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HomeMy WebLinkAbout19_Ch5_OtherCEQA_web CHAPTER 5OtherCEQAConsiderations Section 15126 of the California Environmental Quality Act (CEQA) Guidelines requires that all aspects of a project must be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. As part of this analysis, the Master Environmental Impact Report (MEIR) must also identify (1) significant environmental effects that cannot be avoided if the proposed project is implemented, (2) significant irreversible environmental change that would result from implementation of the proposed project, (3) growth-inducing impacts of the proposed project, (4) mitigation measures proposed to minimize significant effects, (5) cumulative impacts, and (6) alternatives to the proposed project. 5.1SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE AVOIDED IF THE PROPOSED PROJECT IS IMPLEMENTED Section 15126.2(b) of the CEQA Guidelines requires that an EIR describe any significant impacts that cannot be avoided, even with the implementation of feasible mitigation measures. In such cases where an impact cannot be mitigated to a level considered less than significant, a Statement of Overriding Considerations must be prepared prior to approval of a project, and in accordance with CEQA Guidelines Section 15091 and 15093. Because implementation of the proposed project would create significant, unavoidable impacts, as further described, a Statement of Overriding Considerations is required to describe the specific reasons for approving the project, based on information contained within the Final MEIR, as well as any other information in the public record. Development of the proposed project would result in the following significant and unavoidable project- related impacts. A detailed discussion of the project related impacts can be found in Section 4 (Environmental Analysis) of this document, and cumulative impacts are discussed below in Section 5.5. Air Quality ?Violate any air quality standard or contribute substantially to an existing or projected air quality violation or result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (Operation). Project related and cumulative. Noise and Vibration ?Cause substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. Project related and cumulative. Transportation and Circulation ?Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways. Specifically, the project would create a significant impact if it would cause the Level of Service at a freeway segment or Genentech Corporate Facilities Master EIR 5-1 Chapter 5 Other CEQA Considerations freeway ramp to degrade from LOS D to LOS E or worse, from LOS E to F, or cause an increase in the volume-to-capacity ratio of 0.5 or more and cause an increase in density by four passenger cars per lane per mile. 5.2SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL EFFECTS Section 15126.2(c) of the CEQA Guidelines requires a discussion of any significant irreversible environmental changes that the proposed project would cause. Specifically, Section 15126.2(c) states: Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts, and particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified. The construction and implementation of the proposed project will entail the commitment of energy, human resources, and building materials. This commitment of energy, personnel, and building materials will be commensurate with that of other projects of similar magnitude, and none of these commodities are in short supply. Manpower would also be committed for the construction of buildings and public facilities necessary to support the new development. Ongoing maintenance and operation of the proposed project will entail a further commitment of energy resources in the form of natural gas, electricity, and water resources. Long-term impacts would also result from an increase in vehicular traffic, and the associated air pollutant and noise emissions. This commitment of energy resources will be a long-term obligation in view of the fact that, practically speaking, it is impossible to return the land to its original condition once it has been developed. However, as established in Section 4.13 (Utilities and Service Systems), the impacts of increased energy usage are not considered significant environmental impacts. In summary, implementation of the proposed project would involve the following irreversible environmental changes to existing on-site natural resources: Commitment of energy and water resources as a result of the operation and maintenance of the proposed development. Alteration of the existing topographic character of the project area. 5.3GROWTH-INDUCING IMPACTS A project?s growth-inducing potential does not automatically result in growth, whether it is a portion of growth or actually exceeds projected levels of growth. Growth at the local level is fundamentally controlled by the land use policies of local municipalities or counties, which are determined by the local politics in each jurisdiction. As required by the CEQA Guidelines, an EIR must include a discussion of the ways in which the proposed project could directly or indirectly foster economic development or population growth, or the 5-2 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations construction of additional housing and how that growth would, in turn, affect the surrounding environment (CEQA Guidelines Section 15126.2(d)). Growth can be induced in a number of ways, including the elimination of obstacles to growth, or through the stimulation of economic activity within the region. The discussion of removal of obstacles to growth relates directly to the removal of infrastructure limitations or regulatory constraints that could result in growth unforeseen at the time of project approval. Under CEQA, induced growth is not considered necessarily beneficial, detrimental, or of little significance to the environment. In general, a project may foster spatial, economic, or population growth in a geographic area if it meets any one of the criteria identified below: The project removes an impediment to growth (e.g., the establishment of an essential public service, or the provision of new access to an area) The project results in the urbanization of land in a remote location (leapfrog development) The project establishes a precedent-setting action (e.g., a change in zoning or General Plan amendment approval) Economic expansion or growth occurs in an area in response to the project (e.g., changes in revenue base, employment expansion, etc.) If a project meets any one of these criteria, it may be considered growth inducing. Generally, growth- inducing projects are either located in isolated, undeveloped, or underdeveloped areas, necessitating the extension of major infrastructure such as sewer and water facilities or roadways, or encourage premature or unplanned growth. 5.3.1Remove an Impediment to Growth/Precedent-Setting Action Although the proposed project includes General Plan Amendments and a zone change to expand the boundaries of the existing Genentech R&D Overlay District, the proposed land uses and zoning would be consistent with the existing Planned Industrial zoning designation for biotechnology research and development land uses. The proposed amendment to the overlay district would not set a precedent by increasing the boundary of the existing land use overlay within the East of 101 Area. The types of development allowed under the overlay would remain the same; however, the growth strategy would aim for expansion and redevelopment throughout the Campus and the 2006 FMPU would provide an overall structure for the anticipated physical development of the area. Thus, the designations would be consistent with the nature of on-site and surrounding development. However, Genentech Campus growth and expansion would necessitate the expansion of infrastructure (e.g., water, sewer, and storm drain lines, etc.) to serve future needs. While the 2006 FMPU describes a general development program for up to 3.17 million sf of new building space by 2016, the specific development pattern of those uses is presently unknown. Depending upon the availability of municipal services (e.g., adequate water supply and sewer line capacity), future development may be limited to available service capacity in the event that any municipal services are exceeded in the future. Therefore, because future development under the 2006 FMPU would require the expansion of municipal utilities, the proposed project would be growth inducing as a result of removing an impediment to growth. See Section 4.13 (Utilities and Service Systems) for a detailed discussion of impacts associated with utilities. 5-3 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations 5.3.2Urbanization of Land in a Remote Location Implementation of the proposed project would not encourage growth through the urbanization of land in remote locations, resulting in ?leapfrog? development. The proposed project is located in an urbanized industrial area of South San Francisco, bordered by rail lines on the west and northwest, connected to the Caltrain station to the west, and located roughly one mile north of the San Francisco International Airport. Consequently, because the proposed project is not located in a remote location, no growth- inducing impacts would occur as a result of this criterion. 5.3.3Economic Expansion or Growth According to the ABAG Projections 2005, the employment base in the City of South San Francisco is anticipated to increase from approximately 42,130 employees in 2005 to approximately 48,410 employees in 2015. This growth would result a net increase of approximately 6,280 employees, or a 15 percent increase over 2005 conditions. Presently, the only employment growth anticipated to occur within the City is expected to take place within the East of 101 Area where the proposed project is located. In addition, employment growth trends within the City are similar to the overall rate of growth anticipated in the County (employment growth in the County is projected to grow from 336,460 jobs in 2005 to 400,000 jobs in 2015, or 19 percent.) Implementation of the proposed project is similarly anticipated to result in an employment increase of approximately 6,661 (from 6,658 employees in December 2005 to 13,319 employees in 2015.) The net increase of approximately 6,661 employees resulting from Genentech?s growth would exceed the City?s entire population growth expected during 2005 and 2015, at approximately 107 percent, and approximately 10 percent of the County?s. Although Genentech is presently the largest employer in the City, because the anticipated employment growth exceeds the existing forecasts for the City, Genentech?s anticipated employment growth is considered substantial and directly growth-inducing. However, based on the company?s history and it?s vertically integrated business strategies, it is estimated that existing residents in the City (as well as residents in neighboring cities) would be likely to fill many of the future jobs. Vertically integrated companies are united through a hierarchy and share a common owner, with each division of the hierarchy structured to produce a different product or service. The products combine to satisfy a common need. Thus, while the field of biotechnology generally requires a high level of specialized skill sets, Genentech is structured in such a way that the future growth resulting from project-related employment generation would include all levels of workers. In addition to employing staff for technical scientific positions, Genentech also employs construction workers and administrative staff. Thus, while some employees that would fill the jobs generated by the proposed project would be expected to relocate to the general area (for the more technical scientific positions), many future employees would also likely be existing residents of the City and surrounding area. It is also important to note that many commercial jobs (i.e., dry cleaners, restaurants, etc.) that would be generated by implementation of the proposed project could be filled by existing City or nearby residents. However, because it is assumed that many of the white-collar positions would be filled by people more likely to 5-4 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations relocate to the area (rather than all positions being filled by existing City residents), this analysis assumes that implementation of the proposed project could result in secondary or indirect growth resulting from project-related employment generation. In essence, because some new employees would be expected to relocate to the City or surrounding area, the new employees would result in new households within the region. Thus, the proposed project would also result in an indirect population and housing increase. Therefore, the redevelopment and expansion envisioned from the proposed project, and associated employment growth would result in direct and indirect growth-inducing impacts. 