in conformance with the General Plan and the Mutual Release
and Settlement Agreement executed in March 2000 between Terrabay Partners. L.L.C.,
Myers/Sunchase I, L.L.C., The Center for Biological Diversity, San Bruno Mountain Watch and the City
of South San Francisco, including wetlands preservation and mitigation, habitat preservation, and
preservation of archaeological resource site CA-SMa-40.
Proposed new development would be required to conduct a records search with the NWIC to
determine the archaeological sensitivity of the site, as well as be referred to the NAHC and local
Native American tribes. If required, an archaeological survey of the site would be conducted and/or
accidental discovery procedures for archaeological resources would be required. In addition,
proposed new development would be required to preserve archaeological resource site CA-SMa-40.
Compliance with General Plan Update policies and actions and the regulations of the Zoning
Ordinance would ensure that future development projects are appropriately reviewed and designed
in terms of potential impacts to archaeological resources (Draft Program EIR, Page 3.4-34-36).
Accordingly, the proposed project's impacts related to cultural resources and tribal cultural resources
would be less than significant with the implementation of applicable regulations, including new and
revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact CUL-3 The proposed project would not disturb human remains, including those interred
outside of formal cemeteries (Draft Program EIR, 3.4-36).
Findings: Less than significant impact (Draft Program EIR, Page 3.4-36). No mitigation required.
Facts in Support of Findings: Excavation and construction activities allowed under the proposed
project may uncover human remains that may not be marked in formal burial locations. Therefore,
as future development and infrastructure projects are reviewed by the City, each project would be
evaluated for conformance with the General Plan Update, South San Francisco Municipal Code, and
other applicable State regulations.
Public Resources Code Section 5097 has specific stop-work and notification procedures to follow
when Native American human remains are inadvertently discovered during excavation and
construction activities. Section 7050.5 of the California Health and Safety Code sets forth provisions
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related to the treatment of human remains, including the treatment of human remains found in
locations other than a dedicated cemetery and the responsibilities of the Coroner. These
requirements apply to all construction projects within the Planning Area.
The General Plan Update includes policies and actions intended to conserve and reduce impacts to
archaeological resources, including human remains. Policy ES-11.1 requires the City to identify,
preserve, and protect TCRs, traditional cultural landscapes, sacred sites, places, features, and
objects, including historic or prehistoric ruins, burial grounds, cemeteries, and ceremonial sites in
consultation or coordination with the appropriate Native American tribe(s). Policy ES-11.1 further
requires the appropriate treatment of Native American and other human remains discovered during
project construction. (Draft Program EIR, 3.4-36).
Accordingly, the proposed project's impacts related to cultural resources and tribal cultural resources
would be less than significant with the implementation of applicable regulations, including new and
revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact CUL-4 The proposed project would not cause a substantial adverse change in the
significance of a Tribal Cultural Resource that is listed or eligible for listing in the
California Register of Historical Resources, or in a local register of historical
resources as defined in Public Resources Code Section 5020.1(k). (Draft Program
EIR, Page 3.4-37-38).
Findings: Less than significant impact (Draft Program EIR, Page 3.4-38). No mitigation required.
Facts in Support of Findings: On February 15, 2022, a letter was sent to the NAHC to determine
whether any sacred sites are listed on its Sacred Lands File for the Planning Area. A response was
received on March 27, 2022, indicating the search returned negative results for TCRs in the Planning
Area. A records search conducted at the NWIC identified 15 listed prehistoric sites that meet the
definition of a TCR within the Planning Area.
Future development allowed under the proposed project could affect known or previously
unidentified TCRs. In addition, the potential for additional undiscovered eligible TCRs to be present
within the Planning Area exists but varies by location. As with prehistoric archaeological resources,
the waterfront and the areas around Colma Creek and San Bruno Creek have the greatest potential
for buried TCRs to be present.
The General Plan Update includes policies and actions intended to conserve and reduce impacts to
TCRs. Policy ES-11.1 requires the City to identify, preserve, and protect TCRs, traditional cultural
landscapes, sacred sites, places, features, and objects, including historic or prehistoric ruins, burial
grounds, cemeteries, and ceremonial sites in consultation or coordination with the appropriate
Native America tribe(s). Policy ES-11.3 requires the City to Consult with local Native American tribes
to identify, evaluate, and appropriately address TCRs and tribal sacred sites through the
development review process. There are no regulations identified in the Zoning Code Amendments
and no actions identified in the Climate Action Plan related to TCRs.
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The General Plan Update also includes policies and actions intended to conserve and reduce impacts
to archaeological resources, which can include TCRs. Policy ES-10.3 requires that development
proposals be referred to the NWIC of the California Archaeological Inventory, NAHC, and local Native
American tribes, for review and recommendations regarding supplemental field investigation. Policy
ES-10.4 requires a records review for any development proposed in areas of known archaeological
resources. As required by Policy ES-10.5, if construction or grading activities result in the discovery of
significant historic or prehistoric archaeological artifacts, then all work within 100 feet of the
discovery shall cease, the Economic and Community Development Department shall be notified, and
the resources shall be examined by a qualified archaeologist for appropriate protection and
preservation measures. As stipulated by Policy ES-10.5, work may only resume when appropriate
protections are in place and the protections have been approved by the Economic and Community
Development Department (Draft Program EIR, Page 3.4-37-38).
Accordingly, the proposed project's impacts related to cultural resources and tribal cultural resources
would be less than significant with the implementation of applicable regulations, including new and
revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact CUL-5 The proposed project would not cause a substantial adverse change in the
significance of a Tribal Cultural Resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be significant pursuant to the
criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. (Draft
Program EIR, Page 3.4-38).
Findings: Less than significant impact (Draft Program EIR, 3.4-38). No mitigation required.
Facts in Support of Findings: On February 15, 2022, a letter was sent to the NAHC to determine
whether any sacred sites are listed on its Sacred Lands File for the project area. A response was
received on March 27, 2022, indicating the search returned negative results for TCRs in the Planning
Area, and recommended contacting tribal representatives from six tribes for additional information.
On January 14, 2022, in accordance with requirements promulgated by SB 18 and AB 52, the City
notified the Amah Mutsun Tribal Band, the Coastanoan Rumsen Carmel Tribe, the Indian Canyon
Mutsun Band, the Muwekma Ohlone Indian Tribe of San Francisco Bay, and the Ohlone Indian Tribe
of the proposed project and invited the tribes to participate in consultation. On April 6, 2022, in
accordance with requirements promulgated by SB 18 and AB 52, the City notified the Wuksache
Indian Tribe/Eshom Valley Band of the proposed project and invited the tribe to participate in
consultation. As of June 6, 2022, no responses have been received.
At this time, the City, in its capacity as Lead Agency, has not identified TCRs throughout various sites
in the Planning Area pursuant to criteria set forth in subdivision (c) of Public Resources Code Section
5024.1 that would be adversely impacted by the proposed project. Nonetheless, as described under
Impact CUL-4, future development allowed under the proposed project could affect previously
unidentified TCRs. The General Plan Update includes policies and actions to conserve and reduce
impacts to TCRs, such as Policy ES-11.1, Policy ES-11.3, Policy ES-10.3, and Policy ES-10.5. By
adhering to the policies and actions in the General Plan Update, as well as the provisions under SB
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18 and AB 52, potential impacts to existing or undiscovered eligible TCRs within the Planning Area
would be reduced to less than significant and no mitigation is required
Cumulative Impact
The proposed project’s cumulative impacts related to cultural resources would be less than
significant (Draft Program EIR, Page 3.4-38-40).
Findings: Less than significant impact (Draft Program EIR, Page 3.4-40). No mitigation required.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for cultural and
TCRs is the South San Francisco Planning Area as well as the surrounding cities of Brisbane, Daly City,
Pacifica, San Bruno, and Millbrae.
Future development within the cumulative geographic scope could have significant cumulative
impacts on known or previously unidentified cultural and TCRs. Development within the cumulative
geographic context would be required to comply with federal, State, and local laws and policies that
protect cultural and TCRs, including the provisions of SB 18 and AB 52, Section 15064.5 of the CEQA
Guidelines, Section 7050.5 of the California Health and Safety Code, and Sections 5024.1 and 5097 of
the Public Resources Code. Compliance with these policies may also require development projects to
prepare site-specific, project-level analysis to fulfill CEQA requirements, which also would include
additional consultation that could lead to the identification of potential site-specific cultural and
TCRs.
Moreover, the proposed project’s incremental contribution to these less than significant cumulative
impacts would not be significant with implementation of the policies and actions proposed in the
General Plan Update. General Plan Update Policy ES-9.5 requires the preparation and submittal of
historic reports and surveys as part of the environmental review process. Policy ES10.3 requires that
development proposals be referred to the NWIC of the California Archaeological Inventory, NAHC,
and local Native American tribes, for review and recommendations regarding supplemental field
investigation. Policy ES-10.4 requires a records review for any development proposed in areas of
known archaeological resources. As required by Policy ES-10.5, if construction or grading activities
result in the discovery of significant historic or prehistoric archaeological artifacts, then all work
within 100 feet of the discovery shall cease, the City’s Economic and Community Development
Department shall be notified, and the resources shall be examined by a qualified archaeologist for
appropriate protection and preservation measures. Lastly, Policy ES-11.1 requires the City to identify,
preserve, and protect TCRs, traditional cultural landscapes, sacred sites, places, features, and
objects, including historic or prehistoric ruins, burial grounds, cemeteries, and ceremonial sites in
consultation or coordination with the appropriate Native America tribe(s).
As discussed under Impacts CUL-1 through CUL-5, development applications will be reviewed by the
City for compliance with the policies and actions of the General Plan Update, the provisions of SB 18
and AB 52, the South San Francisco Municipal Code, and other relevant federal, State, and local
regulations that protect cultural and TCRs, including Section 15064.5 of the CEQA Guidelines and
Sections 5024.1 and 5097 of the Public Resources Code. Other municipalities within the cumulative
geographic context have adopted similar policies to preserve and protect known or previously
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unidentified cultural and TCRs. Therefore, cumulative impacts from implementation of the proposed
project would not result in a considerable incremental contribution to cumulative impacts to cultural
and TCRs. In addition, the General Plan Update contains policies and actions to protect cultural and
TCRs, and future development within the cumulative geographic context would be required to
comply with regulations set forth by local, State, and federal agencies to protect cultural and TCRs.
Therefore, the proposed project’s contribution to cumulative impacts would be less than significant
(Draft Program EIR, Page 3.4-38-40).
Accordingly, the proposed project's cumulative impacts related to cultural resources and tribal
cultural resources would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update policies and implementing actions. No mitigation is
necessary.
1.5.5 - Energy
Potential Effect
Impact ENER-1 The proposed project would not result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary consumption of energy
resources, during project construction or operation. (Draft Program EIR, Page 3.5-
17-22)
Findings: Less than significant impact (Draft Program EIR, Page 3.5-22). No mitigation required.
Facts in Support of Findings:
Construction
The proposed project does not expressly authorize any specific construction projects.
Incremental potential growth in residential and nonresidential uses would be infill
development occurring in already developed areas throughout the City, with the
concentration of population, employment, and services allowing for more efficient use of
energy during construction. Construction activities associated with individual development
projects under the proposed project would consume energy in the form of petroleum fuel for
heavy equipment, as well as from worker trips and material delivery trips to the construction
sites. Because details regarding future construction activities are unknown, energy usage
associated with construction activities cannot be calculated at this time. Subsequent
environmental review of future development projects would be required to assess potential
construction-related energy consumption impacts. Future development projects would be
required to evaluate, measure, and mitigate air quality and GHG impacts generated from
construction activities which would also assist in reducing energy consumption during
construction. The Bay Area Air Quality Management District (BAAQMD) recommended
Construction Measures would apply to future projects, including provisions which would
assist in reducing energy consumption during construction and prevent the wasteful,
inefficient, or unnecessary consumption of energy resources. The General Plan Update
policies and actions related to air quality and GHG emissions, would also assist in reducing
energy consumption during construction. For example, Policy CHEJ-3.1 requires the City to
support regional efforts to improve air quality and protect human health. Action CHEJ-3.1.1
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requires the City to work with the BAAQMD to establish and identify funding for air quality
monitoring and reduction strategies. This action may include purchasing particulate matter
(PM2.5) monitors to track local air quality data in Lindenville, East of 101, and Downtown.
Action CHEJ-3.2.2 requires the City to establish a local ordinance that exceeds the State
vehicle idling restrictions where appropriate, including restrictions for bus layovers, delivery
vehicles, trucks at warehouses and distribution facilities and taxis, particularly when these
activities take place near sensitive land uses (schools, healthcare facilities, affordable
housing, and elder and childcare centers). Action CHEJ3.2.2 also requires the City to manage
truck idling in new residential neighborhoods in Lindenville and East of 101. Lastly, Policy CP-
5.4 requires 75 percent waste diversion for municipal construction and demolition projects.
Additionally, The South San Francisco Municipal Code contains rules and regulations to
reduce energy usage during construction. Chapter 15.60 promotes the redirection of
recyclable materials generated during construction away from landfills. All project applicants
are required to complete and submit a recycling management plan to estimate the volume of
debris to be generated during construction and the estimated amount of debris that would
be sent to the landfill. Section 15.62 (Deconstruction and Salvage and Recovery) requires the
City to encourage contractors to make every structure planned for demolition available for
deconstruction, salvage, and recovery prior to demolition; and to recover the maximum
feasible amount of salvageable designated recyclable and reusable materials prior to
demolition, by at least the rate set forth in Section 4.408 of Chapter 4 of the CALGreen, as
may be amended from time to time.
Future development under the proposed project would be required to comply with
requirements of the South San Francisco Municipal Code and the General Plan Update
policies and actions that directly and indirectly reduce energy consumption during
construction. Future development would also be required to comply with California Code of
Regulations Title 13, Sections 2449(d)(3) and 2485, that limit idling from both on-road and
off-road diesel-powered equipment and are enforced by the ARB.
Operation
The electricity and natural gas consumption associated with the potential development calculated in
CalEEMod found that the potential development would result in a net increase in consumption of
237,352,420 kWh of electricity per year and 392,651,730 kilo-British Thermal Units (kBTUs) of
natural gas per year. These rates are based on CalEEMod default parameters which accounts for the
2019 California Code of Regulations Title 24 Part 6 standards. These standards require all homes
built in California to have zero net energy use, which is achieved through energy efficiency measures
as well as required rooftop solar photovoltaic systems. The 2019 California Code of Regulation Title
24 Part 6 standards also apply to nonresidential buildings and require a variety of energy efficiency
measures to be implemented during construction of the structures that will reduce energy usage as
well as air emissions. It is anticipated that the future development within the City will be designed
and built to minimize electricity and natural gas usage.
The total VMT would increase from the existing 3,387,200 VMT (calculated based on 2019) to
6,585,400 VMT with buildout of the proposed project and the service population would increase
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from the existing 123,500 service population to a service population of 245,700 with buildout of the
proposed project. Because of the balanced growth of both residential and employment
opportunities in the General Plan Update, as well as the extensive public transit options available in
the City, the daily VMT per service population (employees + residents) is anticipated to be reduced
from 27.42 VMT per service population for existing conditions to 26.80 VMT per service population
under proposed project buildout conditions. The reduction in VMT per service population would
result in improvements to energy efficiency for transportation-related energy usage.
The implementation of the proposed project would result in an estimated consumption of an
additional 128,851 gallons of petroleum fuel per year. However, Executive Order N-79-20 requires
sales of all new passenger vehicles to be zero-emission by 2035 and additional measures to
eliminate harmful emissions from the transportation sector; thus, further reduction in vehicle
emissions would be forthcoming.
The General Plan Update contains several policies and actions that assist in reducing energy
consumption and petroleum fuel use. Policy CP-2.1 requires the City to maintain membership in
Peninsula Clean Energy and continue to work to maintain a high level of private property owner
participation in Peninsula Clean Energy. Policy CP-2.2 requires the City to partner with PG&E to
develop options for reducing greenhouse gas emissions associated with the existing natural gas grid.
Action CP-3.1.1 requires the City to provide incentives to encourage new construction to exceed
California’s Building Energy Efficiency Standards outlined in Title 24, Part 6. Policy LU-1.2 requires the
City to improve walk, bike, and accessibility in complete neighborhoods. Policy LU-2.1 requires the
City to collaborate with developers and property owners to locate new housing, mixed use, and
employment uses near transit centers to minimize reliance on personal automobiles. Lastly, Action
CHEJ-3.3.1 requires the City to explore opportunities for production, distribution, and warehousing
uses in Lindenville and East of 101 to reduce pollution, such as greener trucks, energy efficient
buildings, and other strategies.
The South San Francisco Municipal Code contains rules and regulations related to energy resources.
Section 15.22.010 adopts the CALGreen, 2019 Edition. Section 15.26.010 adopts the California
Energy Code 2019 Edition. Chapter 15.62 of the Municipal Code aims to encourage the use of solar
energy systems and comply with the Solar Rights Act by reducing local discretion in permitting for
solar energy systems and creating an expedited, streamlined solar permitting process for small
residential rooftop solar energy systems.
The South San Francisco Zoning Ordinance includes Section 20.300.008 which establishes regulations
allowing outdoor lighting for uses and activities consistent with the need for utility, safety, and
nighttime attractiveness while minimizing energy waste which increases impacts on the environment
through energy production byproducts. Section 20.300.007 includes a number of requirements for
new construction or rehabilitated landscapes to aid in energy conservation by providing shade from
the sun and shelter from the wind and encourage the conservation of water resources through the
use of native and drought-tolerant plans and water-conserving irrigation practices.
The Climate Action Plan includes a number of actions to minimize energy consumption.
Implementation of Action CE-1.3 would establish a streamlined PV system permitting and approval
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process to encourage the addition of solar PV systems. Implementation of Action CE-1.6 includes the
exploration of opportunities to install community scale solar PV or other renewable energy systems
including biogas to support local energy resiliency and provide renewable energy to disadvantaged
communities. Implementation of Action BE-1.2 would update zoning and building codes to require
alternations or additions at least 50 percent the size of the original building to comply with minimum
CALGreen requirements.
Moreover, all new development in the City would be required to meet State energy efficiency
regulations including Title 24 Part 6 building energy efficiency standards that require new residential
uses to meet a net zero energy use standard, which is met through installation of rooftop solar PV
systems, enhanced insulation, and energy efficient appliances. Additionally, the City of South San
Francisco Municipal Code Section 15.26.020 requires new residential development to only include
all-electric design features and prohibits the use of natural gas utilities.1 The Title 24 Part 6
requirements also require nonresidential buildings to be designed for increased energy efficiency
standards. Other State energy efficiency regulations include SB 100 which requires 100 percent of
retail sales of electricity to be generated from zero-carbon emission sources by 2045 and Executive
Order N-79-20 which requires 100 percent of new passenger vehicles sold in California to be zero-
emission by 2035.
Furthermore, the proposed project minimizes petroleum fuel use for transportation by locating new
housing and jobs in the East of 101, Lindenville, Downtown, and El Camino planning sub-areas,
which are well served by Caltrain, BART, or SamTrans service and have good access to opportunity
(such as jobs, neighborhood amenities, and health care facilities). Finally, the implementation of
Mitigation Measure (MM) TRANS-1, which requires the City to implement its Transportation Demand
Management (TDM) Ordinance as part of the Zoning Code Amendments and parking requirements,
would reduce VMT. Lastly, implementation of the proposed project would minimize petroleum fuel
use for transportation. (Draft Program EIR, Page 3.5-17 – 22). The proposed project’s impacts related
to energy would be less than significant with the implementation of applicable regulations, including
new and revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact ENER-2 The proposed project would not conflict with or obstruct a State or local plan for
renewable energy or energy efficiency (Draft Program EIR, Page 3.5-22-23).
Findings: Less than significant impact (Draft Program EIR, Page 3.5-23). No mitigation required.
Facts in Support of Findings: Development (including redevelopment of existing developed sites)
consistent with the proposed project would be required to implement all applicable energy
efficiency measures listed in the CAP. In addition, all future development would be required to
adhere to the South San Francisco Municipal Code and Zoning Ordinance, which contains rules and
regulations regarding energy efficiency. The policies and programs in the General Plan Update would
not conflict with applicable State or regional plans for renewable energy or energy efficiency that
1 City of South San Francisco. 2021. Ordinance Summary. Website:
https://www.ssf.net/home/showpublisheddocument/23685/637582409224270000. Accessed June 6, 2022.
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include Plan Bay Area 2050, BAAQMD 2017 Clean Air Plan, Executive Order N-79-20 which requires
100 percent of new passenger vehicles sold in California to be zero-emissions by 2035, and SB 100
that requires 100 percent of retail sales of electricity to be generated from zero-carbon emission
sources by 2045. On the contrary, the policies and actions in the General Plan Update support State
and regional plans for renewable energy and energy efficiency, such as Policy CP-5.1 which requires
all new municipal buildings and facilities to meet a minimum of Leadership in Energy and
Environmental Design (LEEDTM) silver rating or equivalent green building rating system. Policy CP-5.5
requires new municipal buildings and facilities and major renovation projects to evaluate the
feasibility of incorporating on-site batteries that store electricity from on-site renewable energy
generation to supply the building and community with electricity in the event of a disaster. Policy CP-
8.1 requires the City to continuously evaluate and, as appropriate, replace systems at the
wastewater treatment plant to reduce energy use. (Draft Program EIR, Page 3.5-22) Accordingly, the
proposed project's impacts related to energy would be less than significant with the implementation
of applicable regulations, including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary.
Cumulative Impact
The proposed project’s cumulative impacts related to energy would be less than significant (Draft
Program EIR, Page 3.5-23-24).
Findings: Less than significant impact (Draft Program EIR, Page 3.5-24). No mitigation required.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for energy
resources is the South San Francisco Planning Area as well as the surrounding cities of Brisbane,
Colma, Daly City, Pacifica, San Bruno, and Millbrae.
Cumulative projects would be required to comply with local ordinances and county and city General
Plan policies that address energy conservation and energy efficiency, such as complying with the
latest California Energy Code, Title 24 Building Energy Efficiency Standards, and CALGreen.
Furthermore, PG&E, which supplies electricity to the cumulative project area, would be required by
SB 100 to incrementally increase the proportion of renewable electricity generation supplying its in-
state retail sales until it reaches 100 percent carbon-free electricity generation by 2045. Cumulative
projects would be required to comply with California Code of Regulations Title 13, Sections
2449(d)(3) and 2485, that limit idling from both on-road and off-road diesel-powered equipment and
are enforced by the ARB. Additionally, various federal and State regulations, including the Low
Carbon Fuel Standard (LCFS), Pavley Clean Car Standards, and LEV Program, would serve to reduce
the transportation fuel demand of cumulative projects.
As discussed above, development resulting from implementation of the proposed project would be
subject to General Plan Update and CAP policies and actions and the South San Francisco Municipal
Code and Zoning Ordinance to reduce energy consumption. As previously discussed, future
development under the proposed project would be required to conform to State, regional, and local
policies that would reduce impacts related to energy resources to less than significant levels. When
applicable, any additional new development within the Planning Area would be subject, on a
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project-by-project basis, to independent CEQA review as well as policies and actions in the General
Plan Update and CAP, the South San Francisco Municipal Code and Zoning Ordinance, and other
applicable City requirements that reduce impacts related to energy resources (Draft Program EIR,
Page 3.5-23—24). The proposed project's cumulative impacts related to energy would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
1.5.6 - Geology, Soils, and Seismicity
Potential Effect
Impact GEO-1: The proposed project could directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for
the area or based on other substantial evidence of a known fault? Refer to
Division of Mines and Geology Special Publication 42.
ii) Strong seismic ground shaking.
iii) Seismic-related ground failure, including liquefaction.
iv) Landslides (Draft Program EIR, Page 3.6-17—23).
Findings: Less than significant impact (Draft Program EIR, 3.6-23). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. Because South San
Francisco is a fully built city, new development would primarily occur on parcels that already contain
some existing homes or businesses. The City’s proximity to the San Andreas Fault Zone and other
active faults makes it likely that the Planning Area would experience periodic minor to strong
earthquake motion and potentially expose additional residents and employees to the effects of
surface fault rupture, seismic ground shaking, liquefaction, settlement, and landslides from local and
regional earthquakes. Structures that would be built on steep slopes could be exposed to an existing
risk of landslide or could exacerbate existing landslide conditions. New structures and other private
and public improvements built under the proposed project could also experience substantial damage
during seismic events. Estimating project-specific impacts is not possible at this time as the proposed
project does not describe specific development projects.
Compliance with local codes, mandatory CBC requirements, and implementation of General Plan
Update policies and actions, would ensure that future development projects are appropriately
investigated in terms of potential seismic hazards and that any new buildings and structures are
constructed to withstand the anticipated range of seismic events. At the programmatic level, seismic
impacts would be reduced to a less than significant level. Consistent with General Plan Update
policies and actions and the rules and regulations of the Municipal Code and Zoning Ordinance,
individual development projects would be required to undergo project-specific environmental
review, which may require additional site-specific or project-specific measures to reduce any
potential for loss, injury, or death in the event of a seismic event.
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i) Surface Fault Rupture
Within the Planning Area, the Alquist-Priolo Earthquake Fault Zone is up to 1,200 feet wide, passes
through the westernmost corner of the City, and contains Holocene-active strands of the San
Andreas Fault Zone.2 As depicted on the San Francisco South Regulatory Map, surface fault rupture
occurred within the westernmost corner of the City during the 1906 San Francisco Earthquake. The
majority of potential growth under the proposed project would occur outside the Alquist-Priolo
Earthquake Fault Zone. Land uses within the Alquist-Priolo Earthquake Fault Zone are currently
developed with urban uses and could be exposed to the effects of surface fault rupture in the event
of an earthquake.
The General Plan Update includes policies and actions to minimize structural damage and minimize
the exposure of people to risk of injury or death from structural failure in the event of surface fault
rupture during an earthquake. Action CR-1.3.3 requires the City to enact an ordinance to require real
estate disclosures of all hazards identified in the Hazard Mitigation Plan, including hazards associated
with geologic hazards, for commercial and residential properties including ownership and rental.
Policy CR-1.4 requires the City to periodically adjust infrastructure design standards to address asset-
specific vulnerabilities associated with the hazards. As part of the capital planning and budgeting
process, Policy CR-1.5 requires all projects located within high hazard areas to adhere to risk
assessment guidance and identify appropriate resilience strategies. Action CR-4.1.4 requires the City
to incentivize retrofits of buildings and other mitigation measures in seismic and geologic hazards
zones and explore developing a specific program to address seismic retrofit needs within South San
Francisco’s affordable housing stock. Action CR-4.4.1 requires that permit applications for projects
located within areas susceptible to geologic hazards (Figure 43 of the General Plan Update) prepare
site-specific soils and geologic reports for review and approval by the City Engineer, and incorporate
recommended actions during construction. Lastly, Action CR-4.4.1 requires that future proposed
projects located within the Alquist-Priolo Earthquake Fault Zone be subject to conducting an
environmental analysis at the time a specific project is defined, including preparation of site-specific
soils and geologic reports for review and approval by the City Engineer, and incorporation of the
recommended actions during construction.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, contains rules and regulations regarding development within the Alquist-Priolo
Earthquake Fault Zone. For example, new Section 20.310.002 identifies grading and drainage
requirements for all projects throughout the City, including those located within the Alquist-Priolo
Earthquake Fault Zone.
Potential structural damage and exposure of people to risk of injury or death from structural failure
associated with surface fault rupture would be reduced by compliance with CBC engineering design
and construction measures. Foundations and other structural support features would be designed to
resist or absorb damaging forces from strong ground shaking and surface fault rupture. Chapter
15.08 of the South San Francisco Municipal Code incorporates the most recent CBC. The South San
2 California Division of Mines and Geology (CDMG). Earthquake Planning Scenario for a Magnitude 8.3 Earthquake on the San
Andreas Fault in the San Francisco Bay Area. Special Publication 61, 1982.
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Francisco Building Division reviews plans and applications for site clearance, grading, and building
permits to ensure compliance with Chapter 15.08 (California Building Standards Code) and imposes
requirements for revisions where needed to ensure that new or significantly remodeled structures
are constructed in compliance with the CBC, and reflect any additional measures deemed
appropriate. Permit issuance would be based upon satisfactory completion of any identified
applicable measures.
ii) Strong Seismic Ground Shaking
As mentioned previously, the entire Planning Area is within a seismically active region that could
experience strong ground shaking during a seismic event. The southwestern corner and most of the
City east of El Camino Real is located within Zone VIII (Very Strong) and is estimated to experience
moderate structural damage. The remainder of the City, including the portions fronting the San
Francisco Bay, are located within Zone IX (Violent) and are estimated to experience heavy structural
damage. The intensity of ground shaking at a specific site would depend on the characteristics of the
fault, distance from the fault, magnitude and duration of the earthquake, and site-specific geologic
conditions.
The General Plan Update includes policies and actions to protect residents and employees of the City
and surrounding areas from seismically induced hazards associated with strong seismic ground
shaking. This includes Action CR-4.1.1, Policy CR-1.4, and Policy CR-1.5 discussed above. Action CR-
4.1.2 requires the City to regularly update the City’s Building Code to incorporate current earthquake
standards. Action CR-1.3.1 requires the City to participate in the San Mateo County Hazard
Mitigation Plan maintenance protocols and Countywide initiatives, adopt the Hazard Mitigation Plan
by reference upon update, and update emergency operations plans and protocols to account for
regularly updated hazard information. Action CR-1.6.2 calls for the addition of a second floor to the
City’s EOC and a warehouse to store supplies to support the City in the event of a disaster, as well as
ensure the EOC has the necessary capabilities and can continue operations after all future hazards.
Action CR-1.6.3 requires the City to establish a community resilience education program in
collaboration with San Mateo County and local community partners and work with the Community
Emergency Response Team and promotes programs to disseminate the information. Lastly, Action
CR-1.6.4 requires the City to identify locations for emergency housing, siting locations in areas with
lower hazard risk, and Action CR-1.8.1 requires the City to create a post-disaster recovery framework
that establishes post-disaster policies and programs designating when, where, and how rebuilding
will occur.
Compliance with local codes, mandatory CBC requirements, and implementation of General Plan
Update policies and actions, would ensure that future development projects are appropriately
investigated in terms of potential seismic hazards and that any new buildings and structures are
constructed to withstand the anticipated range of seismic events. Individual development projects
would be required to undergo project-specific environmental review, which may require additional
site-specific or project-specific measures to reduce any potential for loss, injury, or death in the
event of a seismic event.
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iii) Seismic-related Ground Failure
Secondary effects of earthquake shaking may include landslides, slope instability, liquefaction,
subsidence, and lateral spreading. The majority of the Planning Area is located within a low or
moderate risk category for landslides. Portions of the City are hilly and underlain with weak bedrock
with slopes greater than 15 percent and have the greatest susceptibility to landslides. In the Paradise
Valley/Terrabay area, slopes still pose elevated rockfall risks. Areas near the San Francisco Bay have
high ground failure potential, including liquefaction and settlement during earthquake shaking. Most
of the lowland areas of the City have the potential for liquefaction hazards, with very high
liquefaction potential in the East of 101 and Lindenville sub-areas, high potential along Colma Creek,
and moderate potential in the alluvial fan of Colma Creek and in a narrow strip of land south of Sister
Cities Boulevard. Liquefaction-induced lateral spreading could occur in the low-lying coastal areas
and along Colma Creek.3 Additional residents, employees, buildings, and infrastructure, could be
exposed to the secondary effects of local and regional earthquakes.
The South San Francisco Municipal Code and Zoning Ordinance and policies and actions of the
General Plan Update would protect against the secondary effects of earthquake shaking. This
includes previously discussed Chapter 15.08 of the South San Francisco Municipal Code, Section
20.310.002 the South San Francisco Zoning Ordinance, and Section 20.170.004 of the South San
Francisco Zoning Ordinance. Future proposed projects located within areas susceptible to seismic-
related ground failure would be required to conduct an environmental analysis at the time a specific
project is defined, including preparation of site-specific soils and geologic reports for review and
approval by the City Engineer, and incorporation of the recommended actions during construction.
iv) Landslides
As discussed above the majority of the Planning Area is located within a low or moderate risk
category for landslides, with some portions of the City at greater risk for landslides and rockfalls.
Additional residents and employees, as well as buildings and infrastructure, could potentially be
exposed to landslides.
The General Plan Update includes policies and actions specifically designed to protect individuals
from injuries and minimize property damage resulting from land instability by limiting development
in certain areas and requiring increased review and mitigation where appropriate. These include
Action CR-1.3.3, Policy CR-1.4, Policy CR-1.5 as discussed previously. Policy CR-4.3 discourages
development on steep hillside areas more than 30 percent grade and requires that development of
hillside sites follow existing contours to the greatest extent possible and that grading is kept to a
minimum.
3 California Department of Conservation, California Geological Survey (CGS). 2021. Seismic Hazard Zone Report for the San Francisco
South 7.5-Minute Quadrangle. Website:
https://www.conservation.ca.gov/cgs/Documents/Publications/SHZR/SHZR_133_San_Francisco_South_a11y.pdf. Accessed
February 27, 2022
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The South San Francisco Municipal Code also contains rules and regulations to address development
on lands susceptible to landslides. This includes Section 20.310.002 of the South San Francisco
Zoning Ordinance and Chapter 15.08 of the South San Francisco Municipal Code, discussed above.
The South San Francisco Building Division reviews plans and applications for site clearance, grading,
and building permits to ensure compliance with Section 20.310.002 and Chapter 15.08 and imposes
requirements for revisions where needed to ensure that new or significantly remodeled structures
are constructed in compliance with these requirements, and reflect any additional measures
deemed appropriate. Permit issuance would be based upon satisfactory completion of any identified
applicable measures. Future projects would be required to conduct an environmental analysis at the
time a specific project is defined. In reviewing individual project applications, the City would
determine which policies and actions apply, and which sections of the Municipal Code and Zoning
Ordinance apply, depending on the specific characteristics of the project type and/or project site
during the development review process (Draft Program EIR, Page 3.6-17-23). The proposed project's
impacts related to geology, soils, and seismicity would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions.
No mitigation is necessary.
Potential Effect
Impact GEO-2 The proposed project would not result in substantial soil erosion or the loss of
topsoil (Draft Program EIR, Page 3.6-23-24).
Findings: Less than significant impact (Draft Program EIR, Page 3.6-24). No mitigation required.
Facts in Support of Findings: Development under the proposed project would involve construction
activities such as stockpiling, grading, excavation, paving, and other earth-disturbing activities. Loose
and disturbed soils are more prone to erosion and loss of topsoil by wind and water. As such, soil
erosion is dependent on individual site locations and conditions on-site during construction.
Construction activities that disturb one or more acre of land surface are subject to the NPDES
General Permit for Stormwater Discharges Associated with Construction and Land Disturbance
Activities (Order No. 2012-0006-DWQ). Permit conditions require development of a Storm Water
Pollution Prevention Plan and inspection of construction sites before and after a storm to identify
stormwater discharge from construction activity and to identify and implement erosion controls,
where necessary.
The General Plan Update includes policies and actions that would reduce soil erosion and loss of
topsoil, including Policy CR-4.3. Policy ES-7.1 requires the City to partner with regional and local
agencies to develop a comprehensive watershed management strategy that identifies programs,
partnerships, actions, and incentives that the City and partners can take to protect the City’s water
resources and aquatic areas. Policy ES-7.3 requires that new development and redevelopment
projects meet federal, State, regional, and local stormwater requirements, including site design,
stormwater treatment, stormwater infiltration, peak flow reduction, and trash capture.
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The South San Francisco Municipal Code and Zoning Ordinance also contains rules and regulations to
minimize soil erosion and the loss of topsoil. Chapter 15.08 of the Municipal Code regulates grading
activities, including drainage and erosion control. Section 20.300.007 (Landscaping) (revised) of the
Zoning Ordinance includes a number of requirements for new construction or rehabilitated
landscapes, including the preparation of a soil management report and grading design plan to
reduce runoff. Section 14.04.132 (Site design measures for non-regulated projects) of the Municipal
Code states that all new development and redevelopment projects are encouraged to include
adequate site design measures that include minimizing land disturbance and impervious surfaces.
Section 14.04.180 (Reduction of pollutants in stormwater) of the Municipal Code requires BMPs for
all construction sites in the City for erosion control, run-on and runoff control, sediment control,
active treatment systems (as appropriate), and good site management through all phases of
construction (including, but not limited to, site grading, building, and finishing of lots) until the site is
stabilized by landscaping or the installation of permanent erosion control measures. Implementation
of General Plan Update policies and actions would further reduce potential soil erosion and loss of
topsoil from construction-related soil disturbance (Draft Program EIR, Page 3.6-23-24). The proposed
project ’s impacts related to geology, soils, and seismicity would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Potential Effect
Impact GEO-3 The proposed project would not be located on a geologic unit or soil that is
unstable, or that would become unstable as a result of the proposed project, and
potentially result in a settlement, an on- or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse. (Draft Program EIR, Page 3.6-24-26)
Findings: Less than significant impact (Draft Program EIR, 3.6-26). No mitigation required.
Facts in Support of Findings: Certain geologic units present in the Planning Area could have the
potential for landslides, slope instability, rock falls, liquefaction, settlement, and liquefaction-induced
lateral spreading. Other geologic hazards, such as subsidence or collapse, are also present in the
Planning Area. Development allowed under the proposed project could occur within areas
containing unstable geologic units or be located on soils that are unstable or could become unstable
from such development. Any development under the proposed project would be required to comply
with Chapter 15.08 of the South San Francisco Municipal and Sections 20.170.004 and 20.310.002 of
the South San Francisco Zoning Ordinance, discussed above.
The General Plan Update includes policies and actions specifically designed to protect individuals
from injuries and minimize property damage resulting from development on unstable geologic units
or unstable soils by limiting development in certain areas and requiring increased review and
mitigation where appropriate. These include Policy CR-4.3, Action CR-1.3.3, and Action CR-4.1.4.
Policy CR-4.1, which requires the City to protect existing and new buildings, infrastructure, and other
assets from seismic hazards, would also be protective of development within unstable geologic units
or unstable soils. Policy CR-4.4 requires the City to protect existing and new buildings, infrastructure,
and other assets from other geologic hazards, including landslides, slope instability, liquefaction,
settlement, subsidence, unstable geologic units, unstable soils, and expansive soils.
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The proposed project does not include specific plans for individual development; thus, analyzing the
future effects of individual development is not possible. Future proposed projects located within
areas containing unstable geologic units or unstable soils would be required to conduct an
environmental analysis at the time a specific project is defined, including preparation of site-specific
soils and geologic reports for review and approval by the City Engineer, and incorporation of the
recommended actions during construction (Draft Program EIR, Page 3.6-24-26). The proposed
project ’s impacts related to geology, soils, and seismicity would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Potential Effect
Impact GEO-4 The proposed project would not be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect
risks to life or property (Draft Program EIR, Page 3.6-26-27).
Findings: Less than significant impact (Draft Program EIR, Page 3.6-27). No mitigation required.
Facts in Support of Findings: New development constructed on expansive soils could be subject to
damage or become unstable when underlying soil shrinks or swells. Expansive soils in the City are
generally located within the Colma Formation which runs horizontally through the central portion of
the City.4 Along the eastern perimeter of the City near San Francisco Bay is primarily artificial fill
which is susceptible to damage from expansive soils.5 Development under the proposed project
would be required to comply with Chapter 15.08 of the South San Francisco Municipal Code and
Sections 20.310.002 and 20.170.004 of the South San Francisco Zoning Ordinance, as previously
discussed. The General Plan Update also includes policies and actions specifically designed to protect
residents from injuries and minimize property damage resulting from geologic hazards, such as
Action CR-1.3.3, Policy CR-4.1, Policy CR-1.4, Policy CR-1.5, Policy CR-4.4, and Action CR-4.4.1 (Draft
Program EIR, Page 3.6-26—27). The proposed project's impacts related to geology, soils, and
seismicity would be less than significant with the implementation of applicable regulations, including
new and revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact GEO-5 The proposed project would not have soils incapable of adequately supporting the
use of septic tanks or alternative wastewater disposal systems where sewers are
not available for the disposal of wastewater (Draft Program EIR, Page 3.6-27-28).
Findings: Less than significant impact (Draft Program EIR, Page 3.6-28). No mitigation required.
Facts in Support of Findings: The proposed project encourages growth management and
development within the Planning Area. Because South San Francisco is a fully built city, new
development would primarily occur on parcels that already contain some existing homes or
businesses, as previously discussed. Development facilitated by the proposed project would be
4 United States Geological Survey (USGS). 1998. Preliminary Geologic Map of the San Francisco South 7.5’ Quadrangle and Part of the
Hunters Point 7.5’ Quadrangle, San Francisco Bay Area, California.
5 Ibid.
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served by the existing sewer system, and most new development would connect to existing sewer
lines. Should any new development require the installation of septic tanks or alternative wastewater
disposal systems, the General Plan Update includes policies and actions to ensure that any new
development can be feasibly constructed according to soil conditions, including Policy CR-4.3, Policy
CR-4.1, Policy CR-4.4, and Action CR-4.4.1.
Chapter 14.14 (Sewer Lateral Construction, Maintenance, and Inspection) of the South San Francisco
Municipal Code includes provisions to protect the public health and safety by establishing and
providing a mechanism for enforcing performance standards for private sewer laterals that connect
or are connected to a public sewer main, and to maintain all parts of the sewer system and reduce
and prevent sanitary sewer overflows. Section 14.14.050 (Permits—General) requires that a permit
be obtained for the installation of individual waste disposal systems including septic systems and
that all work comply with the provisions of Chapter 14.14, including design standards and
construction standards. Chapter 15.12 (California Plumbing Code) of the South San Francisco
Municipal Code implements the California Plumbing Code on a local level, and includes construction
requirements for the installation of septic tanks or alternative wastewater disposal systems.
Implementation of policies and actions in the General Plan Update, as well as applicable local codes,
would ensure that new septic tanks or alternative wastewater disposal systems are constructed on
soils that can support such systems (Draft Program EIR, Page 3.6-27—28). The proposed project's
impacts related to geology, soils, and seismicity would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Cumulative Impact
The proposed project ’s impacts related to geology, soils, seismicity, or paleontological resources
would be less than significant (Draft Program EIR, Page 3.6-29-31).
Findings: Less than significant impact (Draft Program EIR, Page 3.6-31). No mitigation required.
Facts in Support of Findings: The geographic context for analysis of cumulative impacts related to
geology, soils, and seismicity includes the South San Francisco Planning Area. The geographic context
for paleontological resources includes San Mateo County.
Potentially adverse environmental effects associated with seismic hazards, as well as those
associated with expansive soils, unstable geologic units, unstable soils, landslides, and erosion,
usually are site-specific and generally do not result in cumulative effects. Cumulative projects would
be exposed to similar ground shaking during seismic events, but development of individual projects
would not increase the potential for impacts to occur. Individual development proposals would be
reviewed separately by the appropriate public agency depending on location and undergo
environmental review if appropriate. In the event that future cumulative development would result
in impacts related to geologic or seismic impacts, those potential project or site-specific impacts
would be addressed in accordance with the requirements of CEQA. New buildings would be
constructed utilizing current design and construction methodologies for earthquake-resistant design
as required by relevant regulations, including the San Mateo County Code of Ordinances.
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Compliance with the CBC, NPDES permits, laws and regulations mentioned above would ensure that
cumulative development would have less than significant impacts associated with geology, soils, or
seismicity.
As previously discussed, development facilitated by the proposed project would be required to
comply with provisions of the CBC, excavation and grading requirements of the South San Francisco
Municipal Code and Zoning Ordinance, including enhanced policies and actions developed as part of
the General Plan Update, and mandatory NPDES permit requirements to ensure that potential
impacts related to site-specific geotechnical conditions remain at less than significant levels.
As cumulative development occurs, all future projects must comply with the federal, State, and
pertinent local regulations regarding structural stability, resulting in less than significant cumulative
impacts related to subsidence or collapse. The proposed project would not contribute to a
cumulative impact on liquefaction, lateral spreading, or landslides. As discussed above, impacts
related to subsidence or collapse are less than significant with implementation of the General Plan
Update’s policies and actions, and compliance with the South San Francisco Municipal Code and
Zoning Ordinance.
Cumulative development within the Planning Area could propose to install septic tanks or alternative
wastewater disposal systems, particularly within areas under the jurisdiction of San Mateo County.
Cumulative development would not contribute to potential impacts on the soils related to septic
tanks or alternative wastewater disposal systems since new development would be required to
demonstrate that soils are capable of supporting septic tanks or alternative wastewater disposal
systems. As discussed above, impacts related to soils supporting septic tanks or alternative
wastewater disposal systems are less than significant with implementation of the General Plan
Update’s policies and actions, as well as compliance with the rules and regulations of the South San
Francisco Municipal Code and Zoning Ordinance. Moreover, the proposed project’s incremental
contribution to these less than significant cumulative impacts would not be significant. The City will
review development applications for subsequent development under the proposed project for
compliance with the policies and actions of the General Plan Update and would be required to
demonstrate that soils are capable of supporting septic tanks or alternative wastewater disposal
systems.
Future development in San Mateo County has potential to cumulatively impact paleontological
resources. However, all cumulative projects would be required to comply with federal and State
policies related to protection of paleontological resources which reduces potential cumulative
impacts to paleontological resources to less than significant. Moreover, the proposed project’s
incremental contribution to less than significant cumulative impacts would not be significant. The
City would review development applications for subsequent development under the proposed
project for compliance with MM GEO-6, which requires paleontological monitoring for all proposed
excavations in the Colma Formation and Merced Formation, including those buried in the shallow
subsurface below Quaternary deposits. Future development under the proposed project would also
be required to conform to federal and State policies that protect paleontological resources, including
Section 5097 of the California Public Resources Code (Draft Program EIR, Page 3.6-29-31).
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The proposed project's cumulative impacts related to geology, soils, and seismicity would be less
than significant with the implementation of applicable regulations, including new and revised
General Plan Update policies and implementing actions. No mitigation is necessary.
1.5.7 - Greenhouse Gas Emissions
Potential Effect
Impact GHG-1 The proposed project would not generate greenhouse gas emissions, either
directly or indirectly, that may have a significant impact on the environment (Draft
Program EIR, Page 3.7-53-66).
Findings: Less than significant impact (Draft Program EIR, 3.7-66). No mitigation required.
Facts in Support of Findings:
Construction
Construction activities associated with future development under the proposed project would
generate temporary short-term GHG emissions from heavy-duty construction equipment, worker
commute trips, and material delivery trips (i.e., vendor trips), and hauling trips. On-site activities
would consist of the operation of off-road construction equipment, as well as on-site truck travel
(e.g., haul trucks, dump trucks, and concrete trucks). Off-site sources would include emissions from
construction vehicles used for hauling materials and worker vehicle trips. The City would consider
construction emissions to be potentially significant if a project would not incorporate Best
Management Practices (BMPs) to reduce GHG emissions during construction. New development
facilitated by the proposed project would include BMPs for reducing construction emissions of PM10
and PM2.5 through Mitigation Measure (MM) AIR-1a, which would help reduce construction-related
GHG emissions.
The General Plan Update includes policies and actions specifically designed to address GHG
emissions during project construction activities. Policy CHEJ-3.1 requires the City to support regional
efforts to improve air quality and protect human health. Action CHEJ-3.1.1 requires the City to work
with the BAAQMD to establish and identify funding for air quality monitoring and reduction
strategies. This action may include purchasing particulate matter (PM2.5) monitors to track local air
quality data in Lindenville, East of 101, and Downtown. Action CHEJ-3.2.2 requires the City to
establish a local ordinance that exceeds the State vehicle idling restrictions where appropriate,
including restrictions for bus layovers, delivery vehicles, trucks at warehouses and distribution
facilities and taxis, particularly when these activities take place near sensitive land uses (schools,
healthcare facilities, affordable housing, and elder and childcare centers). Action CHEJ-3.2.2 also
requires the City to manage truck idling in new residential neighborhoods in Lindenville and East of
101. Lastly, Policy CP-5.4 requires 75 percent waste diversion for municipal construction and
demolition projects.
The South San Francisco Municipal Code contains rules and regulations to reduce GHG emissions
during construction. Chapter 15.60 promotes the redirection of recyclable materials generated
during construction away from landfills. All project applicants are required to complete and submit a
recycling management plan to estimate the volume of debris to be generated during construction
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and the estimated amount of debris that would be sent to the landfill. Section 15.62 (Deconstruction
and Salvage and Recovery) requires the City to encourage contractors to make every structure
planned for demolition available for deconstruction, salvage, and recovery prior to demolition; and
to recover the maximum feasible amount of salvageable designated recyclable and reusable
materials prior to demolition, by at least at the rate set forth in Section 4.408 of Chapter 4 of the
CALGreen, as may be amended from time to time.
Future development under the proposed project would be required to comply with the
requirements of the South San Francisco Municipal Code, the General Plan Update policies and
actions, and MM AIR-1a, to reduce GHG emissions during construction. In addition, future
development would be required to comply with California Code of Regulations Title 13, Sections
2449(d)(3) and 2485, that limit idling from both on-road and off-road diesel-powered equipment and
are enforced by the ARB. Construction of future development under the proposed project would not
result in potentially significant impacts related to GHG emissions after inclusion of identified
mitigation and compliance with local policies and regulations.
Operation
Long-term operational sources of GHG emissions associated with the proposed project would
include mobile sources (e.g., vehicle exhaust), energy consumption (e.g., electricity and natural gas),
solid waste, wastewater treatment, and water consumption (e.g., electricity used to deliver and treat
water consumed by customers in the City). The operational GHG emissions from buildout of the
proposed project have been calculated through use of the CalEEMod model for area sources, energy
usage, solid waste, and water and wastewater and EMFAC 2021 for mobile sources (see Appendix B
of Draft Program EIR). The operational GHG emissions are based on proposed project buildout
conditions within the Planning Area in 2040, including up to 38,959 dwelling units and up to
50,052,914 square feet of nonresidential space. The GHG emissions forecast assumes that several
State and local GHG reduction measures listed on page 3.7-54 of the Draft Program EIR, would be
implemented by 2040.
General Plan Update policies and updated 2022 CAP actions, listed on Pages 3.7-55-63 of the Draft
Program EIR, would help reduce GHG emissions generation from existing and future development. It
should be noted that these policies and actions are not specifically incorporated into the emissions
estimates provided in this analysis due to the uncertainty of their widespread utility. The City
adopted Ordinance 21-416 to amend Title 15, Buildings and Construction, to require all new single-
family and low-rise multifamily residential development to be designed all-electric and new
additions or major alterations constituting 50 percent of the building be designed all-electric,
consistent with the updated 2022 CAP Action BNC-2.1. This ordinance will help reduce GHG emission
generation in the City from new development, but it does not currently preclude mid-rise or high-
rise residential development from utilizing natural gas infrastructure, nor does it currently preclude
the use of natural gas infrastructure in nonresidential development or nonresidential occupancies in
mixed use development. Moreover, Ordinance 21-416 contains exceptions that future eligible
residential development may seek depending on the conditions, for instance, if there is no approved
calculation method contained in the California Energy Code or if there is no commercially available
technology for that specific building.
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Table 3.7-3 of the Draft Program EIR shows the estimated GHG emissions generated from the entire
City for the year 2040. Table 3.7-3 is based on year 2022 emission rates from area sources, energy
usage, solid waste, water, and wastewater sources while the VMT data used to support this analysis
utilizes a baseline year of 2019. Compliance with future State regulations would reduce related GHG
emissions through the year 2040, such as SB 100 which requires 100 percent of in-state sales of
electricity to be generated from zero-carbon emissions sources by 2045, which would result in
reducing energy source emissions to near zero levels. In addition, the transportation sources only
incorporate previously adopted State regulations and do not account for recent State regulations
and goals, including the anticipated reductions from Executive Order N-79-20 that established a goal
of 100 percent of new passenger vehicles sold in California to be zero-emission by 2035. The
proposed GHG emission reduction policies and actions included in the proposed project would
further reduce the GHG emissions.
The City is estimated to generate approximately 872,000 MT CO2e per year in 2040 with a service
population (residents and employees) of an estimated 245,700 people. As such, citywide GHG
emissions per service population are projected to be 3.55 MT CO2e in 2040 with implementation of
future development facilitated by the proposed project. The GHG emissions per service population
for the proposed project buildout conditions would not exceed the 4.0 MT CO2e per service
population threshold. The proposed project would result in annual per service population GHG
emissions of 3.55 MT CO2e, which is below the established significance threshold of 4.0 MT CO2e per
service population.
