Serramonte Del Rey Campus Redevelopment v Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
Impact AIR-2: The project would not
result in a cumulatively considerable
net increase of any criteria pollutant
for which the project region is nonattainment under an applicable federal or state ambient air quality standard.
(Less than Significant Impact with
Mitigation Incorporated)
MM AIR-2.1: BAAQMD Best Management Practices: The
project shall implement the Bay Area Air Quality
Management District’s (BAAQMD’s) recommended best
management practices (BMPs) and additional measures to
reduce construction equipment exhaust emissions. These
measures shall include the following:
• All exposed surfaces (e.g., parking areas, staging
areas, soil piles, graded areas, and unpaved access
roads) shall be watered three times a day and at a
frequency adequate to maintain minimum soil
moisture of 12 percent. Moisture content shall be
verified by lab samples or moisture probe.
• All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed using a wet power vacuum
street sweeper at least once per day. The use of dry
power sweeping shall be prohibited.
• All vehicle speeds on unpaved roads shall be limited
to 15 mph.
• All roadways, driveways, and sidewalks to be paved
shall be completed as soon as possible. Building pads
shall be laid as soon as possible after grading unless
seeding or soil binders are used.
• All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
certified mechanic and determined to be running in
proper condition prior to operation.
• Post a publicly visible sign with the telephone
number and person to contact at the Lead Agency
regarding dust complaints. This person shall respond
and take corrective action within 48 hours. The Air
District’s phone number shall also be visible to
ensure compliance with applicable regulations.
• All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed
20 mph and visible dust extends beyond site
boundaries.
• Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of
construction adjacent to sensitive receptors. Wind
breaks should have at maximum 50 percent air
porosity.
• Vegetative ground cover (e.g., fast-germinating
native grass seed) shall be planted in disturbed areas
as soon as possible and watered appropriately until
vegetation is established.
Serramonte Del Rey Campus Redevelopment vi Draft EIR
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Significant Impact Mitigation Measures
• The simultaneous occurrence of excavation, grading,
and ground-disturbing construction activities on the
same area at any one time shall be limited. Activities
shall be phased to reduce the amount of disturbed
surfaces at any one time.
• Avoid tracking of visible soil material on to public
roadways by employing the following measures if
necessary: (1) Site accesses to a distance of 100 feet
from public paved roads shall be treated with a 6 to
12-inch compacted layer of wood chips, mulch, or
gravel and (2) washing truck tires and construction
equipment of prior to leaving the site.
• Sandbags or other erosion control measures shall be
installed to prevent silt runoff to public roadways
from sites with a slope greater than one percent.
MM AIR-2.2: Selection of Construction Equipment: All
construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. Environmental Protection Agency (EPA) Tier 4
emission standards PM (PM10 and PM2.5), if feasible,
otherwise,
• Use equipment that meets U.S. EPA emission
standards for Tier 2 or 3 engines and include
particulate matter emissions control equivalent to
California Air Resources Board (CARB) Level 3
verifiable diesel emission control devices that
altogether achieve a 50-percent reduction in
particulate matter exhaust in comparison to
uncontrolled equipment; alternatively (or in
combination).
• Use of electrical or non-diesel fueled equipment.
Alternatively, the applicant may develop another construction operations plan demonstrating that the construction
equipment used on-site would achieve a reduction in
construction diesel particulate matter emissions by 70 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Implementation of Tier 4 or alternatively fueled
equipment,
• Installation of electric power lines during early
construction phases to avoid use of diesel generators
and compressors,
• Use of electrically-powered equipment,
Serramonte Del Rey Campus Redevelopment vii Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
• Forklifts and aerial lifts used for exterior and interior building construction shall be electric or
propane/natural gas powered,
• Change in construction build-out plans to lengthen
phases, and
• Implementation of different building techniques that
result in less diesel equipment usage.
Such a construction operations plan would be subject to review by an air quality expert and approved by the City prior to construction.
MM AIR-2.3: Low Volatile Organic Compounds (VOC)
Coating: The project shall use low volatile organic compound or VOC (i.e., ROG) coatings, that are below current
BAAQMD requirements (i.e., Regulation 8, Rule 3:
Architectural Coatings), for at least 50 percent of all residential and nonresidential interior paints and 50 percent of exterior paints. This includes all architectural coatings applied during both construction and reapplications
throughout the project’s operational lifetime. At least 50 percent of coatings applied must meet a “super-compliant” VOC standard of less than 10 grams of VOC per liter of
paint. For reapplication of coatings during the project’s operational lifetime, the Declaration of Covenants,
Conditions, and Restrictions shall contain a stipulation for low VOC coatings to be used.
Impact AIR-3: The project would not
expose sensitive receptors to
substantial pollutant concentrations.
(Less than Significant Impact with
Mitigation Incorporated)
See mitigation measures MM AIR-2.1 and MM AIR-2.2
above.
MM AIR-3.1: Prior to the issuance of a grading permit, the applicant shall provide the City with the most recent
construction phasing schedule by parcel for buildout of the proposed Precise Plan. If the most recent construction
phasing schedule increases the number of units per
construction phase compared to the construction phasing assumed in the air quality analysis of this EIR, the applicant shall prepare an updated community health risk assessment to confirm that the new phasing will not result in any new or more significant air quality impacts not previously disclosed in this EIR. The updated community health risk assessment shall be reviewed and approved by the Director of
Community Development or Director’s designee.
Serramonte Del Rey Campus Redevelopment viii Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
Impact AIR-C: The project would not
result in a cumulatively considerable
contribution to a cumulatively
significant air quality impact. (Less
than Significant Cumulative Impact
with Mitigation Incorporated)
See mitigation measures MM AIR-2.1 and MM AIR-2.2
above.
Impact BIO-1: The project would not
have a substantial adverse effect, either
directly or through habitat
modifications, on any species
identified as a candidate, sensitive, or
special status species in local or
regional plans, policies, or regulations,
or by the CDFW or USFWS. (Less
than Significant Impact with
Mitigation Incorporated)
MM BIO-1.1:
• If construction is initiated during the non-breeding
season (September 1 to January 31), then vegetation
removal, building demolition and other construction
may proceed with no restrictions.
• If initial building demolition, vegetation removal,
and construction is proposed during the nesting
season (February 1 to August 31), a focused survey
for nesting raptors and other native birds shall be
conducted by a qualified biologist within 14 days
prior to the onset of construction in order to
determine whether any active nests are present on the
site and surrounding area within 250 feet of proposed
construction. The survey shall be reconducted any
time construction has been delayed or curtailed for
more than 14 days during the nesting season.
• If no active nests are identified during the
construction survey period, then building demolition,
vegetation removal, and other construction may
proceed with no restrictions.
• If active bird nests are found, an adequate setback
shall be established by a qualified biologist, approved by the City Planning Division, around the nest
location and construction activities restricted within
this no-disturbance zone until the qualified biologist
has confirmed that any young birds have fledged and
are able to function outside the nest location.
Required setback distances for the no-disturbance
zone shall be based on input received from the
CDFW and may vary depending on species and
sensitivity to disturbance. As necessary, the nodisturbance zone shall be fenced with temporary orange construction fencing if construction is to be
initiated elsewhere on the site outside this zone.
• A report of findings shall be prepared by the
qualified biologist and submitted to the Director of
Community Development or Director’s designee for
review and approval prior to initiation of
construction during the nesting season (February 1 to
August 31). The report shall either confirm absence
of any active nests or should confirm that any young
are located within a designated no-disturbance zone
and construction can proceed. No report of findings
is required if construction is initiated during the nonPage 1087 of 1426 Serramonte Del Rey Campus Redevelopment ix Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
nesting season (September 1 to January 31) and
continues uninterrupted according to the above
criteria.
MM BIO-1.2: Adequate measures shall be taken to avoid
roosting by special-status bat species as a result of tree removal and building demolition, specifically:
• To the extent feasible, any tree removal or trimming
that is deemed necessary by a certified arborist to
maintain tree health shall be conducted outside of the
bat maternity season (i.e., generally avoiding tree
removal or trimming April through October).
• Building demolition shall, to the extent feasible, be conducted outside of the bat maternity season (i.e.,
generally avoiding demolition April through
October).
• If tree removal, trimming, or building demolition
occurs within bat maternity season (i.e., generally
April through October), a pre-construction bat roost
assessment shall be conducted by a qualified
biologist at least 14 days and no more than 30 days
prior to tree removal or building demolition to
determine if bats roosts are present that may be
impacted by project activities.
• If special-status bat species or maternity roosts are detected during these surveys, a qualified biologist
shall identify any additional measures required to
protect the roosts, such as including avoidance of the
roosts until the end of the maternity roosting season.
• Regardless of the timing of tree removal or trimming
activities, all felled trees or large limbs shall remain on the ground for at least 24-hours prior to chipping,
off-site removal, or other processing to allow any
roosting individual bats to vacate the premises of
their own volition.
• A report of findings shall be prepared by the
qualified biologist and submitted to the Director of
Community Development or Director’s designee for
review and approval prior to initiation of
construction during the maternity roosting season
(April through October). The report shall either
confirm absence of any active maternity roosts or
specify any additional measures necessary to protect
roosts until the end of the maternity roosting season.
No report of findings is required if construction is
initiated during the non-maternity roosting season
(November through March) and continues
uninterrupted according to the above criteria.
Serramonte Del Rey Campus Redevelopment x Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
Impact BIO-C: The project would not
result in a cumulatively considerable
contribution to a cumulatively
significant biological resources impact.
(Less than Significant Cumulative
Impact with Mitigation
Incorporated)
See mitigation measures MM BIO-1.1 and MM BIO-1.2
above.
Impact CUL-2: The project would not
cause a substantial adverse change in
the significance of an archaeological
resource pursuant to CEQA Guidelines
Section 15064.5. (Less than
Significant Impact with Mitigation
Incorporated)
MM CUL-2.1: Undiscovered Archaeological Resources. If
evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5,
including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g.,
worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all grounddisturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation. the City’s Planning Manager shall consult with the archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-than-significant level through data recovery or other methods determined adequate by a
qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.
MM CUL-2.2: Report of Archaeological Resources. If
archaeological resources are identified, a final report summarizing the discovery of cultural materials shall be submitted to the City’s Planning Manager prior to issuance of certificate of occupancy. This report shall contain a
description of the mitigation program that was implemented and its results, including a description of the monitoring and testing program, a list of the resources found and conclusion, and a description of the disposition/curation of the resources.
Impact CUL-3: The project would not
disturb any human remains, including
those interred outside of dedicated
cemeteries. (Less than Significant
Impact with Mitigation
Incorporated)
MM CUL-3.1: Human Remains. If human remains are
discovered during project construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County
coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section
7050.5 of California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC
Serramonte Del Rey Campus Redevelopment xi Draft EIR
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Significant Impact Mitigation Measures
shall be adhered to in the treatment and disposition of the remains. The project sponsor shall also retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide
professional assistance to the Most Likely Descendant,
including the excavation and removal of the human remains.
The City of Daly City shall be responsible for approval of recommended mitigation as it deems appropriate, taking
account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement
approved mitigation, to be verified by the City of Daly City, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.
Impact GEO-6: The project would
not directly or indirectly destroy a
unique paleontological resource or site
or unique geological feature. (Less
than Significant Impact with
Mitigation Incorporated)
MM GEO-6.1: Unique Paleontological and/or Geologic
Features and Reporting. Should a unique paleontological resource or site or unique geological feature be identified at the project site during any phase of construction, all ground disturbing activities within 25 feet shall cease and the City’s Planning Director notified immediately. A qualified
paleontologist shall evaluate the find and prescribe mitigation measures to reduce impacts to a less than significant level.
Work may proceed on other parts of the project site while mitigation for paleontological resources or geologic features is implemented. Upon completion of the paleontological
assessment, a report shall be submitted to the City and, if paleontological materials are recovered, a paleontological repository, such as the University of California Museum of Paleontology.
Impact GEO-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant geology and
soils impact. (Less than Significant
Cumulative Impact with Mitigation
Incorporated)
See mitigation measure MM GEO-6.1 above.
Impact HAZ-2: The project would not
create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment. (Less than Significant
Impact with Mitigation
Incorporated)
MM HAZ-2.1: Prior to the issuance of demolition, grading, or building permits for projects on Parcels C-E, the applicant shall remove the existing underground storage tanks (USTs) and aboveground storage tanks (ASTs) in accordance with the San Mateo County Department of Environmental
Health’s (SMCDEH) Underground Storage Tank Program
and Aboveground Petroleum Storage Tank Program. During
removal of the ASTs and USTs, contractors shall observe for staining and spilled contaminants. If stains and/or spills are observed, an Environmental Professional shall be retained to collect soil samples for laboratory analysis in accordance
Serramonte Del Rey Campus Redevelopment xii Draft EIR
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Significant Impact Mitigation Measures
with commonly accepted environmental protocols. If
contaminants are identified at concentrations exceeding applicable screening levels published by the RWQCB, DTSC and/or EPA , appropriate mitigation measures, such as, but not limited to, a Soil Management Plan and Health Safety Plan, shall be incorporated into the demolition permit.