5.4MITIGATION MEASURES PROPOSED TO MINIMIZE SIGNIFICANT EFFECTS OF THE PROPOSED PROJECT Table 1-2 (Summary of Environmental Effects and Mitigation Measures), which is contained in Chapter 1 of this MEIR, provides a comprehensive identification of the proposed project?s environmental effects and proposed mitigation measures. 5.5CUMULATIVE IMPACTS CEQA requires that EIRs discuss cumulative impacts, in addition to project-specific impacts. In accordance with CEQA, the discussion of cumulative impacts must reflect the severity of the impacts and the likelihood of their occurrence; however, the discussion need not be as detailed as the discussion of environmental impacts attributable to the proposed project alone. Further, the discussion is guided by the standards of practicality and reasonableness. According to Section 15355 of the CEQA Guidelines: ?Cumulative impacts? refer to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects. (b) The cumulative impact from several projects is the change in the environment, which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. Section 15130(a)(1) of the CEQA Guidelines further states that a ?cumulative impact consists of an impact which is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts.? Only those impacts for which the project was found to have a less than significant, potentially significant, or significant and unavoidable impact are discussed. Impacts that were determined to have no project-related impact would also have no cumulative impact, and these are not discussed. A summary of the growth resulting from all the approved and proposed development projects in the greater East of 101 Area (as provided by the City of South San Francisco) is identified in Table 5-1 (Background Growth-2015 Future Without Project Conditions). Table 5-1 is based on the City?s proposed project list developed in December 2005, and was updated in March 2006 based on the City?s 5-5 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations verbal comments. Figure 5-1 identifies the specific cumulative development projects that are included in the summary of Table 5-1 and shows the location of net growth of development in the East of 101 Area. It is important to note that Terra Bay, while not included in the East of 101 Area, is included in the cumulative projects list because it shares an on-ramp with the MEIR Study Area and thus, provides a more accurate representation of cumulative traffic growth for future development. The Traffic Report, Water Supply Assessment, and 2006 East of Highway 101 Sewer Master Plan Addendum prepared for the project all rely on this cumulative growth table for their respective projections and analysis of the proposed project. Overall, there is anticipated to be growth of over 4.6 million sf by year 2015, primarily office and R&D space. It should be noted that these values do not include any planned or programmed projects within Genentech. Table5-1BackgroundGrowth?2015FutureWithoutProjectConditions (square footage) Neighborhood* Commercial Hotel Office R&D Manufacturing Residential Total Bay West Cove 157,500 742,000 899,500 Gateway 121,000 65,250 186,250 Oyster Point 237,648 237,648 P 164,779 164,779 R 315,000 315,000 South Campus 789,000 789,000 Terra Bay 49,795 638,400 309,221 997,416 U 777,639 12,149 789,788 Upper Campus outside Overlay -43,215 -43,215 Y 177,633 177,633 Z 133,000 133,000 Grand Total 335,574 460,398 3,572,672 -31,066 309,221 4,646,799 SOURCE: Korve Engineering 2006, data compiled as of December 2005 * Refer to Legend on Figure 5-1 for identification of parcels and specific projects. Biological Resources In general, the context for this cumulative analysis covers two areas. The discussion of project contributions to coastal salt marsh and associated sensitive species impacts is discussed in the context of the entire San Francisco Bay. The project?s contribution to impacts to nesting birds and conflicts with local tree preservation ordinances is referenced to habitat found within about 2-3 miles of the MEIR Study Area. Analysis methodologies are discussed within the following paragraphs as appropriate. The criteria used previously for what would be considered a substantial change resulting from the proposed project are used within this analysis. 5-6 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Cumulative impacts on species identified as candidate, sensitive or special status species in local or regional plans, policies or regulations, or by California Department of Fish and Game or U.S. Fish and Wildlife Services. Construction activities associated with implementation of the proposed project could result in impacts related to noise and soil deposition to the resources discussed in Impacts 4.1-2, 4.1-3, 4.1-4, and 4.1-6. The coastal salt marsh habitat could support wildlife nursery sites, sensitive bird species, and sensitive plant species. Therefore, because impacts to salt marsh could result in impacts to species these resources are linked and dependent upon each other. Because they are linked, cumulative impacts are considered in a single discussion. Salt marsh is a rare resource within San Francisco Bay and has been substantially reduced from its former range. In the foreseeable future, projects will be implemented that could result in additional reductions in salt marsh habitat and sensitive species through noise and soil deposition generated by construction activities. However, the project does not directly impact coastal salt marsh. Indirect impacts to coastal salt marsh and related resources are minor in the context of the Bay. Thus, the project?s contribution to cumulative impacts is not less-than-significant considerable. This would be considered a cumulative impact. Cumulative impacts on riparian habitat or other sensitive natural community identified in local or regional plans, policies or regulations, or by California Department of Fish and Game or U.S. Fish and Wildlife Services. Cumulative impacts to riparian habitat or other sensitive natural communities are less than significant as described above. In the foreseeable future, projects will be implemented that could result in additional reductions in salt marsh habitat and sensitive species through noise and soil deposition generated by construction activities. However, the project does not directly impact coastal salt marsh. Indirect impacts to coastal salt marsh and related resources are minor in the context of the Bay. Thus, the project?s contribution to cumulative impacts is not considerable. This less-than-significant would be considered a cumulative impact. Cumulative impacts on interfering with the movement of any native resident of migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Construction activities associated with implementation of the proposed project could result in ground-clearing or removal of vegetation, which could interfere with nesting efforts and could conflict with the City?s Tree Preservation Ordinance or movement of migratory bird species of significance. Because of this, Impacts 4.1-7 and 4.1-8 are linked and these impacts are discussed under one cumulative impact. Implementation of the proposed project would involve demolition and removal of existing buildings and landscaping. This would result in impacts to nesting birds and protected trees. The general area around the Genentech Campus is entirely developed. These areas support similar landscaping and tree resources as the existing Campus. Foreseeable projects within the area would also remove trees and nesting habitat, which when added to the proposed project could result in an overall significant impact to these resources. However, new landscaping is expected to be installed with each new project that would replace lost trees and habitat. This results in only short-term reductions in available nesting habitat. Because the entire area will be not be (re)developed at the same time, impacts will be distributed over time such that loss of trees and habitat that would occur in any one area that is a relatively small portion of the entire contextual area. Because loss of nesting habitat and trees is distributed in time and space, the project?s contribution to the overall loss of habitat is limited. 5-9 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Therefore, the proposed project?s contribution to this cumulative impact is not considerable. This would less-than-significant be considered a cumulative impact. Cumulative impacts of conflicting with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. As described above, and under Impact 4.1-8, cumulative impacts from construction activities associated with implementation of the proposed project could result in ground-clearing or removal of vegetation, which could interfere with nesting efforts and could conflict with the City?s Tree Preservation Ordinance. Because loss of trees is distributed in time and space, and new landscaping is expected to be installed with each new project which would replace lost trees, the project?s contribution to the overall removal of trees is limited. Therefore, the proposed project?s contribution to this cumulative impact is not considerable. This would less-than-significant be considered a cumulative impact. Flood and Inundation Hazards The geographic context for the analysis of impacts resulting from flood and inundation hazards generally is site-specific, rather than cumulative in nature, because each project site has a different set of hydrologic considerations that would be subject to specific site development and construction standards. As such, the potential for cumulative impacts to occur is limited. Cumulative impacts to impeding or redirecting flood flows. While the shoreline of the MEIR Study Area is considered a 100-year flood hazard area by the City?s General Plan, it is unlikely that development under the proposed project would place structures directly on the shoreline. However, potential opportunity sites identified in the 2006 FMPU are near the shoreline. The flow of coastal flood waters that encounter a building constructed under the proposed project would not be substantially obstructed or redirected because the path of flow, i.e., the width of the shoreline, is short. In addition, structures that substantially impede flood flows, such as dams and levees, would not be constructed under the proposed project. These potential opportunity sites would not impede or redirect flood flows themselves, and are not located near other anticipated future development sites within the City which would create a cumulative scenario resulting in flood flows being impeded or redirected. This cumulative effect is less than significant considered. Cumulative impacts from exposing people to risk from the failure of a levee or dam. The MEIR Study Area is not prone to flooding in the event of dam or levee failure. Failure of a small-scale levee in the vicinity of the City would not release a volume of water such that the MEIR Study Area would become flooded. Thus, the proposed project would not expose people or structures to flood risks associated with dam or levee failure. There are no dams or levees that would release quantities of water which would create impact zones in South San Francisco. Therefore, no future projects, in conjunction less with the proposed project, would create a cumulative impact. The cumulative effect is considered than significant . Cumulative impacts from exposing people or structures to inundation. The potential for inundation by mudflow within the MEIR Study Area is considered less than significant due to the lack of 5-10 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations steep exposed slopes. In addition, there are no other steep slopes that would be built upon by future developments which would, in conjunction with the proposed project development, expose people or less than significant structures to mudflow. This cumulative effect is considered . The northwestern portion of the MEIR Study Area, in the Lower Campus, could potentially be inundated by a tsunami. A few of the potential opportunity sites identified in the 2006 FMPU are in the tsunami inundation zone. As such, the proposed project could expose people and structures to inundation by tsunami. Other future development sites within the City could be located in