The proposed project's impacts related to GHG emissions would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update and CAP
policies and implementing actions. No mitigation is necessary
Potential Effect
Impact GHG-2 The proposed project would not conflict with any applicable plan, policy or
regulation of an agency adopted for the purpose of reducing the emissions of
greenhouse gases (Draft Program EIR, Page 3.7-66-83).
Findings: Less than significant impact (Draft Program EIR, Page 3.7-83). No mitigation required.
Facts in Support of Findings:
Development facilitated by the proposed project would be required to comply with requirements of
the General Plan Update, updated 2022 CAP, and South San Francisco Municipal Code and Zoning
Ordinance to reduce GHG emissions. In addition, the City will be required to comply with existing
and new federal, State, and local statutes and regulations related to GHG emissions. As
demonstrated below, development facilitated by the proposed project would not conflict with the
applicable plans for reducing GHG emissions.
ARB Climate Change Scoping Plan
In the 2017 Climate Change Scoping Plan, the ARB recommends local plan-level targets of no more
than 6.0 MT CO2e per capita by 2030 and no more than 2.0 MT CO2e per capita by 2050. Based on a
linear interpolation of these two GHG reduction goals, the proposed target for the proposed project
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would be no more than 4.0 MT CO2e per service population by 2040. As identified in Table 3.7-3 of
the Draft Program EIR, the City is projected to emit 3.55 MT CO2e per service population in 2040.
Future projects would be required to comply with State standards for new construction as well as
policies and actions of the General Plan Update and updated 2022 CAP that aim to reduce GHG
emissions, which include GHG reduction actions similar to those recommended in the 2017 Climate
Change Scoping Plan. Policy CP-4.2 directs the City to prepare a Building Electrification Plan to
retrofit existing homes and businesses to all electric. Policy CP-5.1 requires new buildings to meet a
minimum LEEDTM Silver rating or equivalent and requires feasibility studies for net zero energy use,
on-site renewable energy generation, and on-site batteries. In addition, the 2019 California Code of
Regulations Title 24 Part 6 standards also now require that all homes built in California shall have
zero-net-energy use, which is achieved through energy efficiency measures as well as required
rooftop solar photovoltaic systems. The 2019 California Code of Regulations Title 24 Part 6 standards
also apply to nonresidential developments and require a variety of energy efficiency measures to be
implemented during construction of the structures to reduce energy as usage as well as air
emissions.
Plan Bay Area 2050: Strategy for a Sustainable Region
To achieve the ABAG and MTC sustainable vision for the San Francisco Bay Area, the Plan Bay Area
2050 land use concept plan concentrates most new population and employment growth in and
around Priority Development Areas (PDAs). The City of South San Francisco is located within the
North San Mateo County Super District that is forecasted to have an increase of 69,000 households
between the baseline year of 2015 and the proposed plan year of 2050. Buildout of the proposed
2040 General Plan could yield up to 17,153 new residential units (based on 2019 baseline data from
Fehr & Peers). As such, the proposed project would promote implementation of the Plan Bay Area
2050. In addition, the policies and actions of the General Plan Update encourage the use of
alternative modes of travel and reduce dependence on auto use, consistent with Plan Bay Area’s
vision. As shown in Table 3.7-4 of the Draft Program EIR, the proposed project would be consistent
with the GHG-related policy strategies contained in Plan Bay Area 2050.
The General Plan Update and updated 2022 CAP include GHG reduction actions which are consistent
with the Plan Bay Area 2050 GHG-related policy strategies. Future projects would be required to
comply with State standards for new construction as well as policies and actions of the General Plan
Update and updated 2022 CAP that aim to reduce GHG emissions.
Bay Area Air Quality Management District 2017 Clean Air Plan
The BAAQMD 2017 Clean Air Plan contains control measures that focus primarily on reducing GHG
emissions across the following sectors: stationary sources, transportation, energy, buildings,
agriculture, natural and working lands, waste management, water, and super-GHG pollutants. Table
3.7-5 of the Draft Program EIR identifies the control measures from the 2017 Clean Air Plan that are
relevant to the City and the proposed project’s consistency with those measures. Future projects
would be required to comply with requirements of the General Plan Update, updated 2022 CAP, and
the City’s Municipal Code and Zoning Ordinance that aim to reduce GHG emissions in the Planning
Area (Draft Program EIR, Page 3.7-66—83). The proposed project's impacts related to GHG emissions
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would be less than significant with the implementation of applicable regulations, including new and
revised General Plan Update and CAP policies and implementing actions. No mitigation is necessary.
Cumulative Impact
The proposed project’s cumulative impacts related to GHG emissions would be less than significant
(Draft Program EIR, Page 3.7-83—84).
Findings: Less than significant impact (Draft Program EIR, 3.7-84). No mitigation required.
Facts in Support of Findings: The analysis under Impacts GHG-1 and GHG-2 also addresses
cumulative impacts, as GHG emissions related to implementation of the proposed project are not
confined to a particular air basin but are dispersed worldwide.
As discussed under Impacts GHG-1 and GHG-2, the proposed project does not propose the
construction of new housing or other development; rather, it provides a framework for future
growth and development in South San Francisco. Development in the City is required to be analyzed
for consistency with the General Plan Update, updated 2022 CAP, South San Francisco Municipal
Code and Zoning Ordinance, and other applicable local and State requirements; comply with the
requirements of CEQA; and obtain all necessary clearances and permits. Furthermore, existing
federal, State, and local regulations and policies described throughout this section that serve to
reduce communitywide GHG emissions would apply to future projects. This would reduce the
proposed project’s cumulative contribution to this impact.
As discussed under Impact GHG-1 and shown on Table 3.7-3 of the Draft Program EIR, the GHG
emissions per service population for the General Plan buildout conditions would be within the 4.0
MT CO2e per service population threshold necessary for the City to achieve its fair share of
Statewide GHG reductions in accordance with the State’s long-term GHG reduction targets.
Cumulative projects will also be required to comply with existing federal, State, and local regulations
and policies to reduce communitywide GHG emissions. Lastly, cumulative projects will be required to
comply with the requirements of CEQA and obtain all necessary clearances and permits (Draft
Program EIR, Page 3.7-83-84). Accordingly, the proposed project's cumulative impacts related to
GHG emissions would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update and CAP policies and implementing actions. No
mitigation is necessary.
1.5.8 - Hazards and Hazardous Materials
Potential Effect
Impact HAZ-1 The proposed project would not create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous
materials (Draft Program EIR, Page 3.8-24-26).
Findings: Less than significant impact (Draft Program EIR, 3.8-26). No mitigation required.
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Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development, as well as other private and public improvements
throughout the Planning Area, which could result in an increase in the routine transportation, use,
and disposal of hazardous materials. Exhibit 2-4 of the Draft Program EIR identifies the following
land use designations that have the potential to generate hazardous materials: Business Technology
Park, Business Technology Park High, Mixed Industrial, Mixed Industrial High, and Industrial
Transition Zone. Construction and demolition activities may generate small amounts of hazardous
waste or the release of hazardous building materials. All new development (construction and
operations) would be required to comply with mandatory regulations for hazardous materials
adopted by the EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA, and BAAQMD.
Hazardous Material Transportation
Multiple agencies enforce federal and State regulations regarding transportation of hazardous
materials on local roadways and railways and respond to hazardous material spills and releases that
occur on roadways, railway lines, and at railroad crossings. Further, businesses handling or storing
hazardous materials over threshold quantities are required to submit an HMBP to the local CUPA.
Should an accident occur during transport of hazardous materials, the CUPA, South San Francisco
Fire Department (SSFFD), and South San Francisco Police Department (SSFPD) would respond. The
CHP conducts regular inspections of licensed transporters to assure regulatory compliance and
responds to hazardous materials emergencies on roadways.
The General Plan Update contains policies and actions that would further minimize risk to the public
or environment resulting from the transportation of hazardous materials and waste. Policy CHEJ-4.4
requires the City to maintain an up-to-date truck routes map that minimizes exposures to sensitive
land uses from vehicles carrying hazardous materials and toxic waste. Action CR-1.3.1 requires the
City to participate in the San Mateo County Hazard Mitigation Plan maintenance protocols and
Countywide initiatives, adopt the Hazard Mitigation Plan by reference upon update, and update
emergency operations plans and protocols to account for regularly updated hazard information.
Policy CR-1.6 requires the City to continually strengthen emergency management capacity and
coordination with the San Mateo County Emergency Operations Center. Policy CR-7.2 requires the
City to cooperate with federal, State, and County agencies to effectively regulate the management of
hazardous materials and hazardous waste. Lastly, Policy CR-7.3 requires the City to assess the use of
hazardous materials as part of a development’s environmental review and/or include the
development of a hazardous management and disposal plan as a condition of project approval,
subject to review by the San Mateo County Health Department.
Hazardous Material Use
The SSFFD and South San Francisco Building Division coordinate review of building permits to ensure
hazardous materials requirements are met prior to construction, including required separation
between hazardous materials and sensitive land uses and proper hazardous materials storage
facilities. Any businesses that generate or use hazardous materials within the Planning Area would
also be subject to existing hazardous materials regulations such as those implemented by the local
CUPA. The CUPA and SSFFD also conduct inspections for fire safety and hazardous materials
management of businesses and residential dwellings. Businesses storing or handling hazardous
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materials over threshold quantities are required to submit HMBPs pursuant to federal, State, and
local regulations. These HMBPs must include measures for safe storage, use, and handling of
hazardous materials, along with a contingency plan that describes the facility’s response procedures
in the event of a hazardous materials release.
The General Plan Update contains policies and actions that would further minimize risk to the public
or environment resulting from the use of hazardous materials, including Policy CR-7.3 discussed
above. Policy CHEJ-4.5 prohibits new nonresidential uses that are known to release or emit toxic
waste at levels that are harmful to human health while continuing to allow life science, research and
development, medical, and other necessary services such as dry cleaners. Policy LU-6.6 encourages
the development of non-polluting industries that are not major sources of air, water, or noise
pollution. Policy CR-7.1 requires the City to integrate updated remediation strategies related to
hazardous materials in coordination with regulating agencies and continue annual emergency
training related to hazardous materials. Lastly, Policy CR-7.4 requires the City to develop an
awareness program to expand public engagement in the handling and disposal of hazardous waste in
the community, especially at home.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, includes rules and regulations to minimize risk to the public or environment
resulting from the use of hazardous materials. Section 20.300.009 (Performance Standards) (revised)
states that the use, handling, storage, and transportation of hazardous and extremely hazardous
materials shall comply with the provisions of the California Hazardous Materials Regulations and the
California Fire and Building Code as well as the laws and regulations of the California Department of
Toxic Substances Control and the County Environmental Health Agency. Further, activities, processes,
and uses shall not generate or emit any fissionable or radioactive materials into the atmosphere, a
sewage system or onto the ground. Lastly, all activities, processes, and uses involving the use of, or
storage of, flammable and explosive materials shall be provided with adequate safety devices against
the hazard of fire and explosion.
Hazardous Material Disposal
The disposal of hazardous materials is regulated and monitored by the City of South San Francisco
(Chapter 8.20 of the Municipal Code), local CUPA, SSFFD, Cal/OSHA, and the DTSC consistent with
the requirements of federal, State, and local regulations and policies.
The General Plan Update contains policies and actions that would further minimize risk to the public
or environment resulting from the disposal of hazardous materials. These include Policy CR-7.2,
Policy CR-7.3, and Policy CR-7.4, as discussed above. Action CR-7.4.1 requires the City to offer
educational programming on the harmful effects and proper disposal of hazardous materials and
pesticides and recommend alternatives that can be used at home and in businesses.
Estimating project-specific impacts is not possible as the proposed project does not describe specific
development projects. Future projects would be subject to conducting an environmental analysis at
the time a specific project is defined. The City would determine which General Plan Update policies
and actions and Zoning Ordinance chapters apply, depending on the specific characteristics of the
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project type and/or project site during the development review process of individual projects (Draft
Program EIR, Page 3.8-24-26).
The proposed project's impacts related to hazards and hazardous materials would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact HAZ-2 The proposed project would not create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions
involving the likely release of hazardous materials into the environment (Draft
Program EIR, Page 3.8-26—28).
Findings: Less than significant impact (Draft Program EIR, Page 3.8-28). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. Because South San
Francisco is a fully built city, new development would primarily occur on parcels that already contain
existing land uses. Additionally, the proposed project may result in other private and public
improvements throughout the City with the potential for environmental effects related to hazardous
materials. Construction and demolition activities have the potential to release potentially hazardous
materials into the environment. As noted above in Impact HAZ-1, compliance with mandatory
regulations would reduce all potential construction-related impacts to a less than significant level,
and General Plan Update policies and actions and the Zoning Ordinance would further reduce
potential impacts and ensure that they are less than significant.
The General Plan Update contains several policies and actions that would minimize risk to the public
or environment resulting from reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment, including previously discussed Policy CR-7.3.
Policy CHEJ-4.1 requires the City to support Brownfield remediation through cleanup and reuse of
contaminated sites in Lindenville and East of 101 to protect human health. Action CHEJ-4.1.1
requires the City to maintain a map and database of contaminated, hazardous waste and substance
sites (e.g., Cortese List). Action CHEJ-4.1.2 requires the City to implement any future City-prepared
sea level rise adaptation plan for the Oyster Point Marina and landfill to prevent the release of toxins
into the Bay. Lastly, Policy CHEJ-4.2 requires that contaminated sites are adequately remediated
before allowing new development.
To prevent and minimize hazardous conditions to below a level of significance, existing local, State,
and federal law will be enforced at all construction sites. Compliance with existing regulations would
ensure that the public and environment are not exposed to any risks related to hazardous materials
during demolition and construction. Future projects would comply with Cal/OSHA regulations
concerning the use of hazardous materials, including requirements for safety training, exposure
warnings, availability of safety equipment, and preparation of emergency action/prevention plans.
All contaminated waste must be collected and disposed of at an appropriately licensed disposal or
treatment facility.
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Future development, including redevelopment, must comply with the California Code of Regulations.
Title 8 of the California Code of Regulations establishes Cal/OSHA requirements related to public and
worker protection. Topics addressed include materials exposure limits, equipment requirements,
protective clothing, hazardous materials, and accident prevention. Construction safety and exposure
standards for lead and asbestos are set forth in Title 8. Title 17 of the California Code of Regulations
establishes regulations relating to use and disturbance of materials containing naturally occurring
asbestos. Soil excavated during construction is regulated under Title 22 of the California Code of
Regulations.
As previously discussed, development that disturbs one acre or more of soil must obtain permit
coverage under the Construction General Permit by filing a NOI and SWPPP with the RWQCB prior to
commencement of construction. The Best Management Practices in the SWPPP include measures to
prevent spills and require on-site materials for cleanup.
At the time a specific future project is defined, it would be subject to conducting an environmental
analysis. The City would review individual project applications to determine which General Plan
Update policies and actions and Zoning Ordinance chapters apply depending on the specific
characteristics of the project type and/or project site during the development review process. (Draft
Program EIR, Page 3.8-26-28).
The proposed project's impacts related to hazards and hazardous materials would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact HAZ-3 The proposed project would not emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one quarter mile of an
existing or proposed school. (Draft Program EIR, Page 3.8-28-29).
Findings: Less than significant impact (Draft Program EIR, Page 3.8-29). No mitigation required.
Facts in Support of Findings: The City is served by public and private schools, including 15 schools
within the South San Francisco Unified School District (SSFUSD), one private elementary school, 10
preschools, and 10 daycare centers. Given the distribution of schools in the City, it is possible that
future development and redevelopment associated with the proposed project, which may involve
hazardous emissions or handling of hazardous materials and wastes, may occur within 0.25 mile of
an existing or future school.
Development facilitated by the proposed project would be required to comply with existing federal,
State, and local regulations related to hazardous materials, including those codified in General Plan
Update Policies CR-7.3, CR-7.4, CHEJ-4.5, and LU-6.6 and Section 20.300.009 (Performance
Standards) (revised) of the Zoning Ordinance.
In particular, the SSFFD and South San Francisco Building Division coordinate review of building
permits to ensure hazardous materials requirements are met prior to construction, including
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required separation between hazardous materials and sensitive land uses and proper hazardous
materials storage facilities. Future development (including redevelopment of existing developed
sites) under the proposed project would be required by the local CUPA to store, manage, and
dispose of the materials in accordance with the Unified Program. Therefore, impacts related to
hazards and hazardous materials would be less than significant with the implementation of
applicable regulations, including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary.
Potential Effect
Impact HAZ-4 The proposed project would not be located on a site which is included on a list of
hazardous material sites compiled pursuant to Government Code Section 65962.5
and, as a result, would not create a significant hazard to the public or the
environment (Draft Program EIR, Page 3.8-29 – 30).
Findings: Less than significant impact (Draft Program EIR, 3.8-30). No mitigation required.
Facts in Support of Findings: According to an EnviroStor search performed on February 2, 2022, a
total of 29 sites are located within the Planning Area, including four active sites. According to a
GeoTracker search performed on March 3, 2022, a total of 46 open sites are located within the
Planning Area. Of the 46 open sites, seven are LUST Cleanup Sites: Arco #6073 (2300 Westborough
Boulevard), California Golf Club of San Francisco (844 West Orange Avenue), Grand Avenue Gas
(1086 Grand Avenue), Monfredini Property (477 Forbes), Tony's Services (209 El Camino Real), Union
Carbide Corporation (7 South Linden Avenue), and Unocal #6980 (192 El Camino Real). Of the 46
open sites, two are land disposal sites: O'Brien-Haskins Former San Bruno Channel (500 East Jamie
Court) and Oyster Point Landfill (Oyster Point Boulevard). As such, development facilitated by the
proposed project could occur on a contaminated site. Future discretionary projects under the
proposed project will be evaluated for project-specific impacts related to hazardous materials at the
time they are proposed.
As discussed in Impact HAZ-1, HAZ-2, HAZ-3, and the Regulatory Framework of the Draft Program
EIR, any development on a contaminated site would be required to comply with mandatory
regulations, ensuring it does not create a significant hazard to the public or the environment. This
includes Cal/EPA-enforced federal hazardous materials laws and regulations. The DTSC, a
department of the Cal/EPA, requires programs such as HMBPs that include dealing with aftermath
clean-ups of improper hazardous waste management, evaluation of samples taken from sites,
enforcement of regulations regarding use, storage, and disposal of hazardous materials, and
encouragement of pollution prevention.
The General Plan Update contains several policies and actions that would minimize risk to the public
or environment resulting from the inadvertent discovery of hazardous materials on a project site.
These include previously discussed Policy CR-7.3, Policy CHEJ-4.1, Policy CHEJ-4.2, and Action CHEJ-
4.1.1. Action LU-6.6.1 requires the City to seek funding to finance cleanup and redevelopment of
contaminated sites.
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If hazardous materials are encountered during construction activities from development facilitated
by the proposed project, the handling, transportation, and disposal of hazardous materials would be
required to comply with the requirements and regulations set forth by the City of South San
Francisco, EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA, and BAAQMD. The City would review
individual project applications to determine which General Plan Update policies and actions and
Zoning Ordinance chapters apply (Draft Program EIR, Page 3.8-29—30). The proposed project's
impacts related to hazards and hazardous materials would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Potential Effect
Impact HAZ-5 The proposed project would not result in a safety hazard or excessive noise for
people residing or working in the project area (Draft Program EIR, Page 3.8-30—
32).
Findings: Less than significant impact (Draft Program EIR, Page 3.8-32). No mitigation required.
Facts in Support of Findings: Development envisioned by the proposed project is generally focused
in already developed areas of the City; however, development could result in an incremental
increase in the exposure of people residing or working in the Planning Area to a safety hazard or
excessive noise because of proximity to SFO. The Planning Area is located within the Federal Aviation
Regulation Part 77 SOI and within the boundaries of Airport Influence Areas A and B of the SFO
ALUCP. Future projects would be required to comply with the policies and actions within the General
Plan Update and the South San Francisco Municipal Code and Zoning Ordinance regarding interior
noise standards and maximum building heights permitted under Federal Aviation regulations.
Further, continued consultation with the C/CAG and Federal Aviation Administration for projects
located in the vicinity of SFO will minimize the exposure of people residing or working in the City to a
safety hazard or excessive noise because of proximity to SFO.
The General Plan Update contains policies and actions that minimize the exposure of people residing
or working in the Planning Area to a safety hazard or excessive noise because of proximity to SFO.
Policy SA-12.6 requires the City to encourage residential development in the South Spruce area that
is within the 65 decibel (db) CNEL contour, provided the interior of a structure meets the standard
indoor 45 db CNEL noise requirement. Action SA-12.6.1 requires the City to review the SFO ALUCP
and, as needed, to update the City of South San Francisco’s General Plan to be in conformance with
land use compatibility standards in the ALUCP. Action SA-12.6.1 further states that in the event that
updates to the ALUCP allow residential land uses on suitable sites on the El Camino Real corridor
where residential is not currently permitted, the City will update the General Plan to allow Urban
odd Residential uses. Lastly, Policy SA-21.3 requires the City to allow building heights in the East of
101 area to the maximum limits permitted under Federal Aviation regulations. Section 3.11, Noise,
identifies additional policies and actions, as well as Mitigation Measure MM NOI-3, Airport Noise
Impact Reduction Plan, to address potential exposure to people residing or working in the vicinity of
SFO to excessive noise levels.
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The City of South San Francisco will review future development applications for compliance with the
policies and actions of the General Plan Update to reduce the exposure of people residing or
working in the City to a safety hazard or excessive noise because of proximity to SFO. In addition,
Chapter 15.08, CBC, and Chapter 8.32, Noise Regulations, of the City’s Municipal Code would be
reviewed when development applications are received. Further, Section 20.320.002 (Establishment
of Lawful Nonconforming Uses, Structures and Lots) (revised) ensures that no permit shall be
granted that would allow the establishment or creation of an airport hazard or permit a
nonconforming structure or nonconforming use to be made or become higher or become a greater
hazard to air navigation. In accordance with the SFO ALUCP, the City would consult with the C/CAG
and Federal Aviation Administration when development applications for subsequent development
under the proposed project in the vicinity of SFO are received, including submitting applications to
the C/CAG for a determination of consistency with the SFO ALUCP (Draft Program EIR, Page 3.8-30-
32; Errata, p. 3-3). The proposed project's impacts related to hazards and hazardous materials would
be less than significant with the implementation of applicable regulations, including new and revised
General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact HAZ-6 The proposed project would not impair implementation of or physically interfere
with an adopted emergency response plan or emergency evacuation plan (Draft
Program EIR, Page 3.8-32-34).
Findings: Less than significant impact (Draft Program EIR, 3.8-34). No mitigation required.
Facts in Support of Findings: San Mateo County has developed an EOP that establishes policies and
procedures and assigns responsibilities to ensure the effective management of emergency
operations within the San Mateo County Operational Area. New development under the proposed
project would be considered in the context of the San Mateo County EOP. As development occurs
under the proposed project, the San Mateo County EOP can be modified to reflect new growth
within the Planning Area. Most of the development facilitated by the proposed project would be
served by existing emergency evacuation routes, which have sufficient capacity to accommodate
projected growth.
The General Plan Update contains policies and actions that aim to continually strengthen emergency
response and emergency evacuation. These include previously discussed Action CR-1.3.1 and Policy
CR-1.6. Action CR-1.6.5 requires the City to maintain and communicate evacuation route plans for
businesses and residents. Lastly, Policy CR-1.7 requires the City to expand the reach of the CERT
program to strengthen community cohesion and emergency preparedness through community
engagement efforts (Draft Program EIR, Page 3.8-32-34). The proposed project's impacts related to
hazards and hazardous materials would be less than significant with the implementation of
applicable regulations including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary.
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Cumulative Effect
The proposed project’s cumulative impacts related to hazards and hazardous materials would be less
than significant (Draft Program EIR, Page 3.8-34-36).
Findings: Less than significant impact (Draft Program EIR, 3.8-36). No mitigation required.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for hazards
and hazardous materials is the South San Francisco Planning Area as well as the surrounding cities of
Brisbane, Daly City, Pacifica, San Bruno, and Millbrae.
Hazards and Hazardous Materials: Cumulative projects would be subject to the requirements and
regulations set forth by the EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA, and BAAQMD
related to transport, use, and disposal of hazardous materials. Cumulative projects will also be
required to implement a SWPPP and comply with the California Code of Regulations during
construction, site grading, excavation operations, and building demolition.
The proposed project’s incremental contribution to these less than significant cumulative impacts
would not be significant with implementation of the policies and actions proposed in the General
Plan Update. The City of South San Francisco would review applications for development for
compliance with General Plan Update policies and actions including, but not limited to, Policies CR-
7.3, CHEJ-4.1, and CHEJ-4.2. Additionally, as previously stated, development under the proposed
project would be required to comply with all requirements and regulations set forth by the City of
South San Francisco, EPA, OSHA, USDOT, DTSC, Caltrans, CHP, local CUPA, and BAAQMD related to
transport, use, and disposal of hazardous materials. Accordingly, development under the proposed
project would not result in physical changes that would incrementally contribute to a significant
environmental effect.
Airport Safety Hazards: Cumulative projects would be subject to the requirements and regulations
set forth by the SFO ALUCP and Federal Aviation Administration related to the exposure of people
residing or working in the area to a safety hazard or excessive noise. Cumulative projects would also
be required to comply with General Plan policies and Municipal Code regulations related to interior
noise standards and maximum building heights.
Moreover, the proposed project’s incremental contribution to cumulative impacts would not be
significant. As previously discussed, development under the proposed project could result in an
increase in the exposure of people residing or working in the area to a safety hazard or excessive
noise. Potential impacts would be reduced to below a level of significance, as discussed above, with
compliance with the policies and actions within the General Plan Update including Policies SA-12.6
and SA-21.3 and Action SA-12.6.1, as well as Chapters 8.32 and 15.08 of the Municipal Code and
Section 20.320.002 (revised) of the Zoning Ordinance to further reduce potential impacts related to
the exposure of people residing or working in the area to a safety hazard or excessive noise. Further,
continued consultation with the C/CAG and Federal Aviation Administration for projects located in
the vicinity of SFO will minimize the exposure of people residing or working in the City to a safety
hazard or excessive noise because of proximity to SFO. To ensure a less than significant contribution
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to cumulative impacts, development consistent with the General Plan Update and Municipal Code
will be required to implement all applicable policies during the design review process.
Emergency Response and Evacuation Plans: Cumulative impacts related to emergency response and
evacuation plans would be less than significant. The SSFFD manages and maintains emergency plans
and training of City staff and community members and focuses on activities that will prepare the
community to take care of itself in the period immediately following a local disaster. For example,
the CERT program educates volunteers about disaster preparedness for the hazards that may impact
their area and trains them in basic disaster response skills, such as fire safety, light search and
rescue, team organization, and disaster medical operations. In addition, San Mateo County has an
EOP that is regularly updated. Adjacent jurisdictions also have emergency response plans and
emergency evacuation plans. Furthermore, larger regional and statewide resource areas are
regulated by State agencies to address larger-scale statewide issues.
Moreover, the proposed project’s incremental contribution to these less than significant cumulative
impacts would not be significant with the implementation of all applicable General Plan Update
policies and actions. The City will review development applications for subsequent development
under the proposed project for compliance with the policies and actions of the General Plan Update
related to emergency response plans and emergency evacuation plans. Additionally, new
development under the proposed project would be considered in the context of the San Mateo
County EOP and is not expected to impair implementation of or physically interfere with the San
Mateo County EOP (Draft Program EIR, Page 3.8-34 – 36).
The proposed project's cumulative impacts related to hazards and hazardous materials would be less
than significant with the implementation of applicable regulations, including new and revised
General Plan Update policies and implementing actions. No mitigation is necessary.
1.5.9 - Hydrology and Water Quality
Potential Effect
Impact HYD-1 The proposed project would not violate any water quality standards or waste
discharge requirements or otherwise substantially degrade surface or ground
water quality (Draft Program EIR, Page 3.9-27-31).
Findings: Less than significant impact (Draft Program EIR, Page 3.9-31). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. Because South San
Francisco is a fully built city, new development would primarily occur on parcels that already contain
some existing homes or businesses, with the majority of potential growth occurring within the East
of 101, Lindenville, Downtown, and El Camino planning sub-areas. Additionally, the proposed project
may result in other private and public improvements throughout the City with the potential for
environmental effects related to hydrology and water quality. Future development under the
proposed project would also be required to comply with the CWA and regulations enforced by the
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RWQCB, the requirements of the South San Francisco Municipal Code and Zoning Ordinance, the
General Plan Update, and Climate Action Plan policies and actions related to water quality.
Construction
Development under the proposed project could degrade surface and groundwater quality, if not
properly controlled. Future development (including redevelopment of existing developed sites) that
disturbs one acre or more of soil, or that is part of a common plan of development that disturbs one
acre or more of soil, must obtain permit coverage under the Construction General Permit by filing an
NOI and SWPPP with the RWQCB prior to commencement of construction. The SWPPP must
describe the site, the facility, erosion and sediment controls, runoff water quality monitoring, means
of waste disposal, implementation of approved local plans, control of construction sediment and
erosion control measures, maintenance responsibilities, and non-stormwater management controls.
Inspection of construction sites before and after storms is required to identify stormwater discharge
from the construction activity and to identify and implement erosion controls, where necessary.
The General Plan Update includes policies and actions to protect water quality in and around the
Planning Area during project construction. Policy ES-7.3 requires new development and
redevelopment projects to meet federal, State, regional, and local stormwater requirements,
including site design, stormwater treatment, stormwater infiltration, peak flow reduction, and trash
capture. Policy ES-2.1 requires the City to protect and expand existing marsh and wetland habitat to
improve water quality. Policies ES-2.2 and ES-3.3 require the City to maintain standards for new
construction adjacent to the San Francisco Bay and Colma Creek, such as maintaining (or increasing)
building setbacks to support habitat areas, which will also assist in protecting water quality during
construction. Lastly, Policy ES-3.4 requires the City to continue to implement stormwater
management practices across the Colma Creek Watershed, such as the Orange Memorial Park
Stormwater Capture Project to improve water quality and increase trash capture.
The South San Francisco Municipal Code contains rules and regulations to protect water quality
during construction. Section 14.04.180 (Reduction of pollutants in stormwater) identifies
construction-related BMPs to reduce pollutants entering the City storm sewer system. Section
14.04.132 (Site design measures for non-regulated projects) and Section 14.04.133 (Site design and
stormwater treatment requirements for regulated projects) requires all new development and
redevelopment projects to minimize disturbance of natural water bodies and drainage systems,
protect slopes and channels, and conserve natural areas, including existing trees, other vegetation,
and soils.
The Climate Action Plan includes actions that would protect water quality during construction.
Implementation of Action CS-3.1 would enhance Colma Creek as an ecological corridor, creating
transitional habitat zones to build resilience and ecosystem services, which would assist in protecting
water quality during construction. Implementation of Action CS-2.1 would expand the canopy cover
to reach the goals of the Urban Forest Master Plan, which would also assist in protecting water
quality during construction.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations to protect water quality during construction.
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Section 20.180.005 (Development Standards) (new) includes standards for the Flood Plain/SLR
Overlay District which will also assist in protecting water quality during construction. For example, by
installing fencing along riparian areas, pollution associated with construction such as fuel, grease, oil
and other fluids, concrete material, sediment, and litter, would be managed and controlled on-site
and not degrade off-site water quality. Section 20.310.002 (General Site and Building Design) (new)
includes grading and drainage requirements for all projects throughout the City, including submittal
of a grading plan for any grading on a site with a natural slope of 15 percent or greater, and slope
stabilization to control against erosion, which will also assist in protecting water quality during
construction.
Dewatering
Future development may encounter shallow groundwater, in which case dewatering of the
excavation or trenching site may be required. If improperly managed, these dewatering activities
could result in discharge of contaminated groundwater. In accordance with the General Waste
Discharge Requirements for Extracted Groundwater from Structural Dewatering Requiring Treatment
in the San Francisco Bay Region (Order No. R2-2018-0026; General NPDES Permit No. CAG912004),
any contaminated groundwater would be treated prior to discharge or disposed of at an appropriate
disposal facility or wastewater treatment plant. Also, discharges of dewatered groundwater to a
storm drain must be conducted in a manner that complies with the San Francisco Bay RWQCB Order
No. R2-2015-0049, MRP.
Section 14.08.290 (Harmful discharges) of the South San Francisco Municipal Code regulates
excessive, accidental, and harmful discharges and directs the superintendent to suspend the
wastewater treatment service or a wastewater discharge permit in order to stop an actual or
threatened discharge in certain circumstances to protect the health or welfare of people or the
environment. In addition, Chapter 14.08 of the South San Francisco Municipal Code provides for the
regulation of direct and indirect dischargers to the to the publicly owned treatment works through
the issuance of permits for certain nondomestic users and through enforcement of general
requirements for all users, thereby further ensuring that dewatering activities do not degrade water
quality in the Planning Area. Section 14.08.250 (Excessive discharge) directs the superintendent to
impose mass limitations on users which are using dilution to meet applicable pretreatment
standards or requirements, or in other cases where the imposition of mass limitations is appropriate.
Section 14.08.260 (Accidental discharges) requires the submittal of detailed plans showing facilities
and operating procedures to provide protection from accidental discharge of prohibited materials or
other regulated substances to the City for review. The detailed plans shall be approved by the City
before construction of the facility.
Operation
New development under the proposed project could add additional areas of impervious surfaces
within the Planning Area and therefore, the volume and type of pollutants that are typically
associated with urban runoff into the stormwater. These pollutants could result in water quality
impacts to on-site and off-site drainage flows to area waterways.
The General Plan Update includes policies and actions intended to protect water quality in and
around the Planning Area. These include Policies ES-7.3, ES-2.2, and ES-3.3 discussed previously
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under “Construction”. Policy ES-7.1 requires the City to collaborate with regional agencies and
neighboring jurisdictions to manage stormwater, reduce impervious surfaces, and improve water
quality in the Colma Creek Watershed. Lastly, Policy ES-7.2 requires the City to integrate green
infrastructure in City projects.
The South San Francisco Municipal Code also contains rules and regulations to protect water quality
at operation, including Section 14.04.180, Section 14.04.132, and Section 14.04.133 as described
above under “Construction.” Section 14.04.134 (LID requirements) requires that all regulated
projects implement LID requirements as specified in NPDES Permit No. CAS612008 to reduce runoff
and mimic a site’s predevelopment hydrology. Implementation of Action CS-3.1 and CS-2.1 of the
Climate Action Plan, as described above under “Construction”, would protect water quality during
operation.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations to protect water quality in the Planning Area
such as Section 20.180.005 and Section 20.310.002, as described above under “Construction”.
Section 20.300.007 (Landscaping) (revised) includes a number of requirements for new construction
or rehabilitated landscapes, including the preparation of a soil management report and grading
design plan to reduce runoff (Draft Program EIR, Page 3.9-27—31).
The proposed project's impacts related to hydrology and water quality would be less than significant
or no impact with the implementation of applicable regulations, including General Plan policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4, Alternatives to the
Proposed Project, Page 4-12.)
Potential Effect
Impact HYD-2 The proposed project would not substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such that the proposed project
may impede sustainable groundwater management of the basin (Draft Program
EIR, 3.9-31—33).
Findings: Less than significant impact (Draft Program EIR, Page 3.9-33). No mitigation required.
Facts in Support of Findings: Development under the proposed project could lead to an increased
demand for water, which could lead to an increase in groundwater pumping. California Water
Service (Cal Water) South San Francisco District, one of two water providers for the City, has
historically pumped groundwater from the Westside Basin to supplement the supply from the San
Francisco Public Utilities Commission (SFPUC). Groundwater has historically supplied 10 to 15
percent of the Cal Water South San Francisco District’s water demand. The Cal Water South San
Francisco Water District groundwater supply is expected to be 100 percent reliable in all year types
through 2045.6 Subsequent development under the proposed project could result in an increase in
impervious surfaces, which could reduce stormwater and rainwater infiltration and transmitting of
groundwater. Future development under the proposed project would be required to comply with
6 California Water Service (Cal Water). 2021. 2020 Urban Water Management Plan. South San Francisco District. Website:
https://www.calwater.com/docs/uwmp2020/SSF_2020_UWMP_FINAL.pdf. Accessed April 20, 2022.
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requirements of the South San Francisco Municipal Code and Zoning Ordinance, and the General
Plan Update and Climate Action Plan policies and actions related to maximizing infiltration and
rainwater retention.
The General Plan Update includes policies and actions to maximize infiltration and rainwater
retention and minimize impacts to groundwater recharge, including Policies ES-2.2, ES-3.3, and ES-
7.3 as described above in Impact HYD-1. Policy ES-7.4 requires the City to encourage pervious
surfaces in new developments. Lastly, Policy ES-8.1 requires the City to optimize groundwater
recharge from new and redevelopment projects by infiltrating stormwater in accordance with State,
regional, and local requirements.
The South San Francisco Municipal Code also contains rules and regulations to maximize stormwater
infiltration and rainwater retention and minimize impacts to groundwater recharge. These include
Section 14.04.134, Section 14.04.132, and Section 14.04.133 as described above in Impact HYD-1.
The Climate Action Plan includes actions to maximize stormwater infiltration and rainwater retention
and minimize impacts to groundwater recharge. These include Actions CS 3.1 and CS 2.1, as
discussed above in Impact HYD-1.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations to maximize stormwater infiltration and
rainwater retention and minimize impacts to groundwater recharge. Section 20.180.005, described
above in impact HYD-1, will assist in maximizing infiltration and rainwater retention. Section
20.300.007 would maximize stormwater infiltration and rainwater retention and minimize impacts to
groundwater recharge (Draft Program EIR, 3.9-31 – 33).
The proposed project's impacts related to hydrology and water quality would be less than significant
or no impact with the implementation of applicable regulations, including General Plan policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4, Alternatives to the
Proposed Project, Page 4-12.)
Potential Effect
Impact HYD-3: The project would not substantially alter the existing drainage pattern of the site
or area, including through the alteration of the course of a stream or river or
through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on- or off-site;
ii) substantially increase the rate or amount of surface runoff in a manner which
would result in flooding on- or off-site;
iii) create or contribute runoff water which would exceed the capacity of existing
or planned stormwater drainage systems or provide substantial additional
sources of polluted runoff; or
iv) impede or redirect flood flows (Draft Program EIR, Page 3.9-33—37).
Findings: Less than significant impact (Draft Program EIR, Page 3.9-37). No mitigation required.
Facts in Support of Findings:
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i) Erosion and Siltation
Future development would involve construction activities such as stockpiling, grading, excavation,
paving, and other earth-disturbing activities. Loose and disturbed soils are more prone to erosion
and loss of topsoil by wind and water. This could result in an increase in stormwater runoff and the
potential to cause erosion or sedimentation in drainage swales and creeks. As discussed in Impact
HYD-1, construction activities that disturb one or more acres of land surface are subject to the
Construction General Permit adopted by the State Water Board, which requires development of a
SWPPP and inspection of construction sites before and after storms to identify stormwater discharge
from the construction activity and to identify and implement erosion controls, where necessary.
The South San Francisco Municipal Code and Zoning Ordinance set forth rules and regulations to
manage stormwater, which would also reduce erosion and siltation on- or off-site caused by
stormwater runoff. This includes Section 14.04.134 and Section 20.300.007 of the Municipal Code as
discussed above in Impact HYD-1. Section 20.310.002 of the Zoning Ordinance, also described above
in Impact HYD-1, would also reduce erosion and siltation on- or off-site caused by stormwater runoff.
General Plan Update policies and actions would further reduce the potential for erosion and off-site
siltation from construction-related soil disturbance. This includes Policies ES-2.2 and ES-3.3
described in Impact HYD-1 and Policy ES-7.4 described in Impact HYD-2. Policy CR-4.3 requires the
City to discourage development on steep hillside areas greater than a 30 percent grade and limit
grading to a minimum in such areas.
ii) Surface Runoff
Development under the proposed project encourages infill development and discourages
development on hillsides. New development or redevelopment that would be allowed by the
proposed project could increase the total impervious area within the Planning Area and increase
stormwater runoff, which could result in flooding. However, as described previously, compliance with
existing regulations and the General Plan Update and Climate Action Plan policies and actions, as
well as adherence to the South San Francisco Municipal Code and Zoning Ordinance, would
maximize stormwater infiltration and rainwater retention, which would in turn reduce stormwater
runoff.
Chapter 14.04 of the South San Francisco Municipal Code contains regulations that seek to minimize
impervious surfaces, minimize impacts from stormwater runoff, and follow LID requirements.
Section 20.310.002 (new) of the South San Francisco Zoning Ordinance requires City Engineer
approval of all drainage plans that alter the slope of contour of a site’s existing drainage pattern.
General Plan Update policies and actions would further reduce impacts from surface runoff,
including Policies ES-7.3, ES-2.2, ES-3.3, and ES-7.4 as previously described in Impacts HYD-1 and
HYD-2. Lastly, implementation of Climate Action Plan Actions CS 3.1 and CS 2.1, described in Impact
HYD-1, would assist in maximizing infiltration and rainwater retention throughout the Planning Area,
thereby reducing impacts from surface runoff.
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iii) Exceedance of Storm Drain Capacity
New development or redevelopment that would be allowed by the proposed project could increase
the total impervious area within Planning Area and increase stormwater runoff, which could exceed
stormwater drainage facility capacity or create additional sources of polluted runoff. As described
previously, implementation of General Plan Update Policies ES-2.2, ES-3.3, and ES-7.4 as well as
Climate Action Plan policies and actions and adherence to the requirements of the South San
Francisco Municipal Code and Zoning Ordinance would maximize the on-site infiltration capacity for
new development and redevelopment projects and would minimize off-site water runoff. This
includes previously described Chapter 14.04 and Section 20.310.002 of the South San Francisco
Zoning Ordinance.
iv) Impacts to Flood Flows
Some areas of the Planning Area are located within the 100-year flood zone, and some areas are
within the 0.2 percent annual chance flood hazard, which is referred to as the “500- year flood
zone”. As such, development facilitated by the proposed project would occur within FEMA-
designated 100-year flood zones with a 1 percent chance of being flooded in any given year. To a
smaller extent, development facilitated by the proposed project would occur within 500- year flood
zones. Subsequent development, infrastructure, and planning projects would be subject to the
General Plan Update policies and actions, as well as the South San Francisco Municipal Code and
Zoning Ordinance, to reduce the risks of flooding to City residents and properties. Furthermore, as
described in the Regulatory Framework section, federal and State agencies are responsible for
maintaining flood protection features in the City, including the USACE and BCDC.
The General Plan Update includes policies and actions specifically designated to address flood
hazards, including previously described Policy ES-2.1. Policy CR-2.3 requires the City to prioritize
green infrastructure in the Colma Creek Watershed to reduce flooding in developed areas through
continually updated site-specific design guidelines, LID, and design standards for public
infrastructure projects. Policy CR-2.5 requires new development to account for SLR in all project
applications, including the identification of areas of a parcel subject to flooding, the potential depth
of flooding, and raising base floor elevation above the FEMA Base Flood Elevation to include SLR
projections expected for the lifetime of the project. Policy CR-3.1 requires the City to continue to
work with San Mateo County Flood and SLR Resiliency District on developing and implementing
adaptation options for Colma Creek, restore creek ecologies, and create transitional habitat zones to
build resilience against flooding.
The South San Francisco Municipal Code also contains rules and regulations to address flood
hazards. Section 15.56.140 (Development permit) requires that a development permit be obtained
before any construction or other development occurs within an area of special flood hazard. Section
15.56.160 (Standards of construction) includes construction standards for all projects within special
flood hazard zones, including anchoring, construction materials and methods, elevation and
floodproofing. Section 15.56.170 (Standards for utilities) requires that all new and replacement
water supply and sanitary sewage systems be designed to minimize or eliminate infiltration of
floodwaters into the systems and discharge from the systems into floodwaters. Section 15.56.170
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also requires that all on-site waste disposal systems be located to avoid impairment to them, or
contamination from them during flooding. Lastly, Section 15.56.220 (Coastal high hazard areas)
includes standards for construction in coastal high hazard areas. For example, all new construction or
other development shall be located on the landward side of the reach of mean high tide. In addition,
all new residential and nonresidential construction, including substantial improvements, shall be
elevated on adequately anchored pilings or columns and securely anchored to such pilings or
columns so that the bottom of the lowest horizontal structural member of the lowest floor
(excluding the pilings or columns) is elevated to or above the base flood level. Implementation of
Action CS-3.1 and Action CS-2.1 of the Climate Action Plan, as described above in Impact HYD-1,
would increase stormwater infiltration and rainwater retention and assist in minimizing flood
hazards.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations to maximize stormwater infiltration and
rainwater retention, which would assist in minimizing flood hazards. This includes previously
discussed Section 20.180.005 (Development Standards) (new) which includes standards for the
Flood Plain/SLR Overlay District (Draft Program EIR, Page 3.9-33-37).
The proposed project's impacts related to hydrology and water quality would be less than significant
or no impact with the implementation of applicable regulations, including General Plan policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4, Alternatives to the
Proposed Project, Page 4-12.)
Potential Effect
Impact HYD-4 The proposed project could be located in a flood hazard zone, tsunami, or seiche
zone, and could risk release of pollutants due to project inundation (Draft Program
EIR, 3.9-38-40).
Findings: Less than significant impact (Draft Program EIR, 3.9-40). No mitigation required.
Facts in Support of Findings:
Inundation by Seiche
Seiches are changes or oscillations of water levels within a confined body of water. There are no
large, confined water bodies within the City of South San Francisco.
Inundation By Flooding (Including Sea Level Rise)
As described under Impact HYD-3, some areas of the Planning Area are located within the 100-year
flood zone, and some areas of the Planning Area are located within the 0.2 percent annual chance
flood hazard, which is referred to as the “500-year flood zone”.
The appellate court has specifically held that an EIR need not contain an extensive analysis of sea
level rise (SLR) or evaluate the potential impacts of SLR on a project. (Ballona Wetlands Land Trust v.
City of Los Angeles (2011) 201 Cal.App.4th 455, 473-74 [Ballona]). Therefore, this discussion related
to project site inundation from SLR is included for informational purposes. Exhibit 3.9-3 of the Draft
Program EIR shows the projected SLR and coastal flooding by 2100 along the coast of South San
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Francisco. A significant number of public facilities and infrastructure, buildings, and other structures
are likely to be affected based on a vulnerability assessment conducted by San Mateo County.
Portions of US-101, Fire Stations 61 and 62, the former Oyster Point Landfill, Bay Trail, South San
Francisco-San Bruno Water Quality Control Plant, and SFO are among the large public assets exposed
to future SLR.7
In addition to the policies and actions identified under Impact HYD-3 that address flood hazards, the
General Plan Update contains policies and actions to address SLR. Policy CR-2.2 requires the City to
pursue a comprehensive shoreline management plan that uses a variety of adaptation solutions to
protect the shoreline and enhance ecosystem resilience. Action CR-2.2.1 requires the City to
continue ongoing collaboration with the USACE to protect existing and future development by
raising levees or seawalls in accordance with the Continuing Authorities Program Study. Action CR-
2.2.1 also requires the implementation of any future City-prepared SLR adaptation plan for the
Oyster Point Marina and landfill. Action CR-2.2.2 requires the City to explore nature-based solutions
appropriate for the South San Francisco shoreline, particularly at the mouth of Colma Creek, to
provide protection for the built environment and ecosystems.
The South San Francisco Municipal Code and Zoning Ordinance contain rules and regulations related
to flood hazards and SLR. This includes previously discussed Section 15.56.140, Section 15.56.160,
and Section 15.56 of the Municipal Code and Section 20.180.005 of the Zoning Ordinance. Chapter
15.56 (Flood Damage Prevention) of the Municipal Code aims to promote the public health, safety,
and general welfare, and minimize public and private losses due to flood conditions in specific areas
by legally enforceable regulations applied uniformly throughout the community to all publicly and
privately owned land within flood prone, mudslide [i.e., mudflow] or flood-related erosion areas.
Mandatory federal, State, and local regulations govern the storage and use of hazardous materials to
ensure appropriate containment to prevent spills. In addition, General Plan Action LU-6.6.1 requires
the City to seek funding to finance cleanup and redevelopment of contaminated sites. Lastly, Action
CHEJ-4.1.2 requires the City to implement any future City-prepared SLR adaptation plan for the
Oyster Point Marina and landfill to prevent the release of toxins into the Bay.
Inundation by Tsunami
Portions of the City that are low-lying and located in the eastern side and adjacent to San Francisco
Bay, are susceptible to inundation from a tsunami as shown in Exhibit 3.9 of the Draft Program EIR.
As such, development facilitated by the proposed project could be located within a tsunami
inundation area, exposing structures, infrastructure, and people to inundation in the event of a
tsunami. As detailed above, the policies and actions of the General Plan Update and regulations in
the South San Francisco Municipal Code and Zoning Ordinance that address flood hazards and SLR
would also protect structures, infrastructure, and people in the event of inundation by tsunami.
Moreover, the General Plan Update contains policies and actions to prepare the City to respond to
natural disasters and minimize damage and injury caused by these events, including tsunamis. Action
7 Sea Change San Mateo County. 2018. Sea Level Rise Vulnerability Assessment. Website:
https://seachangesmc.org/vulnerabilityassessment/. Accessed April 16, 2022
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CR-1.3.1 requires the City to actively participate in the San Mateo County Hazard Mitigation Plan
maintenance protocols and Countywide initiatives, adopt the Hazard Mitigation Plan by reference
upon update, and update emergency operations plans and protocols to account for regularly
updated hazard information. Policy CR-1.6 requires the City to continually strengthen emergency
management capacity and coordination with the San Mateo County Emergency Operations Center.
Action CR-1.6.1 requires the City to develop a resiliency hub program to help community members
with disaster planning assistance and supplies. Lastly, Action CR-1.6.2 requires the City to add a
second floor to the City’s Emergency Operations Center (EOC), add a warehouse to store supplies to
support the City in the event of a disaster, and ensure the EOC has the necessary capabilities and can
continue operations after all future hazards.
Additionally, Section 3.8, Hazards and Hazardous Materials, provides more detail on mandatory
federal, State, and local regulations that govern the storage and use of hazardous materials to ensure
appropriate containment to prevent spills. In addition, General Plan Action LU-6.6.1 and CHEJ-4.1.2,
described above, relate to the cleanup and redevelopment of contaminated sites and the prevention
of the release of toxins into the Bay (Draft Program EIR, 3.9-38-40). The proposed project's impacts
related to hydrology and water quality would be less than significant or no impact with the
implementation of applicable regulations, including General Plan policies and implementing actions.
No mitigation is necessary. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page
4-12.)
Potential Effect
Impact HYD-5 The proposed project would not conflict with or obstruct implementation of a
water quality control plan or sustainable groundwater management plan (Draft
Program EIR, Page 3.9-40-41).
Findings: Less than significant impact (Draft Program EIR, 3.9-41). No mitigation required.
Facts in Support of Findings: The City is within the jurisdiction of the San Francisco Bay RWQCB. The
RWQCB has established regulatory standards and objectives for water quality in San Francisco Bay in
its Water Quality Control Plan for the San Francisco Bay Basin, commonly referred to as the Basin
Plan.
As discussed under Impact HYD-1, construction and operation of development facilitated by the
proposed project would be required to comply with CWA, the General Plan Update policies and
actions, the South San Francisco Municipal Code and Zoning Ordinance, and the mandatory NPDES
permit requirements. Future development under the proposed project at construction and
operation would not violate any water quality standards or WDRs or otherwise substantially degrade
surface or groundwater quality, in compliance with the San Francisco Bay Basin Plan.
As discussed under Impact HYD-2, groundwater supply is expected to be 100 percent reliable in all
year types through 2045.8 Additionally, the General Plan Update contains several policies and actions
that would facilitate groundwater recharge by encouraging pervious surfaces in new developments
8 California Water Service (Cal Water). 2021. 2020 Urban Water Management Plan. South San Francisco District. Website:
https://www.calwater.com/docs/uwmp2020/SSF_2020_UWMP_FINAL.pdf. Accessed April 20, 2022.
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and requiring projects to meet federal, State, regional, and local stormwater requirements, including
stormwater infiltration (Draft Program EIR, Page 3.9-40-41).
The proposed project's impacts related to hydrology and water quality would be less than significant
or no impact with the implementation of applicable regulations, including General Plan policies and
implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4, Alternatives to the
Proposed Project, Page 4-12.)
Cumulative Effect
The proposed project’s cumulative impacts related to hydrology would be less than significant (Draft
Program EIR, Page 3.9-41—42).