Approval by an appropriate regulatory agency (i.e., RWQCB, DTSC or SMCDEH) shall be obtained prior to conducting
earthwork activities in the vicinity of the impacted soil. The applicant shall provide documentation of the safe removal of all existing USTs and ASTs consistent with SMCDEH
requirements to Director of Economic and Community
Development or Director’s designee for review and approval.
Impact HAZ-3: The project would not
emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
one-quarter mile of an existing or
proposed school. (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measure MM HAZ-2.1 above.
Impact NOI-1: The project would not
result in generation of a substantial
temporary or permanent increase in
ambient noise levels in the vicinity of
the project in excess of standards
established in the local general plan or
noise ordinance, or applicable
standards of other agencies. (Less
than Significant Impact with
Mitigation Incorporated)
MM NOI-1.1: The applicant shall develop a construction
noise control plan for each construction phase, including, but not limited to, the following available controls:
• Construct temporary noise barriers, where feasible, to screen stationary noise-generating equipment.
Temporary noise barrier fences would provide a 5
dBA noise reduction if the noise barrier interrupts the line-of-sight between the noise source and receptor
and if the barrier is constructed in a manner that
eliminates any cracks or gaps.
• Equip all internal combustion engine-driven
equipment with intake and exhaust mufflers that are
in good condition and appropriate for the equipment.
• Unnecessary idling of internal combustion engines
should be strictly prohibited.
• Locate stationary noise-generating equipment, such
as air compressors or portable power generators, as
far as possible from sensitive receptors as feasible. If they must be located near receptors, adequate
muffling (with enclosures where feasible and
appropriate) shall be used to reduce noise levels at
the adjacent sensitive receptors. Any enclosure
openings or venting shall face away from sensitive
receptors.
• Utilize "quiet" air compressors and other stationary
noise sources where technology exists.
Serramonte Del Rey Campus Redevelopment xiii Draft EIR
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Significant Impact Mitigation Measures
• Construction staging areas shall be established at
locations that will create the greatest distance
between the construction-related noise sources and
noise-sensitive receptors nearest the project site
during all project construction.
• Locate material stockpiles, as well as
maintenance/equipment staging and parking areas, as
far as feasible from residential receptors.
• Route construction-related traffic along major
roadways and as far as feasible from sensitive
receptors.
• Locate material stockpiles, as well as
maintenance/equipment staging and parking areas, as
far as feasible from residential receptors.
• Control noise from construction workers’ radios to a
point where they are not audible at existing
residences bordering the project site.
• The contractor shall prepare a detailed construction
schedule for major noise-generating construction
activities. The construction plan shall identify a
procedure for coordination with adjacent residential
land uses so that construction activities can be
scheduled to minimize noise disturbance.
• Designate a "disturbance coordinator" who would be
responsible for responding to any complaints about
construction noise. The disturbance coordinator will
determine the cause of the noise complaint (e.g., bad
muffler, etc.) and will require that reasonable
measures be implemented to correct the problem.
Conspicuously post a telephone number for the
disturbance coordinator at the construction site and
include in it the notice sent to neighbors regarding
the construction schedule.
Impact TRN-2: The project would not
conflict or be inconsistent with CEQA
Guidelines Section 15064.3,
subdivision (b). (Less than
Significant Impact with Mitigation
Incorporated)
MM TRN-2.1: Prior to issuance of building permits, the
project applicant shall develop a transportation demand management (TDM) plan for the proposed project (except for the Parcel A development project which has already been occupied) in accordance with C/CAG’s Transportation
Demand Management Policy Implementation Guide,
including any anticipated phasing, and shall submit the TDM Plan to the City for review and approval. The TDM Plan shall identify trip reduction strategies as well as mechanisms for funding and overseeing the delivery of trip reduction
programs and strategies. The TDM Plan shall be designed to achieve the trip reduction, as required to reduce the VMT per resident from 12.0 to 11.6. The TDM Plan shall describe which measures apply to the entire site and which, if any, apply on a parcel-by-parcel basis.
Serramonte Del Rey Campus Redevelopment xiv Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
Trip reduction strategies applicable to the proposed project may include, but are not limited to, the following:
• Provide Secure and Accessible Bike Parking
• Provide Bicycle Maintenance Facilities
• Price and Unbundle Parking
• Provide Carpooling Programs
• Implement Car-Sharing Program
• Implement Loaner Bike Program
• Provide a Transit Riders Guide
• Provide a Dedicated Transportation Coordinator
• Provide an Online TDM Information Center
• Free Trial Rides on Transit Services
• Implement a Subsidized or Discounted Transit
Program
The TDM plan shall indicate the estimated Vehicle Trip
Reduction (VTR) for each strategy proposed based on
published research or guidelines. For TDM measures
containing ongoing operational VTR strategies, the TDM
plan shall include an ongoing monitoring and enforcement program to ensure the Plan is implemented on an ongoing basis during project operation. For VTR strategies involving physical improvements, the project shall obtain the necessary permits/approvals from the City and install the improvements prior to building occupancy. Applicant will resubmit TDM Plan if there is a material adverse impact resulting from a change from the permitted uses (i.e., unit count, use type, phasing).
The TDM Plan shall require annual evaluation of the
program by the property owner, to determine if the program goals in reducing automobile travel are satisfied and to assess the effectiveness of the various strategies implemented. The property owner shall be required to conduct biennial selfcertification for the first six years of project occupancy per the C/CAG TDM Program. The property owner shall conduct annual travel surveys and driveway counts to monitor the amount of automobile travel generated by the project. The goal of the TDM Plan and programs shall be to reduce the project’s daily VMT per resident from 12.0 to 11.6. Based on the results of the surveys, the TDM programs shall be
increased if these requirements are not met. Annual travel surveys and driveway counts (TDM program monitoring)
shall be conducted for the first two years following project occupancy. The results of the monitoring program and travel surveys shall be submitted to the City for review and
Serramonte Del Rey Campus Redevelopment xv Draft EIR
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Significant Impact Mitigation Measures
approval. If the program VMT reduction goals are met in the first six years, annual monitoring and surveys shall be suspended. If the program’s VMT reduction goals are not satisfied, site management shall prepare and submit for City approval a Corrective Action Plan. The Corrective Action Plan shall detail the additional TDM measures to be
implemented on site and their expected travel/mode split reduction. Additional annual travel surveys and driveway counts shall be conducted for the two years following the implementation of the Corrective Action Plan to determine if the program’s VMT reduction goals are satisfied.
Impact TRN-3: The project would not
substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm
equipment). (Less than Significant
Impact with Mitigation
Incorporated)
MM TRN-3.1: A Construction Traffic Management Plan
shall be developed and implemented to minimize impacts to the transportation system. The Construction Traffic
Management Plan shall detail the Project’s construction schedule, vehicle type time-of-day plans, route planning, advanced public notices of partial or full street closures or traffic diversion, and other strategies to reduce potential conflicts during construction. The plan shall include, but not be limited to, the following:
• Identification of the traffic controls and methods
proposed during each phase of Project construction.
Provision of safe and adequate access for vehicles,
transit, bicycles, and pedestrians. Traffic controls and methods employed during construction shall be in
accordance with Daly City standards and the
requirements of the California Manual of Uniform
Traffic Control Devices (CA MUTCD 2014,
Revision 6).
• Provision of notice to relevant emergency services,
thereby avoiding interference with adopted
emergency plans, emergency vehicle access, or
emergency evacuation plans.
• A prohibition on all construction truck activity
during the weekday morning and evening peak
commute periods (7:00 a.m. to 9:00 a.m. and 4:00
p.m. to 6:00 p.m.).
• Preservation of emergency vehicle access.
• Identification of approved truck routes in
communication with Daly City staff.
• Location of staging areas and the location of
construction worker parking.
• Identification of the means and locations of the
separation (i.e. fencing) of construction areas and
adjacent active uses.
• The provision of flaggers at all on-site locations
where construction trucks and construction worker
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Significant Impact Mitigation Measures
vehicles conflict with vehicle, bicycle, transit, or
pedestrian traffic.
• Provision of a point of contact for residents to obtain construction information, have questions answered
and convey complaints.
MM TRN-3.2: As part of the Parcel B Development
project’s final design, details of the Serramonte Boulevard parking garage driveway design would include the following as determined necessary by the City Traffic Engineer:
• Measures to prohibit vehicular left-turns – either
through the installation of a hard concrete median,
vertical delineators, or alternative means.
• Adequate sight distance – obstructions to sight
distance for all users should not be placed adjacent to the driveway and adequate throat distance to the
garage entry should be provided accordingly.
• Pedestrian and bicycle warning measures – adequate
warning measures for pedestrians and bicycles
should be provided on Serramonte Boulevard,
including the installation of tactile domes on the
sidewalk and green hatched bike lane striping on the
roadway.
• The Parcel B driveway along Serramonte Blvd. shall
provide satisfactory separation distance from the
intersection of Serramonte Blvd. and Highway 1 onand off-ramps to address merging and any turning movements.
• A separate traffic study shall be conducted to
determine if a new traffic signal at the Parcel B
driveway is warranted. The results of the study will
affect the City’s determination on whether a
driveway entry and exit shall be permitted along
Serramonte Blvd.
MM TRN-3.3: As part of the project’s final design, each residential facility’s garage entrance accessed via the public right of way shall be designed to provide adequate storage for expected vehicle queues. The amount of storage shall be calculated based on the individual garage size and forecast rates of arrival and departure. A minimum stacking distance of 25 feet shall be provided between the back of curb and gate installation at the entrance to each residential garage entrance. The purpose of this space is to minimize the
instance of vehicles queued across sidewalks and bicycle facilities. These queue calculations shall be performed for
Serramonte Del Rey Campus Redevelopment xvii Draft EIR
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Significant Impact Mitigation Measures
each garage and submitted to the City Engineer with
planning/building permit for review and approval.
Impact TRN-4: The project would not
result in inadequate emergency access.
(Less than Significant Impact with
Mitigation Incorporated)
MM TRN-4.1: In accordance with City and North County
Fire Authority requirements and design standards, all future development within the project site shall provide even
surface pavement, appropriate signage, delineation, and other features at all emergency access points and internal roadways to accommodate emergency vehicles. As part of the final design and permitting process, each proposed development shall seek and obtain approval from the North County Fire Authority.
Impact TRN-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant transportation
impact. (Less than Significant
Cumulative Impact with Mitigation
Incorporated)
See mitigation measure MM TRN-2.1 above.
Impact TCR-1: The project would not
cause a substantial adverse change in
the significance of a tribal cultural
resource that is listed or eligible for
listing in the California Register of
Historical Resources, or in a local
register of historical resources as
defined in Public Resources Code
Section 5020.1(k). (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Impact TCR-2: The project would not
cause a substantial adverse change in
the significance of a tribal cultural
resource that is determined by the lead
agency, in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth
in subdivision (c) of Public Resources
Code Section 5024.1. (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Impact TCR-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant tribal cultural
resources impact. (Less than
Significant Cumulative Impact with
Mitigation Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Serramonte Del Rey Campus Redevelopment xviii Draft EIR City of Daly City June 2023
Summary of Project Alternatives
The California Environmental Quality Act (CEQA) requires that an EIR identify alternatives to the project as proposed. The CEQA Guidelines state that an EIR must identify alternatives that would feasibly attain the most basic objectives of the project, but avoid or substantially lessen significant environmental effects, or further reduce impacts that are considered less than significant with the incorporation of mitigation. A summary of project alternatives follows. The EIR considered three alternatives, beyond those presented below, but rejected them for further analysis. A full analysis of project alternatives is provided in Section 7.0 Alternatives.
No Project Alternative
The No Project Alternative assumes that the project site would remain as it is today with the existing buildings being reoccupied. All environmental impacts of the project would be avoided. However, this alternative would not achieve any of the project objectives.
No Project – Existing Zoning Alternative
The No Project – Existing Zoning Alternative is what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. This alternative assumes the project is not approved and the project site is redeveloped consistent with the current zoning of PD-31 (Planned Development District).1 The PD-31 zoning is the current 1985 Precise Plan for the project site, which allows for the development of up to 175 residential units (53 units in addition to the 122 units developed on Parcel A) and approximately 700,000 square feet of office space. Associated infrastructure and roadway improvements would also be required in order to construct the No Project – Existing Zoning Alternative. This alternative would lessen the project’s construction criteria pollutant, TAC health risk, construction noise, and construction traffic impacts because it would reduce overall building square footage by approximately 500,000 square feet, but result in slightly greater VMT impacts per resident. This alternative would result in the same or similar impacts to all other environmental resource areas as the project. This alternative does not meet the project objective of providing new market-rate and affordable housing given this alternative would yield 175 units, substantially below the 1,235 proposed. This alternative would result in substantial office space on the project site, which is not an objective of the project.