tsunami inundation zones as well, creating potentially significant cumulative effects in the event of a tsunami. However, as with the proposed project, compliance with the standards contained in Chapter 15.56 of the SSFMC, specifically Section 15.56.140 which identifies standards specific to construction in coastal high less hazard areas, reduces the effects to less-than-significant levels. The cumulative effect is considered than significant . Air Quality Cumulative impacts from conflicting with or obstructing implementation of the applicable air quality plan. The Clean Air Plan, discussed previously, was prepared to accommodate growth, reduce the pollutant levels in the Bay Area, meets federal and state ambient air quality standards, and minimizes the fiscal impact that pollution control measures have on the local economy. As discussed in Impact 4.3- 1, the Clean Air Plan assumed that future growth would occur within the zoning restrictions in effect at the time of its adoption. As described in Chapter 3 (Project Description) and Section 4.8 (Land Use), the project site?s current zoning designation would accommodate the proposed project?s components, as well as cumulative future growth assumed to occur, as summarized in Table 5-1. Thus, the proposed project less than significant would not conflict with the Clean Air Plan, and the cumulative effect is considered . Cumulative impacts from violating any air quality standard or contributing substantially to an existing or projected air quality violation. As discussed in Impact 4.3-3, construction?related activities are generally short-term in duration and the BAAQMD does not recommend any thresholds of significance for construction-related emissions. Instead, the BAAQMD bases the determination of significance on a consideration of the control measures to be implemented. Implementation of mitigation measures MM 4.3-1(a) and MM 4.3-1(b) would ensure that emissions from construction-related activities less than in the Project Area would be less than significant, and the cumulative effect is considered significant . As discussed in Impact 4.3-4, the estimated daily emissions associated with operation of the proposed development would exceed the thresholds of significance recommended by the BAAQMD. The operational emissions that are generated by individual projects and exceed BAAQMD thresholds are also considered to be cumulatively considerable by the BAAQMD. Therefore, since the proposed project would exceed the BAAQMD thresholds of significance and no feasible mitigation is available, this significant and unavoidable cumulative effect is considered . 5-11 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Cumulative impacts from exposing sensitive receptors to substantial pollutant concentrations. The simplified CALINE4 model was used to predict future (Year 2015) CO concentrations with full project buildout at selected locations along the major access routes within the MEIR Study Area. These results are shown in Table 4.3-5 (Future Carbon Monoxide Concentrations). As shown, future CO concentrations at these receptors would not exceed the national and state 1-hour and 8-hour ambient air less than significant quality standards for localized CO concentrations. This cumulative effect is . As discussed in Impact 4.3-5, DPM would be emitted from diesel-powered delivery trucks traveling to and from the project site. To address DPM and other TAC emissions, the ARB has recently finalized an Air Quality and Land Use Handbook: A Community Health Perspective (April 2005) as an ?informational guide? to prioritize the important sources of TACs and reduce exposures to proximate populations. Among the important sources of DPM it identifies are distribution centers, warehouses and other facilities that accommodate 100 or more large diesel trucks per day, and it recommends that no new residential uses be located within 1000 feet of such facilities (or conversely that no new large sources of DPM be located near existing residential uses). As the proposed development would not represent these uses, and typically only a fraction of delivery trucks would be diesel-powered, and only a fraction of the latter would consist of the large tractor-trailer type described. Furthermore, the MEIR Study Area is not zoned for residential use, as described in Chapter 3 (Project Description) and Section 4.8 (Land Use). There are no residential uses located within 1000 feet. Therefore, the proposed project would not expose sensitive less than receptors to substantial concentrations of DPM, and this cumulative effect would be significant . Cumulative impacts from creating objectionable odors affecting a substantial number of people. For this analysis, the relevant geographic area is the City, and related projects projected to be built include primarily residential and commercial developments, and could include restaurants. Odors resulting from the construction of these projects are not likely to affect a substantial number of people, due to the fact that construction activities do not usually emit offensive odors. Although construction activities occurring in association with the proposed project and related projects could generate airborne odors associated with the operation of construction vehicles (i.e., diesel exhaust) and the application of interior and exterior architectural coatings, these emissions would only occur during daytime hours, would generally be restricted to the immediate vicinity of the construction sites and activities, and would less than significant not affect a substantial number of people. This cumulative effect is considered . The most likely potential operational airborne odors associated with operation of the proposed project and related project could emanate from refuse storage areas. These odors would likely be confined to the immediate vicinity of the storage areas, and since the refuse receptacles would have lids and be emptied on a regular basis, substantial odors would not likely have a chance to develop. Therefore, there would be no cumulatively significant adverse odor impacts to sensitive receptors. This cumulative effect is less than significant considered. 5-12 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Noise and Vibration Cumulative impacts from exposing persons to or generating noise levels in excess of standards established in the local general plan or noise ordinances, or applicable standards of other agencies. Implementation of the proposed project could result in the development of approximately 3.17 million sf of office, research and development, manufacturing, amenities, and parking by the year 2016. As discussed in Impact 4.4-1, the sensitive uses surrounding the MEIR Study Area would be exposed during the daytime to construction noise levels that exceed the City?s exterior noise standard of 60 dBA CNEL. Although the construction activities would exceed the 60 dBA CNEL noise standard identified in the SSFMC at these off-site locations during construction at the MEIR Study Area, the increase in noise levels would be temporary in nature, and would not generate continuously high noise levels, although occasional single-event disturbances from grading and construction are possible. Currently, under Section 8.32.050(d) of the SSFMC, construction activities are limited to between the .. to 8:00 .. on weekdays, 9:00 .. to 8:00 .. on Saturdays, and 10:00 .. to hours of 8:00 AMPMAMPMAM 6:00.. on Sundays and holidays, as discussed in Section 4.4.2 of this MEIR. During these times, the PM City exempts noise associated with construction from provisions of SSFMC. Through this exemption of construction noise, the proposed project and related projects would be exempt from the noise standards. Construction noise occurring during these hours is exempted because these hours are outside of the recognized sleep hours for residents and outside of evening and early morning hours and time periods where residents are most sensitive to exterior noise. In addition, implementation of mitigation measures MM 4.4-1(a) through MM 4.4-1(c) would help to reduce noise from construction activities during the less than significant daytime to local sensitive receptors. Therefore, this cumulative effect is . Large HVAC systems associated with new buildings in the MEIR Study Area can result in noise levels that average between 57 to 72 dBA CNEL at 50 feet from the equipment when the equipment is operating constantly over 24 hours. HVAC units are typically mounted on the rooftops of buildings and are required to be screened from view by building features. The nearest off-site sensitive receptors to the MEIR Study Area is the Larkspur Landing Hotel. The Larkspur Landing Hotel is located approximately 2000 feet from the northwest boundary of the MEIR Study Area. Noise levels would diminish rapidly with distance from the MEIR Study Area at a rate of approximately 6 dBA per doubling of distance. Thus, the noise levels generated by the HVAC equipment associated with the new buildings would be approximately 42 dBA CNEL at the Larkspur Landing Hotel, which would not substantially contribute to existing ambient noise around the Larkspur Landing Hotel. Noise levels may also be reduced by intervening structures; generally, a single row of buildings between the receptor and the noise source reduces the noise level by about 5 dBA, while a solid wall or berm reduces noise levels by 5 to 10 dBA. The manner in which older commercial structures in California were constructed (approximately 30 years old or older) generally provides a reduction of exterior-to-interior noise levels of about 20 to 25 dBA with closed windows. The exterior-to-interior reduction of newer commercial is generally 30 dBA or more (HMMH 2006). However, it is expected that the childcare center would only be in operation during typical business days and would not be occupied during evening and nighttime hours. As such, occupants of the proposed childcare center would not be exposed to noise levels above the City?s 75 dBA CNEL limit established for industrial land uses. As related projects would be considered to have a similar impact less than significant on sensitive receptors, this cumulative effect is . 5-13 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Traffic-related noise would increase by as much as 4.1 dBA CNEL at project buildout in the Year 2015, including ambient growth and related projects. This increase is in excess of the 3.0 dBA CNEL threshold of significance for traffic-related noise. However, as shown in Table 4.9-9, traffic noise levels at buildout of the proposed project and ambient growth would not exceed the 75 dBA CNEL noise limit for less than significant industrial and institutional uses. This cumulative effect is . Cumulative impacts from exposing persons to or generating excessive groundborne vibration or groundborne noise levels. Construction activities that would occur under the proposed project and related projects both within the MEIR Study Area and off site could include excavation, which would have the potential to generate low levels of groundborne vibration. Given the distance of the off-site sensitive uses from the MEIR Study Area, the vibration levels experienced at the property lines of these off-site sensitive receptors could reach up to approximately 51 VdB at the Larkspur Landing Hotel, which is the nearest sensitive receptor to the MEIR Study Area Even if construction were to occur closer to sensitive receptors, the construction would have to be within approximately 25 feet of the use to exceed the 85 VdB threshold. As vibration is a localized phenomenon, related projects would need to be within 300 feet of each other to have a significant cumulative effect. As the construction activities would less than already be occurring 2000 feet from the nearest sensitive receptor, this cumulative effect is significant . Genentech and other adjacent land uses potentially use research equipment that may be especially vibration sensitive. The threshold for vibration sensitive equipment is 66 VdB (HMMH 2006). Construction activities have the potential to occur within 25 feet of buildings containing vibration sensitive equipment. This would potentially expose the equipment to vibration levels up to 87 VdB, which exceeds the 66 VdB threshold, for individual projects. As the potential exists for more than one project to occur in close proximity as part of the proposed project, cumulative vibration impacts could be as much as 90 VdB. However, in order to reduce potential impacts to vibration sensitive equipment, MM 4.4-2(a) and MM 4.4-2(b) shall be implemented to reduce the potential impacts to vibration