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HomeMy WebLinkAboutCommunity Civic Center Final SEIRC ITY OF S OUTH S AN F RANCISCO C OMMUNITY C IVIC C AMPUS P ROJECT FINAL SEIR Prepared for: CITY OF SOUTH SAN FRANCISCO 315 MAPLE STREET SOUTH SAN FRANCISCO, CA 94080 Prepared by: 1 KAISER PLAZA, SUITE 1150 OAKLAND, CA 94612 OCTOBER 2017 C ITY OF S OUTH S AN F RANCISCO C OMMUNITY C IVIC C AMPUS P ROJECT FINAL SEIR Prepared for: CITY OF SOUTH SAN FRANCISCO 315 MAPLE STREET SOUTH SAN FRANCISCO, CA 94080 Prepared by: MICHAEL BAKER INTERNATIONAL 1 KAISER PLAZA, SUITE 1150 OAKLAND, CA 94612 OCTOBER 2017 TABLE OF CONTENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR i 1.0 INTRODUCTION 1.1 Purpose of the EIR Process ........................................................................................................ 1-1  1.2 Response to Comments and FEIR Revisions ........................................................................... 1-1  1.3 EIR Certification Process and Project Approval .................................................................... 1-1  2.0 RESPONSE TO COMMENTS 2.1 Introduction ................................................................................................................................ 2-1 2.2 Responses to Comment Letters on the Draft SEIR................................................................. 2-1 2.3 Comments and Responses ...................................................................................................... 2-1 2.4 Responses to Comment Letters .............................................................................................. 2-2 Response to Letter Governor’s Office of Planning and Research (OPR) .......................... 2-3  Response to Letter San Francisco International Airport (SFO) ............................................ 2-6  Response to Letter Mina Richardson (MR) ............................................................................. 2-8  Response to Letter Rob Bartoli (RB) ....................................................................................... 2-10  Response to Letter California Department of Transportation (Caltrans) ....................... 2-12 Response to Letter County of San Mateo (CSM) ................................................................ 2-22  Response to Letter Rene Alejandro Ortega, Esq. (RAO) ................................................... 2-25  Response to Planning Commission Comments (PC) .......................................................... 2-33  3.0 AMENDMENTS TO THE DRAFT SEIR 3.1 Amendments to the Draft SEIR ................................................................................................ 3-1 TABLES 2.0-1 Draft SEIR Comments Received .............................................................................................. 2-1 2.0-2 Community Civic Campus Elements ...................................................................................... 3-1 APPENDIX Appendix A – Mitigation Monitoring and Reporting Plan Appendix B – Draft SEIR TABLE OF CONTENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 ii This page intentionally left blank. 1.0 INTRODUCTION 1.0 INTRODUCTION City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 1-1 1.1 PURPOSE OF THE EIR PROCESS This Final Subsequent Environmental Impact Report (Final SEIR) is an informational document prepared by the City of South San Francisco (City) to evaluate the potential environmental impacts of the proposed Community Civic Campus Project (the project). The primary objectives of the EIR process under the California Environmental Quality Act (CEQA) are to inform decision- makers and the public about a project’s potential significant environmental effects, identify possible ways to minimize significant effects, and consider reasonable alternatives to the project. This SEIR has been prepared with assistance from the City’s environmental consultants, Michael Baker International, along with Kimley-Horn and CSS Environmental Services, Inc., and reviewed by City staff for completeness and adequacy in accordance with Public Resources Code (PRC) Sections 21000–21177 and the CEQA Guidelines. As prescribed by CEQA Guidelines Sections 15088 and 15132, the lead agency, the City of South San Francisco, is required to evaluate comments on environmental issues received from persons who have reviewed the Draft SEIR and to prepare written responses to those comments. This document, together with the Draft SEIR (incorporated by reference in accordance with CEQA Guidelines Section 15150), will comprise the Final SEIR for the project. Pursuant to CEQA requirements, the City must certify the Final SEIR as complete and adequate prior to approval of the project. This Final SEIR contains individual responses to each written and verbal comment received during the public review period for the Draft SEIR. In accordance with CEQA Guidelines Section 15088(b), the written responses describe the disposition of significant environmental issues raised. The City and its consultants have provided a good faith effort to respond in detail to all significant environmental issues raised by the comments. 1.2 RESPONSE TO COMMENTS AND FEIR REVISIONS A Notice of Availability was published by the City and distributed to interested parties on July 12, 2017. The Draft SEIR was posted on the City’s website and available for public review and comment between July 12, 2017, and August 28, 2017. Comments received during the public review period are addressed in this Final SEIR. 1.3 EIR CERTIFICATION PROCESS AND PROJECT APPROVAL In accordance with the requirements of CEQA, the City Council must certify the SEIR as complete and adequate prior to taking action on the proposed Community Civic Campus Project. Once the SEIR is certified and all information considered, using its independent judgment, the City can take action on the project. While the information in the SEIR does not control the City’s decision, the City must respond to each significant effect and mitigation measure identified in the SEIR by making findings supporting its decision. 