Findings: Less than significant impact (Draft Program EIR, Page 3.9-41). No mitigation required.
Facts in Support of Findings: The geographic context for an analysis of cumulative impacts is the
Colma Creek Watershed, which includes Colma, Daly City, South San Francisco, and portions of
unincorporated San Mateo County.9
Cumulative development in the watershed contributes to an incremental increase in impervious
surfaces that could introduce pollutants that are typically associated with urban runoff into the
stormwater and/or contribute to cumulative flood conditions in the watershed. Cumulative
development could also contribute to water quality impacts in the watershed from construction
activities. Cumulative impacts would be less than significant because future cumulative
development, infrastructure, and planning projects would be subject to local, State and federal
permit requirements and would be required to comply with City (Colma, Daly City, South San
Francisco) and San Mateo County ordinances and San Mateo County General Plan policies, as well as
other water quality regulations that control construction-related and operational discharge of
pollutants in stormwater. The water quality regulations implemented by the RWQCB take a basin-
wide approach and consider water quality impairment in a regional context that addresses the entire
geographic context of the Colma Creek Watershed. For example, the Construction General Permit
ties receiving water limitations and basin plan objectives to terms and conditions of the permit, and
the MS4 Permit works with all municipalities within the Colma Creek Watershed (Colma, Daly City,
South San Francisco, and unincorporated San Mateo County) to manage stormwater systems to be
collectively protective of water quality. If a CWA Section 404 permit is required, the USACE would
have approval authority.
Moreover, the proposed project’s incremental contribution to less than significant cumulative
impacts would not be significant with implementation of the policies and actions proposed in the
General Plan Update and the South San Francisco Municipal Code and Zoning Ordinance. As
previously discussed, future development under the proposed project would be required to conform
to federal, State, and local policies that would reduce hydrology and water quality impacts to less
than significant levels. When applicable, any additional new development within the Planning Area
9 County of San Mateo. 2022. Colma Creek Watershed. Website: https://www.smcgov.org/publicworks/colma-creek-watershed.
Accessed April 24, 2022.
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would be subject, on a project-by-project basis, to independent CEQA review as well as policies and
actions in the General Plan Update, the South San Francisco Municipal Code and Zoning Ordinance,
and other applicable City requirements that reduce impacts related to hydrology and water quality.
More specifically, potential changes related to stormwater quality, stormwater flows, drainage,
impervious surfaces, and flooding would be minimized by the implementation of stormwater control
measures, bioswales, infiltration, and LID measures, and review by the City Engineer to integrate
measures to reduce potential flooding impacts. Therefore, development under the proposed project
would not have a cumulatively considerable contribution to a cumulative hydrology impact (Draft
Program EIR, Page 3.9-41—42).
The proposed project's cumulative impacts related to hydrology and water quality would be less
than significant or no impact with the implementation of applicable regulations, including General
Plan policies and implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4,
Alternatives to the Proposed Project, Page 4-12.)
1.5.10 - Land Use and Planning
Potential Effect
Impact LAND-1 The proposed project would not physically divide an established community (Draft
Program EIR, Page 3.10-15—17).
Findings: Less than significant impact (Draft Program EIR, 3.10-17). No mitigation required.
Facts in Support of Findings: The physical division of an established community typically refers to
the construction of a physical feature or the removal of a means of access that would impair mobility
within an existing community, or between a community and outlying areas. The proposed project
does not contemplate or authorize any such physical changes to the community. With
implementation of the General Plan Update and CAP policies and actions, the proposed project
would support community connectivity. New development that occurs within South San Francisco is
anticipated to consist of infill development and redevelopment of existing developed properties.
Infill development and redevelopment generally do not divide established communities, as they
typically occur within individual parcels or adjoining parcels. Future development occurring under
the proposed project would be required to demonstrate consistency with the applicable regulations
requiring connectivity (See generally, Section 3.10, Land Use and Planning, of the Draft Program EIR).
The General Plan Update contains a multitude of policies and actions to require and ensure
community connectivity as buildout occurs. Policy LU-1.2 requires connectivity in complete
neighborhoods. Policy LU-1.4 requires the maintenance and expansion of public facilities and
services including co-locating new public projects near compatible civic uses, thereby encouraging
community connectivity. Policy LU-1.7 facilitates the construction of new neighborhoods in
Lindenville and East of 101 that are well connected. Policies LU-2.1 and LU-2.3 prioritize
development near transit centers and transit-oriented communities with strong pedestrian, shuttle,
and bicycle connections. Policy LU-6.1 prohibits the introduction of new residential, commercial, and
other nonresidential uses in areas designated as Mixed Industrial High to preserve land for industrial
uses. Policy LU-6.2 prohibits additional encroachment of incompatible uses into industrial areas in
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Lindenville and East of 101, except where residential growth is planned. Policy LU-7.1 promotes
complete neighborhoods that provide convenient access to a range of goods and services. Policy
LU7.5 fosters pedestrian and bicycle access. Policy LU-8.3 requires the improvement of pedestrian
connections and sidewalk infrastructure. Policy MOB-2-1 requires the incorporation of complete
streets improvements into all roadway and development projects. Action MOB-2.1.1 ensures that all
roadway and development projects are designed and evaluated to meet the needs of all street users,
and that development projects contribute to multimodal improvements in proportion to their
potential impacts on vehicle miles traveled. Action MOB-2.1.3 implements the Active South City
Pedestrian and Bicycle Plan. Action MOB-2.2.1 requires collaboration with the SSFUSD to implement
Safe Routes to Schools programs and improvements, with an emphasis on schools serving equity
priority communities. Action MOB-3.2.2 incorporates new street connections to better distribute
vehicle trips across South San Francisco’s street network, especially in the East of 101 area.
The Climate Action Plan (CAP) includes a number of actions to ensure community connectivity as
buildout occurs. Implementation of Action TL-2.3 would evaluate the current and best use of curb
space in the City’s activity centers and repurpose space to maximize people served (i.e., for loading,
bikeways, bike parking, bus lanes, EV charging, or parklets). Implementation of Action TL-2.5 would
ensure that all new land use and transportation projects adhere to the City’s Vehicle Miles Traveled
(VMT) Analysis Guidelines and qualitatively assess the proposed project’s effect on multimodal
access. Implementation of Action TL-2.5 would allow for the use of the development review process
to identify opportunities to enhance bicycle, pedestrian, and transit connectivity. Implementation of
Action TL-2.6 would ensure that all roadway and development projects are designed and evaluated
to meet the needs of all street users and that development projects contribute to multimodal
improvements in proportion to their potential impacts on VMT. Implementation of Action TL-2.8
would improve transit station access by leveraging public-private partnerships to increase transit
ridership and improve transit station access by incorporating first/last mile bus, shuttle, and active
transportation connections between employment hubs and regional transit stations.
The South San Francisco Zoning Ordinance, including the new or revised chapters of the Zoning
Ordinance that are part of the proposed project, define allowable land uses and development
standards for each Base Zoning District, Overlay District, and Specific and Area Plan Districts. Some
of the development standards include building heights, building setbacks, and standards for fences
and walls to ensure that community connectivity is maintained as future development occurs within
the Planning Area. In addition, Section 20.300.014 (Underground Utilities) requires that all exterior
utilities, including but not limited to drainage systems, sewers, natural gas lines, water, electrical,
telephone, cable television, and similar distribution lines providing direct service to a development
site shall be installed and maintained underground within a project site. Further, all on-site
underground utilities shall be designed and installed to minimize the disruption of off-site utilities,
paving and landscaping during construction and maintenance.
The South San Francisco Municipal Code contains rules and regulations to ensure community
connectivity as buildout occurs. Chapter 13.16 (Underground Utility Installations) contains
regulations for the installation, maintenance, use, and removal of underground utilities as well as
responsibilities of property owners and utility companies. Chapter 14.14 (Sewer Lateral
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Construction, Maintenance, and Inspection) contains regulations regarding the operation and
maintenance of the City’s sewer system. Section 19.16.030 (Utility Easements) states that easements
not less than 10 feet wide shall be required within or across lots where necessary for underground
utilities, cables, wires, street trees, drainage, conduit and water mains or other utilities (Draft
Program EIR, Page 3.10-15-17).
The proposed project’s impacts related to land use would be less than significant or no impact with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4,
Alternatives to the Proposed Project, Page 4-13.)
Potential Effect
Impact LUP-2 The proposed project would not cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation adopted for the purpose of
avoiding or mitigating an environmental effect (Draft Program EIR, Page 3.10-18-
21).
Findings: Less than significant impact (Draft Program EIR, Page 3.10-21). No mitigation required.
Facts in Support of Findings:
The General Plan Update is consistent with Government Code Section 65300 and includes the seven
mandatory elements. Some elements have been combined and additional relevant elements have
been added. Consistent with General Plan Update requirements under State Planning and Zoning
law, added elements will be submitted for review and approval by applicable State agencies. Also
consistent with Government Code Section 65300, the General Plan Update is internally consistent,
plans for the long term (horizon year of 2040), includes all land within the city limits and SOI
(Planning Area) and is readily available to the public.
The proposed project would draft new and revise existing elements of the City’s current general
plan. As such, the adoption of the General Plan Update would serve as a self-mitigating aspect of the
proposed project and inconsistency with the existing general plan prior to the update would not be
considered a potential significant impact.
Likewise, the City's Zoning Code Amendments would be revised to implement the proposed project,
consistent with State Law (Government Code § 65860(a)). The Zoning Code Amendments would
translate the General Plan Update policies into specific requirements, development standards and
performance criteria to guide the review and consideration of individual development projects.
The General Plan Update, Zoning Code Amendments, and CAP all include various regulations with
the intention of avoiding or mitigating environmental effects. The Zoning Code Amendments are
necessary to implement the General Plan Update and are therefore internally consistent. The City’s
CAP was designed in concert with the General Plan Update to provide clear policy guidance to City
staff and decision-makers on how to reduce GHG emissions and therefore, inherently mitigates
environmental effects. Furthermore, the CAP aligns with new State regulations and targets related to
climate change. The potential environmental impacts related to the implementation of these
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regulatory documents is considered throughout the Draft Program EIR. Lastly, the proposed project
would be consistent with the City’s various Specific Plans, Master Plans, and Area Plans as evidenced
by the General Plan Update’s Action LU-2.1.3, which requires the review and update of existing plans
to ensure consistency.
Future development under the proposed project would be required by the City to demonstrate
consistency with applicable federal, State, and local policies including those mitigating or avoiding
environmental impacts through the mechanisms of project permitting and approvals.
Senate Bill 375 and Plan Bay Area 2050
Plan Bay Area 2050 is a 30-year, long-range strategic plan focused on the interrelated elements of
housing, the economy, transportation, and the environment. As a regional land use plan, Plan Bay
Area 2050 aims to reduce per capita GHG emissions by promoting more compact, mixed-use
residential and commercial neighborhoods located near transit, and therefore aims to reduce and/or
mitigate environmental impacts. Plan Bay Area 2050 implements Senate Bill (SB) 375; however, SB
375 does not directly require local land use policies, regulations, or general plans to be consistent
with Plan Bay Area 2050. Instead, it requires consistency between regional transportation planning
processes and local housing planning processes. Because both Plan Bay Area 2050 and the General
Plan Update use similar growth projections and were developed in consideration of each other, the
General Plan Update would not be expected to conflict with Plan Bay Area 2050.
Airport Land Use Compatibility Plan
The proposed project would intensify land uses within the East of 101, Lindenville, Downtown, and
El Camino planning subareas to create more housing units and employment opportunities. Portions
of proposed mixed-use residential land use designations are located within SFO’s runway safety zone
boundaries and 65 decibel (dB) CNEL noise contour. Some of the Planning Area is located within the
70 dB CNEL noise contour. Residential developments in this area would be required to undergo
federal, State, and local regulatory review processes specific to airport noise, airspace safety, and
other land use compatibility standards, including 14 Code of Federal Regulations Part 77 regulations
for the safety, efficient use, and preservation of navigable airspaces. The SFO ALUCP requires grant of
an avigation easement as a condition of allowing residential development within the 65 dB contour.
Disclosure regarding airport noise is also required under South San Francisco Municipal Code
Chapter 15.58. Residential uses are designated as incompatible with the 70 dB counter and higher.
Residential uses East of 101 would experience significant noise disturbances from aircraft
departures.
As discussed under Impact HAZ-5, portions of the Mixed Industrial High, Business Technology Park
High, East of 101 Mixed Use, High Density Mixed Use, Urban Residential, and El Camino Mixed Use
High land use designations are located within various Safety Compatibility Zones. Future projects
within the Mixed Industrial High land used designations have the potential to conflict with Zone 2
restrictions. Future projects within the Business Technology Park, East of 101 Mixed Use, and High-
Density Mixed-Use land use designations have the potential to conflict with Zone 3 restrictions.
Furthermore, future projects within the El Camino Mixed Use High land use designation have the
potential to conflict with Zone 4 restrictions.
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The ALUCP for the Environs of SFO specifies how land near airports is to be used, based on safety
and noise compatibility considerations, develops height restrictions for new development to protect
airspace in the vicinity of the airport, and establishes construction standards for new buildings near
airports, including sound insulation requirements. Local plans, policy actions, or development
activities that affect areas within that boundary must receive ALUC approval or have a finding of
overriding considerations prior to local permit issuance. The SFO ALUCP requires all residential
development within Area A, which is the entirety of San Mateo County, to provide real estate
disclosures (see SFO ALUCP Appendix G-7). Additionally, within Area B, the ALUC (C/CAG of San
Mateo County) is responsible for reviewing proposed land use policy actions, including new general
plans, specific plans, zoning ordinances, plan amendments and rezoning, and land development
proposals. As such, the City is required to submit the General Plan Update to the ALUC for review
and approval and future development within the SFO ALUCP areas must also be referred to the ALUC
for a determination of consistency with the 2011 California Airport Land Use Planning Handbook and
the SFO ALUCP. In reviewing individual project applications, the City would determine which policies
and actions apply and whether project modifications would be required to ensure compatibility with
the ALUCP, depending on the specific characteristics of the project type and/or project site during
the development review process. Buildings within the ALUCP area would be required to comply with
FAA regulations for height.
Furthermore, the General Plan Update includes policies and actions related to land use compatibility.
Action SA-12.5.1 requires the General Plan to be in conformance with land use compatibility
standards in the ALUCP. Policy SA-21.3 allows building heights within maximum limits permitted
under FAA regulations. These actions, along with the requirements of the ALUCP and South San
Francisco Municipal Code ensure that future development would be consistent with the ALUCP.
Therefore, the proposed project would not cause a significant environmental impact due to a conflict
with ALUCP for the purpose of avoiding or mitigating an environmental effect.
San Francisco Public Utilities Commission
The SFPUC has several water transmission pipelines that traverse the City, generally in a north–
south direction within right-of-way lands that are typically 80 feet wide. Development under the
proposed project would result in additional residential and nonresidential development throughout
the Planning Area, some of which may occur along SFPUC right-of-way lands. The SFPUC may permit
a secondary use on the right-of-way. It also maintains a Right-of-Way Encroachment Removal Policy
and a Right-of-Way Vegetation Management Plan that addresses existing and future encroachments,
maintenance and security. Future buildout of the proposed project located within SFPUC right-of-
way would be required to apply for and have approved any secondary use through the SFPUC’s
formal process, ensuring that the future development would not conflict with SFPUC right-of-way
regulations adopted for the purpose of avoiding or mitigating an environmental effect (Draft
Program EIR, Page 3.10-15-17).
Accordingly, the City finds that the proposed project’s impacts related to land use would be less than
significant or no impact with the implementation of applicable regulations, including new and
revised General Plan Update policies and implementing actions. No mitigation is necessary. (Draft
Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-13.)
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Cumulative Effects
The proposed project’s cumulative impacts related to land use and planning would be less than
significant (Draft Program EIR, Page 3.10-21—22).
Findings: Less than significant impact (Draft Program EIR, Page 3.10-22). No mitigation required.
Facts in Support of Findings: The geographic context for analysis of cumulative impacts related to
land use and planning generally includes the Planning Area and San Mateo County.
Cumulative development is likely to continue occurring in the surrounding incorporated and
unincorporated areas of San Mateo County, most of which would take place in urbanized areas as
infill development and would not require significant land use changes that would create land use
conflicts, nor would they divide existing communities. Development would be subject to the land
use plans, policies, and regulations of the applicable jurisdiction. As such, development within
incorporated and unincorporated areas of San Mateo County is not likely to create significant land
use conflicts or divide existing communities.
The proposed project’s incremental contribution to cumulative land use impacts would also not be
significant. The land uses allowed under the proposed project provide opportunities for cohesive
new growth and redevelopment on existing parcels within developed areas. As discussed under
Impacts LUP-1 and LUP-2, the proposed project would promote strategic development alongside
existing land uses. The proposed General Plan Update contains policies and actions that support a
connected community and promotes a network of pedestrian and bicycle trails that enhance
neighborhoods. Implementation of the proposed project would not include approval of linear
infrastructure projects that may create a barrier or physically divide an established community. The
proposed project does not conflict with any applicable land use plan, policy, or regulation, adopted
for the purpose of avoiding or mitigating an environmental effect, including the SFO ALUCP or SFPUC
regulations. As such, development anticipated under the proposed project would not create
substantial land use impacts or result in the physical division of existing communities. New
development and redevelopment consistent with the proposed project would be designed to
complement the character of existing neighborhoods and provide connectivity between existing
development and new development within the cumulative analysis area. Further, the proposed
project does not approve the construction or development of any new roadways, walls, bridges,
major infrastructure, or other features that would divide existing neighborhoods within the
cumulative analysis areas. Accordingly, the proposed project’s contribution to cumulative impacts
would also be less than significant (Draft Program EIR, Page 3.10-21-22). The City finds that the
proposed project’s cumulative impacts related to land use would be less than significant or no
impact with the implementation of applicable regulations, including new and revised General Plan
Update policies and implementing actions. No mitigation is necessary. (Draft Program EIR, Chapter 4,
Alternatives to the Proposed Project, Page 4-13.)
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1.5.11 - Noise
Potential Effect
Impact NOI-2 The proposed project would not result in generation of excessive groundborne
vibration or groundborne noise levels (Draft Program EIR, Page 3.11-32-34).
Findings: Less than significant impact (Draft Program EIR, Page 3.11-34). No mitigation required.
Facts in Support of Findings: New development under the proposed project would result in
additional residential and nonresidential development, as well as other private and public
improvements, throughout the Planning Area. The short-term and long-term groundborne vibration
impacts associated with construction and operations are discussed separately below.
Construction-Related Vibration
Construction activity can result in varying degrees of ground vibration, depending on the equipment
used on the site. Table 3.11-3 of the Draft Program EIR provides approximate vibration levels for
specific types of construction equipment and activities. Construction vibration levels from future
development projects under the proposed project, including other private and public improvements,
could exceed the FTA damage threshold criteria of 0.12 in/sec PPV. Construction vibration sources
can be mitigated to acceptable levels either at the source or on the adjacent property using
alternate equipment, adequate setbacks, or by digging temporary trenches between the source and
the receptor.
Mandatory requirements in the General Plan Update will ensure that construction vibration impacts
associated with future development projects under the proposed project remain less than
significant. Policy NOI-2.1 requires a vibration impact analysis for any construction activities located
within 100-feet of residential or sensitive receptors that require the use of pile driving or other
construction methods that have the potential to produce high groundborne vibration levels. Policy
NOI-3.1 requires vibration impact analysis for historic structure protection for construction activities
within 150 feet of historic structures. Compliance with these standards is also reiterated in Section
20.300.009 (Performance Standards) (revised) of the Zoning Ordinance. These required site-specific
analyses would identify measures such as setback requirements, use of alternate construction
methods, or pre-emptive trenching to interrupt groundborne vibration transmission. These policies
are applied to all construction permits and compliance is mandatory and is monitored by City
grading and building department personnel.
Operation-Related Vibration
The primary source of groundborne vibration generated within the boundaries of South San
Francisco is rail activity from BART and the Southern Pacific Railroad line. Based on the FTA
Guidelines, the screening distance for conventional railroad activity is 200 feet for residences and
other buildings where people sleep. Groundborne vibration from rail activity could result in levels of
annoyance or disturbance for residential-type land uses located within 200 feet of existing rail lines
within the City. However, BART remains underground throughout the City and compliance with
mandatory requirements of the General Plan Update will ensure that railroad groundborne vibration
impacts are minimized to acceptable levels. Policy NOI-2.2 requires that a vibration impact analysis
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be prepared for new land use developments located within 200 feet of an existing rail line (Draft
Program EIR, Page 3.11-32-34).
The proposed project's impacts related to vibration would be less than significant with the
implementation applicable regulations, including new and revised General Plan Update policies and
implementing actions. No mitigation is necessary.
Cumulative Effects
The proposed project’s cumulative impacts related to noise would be less than significant (Draft
Program EIR, Page 3.11-36-37).
Findings: Less than significant impact (Draft Program EIR, Page 3.11-37). No mitigation required.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for Noise is the
South San Francisco Planning Area as well as the surrounding cities of Brisbane, Daly City, Pacifica,
San Bruno, and Millbrae; however, it is important to note that noise is by definition a localized
phenomenon and reduces in magnitude as the distance from the noise source increases.
Cumulative traffic noise levels would have the highest increase of 1.7 dBA compared to existing
traffic noise levels, along the segment of Grand Avenue from Linden Avenue to Airport Boulevard.
The noise levels resulting from future development under the proposed project would be 61.9 dBA
CNEL along this segment of Grand Avenue. These traffic noise levels are considered normally
acceptable for all types of land uses. Therefore, this increase is not considered a cumulative impact.
As shown in Table 3.11-8 of the Draft Program EIR, for every modeled roadway segment that would
result in traffic noise levels that would exceed normally acceptable standards for some land uses, the
contribution of future development under the proposed project to those impacted roadway
segments is less than a 1 dBA increase or even results in a decrease in noise levels, compared to
noise levels that would exist without the proposed project. Therefore, development under the
proposed project would not have an incremental contribution to the less than significant cumulative
impact, and traffic-related noise levels from the proposed project would not result in a cumulatively
considerable contribution to the noise environment in the vicinity of the proposed project.
With regard to stationary source noise impacts, cumulative development would be required to
comply with existing planning regulations regarding noise. In addition, the implementation of MM
NOI-1, Operational Noise Reduction Plan, would reduce stationary source noise impacts from future
development under the proposed project to less than significant and would not result in any
substantial permanent increase in ambient noise levels. Therefore, stationary source noise levels
from implementation of the proposed project would not result in a cumulatively considerable
contribution to the environment in the vicinity of the proposed project.
The major sources of groundborne vibration within the Planning Area are temporary construction
and ongoing railroad activity. These sources do not constitute an existing cumulative impact.
Furthermore, construction and operational groundborne vibration impacts associated with future
development under the proposed project would remain less than significant with compliance with
mandatory requirements of the General Plan Update. Therefore, there is no cumulative
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groundborne vibration impact, and groundborne vibration levels from implementation of the
proposed project would not result in a cumulatively considerable contribution to this less than
significant cumulative impact
With regard to airport activity noise impacts, the combined effects of cumulative projects (other
cities) surrounding South San Francisco would not result in any additional special events or sources
of single-event noise in the form of aircraft flyover noise, and therefore, would not result in changes
in the 65 dBA CNEL airport noise contours and would not increase airport noise impacts. However,
future buildout cumulative conditions related to airport activity related noise would be the same as
that identified in Impact NOI-3 discussion above. The proposed project could still result in the
introduction of land use development that could be potentially incompatible with the noise
environment in the vicinity of SFO. However, as discussed in Impact NOI-3, implementation of MM
NOI-3, Airport Noise Impact Reduction Plan, would reduce airport activity noise impacts from
implementation of the proposed project to less than significant. No additional mitigation is required
with respect to cumulative impacts. Therefore, airport activity noise levels from implementation of
the proposed project would not result in a cumulatively considerable contribution to this less than
significant cumulative impact (Draft Program EIR, Page 3.11-36-37). The proposed project's
cumulative impacts related to noise would be less than significant with the implementation of
mitigation measures and applicable regulations, including new and revised General Plan Update
policies and implementing actions.
1.5.12 - Population, Housing, and Employment
Potential Effect
Impact POP-1 The proposed project would not induce substantial unplanned population growth
in an area, either directly (for example, by proposing new homes and businesses)
or indirectly (for example, through extension of roads or other infrastructure)
(Draft Program EIR, Page 3.12-19-21).
Findings: Less than significant impact (Draft Program EIR, Page 3.12-21). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. The majority of potential
growth would occur within the East of 101, Lindenville, Downtown, and El Camino planning
subareas. The proposed project anticipates approximately 14,312 net new housing units, with a
projected total of 38,959 housing units by 2040. The proposed project anticipates approximately
42,297 net new employment opportunities, with a projected total of 137,557 employment
opportunities by 2040. This new growth would increase the City’s population by approximately
40,068 to 107,203 by 2040. The population growth under the proposed project would not be
unplanned.
As noted above, the additional population growth is less than the anticipated net new employment
opportunities. By 2040, with buildout of the proposed project, the jobs-to-housing ratio is
anticipated to be approximately 3.53, exceeding a balanced jobs-to-housing ratio of 1.0 to 1.5 jobs
for every housing unit. By 2040, with buildout of the proposed project, the jobs-to-employed
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residents’ ratio is estimated to be 2.95, exceeding the balanced jobs-to-employed residents’ ratio of
1.0. Therefore, under current and future conditions, the City provides more jobs than it has
employable residents, and more jobs than can be filled by existing and projected households. Thus,
the City is likely to experience increased traffic associated with employees traveling from outside
South San Francisco to jobs located within the City, as well as intensified pressure for additional
residential development to house the labor force in the City.
The General Plan Update contains goals, policies and actions that plan for and guide growth within
the City through 2040 and support the objectives of the City. Areas identified for future residential
and commercial development would be required to abide by policies and actions to ensure that new
development or redevelopment does not induce substantial direct or indirect population growth.
The General Plan Update accounts for the 2015-2023 Regional Housing Need Allocation as outlined
by the ABAG. Policy LU-3.7 requires no net loss in housing, meaning that the number of residential
units for a particular site would not be reduced by reconstruction or renovation projects to result in
a loss of units. Policy LU-3.4 facilitates multi-generational housing. Policy LU-3.5 facilitates live/work
housing. Goal LU-4 identifies high-quality residential neighborhoods. The General Plan Update’s
Subareas Element augments citywide goals and policies from the Land Use and Community Design
Element and provides policies and implementation actions specific to subareas related to housing
and employment. The General Plan Update also plans for future expansion of City service to
accommodate expected growth. The South San Francisco Municipal Code also contains regulations
regarding housing and land use types that affect population and employment. Title 20, Zoning, of
the Municipal Code implements the City’s General Plan and provides a precise guide for the physical
development of the City, consistent with the goals and policies of the General Plan. Future
development would be reviewed by the City for compliance with the policies and actions of the
General Plan Update, the City’s Municipal Code, and the mitigation measures referenced in other
sections of the Draft Program EIR and project-specific environmental documentation, thus additional
population growth would be considered planned growth (Draft Program EIR, Page 3.12-19-21).
The proposed project's impacts related to population, housing, and employment would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact POP-2 The proposed project would not displace substantial numbers of existing people
or housing, necessitating the construction of replacement housing elsewhere
(Draft Program EIR, Page 3.12-21-22).
Findings: Less than significant impact (Draft Program EIR, Page 3.12-22). No mitigation required.
Facts in Support of Findings: As discussed above, the proposed project anticipates approximately
14,312 net new housing units and approximately 42,297 net new employment opportunities by
2040, increasing the City’s population by approximately 40,068. The City of South San Francisco will
review applications for future development under the proposed project for compliance with the
policies and actions of the General Plan Update and the South San Francisco Municipal Code and
Zoning Ordinance to ensure the displacement of housing or significant need for new housing does
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not occur. The proposed project includes land use and Zoning Code Amendments but does not
propose or approve any specific development that would result in the displacement of existing
housing units or people, necessitating the construction of replacement housing elsewhere.
The General Plan Update includes policies and actions to ensure that existing housing is
appropriately protected, and additional housing is added to support future growth within the City by
2040, including Policy LU-3.7 and Policy LU-3.5, as discussed above. Goal LU-3 and Policy LU-3.3
encourage a diverse range of housing types and options. Policy LU-3.1 requires the active facilitation
of adding affordable workforce housing. The Housing Element is being updated and once certified,
the Housing Element’s goals and policies would also be applicable to future development within the
City. The 2023-2031 RHNA is expected to be appropriately incorporated into the Housing Element to
guide the City in meeting the housing provision goals.
The City of South San Francisco Municipal Code and Zoning Ordinance, including the Zoning Code
Amendments that are part of the proposed project, contain several existing provisions to address the
location and design of new and renovated housing units. Chapter 20.480 outlines design review,
Section 20.350.035 regulates ADUs, Chapter 19.36 regulates condominiums and community housing
projects, Chapter 20.380 regulates inclusionary housing, Chapter 20.390 implements State density
bonus law, Chapter 20.070 regulates residential zoning districts, and Chapter 20.080 regulates
downtown residential districts. Chapter 8.96 outlines the commercial linkage fee, the revenue of
which can be used to fund new housing, preserve existing units, or acquire new land for nonprofit
developers (Draft Program EIR, Page 3.12-21-22). The proposed project's impacts related to
population, housing, and employment would be less than significant with the implementation of
applicable regulations, including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary.
Cumulative Effects
The proposed project’s cumulative impacts related to population, housing, and employment would
be less than significant (Draft Program EIR, Page 3.12-23).
Findings: Less than significant impact (Draft Program EIR, Page 3.12-23). No mitigation required.
Facts in Support of Findings: The geographic context for analysis of cumulative impacts related to
population, housing, and employment includes the nine Bay Area counties (San Mateo, San
Francisco, Santa Clara, Marin, Sonoma, Napa, Solano, Alameda, and Contra Costa).
ABAG projects that from 2025 to 2040 the population of San Mateo County will increase from
approximately 816,460 to 916,590, an increase of approximately 100,130 people, or, on average,
approximately 0.8 percent increase per year. For the City of South San Francisco, ABAG projects that
from 2025 to 2040, population is projected to increase from 71,080 to 80,015, or, on average,
approximately 0.8 percent increase per year. As such, the City and County growth rates are expected
to be approximately similar.
The general plans and other planning documents prepared by the jurisdictions within the nine Bay
Area counties (San Mateo, San Francisco, Santa Clara, Marin, Sonoma, Napa, Solano, Alameda, and
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Contra Costa) would be required to develop land use plans that comply with State law and that
would accommodate the existing and forecasted population, similar to the long-range planning
guidance included in the proposed project. Consistent with State law, these planning documents
would be required to provide adequate housing to accommodate forecasted numbers of people
within the jurisdiction, and displaced development, if any, would be replaced primarily within the
jurisdiction. Further, new development would be required to address potential environmental
impacts as part of individual project review. As such, cumulative development would not induce
substantial unplanned population growth, either directly or indirectly. Because cumulative projects
would comply with all applicable land use plans to provide adequate development within a
jurisdiction, cumulative impacts would be less than significant.
Moreover, the proposed project would not have a cumulatively considerable contribution to the less
than significant cumulative impact. As the City’s projected population growth is within projected
growth estimates, and the growth would be occurring primarily through infill development within
the City, the proposed project’s contribution to this less than significant cumulative impact would
not be cumulatively considerable. The proposed project would not result in any policies or physical
improvements that would result in direct or indirect unplanned regional growth or result in
substantial displacement of people or the need to construct additional housing and therefore would
not contribute to a cumulative impact (Draft Program EIR, Page 3.12-23). The proposed project's
cumulative impacts related to population, housing, and employment would be less than significant
with the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
1.5.13 - Public Services
Potential Effect
Impact PUB-1 The proposed project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered fire protection facilities,
need for new or physically altered fire protection facilities, the construction of
which could cause significant environmental impacts, in order to maintain
acceptable service ratios, response times or other performance objectives for fire
protection (Draft Program EIR, Page 3.13-22-24).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-24). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area as well as other private
and public improvements throughout the City, with the potential for environmental effects related to
fire protection facilities. Development and growth in the City would increase demand for fire
protection services. There may be a need to increase staffing and equipment or expand or construct
new fire stations to maintain acceptable service ratios, response times, and other performance
standards which could cause environmental impacts.
The General Plan Update includes policies and actions to ensure that fire protection services keep
pace with new development. Policy SA-16.4 requires the City to coordinate with the SSFFD to ensure
public services can accommodate growth impacts of new development in the East of 101 area. Policy
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SA-22.7 requires the City to coordinate with the SSFFD to ensure public services can accommodate
growth impacts of new development in Lindenville. Action ECS-6.1.1 requires the City to maintain an
equitable distribution of Fire Stations so that each neighborhood is equally and adequately served.
The South San Francisco Municipal Code contains rules and regulations related to fire protection
services. Chapter 8.75 of the Municipal Code requires that all residential and nonresidential
development projects pay public safety impact fees to provide funding for adequate fire equipment,
vehicles, and facilities to meet the broad range of needs of South San Francisco residents and
employees. Chapter 15.24 of the Municipal Code implements the California Fire Code on a local
level. In accordance with Chapter 15.24, new development projects must meet fire protection and
emergency access requirements. In addition, new development projects are required to install fire
sprinklers, fire alarms, and fire extinguishers that are up to current code and appropriately located
within proposed buildings or structures.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, includes rules and regulations related to fire protection services. Section
20.300.009 (Performance Standards) (revised) requires that land or buildings shall not be used or
occupied in a manner creating any dangerous, injurious, or noxious fire, explosive, or other hazard
which would adversely affect the surrounding area. All activities, processes, and uses involving the
use of, or storage of, flammable and explosive materials shall be provided with adequate safety
devices against the hazard of fire and explosion. Firefighting and fire suppression equipment and
devices standard in industry shall be approved by the Fire Department. All incineration is prohibited
with the exception of those substances, including chemicals, insecticides, hospital materials, and
waste products, required by law to be disposed of by burning and those instances wherein the Fire
Department deems it a practical necessity. Chapter 20.350 Standards and Requirements for Specific
Uses and Activities (revised) requires setbacks from fire hydrants, fire lanes, and fire access ways, the
use of fire-treated umbrellas, canopies, or other shade elements for outdoor dining areas, and
provision of fire walls to separate every 3,000 square feet within any personal storage structure. For
large recycling facilities, storage containers for flammable material shall be constructed of
nonflammable material and approved by the Fire Department and oil storage must be in containers
approved by the Fire Department and Health Official. Section 20.360.004 (General Standards for All
Signs) (revised) prohibits the placement of any sign on a fire hydrant or in a manner that would
prevent or inhibit free ingress to or egress from any door, window, vent, or any exit way required by
the Building Code or by Fire Department regulations (currently in effect). Section 20.490.005
(Conditions of Approval) (revised) allows the Chief Planner to impose conditions related to fire
protection in approving a temporary use permit.
The project-specific environmental impacts of constructing new or expanded fire protection facilities
cannot be determined at this time because the site-specific locations and designs are not known.
Buildout under the proposed project could result in approximately 68,367 square feet of
nonresidential uses under the “Public” land use designation, which could include fire protection
facilities. It can be expected that construction and operation of future new or expanded fire
protection facilities would have similar impacts as would construction and operation of other types
of new development under the proposed project.
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New or expanded fire protection facilities will be reviewed by the City for compliance with the
policies and actions of the General Plan Update, the City’s Municipal Code, and the mitigation
measures referenced in other sections of the Draft Program EIR. In addition, the City will review
development applications for development under the proposed project for compliance with the
policies and actions of the General Plan Update to ensure that fire protection services keep pace
with new development. Chapter 8.75, Public Safety Impact Fee, and Chapter 15.24, California Fire
Code of the City’s Municipal Code would be reviewed when development applications are received
(Draft Program EIR, Page 3.13-22-24). The proposed project's impacts related to public services and
recreation would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update policies and implementing actions. No mitigation is
necessary.
Potential Effect
Impact PUB-2 The proposed project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered police protection
facilities, need for new or physically altered police protection facilities, the
construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios, response times or other performance
objectives for police protection (Draft Program EIR, Page 3.13-24-26).
Findings: Less than significant impact (Draft Program EIR, 3.13-26). No mitigation required.
Facts in Support of Findings: As described above, development under the proposed project would
result in additional residential and nonresidential development throughout the Planning Area. The
proposed project may result in other private and public improvements throughout the City with the
potential for environmental effects related to police protection facilities. The proposed project
anticipates approximately 14,312 net new housing units and approximately 42,297 net new
employment opportunities by 2040. This new growth would increase the City’s population by
approximately 40,068. Development and growth in the City would increase demand for police
protection services. Thus, there may be a need to increase staffing and equipment, or expand or
construct new police stations, to maintain acceptable service ratios, response times, and other
performance standards which could cause environmental impacts.
The General Plan Update includes policies and actions to ensure that police protection services keep
pace with new development, including Policy SA-16.4 and Policy SA-22.7 as discussed above. Action
ECS-6.1.2 requires the City to establish a Community Safety and Equity Advisory Board to review
data, provide recommendations, build trust, and make recommendations related to public safety or
to any equity issue throughout City departments and programs. Action ECS-6.1.3 requires the City to
strengthen community cohesion through community engagement efforts to build cross-cultural trust
between the Police and Fire Departments and residents of color and low-income residents.
The South San Francisco Municipal Code contains rules and regulations related to police protection
services, including previously discussed Chapter 8.75. The South San Francisco Zoning Ordinance,
including the Zoning Code Amendments that are part of the proposed project, include rules and
regulations related to police protection services. Section 20.350.029 (Other Financial Services) (new)
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requires that a security plan be provided for review and approval by the Chief Planner and the City of
South San Francisco Police Department for other financial services, which includes alternative loan
businesses and pawnbrokers. The plan shall provide for adequate security, including a central station
alarm system to the Police Department. Bars on the windows, exterior phones, and roll-up doors are
prohibited. Section 20.490.005 allows the Chief Planner to impose conditions related to police
protection in approving a temporary use permit.
The project-specific environmental impacts of constructing new or expanded police protection
facilities cannot be determined at this time because the site-specific locations and designs are not
known. Buildout under the proposed project, as described in Impact PUB-1, could include fire
protection facilities. It can be expected that construction and operation of future new or expanded
fire protection facilities would have similar impacts as would construction and operation of other
types of new development under the proposed project.
New or expanded police protection facilities will be reviewed by the City for compliance with the
policies and actions of the General Plan Update, the City’s Municipal Code, and the mitigation
measures referenced in other sections of the Draft Program EIR. In addition, the City will review
development applications for development under the proposed project for compliance with the
policies and actions of the General Plan Update to ensure that fire protection services keep pace
with new development, as well as Chapter 8.75 Public Safety Impact Fee of the City’s Municipal Code
(Draft Program EIR, Page 3.13-24—26). The proposed project's impacts related to public services and
recreation would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update policies and implementing actions. No mitigation is
necessary.
Potential Effect
Impact PUB-3 The proposed project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered school facilities, need
for new or physically altered school facilities, the construction of which could
cause significant environmental impacts, in order to maintain acceptable service
ratios or other performance objectives for schools. (Draft Program EIR, Page 3.13-
26—27)
Findings: Less than significant impact (Draft Program EIR, Page 3.13-27). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. The majority of potential
growth would occur in areas located within the SSFUSD. The proposed project anticipates
approximately 14,312 net new housing units and approximately 42,297 net new employment
opportunities by 2040, increasing the City’s population by approximately 40,068 and increasing
demand for school facilities. According to telephone communication with Jessen Langley of SSFUSD
Student Services on March 7th, 2022, schools within the SSFUSD are operating at approximately 65.7
percent of capacity and existing school facilities would be able to accommodate the additional
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students in existing facilities.10 The incremental increase in staffing and equipment required to
maintain acceptable service ratios and other service objectives for schools as enrollment increases
would not result in significant environmental impacts.
The General Plan Update includes policies and actions to ensure that school facilities keep pace with
new development. These include Policy SA-16.4 and Policy SA-22.7, as described above in Impact
PUB-1. Policy LU-1.4 requires the City to maintain and expand public facilities to better support the
community, including schools, particularly in neighborhoods lacking these resources. Policy LU-1.6
requires the City to promote childcare and pre-K facilities in South San Francisco. Policy ECS-5.3
requires the City to maintain a continuous exchange of information with the SSFUSD on projected
growth of the City. The City will review development applications for subsequent development
under the proposed project for compliance with the policies and actions of the General Plan Update
to ensure that school facilities keep pace with new development. Finally, the City’s Municipal Code,
which implements the City’s General Plan, would be reviewed when development applications are
received, including payment of school impact fees per SB 50.
The proposed project's impacts related to public services and recreation would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact PUB-4 The proposed project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered library facilities, need
for new or physically altered library facilities, the construction of which could
cause significant environmental impacts, in order to maintain acceptable service
ratios or other performance objectives for library facilities (Draft Program EIR,
Page 3.13-27—29).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-29). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area with the majority of
residential uses located within 1 mile of an existing or new library (Community Civic Campus). The
proposed project anticipates approximately 14,312 net new housing units and approximately 42,297
net new employment opportunities by 2040. This new growth would increase the City’s population
by approximately 40,068. Development and growth in the City would increase demand for library
facilities. The new library at the Community Civic Campus can accommodate some of the increase in
demand for library services from buildout of the proposed project, but increased staffing and
equipment to maintain acceptable service ratios and other performance objectives for library
facilities may be needed. If an existing library is at capacity for staffing, this could require an
expansion of an existing library or construction of a new library, the construction of which could
cause environmental impacts.
10 Langley, Jessen. Student Services, South San Francisco Unified School District (SSFUSD). Personal communication: telephone. M arch
7, 2022.
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The General Plan Update includes policies and actions to ensure that library facilities keep pace with
new development, including Policy LU-1.4 as described in Impact PUB-3. Policy ECS-7.1 requires the
City to ensure adequate library services, staffing, and facilities are maintained for all residents. Policy
ECS-7.7 requires the City to develop customer service surveys to use to evaluate library programs
and events. The South San Francisco Municipal Code contains rules and regulations related to library
facilities including Chapter 8.74 of the Municipal Code, which establishes a library impact fee to
finance library facilities and collections which benefit development, and for each new development
to pay its fair and proportional share of these improvements.
The proposed project does not include specific plans for the construction of a new or expanded
library, thus project-specific environmental impacts cannot be determined at this time. However,
library facilities are allowed within the “Public” land use designation and are contemplated as part of
the proposed project. Buildout under the proposed project, as discussed in Impact PUB-1, could
include library facilities. It can be expected that construction and operation of future new or
expanded library facilities would have similar impacts as would construction and operation of other
types of new development under the proposed project. The City will review construction plans of
new or expanded library facilities for compliance with the policies and actions of the General Plan
Update, the City’s Municipal Code, and the mitigation measures referenced in other sections of the
Draft Program EIR. Furthermore, applications for subsequent development under the proposed
project will be reviewed by the City for compliance with the policies and actions of the General Plan
Update to ensure that library facilities keep pace with new development. In addition, development
facilitated by the proposed project would be required to pay library impact fees in accordance with
Chapter 8.74 of the Municipal Code (Draft Program EIR, Page 3.13-27—29). The proposed project's
impacts related to public services and recreation would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Potential Effect
Impact PUB-5 The proposed project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered other public facilities,
need for new or physically altered other public facilities, the construction of which
could cause significant environmental impacts, in order to maintain acceptable
service ratios or other performance objectives for other public facilities (Draft
Program EIR, Page 3.13-29).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-29). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area, increasing the City’s
population by approximately 40,068. Development and growth in the City would increase demand
for other public facilities. As such, there may be an additional need to increase staffing and
equipment to maintain acceptable service ratios and other performance objectives for these other
public facilities. If an existing public facility is at capacity for staffing, an expansion of an existing
public facility or construction of a new public facility may be required, which could cause
environmental impacts.
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The proposed project does not include specific plans for the construction of new or expanded other
public facilities, thus project-specific environmental impacts cannot be determined at this time.
However, public facilities are allowed within the “Public” land use designation and are contemplated
as part of the proposed project (Exhibit 2-4 of Draft Program EIR). Buildout under the proposed
project, as discussed in Impact PUB-1, could include other public facilities. It can be expected that
construction and operation of future new or expanded public facilities would have similar impacts as
would construction and operation of other types of new development under the proposed project.
The City will review plans for the construction of new or expanded public facilities for compliance
with the policies and actions of the General Plan Update, the City’s Municipal Code, and the
mitigation measures referenced in other sections of the Draft Program EIR (Draft Program EIR, Page
3.13-29).
The proposed project's impacts related to public services and recreation would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact REC-1 The proposed project would not increase the use of existing neighborhood and
regional parks or other recreational facilities such that substantial physical
deterioration of the facility would occur or be accelerated (Draft Program EIR,
Page 3.13-30-31).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-31). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area, with the majority of
residential uses located within 0.75 mile of an existing or proposed new park or recreational facility.
The proposed project anticipates approximately 14,312 net new housing units and approximately
42,297 net new employment opportunities by 2040, increasing the City’s population by
approximately 40,068 (Chapter 2, Draft Program EIR). Development and growth in the City would
increase demand for parks and recreational facilities. There may be a need to increase staffing and
other resources, or expand or construct new parks and recreational facilities, to maintain existing
parks and recreational facilities at acceptable service ratios. The environmental impacts from the
construction of new parks and recreational facilities are discussed above under Impact REC-2.
Based on the City’s projected population of 107,203 by 2040, an additional 274 acres of park and
open space would be needed by 2040 to achieve the City’s service standard of 5.5 acres of parkland
per 1,000 residents. The proposed project includes new parks and recreational facilities to assist the
City in meeting the park service standards. Additionally, the General Plan Update includes policies
and actions to ensure that parks and recreational facilities keep pace with new development. Policy
SA-16.3 requires the City to create new parks and open spaces in East of 101, including a public park
within a ten-minute walk to any new residential development East of 101, a Colma Creek linear park
featuring walking and cycling paths, and a recreational greenway between South Airport Boulevard
and Littlefield Avenue. Action SA-31.1.1 requires the City to coordinate with Cal Water to purchase
or lease land along Chestnut Avenue and Colma Creek to expand Orange Park. Policy PR-1.5 requires
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the City to seek opportunities to use vacant and underutilized commercial and industrial buildings
for recreational services, especially in disadvantaged communities. Policy PR-1.4 requires the City to
ensure accessible public facilities and services are equitably distributed throughout the City and are
provided in a timely manner to keep pace with new development. Policy PR-3.3 requires the City to
create new public access points to Sign Hill, San Bruno Mountain State and County Park, and the San
Francisco Bay Trail and parks. Policy PR-4.6 requires the City to work with other agencies, including
PG&E, California Water Service, and SFPUC to convert public easements, such as utility corridors or
unused rights of way, into parks and trails. Lastly, Policy PR-5.2 requires the City to seek
opportunities to acquire property, including former Redevelopment Agency sites, utility right-of-way,
and other vacant and underutilized properties to convert into parkland in the Downtown sub-area.
The South San Francisco Municipal Code contains rules and regulations related to parks and
recreational facilities. Chapter 8.67 of the Municipal Code establishes a parks and recreation impact
fee to acquire property in the City and provide three acres of parkland per 1,000 residents and one-
half acre of parkland per 1,000 new employees, mitigating the impact of development projects on
park facilities. The City will review applications for development under the proposed project for
compliance with the policies and actions of the General Plan Update to ensure that parks and
recreational facilities keep pace with new development. In addition, development facilitated by the
proposed project would be required to pay parks and recreation impact fees in accordance with
Chapter 8.67 of the Municipal Code (Draft Program EIR, Page 3.13-30-31).
The proposed project's impacts related to public services and recreation would be less than
significant with the implementation of applicable regulations, including new and revised General
Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact REC-2 The proposed project could include parks or recreational facilities or require the
construction or expansion of parks or recreational facilities, which may have an
adverse physical effect on the environment (Draft Program EIR, Page 3.13-31-32).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-31). No mitigation required.
Facts in Support of Findings: The proposed project could yield new parks, improved open space
adjacent to State Route 35, and pedestrian and bicycle connections primarily east of US-101 and
along the transit corridors. The proposed project also identifies planned and proposed parks and
open spaces throughout the City, primarily within the Westborough, Orange Park, Lindenville, and
East of 101 planning sub-areas. There could be environmental impacts associated with the
construction of new or expanded parks and recreational facilities. However, project-specific
environmental impacts cannot be assessed as the proposed project does not include specific plans
for new or expanded park and recreation facilities. However, it can be expected that construction
and operation of future new or expanded parks and recreational facilities would have similar impacts
as would construction and operation of other types of new development under the proposed
project. The City will review construction plans of new or expanded parks and recreational facilities
for compliance with the policies and actions of the General Plan Update and the City’s Municipal
Code (Draft Program EIR, Page 3.13-31-32). The proposed project's impacts related to public services
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and recreation would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update policies and implementing actions. No mitigation is
necessary.
Cumulative Effects
The proposed project’s cumulative impacts related to public services and recreation would be less
than significant (Draft Program EIR, Page 3.13-32-35).
Findings: Less than significant impact (Draft Program EIR, Page 3.13-35). No mitigation required.
Facts in Support of Findings: The geographic context for analysis of cumulative impacts related to
public services generally includes the South San Francisco Planning Area and is delineated by the
local service areas within the City, as described below in each service area discussion.
Fire Protection Services
The geographic context for the analysis of cumulative impacts related to fire protection facilities
includes the SSFFD service area, which comprises the City of South San Francisco. A significant
cumulative environmental impact would result if cumulative growth exceeded the ability of SSFFD to
adequately serve its service area, thereby requiring construction of new facilities or modification of
existing facilities. Development activity in the City provides revenue through impact fees, and license
and permit fees. Additionally, SSFFD conducts a regular budgeting process where future facility and
staffing needs are identified. All cumulative projects within the SSFFD service area would be required
to comply with City ordinances and General Plan Update policies and actions that address fire
protection services, including payment of public safety impact fees to provide funding for adequate
fire equipment, vehicles, and facilities to meet the broad range of needs of South San Francisco
residents and employees. Because past and present development will comply with all ordinances
and policies, and there are mechanisms in place to ensure provision of adequate service, there
would be no significant cumulative condition with respect to fire protection services.
Moreover, the proposed project’s incremental contribution to the less than significant cumulative
impacts would not be significant. As discussed under Impact PUB-1, implementation of the proposed
project would not create a need for new or physically altered facilities for the SSFFD to provide fire
protection services to its service area.
As previously discussed, development facilitated by the proposed project would be required to
comply with the policies and actions in the General Plan Update as well as the South San Francisco
Municipal Code, to ensure that fire protection services are adequate as future development is
proposed. Therefore, impacts of the proposed project on fire protection services are not
cumulatively considerable.
Police Protection Facilities
The geographic context for the analysis of cumulative impacts related to police protection facilities
includes the SSFPD service area, which comprises the City of South San Francisco. A significant
cumulative environmental impact would result if this cumulative growth exceeded the ability of the
SSFPD to adequately serve its service area, thereby requiring construction of new facilities or
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modification of existing facilities. Development activity in the City provides revenue through impact
fees and license and permit fees. Additionally, SSFPD conducts a regular budgeting process where
future facility and staffing needs are identified. All cumulative projects within the SSFPD service area
would be required to comply with City ordinances and General Plan Update policies and actions that
address police protection services, including payment of public safety impact fees to provide funding
for adequate police equipment, vehicles, and facilities to meet the broad range of needs of South
San Francisco residents and employees. Because past and present development will comply with all
ordinances and policies, and there are mechanisms in place to ensure provision of adequate service,
there would be no significant cumulative condition with respect to police protection services.
Moreover, the proposed project’s incremental contribution to the less than significant cumulative
impacts would not be significant. As discussed under Impact PUB-2, implementation of the proposed
project would not create a need for new or physically altered facilities for the SSFPD to provide
police protection services to its service area.
As previously discussed, development facilitated by the proposed project would be required to
comply with the policies and actions in the General Plan Update as well as the South San Francisco
Municipal Code, to ensure that police protection services are adequate as future development is
proposed. Therefore, impacts of the proposed project on police protection services are not
cumulatively considerable.
School Facilities
The geographic context for the analysis of cumulative impacts related to school facilities includes the
SSFUSD and private schools that serve South San Francisco and surrounding cities. Regional growth
resulting from past, present, and reasonably foreseeable projects would result in increased demand
for additional school facilities within the SSFUSD. Schools are expected to receive development
impact fees from cumulative development within other jurisdictions. The payment of school impact
fees, per SB 50, would ensure that school facilities can accommodate future students.