sensitive equipment. MM 4.4-2(a) would ensure that construction related activities would not occur adjacent to existing buildings containing vibration sensitive equipment. If construction activities were to occur adjacent to building containing vibration sensitive equipment, MM 4.4-2(b) would ensure that construction activities that could potentially impact vibration sensitive equipment would be scheduled such that vibration sensitive equipment would not be impacted. With implementation of MM 4.4-2(a) and MM 4.4-2(b), the potentially significant impact to vibration sensitive equipment would be reduced to less than significant a level of . During operation of the proposed project and related projects, background operational vibration levels would be expected to average around 50 VdB. This is substantially less than the 85 VdB threshold for people in the vicinity of the project site. Groundborne vibration resulting from operation of the proposed project and related projects would primarily be generated by trucks making periodic deliveries. However, these types of deliveries would be consistent with deliveries that are currently made along roadways in the project vicinity to the existing Campus and surrounding uses and would not increase groundborne vibration above existing levels. Because no substantial sources of groundborne vibration would be built as part of the proposed project or related projects, no significant cumulative vibration 5-14 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations impacts would occur during operation of the proposed project. Therefore, operation of the proposed project would not expose sensitive receptors on or off site to excessive groundborne vibration or less than significant groundborne noise levels, and this cumulative effect is . Cumulative impacts from causing substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. As discussed in Impact 4.4-6, four roadway segments within the Traffic Study Area would exceed the 3.0 dBA CNEL threshold for a significant permanent increase in ambient noise levels. These increases include ambient growth and related projects. Table 5-2 shows Year 2015 traffic noise levels without the proposed project and compares them to Year 2015 traffic noise levels with the project to show the project?s contribution to this impact. As shown in Table 5-2, the project would create a 3.0 dBA CNEL increase in traffic noise level above Year 2015 conditions without the project on the roadway segment of Forbes Boulevard between Gull Road and Allerton Avenue. This is considered a significant contribution to cumulative traffic noise levels. significant and As no feasible mitigation is available to reduce this impact, this cumulative effect is unavoidable . Table 5-2 Project Contribution to Cumulative Traffic Noise in Year 2015 Noise Levels in dBA CNEL at 100 feet Year 2015 Year 2015 Significance Exceeds Significance Roadway Segment Without Project With Project ThresholdThreshold? Increase 1 Airport Blvd./Oyster Point Blvd. to Oyster Point west 64.5 64.6 0.1 3.0 No Airport Blvd./Oyster Point Blvd. to US 101 65.1 65.2 0.1 3.0 No Ramps/Oyster Point Blvd. US 101 Ramps/Oyster Point Blvd. to Oyster Point 67.1 67.9 0.8 3.0 No Blvd./Gateway Blvd. Oyster Point Blvd./Gateway Blvd. to Oyster Point 64.7 66.2 1.5 3.0 No Blvd./Gull Rd. Oyster Point Blvd./Gull Rd. to Oyster Point east 60.6 60.6 0.0 3.0 No Forbes Blvd./Gull Rd. to Forbes Blvd./Allerton Ave. 58.9 61.9 3.03.0Yes Forbes Blvd./Gull Rd. to Forbes east 61.2 61.5 0.3 3.0 No Forbes Blvd./Allerton Ave. to Forbes Blvd. west 58.4 59.6 1.2 3.0 No Grandview Dr./E. Grand Ave. to E. Grand Ave. east 58.9 59.2 0.3 3.0 No Grandview Dr./E. Grand Ave. to Allerton Ave./Grand 63.2 64.9 1.7 3.0 No Ave. Forbes Ave./Grand Ave. to Gateway Blvd./E. Grand 65.7 67.1 1.4 3.0 No Ave. Allerton Ave./Grand Ave. to Forbes Blvd./E. Grand 64.0 65.5 1.5 3.0 No Ave. Gateway Blvd./E. Grand Ave. to Executive/Grand 65.7 65.6 -0.1 3.0 No Ave. Executive/Grand Ave. to Dubuque Ave./Grand Ave. 64.8 65.4 0.6 3.0 No Dubuque Ave./Grand Ave. to Airport Blvd./Grand 64.8 65.5 0.7 3.0 No Ave. Airport Blvd./Grand Ave. to Grand Ave. west 61.6 62.2 0.6 3.0 No 5-15 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Table 5-2 Project Contribution to Cumulative Traffic Noise in Year 2015 Noise Levels in dBA CNEL at 100 feet Year 2015 Year 2015 Significance Exceeds Significance Roadway Segment Without Project With Project Increase ThresholdThreshold? 1 Airport Blvd./San Mateo to San Mateo west 60.8 60.8 0.0 3.0 No Gateway Blvd./Mitchell to Mitchell east 59.4 59.4 0.0 3.0 No Airport Blvd./Oyster Point Blvd. to Airport Blvd. north 64.1 64.1 0.0 3.0 No Airport Blvd./Oyster Point Blvd. to Airport Blvd./Miller 62.2 62.4 0.2 3.0 No Airport Blvd./Miller to Airport Blvd./Grand Ave. 63.9 64.1 0.2 3.0 No Airport Blvd./Grand Ave. to Airport Blvd./San Mateo 64.2 64.2 0.0 3.0 No Airport Blvd./San Mateo to Airport Blvd. south 65.8 66.6 0.8 3.0 No Gateway Blvd./Mitchell to Gateway Blvd./E. Grand 62.7 64.3 1.6 3.0 No Ave. Gateway Blvd./E. Grand Ave. to Gateway 63.1 63.1 0.0 3.0 No Blvd./Oyster Point Blvd. Allerton Ave./Grand Ave. to Allerton Ave./Forbes 53.7 55.8 2.1 3.0 No Blvd. Grandview Dr./E. Grand Ave. to Grandview Dr. north 59.9 62.8 2.9 3.0 No Oyster Point Blvd./Gull Rd. to Forbes Blvd./Gull Rd. 60.6 62.9 2.3 3.0 No SOURCE: EIP Associates 2005 (calculation data and results are provided in Appendix H) 1 . As described in Section 3.10.5 (Thresholds of Significance), the significance threshold is 3 dBA if the noise increase would meet or exceed the City?s 65 dBA CNEL noise level standard at sensitive land uses. However, if the noise levels remain below the City?s 65 dBA CNEL noise level standard at sensitive land uses, then an increase in noise between 3 dBA and 5 dBA would be noticeable, but would not be considered to be significant. 2 . Although a significant increase in ambient noise over existing conditions is experienced at this roadway segment, this roadway segment would not be located adjacent to any existing or proposed sensitive uses. Cumulative impacts from a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project. As discussed in Impact 4.4-1, the sensitive uses surrounding the MEIR Study Area would be exposed during the daytime to construction noise levels that exceed the City?s exterior noise standard of 60 dBA CNEL. Although the construction activities would exceed the 60 dBA CNEL noise standard identified in the SSFMC at these off-site locations during construction at the MEIR Study Area, the increase in noise levels would be temporary in nature, and would not generate continuously high noise levels, although occasional single-event disturbances from grading and construction are possible. The construction activities associated with the proposed project would only occur during the permitted hours designated in the SSFMC. In addition, as discussed in Impact 4.4-1, the SSFMC contains an exemption for construction noise. Due to this exemption, the cumulative impact of temporary increases in ambient noise at off-site locations associated less than significant with construction activities of the proposed project would be . Geology and Soils The geographic context for the analysis of impacts resulting from geologic hazards generally is site- specific, rather than cumulative in nature, because each project site has a different set of geologic considerations that would be subject to specific site development and construction standards. As such, the potential for cumulative impacts to occur is limited. 5-16 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Cumulative impacts associated with potential geologic hazards related to ground rupture, seismic groundshaking or ground failure involving liquefaction or landslides. Impacts associated with potential geologic hazards would occur at individual building sites. These effects are site-specific, and impacts would not be compounded by additional development. Buildings and facilities in the City of South San Francisco would be sited and designed in accordance with appropriate geotechnical and seismic guidelines and recommendations, consistent with the requirements of the California Building Code and The East of 101 Area Plan Geotechnical Safety Element. Adherence to all relevant plans, codes, and regulations with respect to project design and construction would provide adequate levels of safety, and the cumulative impact would be less than significant. Such adherence would ensure that the proposed project would not result in a cumulatively considerable contribution to cumulative impacts regarding ground rupture, seismic groundshaking or ground failure involving liquefaction or landslides, less than significant and, therefore, the cumulative impact of the project would be . Cumulative impacts of soil erosion or loss of topsoil. Impacts from erosion and loss of topsoil from site development and operation can be cumulative in effect within a watershed. Uncontained runoff from the proposed project area would flow into the San Francisco Bay. To minimize the potential for cumulative impacts that could cause erosion, the proposed project and cumulative projects in the adjacent area are required to be developed in conformance with the provisions of applicable federal, state, County, and City laws and ordinances, including the applicable portions of and The East of 101 Area Plan Geotechnical Safety Element. As a result, it is anticipated that cumulative impacts on the San Francisco Bay Watershed caused by runoff and erosion from cumulative development activity would be less than significant. With adherence to these requirements, the project?s contribution to cumulative impacts regarding erosion and loss of topsoil would not be cumulatively considerable and, therefore, less than significant would be . Cumulative impacts associated with unstable soils, landslides, subsidence, liquefaction or collapse. As with seismic groundshaking impacts, the geographic context for analysis of impacts on development from unstable soil conditions including landslides, liquefaction, subsidence, collapse, or expansive soil generally is site-specific. Because all development within CBC Seismic Hazard Zone 4, which includes the City of South San Francisco, is required to undergo analysis of geological and soil conditions applicable to the project site (see Policy GEO-1, GEO-7, GEO-10 in The East of 101 Plan Geotechnical Safety Element), and because restrictions on development would be applied in the event that geological or soil conditions posed a risk to safety, it is anticipated that cumulative impacts from development on soils subject to instability, subsidence, collapse, and/or expansive soil would be less than significant. With adherence to these requirements, the project?s contribution to cumulative impacts less than significant would not be cumulatively considerable and, therefore, would be considered . Cumulative impacts associated with expansive soil. Impacts associated with potential geologic hazards related to expansive soils would occur at individual building sites. These effects are site-specific, and impacts would not be compounded by additional development. Buildings and facilities in the City of South San Francisco would be sited and designed in accordance with appropriate geotechnical and seismic guidelines and recommendations, consistent with the requirements of the California Building Code and The East of 101 Area Plan Geotechnical Safety Element. Adherence to all relevant plans, 5-17 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations codes, and regulations with respect to project design and construction would provide adequate levels of safety, and the cumulative impact would be less than significant. Such adherence would ensure that the proposed project would not result in a cumulatively considerable contribution to cumulative impacts less than regarding expansive soils, and, therefore, the cumulative impact of the project would be significant . Hazards and Hazardous Materials The geographical context for the analysis of cumulative impacts from hazardous materials use, transport, and disposal is the City of South San Francisco, unless otherwise specified. This analysis accounts for all anticipated cumulative growth within this geographic area, as represented by full buildout of the City of South San Francisco General Plan and development of the related projects. Cumulative impacts due to the routine transport, use, disposal, or storage of hazardous materials (including chemical, radioactive, and biohazardous waste). It is anticipated that future growth in the South San Francisco area will result in an incremental