Environmentally Superior Alternative
The CEQA Guidelines state that an EIR shall identify an environmentally superior alternative. As described in Section 7.0 Alternatives, the environmentally superior alternative to the proposed project is the No Project Alternative because all of the project’s significant environmental impacts would be avoided. In addition to the No Project Alternative, the No Project – Existing Zoning Alternative would be an environmentally superior alternative. 1 A smaller portion of the of the site in the northwest corner (Parcel A Development project) is zoned to PD-31A.
The PD-31A zoning was specifically created to allow for the Parcel A Development project, which will construct 122 multifamily units. Since this project is already approved and under construction, the remainder of the project site would be developed consistent with the PD-31 zoning.
Serramonte Del Rey Campus Redevelopment xix Draft EIR
City of Daly City June 2023
Areas of Concern
Environmental concerns expressed thus far from local residents, property owners, organizations, and/or agencies about the project include the following:
• Air quality impacts
• Biological impacts (nesting birds, wetlands, trees)
• Tribal and cultural resources
• School impacts
• Airport safety
• Project-generated traffic on roadway and freeway capacity • Bicycle/Pedestrian impacts
• Required connections to existing utilities infrastructure and needed improvements • Loss of an informal community garden space
Serramonte Del Rey Campus Redevelopment 1 Draft EIR
City of Daly City June 2023
SECTION 1.0 INTRODUCTION
1.1 PURPOSE OF THE ENVIRONMENTAL IMPACT REPORT
The City of Daly City, as the Lead Agency, has prepared this Draft Environmental Impact Report (EIR) for the Serramonte Del Rey Campus Redevelopment project in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines.2
As described in CEQA Guidelines Section 15121(a), an EIR is an informational document that assesses potential environmental impacts of a proposed project, as well as identifies mitigation measures and alternatives to the proposed project that could reduce or avoid adverse environmental impacts (CEQA Guidelines 15121(a)). As the CEQA Lead Agency for this project, the City of Daly City is required to consider the information in the EIR along with any other available information in deciding whether to approve the project. The basic requirements for an EIR include discussions of the environmental setting, significant environmental impacts including growth-inducing impacts, cumulative impacts, mitigation measures, and alternatives. It is not the intent of an EIR to recommend either approval or denial of a project.
1.2 EIR PROCESS
1.2.1 Notice of Preparation and Scoping
In accordance with Section 15082 of the CEQA Guidelines, the City of Daly City prepared a Notice of Preparation (NOP) for this EIR. The NOP was circulated locally on May 7, 2021 and the standard 30-day comment period concluded on June 7, 2021. The NOP was circulated to state and federal agencies through the State Clearinghouse on June 21, 2023 and the 30-day comment period concluded on July 21, 2023. The NOP provided a general description of the proposed project and identified possible environmental impacts that could result from implementation of the project. City of Daly City also held a public scoping meeting on May 19, 2021 to discuss the project and solicit public input as to the scope and contents of this EIR. The meeting was held virtually through a video conference call due to COVID-19 restrictions. Appendix A of this EIR includes the NOP and comments received on the NOP.
1.2.2 Draft EIR Public Review and Comment Period
Publication of this Draft EIR will mark the beginning of a 45-day public review period. During this period, the Draft EIR will be available to the public and local, state, and federal agencies for review and comment. Notice of the availability and completion of this Draft EIR will be sent directly to every agency, person, and organization that commented on the NOP, as well as the Office of Planning and Research. Written comments concerning the environmental review contained in this Draft EIR during the 45-day public review period should be sent to:
2 The project site is owned and operated by the Jefferson Union High School District; however, since the project is proposing residential and commercial uses and not educational facilities, the City of Daly City is considered the Lead Agency for the project.
Serramonte Del Rey Campus Redevelopment 2 Draft EIR
City of Daly City June 2023
Michael Van Lonkhuysen, Planning Manager
City of Daly City – Planning Division
333 90th Street
Daly City, CA 94015
[email protected]
1.3 FINAL EIR/RESPONSES TO COMMENTS
Following the conclusion of the 45-day public review period, the City of Daly City will prepare a Final EIR in conformance with CEQA Guidelines Section 15132. The Final EIR will consist of:
• Revisions to the Draft EIR text, as necessary;
• List of individuals and agencies commenting on the Draft EIR; • Responses to comments received on the Draft EIR, in accordance with CEQA Guidelines (Section 15088);
• Copies of letters received on the Draft EIR.
Section 15091(a) of the CEQA Guidelines stipulates that no public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings. If the lead agency approves a project despite it resulting in significant adverse environmental impacts that cannot be mitigated to a less than significant level, the agency must state the reasons for its action in writing.
This Statement of Overriding Considerations must be included in the record of project approval.
1.3.1 Notice of Determination
If the project is approved, the City of Daly City will file a Notice of Determination (NOD), which will be available for public inspection and posted within 24 hours of receipt at the County Clerk’s Office and available for public inspection for 30 days. The filing of the NOD starts a 30-day statute of limitations on court challenges to the approval under CEQA (CEQA Guidelines Section 15094(g)).
Serramonte Del Rey Campus Redevelopment 3 Draft EIR
City of Daly City June 2023
SECTION 2.0 PROJECT INFORMATION AND DESCRIPTION
2.1 PROJECT LOCATION
The approximately 22-acre project site is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard in the City of Daly City (APN 091-211-230). The majority of the project site has a General Plan land use designation of C-O (Commercial – Office) and is zoned PD-31 (Planned Development District) while a smaller portion of the site in the northwest corner was rezoned to PD31A for a faculty and staff housing project that has been constructed and now is occupied and has a General Plan land use designation of R-HD (Residential-High Density). Regional, vicinity, and aerial maps of the project site are provided in Figure 2.2-1, Figure 2.2-2, Figure 2.2-3, and Figure 2.2-4, respectively.
2.2 PROJECT DESCRIPTION
The project consists of two primary components: (1) development of a new approximately 22-acre Serramonte Del Rey Precise Plan (Precise Plan), and (2) a specific development proposal for the approximately 4.3-acre Parcel B within a portion of the new Precise Plan.
2.2.1 Precise Plan
A Precise Plan was approved in 1985 for an approximately 50-acre area that includes the project site and extends south to Hickey Boulevard. Phase I of the 1985 Precise Plan has already been built and includes the apartment buildings, Summit Shasta High School, and office buildings located south of the project site along Campus Drive (see Figure 2.2-3). Phase II of the 1985 Precise Plan would redevelop the approximately 22-acre project site up to 175 residential units and approximately 700,000 square feet of office space. The proposed Precise Plan would replace Phase II of the 1985 Precise Plan for the approximately 22-acre project site and would leave the original Precise Plan in place for the portion outside of the project site. The zoning and General Plan land use designation of the portion outside of the project site would also remain as-is.
This EIR provides project-level environmental review for the full buildout of the Precise Plan as described below. The City will review future project applications at the time specific development is proposed on each Parcel to ensure each proposed project is consistent with the development assumptions analyzed in this EIR. The new Precise Plan would allow for the redevelopment of the project site area with up to 1,235 units (which includes the existing 122 units on Parcel A) of affordable and market-rate rental housing, up to 14,000 square feet of neighborhood-serving retail/commercial uses (in addition to 2,400 square feet for a Head Start childcare facility), and infrastructure improvements throughout the project area. Compared to the existing approved plan, the proposal would result in a net increase of 1,060 residential units and the elimination of planned office space.3
The new Precise Plan would require a General Plan Amendment from C-O (Commercial – Office) to C-MU (Commercial – Mixed Use). Table 2.2-1 below summarizes the proposed maximum development allowed per parcel, although the overall Precise Plan development totals would be as noted above, and less than the sum of what is possible on each parcel. 3 The total residential units in the proposed Precise Plan is inclusive of the already approved faculty and staff housing project located on Parcel A. 1,235 units – 175 units = 1,060 units.
Serramonte Del Rey Campus Redevelopment 4 Draft EIR
City of Daly City June 2023
Table 2.2-1: Development Maximum Per Parcel
Parcel Number Maximum Residential Units1
Maximum
Retail/Commercial (square
feet)3
Parcel A2 122 0
Parcel B 210 8,000
Parcel C5 125 6,0004
Parcel D 270 6,000
Parcel E 330 6,000
Parcel F 400 6,000
1. Shows maximum residential units per parcel; however, the total amount of residential units across all parcels shall not exceed 1,235 units.
2. Parcel A has been constructed and occupied and was approved under a separate application
3. Parcels C-F may provide retail/commercial space in addition to the 8,000 square feet assumed for Parcel B; however, the total amount across all parcels shall not exceed 14,000 square feet
4. Parcel C is permitted to build up to 1,400 square feet of childcare facilities in addition to the overall retail/commercial square footage
5. Parcel C would be subdivided into two parcels (C1 and C2) The proposed Precise Plan would divide the project site into six development parcels (with Parcel C further subdivided into two smaller parcels) and additional street parcels with public access easements (see Figure 2.2-5). Parcels A, B, and C would have maximum building heights of 77 feet, and Parcels D, E, and F would have a maximum building height of 150 feet. The 1985 Precise Plan allowed for 12-story building within the center of the project site, six-story buildings along the eastern property line, and 3.5-story buildings along the western property line. Build-out of the site and division of parcels is anticipated to be over an eight to 12 year period, but potentially up to 15 years. The proposed phasing for the Precise Plan is development of Parcel B first, followed by Parcels C and D, and finally Parcels E and F, although the phasing order may be adjusted by market conditions or other factors. The proposed Precise Plan would also establish a new Planned Development District, consistent with the City’s Municipal Code Chapter 17.28. A copy of the proposed Precise Plan is included in Appendix B.
San Francisco County
San Mateo County
Monterey Boulevard
John Daly Boulevard John Daly Boulevard
Geary Boulevard
Great Highway
Hillside Boulevard
Sister Cities Boulevard
Geneva Avenue
Ocean Avenue
Portol a Drive
Lincoln Way
Fell Street
Van Ness Avenue
Guerrero Street
Dolores Street
Mission Street
Sharp Park Rd.
Chestnut Ave
Geary Boulevard
Great Highway
Hillside Boulevard
Sister Cities Boulevard
Geneva Avenue
Ocean Avenue
Portol a
Drive
Lincoln Way
Fell Street
Van Ness Avenue
Guerrero Street
Dolores Street
Mission Street
Sharp Park Rd.
Chestnut Ave
1 1
1 1
35 82
82 35
35 101
101
80 280
280
280
380
Pacific
Ocean
Project Site
San Francisco
Daly City
South San Francisco
Pacifica
San Bruno
REGIONAL MAP FIGURE 2.2-1
Pacific
Ocean
San José
Fremont
Oakland
San Francisco
Mountain View
Sunnyvale
Fremont San Mateo
Redwood City
Oakland
San Francisco
Mountain View
Project SiteSan Francisco Bay
01 .5 3 Miles
Collins Avenue
Serramonte Boulevard
Serramonte
Boulevard
Junipero Serra Boulevard
Callan Boulevard
Hickey Boulevard Gellert Bou el va dr
St. Francis Boulevard
Callan Boulevard
Skyline Drive
Westline Drive
Collins Avenue Serramonte Boulevard
S
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a
m
o
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e
B
o
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rd
Junipero Serra Boulevard
Callan Boulevard
Hickey Boulevard Gellert Bou el va dr
St. Francis Boulevard
Callan Boulevard
Skyline Drive
Westline Drive
1 1
35 35
280
280
VICINITY MAP FIGURE 2.2-2
Base Map: ESRI, ArcGIS
0 250 1,000 1,500 2,500 Feet
Project Site
Residential
Cemetery
Residential
Residential
Residential
& Commercial
School
Medical
Offices
Higate Drive Serramonte Boulevard St. Francis Boulevard Callan Boulevard
Campus Drive
Hickey Boulevard
Gellert Boulevard
Serramonte Boulevard
St. Francis Boulevard
C
allan Boulevard
C
a
m
pus Drive
Hickey Boulevard
G
ellert Boulevard
1 1
35 AERIAL PHOTOGRAPH AND SURROUNDING LAND USES FIGURE 2.2-3 Aerial Source: Google Earth Pro, Apr. 30, 2021. Photo Date: Sep. 2020 0 100 400 600 1,000 Feet
Project Boundary
Callan Blvd.
Campus Dr.
Hickey Blvd.
Higate Dr.
Callan Blvd.
etnomarreS .dvlB
St. Francis Blvd. St. Francis Blvd.
PRECISE PLAN BOUNDARY FIGURE 2.2-4
24 Chapter 3: Development Standards and Guidelines Serramonte Del Rey Precise Plan
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Plan Area Districts
Figure 3.1
PARCEL A
PARCEL D
PARCEL C
PARCEL B
PARCEL F PARCEL E
Parcel lines Commercial Mixed Use District (C-MU) Residential Very High Density (R-VHD) District Campus Drive
Entry Drive
West Drive
East Drive
North Drive
St. Francis Blvd.
Callan Blvd.
Serramonte Blvd.