1.0 INTRODUCTION Community Civic Campus Project City of South San Francisco Final SEIR October 2017 1-2 This page intentionally left blank. 2.0 RESPONSE TO COMMENTS 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-1 2.1 INTRODUCTION This Final Subsequent Environmental Impact Report (Final SEIR) was prepared in accordance with the California Environmental Quality Act (CEQA) (California Public Resources Code Section 21000 et seq.) and CEQA Guidelines (California Code Regulations Section 15000 et seq.). The City of South San Francisco (the City) is the lead agency for the environmental review of the project and has the principal responsibility for approving the project. This Final SEIR assesses the expected environmental impacts resulting from the approval and implementation of the project and responds to comments received on the Draft SEIR. 2.2 RESPONSES TO COMMENT LETTERS ON THE DRAFT SEIR The following commenters submitted written comments on the Draft SEIR. The comment period for the Draft SEIR began July 12, 2017, and ended August 28, 2017. Confirmation of lead agency compliance with CEQA for public review of the Draft SEIR was received from the Governor’s Office of Planning and Research on July 12, 2017. The South San Francisco Planning Commission heard comments on the Draft SEIR on August 17, 2017. TABLE 2.0-1 DRAFT SEIR COMMENTS RECEIVED Letter Name Date Received Agencies/Individuals OPR Governor’s Office of Planning and Research (OPR) July 6, 2017 SFO San Francisco International Airport, Nile Ledbetter July 19, 2017 MR Mina Richardson August 15, 2017 RB Rob Bartoli August 23, 2017 CAL California Department of Transportation (Caltrans) August 25, 2017 CSM County of San Mateo August 28, 2017 RAO Rene Alejandro Ortega, Esq. August 28, 2017 Comments at the Planning Commission Meeting PC-1 Teresa Benavides August 17, 2017 PC-2 John Tuvo August 17, 2017 PC-3 Commissioner Mark Nagales August 17, 2017 2.3 COMMENTS AND RESPONSES REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT SEIR CEQA Guidelines Section 15088 requires that lead agencies evaluate all comments on environmental issues received on the Draft EIR and prepare a written response. The written response must address the significant environmental issue raised and must be detailed, especially when specific comments or suggestions (e.g., additional mitigation measures) are not accepted. In addition, there must be a good faith and reasoned analysis in the written response. However, 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-2 lead agencies need only respond to significant environmental issues associated with the project and do not need to provide all the information requested by commenters, as long as a good faith effort at full disclosure is made in the EIR (CEQA Guidelines Section15204). CEQA Guidelines Section 15204 recommends that commenters provide detailed comments that focus on the sufficiency of the Draft EIR in identifying and analyzing the possible impacts on the environment and ways in which the project’s significant effects might be avoided or mitigated. This section also notes that commenters should include an explanation and evidence supporting their comments. Pursuant to CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence supporting such a conclusion. Where changes to the Draft SEIR text result from responding to comments, those changes are included in the response and demarcated with revision marks: underline for new text, strikeout for deleted text. CEQA Guidelines Section 15088 recommends that where a response to comments results in revisions to the Draft EIR, those revisions be incorporated as a revision to the Draft EIR or as a separate section of the Final EIR. Revisions to the Draft SEIR are incorporated as Section 3.0 of this Final SEIR. 2.4 RESPONSES TO COMMENT LETTERS Written comments on the Draft SEIR are reproduced on the following pages, along with responses to those comments. Seven comment letters were received—four from public agencies, one from a public interest group, and two from individuals. In addition, two individuals and one commissioner raised questions pertinent to the Draft SEIR at the Planning Commission meeting on August 17. To assist in referencing comments and responses, the following coding system is used:  Comment letters from government agencies are coded by abbreviations, and each issue raised in the comment letter is assigned a number (e.g., Comment Letter OPR, comment 1 is referred to as OPR-1).  Comment letters from individuals are coded by letters, and each issue raised in the comment letter is assigned a number (e.g., Comment Letter MR, comment 1 is referred to as MR-1).  Comments received at the Planning Commission meeting are coded in the order the comments were received (e.g., Planning Commission comment 1 is referred to as PC-1). 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-3 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-4 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-5 RESPONSE TO LETTER OPR – GOVERNOR’S OFFICE OF PLANNING AND RESEARCH (OPR) Response to Comment OPR-1 This letter includes the project’s Notice of Completion (NOC) endorsed by the State Clearinghouse. The NOC is administrative in nature, and no response is required. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-6 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-7 RESPONSE TO LETTER SFO – SAN FRANCISCO INTERNATIONAL AIRPORT Response to Comment SFO-1 This comment states that the Airport Land Use Compatibility Plan, published in 2012, moved the 65 db noise contour in the previous 1996 Comprehensive Airport Land Use Plan. With the move, no portion of the El Camino Real/Chestnut Avenue (ECR/C) plan area, including the project site, is located within the 65 db noise contour. This document is a subsequent environmental impact report to the 2011 ECR/C EIR. A subsequent EIR analyzes the incremental change that occurs after an EIR is certified to determine if a change would increase the environmental impacts of a project. Each impact finding summarizes the conclusions in the original EIR, then analyzes the impact of the updated project. The original ECR/C EIR was certified in 2011 and used the 65 db noise contour from the 1996 Comprehensive Airport Land Use Plan. At this time, the southwest corner of the ECR/C Area Plan was within the noise contour. On page 3.9-22, in the summary of the findings of the 2011 ECR/C EIR, the Draft SEIR states that the plan area is within the noise contour. The impact conclusion for the subsequent project impact, also on page 3.9-22, states that the project site is not within any noise impact zones. Page 3.9-22, paragraphs 3 and 4, are revised as follows: 2011 ECR/C Area Plan Impacts Under the San Francisco International Comprehensive Airport Land Use Plan, the 2001 Noise Exposure Map (NEM) is the most recent federally accepted NEM and is the noise contour map that C/CAG uses in making its determination of the consistency of a proposed local agency land use policy action with the plan. A small portion of the Planning Area in the southwest is was, at the time of publication of the 2011 ECR/C EIR, located between the 2001 CNEL 60 dB and CNEL 65 dB noise contours (i.e., noise levels are between CNEL 60 dB and CNEL 65 dB). No noise/land use compatibility standards apply within these noise contours (South San Francisco 2011b, p. 3.5-10). Therefore, plan implementation would have no impact. Subsequent Project Impacts As analyzed in the ECR/C EIR, there are no private airports in the vicinity of the project site. The project site is located approximately 2.6 miles northwest of San Francisco International Airport. A review of the updated Comprehensive Airport Land Use Plan for the Environs of San Francisco International Airport (C/CAG 2012) shows the project site is no longer located outside of any within the noise impact zones. Therefore, the revised project would continue to have no impact. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-8 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-9 RESPONSE TO LETTER MR – MINA RICHARDSON Response to Comment MR-1 The commenter questions the need for a civic center and the process by which decisions were made about the project. The comment does not focus on the adequacy or scope of the environmental document. For more information on Measure W, please see: http://www.ssf.net/government/measure-w. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-10 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-11 RESPONSE TO LETTER RB – ROB BARTOLI Response to Comment RB-1 This commenter asks why the intersection of Chestnut Avenue and Commercial Avenue was not analyzed in the transportation impact analysis (TIA), and that it should be studied because the traffic study indicates intersection delays at Grand Avenue and Mission Road would increase slightly. Commercial Avenue is a local street extending east from Chestnut Avenue to Linden Avenue and west to Oak Avenue. It is a four-way stop intersection at Chestnut Avenue. Unlike Grand Avenue, it is not a collector street with high traffic volumes. It generally provides local access to the residential uses on both sides of the street and is not a primary east-west roadway for through- travel in the project vicinity. The intersection of Chestnut Avenue and Commercial Avenue is located between two signalized intersections that were studied in the 2011 ECR/C EIR: Intersection 7, Chestnut Avenue/Grand Avenue and Intersection 9, Mission Road/Chestnut Avenue. The Chestnut Avenue/Commercial Avenue intersection was not studied in the 2011 ECR/C EIR. The environmental impact report prepared for the Community Civic Campus Project was a Subsequent EIR (SEIR). The Draft SEIR specifically considered whether the project would result in new significant impacts not identified in the 2011 ECR/C EIR, or if the project would cause a substantial increase in the severity of the previously identified significant impacts. The SEIR analyzed the same intersections that were analyzed in the DEIR and therefore did not include the Chestnut Avenue/Commercial Avenue intersection. Based on the results of the 2011 ECR/C EIR traffic analysis and the trip distribution for the proposed project (Figure 7 in the TIA [Appendix TRA in the DEIR]), which shows that Commercial Avenue would not add trips to the intersection, there was no compelling reason that the Chestnut Avenue/Commercial Avenue intersection should be analyzed. The traffic analysis prepared for the Draft SEIR, which concluded that the traffic volumes generated by the proposed project would not worsen intersection levels of service at the signalized intersections (Grand Avenue and Mission Road), even though delays would increase by a few seconds under both Existing plus Project (2016) and Existing plus Project (2030). Intersection LOS conditions with or without the project would not require signalization of the intersection. Because there would be no worsening of conditions at the Grand Avenue and Mission Road signalized intersections on Chestnut Avenue, it is reasonable to conclude conditions would not be worsened at the four-way stop at Commercial Avenue with the proposed project, and no further analysis is necessary. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-12 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-13 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-14 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-15 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-16 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-17 RESPONSE TO LETTER CAL – CALIFORNIA DEPARTMENT OF TRANSPORTATION (CALTRANS) The first page of this comment letter and a portion of the second page is introductory material that provides an overview of Caltrans’ role in regional transportation planning, summarizes the proposed project components, and notes that the City of South San Francisco is responsible for project mitigation. It also states that the project location is an ABAG-identified Priority Development Area. The information does not raise any issues regarding the adequacy of the DSEIR. Response to Comment CAL-1 The commenter suggests that the City should analyze bicycle and pedestrian level of service impacts and take measures to increase accessibility of the site for public transportation and transit. The commenter also recommends the project should include completion of nearby bicycle facilities along north/south corridors and proposed bicycle facilities along Chestnut Avenue and proposed intersection improvements at El Camino Real and Chestnut Avenue. The Draft SEIR analyzed bicycle and pedestrian facilities impacts in Impact 3.10.5 on pages 3.10- 33 through 3.10-35 in the Draft SEIR. A description of the City’s Pedestrian Master Plan is included on page 3.10-21 in the Draft SEIR, which provides the following recommended improvements in the vicinity of the proposed Community Civic Campus project: sidewalk improvements at El Camino Real and Chestnut Avenue and Antoinette Lane and Chestnut Avenue; ADA improvements at El Camino Real and Chestnut Avenue, El Camino Real and Arroyo Drive, and Arroyo Drive and Camaritas Avenue; enhancements of linear barriers such as Colma Creek to improve comfort and safety; and extension of Centennial Way Trail through the Chestnut Avenue Crossing. The City’s Bicycle Master Plan is described on page 3.10-22. Improvements identified in the plan in the vicinity of the proposed project are a bicycle lane along Chestnut Avenue and a bicycle route along Arroyo Drive. The Draft SEIR concluded (page 3.10-34) that project implementation would not interfere with the planned pedestrian improvements outlined in the Pedestrian Master Plan or the El Camino Real/Chestnut Avenue (ECR/C) Area Plan. The project would not create inconsistencies with adopted pedestrian system plans, guidelines, policies, or standards. The project would increase the demand on bicycle facilities in the project vicinity. With implementation of the planned facilities identified in the Bicycle Master Plan, the project site would be served by roadways that would be safe and accessible for bicyclists. Currently, sidewalks and pedestrian paths exist along most of the roadways within the ECR/C plan area. Sidewalks along the east side of El Camino Real provide access to the bus stops on the east side of El Camino Real and also provide access to the South San Francisco Bay Area Rapid Transit (BART) station. On the west side of El Camino Real, there are no sidewalks between McLellan Drive and Arroyo Drive. However, the bus stops on the west side of El Camino Real have pedestrian crosswalks at signalized intersections that connect to sidewalks. These pedestrian facilities are critical to the use of transit in the area and would conform to the latest Americans with Disabilities Act (ADA) standards. In addition, a mixed-use path—the Centennial Way Trail—is a trail for pedestrians, shared with bicyclists, to traverse the ECR/C plan area and to connect the San Bruno and South San Francisco BART stations. This path would encourage pedestrian use and also provide an alternative to El Camino Real for pedestrians to travel north–south. The off-street pedestrian pathway provides 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-18 increased safety for pedestrians from vehicles, reduced delays due to fewer roadway crossings, and wider path widths, thereby improving the pedestrian level of service. Although the project would potentially generate pedestrian demand, there should be sufficient capacity based on the existing pedestrian network. Therefore, the project would not interfere with any of the existing or planned pedestrian facilities. Currently, several bicycle facilities exist in the project vicinity. There are also several planned and proposed bicycle facilities within the ECR/C plan area. The Centennial Way Trail, as mentioned above, would be improved as part of the Project and would facilitate bicycle access throughout the ECR/C plan area and access to the San Bruno and South San Francisco BART stations. The off- street bicycle pathway provides increased safety for bicyclists from vehicles, reduced delays due to fewer roadway crossings, and wider path widths, thereby improving the bicycle level of service. Although the project would potentially generate bicycle demand, there should be sufficient capacity based on the existing bicycle network. Additionally, the proposed Grand Boulevard project would provide Class II bicycle lanes with bicycle detector loops on El Camino Real between Chestnut Avenue and McLellan Drive. The Draft SEIR (page 3.10-34) concluded that the project would not interfere with any of the existing or planned bicycle facilities or conflict with currently adopted bicycle goals or policies. Therefore, the project would not result in any adverse impacts on bicyclists. With regard to the commenter’s suggestions about bicycle facility improvements, the proposed project would not result in any significant impacts requiring mitigation. The City would construct necessary bicycle facilities to serve the proposed project, consistent with the Bicycle Master Plan. Recommended improvements beyond those necessary to serve the proposed project or not included in the Bicycle Master Plan may be constructed as City approvals and funding allow. Response to Comment CAL-2 The commenter recommends expanding the freeway segment study area beyond the previous limit to include impacts between the Sneath Lane interchange and the Collins Avenue interchanges, which are on Interstate 280 (I-280). The commenter did not provide an explanation why the freeway segment study area should be expanded. The environmental impact report prepared for the Community Civic Campus Project was a Subsequent EIR (SEIR). The Draft SEIR specifically considered whether the project would result in new significant impacts not identified in the 2011 ECR/C EIR, or if the project would cause a substantial increase in the severity of the