Moreover, the proposed project’s incremental contribution to the less than significant cumulative
impacts would not be significant. As discussed under Impact PUB-3, development facilitated by the
proposed project would be required to pay the school impact fees adopted by each school district,
per SB 50, and this requirement is considered to fully address the impacts of the proposed project
on school facilities. Therefore, impacts of the proposed project on school facilities are not
cumulatively considerable.
Library Facilities
The geographic context for analysis of cumulative impacts to library facilities includes the South San
Francisco Public Library. A significant cumulative environmental impact would result if cumulative
growth exceeded the ability of the South San Francisco Library to adequately serve people within its
service area, thereby requiring construction of new facilities or modification of existing facilities. All
cumulative projects would be required to comply with City ordinances and other policies that
address library facilities and services, including library impact fees.
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Moreover, the proposed project’s incremental contribution to the less than significant cumulative
impacts would not be significant. As discussed under Impact PUB-4, development facilitated by the
proposed project would be required to pay library impact fees. Therefore, impacts of the proposed
project on library facilities are not cumulatively considerable.
Other Public Facilities
The geographic context for analysis of cumulative impacts to other public facilities includes the
Planning Area. Development and growth in the City would increase demand for other public
facilities. A significant cumulative environmental impact would result if cumulative growth exceeded
the ability of the City to adequately serve people within its service area, thereby requiring
construction of new facilities or modification of existing facilities. All cumulative projects would be
required to comply with City ordinances and other policies that address other public facilities.
Moreover, the proposed project’s incremental contribution to the less than significant cumulative
impacts would not be significant. As discussed under Impact PUB-5, implementation of the proposed
project would not create a need for other new or physically altered public facilities to maintain
acceptable service ratios or other performance objectives. Therefore, impacts of the proposed on
other public facilities are not cumulatively considerable.
Parks and Recreational Facilities
The geographic context for the analysis of cumulative impacts of parks and recreational facilities
includes the Planning Area. A significant cumulative environmental impact would result if this
cumulative growth resulted in an increase in the use of existing parks and recreational facilities, such
that substantial physical deterioration of the parks or recreational facilities would occur or be
accelerated, to require the construction of new parks and recreational facilities or modification of
existing parks and recreational facilities. All cumulative projects would be required to comply with
City ordinances and General Plan Update policies that address parks and recreational facilities, such
as paying park in-lieu fees and maintaining adequate parkland ratios.
Moreover, the proposed project’s incremental contribution to less than significant cumulative
impacts would not be significant. As discussed under Impact REC-1, implementation of the proposed
project would not increase the use of existing neighborhood and regional parks or other recreational
facilities, such that substantial physical deterioration of the facility would occur or be accelerated. As
discussed under Impact REC-2, the construction or expansion of parks and other recreational
facilities are not expected to result in an adverse physical effect on the environment. As such,
development anticipated under the proposed project would not create substantial impacts related
to parks and other recreational facilities.
Further, potential future impacts to South San Francisco parks and recreational facilities would be
further reduced through the contribution of a parks and recreation impact fee to ensure facilities at
these locations are adequately maintained and sufficient to accommodate growth associated with
cumulative development. Therefore, impacts of the proposed project on parks and other
recreational facilities are not cumulatively considerable (Draft Program EIR, Page 3.13-32-35).
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Accordingly, the proposed project's cumulative impacts related to public services and recreation
would be less than significant with the implementation of applicable regulations, including new and
revised General Plan Update policies and implementing actions. No mitigation is necessary.
1.5.14 - Transportation
Potential Effect
Impact TRANS-2 Implementation of the proposed project would not conflict with a program, plan,
ordinance, or policy of the circulation system regarding bicycle or pedestrian
facilities, or otherwise decrease the performance or safety of such facilities, that
may have a significant impact on the environment (Draft Program EIR, Page 3.14-
41-44).
Findings: Less than significant impact (Draft Program EIR, Page 3.14-44). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area and may result in other
private and public improvements throughout the City that have the potential for environmental
effects related to bicycle and pedestrian facilities. Future potential development under the proposed
project would contribute to and increase use of bicycle and pedestrian facilities in South San
Francisco. The General Plan Update does not conflict with the Active South City Plan, which seeks to
improve bicycle and pedestrian safety and improve mobility options in South San Francisco. The
proposed circulation network enhances bicycle and pedestrian facilities citywide, improves
connectivity, and shortens walking and biking distances.
While growth within South San Francisco would cumulatively contribute to and increase use of
bicycle and pedestrian facilities, the General Plan Update includes policies and actions, listed on
Pages 3.14-41-43 of the Draft Program EIR, that directly and indirectly result in improving the bicycle
and pedestrian network and supporting programs to increase bicycle and pedestrian travel.
Implementation of these General Plan Update policies and actions of the proposed project would
improve the bicycle and pedestrian network and support programs to increase bicycle and
pedestrian travel and ensure that the proposed project would not conflict with a program, plan,
ordinance, or policy of the circulation system regarding bicycle or pedestrian facilities, or otherwise
decrease the performance or safety of such facilities.
Furthermore, actions identified in the Climate Action Plan, including Actions TL-2.5 (Development
along Transit Corridors) and TL-2.6 (Complete Streets Policy), would enhance the bicycle and
pedestrian network. Implementation of Action TL-2.5 would ensure that all new land use and
transportation projects adhere to the City’s VMT Analysis Guidelines and qualitatively assess the
project’s effect on multimodal access. Action TL-2.5 includes use of the development review process
to identify opportunities to enhance bicycle, pedestrian, and transit connectivity. Implementation of
Action TL-2.6 would ensure that all roadway and development projects are designed and evaluated
to meet the needs of all street users and that development projects contribute to multimodal
improvements in proportion to their potential impacts on VMT. Further, Action TL-2.6 includes the
development of a Capital Improvement Program (CIP) prioritization criteria, including equity
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considerations for SB 1000 neighborhoods, to strategically advance multimodal complete streets
projects. Lastly, Action TL-2.6 would ensure that all capital improvements and development projects
incorporate bicycle and pedestrian improvements identified in the Active South City Plan, such as
trails, bikeways, bicycle detection at traffic signals, high-visibility crosswalks, and pedestrian-oriented
site plans.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations that assist in reducing impacts related to bicycle
and pedestrian facilities. Chapter 20.400 (Transportation Demand Management) (revised) promotes
more efficient utilization of existing transportation facilities and ensures that new developments
maximize transit, active transportation, carpooling, and vanpooling usage. Section 20.400.005
(Submittal Requirements and Approvals) (revised) requires that a project subject to the TDM
Ordinance submit TDM documentation with the development application, which includes a
completed TDM checklist of the trip reduction measures chosen by the applicant and a description
of how the applicable performance requirements would be achieved and maintained over the life of
the project. The trip reduction measures identified in Section 20.400.003 (Trip Reduction Measures
and Requirements) (revised) related to bicycle and pedestrian facilities include the provision of
bicycle storage, showers, and lockers, providing bicycle and pedestrian-oriented site access,
providing on-site pedestrian-oriented amenities, providing active transportation subsidies, providing
cash reward incentives for commuting via walking or biking, and providing a bicycle repair station.
Further, Section 20.330.007 (Bicycle Parking) (revised) establishes short-term and long-term bicycle
parking requirements for new buildings and land uses, reconstruction, expansion, and change in the
use of nonresidential buildings, additions and alterations to existing dwelling units, and alterations
that increase the number of dwelling units (Draft Program EIR, Page 3.14-41-44). Therefore, related
transportation impacts would be less than significant and no mitigation is necessary.
Potential Effect
Impact TRANS-3 Implementation of the proposed project would not conflict with a program, plan,
ordinance, or policy of the circulation system regarding transit facilities, or
otherwise decrease the performance or safety of such facilities, that may have a
significant impact on the environment (Draft Program EIR, Page 3.14-44-47).
Findings: Less than significant impact (Draft Program EIR, Page 3.14-47). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area and may result in other
private and public improvements throughout the City that have the potential for environmental
effects related to transit facilities. Future potential development under the proposed project would
increase use of transit service and transit facilities in South San Francisco.
The General Plan Update includes policies and actions that directly and indirectly result in improving
the transit network and supporting an increase in transit use. Implementation of these General Plan
Update policies and actions would improve the transit network and support programs to increase
travel by transit and would not conflict with a program, plan, ordinance, or policy of the circulation
system regarding transit systems or otherwise decrease the performance or safety of such facilities.
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Actions identified in the Climate Action Plan, including Actions TL 2.5 and TL 2.6 as discussed above
in Impact TRANS-2, as well as TL 2.8 (Improve Transit Station Access) would enhance the transit
network. Implementation of Action TL 2.8 would include leveraging public-private partnerships to
increase transit ridership and improve transit station access by incorporating first/last mile bus,
shuttle, and active transportation connections between employment hubs and regional transit
stations.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, includes rules and regulations that would enhance transit facilities. These
include Chapter 20.400, Section 20.400.005, and Section 20.400.003 as described above in Impact
TRANS-2 (Draft Program EIR, Page 3.14-44-47). Accordingly, impacts would be less than significant
and no mitigation is required.
Potential Effect
Impact TRANS-5 Implementation of the proposed project would not result in inadequate
emergency access (Draft Program EIR, Page 3.14-50-52).
Findings: Less than significant impact (Draft Program EIR, Page 3.14-52). No mitigation required.
Facts in Support of Findings: Future potential development under the proposed project would alter
land use patterns and increase travel demand on the transportation network that may influence
emergency access. To accommodate the additional population and jobs, the proposed project
includes 25 circulation improvements listed in Table 3.14-5 of the Draft Program EIR. The proposed
improvements would increase connectivity in the network, which would promote improved
emergency access. Additionally, new development that occurs pursuant to the proposed project
would be subject to the provisions of the California Fire Code including those that pertain to
emergency access. Multiple policies and actions in the Mobility Element and in other sections of the
proposed project, listed on Pages 3.14-51-52 of the Draft Program EIR, support the maintenance of
adequate emergency access.
Furthermore, actions identified in the Climate Action Plan would support the maintenance of
adequate emergency access. Implementation of Action TL 2.3 would improve curb management by
evaluating the current and best use of curb space in the City’s activity centers and repurposing space
to maximize people served (i.e., for loading, bikeways, bike parking, bus lanes, EV charging, or
parklets). Implementation of Action TL 2.6 would ensure that all roadway and development projects
are designed and evaluated to meet the needs of all street users and that development projects
contribute to multimodal improvements in proportion to their potential impacts on vehicle miles
traveled.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include rules and regulations to reduce impacts related to emergency access
including Chapter 20.400, Section 20.400.005, and Section 20.400.003, as discussed in Impact
TRANS-2. Section 20.400.003 identifies trip reduction measures that promote carpooling and the use
of transit, pedestrian and bicycle facilities, which would assist in reducing the number of vehicles on
the road, thereby reducing traffic congestion throughout the City that could impede emergency
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access (Draft Program EIR, Page 3.14-50-52). Accordingly, impacts would be less than significant and
no mitigation is required.
1.5.15 - Utilities and Service Systems
Potential Effect
Impact UTIL-1 The proposed project would not require or result in the relocation or construction
of new or expanded water, wastewater treatment or stormwater drainage, electric
power, natural gas, or telecommunications facilities, the construction or relocation
of which would cause significant environmental effects (Draft Program EIR, Page
3.15-28-30).
Findings: Less than significant impact (Draft Program EIR, Page 3.15-30). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area. The proposed project is
expected to accommodate 40,068 new residents, 14,312 new housing units, 42,297 new jobs, and
14,100,523 new square feet of nonresidential building space at buildout. These increases would
require additional water, wastewater treatment, storm drainage, electric power, natural gas, and
telecommunication services which may require the construction or relocation of facilities which
could cause significant environmental impacts. Each service is discussed separately below.
Water
As noted in Impact UTIL-2 of the Draft Program EIR, the General Plan Update includes policies and
actions that would reduce water demand of future buildout. The CAP also includes actions that
would reduce water demand of future buildout under the proposed project. Also described under
Impact UTIL-2, both the Cal Water South San Francisco District and WWD project sufficient water
supply availability under normal water years and require conservation measures under dry year
conditions per the Cal Water Shortage Contingency Plan and WWD Water Shortage Contingency
Plan. In addition, most new development accommodated under the proposed project is expected to
be infill and would rely on the existing distribution network that has sufficient capacity to convey
available water supplies. As such, implementation of the proposed project would not result in the
need to construct or expand water supply and treatment facilities that have not already been
described and accounted for the in the 2020 UWMPs.
Furthermore, each individual project would be required to demonstrate the availability of water to
service the development, as required and applicable, in the form of will-serve letters or, for larger
projects, preparation of a WSA per SB 610. If additional facilities were to be constructed, separate
environmental analysis would be required. The City currently complies with the statutory
requirements listed in the regulatory section, and the General Plan Update ensures that the City will
continue to comply with the State and federal regulatory requirements. The General Plan Update
encourages water conservation through Policies ES-5.3, ES-5.8, and ES-5.9. Policy ES-7.1 provides for
ongoing partnerships with regional and local agencies to develop a comprehensive watershed
management strategy that identifies programs, partnerships, actions, and incentives that the City
and partners can take to protect the City’s water resources and Policy ES-7.2 calls for integration of
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green irrigation infrastructure into City-owned landscapes. Additional policies focus on integrating
green infrastructure for energy efficiency.
Cal Water’s 2020 UWMP and WWD’s 2020 UWMP state that there are currently no planned future
water supply projects or programs that are expected to provide a quantifiable increase to the water
supply. However, Cal Water is currently in the process of developing a regional water supply
reliability study to create a long-term supply reliability strategy through 2050 for Cal Water districts
in the Bay Area. It is anticipated this study will identify feasible water supply projects that may
benefit the South San Francisco District. Individual infrastructure improvements that may occur
under the applicable UWMPs would be subject to individual CEQA review and clearance to
determine whether any would have significant environmental impacts. Therefore, the proposed
project would not result in insufficient water supplies from Cal Water and WWD, and no new or
expanded water treatment facilities would be needed under the proposed project.
Wastewater
As described under Impact UTIL-3, the General Plan Update includes policies and actions that would
reduce the need for wastewater treatment. The CAP also includes actions that would reduce the
need for wastewater treatment. In accordance with City requirements, new development that
occurs pursuant to the proposed project would be subject to the latest adopted edition of the
California Plumbing Code and CALGreen Code, including the provisions for water-efficient fixtures
and toilets, which would reduce the amount of effluent entering the wastewater system. Further, as
discussed under Impact UTIL-3, there is sufficient capacity at the South San Francisco/San Bruno
WQCP and Daly City’s North San Mateo WQCP to accommodate wastewater collection and
treatment generated by the proposed project.
Future development under the proposed project would be located within the urban framework of
the City and near existing wastewater infrastructure. As such, implementation and buildout of the
proposed project would not result in the need to construct or expand wastewater collection and
treatment facilities that have not already been described and accounted for in the applicable Sewer
System Master Plans. The City currently complies with the statutory requirements listed in the
regulatory section, and the General Plan Update policies and actions ensure that the City will
continue to comply with State and federal regulatory requirements related to wastewater. Therefore,
the proposed project would not result in insufficient wastewater collection and treatment and no
new or expanded wastewater treatment facilities would be needed.
Storm Drainage Capacity
In accordance with City requirements, new development that occurs pursuant to the proposed
project would be required to install on-site storm drainage infrastructure that would detain
stormwater and release runoff at a rate no greater than the pre-development condition of the
project site. General Plan Policy ES-7.3 requires stormwater management practices for new and
redevelopment projects. Policies ES-7.4 and ES-8.1 allow for groundwater recharge. Policy ES-8.2
implements potable water demand reduction measures. Additional policies require further water
efficiency upgrades and measures. City requirements and policies would ensure that runoff would
not inundate downstream storm drainage facilities such that new or expanded facilities would be
required.
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Electric Power, Natural Gas, and Telecommunications
Electricity, natural gas, and telecommunications utilities respond to increased demands and prepare
long-range plans to accommodate projected growth in their service areas. These planning efforts
consider growth projections, including the growth under the proposed project. Because the
proposed project would not result in unplanned growth, the majority of growth would be infill, and
because the utility providers take into consideration all future growth projections in their planning
efforts, the proposed project would not be expected to require or result in new or expanded
electricity, natural gas, or telecommunications facilities beyond those already planned (Draft
Program EIR, Page 3.15-28-30). The proposed project's impacts related to utilities and service
systems would be less than significant with the implementation of applicable regulations, including
new and revised General Plan Update policies and implementing actions. No mitigation is necessary
Potential Effect
Impact UTIL-2 Sufficient water supplies would be available to serve the proposed project and
reasonably foreseeable future development during normal, dry, and multiple dry
years (Draft Program EIR, Page 3.15-30-35).
Findings: Less than significant impact (Draft Program EIR, 3.5-35). No mitigation required.
Facts in Support of Findings: The proposed project is expected to accommodate 40,068 new
residents, 14,312 new housing units, 42,297 new jobs, and 14,100,523 new square feet of
nonresidential building space at buildout. This increase in development would result in an increased
demand for potable water. The City of South San Francisco receives most of its water supply from Cal
Water, with a small area (the Westborough neighborhood) serviced by the WWD. A significant
impact would occur if water demand for development facilitated by the proposed project could not
be met by the providers’ existing entitlements and water supply resources.
The Westborough planning sub-area, which receives water from the WWD, is projected to see an
increase of 524 residential units and 105 jobs as a result of the proposed project. Based on
residential water demand factors provided by Cal Water in the absence of available data from WWD,
the additional residences are expected to result in an increase of water demand within the
Westborough planning sub-area of approximately to 23.8 MG per year. This increase in water
demand represents 4.9 percent of total projected available supply (482 MG per year) within the
WWD service area by 2040. WWD purchased only between 56 and 68 percent of its 482 MG per
year, thus sufficient water is available. Because the proposed project is planned growth and because
the WWDs UWMP and Water Shortage Contingency Plan consider future planned growth, sufficient
water supplies are expected to be available in single and multiple dry years with the implementation
of the Water Shortage Contingency Plan.
It is assumed that the remainder of the proposed project (13,788 residential units, 42,192 jobs)
would receive water supplies from the Cal Water South San Francisco District. This growth would
result in an increase of approximately 4,768 AFY water demand, which represents approximately 59
percent of total projected demand within the Cal Water South San Francisco District service area by
2040. Since Cal Water’s UWMP’s projected demand is based on general growth in its service area,
the projected water demand from the proposed project, under normal water years, is accounted for
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in the overall demand forecast. Because the project is planned growth and because Cal Water’s
UWMP and Water Shortage Contingency Plan consider future planned growth, sufficient water
supplies are expected to be available in single and multiple dry years with the implementation of the
Water Shortage Contingency Plan.
In addition, with SB X7-7 and the State and County water conservation ordinances in place, each
jurisdiction within the water service area is required to conserve its water use through establishing
water efficiency measures. As required by the General Plan Update, the City of South San Francisco
will continue to coordinate with regional water districts regarding water conservation efforts,
demand management measures promoted by the water districts, compliance with current CALGreen
measures and South San Francisco CAP measures promoting efficient indoor and outdoor water use.
These measures would serve to reduce water use and demand overall and especially during drought
years.
Larger development projects within the Planning Area would be subject to SB 610 and SB 221, which
require preparation of a WSA to confirm whether current and projected water supplies could
accommodate the development as proposed. Other development projects would be required to
obtain a will-serve letter from the water district.
Cal Water intends to adopt a Water Neutral Development Policy in the near future, requiring any
new residential, commercial, or industrial development within the South San Francisco District that
is expected to use 50 AFY or more in net new demand to offset its net increase in water demand.
Once adopted, future development consistent with the proposed project would be required to
comply with the proposed Development Offset Program, which would help ensure that overall
customer demand for water does not exceed available current or future supply under a range of
hydrologic conditions. However, until the Development Offset Program is finalized it is too
speculative to analyze.
Further, the General Plan Update includes policies and actions that would reduce water demand of
future buildout. Policies ES-5.3, ES-5.8, ES-5.9, and ES-7.2 require and encourage water usage
reduction strategies in landscaping design, including waterwise planting pallets, conservative
irrigation systems, alternative irrigation water sources, and green infrastructure. Policy ES-7.4 and
ES-8.1 encourage pervious surfaces and groundwater recharge. Policy ES-8.2 requires the
implementation of potable water demand reduction measures. Policy CP-3.2 requires regular
updates to the City’s building codes to improve the water efficiency of new construction and major
renovation. Policy CP-4.1 aims to establish an energy and water efficiency upgrade program for
existing buildings. Policy CP-8.3 requires the exploration of recycled water supply.
The CAP also includes actions that would reduce water demand from future buildout under the
proposed project. Implementation of Action BE-1.2 would update zoning and building codes to
require alterations or additions at least 50 percent the size of the original building to comply with
minimum CALGreen requirements. Actions WW-1.1 through WW-1.4 would reduce outdoor water
use through landscaping water requirements, alternative water sources, greywater systems, and
landscaping plant lists. Actions WW-2.1 and WW-2.2 would reduce indoor water use through indoor
water efficiency standards and the promotion of water conservation rebates. Action CL-1.1 and CL-
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1.2 would improve environmental efficiencies and performance of municipal buildings, facilities,
landscaping and parks through minimum LEEDTM certification or equivalent for new buildings and
benchmarking the environmental performance of municipal buildings and facilities, including water
use (Draft Program EIR, Page 3.15-30—35). The proposed project's impacts related to utilities and
service systems would be less than significant with the implementation of applicable regulations,
including new and revised General Plan Update policies and implementing actions. No mitigation is
necessary
Potential Effect
Impact UTIL-3 The wastewater treatment provider would have adequate capacity to serve the
proposed project in addition to the provider’s existing commitments (Draft
Program EIR, Page 3.15-35—38).
Findings: Less than significant impact (Draft Program EIR, Page 3.15-38). No mitigation required.
Facts in Support of Findings: The proposed project is expected to accommodate 40,068 new
residents, 14,312 new housing units, 42,297 new jobs, and 14,100,523 new square feet of
nonresidential building space at buildout. Additionally, the proposed project may result in other
private and public improvements throughout the City with the potential for environmental effects
related to wastewater treatment capacity. Development and growth in the City would increase
demand for wastewater treatment capacity. As the demand for wastewater treatment capacity
increases, there may be a need to increase wastewater conveyance and treatment facilities, the
construction of which could cause environmental impacts.
The General Plan Update includes policies and actions to ensure that wastewater treatment capacity
keeps pace with new development. Policies ES-8.3 and CP-3.2 encourage water consumption
reduction measures which would, in turn, reduce wastewater generation. Policy CP-4.3 encourages
greywater permitting to use for irrigation. Policy LU-8.10 ensures adequate infrastructure and
utilities for all future development. Policy CP-8.1 requires the continuous evaluation and, as
appropriate, system replacement at the wastewater treatment plant to reduce energy use. The CAP
includes Action 1.2, which explores options at the South San Francisco/San Bruno WQCP for
delivering non-potable, recycled water for reuse.
Based on the proposed project’s increase in population of 38,444 (outside the Westborough
neighborhood) and the South San Francisco/San Bruno WQCP average per capita flow rate over the
last 10 years of 79 gallons per day (gpd), an additional 3,037,076 gpd or 3.03 MGD of wastewater
would be produced. Based on the proposed project’s increase in population of 1,624 within the
Westborough neighborhood and using the average per capita flow rate of the South San
Francisco/San Bruno WQCP as a proxy for the North San Mateo County Sanitation District, an
additional 130,666 gpd or 0.13 MGD of wastewater would be produced.
In accordance with City requirements, new development that occurs pursuant to the proposed
project would be required to connect to the municipal sewer system. New development would be
subject to the latest adopted edition of the California Plumbing Code and CALGreen Code including
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the provisions for water-efficient fixtures and toilets, which would reduce the amount of effluent
entering the wastewater system.
The two wastewater treatment plants serving the City of South San Francisco have a combined
capacity to treat up to 23.3 MGD and currently have additional dry weather capacity of
approximately 14.6 MGD. The 3.13 MGD of wastewater generated by new development under the
proposed project would represent 23.3 percent of total treatment capacity of the wastewater
treatment plants. As shown in Table 3.15-11 of the Draft Program EIR, both wastewater treatment
plants have capacity to handle the proposed project’s increase in wastewater.
Both the City of South San Francisco and the WWD maintain SSMPs as required under the Statewide
General Waste Discharge Requirements for Sanitary Sewer Systems. The management plans are
audited bi-annually and updated every 5 years. These updates allow for the consideration of
development and redevelopment such as would occur under the proposed project. As such, the
potential for increased wastewater generation and its need for transmission has been and will
continue to be planned for by both the City of South San Francisco and the WWD. The City’s Sewer
Capacity Charge reduces impacts caused by future development and redevelopment in the City by
financing the replacement and renewal of existing sanitary sewer facilities and the upgrade and
construction of new sanitary sewer facilities. Furthermore, the Storm Water Management Plans
(SWMPs) include consideration of future growth in the City such as that of the proposed project.
Finally, the City’s Capital Improvement Plan includes projects covering both the wastewater system
and the WQCP (Draft Program EIR, Page 3.15-35-38).
The proposed project's impacts related to utilities and service systems would be less than significant
with the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact UTIL-4 The proposed project would not generate solid waste in excess of State or local
standards, or in excess of the capacity of local infrastructure, or otherwise impair
the attainment of solid waste reduction goals. In addition, the proposed project
would comply with federal, State, and local statutes and regulations related to
solid waste (Draft Program EIR, 3.15-38-40).
Findings: Less than significant impact (Draft Program EIR, Page 3.15-40). No mitigation required.
Facts in Support of Findings: Development under the proposed project would result in additional
residential and nonresidential development throughout the Planning Area with the potential for
environmental effects related to the generation of solid waste. Development and growth in the City
would increase the generation of solid waste (both temporary construction and permanent
operation waste) which could exceed State or local standards, exceed local infrastructure capacity, or
otherwise impair the attainment of solid waste reduction goals.
The General Plan Update includes policies and actions to reduce and divert solid waste. Policy CP-5.4
requires 75 percent waste diversion for municipal construction and demolition projects. Policy CP-
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6.1 requires maintenance and regular updates of the City’s waste reduction plans and programs to
ensure consistency with California’s waste reduction goals. Policy CP-6.2 develops education and
technical assistance programs to help all residents and businesses to compost and recycle.
The CAP also includes actions to reduce and divert solid waste. Implementation of Action SW-1.1
would adopt an AB 1383 compliant zero-waste plan for municipal operations and the community.
Implementation of Action SW-1.2 entails the City continuing to work with SSF Scavenger to ensure
implementation of waste reduction targets. Implementation of Action SW-1.3 establishes
compliance pathways and enforcement mechanisms for mandatory organics and food waste
diversion. Action SW-1.4 would develop educational and technical assistance programs to help all
residents and businesses to compost and recycle. Implementation of Action CL 1.4 requires
municipal construction projects to achieve 75 percent waste diversion from the landfill.
Development that occurs pursuant to the proposed project would be required by the City to be
served with solid waste, recycling, and green waste services provided by the City’s franchise hauler
(Municipal Code Chapter 8.16). Additionally, construction and demolition debris from new
development would be required to be recycled (Municipal Code Chapter 15.60). Statewide
ordinances, including AB 341, AB 939, SB 1016, and SB 1383 require waste reduction, recycling, and
diversion and would also be applicable to development occurring pursuant to the proposed
project.11
Construction waste would be temporary and would be required to be diverted from landfills in
accordance with Municipal Code Chapter 15.60. Operationally, development under the proposed
project would be estimated to generate approximately 59,014.2 tons or 42,153.0 cubic yards of solid
waste at full buildout. For the solid waste that would be landfilled, the four landfills shown in Table
3.15-11 have a combined remaining capacity of 43.43 million cubic yards. The solid waste generated
by the proposed project would represent approximately 0.09 percent of the remaining capacity of
the servicing landfills. This capacity would be more than sufficient to accommodate the solid waste
generated by implementation of the General Plan Update. Furthermore, as previously discussed, all
future development projects proposed in the City would be consistent with federal, State, and local
statutes and regulations related to solid waste, including the California Health and Safety Code,
California Code of Regulations, California Public Resources Code, and City of South San Francisco
General Plan and Municipal Code (Draft Program EIR, 3.15-38—40). The proposed project's impacts
related to utilities and service systems would be less than significant with the implementation of
applicable regulations, including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary.
Cumulative Effects
The proposed project’s cumulative impacts related to utilities and service systems would be less than
significant (Draft Program EIR, Page 3.15-40-42).
11 City of South San Francisco. 2022. Ordinances and Laws. Website: https://www.ssf.net/departments/public-works/solid-
wasterecycling/ordinances-laws. Accessed April 12, 2022
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Findings: Less than significant impact (Draft Program EIR, Page 3.15-42). No mitigation required.
Facts in Support of Findings:
Water Supply
The geographic context for the analysis of cumulative impacts related to water supply includes the
Cal Water South San Francisco District and WWD service areas. Overall, as described in detail above,
cumulative water demands would neither exceed planned levels of supply nor require building new
water treatment facilities or expanding existing facilities beyond what is currently planned under
normal hydrologic years. Under single dry and multiple dry years, water supply availability is
uncertain. However, each individual project would be required to demonstrate the availability of
water to service the development. Cumulative projects would be required to demonstrate
compliance with the statutory requirements listed in the regulatory section, and the General Plan
Update would ensure that cumulative development in the City will continue to comply with the State
and federal regulatory requirements. As discussed under Impact UTIL-2, if the water service
providers should experience a shortage of supply during a drought, water use reduction plans and
Water Shortage Contingency Plans are in place to reduce water consumption. These measures would
be implemented in conjunction with other State, County, and local water conservation requirements
and water efficiency measures. All cumulative projects would be subject to local, State, and federal
permit requirements and would be required to comply with City/County ordinances and General
Plan policies, as well as other regulations that address water supply. For these reasons, cumulative
impacts are less than significant. The proposed project’s contribution to less than significant
cumulative impacts would not be cumulatively considerable. Development facilitated by the General
Plan would contribute to an increased cumulative demand for water supply, however, the growth
within the water purveyor’s service areas has been considered in their UWMPs. Additionally,
development consistent with the proposed project would be required to follow multiple water
reduction policies outlined in the General Plan Update, CAP, and Municipal Code.
Required compliance with federal, State, and local policies that would reduce water supply impacts
of development facilitated by the proposed project to less than significant levels. When applicable,
any additional new development within the Planning Area would be subject, on a project-by-project
basis, to independent CEQA review as well as policies in the General Plan, the Municipal Code, and
compliance with current regulations, including and SB 610 and SB 221, which require WSAs for large
development projects prior to approval. Accordingly, development consistent with the proposed
project would have a less than significant contribution to cumulative impacts.
For these reasons, development consistent with the proposed project in conjunction with other
cumulative projects would not be cumulatively considerable and the proposed project’s incremental
contribution would be less than significant. Additionally, compliance with Cal Water’s anticipated
future Water Neutral Development Policy, where new developers would pay a Development Offset
Fee to offset their water demand with efficiency improvements elsewhere in the system, would
further ensure that the proposed project’s incremental contribution to less than significant
cumulative impacts would not be cumulatively considerable.
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Wastewater
The geographic context for the analysis of cumulative impacts related to wastewater conveyance and
treatment includes the Cal Water South San Francisco District and WWD service wastewater services
areas. All cumulative projects would be required to comply with City/County ordinances and General
Plan policies, as well as other regulations related to wastewater collection and treatment. As
described under Impact UTIL-3, sufficient wastewater conveyance and treatment capacity is
available to serve the proposed project.
Additionally, the proposed project’s contribution to less than significant cumulative impacts would
not be cumulatively considerable. While development facilitated by the proposed project would
result in an increased demand for wastewater collection and treatment, such wastewater collection
and treatment can be accommodated (see Impact UTIL-3). In addition, future projects within the
Planning Area would be required to comply with requirements of the General Plan and Municipal
Code that aim to reduce wastewater generation flows. Thus, impacts of the proposed project related
to wastewater conveyance and treatment in conjunction with other cumulative development is not
cumulatively considerable.
Solid Waste
The geographic context for the analysis of cumulative impacts related to solid waste includes the
jurisdictions that are served by the Corinda Los Trancos and Newby Island Landfills. Cumulative
development within other jurisdictions would contribute to an incremental increase in solid waste
delivered to these landfills and other landfills in the region. Other future projects within the
cumulative geographic context, would be required to comply with federal, State, and local laws and
policies to address potential impacts related to solid waste.
Additionally, the proposed project’s contribution to less than significant cumulative impacts would
not be cumulatively considerable. While development and growth in the City under the proposed
project would result in an increased generation of solid waste, the affected landfills and other
regional landfills have enough capacity to serve the City (see Impact UTIL-4). In addition,
development facilitated by the proposed project would be required to comply with policies and
programs of the General Plan and the regulations of the Municipal Code that aim to divert solid
waste from the local landfill. The City would also be required to comply with existing and new
federal, State, and local statutes and regulations related to solid waste (See UTIL-4). Therefore, as
discussed, development consistent with the General Plan would have a less than significant
contribution to cumulative impacts.
Storm Drainage
The geographic context for analysis of cumulative impacts to storm drain facilities includes the lands
surrounding the Planning Area. Cumulative development contributes to an incremental increase in
impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities
requiring relocated or new facilities. All cumulative projects would be required to comply with
City/County ordinances and General Plan policies, as well as other regulations that minimize
stormwater runoff, such as the CWA.
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As discussed under Impact UTIL-1, the proposed project’s contribution to less than significant
cumulative impacts would not be cumulatively considerable. The General Plan Update contains
policies and programs to reduce stormwater runoff. Likewise, the sections of the Municipal Code
that protect water quality also minimize stormwater runoff, such as Chapter 11.17 and 11.18. All
future development under the proposed project would also be required to comply with the CWA and
regulations enforced by the RWQCB, which reduce stormwater runoff. Therefore, as discussed,
development consistent with the General Plan would have a less than significant contribution to
cumulative impacts (Draft Program EIR, Page 3.15-40-42). The proposed project's cumulative impacts
related to utilities and service systems would be less than significant with the implementation of
applicable regulations, including new and revised General Plan Update policies and implementing
actions. No mitigation is necessary
1.5.16 - Wildfire
Potential Effect
Impact WILD-1 The proposed project would not expose people or structures, either directly or
indirectly to a significant risk of loss, injury or death involving wildland fires (Draft
Program EIR, Page 3.16-11-15).
Findings: Less than significant impact (Draft Program EIR, Page 3.16-15). No mitigation required.
Facts in Support of Findings: The Planning Area is not located in an FHSZ in an SRA or a VHFHSZ in a
local, State, or federal responsibility area and the proposed project does not approve, propose, or
authorize development in an SRA or FHSZ. Sign Hill Park is susceptible to wildfires and the Planning
Area is adjacent to land identified as Moderate FHSZ within an SRA and High FHSZ within an SRA
(San Bruno Mountain State Park). For properties that adjoin hillsides, and/or other non-developed
open space fire-prone areas, new construction or rehabilitated landscapes require the submittal of a
Standard Landscape Plan in accordance with Section 20.300.007 (Landscaping) (revised) of the South
San Francisco Zoning Ordinance. The Standard Landscape Plan is required to include a landscape
design plan in accordance with Section 492.6 of the Model Water Efficient Landscape Ordinance
(MWELO). In particular, a landscape design plan for projects in fire-prone areas shall address fire
safety and prevention, include a defensible space or zone around a building or structure per Public
Resources Code Section 4291(a) and (b), and avoid fire-prone plant materials and highly flammable
mulches.
New development or improvements under the proposed project in areas adjacent to San Bruno
Mountain State Park or Sign Hill Park could expose people or structures to wildfire spread. However,
land use designations in the vicinity of San Bruno Mountain State Park and Sign Hill Park are not
being modified under the proposed project. As a result, the degree of exposure of people or
structures, either directly or indirectly, to a risk of loss, injury, or death involving wildland fires would
not substantially change with adoption of the proposed project, and current hazards would not be
significantly increased.
The City of South San Francisco, San Mateo County, and SSFFD have plans, policies, actions, and
ordinances in place to reduce the risks associated with wildland fires and future discretionary
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projects facilitated by the proposed project will be evaluated for project-specific impacts at the time
they are proposed.
The San Mateo–Santa Cruz County CWPP identifies recommendations aimed at preventing and
reducing both infrastructure and ecosystem damage associated with wildland fires. The City of South
San Francisco is located within the San Mateo Bayside Planning Area and adjacent to the San Mateo
Interior Planning Area of the CWPP. General recommendations, listed on page 3.16-13 of the Draft
Program EIR, have been identified for the San Mateo Bayside Planning Area, which would assist in
reducing wildfire risk within the City of South San Francisco. Additionally, the San Mateo County
LHMP provides recommendations, listed on page 3.16-13, to assist the County in reducing wildfire
risk, which in turn can assist in reducing wildfire risk within the City of South San Francisco.
The San Mateo County EOP establishes policies and procedures and assigns responsibilities to ensure
the effective management of emergency operations within the San Mateo County Operational Area,
which includes the Planning Area. During an emergency or disaster, such as a wildfire, the San Mateo
County EOP will accomplish actions listed on page 3.16-12 of the Draft Program EIR.
The SSFFD, Division of Fire Prevention, reviews architectural and development plans for compliance
with Chapter 15.24 of the Municipal Code’s fire protection and emergency access requirements.
SSFFD will also review plans to ensure that fire sprinklers, fire alarms, and fire extinguishers are up to
current code and appropriately located within proposed buildings or structures. Buildings and
structures located adjacent to fire hazard areas (San Bruno Mountain State Park and Sign Hill Park),
would be required to maintain the required hazardous vegetation and fuel management as well as
defensible space as outlined in Government Code Sections 51175-51189 and local standards of the
City of South San Francisco. The City enforces these standards through code enforcement.12
The General Plan Update contains policies and actions that reduce risks from wildland fires before
development occurs. Specifically, Policy SA-32.8 requires the City to limit the amount of
development allowed on the north side of Sign Hill (discretionary at one unit per acre maximum) and
not permit excessive grading of this portion of the hill or clustering of development in the future.
Policy CR-5.1 requires the City to continue to implement Sign Hill wildfire mitigation measures (i.e.,
restoration and maintenance of native grass and scrubland habitat, removal of non-native trees and
trees killed in October 2020 fire, removal of dead trees due to drought and disease and maintenance
of existing trails to function as fire breaks). Policy CR-5.2 requires the City to maintain a
comprehensive fire hazard management program to reduce fire hazards on other public lands. Policy
CR-1.2 requires the City to participate in regional hazard planning initiatives. Action CR-1.3.3 requires
the City to enact an ordinance to require real estate disclosures of all hazards identified in the
Hazard Mitigation Plan, including hazards associated with wildfire for commercial and residential
properties, including ownership and rental. Policy CR-1.4 requires the City to periodically adjust
infrastructure design standards to address asset-specific vulnerabilities associated with the hazards,
such as wildfire. Policy CR-1.5 requires that capital projects in high hazard areas adhere to risk
assessment guidance and identify appropriate resilience strategies.
12 City of South San Francisco. 2022. Submit a Request. Website: https://www.ssf.net/departments/public-works/submit-a-request.
Accessed May 26, 2022.
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Implementation of the Climate Action Plan would also indirectly reduce wildfire risks. In particular,
implementation of Action CS-3.1 which would enhance Colma Creek as an ecological corridor and
expand existing marsh and wetland habitat, would assist in providing a fuel break in the event of a
wildland fire. Implementation of Action WW-1.4, which would develop a landscaping plant list for
efficiency and habitat/wildlife for new development and landscape retrofits, could include plants
that are more resistant to wildland fires.
As the City would review development applications for subsequent development under the
proposed project for compliance with the policies and actions of the General Plan Update to reduce
the exposure of people or structures, either directly or indirectly, to a risk of loss, injury, or death
involving wildland fires. In addition, the City’s Municipal Code, which implements the City’s General
Plan, would be reviewed when development applications are received, including Chapter 15.08,
California Building Code; Chapter 15.18, Dangerous Buildings Code; and Chapter 15.24, California
Fire Code.
The proposed project's impacts related to wildfire would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Potential Effect
Impact WILD-2 The proposed project would not substantially impair an adopted emergency
response plan or emergency evacuation plan (Draft Program EIR, Page 3.16-16-17).
Findings: Less than significant impact (Draft Program EIR, Page 3.16-17). No mitigation required.
Facts in Support of Findings: As described in HYD-1, the Planning Area is not located in an FHSZ in an
SRA or a VHFHSZ in a local, State, or federal responsibility area and does not include plans for
development in these areas. The Planning Area is adjacent to land identified as Moderate FHSZ
within an SRA and High FHSZ within an SRA (San Bruno Mountain State Park), and Sign Hill Park is
susceptible to wildfires as evidenced by a fire that occurred in 2020. Development under the
proposed project would result in additional residential and nonresidential development throughout
the Planning Area, some of which could occur in areas adjacent to San Bruno Mountain State Park or
Sign Hill Park. Additionally, the proposed project may result in other private and public
improvements throughout the City that have the potential for environmental effects related to
wildfire should they be constructed near Sign Hill Park or San Bruno Mountain State Park. Therefore,
subsequent development under the proposed project could affect adopted emergency response
plans or emergency evacuation plans.
However, because South San Francisco is a fully built city, most of the development under the
proposed project would occur as redevelopment within the urbanized areas of the City, outside of an
SRA, thus proposed project would not materially overburden any designated evacuation routes nor
substantially impair any emergency response plans or emergency evacuation plans.
Development proposed within the northern portions of the Sunshine Gardens, Sign Hill, Paradise
Valley/Terrabay, and East of 101 sub-areas could be within 100 feet of land designated as Moderate
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FHSZ within an SRA or High FHSZ within an SRA. Development authorized by the proposed project,
including potential development closest to the SRA (within 100 feet) would not impair an adopted
emergency response plan or emergency evacuation plan because policies and actions contained with
the General Plan Update establish requirements for preventive measures and practices to minimize
wildland fire hazards and maintain adequate evacuation and access routes for vehicles in the event
of an emergency, including wildland fires. Policy CR-1.6 requires the City to strengthen emergency
management capacity and coordination with the San Mateo County EOC. Action CR-1.6.5 requires
the City to maintain and communicate evacuation route plans for businesses and residents. Policy
CR-1.7 requires the City to expand the reach of the CERT program to strengthen community
cohesion and emergency preparedness through community engagement efforts. Policy CR-5.1
requires the City to implement Sign Hill wildfire mitigation measures and Policy CR-5.2 requires the
City to maintain a comprehensive fire hazard management program to reduce fire hazards on other
public lands. Lastly, Policy CR-5.3 requires the City to increase community participation and
understanding of evacuation and early warning software programs to minimize threat to life and be
better prepared in case of a wildfire event.
Evacuation routes in the City are designed to accommodate development at buildout of the
proposed project. In addition, the policies and actions in the General Plan Update are designed to
facilitate and support the City’s emergency response and do not have any direct or indirect impact
on the environment.
All development in the City will be required to demonstrate compliance with applicable codes and
regulations. Development under the proposed project would require continued implementation of
the San Mateo County LHMP and San Mateo County EOP. Further, the California Fire Code
establishes requirements for emergency access for fire apparatus. Chapter 15.24 of the Municipal
Code requires development to demonstrate compliance with applicable fire safety measures prior to
the issuance of building permits. Ongoing compliance with safety measures are enforceable through
the City’s code enforcement. As such, new development projects that occur pursuant to the
proposed project would be assessed for compliance with applicable Fire Code requirements that
pertain to emergency access as well as compliance with proposed policies and actions of the General
Plan Update which would further enhance emergency response. By involving the Police and Fire
Departments in the development review process, the City ensures adequate emergency vehicle
access and ensures that development is designed and operated in a manner that minimizes fire
hazards and maximizes the potential for responsive emergency services (Draft Program EIR, Page
3.16-16 – 17). The proposed project's impacts related to wildfire would be less than significant with
the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact WILD-3 The proposed project would not, due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project occupants to, pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire (Draft
Program EIR, Page 3.16-18-19).
Findings: Less than significant impact (Draft Program EIR, 3.16-19). No mitigation required.
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Facts in Support of Findings: There are no SRAs or Fire Hazard Severity Zones within the Planning
Area (Exhibit 3.16-1). However, Sign Hill Park is susceptible to wildfires and the Planning Area is
adjacent to land identified as Moderate FHSZ within an SRA and High FHSZ within an SRA (San Bruno
Mountain State Park).
As described under Impact WILD-1, new development or improvements under the proposed project
in areas adjacent to San Bruno Mountain State Park or Sign Hill Park could expose people or
structures to wildfire spread. However, land use designations in the vicinity of San Bruno Mountain
State Park and Sign Hill Park are not being modified under the proposed project (Exhibit 2-5).
Therefore, the degree of wildland fire hazard would not substantially change with adoption of the
proposed project, and current hazards would not significantly increase.
New development would primarily occur on parcels that already contain some existing homes or
businesses, the majority which would occur over 0.25 mile from San Bruno Mountain State Park or
Sign Hill Park and within the low-lying portions of the Planning Area adjacent to San Francisco Bay,
which are less susceptible to wildland fires. If a fire were to occur in the more flat and urbanized
areas of the City, the risk of the fire spreading rapidly would be less than in areas with steeper
slopes. Nevertheless, smoke from wildfires occurring in remote parts of the State have at times
resulted in poor air quality throughout the bay area.
Development under the proposed project would be consistent with the City of South San Francisco,
San Mateo County, and SSFFD plans, policies, actions, and ordinances in place to reduce the risks
associated with wildland fires. As described under Impacts WILD-1 and WILD-2, these existing plans,
policies, actions, and ordinances reduce the potential for exposure to wildland fires. Reducing
potential for fires to start and mitigating wildfire spread once started reduces exposure to smoke and
air pollution. Safely evacuating people affected by wildfires also reduces exposure. Policy CR-6.4,
which requires the City to maintain adequate cooling and warming centers that can be used as
refuge during excessive heat and cold days, would also provide relief from the potential effects of
wildfires on air quality, thus reducing the exposure of residents to pollutants (Draft Program EIR,
Page 3.16-18-19). The proposed project's impacts related to wildfire would be less than significant
with the implementation of applicable regulations, including new and revised General Plan Update
policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact WILD-4 The proposed project would not require the installation or maintenance of
associated infrastructure (such as roads, fuel breaks, emergency water sources,
power lines or other utilities) that may exacerbate fire risk or that may result in
temporary or ongoing impacts to the environment (Draft Program EIR, Page 3.16-
19-20).
Findings: Less than significant impact (Draft Program EIR, Page 3.16-20). No mitigation required.
Facts in Support of Findings: There are no SRAs or Fire Hazard Severity Zones within the Planning
Area, thus no development under the proposed project would be located within an FHSZ. The
majority of development under the proposed project, including other private and public
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improvements throughout the City (see Chapter 2, Project Description, Section 2.5.2), would occur in
urban and developed areas that contain required defensible space, existing roadways, fuel breaks,
water sources, power lines, and other utilities. The Fire Department will review the installation and
maintenance of fire department access roadways, access walkways to and around buildings, and
hydrant quantity and placement as required by the CFC and CBC. As discussed under Impacts WILD-1
and WILD-2, compliance with the CBC and General Plan Update policies and actions, as well as
review of all new structures as well as private and public improvements by the Police and Fire
Departments, would ensure that fire risks are not exacerbated.
As discussed in Impact UTIL-1, development consistent with the proposed project would not require
or result in the relocation or construction of new or expanded utilities and service systems, the
construction or relocation of which could cause significant environmental effects. Most development
under the proposed project is expected to occur in urbanized and developed areas where existing
infrastructure are already in place. The proposed project would retain the existing roadway patterns
and does not propose any new roadways. The City will review development applications for
development, and private and public improvements, for compliance with the fire protection
measures identified in the General Plan Update, California Fire Code, and the California Public
Resources Code (Draft Program EIR, Page 3.16-19-20). The proposed project's impacts related to
wildfire would be less than significant with the implementation of applicable regulations, including
new and revised General Plan Update policies and implementing actions. No mitigation is necessary.
Potential Effect
Impact WILD-5 The proposed project would not expose people or structures to significant risks,
including downslope or downstream flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage changes (Draft Program EIR, Page 3.16-20-
21).
Findings: Less than significant impact (Draft Program EIR, Page 3.16-21). No mitigation required.
Facts in Support of Findings: As discussed above, there are no SRAs or FHSZs within the Planning
Area. Sign Hill Park and San Bruno Mountain State Park contain sloping hillsides that are susceptible
to landslides and flooding after fire has removed protective vegetative cover. These secondary
hazards associated with wildfires are described in the San Mateo County LHMP.
As described under Impact WILD-1, new development or improvements under the proposed project
in areas adjacent to San Bruno Mountain State Park or Sign Hill Park could expose people or
structures to wildfire spread. However, land use designations in the vicinity of San Bruno Mountain
State Park and Sign Hill Park are not being modified under the proposed project. Therefore, the
degree of wildland fire hazard, including secondary hazards associated with wildfires, would not
substantially change with adoption of the proposed project, and current hazards would not
significantly increase.
As described in WILD-3 the majority of development under the proposed project would occur on
parcels that already contain some existing homes or businesses over 0.25 mile from San Bruno
Mountain State Park or Sign Hill Park and within the low-lying portions of the Planning Area (5 to 20
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feet above sea level) adjacent to San Francisco Bay. If a fire were to occur in the flatter areas of the
City, the risk of flooding or landslides afterward would be negligible because of the nearly flat
topography and because little soil would be exposed due to the developed conditions. Development
under the proposed project would be subject to the rules and regulations of the South San Francisco
Municipal Code and the policies and actions in the General Plan Update regarding development on
unstable geologic soils and controlling stormwater runoff during and after construction. Specific
policies related to the prevention of flooding, landslides, and drainage changes include Policy CR-4.3,
which discourages development on steep hillside areas more than 30 percent grade; Policy ES-3.3,
which requires no net new impervious surfaces in the areas surrounding Colma Creek; Policy ES-7.3,
which requires stormwater management practices for new and redevelopment projects; and Policy
ES-7.4, which encourages pervious surfaces in new developments. The San Mateo–Santa Cruz
County CWPP and San Mateo County LHMP would continue to be implemented and architectural
and development plans would be reviewed by the SSFFD (Draft Program EIR, Page 3.16-20-21).
The proposed project's impacts related to wildfire would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
Cumulative Impacts
The proposed project’s cumulative impacts related to wildfire would be less than significant (Draft
Program EIR, Page 3.16-21-22).
Findings: Less than significant impact (Draft Program EIR, Page 3.16-22). No mitigation required.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for wildfire is
the South San Francisco Planning Area as well as the surrounding cities of Brisbane, Daly City,
Pacifica, San Bruno, and Millbrae.
The cities surrounding the Planning Area are largely urbanized, generally outside the SRA and
VHFHSZs, and include roads and other fuel breaks, emergency water sources, emergency utilities
and maintenance of other infrastructure that would reduce impacts from wildfires. All cumulative
projects, including the installation and/or maintenance of associated infrastructure, would be
subject to similar fire protection development standards and be required to comply with San Mateo
County ordinances, General Plan policies, and plan review by the local fire department to assist in
protecting life and property in the event of a wildfire. Development projects, including the
installation and maintenance of associated infrastructure, within a hazardous fire area must be
reviewed by the County Fire Warden to ensure that building materials, access, vegetative clearance
from structures, fire flows and water supplies are adequate for fire protection purposes and in
conformance to the fire policies of the San Mateo County General Plan. Additionally, development
projects, including the installation and maintenance of associated infrastructure, would be required
to comply with all policies in the California Fire Code, including the requirements for WUI fire areas.
All cumulative projects, including the installation and maintenance of associated infrastructure,
would be covered under existing emergency response plans by San Mateo County. Lastly,
implementation of the San Mateo–Santa Cruz County CWPP and the San Mateo County LHMP
throughout the Planning Area and adjacent areas would reduce cumulative impacts related to
wildfire.
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The proposed project’s incremental contribution to the less than significant cumulative wildfire
hazard impacts would not be significant. As previously discussed, because South San Francisco is a
fully built City, new development would primarily occur on parcels that already contain some
development, with the majority of potential growth occurring over 0.25 mile from San Bruno
Mountain State Park or Sign Hill Park and within the low-lying portions of the Planning Area (5 to 20
feet above sea level) adjacent to San Francisco Bay, which are less susceptible to wildland fires.