Plan Area Districts
Figure 3.1
PARCEL A
PARCEL D
PARCEL C
PARCEL B
PARCEL F PARCEL E
Parcel lines Commercial Mixed Use District (C-MU) Residential Very High Density (R-VHD) District Campus Drive
Entry Drive
West Drive
East Drive
North Drive
St. Francis Blvd.
Callan Blvd.
Serramonte Blvd.
PROPOSED PRECISE PLAN PARCELS FIGURE 2.2-5
Serramonte Del Rey Campus Redevelopment 10 Draft EIR
City of Daly City June 2023
2.2.1.1 Serramonte Del Rey Demonstration Garden
There is an approximately 0.5-acre school demonstration garden located in the southwest corner of the Precise Plan area. This garden was started 20 years ago and used by JUHSD for adult education as a demonstration garden. In 2019, the garden was listed as a “community garden” by the County of San Mateo; however, the listing occurred without the knowledge or permission of JUHSD leadership, and therefore the garden was removed from the list. Since the garden is intended for use by JUHSD for educational purposes, JUHSD provides limited access for members of the public and is restricting hours of use during the interim period of campus utilization prior to the start of construction of Parcel B and the demolition of the existing high school building.
The proposed Precise Plan would remove the existing garden and use the space as a construction staging area until Parcel F is fully developed with up to 400 units and 6,000 square feet of retail uses.
JUHSD is providing raised planter beds at their new adult education building located at 123 Edgemont Drive, which was approved by the JUHSD Board on August 17, 2021 (see Figure 2.2-6).
2.2.1.2 Parcel A Development Project
The JUHSD Faculty and Staff Housing project is constructed and occupied on Parcel A of the proposed Precise Plan. The Parcel A development project was approved by the City of Daly City in January 2020 and consists of four-story (48 feet), 122 multi-family units for JUHSD faculty, staff, and their families on an approximately 3.9-acre site (see Figure 2.2-7). While the Parcel A development project was approved under a separate application, the 122 residential units are included in the proposed Precise Plan’s total unit count of 1,235.
2.2.2 Parcel B Development Project
The specific Parcel B development project would be located on the approximately 4.3-acre Parcel B, as shown in Figure 2.2-8. Parcel B is currently developed with surface parking and a one-story temporary education building in the southeast corner of the parcel.
The proposed development would demolish the existing building and surface parking on-site and construct a seven-story (up to 73.5 feet to top of parapet and 85 feet to top of elevator shaft, see Figure 2.2-9), mixed-use building with 201 residential units and approximately 8,000 square feet of retail space. The building would include two levels of parking (one level of below grade parking).
The lower level of the parking garage would provide 212 parking spaces serving the residential units.
An additional 133 parking spaces would be provided on the ground-floor, with 43 reserved for retail customers and leasing and the remainder reserved for residential parking.
2.2.2.1 Site Access and Circulation
Vehicular access to the Parcel B site would be provided via a new driveway and the existing entry drive on Serramonte Boulevard (see Figure 2.2-8). The new driveway would be located east of the existing entry drive and provide direct access to the lower parking level. An entry road would run north-south between Parcels A and B from the existing driveway along Serramonte Boulevard. An entrance to the proposed ground-floor parking (i.e. the upper level of the parking garage) would be located along this new road. A new road serving Parcels A and B would run west-east along the
Serramonte Del Rey Campus Redevelopment 11 Draft EIR
City of Daly City June 2023
southern boundaries of Parcels A and B. A new multi-use pathway would be constructed around the perimeter of the proposed mixed-use building and Parcel B.
In addition to the proposed Parcel B development project’s on-site transportation improvements (i.e., new roads, bike paths, and pedestrian paths), the City of Daly City and applicant are in discussions regarding potential additional transportation improvements that may be included in the project or possibly required as conditions of approval. Potential off-site improvements that the project may be required to construct include the following:
• Bicycle and pedestrian improvements on Campus Drive
• Serramonte Boulevard bicycle and pedestrian improvements • Serramonte Boulevard/Highway 1 Traffic Signal
• Clarinada Avenue/Highway 1 Traffic Signal
• Sidewalk on Callan Boulevard
• Bicycle and pedestrian improvements within the proposed Precise Plan • Improved access pathways to Gellert Park
• Serramonte Pavement Reconstruction
• Stormwater infrastructure
This EIR evaluates the potential implementation of the above improvements to ensure their environmental effects, if any, are disclosed and mitigated, where needed, to inform the City’s decision whether to require some or all of the improvements to be implemented by the project. Any improvements ultimately to be implemented would be attached to the project as conditions of approval.
The development project would signalize the Serramonte Boulevard and project driveway intersection and add pedestrian improvements (i.e., crosswalks, pedestrian signals) to serve the future residents on Parcel B, as well as residents on constructed Parcel A. Intersections at St. Francis Boulevard/Serramonte Boulevard, St. Francis Boulevard/Callan Boulevard, Hickey Boulevard/Callan Boulevard, and Hickey Boulevard/Campus Drive would also be improved with new bike and pedestrian connections. New bike lanes and sidewalks would also be provided on Serramonte Boulevard along the project frontage and throughout the project site. Potential off-site improvements that the project may be required to construct in connection with Parcels C-F will be evaluated when they are identified and at the time the City completes the subsequent or supplemental environmental review pursuant to Guidelines Section 15162.
Source: HKIT Architects, March 4, 2021.
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DISTRICT OFFICE
GROSS BUILDING AREA 39,000 SF
FOOTPRINT 21,300 SF
GROSS BUILDING AREA 30,000 SF
FOOTPRINT 20,000 SF
NEW IMPERVIOUS
AREA
110,000 SF
NEW BUILDING
FOOTPRINT AREA
41,300 SF
SITE TOTAL PARKING:
237 SPACES
26' WIDE FIRE
LANE
AFFECTED TREE
DRIP LINE
EXISTING TREE
DRIP LINE
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1257+
DEMONSTRATION
GARDEN
26’ WIDE FIRE
LANE
NEW IMPERVIOUS
AREA
110,000 SF
NEW BUILDING
FOOTPRINT AREA
41,300 SF
AFFECTED TREE
DRIP LINE
EXISTING TREE
DRIP LINE
JUHSD DISTRICT OFFICE AND ADULT EDUCATION SITE PLAN FIGURE 2.2-6
Source: Seidel Architects, June 14, 2019.
PARCEL A DEVELOPMENT PROJECT SITE PLAN FIGURE 2.2-7
PARCEL B CONCEPTUAL SITE PLAN FIGURE 2.2-8
Source: Seidel Architects, April 21, 2021.
SOUTH ELEVATION (NORTH DRIVE)
WEST ELEVATION (ENTRY DRIVE)
73’-6” TO TOP OF PARAPET
73’-6” TO TOP OF PARAPET
EL. 481.0’
AVG. GRADE ELEVATION
EL. 481.0’
AVG. GRADE ELEVATION
PARCEL B CONCEPTUAL BUILDING ELEVATIONS FIGURE 2.2-9
Serramonte Del Rey Campus Redevelopment 16 Draft EIR
City of Daly City June 2023
2.2.2.2 Open Space and Landscaping
The proposed Parcel B development project would include three components of open space to be used by the public: 1) approximately 22,300 square-foot public park that would include a large grass area and playground; 2) the first phase of the recreational trail (approximately 6,800 square feet) that would be located in the southeast corner of Parcel B; and 3) open space for public use at the retail plaza (approximately 7,000 square feet) facing the new entry road (see Figure 2.2-10). Open space serving the residents of the building would include both the ground floor terrace and the roof terrace, up to 20 private balconies for individual units, and an approximately 20,300 square-foot courtyard located on the roof of the parking deck of the mixed-use building which includes amenities such as a hot tub, fire pit, lounge furniture, and an outdoor kitchen. The open space reserved for residential use plus the retail open space for public use at Parcel B would exceed the City’s requirement for open space of 150 square feet per unit and is consistent with the proposed Precise Plan.
Parcel B currently contains limited landscaping consisting of grasses, shrubs, and trees within the existing surface parking lot and adjacent to the existing education building. Mature trees are located along the perimeter of Parcel B to the north and east. The proposed development would preserve the mature trees along the perimeter of Parcel B and replace the trees that are determined to be in poor condition by a certified arborist. The project proposes to plant 82 new trees throughout the project site.
2.2.2.3 Utility, Drainage, and Off-Site Improvements
The proposed Parcel B development project would connect to existing utilities within Serramonte Boulevard and the Precise Plan area itself. The Parcel B development project would connect to an existing 10-inch sanitary sewer line within Serramonte Boulevard and a 10-inch water line along the southern edge of Parcel B.
Stormwater would be treated on-site with area drains, drop inlets, manholes, bioretention areas, and below-grade pipes, before being discharged to a 24-inch storm drain line in Serramonte Boulevard.
The project would treat stormwater before entering the city’s storm drain system. In addition, an infiltration gallery is proposed to offset an increase in runoff generated from the proposed development.
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(SEE ARCHITECTURE DRAWINGS FOR INDIVIDUAL BALCONY AREAS)
OPEN SPACE SUMMARY
PARCEL B CONCEPTUAL OPEN SPACE PLAN FIGURE 2.2-10
Serramonte Del Rey Campus Redevelopment 18 Draft EIR
City of Daly City June 2023
2.2.2.4 Construction Schedule
Construction of the proposed Parcel B development project is expected to last approximately 24 months. As noted previously, full build out of the entire Precise Plan would take approximately eight-12 years, but could take up to 15 years. The proposed Parcel B development project would result in a net export of approximately 33,220 cubic yards (cy) of soil; however, the development project is proposing to store that soil on-site for use during development of the rest of the Precise Plan (i.e., Parcels C through F).
2.3 PROJECT OBJECTIVES
• Advance an innovative land use master plan to attract investment, stabilize District finances, increase funding for student education and attract and retain highly qualified teachers and staff.
• Permit development consistent with the City’s General Plan that enables redevelopment of underutilized properties with higher-density, transit supportive development that facilitates bicycle and pedestrian access along an established, highly utilized transit corridor, as outlined in the 2020 Walk Bike Daly City Master Plan.
• Create a pedestrian scale neighborhood with an attractive public realm of park and outdoor spaces, inviting to the surrounding community and people of all ages. • Maximize the number of new high-quality market-rate and affordable housing units as a well-designed, economically feasible, urban residential neighborhood with sufficient density to create a safe, active neighborhood, with development phasing subject to market conditions that provides flexibility with the sequence of construction of buildings, open space, streets, and infrastructure.
• Create opportunities to connect people with nature through open space design, a new recreational trail and immediate proximity to wooded hillside areas. • Encourage alternative transportation with safe on- and off-street bike routes and pedestrianoriented urban design that encourages bicycle, pedestrian, and transit access to, from and through the site.
• Design traffic-calmed residential streets for low volume, slow vehicle access between the intersection of Highway 1 and Serramonte Boulevard and the existing Campus Drive south of the Plan Area.
2.4 USES OF THE EIR
This EIR provides decision makers in the City of Daly City, CalTrans (as a responsible agency) and the general public with environmental information to use in considering the proposed project. It is intended that this EIR be used for the discretionary approvals necessary to implement the project, as proposed. These discretionary actions may include, but are not limited to, the following:
City Actions
Precise Plan
• General Plan Amendment
• Planned Development Rezoning and Permit
Serramonte Del Rey Campus Redevelopment 19 Draft EIR
City of Daly City June 2023
• Major Subdivision
• Design Review for future development projects
Parcel B Development Project
• Design Review Permit
Ministerial permits would subsequently be obtained from the City, which could include demolition permits, grading permits, and building permits, in order to complete the projects and construct necessary infrastructure improvements, including any off-site improvements.
Caltrans Actions
• Encroachment Permit
Serramonte Del Rey Campus Redevelopment 20 Draft EIR
City of Daly City June 2023
SECTION 3.0 ENVIRONMENTAL SETTING, IMPACTS, AND
MITIGATION
This section presents the discussion of impacts related to the following environmental subjects in their respective subsections:
3.1 Aesthetics
3.2 Agriculture and Forestry Resources
3.3 Air Quality
3.4 Biological Resources
3.5 Cultural Resources
3.6 Energy
3.7 Geology and Soils
3.8 Greenhouse Gas Emissions
3.9 Hazards and Hazardous Materials
3.10 Hydrology and Water Quality
3.11 Land Use and Planning
3.12 Mineral Resources
3.13 Noise
3.14 Population and Housing
3.15 Public Services
3.16 Recreation
3.17 Transportation
3.18 Tribal Cultural Resources
3.19 Utilities and Service Systems
3.20 Wildfire
The discussion for each environmental subject includes the following subsections:
Environmental Setting – This subsection 1) provides a brief overview of relevant plans, policies, and regulations that compose the regulatory framework for the project and 2) describes the existing, physical environmental conditions at the project site and in the surrounding area, as relevant.
Impact Discussion – This subsection includes the recommended checklist questions from Appendix G of the CEQA Guidelines to assess impacts.