previously identified significant impacts. The 2011 ECR/C EIR studied the freeway segments on I-280 between Avalon Drive and Hickey Boulevard and concluded that impacts would be less than significant (Draft SEIR pages 3.10-26). The Sneath Lane and Collins Avenue interchanges were not evaluated in the 2011 TIA. As shown in the calculations in footnote 1 on page 3.10-26 in the Draft SEIR, the proposed project is expected to generate significantly fewer project trips in the AM peak hour, PM peak hour, and daily than assumed in the analysis in the 2011 ECR/C EIR. The proposed project would result in fewer trips and is limited to changes in only a portion of the ECR Plan Area. Project impacts on freeway segments were evaluated in Impact 3.10.1 on page 3.10-31 and cumulative Impact 3.10.6 on page 3.10-43 in the Draft SEIR. The Draft SEIR concluded the proposed project would not have a significant effect on the freeway segments that were analyzed. Because the proposed project would not result in new or more severe freeway segment impacts for the ones that were analyzed, it is reasonable to conclude the proposed project would not result in a new or more severe impact at interchanges farther from the study area, and no analysis is necessary. 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-19 The commenter also requested that 95th percentile queuing analysis be completed for eight intersections (four on El Camino Real and four at I-280 ramps). As noted above, the purpose of the Draft SEIR was to identify any new significant or more severe environmental impacts than those disclosed in the 2011 ECR/C EIR. The 2011 ECR/C EIR did not identify any significant traffic queuing impacts at the study area intersections. The four intersections on El Camino Real and the Westborough/I-280 southbound off-ramp were evaluated in the 2011 ECR/C EIR and in the Draft SEIR. The three remaining I-280 ramp intersections were not evaluated in either EIR. The results of the intersection LOS analysis for the proposed project show that the same intersections would be affected as those identified in the 2011 ECR/C EIR, and there would still be significant impacts at the El Camino Real intersections. Identical to the 2011 ECR/C EIR conclusion, there would not be a significant impact at the Westborough/I-280 southbound offramp. A comparison of the LOS and intersection delays in the 2011 ECR/C EIR to the LOS and intersection delays in the Draft SEIR generally show reductions in delay at the evaluated intersections. It is reasonable to conclude queue lengths would also decrease at intersections. Therefore, analysis of intersection queuing, including three intersections not previously considered, is not necessary. Response to Comment CAL-3 The commenter notes discrepancies in peak-hour turning movement volumes for intersections 11 (Westborough Boulevard/I-280 southbound ramp) and 12 (Westborough Boulevard/I-280 northbound/Junipero Serra Boulevard in Figure 10 the TIA. Figure 10 shows the peak hour traffic volumes generated by the proposed project when added to existing (2016) conditions. The discrepancy in turning movement volumes is due to the I-280 northbound diagonal on-ramp. Vehicles traveling westbound on Westborough Boulevard traveling I-280 northbound would make a westbound through movement, not a westbound right-turn movement at Intersection 12. After traveling through this intersection, the vehicles would make a westbound right turn onto I-280 northbound, hence the decrease in traffic volume at Intersection 11 for the westbound approach. Response to Comment CAL-4 The commenter states that Table 22 in the TIA (Freeway Segment Analysis for Cumulative [2030] Plus Project) shows five lanes in each direction for the four I-280 segments analyzed, while there are only four lanes for all four segments. The five lanes studied in each direction for the Cumulative (2030) conditions are based on the City/County Association of Governments for San Mateo County’s Congestion Management Plan for 2009 travel demand model (see Appendix TRA of the Draft SEIR). The Year 2030 Baseline model showed five lanes for each direction on Interstate 280 from Hickey Boulevard to Avalon Drive. This lane configuration was used to generate the future volumes. Even if the freeway segments were not increased to five lanes in each direction, the project would not create a significant impact because the project trips would add less than 1 percent of the freeway capacity (Draft SEIR Table 3.10-10, page 3.10-43). 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-20 Response to Comment CAL-5 The commenter suggests the City use vehicle miles traveled (VMT) as a way to analyze the project’s environmental impacts. The City has not adopted a policy or threshold for evaluating VMT impacts under CEQA. The state’s Office of Planning and Research has developed draft criteria and guidelines for using VMT as a metric for evaluating traffic impacts under CEQA. Once the final draft of changes to the CEQA Guidelines is published, certification and adoption by the Secretary for Resources will be required before the amendments go into effect. Cities will then have 2 years to implement the new guidelines. Although the comment mentions the use of a change in VMT of 15 percent, this is not an adopted threshold for evaluating the significance pursuant to CEQA Until such formal adoption occurs, the Level of Service (“LOS”) standard used in both the ECR/C EIR and the Draft SEIR is an appropriate means to examine the proposed project’s potential environmental impacts. Response to Comment CAL-6 The commenter recommends that the City include a Transportation Demand Management (TDM) Program to reduce VMT, and includes a list of suggested measures. The City requires TDM for all nonresidential development expected to generate 100 or more average daily trips, based on the Institute of Traffic Engineers (ITE) trip generation rates. The City’s TDM program includes a set of policies, programs, and strategies that relieve congestion, improve a project’s