Development could result in an incremental increase in exposure of people and structures to
wildland fires and associated hazards, such as development near Sign Hill Park or San Bruno
Mountain State Park. However, land use designations in the vicinity of San Bruno Mountain State
Park and Sign Hill Park are not being modified under the proposed project. The adoption of the
proposed project would not exacerbate any existing wildfire hazards because the degree of wildland
fire hazard, including secondary hazards, would not substantially change.
Additionally, new development within the Planning Area would be required to comply with the fire
protection measures identified in the General Plan Update, California Fire Code, and the California
Public Resources Code. Action CR-1.3.1 directs the City to actively participate in the San Mateo
County Hazard Mitigation Plan maintenance protocols and Countywide initiatives. Policy CR-1.6
requires the City to strengthen emergency management capacity and coordination with the San
Mateo County EOP. The proposed project’s contribution to cumulative impacts would not be
cumulatively considerable (Draft Program EIR, Page 3.16-21-22).
The proposed project's cumulative impacts related to wildfire would be less than significant with the
implementation of applicable regulations, including new and revised General Plan Update policies
and implementing actions. No mitigation is necessary.
1.6 - Potential Environmental Effects Which Can Be Mitigated Below a Level
of Significance
The City of South San Francisco hereby finds that feasible mitigation measures have been identified
in the Draft Program EIR that will avoid or substantially lessen the following potentially significant
environmental impacts to a less than significant level. The potentially significant impacts, and the
mitigation measures that will reduce them to a less than significant level, are as follows:
1.6.1 - Air Quality
Potential Effect
Impact AIR-3 The proposed project would not expose sensitive receptors to substantial
pollutant concentrations (Draft Program EIR, Page 3.2-54-56).
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.2-56.)
Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)).
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Mitigation Measures
MM AIR-1b Projects that may result in additional toxic air contaminants (TACs) that are located
within 1,000 feet of a sensitive receptor(s) or would place sensitive receptors within
1,000 feet of uses generating TACs, such as roadways with volumes of 10,000
average annual daily trips or greater, shall implement Bay Area Air Quality
Management District (BAAQMD) Guidelines and California Office of Environmental
Health Hazard Assessment (OEHHA) policies and procedures requiring a Health Risk
Assessment (HRA) for residential development and other sensitive receptors.
Screening area distances may be increased on a case-by-case basis if an unusually
large source or sources of hazardous emissions are proposed or currently exist.
Based on the results of the HRA, identify and implement measures (such as air
filtration systems) to reduce potential exposure to particulate matter, carbon
monoxide, diesel fumes, and other potential health hazards. Measures identified in
HRAs shall be included into the site development plan as a component of a
proposed project.
Facts in Support of Findings: Within the SFBAAB, localized risks are primarily associated with
exposure to TAC emissions. Common sources of TAC emissions are stationary sources, subject to
BAAQMD permit requirements, on-road motor vehicles on high-volume roads, and off-road sources
such as construction equipment and diesel-powered trains traveling on the Caltrain corridor.
Although the proposed project does not include specific plans for any new, large stationary sources
of emissions, it could result in new sensitive receptors (primarily residential receptors) near existing
sources of emissions.
Community Risk and Hazards–Plan Land Use Diagram Special Overlay Zones
The proposed project consists of a General Plan Update, Climate Action Plan Update, and Zoning
Code Amendment and would not directly result in construction of any development project. Project-
specific information for future individual land use development projects is unknown, thus potential
impacts to sensitive receptors resulting from construction-generated TACs cannot be determined. If
the proposed project’s land use diagram identifies special overlay zones around existing and planned
sources of TACs, including special overlay zones of at least 500 feet on each side of all freeways and
high-volume roadways (or another BAAQMD-approved modeled distance), and the plan identifies
goals, policies, and objectives to minimize potentially adverse impacts, then the community risk and
hazard impact would not be significant. This is consistent with BAAQMD’s CEQA Air Quality
Guidelines for analyzing plan-level impacts to sensitive receptors. Page 3.2-55 of the Draft Program
EIR lists sites for which the ARB Air Quality and Land Use Handbook recommends avoiding the siting
of new sensitive land uses.
The proposed project does not contain a land use diagram which identifies special overlay zones
around existing and planned sources of TACs. MM AIR-1b, detailed above, would be required to
ensure that future development facilitated by the proposed project would result in less than
significant impacts to sensitive receptors related to operational TACs.
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Community Risk and Hazards–Goals, Policies, and Objectives for Reducing Impacts
A proposed plan must also identify goals, policies, and objectives to minimize potential impacts and
create overlay zones around sources of TACs, PM2.5, and hazards to be considered to result in less
than significant impacts related to exposing sensitive receptors to substantial pollutant
concentrations. The General Plan Update contains several policies and actions that aim to reduce the
potential growth of vehicle use through encouraging the use of alternative modes of transportation,
monitoring and improving existing sources of TACs throughout the City and reducing overall health
impacts related to air quality in general.
General Plan Update policies and actions that target the use of alternative modes of transportation,
such as bicycling, walking, or using public transit, include Action LU-1.1.3, Policy LU-2.1, Action LU-
2.1.2, Policy LU-4.4, and Policy CR-6.5. General Plan Update policies and actions that require the City to
monitor and improve existing source of TACs include Policy PE-2.1, Action CHEJ-3.1.1, Action CHEJ-3.2,
Action CHEJ-3.2.1, Policy CHEJ-3.2.2, Policy CHEJ-3.3, and Action CHEJ-3.3.1. Lastly, General Plan
Update policies and actions that generally aim to reduce health impacts to residents in the City include
Policy SA-17.4, Policy SA-32.5, Policy CHEJ-3.1, Action CHEJ-3.3.2, Policy CHEJ-3.5, and Policy CHEJ-3.6.
The South San Francisco Zoning Ordinance, including the Zoning Code Amendments that are part of
the proposed project, include Section 20.300.010 (Performance Standards), which establishes
regulations related to air contaminants. Section 20.300.010 requires that sources of air pollution
comply with rules identified by the EPA (Code of Federal Regulations, Title 40), the ARB, and the
BAAQMD. The section further requires that operators of activities, processes, or uses that require
“approval to operate” from the BAAQMD, shall file a copy of the permit with the Planning Division
within 30 days of permit approval (Draft Program EIR, Page 3.2-54—56).
The City finds that MM AIR-1b is feasible, is adopted, and will further reduce impacts related to
operational TACs. Accordingly, the City finds that, pursuant to Public Resources Code Section
21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been
required in, or incorporated into, the proposed project that mitigate or avoid the potentially
significant impacts as identified in the EIR. Therefore, impacts associated with air quality would be
less than significant with mitigation incorporated.
1.6.2 - Biological Resources
Potential Effect
Impact BIO-1 The proposed project could have a substantial adverse effect, either directly or
through habitat modifications, on a species identified as a candidate, sensitive, or
special-status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or United States Fish and Wildlife
Service (Draft Program EIR, Page 3.3-18-22).
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.3-22.)
Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)).
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Mitigation Measures
MM BIO-1 Special-status Species, Migratory Birds, and Nesting Birds Special-status species are
those listed as Endangered, Threatened or Rare, or as Candidates for listing by the
United States Fish and Wildlife Service (USFWS) and/or California Department of
Fish and Wildlife (CDFW), or as Rare Plant Rank 1B or 2B species by the California
Native Plant Society (CNPS). This designation also includes CDFW Species of Special
Concern and Fully Protected Species. Applicants or sponsors of projects on sites
where potential special-status species, migratory birds, or nesting birds are present
shall retain a qualified Biologist to conduct a focused survey per applicable
regulatory agency protocols to determine whether such species occur on a given
project site. The project applicant or sponsor shall ensure that, if development of
occupied habitat must occur, species impacts shall be avoided or minimized, and if
required by a regulatory agency or the CEQA process, loss of wildlife habitat or
individual plants shall be fully compensated on the site. If off-site mitigation is
necessary, it shall occur within the South San Francisco Planning Area whenever
possible, with a priority given to existing habitat mitigation banks. Habitat mitigation
shall be accompanied by a long-term management plan and monitoring program
prepared by a qualified Biologist and include provisions for protection of mitigation
lands in perpetuity through the establishment of easements and adequate funding
for maintenance and monitoring.
Facts in Support of Findings: Forty-eight special-status plant species and 51 special-status animal
species were recorded to occur within 5 miles or less of the South San Francisco Planning Area. The
sensitive plant species are most likely to be found in the estuary habitats around San Francisco Bay.
San Bruno Mountain State Park contains critical habitat for Choris’ popcornflower. The special-status
wildlife species are most likely to be found in parks within the City or in the surrounding hillsides.
Shorebirds and aquatic species can be found along the eastern edge of the City, in the estuaries
surrounding San Francisco Bay. A few of these wildlife species, such as birds and bats, may find
suitable nesting habitat within buildings and other human-made structures. The species most
adapted to man-made habitats include the Alameda song sparrow, American peregrine falcon, and
Townsend’s big-eared bat. San Bruno Mountain State Park contains critical habitat for the Bay
checkerspot butterfly. Subsequent development under the proposed project could result in the
direct/indirect loss or indirect disturbance of special-status plant or animal species or their habitats
that are known to occur, or have potential to occur, in the region.
Significant impacts on special-status plant species associated with individual subsequent projects
could include the direct loss of individual plants and of habitat areas associated with these special-
status plant species. Indirect impacts to special-status plant species could include habitat
degradation as a result of impacts to water quantity and quality. Significant impacts could include,
but are not limited to, increased mortality caused by higher numbers of automobiles in new areas of
development; direct mortality from the collapse of underground burrows, resulting from soil
compaction; direct mortality resulting from the movement of equipment and vehicles through
construction areas; direct mortality resulting from removal of trees with active nests; direct
mortality or loss of suitable habitat resulting from the trimming or removal of obligate host plants;
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direct mortality resulting from the filling of wetlands features; loss of breeding and foraging habitat
resulting from the filling of seasonal or perennial wetlands; loss of breeding, foraging, and refuge
habitat resulting from the permanent removal of riparian vegetation; loss of suitable habitat for
vernal pool invertebrates resulting from the destruction or degradation of vernal pools or seasonal
wetlands; abandonment of eggs or young and subsequent nest failure for special-status nesting
birds, including raptors, and other non-special-status migratory birds resulting from construction-
related noises; loss or disturbance of rookeries and other colonial nests; loss of suitable foraging
habitat for special-status raptor species; loss of migration corridors resulting from the construction
of permanent structures or features; and impacts to fisheries/species associated with waterways.
The Endangered Species Act and CESA generally prohibit the taking of protected plant and animal
species or direct impacts to foraging or breeding habitat without a special permit. The General Plan
Update Policy ES-2.1 requires the City to protect and expand existing marsh and wetland habitat to
improve water quality, adapt to climate change, and provide habitat for wildlife. Policy ES-2.2
requires the City to maintain standards and guidelines for new construction within 150 feet of San
Francisco Bay that support the health of the Bay, such as the installation of bioswales to treat runoff
before it enters the Bay, use of low intensity lighting to reduce the amount of light reaching sensitive
habitat, and requiring an assessment as part of the CEQA process to consider wildlife impacts before
project approval to continue to protect special-status of species. Action ES-2.2.1 requires the City to
develop a bird-safe design ordinance to minimize the adverse effects on native and migratory birds
and require new development East of 101 to incorporate design measures. Policy ES-3.3 requires the
City to maintain development standards and guidelines for new construction within 80 feet of Colma
Creek, such as maintaining or increasing building setbacks to support habitat areas. Policy ES-6.1
requires the City to continue to catalog and update information on threatened and endangered
wildlife and plant species in the review of project proposals. Policy ES-6.2 requires wildlife and plant
assessments for new development in areas that could impact threatened or endangered species.
Policy ES-6.3 requires that permit applications for projects located within ecologically sensitive
habitat areas prepare site-specific biological assessments for review and approval by City Planning
staff, and incorporation of the recommended measures during construction to protect ecologically
sensitive habitat areas.
The South San Francisco Zoning Ordinance Chapter 20.170 (existing) creates a Special ES Overlay
District to protect areas of high biological value. Section 20.170.003 (Habitat and Biological Resource
Conservation Areas) (existing) requires a site-specific assessment of biological resources for all
development proposals in areas of the Special ES Overlay District that have been identified as
ecologically sensitive habitat (such as Sign Hill Park, San Bruno Mountain State Park, and the
saltmarshes along San Francisco Bay) as shown on a map or maps maintained by the City. Section
20.170.003 also requires that sensitive habitat areas be protected in the following order: (1)
avoidance; (2) on-site mitigation; (3) off-site mitigation; and (4) purchase of mitigation credits.
Future development under the proposed project would be required to comply with the various
federal and State laws and regulations and with requirements of the South San Francisco Zoning
Ordinance and the General Plan Update policies and actions related to biological resources. To
further enhance and ensure protection of threatened and endangered species, as well as nesting
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and migratory birds, MM BIO-1 requires that focused surveys be conducted. Implementation of
these requirements, policies, and actions will have both direct and indirect beneficial effects for
species by avoiding the most biologically sensitive areas, concentrating development in previously
disturbed areas, requiring surveys, and by emphasizing avoidance, minimization, and mitigation of
impacts to habitats (Draft Program EIR, Page 3.3-18-22).
The City finds that MM BIO-1 is feasible, is adopted, and will further reduce impacts related to
species and habitat. Accordingly, the City finds that, pursuant to Public Resources Code Section
21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been
required in, or incorporated into, the proposed project that mitigate or avoid the potentially
significant impacts as identified in the EIR. Therefore, impacts associated with biology would be less
than significant with mitigation incorporated.
Potential Effect
Impact BIO-3 The proposed project could have a substantial adverse effect on State or federally
protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological interruption, or other means (Draft
Program EIR, Page 3.3-23-25).
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.3-25.)
Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR. (State CEQA
Guideline§ 15091(a)(1).)
Mitigation Measures
MM BIO-3 Assess Potential Wetland Impacts
Applicants or sponsors of projects on sites where potential jurisdictional wetlands or
waterways are present shall retain a qualified Biologist/wetland regulatory specialist
to conduct a site investigation and assess whether wetland or waterway features are
jurisdictional with regard to the United States Army Corps of Engineers (USACE),
Regional Water Quality Control Board (RWQCB), and/or California Department of
Fish and Wildlife (CDFW). This investigation shall include assessing potential impacts
to wetlands and other waters of the United States and/or State. If a feature is found
to be jurisdictional or potentially jurisdictional, the project applicant or sponsor shall
comply with the appropriate permitting process with each agency claiming
jurisdiction prior to disturbance of the feature, and a qualified Biologist/wetland
regulatory specialist shall conduct a detailed wetland delineation if necessary.
Facts in Support of Findings: Estuarine and marine wetlands line the City’s coastline and parts of
Colma Creek and San Bruno Creek. A navigable slough is located south of Colma Creek in the
southeastern portion of the City. Subsequent development under the proposed project, primarily
adjacent to the San Francisco Bay, could result in direct or indirect effects on estuarine habitat and
other sensitive marine communities. Federally protected wetlands and other waters of the United
States and/or State could be affected through direct removal, filling, hydrological interruption
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(including dewatering), alteration of bed and bank, and other construction-related activities, which
could result in significant environmental impacts.
The General Plan Update Policy ES-2.1 requires the City to protect and expand existing marsh and
wetland habitat to improve water quality, adapt to climate change, and provide habitat for wildlife.
Policy ES-2.2 requires the City to maintain standards and guidelines for new construction within 150
feet of San Francisco Bay that support the health of the Bay, such as requiring no net new
impervious areas, maintaining (or increasing) building setbacks to support habitat areas, and
requiring the installation of bioswales to treat runoff before it enters the Bay. Policy ES-3.3 requires
the City to maintain development standards and guidelines for new construction within 80 feet of
Colma Creek, such as requiring no net new impervious areas, maintaining, or increasing building
setbacks to support habitat areas, and encouraging new construction to construct bioswales or
similar features to treat runoff before it enters the creek. Policy ES-7.1 requires the City to partner
with regional and local agencies to develop a comprehensive watershed management strategy that
identifies programs, partnerships, actions, and incentives that the City and partners can take to
protect the City’s water resources and aquatic areas.
The South San Francisco Zoning Ordinance Section 20.170.003 (Habitat and Biological Resource
Conservation Areas) (existing) requires a site-specific assessment of biological resources for all
development proposals in areas of the Special ES Overlay District that have been identified as
ecologically sensitive habitat, such as the saltmarshes along San Francisco Bay. Section 20.170.003
(existing) requires that approval of a development permit for a project on a site located within an
area identified as ecologically sensitive habitat shall not occur unless the applicable review body first
finds that there has been “no net loss” of wetlands and that disturbed wetlands have been replaced
with the same type of wetlands.
MM BIO-3 requires that a qualified Biologist/wetland regulatory specialist conduct a site
investigation and assessment. Future development under the proposed project would comply with
adopted State, federal, and local regulations for the protection of wetlands and waters of the United
States and/or State, including Section 404 and 401 of the Clean Water Act (CWA). In addition, future
projects would comply with requirements of the South San Francisco Zoning Ordinance and the
General Plan Update policies and actions related to the protection of these biological resources.
Lastly, future development would be required to implement MM BIO-3 (Draft Program EIR, Page 3.3-
23-26).
The City finds that MM BIO-3 is feasible, is adopted, and will further reduce impacts related to
wetlands and biological resources. Accordingly, the City finds that, pursuant to Public Resources
Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations
have been required in, or incorporated into, the proposed project that mitigate or avoid the
potentially significant impacts as identified in the EIR. Therefore, impacts associated with biology
would be less than significant with mitigation incorporated.
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Potential Effect
Impact BIO-4 The proposed project could interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native
resident or migratory wildlife corridors or impede the use of wildlife nursery sites.
(Draft Program EIR, Page 3.3-26—27).
Findings: Less than significant impact with mitigation incorporated.
Mitigation Measures
Implement MM BIO-1 and MM BIO-3.
Facts in Support of Findings: The San Francisco Bay provides essential natural resources for
migratory birds on the Pacific Flyway. Pockets of parks and open space within the City provide space
for wildlife and Colma Creek, San Bruno Creek, and Navigable Slough of San Bruno Creek provide
connections between these open areas. The City’s urban forest canopy can support the movement
of a variety of migratory bird species, while creeks and drainages typically serve as movement
corridors for wildlife.
Future development under the proposed project would comply with adopted State, federal, and
local regulations for the protection of biological resources. Future projects would also comply with
requirements of the South San Francisco Municipal Code and Zoning Ordinance and the General Plan
Update policies and actions related to biological resources. MM BIO-1, which requires that focused
surveys be conducted to determine whether special-status species, nesting birds, or migratory birds
occur on a given project site, and that potential impacts to special-status species be avoided and
minimized, would also protect wildlife movement corridors. MM BIO-3, which requires that a site
investigation and assessment be conducted for projects on sites where potential jurisdictional
wetlands or waterways are present, and compliance with the appropriate permitting process with
each agency claiming jurisdiction prior to disturbance of the feature, would also protect wildlife
movement corridors.
Many of the policies and actions already discussed above have both direct and indirect benefits of
protecting movement habitat for wildlife, including Policy ES-1.1, Policy ES-1.2, Policy ES-1.3, Policy
ES-1.4, Policy ES-2.1, Policy ES-3.1, and Action ES-2.2.1. Implementation of these policies and
actions, as well as MMs BIO-1 and BIO-3, therefore, would have both direct and indirect beneficial
effects for protecting regional wildlife linkages and facilitating wildlife movement.
The City finds that MM BIO-1 and MM BIO-3 are feasible, are adopted, and will further reduce
impacts related to wildlife linkages and movement. Accordingly, the City finds that, pursuant to
Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes
or alterations have been required in, or incorporated into, the proposed project that mitigate or
avoid the potentially significant impacts as identified in the EIR. Therefore, impacts associated with
biology would be less than significant with mitigation incorporated.
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1.6.3 - Geology, Soils, and Seismicity
Potential Effect
Impact GEO-6 The proposed project could directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature. (Draft Program EIR, Page 3.6-28-29.)
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.6-29.)
Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)).
Mitigation Measures
MM GEO-6 Applicants, owners, and/or sponsors of all future development or construction
projects shall be required to perform or provide paleontological monitoring for all
proposed excavations in the Colma Formation and Merced Formation, including
those buried in the shallow subsurface below Quaternary deposits, due to the high
paleontological sensitivity for significant resources in these areas. Should significant
paleontological resources (e.g., bones, teeth, well-preserved plant elements) be
unearthed by the future project construction crew, the project activities shall be
diverted at least 15 feet from the discovered paleontological resources until a
professional vertebrate Paleontologist has assessed such discovered resources and,
if deemed significant, such resources shall be salvaged in a timely manner. The
applicant/owner/sponsor of said project shall be responsible for diverting project
work and providing the assessment including retaining a professional vertebrate
Paleontologist for such purpose. Collected fossils shall be deposited by the
applicant/owner/sponsor in an appropriate repository (e.g., University of California
Museum of Paleontology (UCMP), California Academy of Sciences) where the
collection shall be properly curated and made available for future research.
Facts in Support of Findings: Any project involving earthmoving activity could potentially result in
inadvertent discovery and disturbance of paleontological resources during grading and excavation
work. The paleontological records search conducted for the proposed project indicates that the
potentially fossiliferous areas in the Planning Area are the Merced Formation and the Colma
Formation. As such, construction-related and earth-disturbing actions from development facilitated
by the proposed project within the Merced Formation and Colma Foundation have the potential to
damage or destroy fossils resulting in significant impacts on paleontological resources. With
implementation of Mitigation Measure (MM) GEO-6, detailed above, potential impacts to
paleontological resources would be reduced to less than significant.
The remaining portions of the Planning Area have a low paleontological sensitivity and low
paleontological potential. Nonetheless, in the unlikely event that any earth-disturbing construction-
related activities uncover significant paleontological resources, potential impacts to paleontological
resources would be minimized through compliance with federal and State laws that protect
paleontological resources. Section 5097 of the Public Resources Code specifies procedures to be
followed in the event of unexpected discovery of paleontological resources. Compliance with Section
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5097 of the Public Resources Code would minimize the potential to impact paleontological resources
directly and indirectly within the portions of the Planning Area that have a low paleontological
sensitivity and low paleontological potential, and impacts would be less than significant (Draft
Program EIR, Page 3.6-28-29).
The City finds that MM GEO-6 is feasible, is adopted, and will further reduce impacts related to
paleontological resources. Accordingly, the City finds that, pursuant to Public Resources Code Section
21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been
required in, or incorporated into, the proposed project that mitigate or avoid the potentially
significant impacts as identified in the EIR. Therefore, impacts associated with paleontological
resources would be less than significant with mitigation incorporated.
1.6.4 - Noise
Potential Effect
Impact NOI-1 The proposed project could generate a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards
established in the local general plan or noise ordinance, or applicable standards of
other agencies. (Draft Program EIR, Pages 3.11-24-32.)
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.11-
32.) Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)).
Mitigation Measures
MM NOI-1 Operational Noise Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor shall
implement the following measures to limit on-site operational stationary noise
source impacts:
Any proposed development projects that include parking areas, terminals, or loading
docks of commercial or industrial land uses within 300 feet of a residential receptor
shall demonstrate compliance with Policies NOI-1.1 and NOI-1.2 of the City’s Noise
Element by submitting a final acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to adequately minimize the
potential noise impacts of vehicles on the site to adjacent land uses. The report
must be approved by the Planning Division prior to issuance of building permits.
For any future development project that would include exterior mechanical systems
(such as mechanical ventilation systems) within 50 feet of a residential receptor, the
project applicant or sponsor shall submit a final acoustical report prepared to the
satisfaction of the Planning Division that demonstrates compliance of the project
with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element. Noise reduction
design features may include, but are not limited to, locating stationary noise sources
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on the site to be shielded by structures (buildings, enclosures, or sound walls) or by
using equipment that has a quieter rating. The report must be approved by the
Planning Division prior to issuance of building permits.
Facts in Support of Findings: The proposed project could result in new residential and nonresidential
uses within the Planning Area. Additionally, the proposed project may result in other private and
public improvements throughout the City that have the potential for environmental effects related
to noise. The General Plan Update includes policies that require preparation of acoustical studies for
residential development where the existing noise levels exceed an exterior noise level of 65 dBA
CNEL. Additionally, General Plan Update policies require that new office and commercial
development be designed to reduce interior noise levels. Individual development projects would be
required to demonstrate compliance with these standards during the design review process. The
applicable chapters of the Municipal Code and Zoning Ordinance, including the revised chapters of
the Zoning Ordinance that are part of the proposed project, reiterate compliance with the noise
performance thresholds identified in the Municipal Code.
Construction activity can temporarily increase noise, while traffic and stationary noise sources
related to future development projects can result in permanent noise increase. Potential temporary
and permanent noise increase impacts from construction and operation of the proposed project are
analyzed below.
Temporary Construction Noise Increases
A significant impact would occur if noise producing construction activities from the proposed project
exceed noise performance standards during certain hours depending on land use as permissible by
the City’s Municipal Code listed on page 3.11-25 of the Draft Program EIR. An exception to these
standards may only be granted if an application for construction-related exception is submitted and
considered by the City Manager or the manager’s designee in accordance with Section 8.32.060 of
the Municipal Code.
The proposed project does not include specific development proposals, thus exact noise levels,
locations, or time periods for construction of such projects cannot be determined. However, sites
adjacent to areas where future development/redevelopment is anticipated to occur could expose
people to construction noise throughout the construction period. Because construction is performed
in discrete steps with unique noise characteristics, noise levels vary as construction progresses.
However, similarities in the dominant noise sources and patterns of operation allow construction
noise ranges to be categorized by work phase. The site preparation phase, which includes excavation
and grading activities, generate the highest noise levels. Typical noise levels of construction
equipment as measured at a distance of 50 feet from the operating equipment are shown in Table
3.11-2 of the Draft Program EIR.
The City has not adopted numeric thresholds of significance for construction noise. However, the
City has adopted mandatory requirements in the South San Francisco Municipal Code and General
Plan Update that will ensure that construction noise associated with General Plan implementation
remains less than significant. Municipal Code Section 8.32.050, as previously mentioned, regulates
the time when construction activities may occur, and an exception may be granted to these hours
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only if an application for construction-related exception is made to and considered by the City
Manager or the City Manager’s designee. Section 8.32.050 of the Municipal Code is applied to all
construction permits and compliance is mandatory and is monitored by City grading and building
department personnel and is also monitored and addressed through reporting by members of the
public when construction hours are not being observed. Furthermore, Policy NOI-1.2 of the Noise
Element requires enforcement of the City’s Noise Ordinance noise performance standards. In
addition, the Actions of Policy NOI-1.2 include the requirement to restrict construction activities to
acceptable time periods and to consider constructing temporary sound walls surrounding
construction sites during construction. This ensures that construction noise will not occur to a level
beyond what is stipulated in the Municipal Code when residents are most vulnerable to noise
disturbance.
This analysis identifies the worst-case, loudest phase of construction and identifies the compliance
requirements that would reduce this worst-case impact to less than significant. Therefore, other
phases of construction that would produce lower noise levels would similarly be reduced to less than
significant with the same compliance requirements. Compliance with mandatory requirements of
the Municipal Code and General Plan Update will ensure that construction noise occurs only at
appropriate times of day and is minimized to acceptable levels.
Permanent Traffic Noise Increases
A significant impact would occur if traffic generated by the proposed project would result in a
substantial increase in ambient noise levels compared with existing conditions. The County does not
define “substantial increase.” For purpose of this analysis, a substantial increase is based on the
following criteria. A characteristic of noise is that audible increases in noise levels generally refer to a
change of 3 dBA or more, as this level has been found to be barely perceptible to the human ear in
outdoor environments. A change of 5 dBA is considered the minimum readily perceptible change to
the human ear in outdoor environments. Therefore, for purposes of this analysis, a significant impact
would occur if the proposed project would cause the CNEL to increase by any of the amounts listed
on page 3.11-27 of the Draft Program EIR.
As identified in Table 3.11-7 of the Draft Program EIR, noise environments with noise levels of up to
65 dBA CNEL are considered normally acceptable for residential land use developments, industrial
and commercial land use development, and for open land use areas and schools.
The FHWA highway traffic noise prediction model (FHWA-RD-77-108) was used to evaluate existing
and future traffic noise conditions with implementation of the proposed project along modeled
roadway segments in the vicinity of the Planning Area. Traffic modeling was performed using the
data provided by Fehr & Peers. The traffic noise modeling input and output files included in
Appendix G of the Draft Program EIR. Table 3.11-8 of the Draft Program EIR shows a summary of the
traffic noise levels for year 2040 projected traffic conditions without and with the proposed project,
as measured at 50 feet from the centerline of the outermost travel lane. Several of the modeled
roadway segments would experience a reduction in traffic noise levels with implementation of the
proposed project, compared to conditions that would exist without the proposed project, due to
lower anticipated average daily trips generated by the proposed land uses compared to the total
development that could occur under the existing General Plan. The highest increase that would
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occur along these modeled roadway segments would be a 1.7 dBA increase above conditions
without the proposed project and would occur along Grand Avenue from Linden Avenue to Airport
Boulevard. According to the significance impact criteria identified above, a 5 dBA increase would be
considered significant for these conditions.
Although this analysis evaluates buildout of the proposed project against baseline conditions, it is
important to note that the development contemplated by the proposed project is consistent with
development already allowed under the existing General Plan. Accordingly, it is reasonable to
assume that development consistent with the existing General Plan would potentially occur absent
the adoption of the General Plan Update. While development envisioned by the proposed project
would result in an incremental increase in development in the Planning Area, future development
would be required to comply with requirements of the General Plan Update and City of South San
Francisco Municipal Code protecting against noise impacts. Specifically, Policy 1-1 requires that all
new development within the City complies with the Land Use/Noise Compatibility guidelines, along
with associated Actions which require that projects must be assessed through the subdivision, site
plan, conditional use permit, and other development review processes, and that such projects must
incorporate conditions of approval and mitigation measures that ensure noise compatibility where
appropriate. In addition, Section 20.300.009 (Performance Standards) (revised) of the Zoning
Ordinance also establishes land use development requirements and limitations, as well as acoustic
design requirements for development in noise impacted areas.
Permanent Stationary Source Noise Increases
A significant impact would occur if operational noise levels generated by stationary noise sources at
development projects under the proposed project exceed noise performance standards listed on
page 3.11-30 of the Draft Program EIR. Future development projects under the proposed project
would include new stationary noise sources such as parking lot activities, and mechanical ventilation
system equipment. These would be potential point sources of noise that could affect noise-sensitive
receptors in the vicinity of the proposed project.
Parking Lot and Truck Loading/Unloading Activities
Typical parking lot activities generate noise levels ranging from approximately 60 dBA to 70 dBA Lmax
at 50 feet. Noise levels from typical rooftop unit mechanical ventilation equipment range from 50
dBA to 60 dBA Leq at a distance of 25 feet. Typical maximum noise levels from truck loading and
unloading activity are 70 dBA to 80 dBA Lmax as measured at 50 feet. These stationary source
operational noise levels could exceed the City’s noise performance thresholds if they were to occur
in areas adjacent to sensitive receptor land uses. With implementation of Mitigation Measure (MM)
NOI-1, detailed above, impacts generated by future development projects under the proposed
project would be reduced to less than significant.
Mechanical Equipment Operations
Noise levels from commercially available mechanical ventilation equipment range from 50 dBA to 60
dBA Leq at a distance of 25 feet. These stationary source operational noise levels could exceed the
City’s thresholds if they were to occur in areas adjacent to sensitive receptor land uses. With
implementation of MM NOI-1, detailed above, impacts generated by future development projects
under the proposed project would be reduced to less than significant (Draft Program EIR, Pages 3.11-
24-3.11-32).
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The City finds that MM NOI-1 is feasible, is adopted, and will further reduce impacts related to noise
impacts on sensitive receptors. Accordingly, the City finds that, pursuant to Public Resources Code
Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have
been required in, or incorporated into, the proposed project that mitigate or avoid the potentially
significant impacts as identified in the EIR. Therefore, impacts associated with noise would be less
than significant with mitigation incorporated.
Potential Effect
Impact NOI-3 The proposed project could expose people residing or working in the plan area to
excessive noise levels for a project located within the vicinity of a private airstrip
or an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport (Draft Program EIR, Pages 3.11-
34-35).
Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.11-
35.) Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)).
Mitigation Measures
MM NOI-3 Airport Noise Impact Reduction Plan
Prior to issuance of building permits, the project applicant or sponsor of proposed
development projects shall implement the following measures to limit airport
activity noise source impacts:
• Any proposed residential development project or any hotel, motel, or transient
lodging land use development project, that would be located within the San
Francisco International Airport (SFO) 65 A-weighted decibel (dBA) Community
Noise Equivalent Level (CNEL) noise contours, shall demonstrate compliance with
Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by submitting a final
acoustical report prepared to the satisfaction of the Planning Division that
identifies design measures to adequately minimize airport activity noise levels to
meet the interior noise level standards shown in Table 11 of the Noise Element.
Outdoor active use space must also comply with the exterior noise standards of
Table 11 of the Noise Element or must be excluded from such projects. The report
must be approved by the Planning Division prior to issuance of building permits.
• Any proposed commercial development project that would be located within the
SFO 70 dBA CNEL noise contours shall demonstrate compliance with Policies NOI-
1.1 and NOI-1.2 of the City’s Noise Element by submitting a final acoustical report
prepared to the satisfaction of the Planning Division that identifies design
measures to adequately minimize airport activity noise levels to meet the interior
noise level standards shown in Table 11 of the Noise Element. The report must be
approved by the Planning Division prior to issuance of building permits.
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• Any proposed institutional or public facility development project that would be
located within the SFO 65 dBA CNEL noise contours shall demonstrate compliance
with Policies NOI-1.1 and NOI-1.2 of the City’s Noise Element by submitting a final
acoustical report prepared to the satisfaction of the Planning Division that
identifies design measures to adequately minimize airport activity noise levels to
meet the interior noise level standards shown in Table 11 of the Noise Element.
Outdoor active use space must also comply with the exterior noise standards of
Table 11 of the Noise Element or must be excluded from such projects. The report
must be approved by the Planning Division prior to issuance of building permits.
Facts in Support of Findings: The City of South San Francisco experiences air traffic noise impacts
due to its proximity to SFO. Aircraft noise in the City results from aircraft departing from Runway 28
and from Runway 1. Flights departing from Runway 28 climb directly over noise-sensitive land uses
resulting in high pass-by noise levels in residential areas, including areas outside the contours that
define noise-impacted areas. The proposed project does not propose additional special events or
sources of single-event noise in the form of aircraft flyover noise. Therefore, the proposed project
would not result in changes in the 65 dBA CNEL airport noise contours and would not increase
airport noise impacts.
However, future development could introduce noise-sensitive land uses to excessive aircraft noise
levels if they would occur within the 65 dBA CNEL contours of the airport. Any local plans, policy
actions or development activities that affect areas within the 65 dBA CNEL contour established in the
SFO ALUCP must receive San Mateo County ALUC approval or have a finding of overriding
consideration prior to local permit issuance. The proposed project envisions future development
that could occur within the 65 dBA CNEL noise contours which could expose persons residing or
working at these areas to noise levels from airport activity that would be in excess of normally
acceptable land use compatibility standards. For example, the proposed project includes planned
mixed-use residential areas east of US-101 which would lie within the airport’s runway safety zone
boundaries and the SFO 65 dBA CNEL noise contours shown on Exhibit 3.11-2 of the Draft Program
EIR.
These airport activity noise levels could exceed the City’s noise/land use compatibility standards for
certain land uses. Therefore, mitigation would be required to reduce this potential impact. With
implementation of MM NOI-3, detailed above, impacts generated by future development projects
under the proposed project would be reduced to less than significant (Draft Program EIR, Pages 3.11-
34-35).
The City finds that MM NOI-3 is feasible, is adopted, and will further reduce noise impacts.
Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State
CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated
into, the proposed project that mitigate or avoid the potentially significant impacts as identified in
the EIR. Therefore, impacts associated with noise would be less than significant with mitigation
incorporated.
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1.7 - Impacts Identified in the Draft Program EIR as Being Significant and
Unavoidable Even After the Incorporation of All Feasible Mitigation Measures
The City of South San Francisco hereby finds that, despite the incorporation of mitigation measures
outlined in the Draft Program EIR and the attached MMRP, the following impacts from the proposed
project and related approvals cannot be fully mitigated to a less than significant level and a
Statement of Overriding Considerations is therefore included herein.
1.7.1 - Air Quality
Impact AIR-1 The proposed project would conflict with or obstruct implementation of an
applicable air quality plan (Draft Program EIR, Page 3.2-35-50).
Findings: Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even
with mitigation incorporated. Specific economic, legal, social, technological, or other considerations,
including provision of employment opportunities for highly-trained workers, make infeasible the
mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines §
15091(a)(3)). (Draft Program EIR, Page 3.2-50).
Mitigation Measures
MM AIR-1a Individual development projects facilitated by the proposed project shall incorporate
the following Basic Construction Mitigation Measures recommended by the Bay
Area Air Quality Management District (BAAQMD):
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day.
• All haul trucks transporting soil, sand, or other loose material off-site shall be
covered.
• All visible mud or dirt trackout 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.
• All vehicle speeds on unpaved roads shall be limited to 15 mph.
• 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.
MM AIR-1b Projects that may result in additional toxic air contaminants (TACs) that are located
within 1,000 feet of a sensitive receptor(s) or would place sensitive receptors within
1,000 feet of uses generating TACs, such as roadways with volumes of 10,000
average annual daily trips or greater, shall implement Bay Area Air Quality
Management District (BAAQMD) Guidelines and California Office of Environmental
Health Hazard Assessment (OEHHA) policies and procedures requiring a Health Risk
Assessments (HRA) for residential development and other sensitive receptors.
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Screening area distances may be increased on a case-by-case basis if an unusually
large source or sources of hazardous emissions are proposed or currently exist.
Based on the results of the HRA, identify and implement measures (such as air
filtration systems) to reduce potential exposure to particulate matter, carbon
monoxide, diesel fumes, and other potential health hazards. Measures identified in
HRAs shall be included into the site development plan as a component of a
proposed project.
MM TRANS-1 Transportation Demand Management
To reduce Vehicle Miles Traveled (VMT), the City shall implement its Transportation
Demand Management (TDM) Ordinance as part of the Zoning Code Amendments
and parking requirements. The City shall also update its TDM Ordinance and parking
requirements every five to ten years and establish an East of 101 Area Trip Cap, to
achieve the maximum feasible reductions in vehicle travel. The City shall achieve the
performance standards outlined in the TDM Ordinance.
The City shall update its TDM Ordinance every 5 to 10 years to limit Total VMT and
Work-Based VMT by incentivizing use of transit and active transportation and
disincentivizing auto use. The TDM Ordinance shall cover all development projects
generating greater than 100 daily trips, with the most stringent requirements for
office/Research and Development (R&D) land uses that disproportionately account
for the highest rates of VMT in the City. Development projects shall implement a
combination of TDM programs, services, and infrastructure improvements, including
but not limited to: establishing trip reduction programs; subsidizing transit and
active transportation use; coordinating carpooling and vanpooling; encouraging
telecommuting and flexible work schedules; designing site plans to prioritize
pedestrian, bicycle, and transit travel; funding first/last mile shuttle services;
establishing site-specific trip caps; managing parking supply; and constructing transit
and active transportation capital improvements. Developments shall be subject to
annual monitoring. The City shall establish an administrative fine structure for
developments found to be out of compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.
The City shall establish an East of 101 Area Trip Cap to support the monitoring of
vehicle trip activity and focus efforts to reduce VMT. The area-wide trip cap shall
apply to the high-density employment uses in the East of 101 Area. The City shall
conduct annual traffic counts along the cordon area perimeter. Should the trip cap
be reached, the City shall consider corrective actions such as: revising mode share
targets for projects subject to the TDM Ordinance, identifying new funding
measures for TDM services, implementing new vehicle user charges, creating new
street connections, or slowing the pace of development approvals within the cordon
zone.
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The City shall update its parking requirements every 5 to 10 years to align with its
TDM Ordinance and East of 101 Area Trip Cap. The City shall establish parking
maximums for office/R&D uses to ensure that VMT reduction goals are incorporated
into the design of development projects.
Facts in Support of Findings: According to the BAAQMD’s guidance, a proposed land use plan would
be consistent with the AQP if it would: (1) support the primary goals of the AQP, (2) include
applicable control measures from the AQP, (3) not disrupt or hinder implementation of any AQP
control measures, and (4) the plan’s projected VMT increase must be less than or equal to its
projected population growth.
(1) The proposed project supports the primary goals of the AQP: The primary goals of the 2017
Bay Area Clean Air Plan are to attain air quality standards, reduce population exposure and
protect public health, and reduce GHG emissions and protect the climate.
The proposed project would be consistent with the 2017 Bay Area Clean Air Plan’s primary goal of
achieving and maintaining attainment status for AAQS as the land use patterns in the proposed
project would not be substantially different from existing land use patterns. In addition to existing
regulations in the Municipal Code, the proposed project includes several policies and actions related
to improving air quality, including Policy CHEJ-3.1, Action CHEJ-3.1.1, Action CHEJ-3.2, Action CHEJ-
3.2.2, Action CHEJ-3.3.2, Policy CEHJ-3.5, Policy CR-6.1, and Policy CR-6.5. The CAP includes several
actions that assist in reducing or avoiding impacts related to air quality. Several of the CAP measures
focus on reducing VMT and consequently mobile source emissions, as well as promoting green
building design which reduces indirect air quality associated with the building envelope. These
include Action CE-1.1, CE-1.3, CE-1.6, TL-1.1, TL-2.2, and TL-2.6, as well as the South San Francisco
Zoning Ordinance, including the Zoning Code Amendments that are part of the proposed project,
including Section 20.300.008 (Lighting and Illumination), Section 20.480 (Design Review), and
Section 20.300.010 (Performance Standards). Furthermore, as discussed in Impact AIR-2, individual
development projects would be required to undergo their own respective CEQA environmental
review, including an analysis of potentially significant impacts on local and regional air quality and
consideration of an individual development project’s contribution to an existing or forecasted air
quality violation. MM AIR-1a would be required to ensure that individual development projects
would result in less than significant construction fugitive dust impacts. MM AIR-1a contains
BAAQMD’s “Basic Construction Mitigation Measures Recommended for All Proposed Projects.”
The daily VMT per service population (employees + residents) is anticipated to be reduced from
27.42 VMT per service population for existing conditions to 26.80 VMT per service population for
proposed project buildout conditions (see Draft Program EIR, Section 3,14, Transportation.) The
reduction in VMT per service population would reduce the population’s exposure to TACs from
transportation-related sources. As identified in the discussion of community risk and hazards (see
Impact AIR-3), new sensitive land uses could be proximate to sources of TACs, and new commercial
land uses could generate an increase in TACs. As discussed in Impact AIR-3, mandatory compliance
with BAAQMD regulations would ensure that new sources of TACs do not expose populations to
significant health risk. Consistent with BAAQMD’s CEQA Air Quality Guidelines, the proposed project
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would not result in a potentially significant community risk and hazard impact if the land use
diagram identifies special overlay zones around existing and planned sources of TACs, including
special overlay zones of at least 500 feet on each side of all freeways and high-volume roadways (or
another BAAQMD-approved modeled distance), and the plan identifies goals, policies, and
objectives to minimize potentially adverse impacts. Because the proposed project does not currently
contain a land use diagram which identifies special overlay zones around existing and planned
sources of TACs, MM AIR-1b would be required to ensure that future development facilitated by the
proposed project would result in less than significant impacts related to exposing sensitive receptors
to substantial pollutant concentrations. Measures identified in HRAs shall be included into the site
development plan as a component of the project. MM AIR-1b would ensure that future
development facilitated by the proposed project would result in less than significant impacts to
sensitive receptors related to operational TACs. Implementation of new and revised General Plan
Update and CAP policies and programs would reduce community risk and hazards. Lastly, future
development would be required to comply with Section 20.300.010 (Performance Standards) of the
Zoning Ordinance.
As discussed in Section 3.7, Greenhouse Gas Emissions, implementation of the proposed project would
substantially contribute to the region’s achievement of the 2030 Statewide GHG reduction goal and is
forecasted to advance toward the 2050 Statewide goal. In addition, the proposed project is consistent
with regional strategies for infill development identified by the MTC/ABAG in the Plan Bay Area.
Consequently, the proposed project is consistent with the goals of the 2017 Bay Area Clean Air Plan to
reduce GHG emissions.
(2) The Proposed Project Includes Applicable Control Measures From the AQP: The proposed
project includes the applicable control measures from the AQP. Table 3.2-5 from the Draft
Program EIR identifies the applicable control measures included in the 2017 Clean Air Plan
and the General Plan Update and CAP policies and actions, as well as regulations in the
South San Francisco Municipal Code and Zoning Ordinance related to the control measures.
Measures not included in Table 3.2-5 were determined by the City to not be applicable to
the proposed project. As shown in Table 3.2-5, the General Plan Update, South San
Francisco Zoning Ordinance, CAP, and South San Francisco Municipal Code include policies,
actions, and requirements that incorporate and implement the control measures included
in the 2017 Clean Air Plan. As such, the proposed project would be consistent with the 2017
Clean Air Plan under this criterion.
(3) The Proposed Project Would Not Disrupt or Hinder Implementation of Any AQP Control
Measures: As shown in Table 3.2-5, the General Plan Update and South San Francisco
Municipal Code incorporate and are consistent with the control measures included in the
2017 Clean Air Plan. The proposed project does not include any components that would
disrupt or hinder implementation of any control measures, such as precluding an extension
of a planned transit line or bike bath or proposing excessive parking. As previously
discussed, control measures not included above would not pertain to the proposed project
as a long-range land use planning document, such as Control Measure SS7, Sulfuric Acid
Plants, which calls for the consideration of amending District Rule 9-1 to limit SO2 emissions
from acid plants associated with petroleum refining or Control Measure TR1, Clean Air
Te leworking Initiative, that calls for the development of teleworking best practices for
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employers. Measures not included in Table 3.2-5 were determined by the City to not be
applicable to the proposed project. Please refer to the BAAQMD’s 2017 Clean Air Plan for
more information on all 55 control measures. As such, the proposed project would not
hinder the BAAQMD from implementing the control measures in the 2017 Clean Air Plan.
(4) The Proposed Project Would Not Reduce VMT Per Capita: The increase in daily VMT from
implementation of the proposed project has been analyzed in Section 3.14, Transportation,
which found that the total daily VMT would increase from the existing (year 2019)
3,387,200 VMT to 6,585,400 VMT in 2040 with buildout of the proposed project, resulting
in a net increase of 3,198,200 daily VMT. As discussed in Section 3.14, Transportation, the
City’s population would grow from an estimated 67,200 people under existing conditions to
an estimated 108,100 people in 2040 with buildout of the proposed project. As such, the
proposed project would facilitate an estimated population growth of 40,900 people by
2040. The VMT growth facilitated by the proposed project would constitute an
approximately 94 percent growth through 2040 while population growth facilitated by the
proposed project would constitute an approximately 61 percent growth through 2040. The
forecasted VMT growth would outpace the forecasted population growth facilitated by the
proposed project. Therefore, the proposed project would be considered inconsistent with
the 2017 Clean Air Plan. The proposed project would implement MM TRANS-1, which
would require the City to implement its Transportation Demand Management (TDM)
Ordinance as part of the Zoning Code Amendments and parking requirements to reduce
project-generated VMT. MM TRANS-1 also requires the City to update its TDM Ordinance
and parking requirements every 5 to 10 years and establish an East of 101 Area Trip Cap, to
achieve the maximum feasible reductions in vehicle travel. However, even with the
implementation of the General Plan Update policies and actions and implementation of
MM TRANS-1, because the effectiveness of VMT reduction strategies cannot be quantified
in this programmatic analysis, the City of South San Francisco may not achieve the overall
VMT threshold reduction level. As such, this impact would be significant and unavoidable.
In conclusion, overall development facilitated by the proposed project would be inconsistent with
the 2017 Clean Air Plan, since it would facilitate VMT growth which outpaces the forecasted
population growth. Nonetheless, the proposed project would support the primary goals of the AQP,
include applicable control measures from the AQP, and neither disrupt nor hinder implementation of
any AQP control measures. Because the proposed project would facilitate VMT growth which
outpaces forecasted population growth through 2040, the proposed project would conflict with the
2017 Clean Air Plan and impacts would be significant and unavoidable after mitigation. (Draft
Program EIR, Page 3.2-34-50).
The City finds that MM AIR-1a, MM AIR-1b and MM TRANS-1 are feasible, are adopted, and will
reduce VMT impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public
Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or
alterations have been required in, or incorporated into, the project that mitigate or reduce the
potentially significant impacts as identified in the EIR to the extent feasible. However, impacts
associated with VMT growth would remain significant and unavoidable even with mitigation
incorporated.
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Impact AIR-2 The proposed project would result in a cumulatively considerable net increase of
any criteria pollutant for which the project region is nonattainment under an
applicable federal or State ambient air quality standard (Draft Program EIR, Page
3.2-50-54).
Findings: Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even
with mitigation incorporated. Specific economic, legal, social, technological, or other considerations,
including provision of employment opportunities for highly trained workers, make infeasible the
mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines §
15091(a)(3)). (Draft Program EIR, Page 3.2-54).
Mitigation Measures
Implement MM AIR- 1a and MM TRANS-1.
Facts in Support of Findings: Construction: Future development supported by the proposed project
would result in short-term construction-related criteria pollutant emissions that have the potential
to have an adverse effect on air quality. Short-term criteria pollutant emissions would occur during
demolition, site preparation, grading, building construction, paving, and architectural coating
activities associated with individual development projects. ROG and NOX emissions are primarily
associated with gasoline and diesel equipment exhaust and the application of architectural coatings.
Fugitive dust emissions (PM10 and PM2.5) are primarily associated with site preparation and vary as a
function of such parameters as soil silt content, soil moisture, wind speed, acreage of disturbance
area, and VMT by construction vehicles on- and off-site. Typical construction equipment associated
with development and redevelopment projects includes dozers, graders, excavators, loaders, and
trucks.
Although the exact coverage, location, or duration of future construction projects is unknown at the
time of preparation of the Draft Program EIR, future development activities would generally entail
demolition, site preparation, grading, building construction, paving, and painting. Since South San
Francisco is generally a built-out city, many new projects in the City will likely require the demolition
of existing structures to make room for newer ones. In addition, the proposed project may result in
other private and public improvements throughout the City. Fugitive dust emissions would typically
be greatest during building demolition, site preparation, and grading due to the disturbance of soils
and transport of material. NOX emissions would also result from the combustion of diesel fuels used
to power off-road heavy-duty vehicles and equipment (e.g., backhoes, bulldozers, excavators). The
types and quantity of equipment, as well as duration of construction activities, would be dependent
on project-specific conditions. Larger projects would require more equipment over a longer time
frame than that required for redevelopment of a single, residential home or small residential or
mixed-use project.
The BAAQMD maintains and recommend project-level thresholds would apply to potential future
development projects. In addition, the BAAQMD’s CEQA Air Quality Guidelines identify and
recommend a series of “Basic” measures to control and reduce construction-related emissions. For
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all projects, the BAAQMD recommends implementation of eight Basic Construction Measures to
reduce construction fugitive dust emissions. The BAAQMD determines a less than significant impact
with respect to construction fugitive dust emissions when following Basic Construction Measures
highlighted in the Draft Page EIR at page 3.2-51. MM AIR-1a would be required to ensure that
individual development projects facilitated by the proposed project would result in less than
significant impacts. MM AIR-1a contains BAAQMD’s “Basic Construction Mitigation Measures
Recommended for All Proposed Projects” in the bullet points listed above and contained in the
BAAQMD’s 2017 CEQA Air Quality Guidelines, which are recommended by the BAAQMD to ensure
construction fugitive dust emissions are less than significant.
Operation: The proposed project would accommodate new residential and nonresidential
development that will operate through the General Plan Update horizon year 2040. Long-term
criteria pollutant emissions would result from the operation of residential, retail, light industrial,
commercial, and institutional uses supported by the proposed project. Operational air quality
emissions are principally generated from area, energy, and mobile sources. Area source emissions
are the combination of many small emission sources that include use of outdoor landscape
maintenance equipment, use of consumer products such as cleaning products, use of fireplaces and
hearths, and periodic reapplication of architectural coatings. Criteria pollutants generated from
energy sources are principally from the on-site use of natural gas; electricity consumption is not
included in energy source emissions as those potential emissions would be generated as the result
of the operation of an electricity generation facility which may or may not be within the same air
basin and under the same attainment status as the end-use. Mobile source emissions result from the
vehicle activity associated with the operation of a given land use development project, including
resident, worker, and patron vehicle trips.