• Project Impacts – This subsection discusses the project’s impact on the environmental subject as related to the checklist questions. For significant impacts, feasible mitigation measures are identified. “Mitigation measures” are measures that will minimize, avoid, or eliminate a significant impact (CEQA Guidelines Section 15370). Each impact is numbered to correspond to the checklist question being answered. For example, Impact BIO-1 answers the first checklist question in the Biological Resources section. Mitigation measures are also numbered to correspond to the impact they address. For example, MM BIO-1.3 refers to the third mitigation measure for the first impact in the Biological Resources section. • Cumulative Impacts – This subsection discusses the project’s cumulative impact on the environmental subject. Cumulative impacts, as defined by CEQA, refer to two or more individual effects, which when combined, compound or increase other environmental impacts. Cumulative impacts may result from individually minor, but collectively significant effects taking place over a period of time. CEQA Guideline Section 15130 states that an EIR should discuss cumulative impacts “when the project’s incremental effect is cumulatively considerable.” The discussion does not need to be in as great detail as is necessary for project impacts, but is to be “guided by the standards of practicality and reasonableness.” The purpose of the cumulative analysis is to allow decision makers to better understand the
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impacts that might result from approval of past, present, and reasonably foreseeable future projects, in conjunction with the proposed project addressed in this EIR.
The CEQA Guidelines advise that a discussion of cumulative impacts should reflect both their severity and the likelihood of their occurrence (CEQA Guidelines Section 15130(b)). To accomplish these two objectives, the analysis should include either a list of past, present, and probable future projects or a summary of projections from an adopted general plan or similar document (CEQA Guidelines Section 15130(b)(1)). This EIR uses the list of projects approach.
The analysis must determine whether the project’s contribution to any cumulatively significant impact is cumulatively considerable, as defined by CEQA Guideline Section 15065(a)(3). The cumulative impacts discussion for each environmental issue accordingly addresses the following issues: 1) would the effects of all of past, present, and probable future (pending) development result in a significant cumulative impact on the resource in question; and, if that cumulative impact is likely to be significant, 2) would the contribution from the proposed project to that significant cumulative impact be cumulatively considerable?
Table 3.0-1 identifies the approved (but not yet constructed or occupied) and pending projects in the project vicinity that are evaluated in the cumulative analysis.
Table 3.0-1: Cumulative Projects List
Name Address Description Status
Serramonte Shopping
Center Expansion –
Northwest Quadrant
3 Serramonte
Center, Daly City
70,000 sq. ft. Cinema, 75,000 sq. ft.
Hotel, 28,000 sq. ft. Retail, 12,000
sq. ft. Restaurants
Approved
Serramonte Shopping
Center Expansion –
Northeast Quadrant
3 Serramonte
Center, Daly City
Two drive-through restaurants (5,100
sq. ft. and 2,100 sq. ft.)
Under
Construction
Seton Medical Center
Expansion
1900 Sullivan
Avenue, Daly
City
Four hospital buildings totaling
433,385 sq. ft. of new hospital space.
Overall net increase of 200,385 sq.
ft. of building space
Under
Construction
Serramonte
Condominiums
525-595
Serramonte
Boulevard, Daly
City
323 total units - 17-story 133-unit
170,164 GSF condo building and
two 13-story 95-unit 181,806 GSF
condo buildings
Approved
Serramonte Hotel
525-595
Serramonte
Boulevard, Daly
City
12-story, 176-room 153,886 GSF
hotel Approved
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For each resource area, cumulative impacts may occur over different geographic areas. For example, the project effects on air quality would combine with the effects of projects in the entire air basin, whereas noise impacts would primarily be localized to the surrounding area.
The geographic area that could be affected by the proposed project varies depending upon the type of environmental issue being considered. Section 15130(b)(3) of the CEQA Guidelines states that lead agencies should define the geographic scope of the area affected by the cumulative effect. Table 3.0-2 provides a summary of the different geographic areas used to evaluate cumulative impacts.
Table 3.0-2: Geographic Considerations in Cumulative Analysis Resource Area Geographic Area
Aesthetics Project site and adjacent parcels
Agriculture and Forestry Resources Countywide
Air Quality San Francisco Bay Area Air Basin
Biological Resources Project site and adjacent parcels
Cultural Resources Project site and adjacent parcels
Energy Energy provider’s territory
Geology and Soils Project site and adjacent parcels
GHGs Planet-wide
Hazards and Hazardous Materials Project site and adjacent parcels Hydrology and Water Quality Colma Creek watershed
Land Use and Planning/Population and Housing Citywide
Minerals Identified mineral recovery or resource area
Noise and Vibration Project site and adjacent parcels
Public Services and Recreation Citywide
Transportation/Traffic Citywide
Tribal Cultural Resources Project site and adjacent parcels Utilities and Service Systems Citywide
Wildfire Within or adjacent to the wildfire hazard zone
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3.1 AESTHETICS
3.1.1 Environmental Setting
3.1.1.1 Regulatory Framework
State
Senate Bill 743
Senate Bill (SB) 743 was adopted in 2013 and, among other changes, SB 743 specifies that aesthetic impacts of qualifying transit oriented developments are not considered significant impacts on the environment if:
1. The project is a residential, mixed-use residential, or employment center project, and
2. The project is located on an infill site within a transit priority area.4 The exemption for aesthetic impacts does not include impacts to historic or cultural resources, however. In addition, local governments retain their ability to regulate a project’s transportation, aesthetics, and parking impacts outside of the CEQA process.
Scenic Highways Program
The California Scenic Highway Program is managed by the California Department of Transportation (Caltrans). The program is intended to protect and enhance the natural scenic beauty of California highways and adjacent corridors through special conservation treatment. State laws governing the Scenic Highway Program are found in the Streets and Highway Code, Sections 260 through 263.
There are three eligible State scenic highways within the City of Daly City, although none are officially designated; Skyline Boulevard (State Route (SR) 35), Cabrillo Highway (SR 1), and Junipero Serra (I-280).
Local
Daly City 2030 General Plan
The City of Daly City General Plan includes a Visual Quality section under the Resources Management Element. General Plan policies and tasks relevant to the project with regards to aesthetics are listed below.
4 An “infill site” is defined as “a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right-ofway from, parcels that are developed with qualified urban uses.” A “transit priority area” is defined as “an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations.” A “major transit stop” means “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” Source: Office of Planning and Research. “Changes to CEQA for Transit Oriented Development – FAQ.” October 14, 2014. Accessed: August 24, 2021. http://www.opr.ca.gov/ceqa/updates/sb-743/transit-oriented.html.
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Policy/Task Description
Task CE-20.7 As a part of all new development, require, where appropriate, the provision of pedestrian-oriented signs, pedestrian-scaled lighting, benches, and other street furniture so as to make non-motorized forms of travel comfortable and attractive alternatives to the automobile. Where necessary in new development, the City may require additional sidewalk and/or right-of-way width to accommodate these amenities.
Policy LU-16 Regulate the size, quantity, and location of signs to maintain and enhance the visual appearance of Daly City.
Policy RME-20 Recognize the physical differences between different parts of the City and regulate land uses within these areas accordingly.
Task RME-20.4 Incorporate design features in new development that reflect the character of the neighborhood, to ensure that new construction is compatible with existing development.
Policy LU-17 Ensure that private development is responsible for providing any on-or off-site improvements related to and/or mitigating the impacts it causes.
3.1.1.2 Existing Conditions
Project Site
The 22-acre project site is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard (see Figure 2.2-3). The northwest corner of the project site (Parcel A) is developed with the Jefferson Union High School District (JUHSD) Faculty and Staff Housing project. The northeast corner of the project site (Parcel B) is currently developed with a surface parking lot and portable building units (see Photo 1). The southwest corner of the project site is developed with the JUHSD demonstration garden (see Photo 2). The remainder of the project site it developed with surface parking lots and a one- to two-story concrete building that serves as the existing JUHSD district office and adult education buildings (see Photo 3). The project site meets the definition of an infill site per SB 743.
Surrounding Visual Character
The project site is surrounded by residential development to the north, northeast, south, and west.
The residences to the north and northeast are two- to three-story apartment buildings made of stucco and wood construction. The residences to the south (Serramonte Ridge Apartment Homes) are threeto four-story apartment buildings also made of stucco and wood construction. The residences to the west are two-story, single-family homes made of wood construction (see Photo 4).
Southeast of the project site is the Summit Shasta High School, which is developed with one- to twostory concrete education buildings (see Photo 4). East of the project site across Callan Boulevard is a Chinese cemetery consisting of mostly open space and gravestones.
Photo 1: View from Serramonte Boulevard looking south.
Photo 2: View of Demonstration Garden looking northwest.
PHOTOS 1 & 2
Photo 3: View of administration building looking north.
Photo 4: View looking south of project site down Campus Drive.
PHOTOS 3 & 4
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Scenic Vistas and Resources
San Bruno Mountain reaches approximately 1,000 feet in elevation and is visible from various locations throughout the City, including the project site, which is about a 2.6 miles southwest of San Bruno Mountain. Views of the coastline are not visible from the project site. The project site is comprised of surface parking lots and commercial buildings and no scenic resources, such as rock outcroppings or historic buildings (refer to Section 4.5 Cultural Resources), are present on the site or in the project area, other than numerous mature trees. The project site is not visible from any state or County designated scenic highways or roadways.
Locations within a Transit Priority Area
The project site is located within a transit priority area as defined in SB 743. The Serramonte Shopping Center bus stop, and the multiple bus lines serving that location, qualifies as a major transit stop and the project site is within one-half mile (see Figure 3.1-1).
3.1.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on aesthetics, except as provided in Public Resources Code Section 21099, would the project:
1) Have a substantial adverse effect on a scenic vista? 2) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
3) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings?5
If the project is in an urbanized area, would the
project conflict with applicable zoning and other regulations governing scenic quality? 4) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
3.1.2.1 Project Impacts
Impact AES-1: The project would not have a substantial adverse effect on a scenic vista. (Less than Significant Impact)
Implementation of the project would result in changes to the built environment; however, the proposed project would consist of mixed-use residential land uses and is located on an infill site within a transit priority area. Pursuant to SB 743 (Public Resources Code section 21099[d][1]) “aesthetic and parking impacts of a residential, mixed-use residential, or employment center on an infill site within a transit priority area shall not be considered significant impacts on the environment;” therefore, the aesthetics impacts of the project are not considered significant. (Less than Significant Impact)
5 Public views are those that are experienced from publicly accessible vantage points.
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3.1.2.2 Cumulative Impacts
Impact AES-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant aesthetics impact. (Less than Significant Cumulative Impact)
Precise Plan and Parcel B Development Project
By statute, the project’s aesthetic impacts, individually and cumulatively, are deemed less than significant, see Impact AES-1 discussion above. (Less than Significant Cumulative Impact)
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3.2 AGRICULTURE AND FORESTRY RESOURCES
3.2.1 Environmental Setting
3.2.1.1 Regulatory Framework
State
Farmland Mapping and Monitoring Program
The California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP) assesses the location, quality, and quantity of agricultural land and conversion of these lands over time. Agricultural land is rated according to soil quality and irrigation status. The best quality land is identified as Prime Farmland. In CEQA analyses, the FMMP classifications and published county maps are used, in part, to identify whether agricultural resources that could be affected are present on-site or in the project area.6
California Land Conservation Act
The California Land Conservation Act (Williamson Act) enables local governments to enter into contracts with private landowners to restrict parcels of land to agricultural or related open space uses.
In return, landowners receive lower property tax assessments. In CEQA analyses, identification of properties that are under a Williamson Act contract is used to also identify sites that may contain agricultural resources or are zoned for agricultural uses.7 Fire and Resource Assessment Program
The California Department of Forestry and Fire Protection (CAL FIRE) identifies forest land, timberland, and lands zoned for timberland production that can (or do) support forestry resources.8 Programs such as CAL FIRE’s Fire and Resource Assessment Program and are used to identify whether forest land, timberland, or timberland production areas that could be affected are located on or adjacent to a project site.9
3.2.1.2 Existing Conditions
The approximately 22-acre project site is not used for agricultural or timberland purposes. A demonstration garden is located in the southwest corner of the project site (see Photo 2); however, this garden is not considered an agricultural resource under CEQA as it does not meet the definition 6 California Department of Conservation. “Farmland Mapping and Monitoring Program.” Accessed December 6, 2021. http://www.conservation.ca.gov/dlrp/fmmp/Pages/Index.aspx. 7 California Department of Conservation. “Williamson Act.” http://www.conservation.ca.gov/dlrp/lca. 8 Forest Land is land that can support 10 percent native tree cover and allows for management of forest resources (California Public Resources Code Section 12220(g)); Timberland is land not owned by the federal government or designated as experimental forest land that is available for, and capable of, growing trees to produce lumber and other products, including Christmas trees (California Public Resources Code Section 4526); and Timberland Production is land used for growing and harvesting timber and compatible uses (Government Code Section 51104(g)).
9 California Department of Forestry and Fire Protection. “Fire and Resource Assessment Program.” Accessed December 6, 2021. http://frap.fire.ca.gov/.