environmental footprint, and reduce parking demand by using existing resources and investments more efficiently. Existing resources include local streets and regional highways, public transit, bicycle and pedestrian facilities, and other public infrastructure. TDM does this by: • Eliminating trips (i.e., working remotely or compressed workweeks)  Shifting inefficient, single-occupant trips to higher efficiency, higher occupancy trips (transit, shuttles, and carpools) • Shifting the time of travel to avoid “peak” congestion periods • Shifting auto trips to active transportation modes (i.e., walking, bicycling) • Providing technological solutions (i.e., clean air vehicles) to reduce pollution In addition to policies in the City’s General Plan, the City’s Climate Action Plan reinforces the need for TDM. The City will require and implement TDM measures for the project in accordance with zoning regulations, General Plan policies and the CAP, as applicable. Response to Comment CAL-7 The commenter asks that the City identify project-generated travel demand on public transportation and estimate the costs of public improvements. As noted on page 3.10-34 of the Draft SEIR, the project is expected to generate transit ridership. The current transit services in the area are not running at full capacity; therefore, the additional passengers would be accommodated by the existing services. In addition, the project-generated 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-21 riders would be spread across the various planned bus routes and Bay Area Rapid Transit system resulting in a minimal effect on transit capacity. CEQA does not require analysis of the fiscal impacts of projects. Response to Comment CAL-8 The commenter advises that projects in the state right-of-way require encroachment permits. Comment noted. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-22 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-23 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-24 RESPONSE TO LETTER CSM – COUNTY OF SAN MATEO Response to Comment CSM-1 This commenter refers to the Colma Creek Flood Control Zone and states that future projects would need to demonstrate that the post-development discharge rate would not exceed the existing rate. This statement is correct. Future development would comply with the County’s discharge requirements. Those calculations would be submitted for comment and review as part of the final design package and will show compliance with county and local regulations. Response to Comment CSM-2 The commenter recommends that trash management measures be incorporated into the design elements of the storm drainage system and appurtenances. The City’s Environmental Compliance Program administers the Pretreatment Program, Pollution Prevention Program, and Stormwater Pollution Prevention Program mandated by the State of California. The programs regulate and control concentrations of wastewater and stormwater pollutants discharged by industrial, commercial , and residential discharges. Future development would comply with the City’s programs and state, regional, and local regulations regarding water quality. 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-25 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-26 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-27 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-28 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-29 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-30 RESPONSE TO LETTER RAO – RENE ALEJANDRO ORTEGA, ESQ. Response to Comment RAO-1 The commenter summarizes concerns in the overall letter. Responses to individual comments are provided below. Response to Comment RAO-2 This comment states the legal requirements for general plans and housing elements. It is for information purposes and does not focus on the adequacy or scope of the environmental document. No additional response is required. Response to Comment RAO-3 This comment outlines the Regional Housing Needs Allocation (RHNA) for the City of South San Francisco. It is for information purposes and does not focus on the adequacy or scope of the environmental document. No additional response is required. Please see response to comment RAO-4 regarding the City’s Regional Housing Needs Allocation (RHNA) requirements. Response to Comment RAO-4 The commenter states that the SEIR fails to discuss the project’s inconsistency with the City’s Housing Element because it would remove planned housing in the Transit Village Area. The City RHNA requires zoning to permit at least 1,864 units within the 2015-2023 Adopted Housing Element. The City has zoning in place to construct up to 2,169 units; this allocation is split between units in the Downtown Area and Transit Village Area, comprised of much of the area identified within the ECR/C Plan. Zoning in place assumes up to 305 units greater than required by RHNA for possible construction. The commenter indicates that the proposed project area removes 331 assumed potential housing units across Site 3-H and Site 5 from Figure 2 of the adopted Housing Element. This is a correct assessment. While the adopted Housing Element identified zoning to allow 305 units in excess of the RHNA requirement, this would leave a gap of 26 units1. The project includes rezoning of the Municipal Services Building at 33 Arroyo Drive and adjacent parking lot, an approximately 2.1 acre site. As described on page 2.0-12 of the Draft SEIR, the western project site would be redesignated to the El Camino Real Mixed Use North, High Intensity land use designation. While construction of a new 7,250-square-foot Fire Station 63 is proposed in the site’s western corner, the new zoning designation would allow for up to 80 dwelling units per acre over the remaining1.8 acres (estimate), for a potential of 144 dwelling units permissible under the new zoning. With this revision, the Housing Opportunity Sites identified within the 2015-2023 Housing Element will have the capacity for 1,982 potential units, with an excess capacity of 118 1 Calculation: 331 housing units minus 305 housing units = 26 housing units. 