increase in the amount of hazardous materials used, treated, transported, and disposed areawide. Although each development site has potentially unique hazardous materials considerations, it is expected that future growth will generally comply with the range of federal, state, and local statutes and regulations applicable to hazardous materials, and will be subject to existing and future programs of enforcement by the appropriate regulatory agencies. For these reasons, cumulative impacts resulting from the use, transport, and disposal less than of hazardous materials, or risk of upset from a release of hazardous materials, would be significant . As discussed above, the MEIR Study will not result in significant public hazards as a result of hazardous materials use, transport, or disposal, or as a result of accidental release of hazardous materials. While the Genentech facility will continue to use varying amounts and types of hazardous materials (including chemical and bio-hazardous materials) in day-to-day activities and operations, the facility will continue to comply with all applicable laws and regulations concerning the use, storage, transportation, and/or exposure of hazardous materials, as well as with existing on-site programs, practices, and procedures, to reduce potential impacts for each project under the proposed project. Consequently, the contribution of less than significant the proposed project to cumulative impacts is also . The cumulative effects of hazardous waste disposal, and the geographical area of impact, vary based upon the type of waste in question. Non-radioactive hazardous waste materials are disposed into readily available local permitted hazardous waste facilities, while radioactive waste is disposed of in facilities that accept radioactive waste generated nationwide. (Cumulative impacts from disposal of solid waste are evaluated in Section 4.13 [Utilities].) Disposal facilities accepting non-radioactive hazardous waste are not currently in short supply, and are not anticipated to be in short supply in the future, and thus cumulative impacts for non-radioactive hazardous waste would be less than significant. Therefore, the contribution of the proposed project to cumulative impacts associated with the use, storage, transportation, and/or exposure of non-radioactive hazardous materials would also be less than significant. This is considered to less-than-significant be a impact. 5-18 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations As discussed above, low-level radioactive waste (LLRW) must be disposed of in authorized facilities, which accept LLRW from a wide array of sources in addition to Genentech. As a result, cumulative less than significant impacts associated with the disposal of LLRW nationwide are anticipated to be . Cumulative impacts due to hazardous emissions, handling of hazardous materials, substances, or hazardous waste. It is possible that a number of the related projects and other future development in the City of South San Francisco will involve significant renovation demolition activity, which could subject construction workers to health or safety risks through exposure to hazardous materials, although the individual workers potentially affected would vary from project to project. It is anticipated that future development projects will adhere to the applicable federal, state and local requirements that regulate worker safety and exposure. As a result, cumulative impacts would be less than significant. Genentech will continue to adhere to these applicable regulations, as well as established programs and practices. As a result, the proposed project?s contribution to cumulative impacts associated with potential exposure of less than significant construction workers to hazardous materials will be . It is further possible that a number of the related projects and other future development in the City of South San Francisco could expose residents and construction workers to contaminated soil or groundwater. It is anticipated that future development projects will adhere to the applicable federal, state, and local laws and regulations that govern underground storage tanks and pesticide use, as well as requirements applicable to disposal and cleanup of contaminants. As a result, cumulative impacts would be less than significant. Although there is no known soil or groundwater contamination on the Genentech Campus, in the event that soil or groundwater contamination is discovered, Genentech will continue to adhere to these regulations, as well as established programs and practices. As a result, the proposed project?s contribution to cumulative impacts associated with exposure to contaminated soil or less than significant groundwater would be . Cumulative impacts associated with being located on a hazardous materials site, pursuant to Government Code Section 65962.5. Future development in the City of South San Francisco, including the related projects, may be located on or near a site included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. It is anticipated that future development will comply with applicable laws and regulations pertaining to hazardous wastes, and that risks associated with identified hazardous materials sites would be eliminated or reduced through proper handling, disposal practices, and/or clean-up procedures. In many cases, development applications for projects affected by hazardous materials on identified sites would be denied by the City of South San Francisco if adequate cleanup or treatment is not feasible. Accordingly, cumulative impacts on the public or environment associated with development on or near hazardous materials sites would be less than significant. There are no listed contaminated soil or groundwater sites as listed pursuant to Government Code Section 65962.5 on the Genentech Campus. All remaining active or inactive USTs on-site conform to applicable laws and regulations and are registered and permitted by the SSFFD. If future UST-related cleanup were determined to be necessary, all work would be performed in accordance with the guidelines of the regional Underground Storage Tank Program. All non-UST hazardous waste storage locations are managed in accordance with all applicable federal and state laws, such as RCRA and the California Hazardous Waste Control Law, as well as all existing Genentech programs, practices, and procedures. As 5-19 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations a result, the proposed project?s contribution to cumulative impacts associated with development on or less than significant near hazardous material sites would be . Cumulative impacts with impairing with the implantation or physically interfering with an adopted emergency response plan. Construction and operation associated with the related projects and other future development in the City of South San Francisco could result in activities that could interfere with adopted emergency response or evacuation plans, primarily by temporary construction barricades or other obstructions that could impede emergency access. It is anticipated that future development projects will undergo CEQA review of potential impacts on adopted emergency response or evacuation plans, and will be required to implement measures necessary to mitigate potential impacts. As a result, cumulative impacts relating to inference with adopted emergency response or evacuation plans would be less than significant. Construction and operation activities under the proposed project with respect to emergency response or evacuation plans due to temporary construction barricades or other obstructions that could impede emergency access on-site, would be mitigated by MM 4.6-2. Multiple emergency access or evacuation routes would be provided on-site to ensure that in the event one roadway or travel lane is temporarily blocked, another may be utilized. Furthermore, ongoing coordination between Genentech and the appropriate agencies pursuant to MM 4.6-3 ensures that roadway or travel lane closures will be coordinated with emergency response personnel to ensure that individual development projects under the proposed project would not impair implementation of, or physically interfere with, emergency response and evacuation efforts. As a result, the proposed project?s contribution to cumulative impacts associated with inference with adopted emergency response or less than significant evacuation plans would be . Transportation and Circulation The geographical context for the analysis of cumulative impacts from traffic and circulation is the East of 101 Area, unless otherwise specified. This analysis accounts for all anticipated cumulative growth within this geographic area, as represented by the summary of cumulative development provided in Table 5-1 and illustrated in Figure 5-1. Cumulative impacts related to intersections and freeways. The traffic analysis presented in the impact analysis and impact statements in the Transportation and Circulation section (for intersections and freeway segments in the MEIR Study Area) includes the forecasted year 2015 cumulative impacts of general area-wide growth and traffic that would be generated by other proposed projects within the project area. Therefore, the cumulative traffic impacts and the proposed project?s contribution to the cumulative traffic impacts have been addressed and quantified in the impact discussions. As noted in the traffic analysis, cumulative traffic would be added to the project area and would affect already deficient intersections and freeway segments, resulting in significant cumulative traffic impacts. The implementation of MM 4.7-1 through MM 4.7-10(b), however, would ensure that project-related less than significant intersection impacts are . Therefore, the project?s contribution would not be cumulatively considerable. Thus, although significant cumulative traffic impacts would occur, the project?s contribution would not be cumulatively considerable. As identified in Impact 4.7-11, project freeway segment impacts would be significant and unavoidable, as would the cumulative impact. The 5-20 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations project?s contribution to this impact would be significant and unavoidable as no mitigation is available that does not require the approval of other agencies. Inasmuch as the project could not guarantee the significant and unavoidable implementation of mitigation, this cumulative impact would be , and the project?s contribution would be cumulatively considerable. Cumulative impacts related to transit service. Impacts related to increased transit use and related LOS would be less than significant for the project, and for cumulative development identified in Table 5- 1. While transit demand would increase, there are numerous transit providers (public and private) that no cumulative impact serve the project area on a demand-responsive basis. Therefore, to transit use and related LOS will occur. Cumulative impacts related to Congestion Management Program segments and ramps. Finally, the SMCCMP identifies LOS E as acceptable for designated roads and highways. While the project would affect operation of US 101 segments and on- and off-ramps as identified in Impact 4.7-13, the less than significant change in LOS would result in a project and cumulative impact. Cumulative impacts related to hazards due to design. The design of project site access points and on-site roads and circulation system is not anticipated to include any design features that would result in a substantial increase in vehicular or pedestrian hazards. The project and cumulative impacts to traffic less than significant and circulation hazards would be , and the project?s contribution to the cumulative impacts would also be less than significant. Cumulative impacts related to emergency access. The onsite roadway infrastructure and parking areas are currently and would continue to be designed to accommodate emergency vehicle access. Vehicle access drives to/from and within the project site are currently and would continue to be designed to meet the City of South San Francisco design requirements for emergency vehicle less than significant accessibility. The project and cumulative impacts to emergency access would be , and the project?s contribution to the cumulative impacts would also be less than significant. Each cumulative project would be required, like the project, to ensure that emergency access impacts are addressed, and therefore no cumulative impact would occur. Cumulative impacts related to parking capacity. As described above, project-related parking impacts at the Genentech Campus would be less than