Implementation of the proposed project may result in development of up to 17,153 net new
residential units (based on 2019 baseline data from Fehr & Peers), and up to 14,100,523 square feet
of net new nonresidential space. Future development projects would be subject to the City’s
standard CEQA review process and would be required to assess project-specific emissions in relation
to the BAAQMD significance thresholds.
The estimated net criteria air pollutants resulting from the proposed project are shown in the Draft
Program EIR, Table 3.2-7. Overall area and energy source emissions would increase from baseline
conditions as a result of the projected increase in residential units and nonresidential space. Overall
mobile source emissions would decrease from baseline emissions as a result of improved fuel
efficiency standards, the accelerated adoption of EVs, and fleet turnover requirements implemented
at the State level through 2040 as compared to existing conditions.
As discussed in Impact AIR-1, the proposed project would be consistent with the applicable 2017
Clean Air Plan control measures. As discussed in Impact AIR-1, the VMT growth facilitated by the
proposed project would constitute an approximately 94 percent growth rate through 2040, while
population growth facilitated by the proposed project would constitute an approximately 61 percent
growth rate through 2040. Therefore, the forecasted VMT growth would outpace the forecasted
population growth facilitated by the proposed project. As such, this impact would be potentially
significant. As described in Impact AIR-1, there is no reasonable mitigation that could be
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implemented to increase population projections while keeping VMT growth to a minimum in an area
that is already fully urbanized and built out, such as the City of South San Francisco; therefore, this
impact would remain significant and unavoidable after mitigation (Draft Program EIR, Page 3.2-50—
54).
The City finds that MM AIR-1a and MM TRANS-1 are feasible, are adopted, and will reduce VMT
impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code
Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have
been required in, or incorporated into, the project that mitigate or reduce the potentially significant
impacts as identified in the EIR to the extent feasible. However, impacts associated with VMT growth
would remain significant and unavoidable even with mitigation incorporated.
Cumulative Impacts
The proposed project’s cumulative impacts related to air quality would be significant and
unavoidable, even with mitigation incorporated. (Draft Program EIR, Page 3.2-58-63).
Findings: Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even
with mitigation incorporated. Specific economic, legal, social, technological, or other considerations,
including provision of employment opportunities for highly trained workers, make infeasible the
mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines §
15091(a)(3)). (Draft Program EIR, Page 3.2-63).
Mitigation Measures
Implement MM AIR-1a, MM AIR-1b, and MM TRANS-1.
Facts in Support of Findings: The geographic scope of the cumulative impact analysis for air quality
is the Air Basin.
As discussed in Impact AIR-4, the proposed project would not result in cumulatively considerable
impacts related to odor impacts or cumulatively considerable impacts exposing sensitive receptors
to substantial pollutant concentrations. Nonetheless, as discussed in Impact AIR-1, the proposed
project would result in an inconsistency with the 2017 Clean Air Plan and a cumulatively
considerable net increase in criteria pollutants as a result of VMT growth facilitated by the proposed
project. As such, the proposed project would have a cumulatively considerable contribution to a
cumulative impact, even with implementation of the policies in the proposed project and all feasible
mitigation.
2017 Clean Air Plan Consistency
The BAAQMD CEQA Guidelines provide that land use plans should incorporate policies and
requirements that ensure they do not inhibit attainment of air quality standards and that actually
assist in improving local and regional air quality. BAAQMD further recommends that air quality-
related goals, policies, performance measures and standards should be incorporated within the
context of the plan itself, rather than introduced as corrective actions within the plan’s EIR. As shown
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in Table 3.2-5 of the Draft Program EIR, the General Plan Update, South San Francisco Zoning
Ordinance, CAP, and South San Francisco Municipal Code include policies, actions, and requirements
that incorporate and implement the control measures included in the 2017 Clean Air Plan. As
discussed in Impact AIR-1, the proposed project would support the overall goals of the 2017 Clean
Air Plan with implementation of MMs AIR-1a and AIR-1b.
BAAQMD evaluates criteria pollutants resulting from long-range plans such as the proposed project,
by evaluating consistency with the AQP, as well as a comparison of project VMT to projected
population increase. The proposed project would support the primary goals of the AQP, include
applicable control measures from the AQP, and neither disrupt nor hinder implementation of any
AQP control measures. However, as noted in Impact AIR-1, the development envisioned by the
proposed project would be inconsistent with the 2017 Bay Area Clean Air Plan, since it would
facilitate VMT growth which outpaces the forecasted population growth.
The SFBAAB is currently designated as a nonattainment area for PM. The BAAQMD’s recommended
significance threshold for construction fugitive dust is binary–meaning a project’s construction
fugitive dust emissions would be less than significant with the inclusion of dust control BMPs, and
potentially significant without dust control BMPs. Implementation of MM AIR-1a, detailed above in
Impact AIR-1, would ensure that individual development projects facilitated by the proposed project
would result in less than significant construction fugitive dust impacts.
Consistent with BAAQMD’s CEQA Air Quality Guidelines, the proposed project would not result in a
potentially significant community risk and hazard impact if the land use diagram identifies special
overlay zones around existing and planned sources of TACs, including special overlay zones of at least
500 feet on each side of all freeways and high-volume roadways (or another BAAQMD-approved
modeled distance), and the plan identifies goals, policies, and objectives to minimize potentially
adverse impacts. The proposed project does not currently contain a land use diagram which
identifies special overlay zones around existing and planned sources of TACs. Implementation of MM
AIR-1b, detailed in Impact AIR-1 would ensure that future development facilitated by the proposed
project would result in less than significant impacts related to exposing sensitive receptors to
substantial pollutant concentrations.
Criteria Air Pollutant and Ozone Precursor Emissions
BAAQMD’s plan-level guidelines do not require an emissions inventory of criteria air pollutants for
plan-level projects. Impact AIR-2 provides an inventory of criteria pollutants for informational
purposes only. A plan-level analysis must demonstrate project consistency with AQP control
measures and a projected VMT increase that is less than or equal to its projected population growth
for this impact to be less than significant.
As explained previously, the development envisioned by the proposed project would be inconsistent
with the 2017 Bay Area Clean Air Plan, since it would facilitate VMT growth which outpaces the
forecasted population growth. Nonetheless, the proposed project would support the primary goals
of the AQP, include applicable control measures from the AQP, and neither disrupt nor hinder
implementation of any AQP control measures. The General Plan Update and CAP contain new
policies and actions to reduce criteria air pollutants to the maximum extent practicable.
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All new development and redevelopment within the City would be required to meet the BAAQMD
rules and regulations, including Regulation 6-3-306 which restricts the installation of wood burning
fireplaces into a new building and Regulation 8-3-301, which limits the allowed VOC levels in the
architectural coatings applied onto buildings within the City. The 2019 California Code of
Regulations, Title 24, Part 6, standards also now require all homes built in California to have zero-
net-energy use, which is achieved through energy efficiency measures as well required rooftop solar
photovoltaic systems. The 2019 California Code of Regulations, Title 24, Part 6, standards also apply
to nonresidential buildings and require a variety of energy efficiency measures to be implemented
that will reduce energy usage as well as air emissions.
Therefore, compliance with the applicable policies and actions in the General Plan Update and CAP,
as well applicable State and BAAQMD rules and regulations, would minimize the potential air quality
impacts resulting from implementation of the proposed project, which would encourage or require
the use of fuel-efficient equipment, vehicles, and BMPs. Mandatory compliance with design review
regulations and policies in the South San Francisco Municipal Code and General Plan would ensure
that operation-related air quality impacts from new development under the General Plan would be
less than significant on an individual project basis, and the City will review those future projects
under its standard design review procedures in the Municipal Code.
As previously discussed, the SFBAAB is currently designated as a nonattainment area for PM. The
BAAQMD’s recommended significance threshold for construction fugitive dust is binary–meaning a
project’s construction fugitive dust emissions would be less than significant with the inclusion of
dust control BMPs, and potentially significant without dust control BMPs. Implementation of MM
AIR-1a, detailed above in Impact AIR-1, would ensure that individual development projects
facilitated by the proposed project would result in less than significant construction fugitive dust
impacts.
Nonetheless, as the proposed project would facilitate VMT growth which outpaces projected
population growth through the planning horizon of 2040, the proposed project would be
inconsistent with the 2017 Clean Air Plan and would therefore result in a cumulatively considerable
net increase in criteria air pollutants and ozone precursors, resulting in a conflict with the applicable
air quality plan, even after implementation of MMs AIR-1a and AIR-1b.
Sensitive Receptor Exposure to Substantial Pollutant Concentrations
As discussed under Impact AIR-3, localized risks are primarily associated with exposure to TAC
emissions. Common sources of TAC emissions are stationary sources (e.g., dry cleaners, diesel
backup generators, and gasoline stations), which are subject to BAAQMD permit requirements.
Another common and often more significant source type is on-road motor vehicles on high-volume
roads, such as US-101, I-280, SR-82, SR-35, and off-road sources such as construction equipment and
diesel-powered trains traveling on the Caltrain corridor. Although the proposed project does not
include specific plans for any new, large stationary sources of emissions, it could result in new
sensitive receptors (primarily residential receptors) near existing sources of emissions.
As discussed above, the proposed project would not result in a potentially significant community risk
and hazard impact if the land use diagram identifies special overlay zones around existing and
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planned sources of TACs, including special overlay zones of at least 500 feet on each side of all
freeways and high-volume roadways (or another BAAQMD-approved modeled distance), and the
plan identifies goals, policies, and objectives to minimize potentially adverse impacts. The proposed
project does not currently contain a land use diagram which identifies special overlay zones around
existing and planned sources of TACs. Implementation of MM AIR-1b, detailed in Impact AIR-1 would
ensure that future development facilitated by the proposed project would result in less than
significant impacts related to exposing sensitive receptors to substantial pollutant concentrations.
The General Plan Update contains several policies and actions that aim to reduce the potential
growth of vehicle use through encouraging the use of alternative modes of transportation,
monitoring and improving existing sources of TACs throughout the City and reducing overall health
impacts related to air quality in general.
Odor Impacts
While odors could be generated during construction activities, the proposed project consists of a
General Plan Update, Climate Action Plan Update, and Zoning Code Amendment and would not
directly result in construction of any development project. Project-specific information for future
individual land use development projects is unknown, thus identification of potential impacts related
to construction-generated odors from future projects is not possible. As discussed in Impact AIR-4,
the City contains several of the land uses listed by the BAAQMD as potential odor sources. As the
City of South San Francisco is a fully urbanized and built-out city, it currently has, and the proposed
project would facilitate future development of, sensitive receptors within the identified screening
distances of existing odor sources. Consistent with the BAAQMD’s CEQA Air Quality Guidelines, a
plan-level analysis must acknowledge odor sources within the Planning Area and identify policies,
goals, and objectives aimed at reducing potential odor impacts to ensure that potential impacts
would be less than significant.
Furthermore, the South San Francisco Zoning Ordinance, including the Zoning Code Amendments
that are part of the proposed project, contain Section 20.300.010 (Performance Standards), which
establishes regulations related to odors and restricts uses, processes, or activities that produce
objectionable odors that are perceptible without instruments by a reasonable person at the lot lines
of a site. Sections 20.410.004 (Indoor Commercial Cannabis Cultivation), 20.410.005 (Commercial
Cannabis Manufacturing), and 20.410.006 (Cannabis Testing Operations) require that operators
install and maintain, in good working-order, air treatment or other ventilation systems to prevent
odors generated from the cultivation of cannabis from being detected within 10 feet of the structure
in which commercial cannabis cultivation occurs. In addition, BAAQMD Regulation 7 limits emissions
of odorous substances within the Air Basin and would apply to any future odor source within the
Planning Area (Draft Program EIR, Page 3.2-58—63).
The City finds that MM AIR-1a, MM AIR-1b, and MM TRANS-1 are feasible, are adopted, and will
reduce air quality impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public
Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or
alterations have been required in, or incorporated into, the project that mitigate or reduce the
potentially significant impacts as identified in the EIR to the extent feasible. However, air quality
impacts would remain significant and unavoidable even with mitigation incorporated.
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1.7.2 - Transportation and Traffic
Impact TRANS-1 Implementation of the proposed project would conflict or be inconsistent with
CEQA Guidelines Section 15064.3, subdivision (b) (Draft Program EIR, Page 3.14-
35-40).
Findings: Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even
with mitigation incorporated. Specific economic, legal, social, technological, or other considerations,
including provision of employment opportunities for highly trained workers, make infeasible the
mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines §
15091(a)(3)). (Draft Program EIR, Page 3.14-40).
Mitigation Measures
Implement MM TRANS-1.
Facts in Support of Findings: While impacts would be less than significant for citywide Home-Based
VMT Per Resident for residential use without mitigation, impacts with mitigation (MM TRANS-1) for
citywide Total VMT Per Service Population and for Work-Based VMT Per Employee would remain
significant and unavoidable. Even with the General Plan Update policies and mitigation measures
related to the TDM Ordinance, East of 101 Area Trip Cap, and parking requirements, the City may not
achieve the overall VMT threshold reduction level due to uncertainty in the cumulative effectiveness
of these measures as well as unknowns related to transit service levels, transportation technology,
and travel behavior. Moreover, these policies and mitigation measures primarily apply to new
developments; existing land uses, and land uses that have already been approved and are under
construction are generally not affected. Because of the programmatic nature of the proposed
project, no additional mitigation measures are available, and the impact is considered significant and
unavoidable. (Draft Program EIR, Page 3.14-35-40).
The City finds that MM TRANS-1 is feasible, is adopted, and will reduce VMT impacts to the extent
feasible. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and
State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or
incorporated into, the project that mitigate or reduce the potentially significant impacts as identified
in the EIR to the extent feasible. However, impacts associated with VMT growth would still have
traffic impacts that remain significant and unavoidable even with mitigation incorporated.
Impact TRANS-4 Implementation of the proposed project could substantially increase hazards due
to a geometric design feature (e.g., sharp curves or dangerous intersections) or
incompatible uses (e.g., farm equipment) (Draft Program EIR, Pages 3.14-48-50).
Findings: Changes or alterations have been required in, or incorporated into, the project which avoid
or substantially lessen the significant environmental effects as identified in the EIR (State CEQA
Guidelines § 15091(a)(1)). However, impacts would still remain significant and unavoidable even
with mitigation incorporated. Specific economic, legal, social, technological, or other considerations,
including provision of employment opportunities for highly trained workers, make infeasible the
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mitigation measure or project alternatives identified in the EIR (State CEQA Guidelines §
15091(a)(3)). (Draft Program EIR, Page 3.14-50).
Mitigation Measures
Implement MM TRANS-1 and MM TRANS-4.
MM TRANS-4 Freeway Offramp Queue Improvements
To minimize queueing hazards, the City shall work with Caltrans to develop
improvement measures for freeway off-ramps and adjacent intersections that help
manage offramp queues. These measures may include geometric changes, changes
to signal timing and phasing, and new connections as identified in Table 3.14-5. Such
improvement measures shall not adversely affect pedestrian, bicycle, and transit
conditions or otherwise undermine the City’s VMT mitigation efforts described in
MM TRANS-1. MM TRANS-1 is also applicable here and should be implemented to
minimize freeway offramp queues.
Facts in Support of Findings: Even with the implementation of General Plan Update policies and
actions and implementation of MMs TRANS-4 and TRANS-1, given the uncertainty around specific
operational conditions and ability to mitigate such conditions in a constrained right-of-way, this
impact remains significant and unavoidable. However, due to the programmatic nature of the
proposed project, no additional mitigation measures are available, and the impact is considered
significant and unavoidable.
The City finds that MM TRANS-1 and MM TRANS-4 are feasible, are adopted, and will reduce traffic
impacts to the extent feasible. Accordingly, the City finds that, pursuant to Public Resources Code
Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have
been required in, or incorporated into, the project that mitigate or reduce the potentially significant
impacts as identified in the EIR to the extent feasible. However, impacts associated with traffic
hazards would still remain significant and unavoidable even with mitigation incorporated. (Draft
Program EIR, Pages 3.14-48—50).
1.8 - Findings Regarding Alternatives
1.8.1 - Introduction
This section presents findings regarding alternatives to the proposed project. The section provides a
summary and discussion of the feasibility of the following alternatives evaluated in the Draft
Program EIR:
• Alternative 1: No Project Alternative/1999 General Plan.
• Alternative 2: Decreased Employment Alternative.
• Alternative 3: Increased Residential Alternative
In accordance with CEQA Guidelines Section 15126.6, the Draft Program EIR contained a
comparative impact assessment of alternatives to the proposed project. The primary purpose of this
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analysis is to provide decision makers and interested agencies, organizations and individuals with
information about a reasonable range of potentially feasible project alternatives, which could avoid
or reduce any of the proposed project’s significant adverse environmental effects. Important
considerations for the alternatives analysis are noted below:
• An EIR need not consider every conceivable alternative to a project;
• An EIR should identify alternatives that were considered by the lead agency, but rejected as
infeasible during the scoping process;
• Reasons for rejecting an alternative include:
- Failure to meet most of the basic project objectives identified in Section 4.2, Project
Objectives;
- Infeasibility; and
- Inability to avoid significant environmental effects.
CEQA does not require that an analysis of alternate sites always be included in an EIR. Pursuant to
CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an
alternate site, the “key question and first step in analysis is whether any of the significant effects of
the project would be avoided or substantially lessened by putting the project in another location.
Only locations that would avoid or substantially lessen any of the significant effects of the project
need to be considered for inclusion in the EIR.”
In this case, an alternative location does not constitute a feasible alternative because the project in
question consists of a comprehensive update to the City of South San Francisco General Plan, Zoning
Code Amendments, and Climate Action Plan. A General Plan serves as the comprehensive land use
planning document for the jurisdiction that adopts it; as such, the geographical area encompassed
by the plan is an immutable, fundamental characteristic. Similarly, the Zoning Code and Climate
Action Plan address the entire City. Thus, it is not possible to evaluate an alternative location for
programmatic planning documents such as the City’s General Plan, Zoning Code, or Climate Action
Plan.
Alternative 1: No Project Alternative/1999 General Plan.
Under the No Project Alternative/1999 General Plan, the General Plan would not be updated with
new policies and no zoning or land use designation changes would occur. Future development would
be in accordance with the current land use and zoning maps identified in the 1999 General Plan. The
1999 General Plan provided for development of then-approved projects plus future development of
a total of 2,780 housing units and 9 million square feet of nonresidential space to the City’s current
inventory of an estimated 19,400 housing units and 18.1 million square feet of nonresidential
development. The 1999 General Plan estimated a population of 67,400 at projected buildout in
2020. Existing land uses in 2019 include 24,647 residential units and 31,906,205 square feet of
commercial/industrial/civic space. Exhibit 4-1 illustrates the existing land use map from the 1999
General Plan. Additionally, under this alternative the Zoning Code would not be updated, and the
City would not consider updating the existing Climate Action Plan. Under this alternative, the current
goals, policies, and zoning would remain in place through the horizon year.
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The No Project Alternative/1999 General Plan would have similar impacts to the proposed project’s
less than significant or no impacts associated with biological resources, cultural resources, and tribal
cultural resources. Because the No Project Alternative/1999 General Plan would not offer the policy
enhancements and benefits that the proposed project would, overall impacts would not be reduced
to the same degree as the proposed project, resulting in greater impacts associated with aesthetics,
light, and glare, air quality, energy, geology, soils, and seismicity, GHG emissions, hazards and
hazardous materials, hydrology and water quality, land use and planning, noise, population, housing,
and employment, public services and recreation, utilities and service systems, and wildfire. (Draft
Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-18.) The significant and
unavoidable impacts related to exceedance of the VMT threshold and freeway offramp queueing
impacts would remain significant and unavoidable under this alternative, and somewhat greater for
VMT impacts than the proposed project. The significant and unavoidable impacts related to a
conflict with the 2017 Clean Air Plan and a cumulatively considerable net increase in criteria
pollutants would remain significant and unavoidable under the No Project Alternative/1999 General
Plan.
Additionally, the No Project Alternative/1999 General Plan would not meet the majority of project
objectives. As the new policies and programs in the proposed project reflect the current goals and
vision expressed by City residents, businesses, decision-makers, and other stakeholders, continuing
development under the 1999 vision of the No Project Alternative/1999 General Plan would not
achieve the first objective of the proposed project. Additionally, the No Project Alternative/1999
General Plan would not update the General Plan or update the CAP to address issues and concerns
related to energy, sustainability and climate resiliency, sea level rise, hydrology and water quality, or
any other issue raised by City residents and therefore would not meet the second objective of the
proposed project. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-19)
The No Project Alternative/1999 General Plan would not provide additional mitigation for biological
resources or cultural and tribal cultural resources or reduce VMT and noise impacts to the same
extent as the proposed project. The No Project Alternative/1999 General Plan would also fail to
achieve objectives because this alternative would not meet the City’s housing needs, nor would it
include new policies and programs that provide direction for cohesive development to meet the
projected population and employment growth. Neither would the No Project Alternative/1999
General Plan meet the last two objectives because it would not update the Zoning Code and would
not provide needed updates to address new requirements of State law. (Draft Program EIR, Chapter
4, Alternatives to the Proposed Project, Page 4-19.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City
finds that the No Project Alternative fails to meet the majority of the project objectives. The City
rejects this alternative as infeasible.
Alternative 2: Decreased Employment Alternative.
Under the Decreased Employment Alternative, there would be a 25 percent decrease in
nonresidential uses in the East of 101, Lindenville, and El Camino subareas to decrease the number
of employment opportunities and improve the jobs/housing balance in the City. It is assumed that
these decreases would not occur within 0.333 mile of existing transit. This alternative was selected
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because it would decrease VMT associated with employment and would therefore result in reduced
traffic-related impacts compared to the proposed project.
The Decreased Employment Alternative would have similar less than significant impacts compared
to the proposed project with respect to biological resources, cultural and tribal cultural resources,
geology, soils and seismicity, GHG emissions, hazards and hazardous materials, hydrology and water
quality, land use and planning, population, housing and employment, and wildfire. This alternative
would incrementally decrease the proposed project’s less than significant impacts related to
aesthetics, light and glare, air quality, energy, noise, public services, recreation, and utilities. This
alternative would slightly decrease the significant and unavoidable impacts associated with
exceedance of the VMT threshold, freeway offramp queuing, a conflict with the 2017 Clean Air Plan,
and a cumulatively considerable net increase in criteria pollutants, although not to less than
significant. (Draft Program EIR, Chapter 4, Alternatives to the Proposed Project, Page 4-25.)
The Decreased Employment Alternative would partially achieve the project objectives related to
developing a resilient community that is prepared for climate change by updating the CAP as part of
the alternative. Additionally, this alternative would meet objectives to develop a well-connected
transportation system by encouraging development near transit, increasing transit ridership,
improving circulation for all modes, and improving the pedestrian environment. Because of
decreased capacity for jobs, this alternative is less likely to meet project objectives relating to
economic development and job growth because this alternative would prioritize increased
residential development over nonresidential development, which does not reflect the goals and
vision expressed by City stakeholders to the same extent as the proposed project. Similar to the
proposed project, this alternative would incorporate updates to the Zoning Code and provide
updates to address existing new laws. (Draft Program EIR, Chapter 4, Alternatives to the Proposed
Project, Page 4-26.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City
finds that the Reduced Residential Alternative only partially meets the project objectives. The City
rejects this alternative as infeasible.
Alternative 3: Increased Residential Alternative.
This alternative would propose an increase in residential development along the El Camino Real
transit corridor through increased density zoning (see Exhibit 4-2). This alternative would result in an
increase in approximately 500 dwelling units compared to the proposed project. An additional 3,017
residential units would be added to this area (compared to the 2,524 units under the proposed
project). Approximately 95 acres of what is now proposed as Medium-Density Mixed Use along El
Camino Real and around the Bay Area Rapid Transit (BART) station would be designated as High-
Density Mixed Use, resulting in a change in maximum allowable density from 120 dwelling units per
acre to 180 dwelling units per acre. Maximum building heights for these parcels would increase from
85 feet to 120 feet. This alternative was selected because it would reduce the jobs to housing
imbalance; thereby reducing VMT impacts associated with commuting compared to the proposed
project.
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The Increased Residential Alternative would have similar less than significant impacts compared to
the proposed project with respect to air quality, biological resources, cultural resources and tribal
cultural resources, geology, soils, and seismicity, hazards and hazardous materials, hydrology and
water quality, population, housing, and employment, and wildfire (Draft Program EIR, Chapter 4,
Alternatives to the Proposed Project, Page 4-33). This alternative would result in greater impacts
associated with aesthetics, light, and glare, energy, GHG emissions, land use and planning, noise,
public services and recreation, and utilities and service systems. The Increased Residential
Alternative would further decrease VMT compared to the proposed project, but not to below the
significance threshold and the significant and unavoidable impacts associated with exceedance of
the VMT threshold, freeway offramp queuing, a conflict with the 2017 Clean Air Plan, and a
cumulatively considerable net increase in criteria pollutants would remain. Similar to the proposed
project, the Increased Employment Alternative would be required to comply with identified
mitigation along with applicable regulations including internally consistent General Plan Update and
Zoning Code policies and implementing actions. The Increased Residential Alternative would achieve
the project objectives related to developing a resilient community that is prepared for climate
change by updating the CAP to reduce greenhouse gas emissions as part of the alternative.
Additionally, this alternative would meet objectives to provide affordable, safe, attractive, amenity-
rich neighborhoods, develop a well-connected transportation system by encouraging development
near transit, increasing transit ridership, improving circulation for all modes, and improving the
pedestrian environment. Similar to the proposed project, this alternative would incorporate updates
to the Zoning Code and provide updates to address existing new laws. However, because this
alternative would also result in incrementally greater impacts on aesthetics, air quality, energy,
greenhouse gas emissions, land use and planning, noise, public services and recreation, and utilities
it would not meet the City’s fundamental objective to address issues and concerns identified by
South San Francisco residents, businesses, decision-makers, and other stakeholders to the same
degree as the proposed project. Nor would it address the City’s goal of providing attractive, balanced
housing to the same degree due to the increased aesthetic impacts of locating increased height
buildings adjacent to single family residential neighborhoods. (Draft Program EIR, Chapter 4,
Alternatives to the Proposed Project, Page 4-33.)
Finding: Based on the discussion in the Draft Program EIR and all other evidence before it, the City
finds that the Increased Residential Alternative only partially meets the project objectives. The City
rejects this alternative as infeasible.
Environmentally Superior Alternative
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives to a
proposed project shall identify an environmentally superior alternative among the alternatives
evaluated in an EIR.
Each of the three project alternatives would lessen the environmental impacts relative to the
proposed project to a certain degree (as described above and further in the EIR). Overall, based on
these Findings, the Decreased Employment Alternative would be considered the environmentally
superior alternative, even though, as discussed above, the City finds that it fails to fully implement
proposed project objectives and is therefore infeasible.
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1.9 - Findings Regarding Cumulative Impacts
Consistent with CEQA’s requirements, the Draft Program EIR for the proposed project includes an
analysis of cumulative impacts in every topical discussion. As discussed above, except as to
cumulative air quality impacts, all other cumulative impacts associated with the proposed project
are less than significant with the implementation of applicable regulations including new and revised
General Plan Update policies and implementing actions. Cumulative air quality impacts remain
significant and unavoidable even with incorporation of all available feasible mitigation.
1.10 - Findings Regarding Growth Inducement
State CEQA Guidelines Section 15126.2(e) requires a discussion of the ways in which a proposed
project could foster economic or population growth, or the construction of additional housing,
either directly or indirectly, in the surrounding environment. Typical growth-inducing factors might
be the extension of urban services or transportation infrastructure to a previously unserved or
underserved area, or the removal of major barriers to development.
Direct growth-inducing impacts occur when the development of a project imposes new burdens on a
community by directly inducing population growth, or by leading to the construction of additional
developments in the same area. Also included in this category are projects that remove physical
obstacles to population growth. Projects that physically remove obstacles to growth, or projects that
indirectly induce growth may provide a catalyst for future unrelated development in an area such as
a new residential community that requires additional commercial uses to support residents.
Consistent with the State CEQA Guidelines Section 15126.2(e), it “must not be assumed that growth
in any one area is necessarily beneficial, detrimental or of little significance to the environment.”
The General Plan Update does not propose or entitle any specific development that would directly
increase growth. Additionally, the General Plan Update cannot predict when any particular
development would occur; however, the General Plan Update anticipates approximately 14,312 net
new housing units, for a total of 38,959 housing units by 2040. A total of 40,068 new persons could
be accommodated under the General Plan Update at full buildout, for a total projected population of
approximately 107,203. The General Plan Update anticipates approximately 42,297 net new
employment opportunities, for a total of 137,557 employment opportunities from full buildout of
the General Plan Update by 2040. The population estimate is 34 percent greater than the
Association of Bay Area Government (ABAG) 2040 estimates, while the employment opportunities
estimate is 154 percent greater.13 However, full buildout may not be achieved by 2040. To provide a
reasonable forecast, the City’s population and employment projections are based on projects that
are entitled, under review, or under construction, and approved plans.
The City’s jobs-to-employed residents’ ratio was approximately 1.46 in 2010 and 1.70 in 2019. By
2040, with buildout of the proposed project, the jobs-to-employed residents’ ratio is estimated to be
2.95, meaning there are more jobs than employable residents under current and future conditions.
Therefore, under current and future conditions, it is reasonably anticipated that nonresidents would
13 Association of Bay Area Governments (ABAG). 2017. Projections 2040 by Jurisdiction. Website: https://abag.ca.gov/our-
work/landuse/forecasts-projections. Accessed May 18, 2022.
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continue to fill employment positions in the City. As there is not enough housing in the City for the
projected labor force, employees may need to commute to the City for employment.
It is too speculative at this time to identify the particular sectors for future job growth or to
anticipate whether any of these positions would be virtual employment opportunities that could be
filled by individuals residing in higher unemployment areas that would not have associated growth-
inducing impacts. Additionally, while an increase in permanent employment demand in the City
could result in an increase in population growth that may necessitate the construction of housing or
other infrastructure to support the population increase in adjacent communities, and while this
construction could cause physical environmental effects; it is too speculative to identify where or
when this increase would occur. Because of these uncertainties, it would be too speculative for the
City to identify and discuss any potential related environmental impacts as part of the Draft Program
EIR pursuant to CEQA Guidelines Section 15145. Specific projects under the proposed project would
comply with local and State regulations and undergo project-level environmental review to assess
environmental effects. Therefore, because the new employment opportunities in the City of South
San Francisco exceed growth projections and would likely be filled by employees residing outside the
City, the new employment opportunities could have growth-inducing impacts outside of the
Planning Area; however, those potential impacts are too speculative to address in further detail.
Because South San Francisco is a fully built city, new development would primarily occur on parcels
that already contain some existing homes or businesses, with the majority of potential growth
occurring within the East of 101, Lindenville, Downtown, and El Camino planning subareas. The City
is already well served by existing services and infrastructure As such, implementation of the
proposed project would not likely require extensions of electrical, natural gas, or water utility
infrastructure beyond that which currently exists within the Planning Area. However, for
undeveloped sites, future projects may require connections to existing infrastructure on or adjacent
to those sites. The proposed project would not extend urban infrastructure other than to future
projects within the Planning Area, and thus would not induce growth in other areas outside the
City’s Sphere of Influence. As such, the proposed project would not result in indirect population
growth through providing an extension of infrastructure or services, or through the removal of a
barrier to growth.
As discussed above, possible growth-inducing impacts outside of the Planning Area as a result of
new employment facilitated by the proposed project are too speculative to address in further detail.
The reasonably foreseeable environmental impacts resulting from the growth envisioned by the
General Plan Update would be avoided or lessened with the implementation of proposed General
Plan Update policies, including policies related to growth management, and by implementation of
mitigation measures. Therefore, by design, the proposed project reduces most of the impacts of the
growth it could otherwise have induced (Draft Program EIR, Chapter 5, Other CEQA Considerations,
Page 5-3-6).
1.11 - Findings Regarding Significant Irreversible Environmental Changes
According to Sections 15126(c) and 15126.2(d) of the State CEQA Guidelines, the City of South San
Francisco must address any significant irreversible environmental changes that would occur should
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the project be implemented. Generally, a project would result in significant irreversible
environmental changes if any of the following would occur:
• The proposed project would involve a large commitment of non-renewable resources;
• The primary and secondary impacts of the project would generally commit future generations
to similar uses;
• The proposed project involves uses in which irreversible damage could result from any
potential environmental accidents; or
• The proposed consumption of resources is not justified.
• Development under the proposed project could result in approximately 14,312 net new
housing units and approximately 42,297 net new employment opportunities within the
Planning Area. Because South San Francisco is a fully built city, new development would
primarily occur on parcels that already contain some existing homes or businesses.
Additionally, the proposed project may result in other private and public improvements
throughout the City.
Construction facilitated by the proposed project would include the consumption of resources that
are not replenishable or which may renew so slowly to be considered nonrenewable. These
resources would include the following: certain types of lumber and other forest products; aggregate
materials used in concrete and asphalt such as sand, gravel, and stone; metals such as steel, copper,
and lead; petrochemical construction materials such as plastics; and water. Fossil fuels such as
gasoline and oil would also be consumed in the use of construction vehicles and equipment.
Development would not be expected to involve an unusual commitment of nonrenewable resources,
nor be expected to consume any resources in a wasteful manner. Construction-related impacts
related to electricity and fuel consumption would be less than significant.
At operation, the proposed project would include the consumption of energy as part of building
operations and transportation activities (vehicle trips associated with the proposed project). Fossil
fuels, a nonrenewable resource, would be the primary energy source during operation of the
proposed project. All new development in the City would be required to meet State energy efficiency
regulations that include Title 24 Part 6 building energy efficiency standards that require new
residential uses to meet a net zero energy use standard and nonresidential buildings to be designed
for increased energy efficiency standards (Section 3.5, Draft Program EIR). Other State energy
efficiency regulations include Senate Bill (SB) 100 that requires 100 percent of retail sales of
electricity to be generated from zero-carbon emission sources by 2045 and Executive Order N-79-20
that requires 100 percent of new passenger vehicles sold in California to be zero-emissions by 2035.
In addition, compliance with the General Plan Update and Climate Action Plan policies and actions,
adherence to the development standards in the South San Francisco Municipal Code and Zoning
Ordinance, and compliance with State regulations, would ensure that implementation of the
proposed project would not result in wasteful, inefficient, or unnecessary consumption of energy,
thus minimizing demands for energy resources and ensuring their efficient use. Furthermore, the
proposed project minimizes petroleum fuel use for transportation by locating new housing and jobs
in areas well-served by transit services and that have good access to opportunity (such as jobs,
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neighborhood amenities, and health care facilities). Finally, the implementation of MM TRANS-1,
which requires the City to implement its TDM Ordinance as part of the Zoning Code Amendments
and parking requirements, would reduce VMT. Thus, although the proposed project would result in
an irretrievable commitment of nonrenewable resources at operation, the resources would not be
consumed inefficiently, unnecessarily, or wastefully.
Implementation of the proposed project could result in an irreversible commitment of land uses
from existing land uses to land uses proposed under the General Plan Update. Therefore, future
generations would be committed to similar land uses and the irreversible long-term environmental
changes discussed below.
The irreversible long-term environmental changes associated with the proposed project would
include an increase in local and regional vehicular traffic, and the resultant increase in air pollutants,
greenhouse gas emissions, and noise generated by this traffic. The proposed project would also
irreversibly increase the commitment of energy resources, potable water supply, wastewater
treatment, solid waste disposal, and public services, such as providing police and fire services, to
support the proposed project through its lifetime. However, features incorporated into the proposed
project and proposed mitigation measures would minimize the significant effects of the
environmental changes associated with the proposed project to the maximum degree feasible.
The proposed project may have the potential to cause significant environmental accidents through
hazardous material releases into the environment by new commercial or industrial land uses.
Compliance with State law and implementation of a Storm Water Pollution Prevention Plan (SWPPP)
during construction activities would ensure that future development would not create a significant
hazard to the public or environment through reasonably foreseeable upset and accident conditions
involving release of hazardous materials. According to California Department of Forestry and Fire
Protection (CAL FIRE), the Planning Area is not located in a Fire Hazard Severity Zone (FHSZ) but is
adjacent to land identified as Moderate FHSZ within a State Responsibility Area (SRA) and High FHSZ
within an SRA (San Bruno Mountain State Park). Sign Hill Park is susceptible to wildfires as evidenced
by a fire that occurred in 2020. Land use designations in the City in the vicinity of San Bruno
Mountain State Park and Sign Hill Park are not being modified under the General Plan Update. As a
result, the degree of wildland fire hazard, including secondary hazards, would not substantially
change with adoption of the General Plan Update, and current hazards would not significantly
increase. In addition, existing fire protection facilities would be adequate to serve the Planning Area
under the proposed project, and the proposed project would not result in a significant and
unavoidable impact related to need for new or altered fire protection facilities. Thus,
implementation of the proposed project would not have the potential to result in significant
environmental accidents related to wildfire hazards and would not result in significant irreversible
environmental changes (Draft Program EIR, Chapter 5, Other CEQA Considerations, Pages 5-6-8).
1.12 - Findings Regarding Recirculation
During the public review period after the Draft Program EIR was published, the City of South San
Francisco received certain additional information. City of South San Francisco staff and consultants
involved in preparing the various studies, reports and analyses included in the Project EIR have also
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presented additional information since the publication of the Draft Program EIR. Some of this
information was contained in comments submitted on the Draft Program EIR, and in responses to
those comments contained in the Final EIR. Other information was presented at or before public
meetings/hearings on the Draft Program EIR. The Draft Program EIR incorporates additions,
clarifications, modifications, and other changes, in response to comments and as determined
appropriate by City of South San Francisco staff and required under CEQA Guidelines.
The City of South San Francisco has considered all relevant information including the opinions and
comments of interested agencies, organizations and individuals. The City of South San Francisco
finds that the additional information does not show that any of the following situations requiring
recirculation identified in CEQA Guidelines Section 15088.5 have occurred:
• A new significant environmental impact that would result from the project (or any alternative)
or from a new mitigation measure proposed to be implemented.
• A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance.
• A feasible project alternative or mitigation measure considerably different from others
previously analyzed would clearly lessen the significant environmental impacts of the project
(or an alternative), but the project ’s proponents decline to adopt it.
• The Draft Program EIR was so fundamentally and basically inadequate and conclusory in
nature that meaningful public review and comment were precluded.
Based on the foregoing and as explained in more detail in the Final EIR, and having reviewed all the
information in the record of proceedings, the lead agency hereby finds that this additional
information does not constitute significant new information, nor does it require recirculation of the
Draft Program EIR. The additional information merely clarifies or amplifies an adequate EIR.
1.13 - Statement of Overriding Considerations
CEQA requires that a Lead Agency balance the benefits of a project against its unavoidable
environmental risk in determining whether to approve the project. If the benefits outweigh the
unavoidable adverse effects, those effects may be considered “acceptable” pursuant to CEQA
Guidelines Section 15093(a). CEQA requires that a Lead Agency support, in writing, the specific
reasons for considering a project acceptable when significant impacts are infeasible to mitigate.
Those reasons must be based on substantial evidence in the EIR or elsewhere in the administrative
record pursuant to CEQA Guidelines Section 15093(b). The Lead Agency ’s written reasons are
referred to as a Statement of Overriding Considerations.
As explained in the above Findings of Fact, most of the proposed project’s impacts on the
environment would either be insignificant or, through the incorporation of mitigation measures as
conditions of approval of the proposed project, can be reduced to less than significant. However, as
set forth in Section 1.6 above, even with implementation of all available mitigation, the proposed
project would result in significant unavoidable impacts related to project-level vehicle miles traveled,
project-level roadway safety, cumulative vehicle miles traveled, cumulative roadway safety, project-
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level conflict with 2017 Bay Area Clean Air Plan and cumulative criteria air pollutants. Further, as set
forth in Section 1.7 above, there are no feasible alternatives to the proposed project, which would
mitigate or avoid those environmental impacts, and which would meet project objectives.
Accordingly, as set forth below, the City of South San Francisco hereby declares that the following
benefits provided to the public through the approval and implementation of the proposed project
outweigh the identified significant adverse environmental impacts of the proposed project that
cannot be mitigated. The Planning Commission finds that each of the proposed project benefits
separately and individually outweigh all of the unavoidable adverse environmental effects identified
in the Draft Program EIR and therefore finds those impacts to be acceptable.
The City of South San Francisco hereby declares that pursuant to the State CEQA Guidelines Section
15093, the City of South San Francisco has balanced the benefits of the proposed project against any
unavoidable environmental impacts in determining whether to approve the proposed project.
Pursuant to the State CEQA Guidelines, if the benefits of the proposed project outweigh the
proposed project’s unavoidable adverse environmental impacts, those impacts may be considered
“acceptable.”
Having reduced the adverse significant environmental effect of the proposed project to the extent
feasible by adopting the mitigation measures contained in the Draft Program EIR, the MMRP, and
this Resolution, having considered the entire administrative record on the proposed project, and
having weighed the benefits of the proposed project against its unavoidable adverse impact after
mitigation, the Planning Commission has determined that each of the following social, economic and
environmental benefits of the proposed project separately and individually outweigh the potential
unavoidable adverse impact and render those potential adverse environmental impacts acceptable
based upon the following overriding considerations:
• The proposed project would provide consistent direction for development of vacant and
underutilized sites in the City and the ensure cohesive development of attractive buildings
that meet or exceed current building standards and complement existing and planned uses, in
accordance with the General Plan.
• The proposed project would promote the effective use of City resources by establishing a
framework to promote business diversification, create cohesive innovative areas, and retain
local businesses.
• The proposed project would implement policies of importance to the City, as reflected in the
General Plan Update.
• The proposed project would promote more efficient land use interaction by encouraging
residential and nonresidential development within already developed urban areas; the
concentration of population, employment, and services allows for more mixed-use and would
consequently reduce air quality impacts.
• The proposed project would protect unique views in the City and promote restoration of
Colma Creek through General Plan Update Policy LU-8.7 and Action CS-3.1 of the Climate
Action Plan. Additionally, the Zoning Code Amendments that are part of the proposed project
contain architectural guidelines, design review criteria, lot and development standards,
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landscaping requirements, and other regulations for various land uses in order to promote
aesthetic quality within the City and protect scenic views.
• The proposed project, especially the update to the General Plan, includes policies that
encourage civic engagement in the public decision-making process as well as goals and
policies to promote safe and sanitary homes throughout the City.
• The proposed project contains policies and actions that support a connected community. The
proposed project will contribute to the community through the provision of pedestrian and
bicycle facilities that may reduce greenhouse gas emissions.
• The proposed project would assist the City in competing economically on a domestic and
international scale by developing commercial and industrial uses that are positioned to be
economically competitive.
The proposed project proposes modern state-of-the-art infrastructure improvements that would
benefit the entire community and would be designed to comply with the California MUTCD and the
City’s design guidelines. Additionally, the proposed project would designate official truck routes. The
official designation of truck routes would direct heavy vehicles to roadways that are suited for such
travel. Likewise, it would promote avoidance of neighborhood streets that are poorly suited for
heavy vehicle traffic, thereby reducing incompatible uses in neighborhoods.
Custodian of Record; Scope and Content of Record
The documents and materials that constitute the record of proceedings on which these Findings are
based are located at Planning Division at 315 Maple Avenue South San Francisco, CA 94080. This
information is provided in compliance with Public Resources Code Section 21081.6.
Various documents, information, testimony, reports, studies, analyses and other materials (both oral
and written) constitute the record upon which the Commission bases these Findings and the basis
for the Commission’s approval and/or adoption contained herein. These Findings cite specific pieces
of evidence, but none of the Commission's findings are based solely on those cited pieces of
evidence. Rather, these Findings are based upon the entire record, and the City of South San
Francisco intends to rely upon all supporting evidence in the record for each of its conclusions
contained herein.
The documents in the record include all items referenced in Public Resources Code Section
21167.6(e):
(i) All project application materials;
(ii) The Project EIR (including the Draft Program, the Final EIR, and all appendices attached
thereto);
(iii) All staff reports, and related documents prepared by the lead agency and/or consultants
with respect to the lead agency’s compliance with the substantive and procedural
requirements of this division and with respect to the action on the project;
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(iv) All staff reports, and related documents prepared by the lead agency and written
testimony, or documents submitted by any person relevant to any findings or statement of
overriding considerations adopted by the lead agency pursuant to this division;
(v) All documentary and oral evidence received and reviewed at public hearings, public
meetings, study sessions, and workshops on the Project EIR, and any transcript or minutes
of the proceedings at which any advisory body or decision-making body heard testimony
on, or considered the Project EIR;
(vi) All notices issued by the lead agency to comply with this division or with any other law
governing the processing and approval of the project;
(vii) All written comments received in response to, or in connection with, the Project EIR,
including comments on the Draft Program EIR;
(viii) All written evidence or correspondence submitted to, or transferred from, the lead agency
with respect to compliance with this division or with respect to the project;
(ix) Any proposed decisions or findings submitted to the decision makers by lead agency staff,
or the project proponent, project opponents, or other interested agencies, organizations
and/or individuals;
(x) The documentation of the final decision, including the Project EIR and all documents, in
addition to those referenced in paragraph (c), cited or relied on in the findings or in a
statement of overriding considerations adopted pursuant to this division;
(xi) For documentary and informational purposes, all locally-adopted land use plans and
ordinances, including, without limitation, general plans, specific plans and ordinances,
master plans together with environmental review documents, findings, mitigation
monitoring programs, and other documentation relevant to planned growth in the area;
(xii) Any other written materials relevant to the lead agency’s compliance with this division or
to its decision on the merits of the project, including any drafts of any environmental
document or portions thereof, which have been released for public review, and copies of
studies or other documents relied upon in any environmental document prepared for the
project and either made available to the public during the public review period or included
in the lead agency's files on the project, and all internal agency communications, including
staff notes and memoranda related to the project or to compliance with this division;
(xiii) The full written record before any inferior administrative decision-making body whose
decision was appealed to a superior administrative decision-making body prior to the filing
of litigation; and
(xiv) Any additional items not included above if otherwise required by law.
City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
CEQA Findings of Fact and Statement of Overriding Considerations
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Attachment A:
Mitigation Monitoring and Reporting Program
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WWW.FIRSTCARBONSOLUTIONS.COM
Mitigation Monitoring and Reporting Program
for the
General Plan Update, Zoning Code Amendments, and Climate
Action Plan
City of South San Francisco, San Mateo County, California
Prepared for:
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Report Date: September 6, 2022
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City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
Mitigation Monitoring and Reporting Program Preface
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PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section
15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP)
whenever it adopts an Environmental Impact Report (EIR) in conjunction with a project approval.
The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during
project implementation.
The Draft Program EIR prepared for the General Plan Update, Zoning Code Amendments, and
Climate Action Plan concluded that project implementation could result in potentially significant
effects on the environment and mitigation measures were incorporated into the proposed project or
are required as a condition of project approval that reduce these potential impacts to a less than
significant level. This MMRP documents how and when the mitigation measures adopted by the lead
agency will be implemented and confirms that potential environmental impacts are reduced to less
than significant levels as identified in the Draft Program EIR.
This document does not discuss those subjects that the environmental analysis demonstrates would
result in less than significant impacts and for which no mitigation was proposed or necessary.
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General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Table 1: General Plan Update, Zoning Code Amendments, and Climate Action Plan Project Mitigation Monitoring and Reporting Program
Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
3.2 Air Quality
MM AIR-1a: Individual development projects facilitated by
the proposed project shall incorporate the following Basic
Construction Mitigation Measures recommended by the Bay
Area Air Quality Management District (BAAQMD):
• All exposed surfaces (e.g., parking areas, staging areas, soil
piles, graded areas, and unpaved access roads) shall be
watered two times per day.
• All haul trucks transporting soil, sand, or other loose
material off-site shall be covered.
• All visible mud or dirt trackout 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.
• All vehicle speeds on unpaved roads shall be limited to 15
mph.
• 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.
• 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 [ATCM] Title 13, Section
2485 of the California Code of Regulations). Clear signage
shall be provided for construction workers at all access
points.
• All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a certified
Incorporation into
project construction
documents; the City of
South San Francisco
Planning Division shall
inspect the worksite
regularly to ensure the
mitigation measures are
implemented
Prior to issuance of
building permits for
individual projects
and ongoing
throughout
construction
City of South San
Francisco Planning
Division,
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
mechanic and determined to be running in proper
condition prior to operation.
• Prior to the commencement of construction activities,
individual project proponents shall 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 BAAQMD phone number shall also be visible to ensure
compliance with applicable regulations.
MM AIR-1b: Projects that may result in additional toxic air
contaminants (TACs) that are located within 1,000 feet of a
sensitive receptors(s) or would place sensitive receptors
within 1,000 feet of uses generating TACs, such as roadways
with volumes of 10,000 average annual daily trips or greater,
shall implement Bay Area Air Quality Management District
(BAAQMD) Guidelines and California Office of Environmental
Health Hazard Assessment (OEHHA) policies and procedures
requiring a Health Risk Assessments (HRA) for residential
development and other sensitive receptors. Screening area
distances may be increased on a case-by-case basis if an
unusually large source or sources of hazardous emissions are
proposed or currently exist. Based on the results of the HRA,
identify and implement measures (such as air filtration
systems) to reduce potential exposure to particulate matter,
carbon monoxide, diesel fumes, and other potential health
hazards. Measures identified in HRAs shall be included into
the site development plan as a component of a proposed
project.
Qualified air quality
specialist conducts an
HRA and identifies
mitigation measures;
incorporation of
mitigation measures into
the site development
plan; on-site inspection
Prior to plan check
review; during
construction
City of South San
Francisco Planning
Division
MM TRANS-1: Transportation Demand Management
To reduce Vehicle Miles Traveled (VMT), the City shall
implement its Transportation Demand Management (TDM)
Ordinance as part of the Zoning Code Amendments and
parking requirements. The City shall also update its TDM
Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
Ordinance and parking requirements every five to ten years
and establish an East of 101 Area Trip Cap, to achieve the
maximum feasible reductions in vehicle travel. The City shall
achieve the performance standards outlined in the TDM
Ordinance.
The City shall update its TDM Ordinance every 5 to 10 years
to limit Total VMT and Work-Based VMT by incentivizing use
of transit and active transportation and disincentivizing auto
use. The TDM Ordinance shall cover all development projects
generating greater than 100 daily trips, with the most
stringent requirements for office/Research and Development
(R&D) land uses that disproportionately account for the
highest rates of VMT in the City. Development projects shall
implement a combination of TDM programs, services, and
infrastructure improvements, including but not limited to:
establishing trip reduction programs; subsidizing transit and
active transportation use; coordinating carpooling and
vanpooling; encouraging telecommuting and flexible work
schedules; designing site plans to prioritize pedestrian,
bicycle, and transit travel; funding first/last mile shuttle
services; establishing site-specific trip caps; managing parking
supply; and constructing transit and active transportation
capital improvements. Developments shall be subject to
annual monitoring. The City shall establish an administrative
fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.
The City shall establish an East of 101 Area Trip Cap to
support the monitoring of vehicle trip activity and focus
efforts to reduce VMT. The area-wide trip cap shall apply to
the high density employment uses in the East of 101 Area.
The City shall conduct annual traffic counts along the cordon
area perimeter. Should the trip cap be reached, the City shall
establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
consider corrective actions such as: revising mode share
targets for projects subject to the TDM Ordinance, identifying
new funding measures for TDM services, implementing new
vehicle user charges, creating new street connections, or
slowing the pace of development approvals within the cordon
zone.
The City shall update its parking requirements every 5 to 10
years to align with its TDM Ordinance and East of 101 Area
Trip Cap. The City shall establish parking maximums for
office/R&D uses to ensure that VMT reduction goals are
incorporated into the design of development projects.