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of agricultural land.10 Surrounding land uses include residences to the north, west, and south, a shopping mall to the northeast, and a cemetery and park to the east. The San Mateo County Important Farmlands 2018 Map designates the project site as “Urban and Built-Up Land”, defined as land with at least six structures per 10 acres. Common examples of “Urban and Built-Up Land” are residential, institutional, industrial, commercial, landfill, golf course, airports, and other utility uses. The site is not under a Williamson Act contract and there are no existing agricultural or forestry resources on or in the vicinity of the site.
The project site is zoned as a Planned Development. A Planned Development district allows various types of development such as neighborhood shopping centers, professional and administrative areas, commercial service centers, industrial parks, single-family, multi-family residential, or a combination of any of the above-mentioned uses.
3.2.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on agriculture and forestry resources, would the project:
1) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? 2) Conflict with existing zoning for agricultural use, or a Williamson Act contract? 3) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
4) Result in a loss of forest land or conversion of forest land to non-forest use? 5) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
3.2.2.1 Project Impacts
Impact AG-1: The project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. (No Impact)
As discussed under Section 3.2.1.2, the project site is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Therefore, the project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use. (No Impact)
10 Agricultural land is means prime farmland, farmland of statewide importance, or unique farmland, as defined by the United States Department of Agriculture land inventory and monitoring criteria, as modified for California (California Public Resources Code Section 21060.1).
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Impact AG-2: The project would not conflict with existing zoning for agricultural use, or a Williamson Act contract. (No Impact)
As discussed under Section 3.2.1.2, the project site is neither zoned for agricultural use or under a Williamson Act contract; therefore, the proposed project would not conflict with zoning for agricultural uses or a Williamson Act contract. (No Impact) Impact AG-3: The project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. (No Impact)
As discussed under Section 3.2.1.2, the project site is not zoned as timberland or forest land. For this reason, the project would have not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. (No Impact) Impact AG-4: The project would not result in a loss of forest land or conversion of forest land to non-forest use. (No Impact)
See response to Impact AG-3. (No Impact)
Impact AG-5: The project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use. (No Impact)
See responses to Impact AG-1 through Impact AG-4. In addition, as discussed above in Section
3.2.1.2 Existing Conditions, the demonstration garden on the project site is not considered an agricultural resource and its removal would not result in a significant impact. The school district, however, is providing a substitute demonstration garden at their new district offices next to Westmoor High School (see Section 2.2.1.1 for more details). (No Impact)
3.2.2.2 Cumulative Impacts
Impact AG-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant agricultural and forestry resources impact. (No Cumulative Impact)
As discussed above, the implementation of the proposed project would not impact agricultural, forestry, and/or timberland; therefore, implementation of the project would not contribute to a cumulative impact to those resources. (No Cumulative Impact)
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3.3 AIR QUALITY
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2022, is attached to this EIR as Appendix C.
3.3.1 Environmental Setting
3.3.1.1 Background Information
Criteria Pollutants
Air quality in the Bay Area is assessed related to six common air pollutants (referred to as criteria pollutants), including ground-level ozone (O3), nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), sulfur oxides (SOx), and lead.11 Criteria pollutants are regulated because they result in health effects. An overview of the sources of criteria pollutants and their associated health effects are summarized in Table 3.3-1. The most commonly regulated criteria pollutants in the Bay Area are discussed further below.
Table 3.3-1: Health Effects of Air Pollutants
Pollutants Sources Primary Effects
Ozone (O3) Atmospheric reaction of organic gases
with nitrogen oxides in sunlight
• Aggravation of respiratory and
cardiovascular diseases
• Irritation of eyes
• Cardiopulmonary function impairment
Nitrogen
Dioxide (NO2)
Motor vehicle exhaust, high
temperature stationary combustion,
atmospheric reactions
• Aggravation of respiratory illness
• Reduced visibility
Fine
Particulate
Matter (PM2.5)
and Coarse
Particulate
Matter (PM10)
Stationary combustion of solid fuels,
construction activities, industrial
processes, atmospheric chemical
reactions
• Reduced lung function, especially in
children
• Aggravation of respiratory and
cardiorespiratory diseases
• Increased cough and chest discomfort
• Reduced visibility
Toxic Air
Contaminants
(TACs)
Cars and trucks, especially dieselfueled; industrial sources, such as chrome platers; dry cleaners and service
stations; building materials and
products
• Cancer
• Chronic eye, lung, or skin irritation
• Neurological and reproductive
disorders
High O3 levels are caused by the cumulative emissions of reactive organic gases (ROG) and NOX.
These precursor pollutants react under certain meteorological conditions to form high O3 levels.
Controlling the emissions of these precursor pollutants is the focus of the Bay Area’s attempts to 11 The area has attained both state and federal ambient air quality standards for CO. The project does not include substantial new emissions of sulfur dioxide or lead. These criteria pollutants are not discussed further.
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reduce O3 levels. The highest O3 levels in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources.
PM is a problematic air pollutant of the Bay Area. PM is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM10) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM2.5). Elevated concentrations of PM10 and PM2.5 are the result of both region-wide emissions and localized emissions.
Toxic Air Contaminants
TACs are a broad class of compounds known to have health effects. They include but are not limited to criteria pollutants. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, diesel fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter [DPM] near a freeway).
Diesel exhaust is the predominant TAC in urban air and is estimated to represent about three-quarters of the cancer risk from TACs. Diesel exhaust is a complex mixture of gases, vapors, and fine particles. Medium- and heavy-duty diesel trucks represent the bulk of DPM emissions from California highways. The majority of DPM is small enough to be inhaled into the lungs. Most inhaled particles are subsequently exhaled, but some deposit on the lung surface or are deposited in the deepest regions of the lungs (most susceptible to injury).12 Chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the California Air Resources Board (CARB).
Sensitive Receptors
Some groups of people are more affected by air pollution than others. CARB has identified the following persons who are most likely to be affected by air pollution: children under 16, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, and elementary schools.
3.3.1.2 Regulatory Framework
Federal and State
Clean Air Act
At the federal level, the United States Environmental Protection Agency (EPA) is responsible for overseeing implementation of the Clean Air Act and its subsequent amendments. The federal Clean Air Act requires the EPA to set national ambient air quality standards for the six common criteria pollutants (discussed previously), including PM, O3, CO, SOx, NOx, and lead. 12 California Air Resources Board. “Overview: Diesel Exhaust and Health.” Accessed December 6, 2021. https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health.
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CARB is the state agency that regulates mobile sources throughout the state and oversees implementation of the state air quality laws and regulations, including the California Clean Air Act.
The EPA and the CARB have adopted ambient air quality standards establishing permissible levels of these pollutants to protect public health and the climate. Violations of ambient air quality standards are based on air pollutant monitoring data and are determined for each air pollutant.
Attainment status for a pollutant means that a given air district meets the standard set by the EPA and/or CARB.
Risk Reduction Plan
To address the issue of diesel emissions in the state, CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. In addition to requiring more stringent emission standards for new on-road and off-road mobile sources and stationary diesel-fueled engines to reduce particulate matter emissions by 90 percent, the plan involves application of emission control strategies to existing diesel vehicles and equipment to reduce DPM (in additional to other pollutants). Implementation of this plan, in conjunction with stringent federal and CARB-adopted emission limits for diesel fueled vehicles and equipment (including off-road equipment), will significantly reduce emissions of DPM and NOX.
Regional
2017 Clean Air Plan
The Bay Area Air Quality Management District (BAAQMD) is the agency primarily responsible for assuring that the federal and state ambient air quality standards are maintained in the San Francisco Bay Area. Regional air quality management districts, such as BAAQMD, must prepare air quality plans specifying how state and federal air quality standards will be met. BAAQMD’s most recently adopted plan is the Bay Area 2017 Clean Air Plan (2017 CAP). The 2017 CAP focuses on two related BAAQMD goals: protecting public health and protecting the climate. To protect public health, the 2017 CAP describes how BAAQMD will continue its progress toward attaining state and federal air quality standards and eliminating health risk disparities from exposure to air pollution among Bay Area communities. To protect the climate, the 2017 CAP includes control measures designed to reduce emissions of methane and other super-greenhouse gases (GHGs) that are potent climate pollutants in the near-term, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.13
CEQA Air Quality Guidelines
The BAAQMD CEQA Air Quality Guidelines are intended to serve as a guide for those who prepare or evaluate air quality impact analyses for projects and plans in the San Francisco Bay Area.
Jurisdictions in the San Francisco Bay Area Air Basin utilize the thresholds and methodology for assessing air quality impacts developed by BAAQMD within their CEQA Air Quality Guidelines.
The guidelines include information on legal requirements, BAAQMD rules, methods of analyzing impacts, and recommended mitigation measures.
13 BAAQMD. Final 2017 Clean Air Plan. April 19, 2017. http://www.baaqmd.gov/plans-and-climate/air-qualityplans/current-plans.
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Local
Daly City 2030 General Plan
The Daly City 2030 General Plan (General Plan) includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to air quality and are applicable to the proposed project.
Policy/Task Description
Policy RME-5 Assess projected air emissions from new development and associated construction and demolition activities in conformance with the BAAQMD CEQA Guidelines, and relative to state and federal standards.
Task RME-5.1 Amend the Planning Division’s development review procedures to include a formal step that would help identify how a development project can incorporate design or functional changes that will minimize air quality impacts.
Task RME-5.3 Consider cumulative air quality impacts consistent with the region's Clean Air Plan and State law.
Task RME-5.4 Require the preparation of a Transportation Systems Management plan for new development that has been determined to contribute to a reduction in location air quality.
Task RME-5.5 Consult with BAAQMD to identify stationary and mobile TAC sources and determine the need for and requirements of a health risk assessment for proposed developments.
Policy RME-6 Minimize exposure of residents to objectionable smoke and odors by proactively regulating potential sources.
Task RME-6.2 Require new residential development projects and projects categorized as sensitive receptors to be located an adequate distance from facilities that are existing and potential sources of odor. An adequate separate distance will be determined based upon the type, size and operations of the facility.
3.3.1.3 Existing Conditions
The project is located in San Mateo County, which is in the San Francisco Bay Area Air Basin. The project area’s proximity to both the Pacific Ocean and the San Francisco Bay has a moderating influence on the climate. The Bay Area is considered a nonattainment area for ground-level O3 and PM2.5 under both the federal Clean Air Act and state Clean Air Act. The area is also considered in nonattainment for PM10 under the state act, but not the federal act. The area has attained both state and federal ambient air quality standards for CO. As part of an effort to attain and maintain ambient air quality standards for O3 and PM10, BAAQMD has established thresholds of significance for these air pollutants and their precursors. These thresholds are for O3 precursor pollutants (ROG and NOX), PM10, and PM2.5, and apply to both construction period and operational period impacts.
The northwest corner of the project site (Parcel A) has been developed with the Jefferson Union High School District (JUHSD) Faculty and Staff Housing project. The northeast corner of the project site (Parcel B) is currently developed with a surface parking lot and portable building units. The southwest corner of the project site is developed with the JUHSD demonstration garden. The remainder of the project site it developed with surface parking lots and a one- to two-story concrete
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building that serves as the existing JUHSD district office and adult education buildings. The nearest sensitive receptors to the project site are single- and multi-family residences adjacent the west and south, across Serramonte Boulevard to the north, and the Summit Shasta High School adjacent to the south.
3.3.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on air quality, would the project:
1) Conflict with or obstruct implementation of the applicable air quality plan? 2) 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?
3) Expose sensitive receptors to substantial pollutant concentrations? 4) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
3.3.2.1 Thresholds of Significance
Impacts from the Project
As discussed in CEQA Guidelines Section 15064(b), the determination of whether a project may have a significant effect on the environment calls for judgment on the part of the lead agency and must be based, to the extent possible, on scientific and factual data. The City of Daly City has considered the air quality thresholds updated by BAAQMD in May 2017 and regards these thresholds to be based on the best information available for the San Francisco Bay Area Air Basin and conservative in terms of the assessment of health effects associated with TACs and PM2.5. The BAAQMD CEQA Air Quality thresholds used in this analysis are identified in Table 3.3-2 below.
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Table 3.3-2: BAAQMD Air Quality Significance Thresholds Pollutant
Construction
Thresholds Operation Thresholds
Average Daily
Emissions
(pounds/day)
Average Daily
Emissions
(pounds/day)
Annual Average
Emissions (tons/year)
Criteria Air Pollutants
ROG, NOx 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
CO Not Applicable 9.0 ppm (eight-hour) or 20.0 ppm (one-hour) Fugitive Dust
Dust Control
Measures/Best
Management Practices
Not Applicable
Health Risks and Hazards for New Sources (within a 1,000-foot Zone of Influence) Health Hazard Single Source Combined Cumulative Sources Excess Cancer Risk 10 per one million 100 per one million Hazard Index 1.0 10.0
Incremental Annual PM2.5 0.3 µg/m3 0.8 μg/m3 (average)
3.3.2.2 Project Impacts
Impact AIR-1: The project would not conflict with or obstruct implementation of the applicable air quality plan. (Less than Significant Impact) The proposed project will not conflict with the latest Clean Air planning efforts since; (1) the project’s operational emissions would be well below the BAAQMD thresholds of significance for air pollutants as discussed below in Impact AIR-2 and development of the project site would be considered urban infill. (Less than Significant Impact) Impact AIR-2: The project would not 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. (Less than Significant Impact with Mitigation Incorporated)
The California Emissions Estimator Model (CalEEMod) Version 2020.4.0 was used to estimate emissions from construction and operation of the project. The project land use types and size, and anticipated construction schedule were input to CalEEMod. The model output from CalEEMod along with construction and operational inputs can be found in Appendix C.