significant. While capacity utilization in 2015 is expected to be about 94%, there are opportunities to park elsewhere in the neighborhood. Although Genentech comprises the majority of parking demand in the overlay district area, cumulative impacts from additional related projects are likely to result in a significant cumulative impact, and Genentech would have a considerable contribution to this impact. Further, although cumulative development projects could implement individual parking mitigation measures, the proposed project cannot ensure that adequate mitigation would be in place to reduce all potential cumulative parking impacts. Therefore, the significant and unavoidable cumulative parking impact is considered . Cumulative impacts related to policies or programs supporting alternative transportation. In consideration of the fact that the project would include TDM, would be designed to accommodate and 5-21 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations encourage bicycle and pedestrian connections and access/use throughout the Genentech Campus, the project would result in a less than significant effect upon these alternative transportation modes. Since the City has a TDM ordinance and requires implementation of TDM programs, development of less than significant additional, related projects would result in a cumulative impact on alternative transportation. The project?s contribution to this impact would also be less than cumulatively considerable as the project is expected to exceed the City?s TDM requirements. Land Use and Planning This cumulative impact analysis considers development of the proposed project, in conjunction with other development in the East of 101 Area of South San Francisco, unless otherwise specified. This analysis accounts for all anticipated cumulative growth within this geographic area, as represented by full implementation of the City of South San Francisco General Plan and development of the related projects. Cumulative plan consistency. As required by Section 15125(d) of the CEQA Guidelines, Section 4.8 Land Use and Planning discusses any inconsistencies between the proposed project and applicable regional and local plans. Implementation of the proposed project would conflict with development standards within the SSFMC; Chapter 20.32: Planned Industrial District. Development standards relating to building height, Floor Area Ratio and parking regulations within the 2006 FMPU are not consistent with the Planned Industrial District (P-I District) standards. However, development standards such as building height, FAR, and parking standards contained within 2006 FMPU are consistent with the Genentech R& D Overlay District regulations and standards. It is anticipated that the Genentech R&D Overlay District will be expanded as part of adoption of the MMEIR and proposed project to include the Genentech property currently within the boundaries of the Planned Industrial District. Therefore, the less than significant cumulative impact from implementation of the proposed project would be . Cumulative development within the City could have a potentially significant impact on the environment by conflicting with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect. Specifically, and as shown in Table 5-1, the cumulative projects include a total of 3,572,672 sf of office/R&D uses, 335,574 sf of commercial uses, 460,938 sf of hotel uses, 309,221 sf of residential uses in the Terra Bay development, and a loss of 31,066 sf of manufacturing. As discussed previously, Terra Bay is located outside of the East of 101 Area Plan; however, it is included in the cumulative development projections for the area because it shares an on-ramp with the MEIR Study Area. However, these projects are in line with existing plans that call for transforming the East of 101 Area to a denser office and research and development center. Therefore, cumulative development would be consistent with existing plans and policies. Aesthetics This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the vicinity of the project in the East of 101 Area in the City of South San 5-22 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Francisco. The East of 101 Area is an appropriate geographic context for cumulative impacts on visual quality because this area is a distinct development area, isolated from the rest of the City by US 101 to the west and bounded by the Bay to the east. Cumulative impacts to a scenic vista. The proposed project would not result in a significant effect on scenic vistas of the San Bruno Mountains or the San Francisco Bay, as described in 4.09 Aesthetics. Although the proposed project resides at the highest point within the East of 101 Area, on Point San Bruno Hill, future development would be subject to FAA height regulations and be designed so as to protect and enhance view corridors, such that impacts on scenic vistas would be less than significant. Cumulative development in the area would not include other development on Point San Bruno Hill. Additional projects proposed in the area include buildings primarily ranging from one to seven stories, with one 20-story hotel proposed to the northwest of the project which could have a potentially significant impact on long-range views of the mountains and Bay from various vantage points. However, the proposed hotel is compatible with the other numerous hotels and land uses in the vicinity, is consistent with the City?s General Plan and East of 101 Area Plan, and would be subject to the City?s Zoning Code and Design Review Boards. Considering combined visual impacts from the hotel and the proposed project, cumulative impacts on scenic vistas would not be significant. As there would be no less than significant cumulative impact on scenic vistas, this impact is considered . Cumulative impacts on existing visual character or quality of a site or its surroundings. As described in 4.9 (Aesthetics), implementation of the proposed project would not result in a significant impact on the visual character or quality of the existing Genentech R&D Overlay District. The regulating policies and development standards pertaining to the design and aesthetics of the Genentech R&D Overlay District would ensure that new development introduced as part of implementation of the proposed project would enhance the visual character and quality of the area. The proposed project is entirely compatible with the City?s goals and policies for future growth and development within the East of 101 Area, as prescribed in the East of 101 Area Plan, which promotes campus-style biotechnology, high-technology, and research and development uses for the East of 101 Area. Construction of new development as part of implementation of the proposed project would result in short-term impacts on visual character during the construction period. Other development in the East of 101 Area could result in significant impacts on visual character during the construction period. The significant impacts on the visual character or quality of the site and vicinity due to project construction (i.e. construction equipment, fencing, and debris) could exacerbate construction period visual character impacts of other projects. Thus, the project could contribute to a cumulative impact on visual character during the construction period. However, this visual condition would be a temporary visual distraction typically associated with construction activities and equipment. Therefore, the cumulative impact from less than significant implementation of the proposed project would be . Additional development proposed in the East of 101 Area includes primarily office and R&D land uses, with some hotel and retail uses, and a new ferry terminal, each of which would be approved subject to consistency with the same policies established in the East of 101 Area Plan and compliance with development standards of the City?s Zoning Code. The Zoning Code promotes development consistent with its surroundings, in terms of design, massing, and building heights. Each project would also be 5-23 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations subject to extensive design oversight as part of the City?s entitlement process. Consequently, changes in land use that would substantially degrade the area would generally not be permitted to occur under the General Plan or CEQA review, thereby protecting the visual character of the East of 101 Area. Consequently, cumulative impacts on the visual character and quality of the East of 101 Area would be less than significant . Cumulative effects of light or glare affecting day or nighttime views. The East of 101 Area is highly urbanized and nearly built out and contains numerous existing sources of daytime glare and nighttime lighting. However, residential land uses are not permitted within the entire East of 101 Area, and therefore sensitive land uses are not at risk by the potential accumulation of light and glare. As described under Impact 4.9-5, new development within the Upper Campus could create a significant impact to distant views by increasing daytime glare in a highly visible location on Point San Bruno Hill. Cumulative development within the surrounding areas could result in some increase in daytime glare, as specific building materials and configurations are uncertain. However, additional development in the area would occur at lower topographies and not be surrounded by sensitive land uses. Consequently, cumulative daytime glare within the surrounding area would be less than significant. As implementation of the proposed project would not, after mitigation, result in a significant daytime glare impact, the proposed project would not result in a cumulatively considerable contribution to this impact. Therefore, cumulative impacts associated with daytime glare would not be cumulatively considerable and would be less than significant . Development within the areas adjacent to the proposed project area could result in the creation of new sources of light that could affect nighttime views. As described in 4.9 (Aesthetics), additional development in the East of 101 Area consists of the intensification of existing land uses, primarily research and development facilities, with some hotel and retail development. Additional development would increase nighttime lighting and could contribute to a diminishment in nighttime sky; however, all uses in the East of 101 Area primarily consist of office and R&D development, and would not be considered light-sensitive land uses. Therefore, this impact is not considered cumulative and would be less than significant . Cultural Resources This cumulative impact analysis considers development of the proposed project, in conjunction with other development in the East of 101 Area of South San Francisco, unless otherwise specified. This analysis accounts for all anticipated cumulative growth within this geographic area, as represented by full implementation of the City of South San Francisco General Plan and development of the related projects. Cumulative impacts on historic resources. Implementation of the proposed project would not encroach upon historical properties within the City; therefore, impacts on historical resources from any other project would not combine with the proposed project. Therefore, this impact is not considered less than significant cumulative and would be . 