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-31 units above the RHNA requirement for 1,864 units. Therefore, the project would not conflict with the City’s Housing Element because it maintains an adequate overall number of potential housing units that meets the RHNA obligation and will not result in displacement of assumed units. The adopted 2015-2023 Housing Element will be updated as part of the General Plan Amendment for the Project to reflect this change in the identified opportunity sites. Response to Comment RAO-5 The commenter states that the SEIR fails to adequately address air quality impacts and greenhouse gas emissions because the people who would have lived in the Transit Village Area would be forced to commute farther. The City prepared an SEIR to the ECR/C EIR because the project included changes that required additional analyses per CEQA Section 15162(b). The SEIR evaluated the air quality impacts and greenhouse gas (GHG) emissions of the change in the ECR/C project by comparing the revised project to the original ECR/C EIR analyses. The ECR/C EIR concluded that the ECR/C Area Plan would not be inconsistent with air quality control measures in the 2010 Bay Area Clean Air Plan. The Bay Area Air Quality Management District (BAAQMD) guidelines specify that the plan-level air quality impact is evaluated by determining the proposed plan’s VMT increase and comparing it to the project population increase. The plan would increase population by 20.4 percent in South San Francisco, while VMT would increase by approximately 16.6 percent. The ECR/C area plan and the City’s General Plan policies conform to the control strategies included in the 2010 Bay Area Clean Air Plan. Therefore, the plan would have a less than significant impact on air quality. The ECR/C EIR also determined that the ECR/C Area Plan would increase commercial development in the planning area and could result in increased GHG emissions, which would contribute to global climate change. With emissions reductions under these laws and guidelines, the project would result in 2035 emissions levels that are slightly higher than baseline levels without the project, but emissions per service population are lower than the BAAQMD thresholds baseline rate under the plan. Due to these emissions reductions, emissions in 2020 and 2035 would not exceed existing levels. Per service population emissions would not exceed 4.6 metric tons of CO2e. Therefore, the plan would not make a considerable contribution to the impact. The SEIR determined that the revised project would not conflict with the BAAQMD’s 2017 Clean Air Plan. As shown in Table 3.2-9 (page 3.2-22 of the Draft SEIR), the project’s predicted maximum daily construction-generated emissions with mitigation would not exceed BAAQMD’s significance thresholds for air pollutants. Also, as outlined in Table 3.2-10 (page 3.2-23 of the Draft SEIR), the project’s long-term operational emissions of criteria air pollutants and ozone precursors would not exceed BAAQMD’s significance thresholds. This impact would be less than significant with mitigation for construction emissions. The SEIR concluded that the revised project would not exceed the BAAQMD’s service population efficiency threshold for GHG emission impacts. Table 3.6-7 (page 3.6-19 of the Draft EIR) show that the project’s annual generation of GHG emissions from construction and operations divided by the service population would not exceed the BAAQMD efficiency-based threshold. This impact would be less than significant. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-32 Per CEQA Guidelines Section 15064(d)(3), a lead agency need not consider a change that is speculative. The City determined that future air quality and greenhouse gas emissions from any potential displacement of residents would be speculative and need not be discussed further, in compliance with CEQA Guidelines Section 15145. Response to Comment RAO-6 The commenter states that the SEIR does not adequately inform the public and decision-makers of the environmental effects of the project, since it does not address inconsistencies between the proposed project and the City’s Housing Element or the potential increase in air quality and greenhouse gas emissions due to potential displacement of future occupants. Please see responses to comments RAO-4 and RAO-5 regarding the SEIR’s adequate analyses of CEQA thresholds. 2.0 RESPONSES TO COMMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 2-33 RESPONSE TO COMMENTS RECEIVED AT PLANNING COMMISSION (PC) MEETING Response to Comment PC-1 Teresa Benavides stated that she thought the project was a fantastic idea for the city, but she expressed concerns about the projects being proposed at the Civic Center Campus, the South San Francisco carwash location, and the existing Municipal Services Building location. She stated that the Chestnut Avenue/El Camino Real intersection is a traffic nightmare and should be coordinated. She said congestion is a major concern. As described on page 3.10-28 of the Draft SEIR, the project would cause significant impacts on the Chestnut Avenue/El Camino Real intersection and would require the following mitigation measure. MM 3.10.1b The City shall modify the signal timing, as outlined in the TIA, to optimize the cycle length at the intersection of El Camino Real and Chestnut Avenue. With implementation of mitigation measure MM 3.10.1b, impacts would be reduced to less than significant. Additionally, the Project and any subsequent development will require a City reviewed and approved traffic control plan and hauling plan for the duration of on-site construction. This plan will monitor and obligate the on-site contractors to operate consistent with local and state traffic regulations. Response to Comment PC-2 John Tuvo asked for specific information regarding the recreation center. He wanted to know what that facility will include, such as a multipurpose