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BAAQMD is the regional agency responsible for overseeing compliance with State and Federal laws, regulations, and programs within the San Francisco Bay Area Air Basin. As previously stated, BAAQMD’s most recently adopted plan is the 2017 CAP. The primary goals of the 2017 CAP are to attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions and protect the climate. The BAAQMD has also developed CEQA guidelines to assist lead agencies in evaluating the significance of air quality impacts. In formulating compliance strategies, BAAQMD relies on planned land uses established by local general plans. Land use planning affects vehicle travel, which in turn affects region-wide emissions of air pollutants and GHGs.
The 2017 CAP includes control measures that are intended to reduce air pollutant emissions in the Bay Area either directly or indirectly. Plans must show consistency with the control measures listed within the 2017 CAP. As shown in Table 3.3-3 below, the proposed project would generally be consistent with the 2017 CAP measures to reduce automobile trips, as well as energy and water use.
Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
Transportation Measures
TR2 - Trip Reduction Programs: Implement the regional
Commuter Benefits Program (Rule 14-1) that requires
employers with 50 or more Bay Area employees to provide commuter benefits. Encourage trip reduction policies and programs in local plans, e.g., general and specific plans while providing grants to support trip reduction efforts. Encourage local governments to require mitigation of vehicle travel as part of new development approval, to adopt transit benefits ordinances in order to reduce transit costs to employees, and to develop innovative ways to encourage rideshare, transit, cycling, and walking for work trips. Fund various employerbased trip reduction programs.
Consistent: The project is required to
implement a Transportation Demand
Management (TDM) program (see
mitigation measure MM TRN-2.1) to
reduce vehicle miles traveled by at
approximately three percent. The
program measures could include, but
are not limited to, carpool incentives,
carshare memberships, additional
last-mile services, and vanpools. The
project sites are also in proximity to
regional transit.
TR8 - Ridesharing, Last-Mile Connection: Promote
carpooling and vanpooling by providing funding to continue regional and local ridesharing programs, and support the expansion of carsharing programs. Provide incentive funding for pilot projects to evaluate the feasibility and costeffectiveness of innovative ridesharing and other last-mile solution trip reduction strategies. Encourage employers to promote ridesharing and carsharing to their employees.
TR9 - Bicycle and Pedestrian Access and Facilities:
Encourage planning for bicycle and pedestrian facilities in local plans, e.g., general and specific plans, fund bike lanes, routes, paths and bicycle parking facilities.
Consistent: As discussed in Section
3.17 Transportation, the existing
bicycle and pedestrian facilities
provide adequate access to the project
site. The project would construct
additional bicycle/pedestrian facilities
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Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
as part of the project and include
bicycle parking facilities on-site.
TR13 - Parking Policies: Encourage parking policies and programs in local plans, e.g., reduce minimum parking
requirements; limit the supply of off-street parking in transitoriented areas; unbundle the price of parking spaces; support implementation of demand-based pricing in high-traffic areas.
Consistent: The project proposes a
lower parking supply than required by
the City’s Municipal Code (see
Section 3.17.3). In addition, as
required by mitigation measure MM
TRN-2.1, the project shall implement
TDM measures to promote
alternatives to single-occupancy
vehicle trips.
Building Measures
BL1 - Green Buildings: Collaborate with partners such as KyotoUSA to identify energy-related improvements and
opportunities for onsite renewable energy systems in school districts; investigate funding strategies to implement upgrades.
Identify barriers to effective local implementation of the California Green Building Standards Code (CALGreen;
Title 24) statewide building energy code; develop solutions to improve implementation/enforcement. Work with ABAG’s
BayREN program to make additional funding available for energy-related projects in the buildings sector. Engage with additional partners to target reducing emissions from specific types of buildings.
Consistent: The project would be
constructed consistent with
CALGreen and Title 24 requirements.
BL2 - Decarbonize Buildings: Explore potential Air District rulemaking options regarding the sale of fossil fuel-based space and water heating systems for both residential and commercial use. Explore incentives for property owners to replace their furnace, water heater or natural-gas powered appliances with zero-carbon alternatives. Update Air District guidance documents to recommend that commercial and
multi-family developments install ground source heat pumps and solar hot water heaters.
Consistent: Electricity is provided to
the site by Peninsula Clean Energy
(PCE). PCE customers are
automatically enrolled in the
ECOplus plan, which generates its
electricity from 100 percent carbonfree sources, with at least 50 percent from renewable sources. Customers
have the option to enroll in the
ECO100 plan, which generates its
electricity from 100 percent carbonfree, renewable sources
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Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
Waste Management Measures
WA4 - Recycling and Waste Reduction: Develop or identify and promote model ordinances on community-wide zero
waste goals and recycling of construction and demolition materials in commercial and public construction projects.
Consistent: The project shall recycle
and/or salvage for reuse a minimum
of 60 percent of nonhazardous
construction and demolition waste,
consistent with Chapter 15.64,
Recycling and Diversion of
Construction and Demolition Debris
of the City’s Municipal Code.
Water Measures
WR2 - Support Water Conservation: Develop a list of best practices that reduce water consumption and increase on-site water recycling in new and existing buildings; incorporate into local planning guidance.
Consistent: The project would be
constructed consistent with
CALGreen and Title 24 requirements,
which require incorporation of water
conservation measures.
As described above in Table 3.3-3, the project would be consistent with the applicable 2017 CAP control measures by reducing project generated trips, including bicycle parking facilities on-site, complying with CALGreen and Title 24, using 100 percent carbon free electricity, and recycling. The project, therefore, would not conflict with or obstruct the implementation of the 2017 CAP.
At the project-level, there are no consistency measures or thresholds. The proposed project would not conflict with the latest Clean Air planning efforts because the project would have operational emissions below the BAAQMD thresholds and would be an urban infill development.
Construction Period Emissions
CalEEMod provided annual emissions for construction including both on-site and off-site construction activities for full buildout of the proposed Precise Plan. Construction emissions were based on land use, construction start dates, and soil hauling information provided by the applicant to then generate CalEEMod default equipment and schedule information for a project of this type and size per phase. On-site activities are primarily made up of construction equipment emissions, while off-site activity includes worker, hauling, and vendor traffic. As noted previously in the Project Description, full build out of the entire Precise Plan would take approximately eight-12 years, but could take up to 15 years. However, for purposes of the air quality analysis, the project construction schedule and equipment usage assume the project would be constructed over a period of six years (1,110 workdays). In disclosing construction air quality impacts, it is more conservative to evaluate a shorter construction period, since compressing the total construction activity into a shorter period of time results in higher daily emissions than if the project were built over a longer period of time, so assuming six years rather than eight to 12 years would overstate the construction emissions. The project’s average daily emissions were computed by dividing the total construction emissions by the number of construction days.
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Table 3.3-4 shows average daily construction emissions of ROG, NOX, PM10 exhaust, and PM2.5 exhaust during construction of the project.
Table 3.3-4: Average Daily Construction Period Emissions - Unmitigated Year ROG (lbs./day) NOX (lbs./day) PM10 (lbs./day) PM2.5 (lbs./day) 2023 (130 workdays) 2.03 18.60 0.92 0.75
2024 (209 workdays) 18.62 15.99 0.79 0.64
2025-2026 (304
workdays) 2.03 16.63 0.80 0.63
2027 (126 workdays) 48.07 12.66 0.65 0.49
2028 (219 workdays) 2.17 16.46 0.87 0.63
2029 (122 workdays) 81.00 13.27 0.74 0.52
BAAQMD
Thresholds (lbs./day) 54 54 82 54
Exceed Threshold? Yes (2029) No No No
As shown in Table 3.3-4 above, the project would generate significant levels of average daily ROG (ROG is primarily emitted from architectural coatings) in 2029 during construction. Additionally, construction activities, particularly during site preparation and grading, would temporarily generate fugitive dust in the form of PM10 and PM2.5. Sources of fugitive dust would include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site would deposit mud on local streets, which could be an additional source of airborne dust after it dries. The BAAQMD CEQA Air Quality Guidelines consider these impacts to be less than significant if best management practices (BMPs) are implemented to reduce these emissions.
Mitigation Measures: The project will be required to implement the following mitigation measures to reduce reactive organic gas (ROG) and fugitive dust generation to a less than significant level:
MM AIR-2.1: BAAQMD Best Management Practices: The project shall implement the Bay Area Air Quality Management District’s (BAAQMD’s) recommended best management practices (BMPs) and additional measures to reduce construction equipment exhaust emissions. These measures shall include the following:
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered three times a day and at a frequency adequate to maintain minimum soil moisture of 12 percent.
Moisture content shall be verified by lab samples or moisture probe. • All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
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• All visible mud or dirt track-out onto adjacent public roads shall be removed using a wet power vacuum street sweeper at least once per day. The use of dry power sweeping shall be prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 mph. • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
• All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
• Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations. • All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph and visible dust extends beyond site boundaries.
• Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of construction adjacent to sensitive receptors. Wind breaks should have at maximum 50 percent air porosity.
• Vegetative ground cover (e.g., fast-germinating native grass seed) shall be planted in disturbed areas as soon as possible and watered appropriately until vegetation is established.
• The simultaneous occurrence of excavation, grading, and ground-disturbing construction activities on the same area at any one time shall be limited.
Activities shall be phased to reduce the amount of disturbed surfaces at any one time.
• Avoid tracking of visible soil material on to public roadways by employing the following measures if necessary: (1) Site accesses to a distance of 100 feet from public paved roads shall be treated with a 6 to 12-inch compacted layer of wood chips, mulch, or gravel and (2) washing truck tires and construction equipment of prior to leaving the site.
• Sandbags or other erosion control measures shall be installed to prevent silt runoff to public roadways from sites with a slope greater than one percent.
MM AIR-2.2: Selection of Construction Equipment: All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. Environmental Protection Agency (EPA) Tier 4 emission standards PM (PM10 and PM2.5), if feasible, otherwise,
• Use equipment that meets U.S. EPA emission standards for Tier 2 or 3 engines and include particulate matter emissions control equivalent to
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California Air Resources Board (CARB) Level 3 verifiable diesel emission control devices that altogether achieve a 50-percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination).
• Use of electrical or non-diesel fueled equipment.
Alternatively, the applicant may develop another construction operations plan demonstrating that the construction equipment used on-site would achieve a reduction in construction diesel particulate matter emissions by 70 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Implementation of Tier 4 or alternatively fueled equipment, • Installation of electric power lines during early construction phases to avoid use of diesel generators and compressors,
• Use of electrically-powered equipment,
• Forklifts and aerial lifts used for exterior and interior building construction shall be electric or propane/natural gas powered,
• Change in construction build-out plans to lengthen phases, and • Implementation of different building techniques that result in less diesel equipment usage.
Such a construction operations plan would be subject to review by an air quality expert and approved by the City prior to construction.
MM AIR-2.3: Low Volatile Organic Compound (VOC) Coating: The project shall use low volatile organic compound or VOC (i.e., ROG) coatings, that are below current BAAQMD requirements (i.e., Regulation 8, Rule 3: Architectural Coatings), for at least 50 percent of all residential and nonresidential interior paints and 50 percent of exterior paints. This includes all architectural coatings applied during both construction and reapplications throughout the project’s operational lifetime.
At least 50 percent of coatings applied must meet a “super-compliant" VOC standard of less than 10 grams of VOC per liter of paint. For reapplication of coatings during the project’s operational lifetime, the Declaration of Covenants, Conditions, and Restrictions shall contain a stipulation for low VOC coatings to be used.
MM AIR-2.1 through MM AIR-2.3 would reduce ROG emissions by 50 percent, to 40.74 lbs./day, resulting in ROG emissions below the BAAQMD threshold. Therefore, with implementation of MMAIR-2.1 through MM-AIR-2.3, project construction would not exceed BAAQMD’s thresholds of significance.