5-24 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Cumulative impacts on archaeological resources. In regards to archaeological resources, there are no known archaeological resources in the project vicinity, therefore, impacts on known archaeological resources from any other project would not combine with the proposed project. This cumulative effect is less than significant considered. Unknown archaeological resources may potentially be located within the project vicinity. Without mitigation, impacts from the proposed project and anticipated future development would be potentially significant in terms of encountering sensitive resources. The potential impact would be considered a significant cumulative impact. Because the proposed project could contribute to this impact within a large area of the East of 101 Area, its contribution would be cumulatively considerable. Mitigation measures MM 4.10-1 and MM 4.10-2, located in Section 4.10 (Cultural Resources), would prevent significant project impacts to archaeological resources, and would likewise render project impacts less than cumulatively considerable in relation to anticipated future development in the vicinity. If other projects have the potential to result in significant impacts on archaeological resources, then CEQA would similarly require the adoption and implementation of feasible mitigation measures for those projects. Therefore, other projects would likely be mitigated or conditioned in a similar fashion to the proposed project such that no significant cumulative effect would occur. This cumulative effect is less than significant considered after mitigation. Cumulative impacts on paleontological resources. In regards to paleontological resources and unique geologic resources, there are no known paleontological resources or unique geologic resources in the project vicinity, therefore, impacts on known paleontological resources from any other project would less than significant not combine with the proposed project. This cumulative effect is considered . Unknown paleontological resources may potentially be located within the project vicinity. Without mitigation, impacts from the proposed project and anticipated future development would be potentially significant in terms of encountering sensitive resources. The potential impact would be considered a significant cumulative impact. Because the proposed project could contribute to this impact within a large, 220-acre area, its impact contribution would be cumulatively considerable. Mitigation measure MM 4.10-3, located in Section 4.10 (Cultural Resources), would prevent significant project impacts to paleontological resources, and would likewise render project impacts less than cumulatively considerable in relation to anticipated future development in the vicinity. If other projects have the potential to result in significant impacts on paleontological resources, then CEQA would similarly require the adoption and implementation of feasible mitigation measures for those projects. Therefore, other projects would likely be mitigated or conditioned in a similar fashion to the proposed less project such that no significant cumulative effect would occur. This cumulative effect is considered than significant . Cumulative impacts on unknown human remains. Unknown locations with human remains may potentially be located within the project vicinity. Without mitigation, impacts from the proposed project and anticipated future development would be potentially significant in terms of encountering human remains. The potential impact would be considered a significant cumulative impact. Because the 5-25 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations proposed project could contribute to this impact within a large area of the East of 101 Area, its contribution would be cumulatively considerable. Mitigation measure MM 4.10-4, located in Section 4.10 (Cultural Resources), would prevent significant project impacts to human remains, and would likewise render project impacts less than cumulatively considerable in relation to anticipated future development in the vicinity. If other projects have the potential to result in significant impacts on human remains, then CEQA would similarly require the adoption and implementation of feasible mitigation measures for those projects. Therefore, other projects would likely be mitigated or conditioned in a similar fashion to the proposed project such that less than significant no significant cumulative effect would occur. This cumulative effect is considered . Population and Housing This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the City of South San Francisco. This analysis accounts for all anticipated cumulative growth within the City and the proposed project?s contribution to the cumulative impacts on population, employment, and housing. Cumulative impacts to population growth. The proposed project includes opportunity sites to be developed for R&D/office uses. As a result of this development, population growth will be induced in the South San Francisco region. Other future development sites will have the same effect as each project will create new jobs and/or homes within the City. The proposed project in conjunction with existing and future area projects will be cumulatively considerable creating a significant impact on population growth in the South San Francisco area; however, continued job growth in the city will promote a greater regional balance between jobs and housing. In its final Regional Needs Determination (RHND) figures, ABAG allocated 1,331 housing units to the City of South San Francisco (Housing Element 2005). Between January 1, 1999, and December 31, 2001, which is within the planning timeframe of the Housing Element, South San Francisco approved or built 1,688 new units. After accounting for approved and constructed housing units between January 1, 1999, and December 31, 2001, South San Francisco?s remaining fair share need is 504 new units (Housing Element 2005). According to the General Plan Housing Element, Summary of Quantified Objectives, pending projects and units that will be developed through implementation measures during the time frame of 2001 through 2006 will construct 528 more units. Once all units are constructed, the RHND will be exceeded by 24 units. As an inner Bay Area community well served by all modes of transit?including air and rail, BART and ferry service in the near future?future employees from and traveling to the city will have varied means of reaching employment sites. Therefore, because the Housing Element Summary of Quantified Objectives exceeds the RHND by 24 units, and continued employment growth within the City would serve to less than significant balance regional needs between jobs and housing, this impact is considered to be . Public Services This cumulative impact analysis considers development of the proposed project, in conjunction with other development within the City of South San Francisco. This analysis accounts for all anticipated 5-26 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations cumulative growth within the City and the proposed project?s contribution to a cumulative impact on public services. Cumulative impacts to police protection services. As additional development occurs in the City, there may be an overall increase in the demand for police protection services, including personnel, equipment, and/or facilities. The provision of adequate police protection services is of critical importance to the City, and funds are allocated to these services during the annual monitoring and budgeting process to ensure that police protection services are responsive to changes in the City. Funds collected in the form of plan check fees and inspection fees (for new development) are deposited into the General Fund and allocated to City services, as needed. In addition, staffing levels are evaluated by the SSFPD during the annual budgetary process, and personnel are hired, as needed, to ensure that adequate police protection services are provided. The cumulative impact, therefore, on police services in the City would be less than significant. The proposed project contribution to this cumulative impact is also less than significant because current response times are adequate and not expected to increase as a result of the proposed project and there would only be a negligible increase in daytime population as a result of the project which ensures that the officer to population ratio would remains adequate. In addition, existing city programs, practices, and procedures would continue to ensure the adequate provision police protection services. Therefore, the contribution of the proposed project to cumulative impacts on police less-than- protection services would not be cumulatively considerable. This is considered to be a significant impact. Cumulative impacts to fire protection services. As additional development occurs in the City, there may be an overall increase in the demand for fire protection services, including personnel, equipment, and/or facilities. The provision of adequate fire protection services is of critical importance to the City, and funds are allocated to these services during the annual monitoring and budgeting process to ensure that fire protection services are responsive to changes in the City. Funds collected in the form of plan check fees and inspection fees (for new development) are deposited into the General Fund and allocated to City services, as needed. In addition, staffing levels are evaluated by the SSFFD during the annual budgetary process, and personnel are hired, as needed, to ensure that adequate fire protection services are provided. The cumulative impact, therefore, on fire services in the City would be less than significant. The proposed project?s contribution to this cumulative impact is also less than significant because current response times are adequate and not expected to increase as a result of the proposed project and there would only be a negligible increase in daytime population as a result of the project which ensures that the officer to population ratio would remains adequate. In addition, existing city programs, practices, and procedures would continue to ensure the adequate provision police protection services. Therefore, the contribution of the proposed project to cumulative impacts on fire protection services would not be less-than-significant cumulatively considerable. This is considered to be a impact. Utilities The geographic context for a discussion of cumulative impacts to utilities is the service area of the utility in question. For instance, the geographic context for cumulative impacts to water supply is the CWSC and SFPUC service areas; to wastewater, it is the East of 101 Area; and to the storm drainage system, the 5-27 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations geographic context is the local watershed. The cumulative impacts analysis for each utility includes all cumulative growth within its respective service area, as identified by the providers? demand projections. Growth and utility demand forecasts for each utility are presented in the ?Existing Conditions? and ?Environmental Analysis? discussions of 4.13 Utilities. Cumulative effect on groundwater supplies or interference with groundwater recharge. By 2030, CWSC?s three peninsula district are projected to increase the average daily demand by an additional 1.5 mgd, while supply allocation form the SFPUC is expected to increase by 1.2 mgd, as shown in Table 5-3. The proposed project?s projected increase in demand is 0.29 mgd or 20 percent of the anticipated growth from the three districts. Any increase in the total demand will increase the demand on groundwater resources during drought years to supplement surface water shortfalls and could have a significant impact on the water table during drought years. The current shortfall is 10.4 mgd during multiple drought years. By 2030, the shortfall will be reduced to 8.03 mgd due to projected increases in SFPUC supplies. The proposed project?s projected increase in demand is 20 percent of anticipated growth, and represents less than 4 percent of the future supply deficit during multiple drought years, as a result the impact is cumulatively considerable. Table 5-3 CWSC Supply and Demand Comparison for Normal, Dry, and Multiple Dry Years Multiple Dry Year Event Normal Year One Critical Purchase Request Dry Year Year 1 Year 2 Year 3 2005 mgdpercent mgdpercent mgdpercent mgdpercent mgdpercent CWSC SFPUC 38.25 100% 31.33 81.9% 31.33 81.9% 27.23 71.2% 27.23 71.2% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 40.98 100% 33.79 82.4% 33.79 82.4% 29.41 71.8% 29.41 71.8% CWSC Demand 39.83 39.83 39.83 39.83 39.83 b Difference 1.15 2.9% -6.04 -15.2% -6.04 -15.2% -10.42 -26.2% -10.42 -26.2% 2010 CWSC SFPUC 35.78 100% 32.13 89.8% 32.13 89.8% 27.97 78.2% 27.97 78.2% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 38.51 100% 34.59 89.8% 34.59 89.8% 30.15 78.3% 30.15 78.3% CWSC Demand 40.45 40.45 40.45 40.45 40.45 b Difference -1.94 -4.8% -5.87 -14.5% -5.87 -14.5% -10.30 -25.5% -10.30 -25.5% 2015 CWSC SFPUC 35.47 100% 32.59 91.9% 32.59 91.9% 28.39 80.0% 28.39 80.0% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 38.2 100% 35.05 91.7% 35.05 91.7% 30.57 80.0% 30.57 80.0% CWSC Demand 40.48 40.48 40.48 40.48 40.48 b Difference -2.28 -5.6% -5.44 -13.4% -5.44 -13.4% -9.91 -24.5% -9.91 -24.5% 5-28 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations Table 5-3 CWSC Supply and Demand Comparison for Normal, Dry, and Multiple Dry Years Multiple Dry Year Event Normal Year One Critical Purchase Request Dry Year Year1Year2Year3 2005 mgdpercent mgdpercent mgdpercent mgdpercent mgdpercent 2020 CWSC SFPUC 36.01 100% 33.61 93.3% 33.61 93.3% 29.29 81.3% 29.29 81.3% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 38.74 100% 36.07 93.1% 36.07 93.1% 31.47 81.2% 31.47 81.2% CWSC Demand 40.72 40.72 40.72 40.72 40.72 b Difference -1.98 -4.9% -4.66 -11.4% -4.66 -11.4% -9.25 -22.7% -9.25 -22.7% 2025 CWSC SFPUC 36.32 100% 34.66 95.4% 34.66 95.4% 30.22 83.2% 30.22 83.2% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 39.05 100% 37.12 95.0% 37.12 95.0% 32.40 83.0% 32.40 83.0% CWSC Demand 40.96 40.96 40.96 40.96 40.96 b Difference -1.91 -4.7% -3.85 -9.4% -3.85 -9.4% -8.56 -20.9% -8.56 -20.9% 2030 CWSC SFPUC 36.96 100% 35.66 96.5% 35.66 96.5% 31.10 84.1% 31.10 84.1% Allocation a Local CWSC Supplies 2.73 100% 2.46 90.0% 2.46 90.0% 2.18 80.0% 2.18 80.0% a TOTAL CWSC Supplies 39.69 100% 38.12 96.0% 38.12 96.0% 33.28 83.9% 33.28 83.9% CWSC Demand 41.31 41.31 41.31 41.31 41.31 b Difference -1.62 -3.9% -3.20 -7.7% -3.20 -7.7% -8.03 -19.4% -8.03 -19.4% a Refer to Appendix F, Table 2-4. b Refer to Appendix F, Table 3-6. A new Groundwater Management Plan is being prepared by CWSC, the cities of San Bruno, Daly City and San Francisco. This plan is expected to outline methods to maintain water quality and ensure water supply availability. The plan will also attempt to quantify the amount of groundwater available. The findings in this plan will guide future groundwater withdrawal rates based on the available supply and acceptable yield rates. As a result, the impact is not cumulatively significant. While the proposed project?s effect on groundwater supply is not a significant effect under CEQA, there are measures that the City could encourage the project sponsor to implement or impose as conditions of approval. Mitigation measures MM 4.13-1(a) through (c) would reduce the proposed project?s contribution to the total groundwater demand. Therefore, the cumulative impact would be considered less than significant. Cumulative effect on water supply. Table 5-3 demonstrates the supply reliability and projected future demands by varying hydrologic conditions over the 25-year planning horizon through 2030 as required by SB 610. Based on modeling of historical weather data, all BAWSCA members have a significant risk 5-29 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations of water shortage relying on potable water supplies delivered through the regional water supply system. The SFPUC Water Supply Reliability Letter estimates that in 2010 CWSC has a 10.8 percent probability of at least a 10.2 percent shortage (3.65 mgd) and a 4.8 percent probability of a 21.8 percent (7.8 mgd) shortage, given the modeling circumstances and assumptions. As total water demands on the regional water system grow, water shortages will increase both in frequency and in magnitude. As such, the CWSC SSFD 2005 Draft UWMP contains a Water Shortage Contingency plan in the event of these potential system-wide supply reductions. The analysis of supply and demand shows that CWSC does not have sufficient water supplies to meet normal year demands after 2010 which is contrary to the SFPUC reliability statement in the SFPUC 39 This comparison of supply and demand finds that under the current supply situation, CWSC UWMP. can not meet the areas demand with secure purchase allotments from SFPUC even during normal years. With this understanding, it will be necessary for CWSC to further develop improved demand management measures that will increase conservation beyond the passive conservation mechanisms that are currently in place. 40 CWSC has committed to reducing demand in all service areas in 2030 by 2.36 mgd, which will allow CWSC to meet average, but not single dry year demands (10.8 percent probability of a shortage). A 10.8 percent probability of mandated reduction of normal year demand is considered a significant impact. As analyzed in the cumulative effects on groundwater, the proposed project would represent 20 percent of the projected growth for the CWSC?s three peninsula districts; as such the proposed project impact on supply is cumulatively considerable. SFPUC and CWSC are dedicated to implementing conservation and water recycling measures. Although aggressive demand reduction of the project?s water demands will not reduce the cumulative impact to less than significant, implementation of MM 4.13-1(a) through (c) on all development within the cities? boundaries would reduce severity and frequency of mandated reductions. Therefore, the cumulative impact would be considered less than significant. Cumulative impact related to erosion from altering the existing drainage pattern of the site, the course of a stream or river, or substantially increasing erosion or siltation on- or off-site. The City of South San Francisco is a highly developed urban area with a large amount of impervious surface area. The project area is currently developed with buildings, parking areas and other structures. There are no waterways on the project site and development of the project, or other foreseeable development, would not alter the course of a stream or river. All projects over one acre in size must obtain an NPDES General Permit for stormwater discharge associated with construction activity. Under this permit, developers proposing construction activity that disturbs more than one acre of land must submit a Notice of Intent (NOI), develop a Stormwater Pollution Prevention Plan (SWPPP), conduct monitoring and inspections, retain records of the monitoring, report incidences of noncompliance, and submit annual compliance reports. The SWPPP SFPUC, 2005 UWMP. p 81 39 Personal Communication with Nicole Sandkulla, Monday, March 6, 2006. 40 5-30 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations must address both grading/erosion impacts and non-point source pollution impacts of the development project, including post-construction impacts and sampling/monitoring requirements. Individual projects proposed under the 2006 FMPU that would disturb more than one acre of land would be required to obtain and comply with a NPDES General Permit for construction activity. Because the City is so highly developed, it is unlikely that any proposed project in the City would substantially convert a large parcel of land from pervious to impervious, thereby substantially increasing the amount of stormwater drainage flows, which could lead to increased erosion or siltation. Long term operational impacts of cumulative development would be similar to what currently exists in the area, with no substantial increase in stormwater runoff. With applicable projects obtaining the required NPDES permit to limit construction impacts and the small conversion of pervious to impervious surfaces, the same potential for erosion and siltation would occur as what currently exists. Therefore, the impact less than significant would be . Cumulative impact related to flooding from altering the existing drainage pattern of the area, the course of a stream or river or substantially increasing runoff. Foreseeable development in the City of South San Francisco could potentially alter the existing drainage pattern of the area, alter the course of a stream or river, or increase runoff that could cause on- or off-site flooding. It is possible that cumulative development could increase the amount of impervious surface area in the City such that drainage patterns are altered. However, it is not anticipated that the addition of a small amount of impervious surface area in the City would drastically increase stormwater flows. Surface water and stormwater runoff in the East of 101 Area are collected by the City?s storm drainage system and discharged to San Francisco Bay to the east of the MEIR Study Area. Thus, all cumulative development as identified in Table 5-1 drains to the same drainage system (including the proposed project), and cumulative development could experience localized flooding. During heavy storm events, outfalls below the mean high tide water elevation in the San Francisco Bay are likely to experience flooding when a heavy storm event happens during high tide water elevations. During lower tide, the outfall would be above the mean high tide elevation and flooding likely would not occur. However, this is a potentially significant impact. Implementation of mitigation measure MM 4.13-7 would ensure that stormwater flows generated from individual projects are analyzed prior to project construction and the less-than-significant impact would be reduced to a level. Cumulative impact related to creating or contributing runoff that could add substantial additional sources of polluted runoff. The existing drainage system in the East of 101 Area is generally designed and constructed for industrial development, which has a high ratio of impervious surfaces (Brady 1994). The Genentech storm drainage system consists of underground pipes and outfalls emptying into San Francisco Bay at various locations (Dyett & Bhatia 2005). The outfalls to the San Francisco Bay are both above and below the mean high tide elevation of 3.1 feet. Stormwater point and non-point source discharges are a major source of pollution in San Francisco Bay from the City, as the City?s storm drainage system discharges to the Bay. As redevelopment in the East of 101 Area continues, industrial and commercial development could degrade water quality through industrial pollutant discharges or simply as a result of increased traffic. 5-31 Genentech Corporate Facilities Master EIR Chapter 5 Other CEQA Considerations To combat this problem, the San Mateo Countywide Stormwater Pollution Program (STOPPP), a consortium of all 20 cities located within San Mateo County, has prepared a Best Management Practices (BMPs) plan to control pollutants in their stormwater system. Compliance with the permit requirements for non-point source stormwater discharge under the National Pollutant Discharge Elimination System (NPDES) also requires the property owner of all construction projects over one acre in size to obtain a stormwater discharge permit. The WQCP operates under STOPPP?s Joint Municipal NPDES Permit. Still cumulative impact and redevelopment may result in a significant increase of pollutant load in the run-off. The proposed project represents 167 acres or 14 percent of the 1,177 acres in the East of 101 Area, as a result the proposed project is cumulatively considerable. Compliance with mitigation measures MM 4.13-1 and MM 4.13-6 would ensure that the project?s contribution to stormwater pollutants flows would be minimized and would help reduce the amount of less-than-significant potentially harmful toxins on City streets, resulting in a cumulative impact. Cumulative impact related to a determination by the wastewater treatment provider that serves or may serve the project that it has inadequate capacity to serve the service area. The 2002 East of 101 Sewer System Master Plan (Carollo, 2002) required sewer system upgrades and allocated construction costs to existing and future users. Projected flow rates were calculated to a 2020 planning horizon based on redevelopment of 32 parcels to research and development. An addendum to the 2002 East of 101 Sewer System Master Plan (Carollo, 2006) recalculated demands based on the land use projections summarized in Table 5-1 (Background Growth?2015 Future Without Project Conditions and Figure 5- 1 (2015 Net Growth and TAZ Boundaries) in Chapter 5 Other CEQA Considerations. Demand factors and calculations are in Appendix F of the WSA (Appendix F of the DEIR). Current average dry weather flows in the East of 101 Area are approximately 2.0 mgd. The recalculated sewer flow rates, assumes the wastewater flow rates are equal to the water demands. The recalculated average dry flows were 4.7 mgd in 2015 and 6.4 mgd in 2030. The previous flow projections were 12.1 mgd in 2020, 1.9 times greater the revised flow. Deficiencies in the collection identified in 2002 East of 101 Sewer System Master Plan still need to be repaired to provide for future capacity (Carollo, 2006), but the lower projected flows may result in a larger connection charge per unit of capacity. Since planned improvements to the collection will less than significant adequately the serve the cumulative growth, the impact to the collection systems is . Current flows to the WQCP are approximately 10 mgd, while the permitted capacity of the plant is 13.4 mgd (Waste Discharge Requirements R2 2003-0010). No water quality violations have occurred within the last two years. Projected growth for the East 101 Area is 3.7 mgd, an increase of 1.7 mgd. The resulting increase for the East of 101 Area does not exceed the capacity of the WQCP, as the cumulative less than significant impact would be . 5.6ALTERNATIVES TO THE PROPOSED PROJECT Alternatives to the proposed project are presented in Chapter 6 (Alternatives to the Proposed Project) of this Draft MEIR. 5-32 Genentech Corporate Facilities Master EIR