room or other indoor uses. He also stated that basketball facilities are needed in the city. He asked what will happen to the existing municipal building. He also questioned whether the project was being funded by bonds. As described in the Draft SEIR, the joint Library and Recreation Center would be up to 92,000 square feet in size and would contain space for a variety of uses. Preliminary program space is fully described in Table 2.0-2, Community Civic Campus Elements (page 2.0-11 of the Draft SEIR). As described on page 2.0-12 of the Draft SEIR, the Municipal Services Building is seismically unsafe and is unlikely to be retenanted in its current form. It is unclear at this time whether the Municipal Services Building would be seismically retrofitted or if the building would be demolished to make way for a new use. For more information on Measure W, please see: http://www.ssf.net/government/measure-w. Response to Comment PC-3 Planning Commissioner Mark Nagales asked about the one entrance off Chestnut Avenue. He wanted to know the traffic implications of having one way in and out of the site. He mentioned that those four points are busiest. He suggested the need for another entrance/exit on El Camino Real and opined that the project needs multiple points of entrance. 2.0 RESPONSES TO COMMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 2-34 The project would have a significant impact on the intersection of El Camino Real and Chestnut Avenue, but mitigation measure MM 3.10.1b would reduce impacts to less than significant. In addition, this intersection is already operating at unacceptable levels of service in the existing AM and cumulative AM and PM peak hours without the project. The traffic analysis did assume an entry/exit on El Camino Real between Arroyo Drive and Chestnut Avenue. However, to reduce the impact on the El Camino Real/Chestnut Avenue intersection, it was recommended that an entry/exit at the intersection of Arroyo Drive and El Camino Real be incorporated in the final design. 3.0 AMENDMENTS TO THE DRAFT SEIR 3.0 AMENDMENTS City of South San Francisco Community Civic Campus Project October 2017 Final SEIR 3-1 3.1 AMENDMENTS TO THE DRAFT SEIR In the revised text below, please note that additions are underlined and deletions are shown in strikeout. AMENDMENT TO SECTION 2.0, PROJECT DESCRIPTION In Table 2.0-2, Community Civic Campus Elements (page 2.0-11), it is unclear how much space is allocated to large and medium-sized classrooms. The square footage presented in the table is per classroom, not total for classroom space. The corrected Table 2.0-2 is below. TABLE 2.0-2 COMMUNITY CIVIC CAMPUS ELEMENTS* Type of Space Purpose and Size Performance space  100-seat theater Exhibit space  300 square feet of gallery space Social space  3,000 square feet of informal social space  Library reading rooms and seating areas for children, teens, and adults  Library collaboration spaces Program spaces  6,000-square foot social hall, frequent rentals  1,600-square-foot library program room  1,100-square-foot maker space “Tinker Lab”  800-square-foot technology lab Classrooms  Four large classrooms (1,200 square feet each)  Two medium-sized classrooms (1,000 square feet each)  One large dance studio (1,600 square feet)  One medium dance studio (800 square feet) Retail  300-square-foot café  500-square-foot Friends of the Library store Civic  3,000-square-foot council chambers, flexible for City programming and rentals  City Council support spaces Preschool*  Three 20-child classrooms  Staff workspace and support space  Secure outdoor play space for 60 children Staff space  Library offices and workstations  Parks and Recreation Department offices and workstations  Shared reception, collaboration, and breakout space  Space for future staff growth Storage and building support  Building and program storage  Building systems, restrooms Outdoor space  Building rooftops: up to 6,000 square feet of usable rooftop area  Events plaza: for day-to-day informal gathering and seating with the ability to host periodic special events for 350–500 people 3.0 AMENDMENTS Community Civic Campus Project City of South San Francisco Final SEIR October 2017 3-2 Type of Space Purpose and Size  Meadow: for casual gathering and passive recreation  Centennial Trail: connection to the existing trail with a bike and running path Parking  Up to 294 spaces, both underground and aboveground Source: South San Francisco 2017 Notes*: 1.Programming for purposes of CEQA but minor variations possible in final Community Civic Campus Project. 2. Preschool programming is under consideration for purposes of CEQA but may not be included in final Community Civic Campus Project if alternative locations are identified. AMENDMENTS TO SECTION 3.9, NOISE Page 3.9-22: 2011 ECR/C Area Plan Impacts Under the San Francisco International Comprehensive Airport Land Use Plan, the 2001 Noise Exposure Map (NEM) is the most recent federally accepted NEM and is the noise contour map that C/CAG uses in making its determination of the consistency of a proposed local agency land use policy action with the plan. A small portion of the Planning Area in the southwest is was, at the time of publication of the 2011 ECR/C EIR, located between the 2001 CNEL 60 dB and CNEL 65 dB noise contours (i.e., noise levels are between CNEL 60 dB and CNEL 65 dB). No noise/land use compatibility standards apply within these noise contours (South San Francisco 2011b, p. 3.5-10). Therefore, plan implementation would have no impact. Subsequent Project Impacts As analyzed in the ECR/C EIR, there are no private airports in the vicinity of the project site. The project site is located approximately 2.6 miles northwest of San Francisco International Airport. A review of the updated Comprehensive Airport Land Use Plan for the Environs of San Francisco International Airport (C/CAG 2012) shows the project site is no longer located outside of any within the noise impact zones. Therefore, the revised project would continue to have no impact.