3.3 Biological Resources
MM BIO-1: Special-status Species, Migratory Birds, and
Nesting Birds
Special-status species are those listed as Endangered,
Threatened or Rare, or as Candidates for listing by the United
States Fish and Wildlife Service (USFWS) and/or California
Department of Fish and Wildlife (CDFW), or as Rare Plant
Rank 1B or 2B species by the California Native Plant Society
(CNPS). This designation also includes CDFW Species of
Special Concern and Fully Protected Species. Applicants or
sponsors of projects on sites where potential special-status
species, migratory birds, or nesting birds are present shall
retain a qualified Biologist to conduct a focused survey per
applicable regulatory agency protocols to determine whether
such species occur on a given project site. The project
applicant or sponsor shall ensure that, if development of
occupied habitat must occur, species impacts shall be avoided
or minimized, and if required by a regulatory agency or the
CEQA process, loss of wildlife habitat or individual plants shall
be fully compensated on the site. If off-site mitigation is
necessary, it shall occur within the South San Francisco
Planning Area whenever possible, with a priority given to
Pre-construction survey
by a qualified Biologist;
mitigation and
monitoring program (if
required) by a qualified
Biologist; submittal and
review of survey and
monitoring documents
Prior to
commencement of
grading and
construction
activities for
individual projects;
ongoing during
construction
City of South San
Francisco Planning
Division;
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 7
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
existing habitat mitigation banks. Habitat mitigation shall be
accompanied by a long-term management plan and
monitoring program prepared by a qualified Biologist, and
include provisions for protection of mitigation lands in
perpetuity through the establishment of easements and
adequate funding for maintenance and monitoring.
MM BIO-3: Assess Potential Wetland Impacts
Applicants or sponsors of projects on sites where potential
jurisdictional wetlands or waterways are present shall retain a
qualified Biologist/wetland regulatory specialist to conduct a
site investigation and assess whether wetland or waterway
features are jurisdictional with regard to the United States
Army Corps of Engineers (USACE), Regional Water Quality
Control Board (RWQCB), and/or California Department of Fish
and Wildlife (CDFW). This investigation shall include assessing
potential impacts to wetlands and other waters of the United
States and/or State. If a feature is found to be jurisdictional or
potentially jurisdictional, the project applicant or sponsor
shall comply with the appropriate permitting process with
each agency claiming jurisdiction prior to disturbance of the
feature, and a qualified Biologist/wetland regulatory
specialist shall conduct a detailed wetland delineation if
necessary.
Site investigation and
assessment by a
qualified Biologist;
submittal of
investigation and
assessment documents
Prior to issuance of
grading permit and
construction
activities for
individual projects
City of South San
Francisco Planning
Division
3.6 Geology, Soils, and Seismicity
MM GEO-6: Applicants, owners, and/or sponsors of all future
development or construction projects shall be required to
perform or provide paleontological monitoring for all
proposed excavations in the Colma Formation and Merced
Formation, including those buried in the shallow subsurface
below Quaternary deposits, due to the high paleontological
sensitivity for significant resources in these areas. Should
significant paleontological resources (e.g., bones, teeth, well-
preserved plant elements) be unearthed by the future project
Retention of a
professional
paleontologist; ongoing
monitoring
Prior to issuance of
grading permit for
individual projects.
Ongoing during
construction
activities
City of South San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 8
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
construction crew, the project activities shall be diverted at
least 15 feet from the discovered paleontological resources
until a professional vertebrate Paleontologist has assessed
such discovered resources and, if deemed significant, such
resources shall be salvaged in a timely manner. The
applicant/owner/sponsor of said project shall be responsible
for diverting project work and providing the assessment
including retaining a professional vertebrate Paleontologist
for such purpose. Collected fossils shall be deposited by the
applicant/owner/sponsor in an appropriate repository (e.g.,
University of California Museum of Paleontology (UCMP),
California Academy of Sciences) where the collection shall be
properly curated and made available for future research.
3.11 Noise and Vibration
MM NOI-1: Operational Noise Reduction Plan
Prior to issuance of building permits, the project applicant or
sponsor shall implement the following measures to limit on-
site operational stationary noise source impacts:
• Any proposed development projects that include parking
areas, terminals, or loading docks of commercial or
industrial land uses within 300-feet of a residential
receptor shall demonstrate compliance with Policies NOI-
1.1 and NOI-1.2 of the City’s Noise Element by submitting a
final acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to
adequately minimize the potential noise impacts of
vehicles on the site to adjacent land uses. The report must
be approved by the Planning Division prior to issuance of
building permits.
• For any future development project that would include
exterior mechanical systems (such as mechanical
ventilation systems) within 50 feet of a residential receptor,
the project applicant or sponsor shall submit a final
Implementation of
measures and submittal
and approval of final
acoustical report, when
applicable
Prior to issuance of
building permits for
individual projects
City of San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
acoustical report prepared to the satisfaction of the
Planning Division that demonstrates compliance of the
project with Policies NOI-1.1 and NOI-1.2 of the City’s
Noise Element. Noise reduction design features may
include, but are not limited to, locating stationary noise
sources on the site to be shielded by structures (buildings,
enclosures, or sound walls) or by using equipment that has
a quieter rating. The report must be approved by the
Planning Division prior to issuance of building permits.
MM NOI-3: Airport Noise Impact Reduction Plan
Prior to issuance of building permits, the project applicant or
sponsor of proposed development projects shall implement
the following measures to limit airport activity noise source
impacts:
• Any proposed residential development project or any
hotel, motel, or transient lodging land use development
project, that would be located within the San Francisco
International Airport (SFO) 65 A-weighted decibel (dBA)
Community Noise Equivalent Level (CNEL) noise contours,
shall demonstrate compliance with Policies NOI-1.1 and
NOI-1.2 of the City’s Noise Element by submitting a final
acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to
adequately minimize airport activity noise levels to meet
the interior noise level standards shown in Table 11 of the
Noise Element. Outdoor active use space must also comply
with the exterior noise standards of Table 11 of the Noise
Element or must be excluded from such projects. The
report must be approved by the Planning Division prior to
issuance of building permits.
• Any proposed commercial development project that would
be located within the SFO 70 dBA CNEL noise contours shall
demonstrate compliance with Policies NOI-1.1 and NOI-1.2
of the City’s Noise Element by submitting a final acoustical
Implementation of
measures and submittal
and approval of a final
acoustical report, when
applicable
Prior to the
issuance of building
permits for
individual projects
City of South San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
report prepared to the satisfaction of the Planning Division
that identifies design measures to adequately minimize
airport activity noise levels to meet the interior noise level
standards shown in Table 11 of the Noise Element. The
report must be approved by the Planning Division prior to
issuance of building permits.
• Any proposed institutional or public facility development
project that would be located within the SFO 65 dBA CNEL
noise contours shall demonstrate compliance with Policies
NOI-1.1 and NOI-1.2 of the City’s Noise Element by
submitting a final acoustical report prepared to the
satisfaction of the Planning Division that identifies design
measures to adequately minimize airport activity noise
levels to meet the interior noise level standards shown in
Table 11 of the Noise Element. Outdoor active use space
must also comply with the exterior noise standards of Table
11 of the Noise Element or must be excluded from such
projects. The report must be approved by the Planning
Division prior to issuance of building permits.
3.14 Transportation
MM TRANS-1: Transportation Demand Management
To reduce VMT, the City shall implement its Transportation
Demand Management (TDM) Ordinance as part of the Zoning
Code Amendments and parking requirements. The City shall
also update its TDM Ordinance and parking requirements
every five to ten years and establish an East of 101 Area Trip
Cap, to achieve the maximum feasible reductions in vehicle
travel. The City shall achieve the performance standards
outlined in the TDM Ordinance pursuant to Section
20.400.004 of the Zoning Ordinance.
The City shall review and update its TDM Ordinance every five
to ten years to limit Total VMT and Work-Based VMT by
incentivizing use of transit and active transportation and
Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
disincentivizing auto use. The TDM Ordinance shall cover all
development projects generating greater than 100 daily trips,
with the most stringent requirements for office/R&D land
uses that disproportionately account for the highest rates of
VMT in the City. Development projects shall implement a
combination of TDM programs (pursuant to Sections
20.400.003 and 20.400.004 of the Zoning Ordinance),
services, and infrastructure improvements, including but not
limited to: establishing trip reduction programs; subsidizing
transit and active transportation use; coordinating carpooling
and vanpooling; encouraging telecommuting and flexible
work schedules; designing site plans to prioritize pedestrian,
bicycle, and transit travel; funding first/last mile shuttle
services; establishing site-specific trip caps; managing parking
supply; and constructing transit and active transportation
capital improvements. Developments shall be subject to
annual reporting and monitoring. The City shall establish a
fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.
The City shall establish an East of 101 Area Trip Cap to
support the monitoring of vehicle trip activity and focus
efforts to reduce VMT. The area-wide trip cap shall apply to
the high intensity employment uses in the East of 101 Area.
The City shall conduct annual traffic counts along the cordon
area perimeter. Should the trip cap be reached, the City shall
consider corrective actions such as: revising mode share
targets for projects subject to the TDM Ordinance, identifying
new funding measures for TDM services, implementing new
vehicle user charges, creating new street connections, or
slowing the pace of development approvals within the cordon
zone.
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
The City shall review and update its parking requirements
every five to ten years to align with its TDM Ordinance and
East of 101 Area Trip Cap. The City shall establish parking
maximums for office/R&D uses to ensure that VMT reduction
goals are incorporated into the design of development
projects.
MM TRANS-4: Freeway Offramp Queue Improvements
To minimize queueing hazards, the City shall work with
Caltrans to develop improvement measures for freeway off-
ramps and adjacent intersections that help manage offramp
queues. These measures may include geometric changes,
changes to signal timing and phasing, and new connections as
identified in Table 3.14-5. Such improvement measures shall
not adversely affect pedestrian, bicycle, and transit conditions
or otherwise undermine the City’s VMT mitigation efforts
described in MM TRANS-1. MM TRANS-1 is also applicable
here and should be implemented to minimize freeway
offramp queues.
Development of
improvement measures.
Documentation in the
General Plan progress
report.
Ongoing.
Consultation with
Caltrans to initiate
within a year of
adoption of General
Plan Update.
City of South San
Francisco Planning
Division, Caltrans
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WWW.FIRSTCARBONSOLUTIONS.COM
Mitigation Monitoring and Reporting Program
for the
General Plan Update, Zoning Code Amendments, and Climate
Action Plan
City of South San Francisco, San Mateo County, California
Prepared for:
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Report Date: September 6, 2022
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City of South San Francisco–General Plan Update, Zoning Code Amendments, and Climate Action Plan
Mitigation Monitoring and Reporting Program Preface
FirstCarbon Solutions 1
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PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines Section
15097 require a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP)
whenever it adopts an Environmental Impact Report (EIR) in conjunction with a project approval.
The purpose of the MMRP is to ensure compliance with the mitigation measures occurs during
project implementation.
The Draft Program EIR prepared for the General Plan Update, Zoning Code Amendments, and
Climate Action Plan concluded that project implementation could result in potentially significant
effects on the environment and mitigation measures were incorporated into the proposed project or
are required as a condition of project approval that reduce these potential impacts to a less than
significant level. This MMRP documents how and when the mitigation measures adopted by the lead
agency will be implemented and confirms that potential environmental impacts are reduced to less
than significant levels as identified in the Draft Program EIR.
This document does not discuss those subjects that the environmental analysis demonstrates would
result in less than significant impacts and for which no mitigation was proposed or necessary.
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City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 3
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Table 1: General Plan Update, Zoning Code Amendments, and Climate Action Plan Project Mitigation Monitoring and Reporting Program
Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
3.2 Air Quality
MM AIR-1a: Individual development projects facilitated by
the proposed project shall incorporate the following Basic
Construction Mitigation Measures recommended by the Bay
Area Air Quality Management District (BAAQMD):
• All exposed surfaces (e.g., parking areas, staging areas, soil
piles, graded areas, and unpaved access roads) shall be
watered two times per day.
• All haul trucks transporting soil, sand, or other loose
material off-site shall be covered.
• All visible mud or dirt trackout 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.
• All vehicle speeds on unpaved roads shall be limited to 15
mph.
• 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.
• 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 [ATCM] Title 13, Section
2485 of the California Code of Regulations). Clear signage
shall be provided for construction workers at all access
points.
• All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a certified
Incorporation into
project construction
documents; the City of
South San Francisco
Planning Division shall
inspect the worksite
regularly to ensure the
mitigation measures are
implemented
Prior to issuance of
building permits for
individual projects
and ongoing
throughout
construction
City of South San
Francisco Planning
Division,
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 4
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
mechanic and determined to be running in proper
condition prior to operation.
• Prior to the commencement of construction activities,
individual project proponents shall 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 BAAQMD phone number shall also be visible to ensure
compliance with applicable regulations.
MM AIR-1b: Projects that may result in additional toxic air
contaminants (TACs) that are located within 1,000 feet of a
sensitive receptors(s) or would place sensitive receptors
within 1,000 feet of uses generating TACs, such as roadways
with volumes of 10,000 average annual daily trips or greater,
shall implement Bay Area Air Quality Management District
(BAAQMD) Guidelines and California Office of Environmental
Health Hazard Assessment (OEHHA) policies and procedures
requiring a Health Risk Assessments (HRA) for residential
development and other sensitive receptors. Screening area
distances may be increased on a case-by-case basis if an
unusually large source or sources of hazardous emissions are
proposed or currently exist. Based on the results of the HRA,
identify and implement measures (such as air filtration
systems) to reduce potential exposure to particulate matter,
carbon monoxide, diesel fumes, and other potential health
hazards. Measures identified in HRAs shall be included into
the site development plan as a component of a proposed
project.
Qualified air quality
specialist conducts an
HRA and identifies
mitigation measures;
incorporation of
mitigation measures into
the site development
plan; on-site inspection
Prior to plan check
review; during
construction
City of South San
Francisco Planning
Division
MM TRANS-1: Transportation Demand Management
To reduce Vehicle Miles Traveled (VMT), the City shall
implement its Transportation Demand Management (TDM)
Ordinance as part of the Zoning Code Amendments and
parking requirements. The City shall also update its TDM
Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 5
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
Ordinance and parking requirements every five to ten years
and establish an East of 101 Area Trip Cap, to achieve the
maximum feasible reductions in vehicle travel. The City shall
achieve the performance standards outlined in the TDM
Ordinance.
The City shall update its TDM Ordinance every 5 to 10 years
to limit Total VMT and Work-Based VMT by incentivizing use
of transit and active transportation and disincentivizing auto
use. The TDM Ordinance shall cover all development projects
generating greater than 100 daily trips, with the most
stringent requirements for office/Research and Development
(R&D) land uses that disproportionately account for the
highest rates of VMT in the City. Development projects shall
implement a combination of TDM programs, services, and
infrastructure improvements, including but not limited to:
establishing trip reduction programs; subsidizing transit and
active transportation use; coordinating carpooling and
vanpooling; encouraging telecommuting and flexible work
schedules; designing site plans to prioritize pedestrian,
bicycle, and transit travel; funding first/last mile shuttle
services; establishing site-specific trip caps; managing parking
supply; and constructing transit and active transportation
capital improvements. Developments shall be subject to
annual monitoring. The City shall establish an administrative
fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.
The City shall establish an East of 101 Area Trip Cap to
support the monitoring of vehicle trip activity and focus
efforts to reduce VMT. The area-wide trip cap shall apply to
the high density employment uses in the East of 101 Area.
The City shall conduct annual traffic counts along the cordon
area perimeter. Should the trip cap be reached, the City shall
establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 6
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
consider corrective actions such as: revising mode share
targets for projects subject to the TDM Ordinance, identifying
new funding measures for TDM services, implementing new
vehicle user charges, creating new street connections, or
slowing the pace of development approvals within the cordon
zone.
The City shall update its parking requirements every 5 to 10
years to align with its TDM Ordinance and East of 101 Area
Trip Cap. The City shall establish parking maximums for
office/R&D uses to ensure that VMT reduction goals are
incorporated into the design of development projects.
3.3 Biological Resources
MM BIO-1: Special-status Species, Migratory Birds, and
Nesting Birds
Special-status species are those listed as Endangered,
Threatened or Rare, or as Candidates for listing by the United
States Fish and Wildlife Service (USFWS) and/or California
Department of Fish and Wildlife (CDFW), or as Rare Plant
Rank 1B or 2B species by the California Native Plant Society
(CNPS). This designation also includes CDFW Species of
Special Concern and Fully Protected Species. Applicants or
sponsors of projects on sites where potential special-status
species, migratory birds, or nesting birds are present shall
retain a qualified Biologist to conduct a focused survey per
applicable regulatory agency protocols to determine whether
such species occur on a given project site. The project
applicant or sponsor shall ensure that, if development of
occupied habitat must occur, species impacts shall be avoided
or minimized, and if required by a regulatory agency or the
CEQA process, loss of wildlife habitat or individual plants shall
be fully compensated on the site. If off-site mitigation is
necessary, it shall occur within the South San Francisco
Planning Area whenever possible, with a priority given to
Pre-construction survey
by a qualified Biologist;
mitigation and
monitoring program (if
required) by a qualified
Biologist; submittal and
review of survey and
monitoring documents
Prior to
commencement of
grading and
construction
activities for
individual projects;
ongoing during
construction
City of South San
Francisco Planning
Division;
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 7
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
existing habitat mitigation banks. Habitat mitigation shall be
accompanied by a long-term management plan and
monitoring program prepared by a qualified Biologist, and
include provisions for protection of mitigation lands in
perpetuity through the establishment of easements and
adequate funding for maintenance and monitoring.
MM BIO-3: Assess Potential Wetland Impacts
Applicants or sponsors of projects on sites where potential
jurisdictional wetlands or waterways are present shall retain a
qualified Biologist/wetland regulatory specialist to conduct a
site investigation and assess whether wetland or waterway
features are jurisdictional with regard to the United States
Army Corps of Engineers (USACE), Regional Water Quality
Control Board (RWQCB), and/or California Department of Fish
and Wildlife (CDFW). This investigation shall include assessing
potential impacts to wetlands and other waters of the United
States and/or State. If a feature is found to be jurisdictional or
potentially jurisdictional, the project applicant or sponsor
shall comply with the appropriate permitting process with
each agency claiming jurisdiction prior to disturbance of the
feature, and a qualified Biologist/wetland regulatory
specialist shall conduct a detailed wetland delineation if
necessary.
Site investigation and
assessment by a
qualified Biologist;
submittal of
investigation and
assessment documents
Prior to issuance of
grading permit and
construction
activities for
individual projects
City of South San
Francisco Planning
Division
3.6 Geology, Soils, and Seismicity
MM GEO-6: Applicants, owners, and/or sponsors of all future
development or construction projects shall be required to
perform or provide paleontological monitoring for all
proposed excavations in the Colma Formation and Merced
Formation, including those buried in the shallow subsurface
below Quaternary deposits, due to the high paleontological
sensitivity for significant resources in these areas. Should
significant paleontological resources (e.g., bones, teeth, well-
preserved plant elements) be unearthed by the future project
Retention of a
professional
paleontologist; ongoing
monitoring
Prior to issuance of
grading permit for
individual projects.
Ongoing during
construction
activities
City of South San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 8
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
construction crew, the project activities shall be diverted at
least 15 feet from the discovered paleontological resources
until a professional vertebrate Paleontologist has assessed
such discovered resources and, if deemed significant, such
resources shall be salvaged in a timely manner. The
applicant/owner/sponsor of said project shall be responsible
for diverting project work and providing the assessment
including retaining a professional vertebrate Paleontologist
for such purpose. Collected fossils shall be deposited by the
applicant/owner/sponsor in an appropriate repository (e.g.,
University of California Museum of Paleontology (UCMP),
California Academy of Sciences) where the collection shall be
properly curated and made available for future research.
3.11 Noise and Vibration
MM NOI-1: Operational Noise Reduction Plan
Prior to issuance of building permits, the project applicant or
sponsor shall implement the following measures to limit on-
site operational stationary noise source impacts:
• Any proposed development projects that include parking
areas, terminals, or loading docks of commercial or
industrial land uses within 300-feet of a residential
receptor shall demonstrate compliance with Policies NOI-
1.1 and NOI-1.2 of the City’s Noise Element by submitting a
final acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to
adequately minimize the potential noise impacts of
vehicles on the site to adjacent land uses. The report must
be approved by the Planning Division prior to issuance of
building permits.
• For any future development project that would include
exterior mechanical systems (such as mechanical
ventilation systems) within 50 feet of a residential receptor,
the project applicant or sponsor shall submit a final
Implementation of
measures and submittal
and approval of final
acoustical report, when
applicable
Prior to issuance of
building permits for
individual projects
City of San
Francisco Planning
Division
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
FirstCarbon Solutions 9
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
Verification
Verification of Completion
Date Initial
acoustical report prepared to the satisfaction of the
Planning Division that demonstrates compliance of the
project with Policies NOI-1.1 and NOI-1.2 of the City’s
Noise Element. Noise reduction design features may
include, but are not limited to, locating stationary noise
sources on the site to be shielded by structures (buildings,
enclosures, or sound walls) or by using equipment that has
a quieter rating. The report must be approved by the
Planning Division prior to issuance of building permits.
MM NOI-3: Airport Noise Impact Reduction Plan
Prior to issuance of building permits, the project applicant or
sponsor of proposed development projects shall implement
the following measures to limit airport activity noise source
impacts:
• Any proposed residential development project or any
hotel, motel, or transient lodging land use development
project, that would be located within the San Francisco
International Airport (SFO) 65 A-weighted decibel (dBA)
Community Noise Equivalent Level (CNEL) noise contours,
shall demonstrate compliance with Policies NOI-1.1 and
NOI-1.2 of the City’s Noise Element by submitting a final
acoustical report prepared to the satisfaction of the
Planning Division that identifies design measures to
adequately minimize airport activity noise levels to meet
the interior noise level standards shown in Table 11 of the
Noise Element. Outdoor active use space must also comply
with the exterior noise standards of Table 11 of the Noise
Element or must be excluded from such projects. The
report must be approved by the Planning Division prior to
issuance of building permits.
• Any proposed commercial development project that would
be located within the SFO 70 dBA CNEL noise contours shall
demonstrate compliance with Policies NOI-1.1 and NOI-1.2
of the City’s Noise Element by submitting a final acoustical
Implementation of
measures and submittal
and approval of a final
acoustical report, when
applicable
Prior to the
issuance of building
permits for
individual projects
City of South San
Francisco Planning
Division
City of South San Francisco
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Responsible for
Verification
Verification of Completion
Date Initial
report prepared to the satisfaction of the Planning Division
that identifies design measures to adequately minimize
airport activity noise levels to meet the interior noise level
standards shown in Table 11 of the Noise Element. The
report must be approved by the Planning Division prior to
issuance of building permits.
• Any proposed institutional or public facility development
project that would be located within the SFO 65 dBA CNEL
noise contours shall demonstrate compliance with Policies
NOI-1.1 and NOI-1.2 of the City’s Noise Element by
submitting a final acoustical report prepared to the
satisfaction of the Planning Division that identifies design
measures to adequately minimize airport activity noise
levels to meet the interior noise level standards shown in
Table 11 of the Noise Element. Outdoor active use space
must also comply with the exterior noise standards of Table
11 of the Noise Element or must be excluded from such
projects. The report must be approved by the Planning
Division prior to issuance of building permits.
3.14 Transportation
MM TRANS-1: Transportation Demand Management
To reduce VMT, the City shall implement its Transportation
Demand Management (TDM) Ordinance as part of the Zoning
Code Amendments and parking requirements. The City shall
also update its TDM Ordinance and parking requirements
every five to ten years and establish an East of 101 Area Trip
Cap, to achieve the maximum feasible reductions in vehicle
travel. The City shall achieve the performance standards
outlined in the TDM Ordinance pursuant to Section
20.400.004 of the Zoning Ordinance.
The City shall review and update its TDM Ordinance every five
to ten years to limit Total VMT and Work-Based VMT by
incentivizing use of transit and active transportation and
Implementation of TDM
Ordinances; review and
update of TDM
Ordinances and parking
requirements;
establishment of an East
of 101 Area Trip Cap;
achievement of
performance standards
outlined in the TDM
Ordinance
Review and update
of TDM Ordinances
and parking
requirements:
every 5 to 10 years
City of South San
Francisco
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
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Verification of Completion
Date Initial
disincentivizing auto use. The TDM Ordinance shall cover all
development projects generating greater than 100 daily trips,
with the most stringent requirements for office/R&D land
uses that disproportionately account for the highest rates of
VMT in the City. Development projects shall implement a
combination of TDM programs (pursuant to Sections
20.400.003 and 20.400.004 of the Zoning Ordinance),
services, and infrastructure improvements, including but not
limited to: establishing trip reduction programs; subsidizing
transit and active transportation use; coordinating carpooling
and vanpooling; encouraging telecommuting and flexible
work schedules; designing site plans to prioritize pedestrian,
bicycle, and transit travel; funding first/last mile shuttle
services; establishing site-specific trip caps; managing parking
supply; and constructing transit and active transportation
capital improvements. Developments shall be subject to
annual reporting and monitoring. The City shall establish a
fine structure for developments found to be out of
compliance and apply any revenues from fines to
infrastructure and services aimed at reducing VMT.
The City shall establish an East of 101 Area Trip Cap to
support the monitoring of vehicle trip activity and focus
efforts to reduce VMT. The area-wide trip cap shall apply to
the high intensity employment uses in the East of 101 Area.
The City shall conduct annual traffic counts along the cordon
area perimeter. Should the trip cap be reached, the City shall
consider corrective actions such as: revising mode share
targets for projects subject to the TDM Ordinance, identifying
new funding measures for TDM services, implementing new
vehicle user charges, creating new street connections, or
slowing the pace of development approvals within the cordon
zone.
City of South San Francisco
General Plan Update, Zoning Code Amendments, and Climate Action Plan Mitigation Monitoring and Reporting Program
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Mitigation Measures Method of Verification Timing of Verification
Responsible for
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Verification of Completion
Date Initial
The City shall review and update its parking requirements
every five to ten years to align with its TDM Ordinance and
East of 101 Area Trip Cap. The City shall establish parking
maximums for office/R&D uses to ensure that VMT reduction
goals are incorporated into the design of development
projects.
MM TRANS-4: Freeway Offramp Queue Improvements
To minimize queueing hazards, the City shall work with
Caltrans to develop improvement measures for freeway off-
ramps and adjacent intersections that help manage offramp
queues. These measures may include geometric changes,
changes to signal timing and phasing, and new connections as
identified in Table 3.14-5. Such improvement measures shall
not adversely affect pedestrian, bicycle, and transit conditions
or otherwise undermine the City’s VMT mitigation efforts
described in MM TRANS-1. MM TRANS-1 is also applicable
here and should be implemented to minimize freeway
offramp queues.
Development of
improvement measures.
Documentation in the
General Plan progress
report.
Ongoing.
Consultation with
Caltrans to initiate
within a year of
adoption of General
Plan Update.
City of South San
Francisco Planning
Division, Caltrans
NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
FINAL
Environmental Impact Report
General Plan Update, Zoning Code Amendments, and Climate Action Plan
City of South San Francisco, San Mateo County, California
State Clearinghouse Number 2021020064
Prepared for:
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
650.877.8535
Contact: Billy Gross, Senior Planner
Prepared by:
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Date: September 6, 2022
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Final EIR Table of Contents
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Table of Contents
Section 1: Introduction ............................................................................................................... 1-1
Section 2: Responses to Written Comments ................................................................................ 2-1
2.1 - List of Authors ................................................................................................................ 2-1
2.2 - Responses to Comments ................................................................................................ 2-1
Section 3: Errata.......................................................................................................................... 3-1
3.1 - Changes in Response to Specific Comments .................................................................. 3-1
Attachment A: Updated Exhibits
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Final EIR Introduction
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SECTION 1: INTRODUCTION
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of
South San Francisco (Lead Agency) has evaluated the comments received on the General Plan
Update, Zoning Code Amendments, and Climate Action Plan Draft Program Environmental Impact
Report (Draft Program EIR). Pursuant to CEQA Guidelines Section 15132, this Final EIR includes a list
of persons, organizations, and agencies that provided comments on the Draft Program EIR;
responses to the comments received regarding the Draft Program EIR; and errata, or revisions to the
Draft Program EIR; as well as a Mitigation Monitoring and Reporting Program (MMRP) for use by the
City of South San Francisco during its review.
This document is organized into three sections:
• Section 1—Introduction. Provides an introduction to the Final EIR.
• Section 2—Responses to Written Comments. Provides a list of the agencies, organizations,
and individuals who commented on the Draft EIR. Copies of all of the letters received
regarding the Draft EIR and responses thereto are included in this section.
• Section 3—Errata. Includes an addendum listing refinements and clarifications on the Draft
EIR, which have been incorporated.
The Final EIR includes the following contents:
• Draft Program EIR (provided under separate cover)
• Draft Program EIR Appendices (provided under separate cover)
• Responses to Written Comments on the Draft Program EIR and Errata (Sections 2 and 3 of this
document)
• Mitigation Monitoring and Reporting Program (MMRP) (provided under separate cover)
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SECTION 2: RESPONSES TO WRITTEN COMMENTS
2.1 - List of Authors
A list of public agencies, organizations, and individuals that provided comments on the City of South
San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan Draft Program
Environmental Impact Report (Draft Program EIR) is presented below. Each comment has been
assigned a code. Individual comments within each communication have been numbered so
comments can be crossed-referenced with responses. Following this list, the text of the
communication is reprinted and followed by the corresponding response.
Author Author Code
State Agencies
California Department of Transportation .................................................................................... Caltrans
California Geological Survey ............................................................................................................... CGS
Local Agencies
San Francisco International Airport .................................................................................................... SFO
Individuals
Buchalter ............................................................................................................................... BUCHALTER
2.2 - Responses to Comments
2.2.1 - Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the
City of South San Francisco, as the Lead Agency, evaluated the comments received on the Draft
Program EIR (State Clearinghouse No. 2021020064) for the General Plan Update, Zoning Code
Amendments, and Climate Action Plan, and has prepared the following responses to the comments
received. Section 15088(c) of the State CEQA Guidelines specifies that the focus of the responses to
comments shall be on the disposition of significant environmental issues. Responses to comments
regarding the merits of the project or on issues unrelated to the project’s environmental impacts are
not required. Accordingly, such comments are summarized and noted in the responses and will be
reviewed by the City before any action by decision makers.
This Response to Comments document becomes part of the Final EIR for the project in accordance
with CEQA Guidelines Section 15132.
2.2.2 - Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used in the
List of Authors.
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“Provide a safe and reliable transportation network that serves all people and respects the environment”
DISTRICT 4
OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
August 9, 2022 SCH #: 2021020064
GTS #: 04-SM-2021-00446
GTS ID: 21933
Co/Rt/Pm: SM/101/22.022
Billy Gross, Principal Planner
315 Maple Avenue
South San Francisco, CA 94083
Re: South San Francisco General Plan Update, Zoning Code Amendments, and Climate
Action Plan Program Environmental Impact Report
Dear Billy Gross:
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the General Plan Update, Zoning Code
Amendments and Climate Action Plan Project. We are committed to ensuring that
impacts to the State’s multimodal transportation system and to our natural
environment are identified and mitigated to support a safe, sustainable, integrated,
and efficient transportation system. The following comments are based on our review
of the July 2022 draft EIR.
Project Understanding
The proposed project includes the implementation of the South San Francisco General
Plan Update, Zoning Code Amendments, and Climate Action Plan which are
collectively referred to as the proposed project in this document. The General Plan
Update anticipates approximately 14,312 net new housing units and approximately
42,297 net new employment opportunities by 2040. The Proposed Land Use Map
designates the general location, distribution, and extent of land uses within the
Planning Area and identifies proposed land use designations for each parcel within
the City of South San Francisco and within the City’s SOI. The updated 2022 Climate
Action Plan (CAP) includes a community-wide inventory of greenhouse gas (GHG)
emissions and identifies strategies and measures to reduce GHG emissions generated
by existing and future uses in the City.
Caltrans
Page 1 of 3
Billy Gross, Principal Planner
August 9, 2022
Page 2
“Provide a safe and reliable transportation network that serves all people and respects the environment”
Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient
development patterns, innovative travel demand reduction strategies, and
multimodal improvements. For more information on how Caltrans assesses
Transportation Impact Studies, please review Caltrans’ Transportation Impact Study
Guide (link).
Caltrans’ acknowledges that the project Vehicle Miles Traveled (VMT) analysis and
significance determination are undertaken in a manner consistent with the Office of
Planning and Research’s (OPR) Technical Advisory. However, due to the increased
amount of projected vehicle miles traveled, this project will have significant and
unavoidable impacts to the transportation network as indicated in the environmental
document. The Plan presents an expected jobs to housing ratio of 3.53 by 2040. This
jobs to housing ratio results in greater VMT and greenhouse gas emissions and may
negatively impact local and State climate goals and the transportation network.
Increasing the housing development in the two Priority Development Areas of the City
(the Downtown PDA and the El Camino Real PDA) can support lower VMT and
mitigate impacts from the Plan.
Active Transportation
Class IV facilities, along with Class I paths, are typically the lowest-stress facilities for
users of all ages and abilities. It is noted that the City currently has 0 miles of Class IV
facilities. While the City emphasizes low-stress active transportation networks and
connectivity in this project, Caltrans encourages prioritizing the implementation of a
network of low-stress bikeways so that this number increases. Prioritization and target
build horizons of Class IV facilities should be included in both policy and action in this
General Plan update. Please reach out to Caltrans for coordination as needed to
support this implementation.
MOB-4.1.4 and MOB-4.2 mention incorporating first/last-mile connections and micro-
mobility as an innovation where feasible. Caltrans encourages a more robust
prioritization of micro-mobility, which may realize more mitigation of projected VMT
impacts. Scooters, bikeshare, e-bikes, e-mopeds, and infrastructure to store, dock, and
support these devices can successfully shift users from single occupancy vehicle trips
to non-polluting transportation modes. As with all transport, a well-established multi-
modal network provides compounding positive effects. Caltrans encourages multi-
modal goals, policies and projects that support safe and equitable access for all users,
motorized and non-motorized, within the City’s travelshed. By emphasizing micro-
mobility, low-stress bikeways, and a lower jobs to housing ratio, it will help mitigate
negative impacts of the projected VMT increases.
Caltrans
Page 2 of 3
Billy Gross, Principal Planner
August 9, 2022
Page 3
“Provide a safe and reliable transportation network that serves all people and respects the environment”
Transportation Operations
Caltrans appreciates the City working with Caltrans to develop improvement
measures for freeway off-ramps and adjacent intersections that help manage offramp
queues related to safety. When conducting safety reviews for proposed land use
projects and plans affecting the State Highway System, please refer to the Caltrans
Traffic Safety Bulletin.
Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet
American Disabilities Act (ADA) Standards after project completion. As well, the
project must maintain bicycle and pedestrian access during construction. These
access considerations support Caltrans’ equity mission to provide a safe, sustainable,
and equitable transportation network for all users.
Thank you again for including Caltrans in the environmental review process. Should
you have any questions regarding this letter, or for future notifications and requests for
review of new projects, please email LDR-D4@dot.ca.gov.
Sincerely,
MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
Caltrans
Page 1 of 3
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State Agencies
California Department of Transportation (Caltrans)
Response to Caltrans-1
The commenter provides general introductory remarks and does not raise any environmental issues.
No response is required.
Response to Caltrans-2
The commenter provides general information about the analysis of Vehicle Miles Traveled (VMT) and
does not raise any environmental issues. No response is required.
Response to Caltrans-3
The commenter acknowledges that the Draft Program EIR provided VMT analysis consistent with the
Governor’s Office of Planning and Research (OPR) Technical Advisory. No response is required.
Response to Caltrans-4
The commenter notes that the Draft Program EIR identifies a significant and unavoidable VMT
impact, and suggests that increasing housing development in the two Priority Development Areas in
the City can support lower VMT that would mitigate this impact.
Comment is noted. The General Plan would increase the allowable area of housing in both Priority
Areas, adding allowances for mixed use, as well as the addition of approximately 10,000 housing
units.
Through an extensive community engagement process that included over 75 public meetings, the
General Plan created a land use plan that aimed to:
• Retain life science uses that will ensure South San Francisco will remain a world class life
sciences destination and an economic engine for the region.
• Produce a range of housing types for different income levels and household types across the
City to balance job and housing growth and distribute the potential impacts of future growth.
• Maintain industrial uses in Lindenville and East of 101 Area.
The General Plan and EIR allows up to 14,312 net new housing units within the General Plan 2040
time horizon, representing a 63 percent increase in housing units in the City (22,877 housing units in
2022 per California Department of Finance). Along with new housing opportunities along El Camino
near the South San Francisco Bay Area Rapid Transit (BART) station and Downtown near the South
San Francisco Caltrain Station, the General Plan establishes new, mixed-use residential
neighborhoods in East of 101 and Lindenville. These areas allow for a mix of high-density residential
and commercial uses. Since these areas did not previously allow residential development, the
General Plan also ensures development of appropriate City services, amenities, and retail to support
new residential growth.
To support this effort and the implementation of mixed-use communities, the City launched a
Specific Plan for Lindenville earlier this year as a follow-up implementation action in the General Plan
(SA-22.1.1). The Specific Plan aims to help realize the General Plan’s vision for the area with the
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Responses to Written Comments Administrative Final EIR
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development of more detailed design standards, implementation programs, and capital
improvements to successfully create residential neighborhoods in a historically industrial area.
Response to Caltrans-5
The commenter provides information about Class IV bikeway facilities and encourages the City to
prioritize the implementation of a network of low-stress bikeways as part of the General Plan
Update.
The comment is noted, and the City agrees with the need for more Class IV facilities. As noted in the
General Plan Update, the proposed project encourages implementation of the Active South City
Plan, which focuses on a number of new bikeway facilities including Class IV facilities.
Response to Caltrans-6
The commenter provides information about first/last-mile connections and encourages the City to
prioritize micro-mobility and multimodal goals, policies and projects to help mitigate the negative
impacts of the projected VMT increases.
The comment is noted, and the City agrees with the need for more micro-mobility facilities. As noted
in the comment, MOB 2.1.3 directs the City to implement the Active South City Pedestrian and
Bicycle Plan. This Plan is the City’s roadmap to encouraging use of and designing facilities for micro-
mobility devices, which have overlap with bicycle and pedestrian facilities.
Response to Caltrans-7
The commenter expresses appreciation for the City in working with Caltrans to develop
improvement measures for freeway off-ramps and adjacent intersections, and provides a link to the
Caltrans Traffic Safety Bulletin.
The comment is noted; no response is required.
Response to Caltrans-8
The commenter notes that the project must maintain bicycle and pedestrian access during
construction and that any Caltrans facilities affected by the project must meet Americans with
Disabilities Act (ADA) standards after project construction.
The comment does not identify any significant environmental issues or raise questions regarding the
analysis in the Draft Program EIR. The City intends to maintain bike and pedestrian access
throughout construction. No further response is required.
Response to Caltrans-9
The commenter provides closing remarks and contact information. No response is required.
From: "Frost, Erik@DOC" <Erik.Frost@conservation.ca.gov>
Date: August 9, 2022 at 10:56:57 AM MDT
To: "Gross, Billy" <Billy.Gross@ssf.net>
Cc: OLRA@conservation.ca.gov, OPR State Clearinghouse <State.Clearinghouse@opr.ca.gov>
Subject: City of South San Francisco General Plan Update (SCH 2021020064) - CGS comments
[NOTICE: This message originated outside of City of South San Francisco -- DO NOT CLICK on links or
open attachments unless you are sure the content is safe.]
Mr. Gross,
The California Geological Survey (CGS) has received the Notice of Availability of a Program
Environmental Impact Report (EIR) for the proposed South San Francisco General Plan Update. This
email conveys the following recommendations from CGS concerning geologic issues related to the
subject area:
1. Liquefaction and Landslide Hazards
On September 23, 2021, the CGS released an Official Seismic Hazard Zone Report (SHZR) and
Earthquake Zone of Required Investigation Map (EZRIM) for the San Francisco South
quadrangle, which includes the subject area. Although the EIR does appear to accurately reflect
the extent of Earthquake Zones of Require Investigation (EZRI) for liquefaction in Exhibit 3.6-5,
the EZRI for landslides do not match those published by the CGS. The EIR text should be revised
to note that zone of required investigation for liquefaction and landsliding are mapped within
the City, and Exhibit 3.6-4 should be revised based on information in the links below:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=regulatorymaps
Cities and counties affected by EZRI must regulate certain development projects within them.
The Seismic Hazards Mapping Act (1990) also requires sellers of real property (and their agents)
to disclose at the time of sale that the property lies within such a zone.
If you have any additional comments or questions, please feel free to call or email.
Erik
Dr. Erik Frost
Senior Engineering Geologist | Seismic Hazards Program
California Geological Survey
715 P Street, MS 1901, Sacramento, CA 95814
(916) 205-825 5
erik.frost@conservation.ca.gov
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California Geological Survey (CGS)
Response to CGS-1
The commenter provides a link to mapping for liquefaction and landslide hazards, and asks that
Exhibit 3.6-4 and Exhibit 3.6-5 be revised accordingly.
The comment is noted, and the updated Exhibit 3.6-4 and Exhibit 3.6-5 are included in Section 3,
Errata. The updated exhibits do not change the analysis or conclusions of the Draft Program EIR.
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August 9, 2022
Billy Gross, Principal Planner TRANSMITTED VIA E-MAIL and U.S. MAIL
City of South San Francisco billy.gross@ssf.net
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Comment Letter: Draft Program Environmental Impact Report for Proposed
South San Francisco General Plan Update, Zoning Code Amendments, and
Climate Action Plan
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the
preparation of a Draft Program Environmental Impact Report (Program EIR) for the proposed South
San Francisco General Plan Update, Zoning Code Amendments, and Climate Action Plan (the
Proposed Project). We appreciate this opportunity to coordinate with the City of South San
Francisco (the City) in considering potential land use compatibility issues that the Proposed Project
may pose and should address.
As described in the Draft Program EIR, the project site is the geographic limits of the City, in San
Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with,
City and County of San Francisco/SFO property boundaries. The City is primarily residential, with
this use occupying approximately 40% of its land area, followed by industrial/research and
development at approximately 30%, and parks/open space/common greens at approximately 10%.
The Proposed Project would serve as a blueprint for the City’s vision through the year 2040 and
would replace the 1999 General Plan and inform updates to the City’s Zoning Ordinance.
The Airport’s specific comments regarding Draft Program EIR are noted below:
1. NOISE COMPATIBILITY
The Airport is concerned that much of the land slated for zoning changes is closer to the Airport
than the previous General Plan’s housing element, and portions of the proposed mixed-use
residential zones are within the Airport’s runway safety zone boundaries and 65 decibel (dB)
Community Noise Equivalent Level (CNEL) noise contour. We expressed concern about this issue
in our March 22, 2021 comment letter, which is attached hereto as Exhibit A (and incorporated by
reference.). In the 1999 General Plan, the City acknowledged the significance of and retained areas
east of U.S. 101 for cargo handling and freight forwarder uses that support the cargo operations of
companies using SFO. The Airport appreciates that in the intervening years, the City has
successfully maintained these land uses east of U.S. 101, which enhance and support the
relationship among the City, its residents, and the Airport, and supports the City and regional
economy. These existing compatible land uses east of U.S. 101 include industrial, warehousing,
hotels, and office/research & development. The Airport cautions against the Proposed Project’s
departure from this successful practice.
DocuSign Envelope ID: 58D5020A-9B73-4360-921E-A37F27534F74
Billy Gross, City of South San Francisco
August 9, 2022
Page 2 of 4
The Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco
International Airport (SFO ALUCP) policies for noise are to protect the comfort and quality of life
of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher
contours. The Draft Program EIR identifies in Impact HAZ-5 that the General Plan Policy SA-12.6
requires the City to encourage residential development in the South Spruce area that is within the 65
dB CNEL, provided that the structure meets the standard indoor 45 dB noise requirement. This
impact statement does not acknowledge that the SFO ALUCP also requires the grant of an avigation
easement to the City and County of San Francisco, as the proprietor of SFO, as a condition of
allowing residential development within the 65 dB CNEL contour.1 At a minimum, the requirement
for granting an avigation easement should be included in Impact HAZ-5 in determining the level of
significance. Impact LUP-2 also acknowledges that portions of the proposed mixed-use residential
land use designations are located within the 65 dB CNEL and does state the requirement for
granting an avigation easement but does not mention the requirement to reduce the indoor noise
level to 45 dB. Also, while avigation easements are an important liability mitigation tool, they do
not replace the imperative to avoid introducing incompatible uses into a noise-affected area. As
shown in ALUCP Table IV-1, residential uses are not compatible within the 70 dB contour and
higher, and the Draft Program EIR should evaluate them as such.
Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap
or Oyster Point, including one procedure, the Shoreline Departure visual procedure, which is a noise
abatement procedure designed specifically to keep aircraft over the industrial areas of the City east
of U.S. 101 and away from its traditional residential areas. Any residential developments east of
U.S. 101, such as those proposed in the General Plan Update, could reduce the efficacy of the
Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to
protect residents of South San Francisco, Daly City, and Pacifica by maximizing flights over water
and industrial areas between 1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of
U.S. 101 would experience noise disturbances from aircraft departures. We expressed concern about
this in our March 22, 2021 comment letter. The Draft Program EIR has not specifically analyzed
these potential environmental impacts of the Proposed Project. The Airport also urges the City to
engage the SFO Airport/Community Roundtable as soon as possible to notify the public and
stakeholders about the project as it relates to the existing and long-established aircraft noise
abatement procedures to the City and adjacent cities.
Also, in Impact NOI-3, the Draft Program EIR states “These airport activity noise levels could
exceed the City’s noise/land use compatibility standards for certain land uses.” This language
implies that the Airport is actively exceeding noise and land use compatibility standards. This
language is misleading and should be corrected; rather, the General Plan Update would allow for
mixed-use residential uses within the already established 65 dBA CNEL. Also, within this impact
statement, an incorrect reference to Mitigation Measure (MM) NOI-2 is made; there is no MM
NOI-2. Rather, it should be MM NOI-3, which properly corresponds to the number of the impact
statement.
1 SFO ALUCP Noise Policy-3.
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Billy Gross, City of South San Francisco
August 9, 2022
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If the City were to propose a development which the ALUC determines is incompatible with the
SFO ALUCP, then the City would be compelled to override the ALUC determination through its
City Council if it wishes to proceed with the development. An override of the noise compatibility
policy requires granting of an avigation easement to the City and County of San Francisco, as
proprietor of SFO.
2. SAFETY COMPATIBILITY
With respect to safety, Impact LUP-2 identifies that the southern portions of the General Plan
Update area are within various runway end safety zones, including the Inner Approach/Departure
Zone (Zone 2), Inner Turning Zone (Zone 3), and Outer Approach/Departure Zone (Zone 4) and has
the potential to conflict with respective zone restrictions. We expressed concern about this in our
March 22, 2021 comment letter. Each of these zones carries restrictions on what may be located
there, based on the safety compatibility criteria and guidelines in the ALUCP, which in turn were
adapted from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already
recognizes the intense level of existing development in the vicinity of SFO and makes compromises
compared to the Handbook’s recommendations, and the Airport recommends against further
degradation of these safety restrictions.
The Draft Program EIR concludes, however, under Impact LUP-2 that the Proposed Project would
not cause a significant environmental impact. It is not clear how the Draft Program EIR comes to
this conclusion as there are clear potential conflicts with safety compatibility policies as
acknowledged in Impact LUP-2. The purpose of the safety compatibility policies is twofold: 1) to
protect the public health, safety, and welfare by minimizing the public’s exposure to the risk
associated with potential aircraft accidents in the Airport vicinity and 2) to protect the public
interest in providing for the orderly development of SFO by preventing the creation of new safety
problems in Airport environs. The overall objective is to minimize risks associated with potential
aircraft accidents to persons on the ground and aircraft occupants.
3. AIRSPACE COMPATIBILITY
Impact HAZ-5 describes how the City would consult with the City/County Association of
Governments (C/CAG) and the Federal Aviation Administration (FAA) when new development is
proposed in the vicinity of SFO. This language is potentially misleading as the City is not required
to “consult” with but rather, it is required to submit to the C/CAG (or specifically, the Airport Land
Use Commission within C/CAG) for a determination of consistency with the SFO ALUCP.
As it pertains to height compatibility, any proposed structure must lie wholly beneath the critical
aeronautical surfaces defined in the SFO ALUCP and must obtain a Determination of No Hazard
from the FAA. These processes are parallel, as the SFO ALUCP and the FAA study different
airspace surfaces when coming to their determinations. Given the degree of confusion that the City
and the Airport have observed on this process over the past several years, the Airport suggests
clarifying language that acknowledges these two parallel determination processes. Further, the
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Billy Gross, City of South San Francisco
August 9, 2022
Page 4 of 4
Airport recommends clarifying that for purposes of airspace evaluation, both the FAA and the SFO
ALUCP reference elevations above mean sea level (MSL) as defined by the 0-foot origin of the
North American Vertical Datum of 1988 (NAVD88), and not the ground level.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance as the City
considers airport land use compatibility as they relate to the General Plan update, Program EIR, or
any future projects, please do not hesitate to contact me at (650) 821-6678 or at
nupur.sinha@flysfo.com.
Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
P.O. Box 8097
San Francisco, California 94128
Attachment
cc: Susy Kalkin, ALUC
Sean Charpentier, C/CAG
Sam Hindi, Chairperson, SFO Airport/Community Roundtable
Audrey Park, SFO
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ATTACHMENT
Comment Letter from SFO to City of South San Francisco re: Notice of Preparation of a Program
Environmental Impact Report for Proposed South San Francisco General Plan Update (March 22, 2021)
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March 22, 2021
Billy Gross TRANSMITTED VIA EMAIL
Senior Planner billy.gross@ssf.net
City of South San Francisco
Planning Division
315 Maple Ave.
South San Francisco, CA 94080
Subject: Notice of Preparation of a Program Environmental Impact Report for Proposed South San
Francisco General Plan Update
Dear Mr. Gross,
Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of a
Program Environmental Impact Report (Program EIR) for the proposed South San Francisco General Plan Update
(the project). We appreciate this opportunity to coordinate with the City of South San Francisco (the City) in
considering and evaluating potential land use compatibility issues that the project may pose and should address.
As described in the Notice of Preparation (NOP), the project site is the geographic limits of the City, in San
Mateo County. The southeastern portion of the project borders, and in certain areas overlaps with, City and
County of San Francisco/SFO property boundaries. The City is primarily residential, with this use occupying
approximately 40% of its land area, followed by industrial/research and development (RD) at approximately 30%,
and parks/open space/common greens at approximately 10%. The NOP notes that presently there are about 150
acres of vacant land remaining in the City, which amounts to 3.4% of the City. This project will serve as a
blueprint for the City’s vision through the year 2040 and will replace the 1999 General Plan and inform updates to
the City’s Zoning Ordinance.
The City’s proposed changes are highlighted in Proposed Land Use Maps and, specifically, the Land Use Map
depicting the changes from the existing map (see Figure 1). This map highlights the concentration in change along
the U.S. Highway 101 (U.S. 101) corridor, the “East of 101” precinct including Oyster Point, and transit nodes
such as the San Bruno Bay Area Rapid Transit (BART) and South San Francisco BART and Caltrain stations,
which have been targeted for zoning intensification. The NOP notes that the project permits approximately 14,324
net new housing units and approximately 13,352 net new employment opportunities by 2040. This map highlights
that much of this change will come from intensifying land uses which were previously exclusively office/RD or
industrial under the 1999 General Plan to include mixed use or high -density mixed use, which would allow for
residential uses.
The Airport is concerned that much of the land slated for this change is closer to the Airport than the previous
General Plan’s housing element, and portions of the proposed mixed-use residential zones are within the Airport’s
runway safety zone boundaries and 65 decibel (dB) Community Noise Equivalent Level (CNEL) noise contour.
In the 1999 General Plan, the City acknowledged the significance of and retained areas east of U.S. 101 for cargo
handling and freight forwarder uses that support the cargo operations at SFO. The Airport appreciates that in the
intervening years, the City has successfully maintained these land uses east of U.S. 101, which enhance and
support the relationship among the City, its residents, and the Airport. These existing compatible land uses east of
U.S. 101 include industrial, warehousing, hotels, and office/RD. The Airport cautions against the project’s
proposed departure from this successful practice.
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Mr. Billy Gross
March 22, 2021
Page 2 of 5
The close proximity of these areas to SFO would require developments to undergo federal, state, and local
regulatory review processes specific to airport noise, airspace safety, and other land use compatibility standards,
including 14 Code of Federal Regulations Part 77 regulations for the safety, efficient use, and preservation of
navigable airspaces. Airport staff encourages the City to work closely with the Airport Land Use Commission
(ALUC)1 to determine project consistency with the Comprehensive Airport Land Use Compatibility Plan for the
Environs of SFO (ALUCP)2 and other regulatory review procedures. The Program EIR should evaluate the
project for consistency with all ALUCP regulatory requirements and policies.
Figure 1: Proposed Changes from Existing Land Use Map (NOP of Program EIR Exhibit 5)
The ALUCP establishes policies, to ensure compatibility between the Airport and surrounding land uses and to
protect local residents and workers from adverse effects of airport operations. All three topics are based on
research into actual effects of airport operations on human health and safety.3
Noise: Reduce the potential number of future residents who could be exposed to noise effects from airport
and aircraft operations.
Safety: Minimize the potential number of future residents and land use occupants exposed to hazards
related to aircraft operations and/or catastrophic incidents.
Elevation/Height: Protect the navigable airspace around the Airport for the safe and efficient operation
of aircraft in flight.
1 State law requires an ALUC for every county with an airport in its jurisdiction. See Cal. Pub. Util. Code §§ 21670-21679.5.
In San Mateo County, the City/County Association of Governments of San Mateo County (C/CAG) board serves as the
ALUC.
2 State law requires the preparation of an ALUCP. See id. In 2012, C/CAG, in consultation with the Airport and surrounding
communities, adopted the current ALUCP, which addresses issues related to compatibility between airport operations and
surrounding proposed land use development, considering noise impacts, safety of persons on the ground and in flight, height
restrictions/airspace protection, and overflight notification.
3 California Department of Transportation (Caltrans) Division of Aeronautics, Califo rnia Airport Land Use Planning
Handbook, October 2011.
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Mr. Billy Gross
March 22, 2021
Page 3 of 5
Most of the City, and all of the areas of proposed land use intensification around and to the east of U.S. 101, are
located within the ALUCP Airport Influence Areas A and B (see Figure 2). The ALUCP requires all residential
development within Area A, which is the entirety of San Mateo County, to provide real estate disclosures, a copy
of which can be found at ALUCP Appendix G-7. Additionally, within the more restrictive Area B, “the ALUC
[the C/CAG Board] shall exercise its statutory duties to review proposed land use policy actions, including new
general plans, specific plans, zoning ordinances, plan amendments and rezoning, and land development
proposals.”4 The City must accordingly submit the proposed general plan update to the ALUC for review.
Figure 2: ALUCP-defined boundaries affecting South San Francisco (ALUCP Exhibit IV-3)
With respect to noise compatibility, portions of the project are situated within the Airport’s 65 dB CNEL noise
contour, and some even within the 70 dB contour. The ALUCP policies for noise are to protect the comfort and
quality of life of the City’s residents, and SFO discourages residential uses within the Airport’s 65 dB or higher
contours. To the extent that the project would allow such uses, the Program EIR must disclose and evaluate any
inconsistency with the ALUCP. The ALUCP requires the grant of an avigation easement to the City and County
of San Francisco, as the proprietor of SFO, as a condition of allowing residential development within the 65 dB
contour.5 While avigation easements are an important mitigation tool, they do not replace the imperative to avoid
introducing incompatible uses into a noise-affected area in the first place. As shown in ALUCP Table IV-1,
residential uses are not compatible within the 70 dB contour and higher, and the Program EIR should evaluate
them as such.
Further, many Airport departure procedures are designed to ascend over either the San Bruno Gap or Oyster
Point, including one procedure, the Shoreline Departure visual procedure, which is a noise abatement procedure
designed specifically to keep aircraft over the industrial areas of the City east of U.S. 101 and away from its
traditional residential areas. Any residential developments east of U.S. 101 could reduce the efficacy of the
Nighttime Preferential Runway Use program developed in 1988 and put in place specifically to protect residents
of South San Francisco, Daly City, and Pacifica by maximizing flights over water and industrial areas between
4 ALUCP IP-2 (Airport Influence Area B – Policy/Project Referral Area), p. IV-11.
5 ALUCP NP-3.
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Mr. Billy Gross
March 22, 2021
Page 4 of 5
1:00 a.m. and 6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise
disturbances from aircraft departures. The Program EIR should evaluate these potential environmental impacts of
the project. The Airport also urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the project as it relates to the existing and long-established
aircraft noise abatement procedures to the City and adjacent cities.
Any proposed residential uses outside of the 65 dB contour should still meet the interior noise requirements of the
California Building Code. Noise impacts on sensitive receptors and any necessary mitigation measures should be
fully evaluated in the Program EIR, and the EIR should describe the project’s consistency with noise policies
described in ALUCP, including noise policies NP-1 through NP-4.
The Airport understands and supports the City’s efforts to address the region’s housing supply shortage with its
General Plan update. SFO has felt the effects of the housing crisis firsthand, with many people who work at the
Airport forced to finding housing 60 miles away, or farther. This places a considerable hardship on the
employees, Airport, neighboring communities, and the regional surface transportation system, and we would
welcome affordable, transit-oriented housing closer to the Airport. However, subjecting new residents to
excessive aircraft noise is not an equitable solution. SFO requests that the City revise its proposals for residential
and mixed uses away from the 65 dB CNEL contour, including the southern portions of Highway 101 and San
Bruno BART station. Any upzoning proposed along the City’s commercial core along Grand Avenue or higher
density around South San Francisco BART station would be outside of the critical 65 dB CNEL contour and
would not pose these concerns.
Figure 3: SFO runway safety compatibility zones around South San Francisco (ALUCP Exhibit IV-8)
With respect to safety, the southern portions of the General Plan area are within various runway end safety zones,
including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer Approach/Departure Zone (see
Figure 3). Each of these zones carry restrictions on what may be located there, based on the safety compatibility
criteria and guidelines from the California Airport Land Use Planning Handbook. The Handbook’s risk-based
guidance is informed by a rigorous analysis of historical aircraft incident data. The ALUCP already recognizes the
intense level of existing development in the vicinity of SFO, and the Airport recommends against overriding these
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Mr. Billy Gross
March 22, 2021
Page 5 of 5
restrictions. The Program EIR should also describe and evaluate the project’s consistency with land use criteria
within these runway end safety zones, as described in ALUCP SP-1 through SP-3.
With respect to elevation, the Airport appreciates the City’s commitment to protecting the critical airspace
surfaces defined in the ALUCP, as these surfaces protect the safety and economic vitality of the Airport and the
City. The Airport has observed several points of confusion regarding airspace surfaces and requests that the City
work with SFO staff to ensure the accuracy of the guidance provided in the General Plan Update.
For example, all critical airspace surfaces are based on elevation above mean sea level (AMSL) – not height
above ground level (AGL). Therefore, if the General Plan Update establishes height restrictions, it should note
them in AMSL rather than AGL and incorporate by reference the most recently adopted version of the ALUCP. It
should also note that the finished height of any proposed development must be maintained below these clearance
limits, including architectural parapets, machine rooms, antennas, etc. The Airport suggests that any exhibits
included in the General Plan Update should include prominent notes which address these common concerns.
Finally, the General Plan Update also proposes a new vehicular bridge between Oyster Point, likely ar ound the
southern end of Haskins Way, and North Access Road on Airport property. While we understand this may be
highly notional, if the City does intend to pursue the concept, the Program EIR should fully evaluate it. We also
request that the City keep the Airport apprised of any developments regarding this proposal, which would require
close coordination with the Airport. For example, the Airport would need to understand vehicular movements and
how the bridge could increase or redistribute traffic on the Airport’s roadways and intersection with Interstate 380
in deciding whether to support the project.
The Airport appreciates your consideration of these comments. If I can be of assistance as the City considers
airport land use compatibility as they relate to the General Plan update, Program EIR, or any future projects,
please do not hesitate to contact me at (650) 821-9464 or at nupur.sinha@flysfo.com.
Sincerely,
Nupur Sinha
Acting Planning Director
Planning and Environmental Affairs
cc: Susy Kalkin, Airport Land Use Committee
Sandy Wong, C/CAG
Audrey Park, SFO, Acting Environmental Affairs Manager
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City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
FirstCarbon Solutions 2-23
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/EIR/3 - Final EIR/50000006 Sec02-00 Responses to Written Comments.docx
Local Agencies
San Francisco International Airport (SFO)
Response to SFO-1
The commenter provides introductory remarks. No response is required.
Response to SFO-2
The commenter expresses concern about the location of proposed land uses being closer to the
Airport than the previous General Plan’s housing element, noting that appropriate compatible uses
east of U.S. 101 include industrial, warehousing, hotels, and office/research and development. SFO
discourages residential uses within the Airport’s 65 decibel (dB) or higher contours.
The comment is noted. In response to the SFO 2021 letter, the City modified the proposed plan to
ensure that residential uses would not be located within the 70 dB or higher contours identified in
the SFO Airport Land Used Compatibility Plan (ALUCP) . Residential uses within the 65 dB contour are
required to meet the 45 dB interior standard (Title 24).
Response to SFO-3
The commenter notes that GP Policy SA-12.6 requires the City to encourage residential development
in the South Spruce area that is within the 65 dB Community Noise Equivalent Level (CNEL), provided
that the structure meets the standard indoor 45 dB noise requirement. The ALUCP requires the grant
of an avigation easement to the City and County of San Francisco, as the proprietor of SFO, as a
condition of allowing residential development within the 65 dB CNEL contour, and this requirement
should be included in Impact HAZ-5 in determining the level of significance.
The commenter also notes that Impact LUP-2 acknowledges this requirement but does not mention
the requirement to reduce indoor noise to 45 dB.
Proposed/future development must comply with the City’s Policies NOI-1.1 and NOI-1.2, which
establish interior noise compatibility standards. This impact is identified and addressed in Impact
NOI-3 and is mitigated to less than significant with implementation of MM NOI-2.
Response to SFO-4
The commenter notes that while avigation easements are an important liability mitigation tool, they
do not replace the imperative to avoid introducing incompatible uses into a noise-affected area. As
shown in ALUCP Table IV-1, residential uses are not compatible within the 70 dB contour and higher,
and the Draft Program EIR should evaluate them as such.
In response to the SFO 2021 letter, the City modified the proposed plan to ensure that residential
uses would not be located within the 70 dB or higher contours. Residential uses within the 65 dB
contour are required to meet the 45 dB interior standard (Title 24).
Response to SFO-5
The commenter notes that any residential developments east of U.S. 101, such as those proposed in
the General Plan Update, could reduce the efficacy of the Nighttime Preferential Runway Use
program developed in 1988 and put in place specifically to protect residents of South San Francisco,
Daly City, and Pacifica by maximizing flights over water and industrial areas between 1:00 a.m. and
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Responses to Written Comments Administrative Final EIR
2-24 FirstCarbon Solutions
https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5000/50000006/EIR/3 - Final EIR/50000006 Sec02-00 Responses to Written Comments.docx
6:00 a.m. Any residential uses allowed in areas east of U.S. 101 would experience noise disturbances
from aircraft departures. The Draft Program EIR has not specifically analyzed these potential
impacts.
See Response to Comment SFO-3, in reference to the fact that the impact is mitigated by requiring
developments to comply with interior noise standards.
Response to SFO-6
The commenter urges the City to engage the SFO Airport/Community Roundtable as soon as
possible to notify the public and stakeholders about the proposed project as it relates to the existing
and long-established aircraft noise abatement procedures to the City and adjacent cities.
The comment is noted. No further response is required.
Response to SFO-7
The commenter notes that in the discussion for Impact NOI-3, the Draft Program EIR states “These
airport activity noise levels could exceed the City’s noise/land use compatibility standards for certain
land uses.” This language implies that the Airport is actively exceeding noise and land use
compatibility standards. The comment notes that this language is misleading and should be
corrected to state that the General Plan Update would allow for mixed -use residential uses within
the already established 65 dBA CNEL. The commenter also notes a typographical error related to
Mitigation Measure (MM) NOI-2. The comment states that the correct reference should be MM NOI-
3, which properly corresponds to the number of the impact statement.
The statement has been revised in Section 3, Errata to state, “The General Plan Update would allow
for mixed -use residential uses within the already established 65 dBA CNEL.”
The reference to MM NOI-3 has been corrected in Section 3, Errata to reference MM NOI-2.
Response to SFO-8
The commenter notes that if the City were to propose a development which the Airport Land Use
Commission (ALUC) determines is incompatible with the SFO ALUCP, then the City would be
compelled to override the ALUC determination through its City Council if it wishes to proceed with
the development. An override of the noise compatibility policy requires granting of an aviation
easement to the City and County of San Francisco, as proprietor of SFO.
The comment is noted; no further response is required.
Response to SFO-9
The commenter notes that Draft Program EIR Impact LUP-2 identifies that the southern portions of
the General Plan Update area are within various runway end safety zones, including the Inner
Approach/Departure Zone (Zone 2), Inner Turning Zone (Zone 3), and Outer Approach/Departure
Zone (Zone 4) and has the potential to conflict with respective zone restrictions. The Draft Program
EIR concludes under Impact LUP-2 that the proposed project would not cause a significant
environmental impact. The commenter inquires as to how the Draft Program EIR comes to this
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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conclusion as there are clear potential conflicts with safety compatibility policies as acknowledged in
Impact LUP-2.
The Draft Program EIR identifies the requirement that future projects would be required to be
designed to ensure conformance with the SFO ALUCP.
As stated in Impact LUP-2, local plans, policy actions, or development activities that affect areas
within that boundary must receive ALUC approval or have a finding of overriding considerations
prior to local permit issuance. The SFO ALUCP requires all residential development within Area A,
which is the entirety of San Mateo County, to provide real estate disclosures (see SFO ALUCP
Appendix G-7). Additionally, within Area B, the ALUC (C/CAG of San Mateo County) is responsible for
reviewing proposed land use policy actions, including new general plans, specific plans, zoning
ordinances, plan amendments and rezoning, and land development proposals. As such, the City is
required to submit the General Plan Update to the ALUC for review and approval. Further, future
development within the SFO ALUCP areas must also be referred to the ALUC for a determination of
consistency. Future development under the proposed project would be evaluated for consistency
with the 2011 California Airport Land Use Planning Handbook and the SFO ALUCP. In reviewing
individual project applications, the City would determine which policies and actions apply and
whether project modifications would be required to ensure compatibility with the ALUCP, depending
on the specific characteristics of the project type and/or project site during the development review
process. Buildings within the ALUCP area would be required to comply with Federal Aviation
Administration (FAA ) regulations for height.
Furthermore, the General Plan Update includes policies and actions related to land use compatibility.
Action SA-12.5.1 requires the General Plan to be in conformance with land use compatibility
standards in the ALUCP. Policy SA-21.3 allows building heights within maximum limits permitted
under FAA regulations. These actions, along with the requirements of the ALUCP and South San
Francisco Municipal Code ensure that future development would be consistent with the ALUCP.
Response to SFO-10
The commenter clarifies that the use of the term consultation with the City/County Associations of
Governments (C/CAG) and FAA is misleading, as the City is actually required to submit to the C/CAG
for a determination of consistency.
Impact HAZ-5 is revised in the Final EIR to clarify that the City is required to submit to the C/CAG for
a determination of consistency with the SFO ALUCP. Please refer to Section 3, Errata.
Response to SFO-11
The commenter notes that any proposed structure must lie wholly beneath the critical aeronautical
surfaces defined in the SFO ALUCP and must obtain a Determination of No Hazard from the FAA. The
commenter recommends clarifying that for purposes of airspace evaluation, both the FAA and the
SFO ALUCP reference elevations above mean sea level (MSL) as defined by the 0-foot origin of the
North American Vertical Datum of 1988 (NAVD88), and not the ground level.
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Responses to Written Comments Administrative Final EIR
2-26 FirstCarbon Solutions
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As the commenter notes, for purposes of airspace elevation, MSL and not ground level is used to
reference elevations. This comment does not raise any environmental issues with respect to the
Draft Program EIR or proposed project and no further response is required.
Response to SFO-12
The commenter provides closing remarks. No response is required.
Response to SFO-13
The commenter provides introductory remarks in response to the March 22, 2021 Notice of
Preparation (NOP). The comment does not raise any environmental concerns or questions regarding
the project. No further response is required.
Response to SFO-14
This NOP comment raises questions regarding the location of proposed land uses in relation to the
airport. In response to this comment, the proposed plan was revised as further explained in
Response to SFO-2.
Response to SFO-15
This NOP comment summarizes the proposed project and states that the City must submit the
proposed plan to the ALUC for review. As explained in Impact LUP-2 and Response to SFO-9, the City
is required to submit the General Plan Update to the ALUC for review and approval. Moreover, the
Draft Program EIR identifies the requirement that future projects would be required to be designed
to ensure conformance with the SFO ALUCP.
Response to SFO-16
This NOP comment discusses the need for an avigation easement. Please refer to Response to SFO-4.
Response to SFO-17
This NOP comment regarding residential development east of U.S. 101 and the relationship to the
efficacy of the Nighttime Preferential Runway Use program is addressed in Response to SFO-5. The
suggestion to SFO Airport/Community Roundtable is noted; however, this suggestion does not raise
any environmental concern or question that requires a further response under CEQA. This NOP
comment also suggests that Draft Program EIR discuss noise impacts with relation to areas outside of
the 65 dBA contour. Accordingly, potential impacts to areas outside of the 65dBA CNEL contours are
discussed in Section 3.11 of the Draft Program EIR. (See, e.g., Draft EIR, pp, 3.11-13, 3.11-34-3.11-
35.)
Response to SFO-18
This NOP comment expresses support for the City ’s housing supply shortage and raises concerns
about location of proposed land uses. In response, the City modified the proposed plan to ensure
that residential uses would not be located within the 70 dBA or higher contours identified in the
ALUCP. Please refer to Response to SFO-3.
Response to SFO-19
This NOP comment states that the southern portions of the Planning Area are within various runway
end safety zones, including the Inner Approach/Departure Zone, Inner Turning Zone, and Outer
Approach/Departure Zone, and requests that the Draft Program EIR describe and evaluate the
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
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project’s consistency with land use criteria within these runway end safety zones, as described in the
SFO Airport Land Use Compatibility Plan (ALUCP) SP-1 through SP-3. Please refer to Response to SFO-
9.
Response to SFO-20
This NOP comment notes that for purposes of airspace elevation, MSL and not ground level is used
to reference elevations. This comment does not raise any environmental issues with respect to the
Draft Program EIR or proposed project and no further response is required.
Response to SFO-21
This NOP comment requests that the Draft Program EIR evaluate impacts of the proposed vehicular
bridge between Oyster Point and North Access Road on airport property. Proposed improvements on
airport property and potential hazards are addressed in Impact HAZ-5 in Section 3.8 of the Draft
Program EIR. Land use compatibility of proposed improvements are further discussed in Section 3.10
of the Draft Program EIR.
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425 Market Street
Suite 2900
San Francisco, CA 94105
415.227.0900 Phone
415.227.0770 Fax
BN 71998654v5
415.227.3508 Direct
aguerra@buchalter.com
August 9, 2022
VIA E-MAIL (BILLY.GROSS@SSF.NET)
Billy Gross
Principal Planner
City of South San Francisco
315 Maple Avenue
South San Francisco, CA 94080
Re: Comments on the Shape SSF 2040 General Plan Update and Draft Environmental
Impact Report (SCH# 2021020064)
Dear Billy:
Thank you for the opportunity to comment on the City of South San Francisco’s Shape
SSF 2040 General Plan Update (the “General Plan Update”), associated Zoning Code Update
and Draft Environmental Impact Report (“DEIR”).
As you know, Healthpeak is the owner of the property located at 420, 440, 466, and 494
Forbes Boulevard (“Property”) in the “East of 101” area of the City of South San Francisco,
California (the “City,” or “South S.F.”). Buchalter represents Healthpeak as land use counsel for
the development of the Property. Healthpeak looks forward to the City Council’s adoption of the
General Plan Update and Zoning Code Update so that Healthpeak may proceed with its efforts to
develop the Property with approximately 1,652,930 square feet of office and lab space and
associated amenities (the “Vantage Project”). Healthpeak also proposes to construct a new fire
station on the Property to benefit the Forbes Boulevard area.
Healthpeak supports and endorses the City’s efforts to prepare a General Plan Update and
Zoning Code amendments that incorporate the vision for a more intensive level of development
in the East of 101 area. We are encouraged by the policies the City is proposing to incorporate
into the General Plan Update and Zoning Code amendments, and appreciate the DEIR’s
thorough analysis of the potential impacts of buildout of the General Plan. The proposed changes
to the General Plan and City zoning ordinance increase the intensity within the Business and
Technology Park land use designation and will allow Healthpeak to develop the Vantage Project
Billy Gross
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at the 2.0 FAR density it envisions. Accordingly, the purpose of this letter is to submit clarifying
comments regarding the General Plan Update as applied to the Property, and clarify the DEIR’s
assessment of impacts associated with the proposed increased development potential in
furtherance of implementing the City’s development vision for the area.
The General Plan contemplates development at a 2.0 FAR on the Property, and the
DEIR fully evaluates associated impacts.
General Plan, pages 60-64 – General Plan Update Figure 6 and Table 2: General Plan
Land Use Designations designate the Property Business Technology Park (BTP) High.
According to the General Plan, the BTP High designation allows high-density corporate
headquarters, research and development facilities, and offices (FAR ranges from 0.5 up to 2.0
with community benefits). Healthpeak supports the proposed General Plan Update land use
designation on the Property.
General Plan, page 116– Policy SA-21.1 promotes urban campus-style life science uses
for R&D uses for life science and other innovative companies. Policy SA-21.2 proposes to
restrict warehousing and distribution uses in BTP High areas. R&D campus uses often include
distribution facilities and warehouses as ancillary uses to support R&D and life science uses.
Please clarify that such ancillary uses would be allowed as secondary uses under the BTP High
designation.
DEIR, Pages 2-7, -10 through -11, -13, -15 – Healthpeak understands that the building
projections in the General Plan Update and DEIR are based on the General Plan Update
designation for the Property as Business Technology Park (BTP) High. The BTP High land use
designation allows “high-density corporate headquarters, research and development facilities,
and offices” with FAR density ranging from 0.5 to 2.0 with community benefits. (General Plan
Update, p. 65.) This is necessary to achieve the City’s Policy LU-5.2 for the City to “support a
mix of larger, higher-intensity [R&D company] campuses.” (General Plan Update, p. 72.)
Recognizing that the City “is a fully built city,” the DEIR explains that, “new
development will primarily occur on parcels that already contain some existing homes or
businesses” and that this will require locating much of this new development in the East of 101
area. (DEIR, p. 2-10.) Approximately 493 acres of the East of 101 area is slated for the BTP
High designation. (DEIR, Table 2-2.) The Draft EIR and specifically Tables 2-4, 2-6, and 2-7
describe the estimated “development activity anticipated to occur through buildout of the
General Plan Update.” These estimates include the number of Projected Jobs, as well as
Projected Square Footage to increase in the Business Technology Park High land use designation
upon General Plan buildout. For example, the BTP High designation is projected to create
approximately 16,198 jobs and to amount to approximately 7,788,187 additional square feet of
development in the City. (DEIR, Table 2-6.)
Billy Gross
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The Property is currently underutilized. We agree with the City’s proposal to designate
the Property as BTP High, as it is a prime location for accommodating some of the General Plan
Update’s anticipated development. Currently, much of the Property contains a variety of low
intensity single-story commercial uses. One parcel is undeveloped and is used for semi-truck
parking. The Vantage Project would redevelop this underutilized Property at a 2.0 FAR with
over 1.6 million square feet of high-intensity research and development and office facilities as
envisioned in the General Plan Update and thoroughly evaluated in the DEIR.
The DEIR assumes that future development under the BTP High land use designation
would generate approximately 40,656 jobs at 83 new jobs per acre. Healthpeak, however, is
concerned that the employment generation estimates identified in Table 2-6 in the DEIR may be
low compared to the actual employment generated by life sciences and R&D land uses based on
the tenants that occupy Healthpeak’s campuses in the City. Please clarify the basis for the
employment estimates presented in Table 2-6 and confirm that the estimates correspond to the
nature of higher intensity life science uses contemplated by the BTP High designation.
The Vantage Project is consistent with General Plan Update policy to locate
employment uses near transit centers, which, in part, further the reduction in the
City’s greenhouse gas (“GHG”) emissions.
General Plan Update pages 70, 198; DEIR, Pages 3.2-25, 3.7-36, 3.7-41, and 3.7-55 –
General Plan Update Policy LU-2.1 encourages the City to “Prioritize development near transit
centers. Collaborate with developers and property owners to locate new . . . employment uses
near transit centers to minimize reliance on personal automobiles.” Policy LU-2.1 encourages
that development “assist in reducing or avoiding potential impacts related to GHG emissions.”
Additionally, mobility Policy MOB-4.1 and its associated action items require a substantial
increase in “the proportion of travel using modes other than driving alone.” This may be through
site connectivity improvements, expanded transit services, employee transit subsidies, and
first/last mile connection improvements. These General Plan Update policies and actions “would
help reduce GHG emission generation from existing and future development.” (DEIR, p. 3.7-55.)
Under the BTP High designation, the higher FAR will enable the Vantage Project to
intensify business and employment-generating uses on the Property. The Vantage Project would
provide office and lab space for life science research and development uses, employing
thousands of workers. Since the Property is located approximately three-quarters of a mile from
the South San Francisco Caltrain Station, Healthpeak’s Project is primed to take advantage of its
proximity to reliable transit service. Through Transportation Demand Management (“TDM”)
measures, the Vantage Project will encourage and incentivize a significant share of future
employees to utilize other means of transportation than single-occupancy vehicles as
contemplated in the General Plan Update. Healthpeak intends to implement TDM strategies
reflected in the General Plan Update to contribute to efforts to promote fewer employees
Billy Gross
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utilizing vehicle travel in the East of 101 area. This significant reduction in single-occupancy
vehicle travel will reduce corresponding GHG emissions consistent with the GP Update and
recommended DEIR mitigation measures.
General Plan Update, page 184; DEIR Pages 3.14-17, -19 through 20, -25, -38
through -40 – The General Plan Update includes policies that would improve transportation
throughout the City and reduce reliance on single-occupancy vehicles. These policies dovetail
with the policies intended to reduce GHG emissions and to encourage environmentally sensitive
design policies. Healthpeak supports the new General Plan Update policies.
The General Plan Update Should Encourage Shared Parking Districts and
Coordinate with TDM to Promote Parking for East of 101 Area BTP Land Uses.
General Plan Update, pages 130 & 200 – East of 101 Area Action SA-16.1.1 provides
that the City should introduce shared, district parking facilities to support visitors and employees
in the East of 101 Area. Healthpeak supports the City’s proposed policy SA-16.1 to provide
shared parking in this employment intensive area. Action MOB 3.3.1 provides that the City may
incorporate parking maximums for office/R&D developments. Although the Vantage Project is
designed to comply with the 2 spaces per 1,000 square foot of office floor area in the Zoning
Code amendment, Healthpeak believes shared parking arrangement (per SA-16.1) will facilitate
efforts to meet parking demand that exceeds 2.0 spaces per 1,000 square feet. Healthpeak is
concerned without flexible parking requirements that it will be unable to meet parking demand
for life sciences and other R&D activities within the East of 101 area, and specifically on Forbes
Boulevard. In this regard, the Zoning Code amendment proposes different parking ratios for
different uses. For example, a parking ratio of 2 spaces per 1,000 square feet of floor area applies
to office uses 1 which differs from the parking requirement for R&D facilities. R&D uses may
provide parking at a rate of 1.5 spaces per 1,000 square feet of floor area. (Amended Zoning
Code, Table 20.330.004.) Office uses may have their parking ratio adjusted “based on
anticipated employee density at the discretion of City.” (Amended Zoning Code, Table
20.330.004.) Healthpeak believes that BTP High uses should be allowed to have a minimum
parking ratio rather than a maximum parking ratio of 2 spaces per 1,000 and to be able to rely on
shared parking arrangements (pursuant to Policy LU-2.5) and other TDM measures to meet
parking demand.
The City Should Equitably Distribute Transportation Improvement Costs on all
New Development and Not Disproportionately Allocate Such Costs Only to R&D
General Plan Update, page 186, Table 6, Proposed New Streets and Major
Transportation Investments – The General Plan Update identifies the Roebling Road
Extension across East Grand Avenue to proposed Railroad Avenue for two lanes, to improve
1 Applicable to office spaces over 10,000 square feet.
Billy Gross
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internal connectivity in East of 101 Area. Healthpeak supports this road improvement, provided
that other new development on Roebling Road contribute to funding these local transportation
improvements.
General Plan Update, page 194 – The General Plan Update notes that the City of South
San Francisco funds transportation improvements through various sources. The primary source is
via a Transportation Impact Fee (Resolution 120-2020). At current fees, the General Plan
buildout could generate approximately $1 billion upon full buildout of the General Plan. The
City is also considering a community facilities district (CFD) within the East of 101 Area to
augment transportation funding for the district. Preliminary funding plans for the CFD expect
that it could generate approximately $160 to $290 million.
The General Plan Update does not clearly identify all of the transportation related impact
fees that would be imposed on new development. For example, we understand that new R&D
development in the East of 101 area may be subject to an “Overpass Contribution Fee” and the
“East of 101 Traffic Impact Fee.” We understand the City is proposing that a Transportation
Impact Fee or CFD assessment supersede the former East of 101 Impact Fee. It is one of the
most significant impact fees anticipated but appears to impact developers differently depending
on the type of land use. For example, the Commercial Linkage Fee seems disproportionate to
R&D developers with a $16.55/SF fee. We are concerned that this fee may further increase, and
be disproportionately allocated to R&D uses.
Healthpeak is concerned that the City will apply new traffic impact fees or a CFD
assessment, fairly and in a proportional and equitable manner for all new development in the
East of 101 area, and requests that the City not disproportionately impact R&D uses with higher
traffic impact fees and assessments.
General Plan Update, page 200 – To support the City’s TDM policies, the General Plan
Update proposes implementation of Action MOB-3.3.1, which calls for incorporating maximum
parking requirements and other TDM requirements for new office/R&D projects. Given the
diversity in uses in the East of 101 Area, we request that the City not disproportionately impose
Billy Gross
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TDM requirements on office/R&D uses, but instead develop a policy that requires all uses in the
East of 101 Area to equitably reduce their impacts caused by vehicle transportation.
The Vantage Project would further the City’s sustainable and environmentally
sensible design policies and policies designed to reduce GHG emissions.
General Plan Update, Policy SA-28.5; DEIR, Pages 3.5-11, -15, 3.7-40, and 3.7-55 –
Policy SA-28.5 requires new projects to implement “sustainable and environmentally sensitive
design. Incorporate sustainable and environmentally sensitive design and equipment, energy
conservation features, water conservation measures and drought-tolerant or equivalent
landscaping, and sustainable stormwater management features.” South S.F. Climate Action Plan
Action Item CL 1.1 additional requires “Minimum LEED™ certification or equivalent for new
buildings. Require all new municipal buildings and facilities to meet a minimum LEED™ silver
standards.” Climate Protection Element Policy CP-5.1 provides an identical requirement for
LEED certification. Implementation of this policy supports the City’s efforts to reduce its GHG
emissions. These General Plan Update policies and actions “would help reduce GHG emission
generation from existing and future development.” (DEIR, p. 3.7-55.)
The Vantage Project would be designed to achieve sustainable and environmentally
sensitive design in accordance with the DEIR and General Plan Update. Under the existing
development agreement, Healthpeak committed to pursue a Leadership in Energy and
Environmental Design (“LEED”) Green Building Rating of “Silver” or higher. Such
certifications are awarded only to buildings that “improve efficiency, lower carbon emissions
and create healthier places for people.” (LEED Rating System, How LEED Works.) Both phases
of the Vantage Project target achieving LEED Gold certification. The Vantage Project is
consistent with the City’s building efficiency and climate action policies. Healthpeak supports
the General Plan Update policies promoting sustainable development.
The General Plan Update EIR evaluates potential impacts associated with
construction of a new fire station in the East of 101 Area.
Page 3.13-24. – In order to achieve its goal of densifying the East of 101 area, the
General Plan Update proposes Policy SA-16.4, which requires the City to coordinate with the
Fire Department “to ensure public services can accommodate growth” in the East of 101 area.
(General Plan Update, p. 113.) Further, the General Plan Update recognizes the need for an
equitable distribution of public services throughout the City, including fire stations through
Action Item ECS-6.1.1. (General Plan Update, p. 252.) Amendments to the Zoning Code would
permit the “Public Safety Facilities” (which is defined to include fire protection services) in the
BTP-H zone. (Amended Zoning Code, Table 20.100.00; § 20.620.020.) Thus, both the General
Plan Update and proposed Zoning Code amendments allow for the development of a fire station
in the BTP High land use designation of the East of 101 area.
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Likewise, the General Plan Update EIR acknowledges that new fire stations may be
required to serve future development in South San Francisco. The DEIR states project-specific
environmental impacts of constructing new or expanded fire protection facilities to support the
growth anticipated under the proposed project cannot be determined at this time because the site-
specific locations and designs of future new or expanded facilities are not known. Nonetheless,
the General Plan Update DEIR indicates that fire protection facilities are contemplated as part of
the General Plan Update. (DEIR, p. 3.13-24.) The DEIR further explains that Table 2-7 assumes
that “buildout under the proposed [General Plan] could result in approximately 68,367 square
feet of nonresidential uses under the “Public” land use designation, which could include fire
protection facilities.” (DEIR, p. 3.13-24.) The DEIR expects that “construction and operation of
future new or expanded fire protection facilities would have similar impacts as would
construction and operation of other types of new development.” (DEIR, p. 3.13-24.) New fire
facilities are addressed in the DEIR and are not expected to cause significant environmental
impacts. (DEIR, p. 3.13-24.)
As you are aware, City representatives have advised Healthpeak of their interest in
locating a fire station on the former Gallo property (included in the Vantage Project).
Healthpeak is designing its Vantage Project to include a new fire station on a portion of the
Property, provided that Healthpeak’s proposed Vantage Project is approved in a manner
consistent with the level of development Healthpeak considers under the BTP High designation.
DEIR, Pages 3.14-17, -19 through 20, -25, -38 through -40 - The DEIR recognizes that
Mitigation Measure (“MM”) TRANS-1, which requires the City to update and implement its
TDM Ordinance, would help reduce total vehicle miles traveled (“VMT”) per employee for new
developments. The General Plan Update and the DEIR provide for a number of new circulation
improvements in the East of 101 Area to mitigate significant traffic impacts.
Conclusion
We believe that the DEIR thoroughly discussed the General Plan Update’s anticipated
environmental impacts and appreciate the City’s consideration of the further clarifying
information we have provided in support of the DEIR analysis. We look forward to reviewing
the final product and working with the City to developing a project that meets the City’s vision
for the East of 101 neighborhood.
Billy Gross
August 9, 2022
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Healthpeak looks forward to continued cooperation with the City to achieve a mutually
beneficial General Plan Update, and supports the City’s vision for the East of 101 area and the
Vantage Property.
Regards,
BUCHALTER
A Professional Corporation
By
Alicia Guerra
AG:nj
cc: Scott Bohn
Natalia De Michele
Heidi Taliaferro
Devin Bertsch
Michele Niaki
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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Individuals
Buchalter (BUCHALTER)
Response to BUTCHALTER-1
The commenter provides introductory remarks, noting that they represent Healthpeak in the
development of their property located at 420, 440, 466, and 494 Forbes Boulevard.
No response is required.
Response to BUCHALTER-2
The commenter supports the City’s efforts to allow for more intensive development east of U.S. 101
within the Business and Technology Park land use designation, which would allow Healthpeak to
develop the Vantage Project at the 2.0 floor area ratio (FAR ) density it envisions.
The comment is noted; no further response is required.
Response to BUCHALTER-3
Healthpeak supports the proposed General Plan Update land use designation of Business Technology
Park (BTP ) High on the property.
The comment is noted; no further response is required.
Response to BUCHALTER-4
The commenter requests the City to confirm that ancillary uses such as distribution facilities and
warehouses would be allowed in the BTP High designated areas.
The comment is noted, but it does not raise an environmental issue. The specifics regarding ancillary
uses are presented in the Zoning Code.
Response to BUCHALTER-5
The commenter notes that the Draft Program EIR assumes that future development under the BTP
High land use designation would generate approximately 40,656 jobs at 83 new jobs per acre.
Healthpeak, however, is concerned that the employment generation estimates identified in Table 2-6
in the Draft Program EIR may be low compared to the actual employment generated by life sciences
and R&D land uses based on the tenants that occupy Healthpeak’s campuses in the City. The
comment requests that the basis for the employment estimates presented in Table 2-6 be clarified
and further requests confirmation that the estimates correspond to the nature of higher intensity
life science uses contemplated by the BTP High designation.
The growth projections do not represent the full development capacity of the City. Rather, the
growth projections represent a reasonably foreseeable estimate of the potential amount of growth
within the General Plan 2040 time horizon. The BTP High designation ranges from 0.5 FAR up to 2.0
FAR with community benefits.
Employee generation for office and R&D uses are based on existing conditions in South San
Francisco. It is estimated that office and R&D uses generate one employee per 425 square feet. This
ratio was used to estimate future employees for office and R&D uses.
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
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Response to BUCHALTER-6
The commenter notes that the Vantage Project would provide office and lab space for life science
research and development uses, employing thousands of workers. Since the property is located
approximately 0.75-mile from the South San Francisco Caltrain Station, Healthpeak’s Project is
primed to take advantage of its proximity to reliable transit service. Through Transportation Demand
Management (TDM) measures, the Vantage Project would encourage and incentivize a significant
share of future employees to utilize other means of transportation than single-occupancy vehicles as
contemplated in the General Plan Update. Healthpeak intends to implement TDM strategies
reflected in the General Plan Update to contribute to efforts to promote fewer employees utilizing
vehicle travel in the East of 101 Area. This significant reduction in single-occupancy vehicle travel
would reduce corresponding greenhouse gas (GHG) emissions consistent with the General Plan
Update and recommended Draft Program EIR mitigation measures.
The comment is noted; individual projects will be reviewed for compliance and consistency with the
General Plan Update mitigation measures related to TDM, which would ensure less than significant
impacts. No further response is required.
Response to BUCHALTER-7
The commenter notes that they are in support of the proposed General Plan Update policies related
to reducing reliance on single-occupancy vehicles.
The comment is noted; no response is required.
Response to BUCHALTER-8
The commenter believes that BTP High uses should be allowed to have a minimum parking ratio
rather than a maximum parking ratio of two spaces per 1,000 and to be able to rely on shared
parking arrangements (pursuant to Policy LU-2.5) and other traffic demand measures to meet
parking demand.
The Draft Program EIR concludes that the buildout of the General Plan would result in significant and
unavoidable VMT impacts; General Plan policies and mitigation measures are aligned to mitigate
VMT impacts to the extent feasible.
Response to BUCHALTER-9
The commenter supports Healthpeak and the proposed expansion of the Roebling Road Extension to
two lanes, provided that other new development on Roebling Road contribute to funding these local
transportation improvements.
Funding for transportation improvements identified in the General Plan Update would come from a
combination of sources including but not limited to impact fees and/or as a condition of approval.
Response to BUCHALTER-10
The commenter discusses the proposed funding of transportation improvements and the need to
clarify how the fees would be assessed to future development projects. Healthpeak is concerned
that the City will apply new traffic impact fees or a Community Facilities District (CFD) assessment
fairly and in a proportional and equitable manner for all new development in the East of 101 Area,
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Responses to Written Comments
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and requests that the City not disproportionately impact R&D uses with higher traffic impact fees
and assessments.
The commenter also discusses Action MOB-3.3.1, which calls for incorporating maximum parking
requirements and other TDM requirements for new office/R&D projects. Given the diversity in uses
in the East of 101 Area, the commenter requests that the City not disproportionately impose TDM
requirement on office/R&D uses, but instead develop a policy that requires all uses in the East of 101
Area to equitably reduce their impacts caused by vehicle transportation.
Please review the Transportation Impact Fee Study. Funding for the implementation of the proposed
roadway improvement may be through Capital Improvement Program (CIP) or may be through
impact fees or conditions of approval for individual projects. New TDM policies would be applied to
all projects, so will more equitably apply requirements. Impact fees and TDM requirements are set
proportional to the transportation impacts generated by a particular land use type. Office and R&D
uses in South San Francisco generate the greatest transportation-related impacts and thus, have the
highest transportation-related impact fees and most aggressive TDM requirements. All new land use
types of a minimum size are responsible for their fair share of fees and TDM strategies.
Response to BUCHALTER-11
The commenter discusses sustainable and environmentally sensible design policies designed to
reduce GHG emissions, and notes that both phases of the Vantage Project target achieving
Leadership in Energy and Environmental Design (LEEDTM) Gold certification. The Vantage Project is
consistent with the City’s building efficiency and climate action policies. Healthpeak supports the
General Plan Update policies promoting sustainable development.
The comment is noted; no response is required.
Response to BUCHALTER-12
The commenter discusses public services and specifically the need for a new fire station in the East
of 101 Area. Healthpeak is designing its Vantage Project to include a new fire station on a portion of
the property, provided that Healthpeak’s proposed Vantage Project is approved in a manner
consistent with the level of development Healthpeak considers under the BTP High designation.
The comment is noted; no response is required.
Response to BUCHALTER-13
The commenter notes the efficacy of MM TRANS-1, which requires the City to update and
implement its TDM Ordinance, would help reduce total VMT per employee for new developments.
No response is required.
Response to BUCHALTER-14
The commenter provides concluding remarks and offers general support for the project. No
environmental issues are raised and no further response is required.
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Final EIR Errata
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SECTION 3: ERRATA
The following are revisions to the Draft Program Environmental Impact Report (Draft Program EIR)
for the General Plan Update, Zoning Code Amendments, and Climate Action Plan. These revisions are
minor modifications to clarify inadvertent typographical errors to the document, and/or to clarify
the discussion and do not change the analysis or significance of any of the environmental issue
conclusions within the Draft Program EIR. The revisions are listed by page number. All additions to
the text are underlined (underlined) and all deletions from the text are stricken (stricken).
3.1 - Changes in Response to Specific Comments
Executive Summary
Page ES-12
Table ES-1: Executive Summary Matrix. The following revision is made to ensure Table ES-1 accurately
reflects the analysis in the Air Quality discussion at pages 3.2-57–3.2-58 of the Draft Program EIR.
None of the conclusions in the Draft Program EIR were revised.
Impacts Mitigation Measures Level of Significance After Mitigation
Impact AIR-4: The proposed
project would not result in other
emissions (such as those leading
to odors) adversely affecting a
substantial number of people.
MMs AIR-1a, AIR-1b, and TRANS-1. – Significant and unavoidable. N/A
Executive Summary
Page ES-14, ES-19
Table ES-1: Executive Summary Matrix. The following revision is made to clarify that Impact CUL-3
and Impact NOI-2 would not have any significant impacts. This revision accurately reflects the
analysis in the Draft Program EIR.
Impacts Mitigation Measures Level of Significance After Mitigation
Impact CUL-3: The proposed project
could would not disturb human
remains, including those interred
outside of formal cemeteries.
– N/A
Impacts Mitigation Measures Level of Significance After Mitigation
Impact NOI-2: The proposed project
could would not result in generation of
excessive groundborne vibration or
groundborne noise levels.
– N/A
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Errata Final EIR
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3.4 - Cultural Resources and Tribal Resources
Page 3.4-36 The following revision is made to clarify that Impact CUL-3 would not have any
significant impacts. This revision accurately reflects the analysis in the Draft Program EIR.
Human Remains
Impact CUL-3: The proposed project could would not disturb human remains, including those
interred outside of formal cemeteries.
3.6 - Geology, Soils, and Seismicity
Exhibit 3.6-4 and Exhibit 3.6-5 are revised to reflect a more recent data source from the California
Geological Survey. These revisions do not change any of the analysis or conclusions in the Draft
Program EIR. Please refer to Exhibit 3.6-4 and Exhibit 3.6-5 in Attachment A.
3.8 - Hazards and Hazardous Materials
Page 3.8-32 The following revisions correct an inadvertent typographical error and provide
clarification. None of the conclusions or analysis in the Draft Program EIR is changed with this
correction.
Proximity to Public Airport Safety Hazard
The General Plan Update contains policies and actions that minimize the exposure of people
residing or working in the Planning Area to a safety hazard or excessive noise because of
proximity to SFO. Policy SA-12.6 requires the City to encourage residential development in
the South Spruce area that are within the 65 decibel (db) CNEL contour, provided the interior
of a structure meets the standard indoor 45 db CNEL noise requirement. Action SA-12.6.1
requires the City to review the SFO ALUCP and, as needed, to update the City of South San
Francisco’s General Plan to be in conformance with land use compatibility standards in the
ALUCP. Action SA-12.6.1 further states that in the event that updates to the ALUCP allow
residential land uses on suitable sites on the El Camino Real corridor where residential is not
currently permitted, the City will update the General Plan to allow Urban Residential uses.
Lastly, Policy SA-21.3 requires the City to allow building heights in the East of 101 area to the
maximum limits permitted under Federal Aviation regulations. Section 3.11, Noise, identifies
additional policies and actions, as well as Mitigation Measure (MM) NOI-3 NOI-2, Airport
Noise Impact Reduction Plan, to address potential exposure to people residing or working in
the vicinity of SFO to excessive noise levels. There are no actions identified in the Climate
Action Plan that minimize the exposure of people residing or working in the Planning Area to
a safety hazard or excessive noise because of proximity to SFO.
As the City receives development applications for subsequent development under the
proposed project, those applications will be reviewed by the City of South San Francisco for
compliance with the policies and actions of the General Plan Update to reduce the exposure
of people residing or working in the City to a safety hazard or excessive noise because of
proximity to SFO. In addition, the City’s Municipal Code, which implements the City’s
General Plan would be reviewed when development applications are received, including
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR Errata
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Chapter 15.08, California Building Code, and Chapter 8.32, Noise Regulations. Further,
Section 20.320.002 (Establishment of Lawful Nonconforming Uses, Structures and Lots)
(revised) ensures that no permit shall be granted that would allow the establishment or
creation of an airport hazard or permit a nonconforming structure or nonconforming use to
be made or become higher or become a greater hazard to air navigation. Lastly, in
accordance with the SFO ALUCP, the City would consult with the C/CAG and Federal Aviation
Administration when development applications for subsequent development under the
proposed project in the vicinity of SFO are received, including submitting applications to the
C/CAG for a determination of consistency with the SFO ALUCP.
Section 3.11 - Noise and Vibration
Page 3.11-35 The following revisions correct an inadvertent typographical error and clarify the
discussion. None of the conclusions or analysis in the Draft Program EIR is changed with this
correction.
Excessive Noise Levels from Airport Activity
These airport activity noise levels could exceed the City’s noise/land use compatibility
standards for certain land uses. The General Plan Update would allow for mixed-use
residential uses within the already established 65 dBA CNEL. Therefore, mitigation would be
required to reduce this potential impact. Airport activity noise can be mitigated at the
receiving land use using acoustic-rated wall and window assemblies. For example, a
combined wall assembly with a Sound Transmission Class (STC) rating of 30-STC can provide
an expected 30 dBA exterior to interior reduction in noise levels. With such an assembly,
exterior noise levels of 70 dBA CNEL would be reduced to approximately 40 dBA CNEL.
Therefore, with implementation of MM NOI-3 NOI-2, which requires preparation of a noise
study to identify appropriate design measures, where required, to reduce the potential
effect of airport activity noise, impacts generated by future development projects under the
proposed project would be reduced to less than significant with mitigation incorporated.
See also Section 3.8, Hazards and Hazardous Materials, which addresses the exposure of
people residing or working in the Planning Area to a safety hazard or excessive noise
because of proximity to SFO.
Page 3.11-37 The following revisions correct an inadvertent typographical error. None of the
conclusions or analysis in the Draft Program EIR is changed with this correction.
3.11.7–Cumulative Impacts
With regard to airport activity noise impacts, the combined effects of cumulative projects
(other cities) surrounding South San Francisco would not result in any additional special
events or sources of single-event noise in the form of aircraft flyover noise, and therefore,
would not result in changes in the 65 dBA CNEL airport noise contours and would not
increase airport noise impacts. However, future buildout cumulative conditions related to
airport activity related noise would be the same as that identified in Impact NOI-3 discussion
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above. The proposed project could still result in the introduction of land use development
that could be potentially incompatible with the noise environment in the vicinity of SFO.
However, as discussed in Impact NOI-3, implementation of MM NOI-3 NOI-2, Airport Noise
Impact Reduction Plan, would reduce airport activity noise impacts from implementation of
the proposed project to less than significant. Therefore, with implementation of MM NOI-3
NOI-2, airport activity noise levels from implementation of the proposed project would not
result in a cumulatively considerable contribution to this less than significant cumulative
impact. Therefore, the proposed project’s contribution to cumulative impacts would be less
than significant.
City of South San Francisco—General Plan Update, Zoning Code Amendments, and Climate Action Plan
Final EIR
FirstCarbon Solutions
Attachment A:
Updated Exhibits
THIS PAGE INTENTIONALLY LEFT BLANK
S
an A
n
dreas Fault
San Francisco Bay
FerryTerminal
San Bruno Creek
C o l m a C r e e k AirportBlvdChestnut AveE Grand Ave
Grand Ave
Oyster Point Blvd
SAi
rpor
t
Bl
vd
H ills id e B lv d
Fo r b es Bl vd
Gateway B lv d
DNAWaySisterCitiesBlvd
E
l
Ca
mi
n
o
R
e
a
lJunipero Ser
r
a Bl
vdW e s tb o roughBlvdCa
ll
a
n
B
lv
d
H i c k e y B l v d
SpruceA v e
S Linden AveUtah AveSSpruceAveGellertBlvd
380
280
35
82
101
California
Golf Club
Unincorporated
Area
Pacifica
San Bruno
Colma
Daly City
Brisbane
San Francisco
International
Airport
50000006 • 08/2022 | 3.6-4_Landslide_Potential.mxd
Exhibit 3.6-4Landslide Potential
Source: Raimi + Associates, July 2019. ESRI, U.S. Geological Survey (USGS). California Department of Conservation. California Geological Survey (CGS).
CITY OF SOUTH SAN FRANCISCOGENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLANENVIRONMENTAL IMPACT REPORT
3,000 0 3,0001,500
Feet
City of South San Francisco
Other City Boundaries
Jurisdictional Boundary
Sphere of Influence
BART
Caltrain
Highway
Transportation Features
Arterial
Local Street
CGS Landslide Zones
Zones of Required Investigation for
Earthquake-Induced Landslides
CGS Alquist Priolo Fault Zones & Traces
Accurately Located
Approximately Located
Approximately Located, Queried
Inferred
CGS Alquist Priolo Fault Zones
San Francisco Bay
FerryTerminal
San Bruno Creek
C o l m a C r e e k AirportBlvdChestnut AveE Grand Ave
Grand Ave
Oyster Point Blvd
SAi
rpor
t
Bl
vd
H ills id e B lv d
Fo r b es Bl vd
Gateway B lv d
DNAWaySisterCitiesBlvd
E
l
Ca
mi
n
o
R
e
a
lJunipero Ser
r
a Bl
vdW e s tb o roughBlvdCa
ll
a
n
B
lv
d
H i c k e y B l v d
SpruceA v e
S Linden AveUtah AveSSpruceAveGellertBlvd
380
280
35
82
101
California
Golf Club
Unincorporated
Area
Pacifica
San Bruno
Colma
Daly City
Brisbane
San Francisco
International
Airport
50000006 • 08/2022 | 3.6-5_Liquefaction Potential.mxd
Exhibit 3.6-5Liquefaction Potential
Source: Raimi + Associates, July 2019. ESRI, U.S. Geological Survey (USGS). California Department of Conservation. California Geological Survey (CGS).
CITY OF SOUTH SAN FRANCISCOGENERAL PLAN UPDATE, ZONING CODE AMENDMENTS, AND CLIMATE ACTION PLANENVIRONMENTAL IMPACT REPORT
3,000 0 3,0001,500
Feet
City of South San Francisco
Other City Boundaries
Jurisdictional Boundary
Sphere of Influence
BART
Caltrain
Highway
Transportation Features
Arterial
Local Street
CGS Liquefaction Zones
Zones of Required Investigation
for Liquefaction
Exhibit C
2040 General Plan Update Draft EIR and Appendices
Links:
- Draft EIR
- Appendix A – NOP and Scoping Comments
- Appendix B – Air Quality, Energy and GHG Supporting Information
- Appendix C – Biological Resources Sup porting Information
- Appendix D – Cultural Resources – Tribal Cultural Resources Supporting Information
- Appendix E – Geology, Soils, and Seismicity Supporting Information
- Appendix F – Hazards and Hazardous Mat erials Supporting Information
- Appendix G – Noise Supporting Information
- Appendix H – Transportation Supporting Information