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Operational Period Emissions
Operational period emissions from full buildout of the proposed Precise Plan would be generated primarily from vehicles driven by future residents, employees, customers, and vendors.14 Evaporative emissions from architectural coatings and maintenance products (classified as consumer products) are also typical emissions from these types of uses. The proposed project also would include four 750-kilowatt (kW) diesel-fueled emergency generators. The emergency generators would be tested periodically and would power the proposed buildings in the event of a power failure. For modeling purposes, it was assumed that the generators would be operated primarily for testing and maintenance purposes. CARB and BAAQMD requirements limit these engine operations to 50 hours each per year of non-emergency operation. During testing periods, the engine would typically be run for less than one hour. CalEEMod was used to estimate emissions from operation of the proposed project. As discussed in Section 3.17 Transportation, the proposed project would implement a Transportation Demand Management (TDM) plan to achieve a three percent reduction in vehicle miles traveled (VMT); therefore, mobile emissions were reduced by three percent to reflect the effectiveness of the TDM plan. A summary of the calculated annual operational emissions is provided in Table 3.3-5, below. It was assumed that the earliest year of full project buildout and operation would occur in 2030 (in the event full buildout occurs later in time beyond 2030, emissions would be even lower as fuel efficiency gains would further reduce emissions), and as individual parcels are built and occupied, emissions would remain below the table values presented below.
Table 3.3-5: Unmitigated Operational Period Emissions
Scenario ROG NOX PM10 PM2.5
2022 Existing Emissions 1.02 0.49 0.65 0.17
2030 Project Operational Emissions (tons/year) 10.83 2.94 6.81 1.78 2030 Net Project Operational Emissions (tons/year) 9.81 2.44 6.16 1.60 BAAQMD Thresholds (tons/year) 10 10 15 10
Exceed Threshold? No No No No
2030 Net Project Operational Emissions (lbs./day)1 53.77 13.38 33.76 8.79 BAAQMD Thresholds (lbs./day)1 54 54 82 54
Exceed Threshold? No No No No
1 Assumes 365-day operation
As shown in Table 3.3-5, above, the project would not exceed annual or daily BAAQMD significance thresholds during project operation. (Less than Significant Impact with Mitigation Incorporated)
14 Vehicle trips from the already built Parcel A project were included in the operational analysis to accurately reflect full buildout of the proposed Precise Plan.
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Impact AIR-3: The project would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant Impact with Mitigation Incorporated)
This project would introduce new sources of TACs during construction (i.e., on-site construction activity and truck hauling emissions) and operation (i.e., emergency diesel generators). Sensitive receptors within the project vicinity include residences to the south, west, and north of the project site and the Summit Shasta High School adjacent to the southern boundary of the project site.
Construction Toxic Air Contaminants
Project construction activity would generate dust and equipment exhaust that would affect nearby sensitive receptors. Community risk impacts were addressed by predicting increased cancer risk, the increase in annual PM2.5 concentrations and computing the Hazard Index (HI) for non-cancer health risks. The maximally exposed individual (MEI) for construction cancer risk was determined to be located on the first floor at a multi-family residence across Serramonte Boulevard north of the project site (see Figure 3.3-1). The maximum annual PM2.5 concentration from construction was shown to occur on the first floor at the Summit Shasta High School, adjacent to the southern boundary of the project (as seen in Figure 3.3-1) and was estimated to be 0.29 μg/m3 . Table 3.3-6 summarizes the
community health risk impacts associated with project construction.
Table 3.3-6: Construction Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Project
Construction
Unmitigated 19.28 (infant) 0.15 0.01
Mitigated3 3.33 (infant) 0.05 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold?
Unmitigated Yes No No
Mitigated No No No
Most Affected Student Receptor – Summit Shasta High School Project
Construction
Unmitigated 11.96 (child) 0.29 0.02
Mitigated 2.13 (child) 0.11 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold?
Unmitigated Yes No No
Mitigated3 No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
3. Assumes implementation of mitigation measures MM AIR-2.1 and MM AIR-2.2.
Source: Illingworth & Rodkin, Inc., June 17, 2022.
Legend
Cancer Risk MEI
Off-Site Residential Receptors
Off-Site School Receptors
Project Generators
Project Traffic Area Model
PM2.5 Concentration MEI
1 35
St. Francis Blvd
Serramonte Blvd
Callan Blvd
St. Francis Blvd
Serramonte Blvd
Callan Blvd
Campus Dr Campus Dr
LOCATION OF OFF-SITE RECEPTORS, MEIS, AND PROPOSED EMERGENCY GENERATORS FIGURE 3.3-1
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As shown in Table 3.3-6, unmitigated project construction would exceed the BAAQMD singlesource threshold for cancer risk at the residential and student MEI. However, implementation of MM AIR-2.1 and MM AIR-2.2 would reduce the project’s cancer risk impacts to less than significant levels. Both the unmitigated and mitigated maximum annual PM2.5 concentration and HI value from project construction would not exceed their respective BAAQMD single-source thresholds.
The community health risk impacts summarized in Table 3.3-6 are based on the proposed construction phasing of developing Parcel B first, followed by Parcels C and D, and finally Parcels E and F (see Section 2.2.1 Precise Plan). Any deviations from this phasing could result in different community health risk impacts than analyzed in this EIR. If construction phasing were to change during buildout of the proposed Precise Plan, the project would be required to implement the following mitigation measure.
Mitigation Measures: The project will be required to implement the following mitigation measure if construction phasing changes in order to confirm community health risk impacts are reduced to a less than significant level:
MM AIR-3.1: Prior to the issuance of a grading permit, the applicant shall provide the City with the most recent construction phasing schedule by parcel for buildout of the proposed Precise Plan. If the most recent construction phasing schedule increases the number of units per construction phase compared to the construction phasing assumed in the air quality analysis of this EIR, the applicant shall prepare an updated community health risk assessment to confirm that the new phasing will not result in any new or more significant air quality impacts not previously disclosed in this EIR. The updated community health risk assessment shall be reviewed and approved by the Director of Community Development or Director’s designee.
Operational Toxic Air Contaminants
As previously stated, operation of the full buildout of the Precise Plan would have long-term emissions from the proposed emergency generators and project generated traffic. Figure 3.3-1 shows the proposed locations of the generators throughout the project site. The MEI for project operation was determined to be the same as the construction MEI for cancer risk and PM2.5. CalEEMod was used to calculate the health risk impacts from the emergency generators and CalTrans version of the EMFAC2017 emissions model was used to calculate health risk impacts from project generated traffic. The results are summarized in Table 3.3-7 below.
Table 3.3-7: Operational Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Project Traffic 0.48 (child) 0.10 <0.01
Emergency Generators 1.37 (child) <0.01 <0.01
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Table 3.3-7: Operational Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Unmitigated Project Total 1.85 (child) 0.1 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
Most Affected Student Receptor – Summit Shasta High School Project Traffic 0.26 (child) 0.11 <0.01
Emergency Generators 0.09 (child) <0.01 <0.01
Unmitigated Project Total 0.35 (child) 0.11 0.02
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
As shown in Table 3.3-7, the proposed emergency generators and project generated traffic would not exceed BAAQMD single-source thresholds at the location of the MEI. Additionally, diesel engines are subject to CARB’s Stationary Diesel Airborne Toxics Control Measure and the proposed generator would require permits from the BAAQMD since it would be larger than 50 horsepower. As part of the BAAQMD permit requirements for toxics screening analysis, the engine emissions will have to meet Best Available Control Technology for Toxics and pass the toxic risk screening level of less than ten in a million. The risk assessment would be prepared by the BAAQMD. Depending on results, the BAAQMD would set limits for DPM emissions (e.g., more restrictive engine operation periods). Sources of air pollutant emissions complying with all applicable BAAQMD regulations generally will not be considered to have a significant air quality community risk impact.
Combined Project Toxic Air Contaminants
As shown in Table 3.3-6 and Table 3.3-7 above, unmitigated project construction would exceed the BAAQMD single-source threshold for cancer risk at the residential and student MEI and unmitigated operational emissions would not exceed BAAQMD single-source thresholds. Table 3.3-8 summarizes the mitigated cancer risks, annual PM2.5 concentrations, and HI values associated with construction and operation of the proposed project.
Table 3.3-8: Combined Mitigated Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Construction (Years 0 – 6)3 3.33 (infant) 0.05 <0.01
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Table 3.3-8: Combined Mitigated Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Traffic (Years 3 – 30) 0.48 (child) 0.10 <0.01
Emergency Generators (Years 3 – 30) 1.37 (child) <0.01 <0.01 Mitigated Project Total 5.18 (infant) 0.10 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
Most Affected Student Receptor – Summit Shasta High School Construction (Years 0 – 6) 3 2.13 (child) 0.11 <0.01
Traffic (Years 3 – 9) 0.26 (child) 0.11 <0.01
Emergency Generators (Years 3 – 9) 0.09 (child) <0.01 <0.01 Mitigated Project Total 2.48 (child) 0.11 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
3. Assumes implementation of mitigation measures MM AIR-2.1 and MM AIR-2.2.
As shown in Table 3.3-8, with implementation of MM AIR-2.1 and MM AIR-2.2, cancer risks would be reduced to less than significant levels. Both the unmitigated and mitigated annual PM2.5 concentration and HI value from construction and operation activities would not exceed the singlesource significance thresholds.
In a 2018 decision (Sierra Club v. County of Fresno), the state Supreme Court determined CEQA requires that when a project’s criteria air pollutant emissions would exceed applicable thresholds and contribute a cumulatively considerable contribution to a significant cumulative regional criteria pollutant impact, the potential for the project’s emissions to affect human health in the air basin must be disclosed. State and federal ambient air quality standards are health-based standards, and exceedances of those standards result in continued unhealthy levels of air pollutants. As stated in the 2017 BAAQMD CEQA Air Quality Guidelines, air pollution by its nature is largely a cumulative impact. No single project is sufficient in size, by itself, to result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. In developing thresholds of significance for air pollutants, BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project has a less than significant impact for criteria pollutants, it is assumed to have no adverse health effect. (Less than Significant Impact with Mitigation Incorporated)
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Impact AIR-4: The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. (Less than Significant Impact)
The project would generate localized emissions of diesel exhaust during construction equipment operation and truck activity. These emissions may be noticeable from time to time by adjacent receptors. However, they would be localized and not likely to adversely affect people off-site by resulting in confirmed odor complaints. Occupancy of the residential buildings and the ground floor retail spaces would not generate odors that would result in complaints. There were no identified odor sources that would affect the project in terms of generating frequent odor complaints. (Less Than Significant Impact)
3.3.2.3 Cumulative Impacts
Impact AIR-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant air quality impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
Cumulative Exposure of Sensitive Receptors
Community health risk assessments typically look at all substantial sources of TACs that can affect sensitive receptors that are located within 1,000 feet of the project site (i.e., influence area). These sources include railroads, freeways or highways, busy surface streets, and stationary sources identified by BAAQMD. A review of the project area indicated that State Route (SR) 1, SR 35 (Skyline Boulevard), Callan Boulevard, Hickey Boulevard, and Serramonte Boulevard have an average daily traffic (ADT) over 10,000 vehicles per day. Other nearby streets all have ADT less than 10,000 vehicles and are not considered sources of TACs. Additionally, a review of the BAAQMD’s Permitted Stationary Sources 2018 GIS website map indicates there is one stationary source within the project site’s 1,000-foot influence area. Table 3.3-9 shows the project and cumulative community risk impacts at the off-site MEI. The off-site MEI is the same as those identified under Impact AIR-3 above.
Table 3.3-9: Cumulative Community Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Project3 Unmitigated 21.13 0.29 0.02
Mitigated 5.18 0.11 <0.01
State Route 1 & 35 5.71 0.09 --
Callan Boulevard, ADT 13,950 0.29 0.02 <0.01
Hickey Boulevard, ADT 17,950 0.02 0.01 <0.01
Serramonte Boulevard, ADT 11,565 2.01 0.01 <0.01
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Table 3.3-9: Cumulative Community Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
KNK Petroleum Inc dba Triton Gas
(Facility ID #111517, Gas Station), MEI
at 325 feet
2.61 -- 0.01
Cumulative Total Unmitigated 31.77 0.42 <0.06
Mitigated 15.82 0.24 <0.05
BAAQMD Cumulative-Source
Threshold 100 0.8 10.0
Exceed Threshold? Unmitigated No No No
Mitigated No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure for residential receptors and 9-year exposure for student receptors.
2. Maximum annual concentration for any year.
3. Cancer risk MEI occurred at residential receptor to the north and PM2.5 Concentration MEI occurred at high school receptor to the south.
As shown in Table 3.3-9, the combined effect of all TAC sources in the project area (with implementation of MM AIR-2.1 and MM AIR-2.2) would be less than significant because the cumulative threshold of significance would not be exceeded. Thus, the project would not make a considerable contribution to a cumulative impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
3.3.3 Non-CEQA Effects
Per California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal. 4th 369 (BIA v. BAAQMD), effects of the environment on the project are not considered CEQA impacts. The following discussion is included for informational purposes only because the City of Daly City has policies (Policy RME-5) that address existing air quality conditions affecting a proposed project.
On-site Community Health Risk – New Project Residents
A health risk assessment was completed to analyze the impact of existing and new TAC sources (i.e., emergency diesel generator, project generated traffic) would have on the new proposed sensitive receptors (i.e., residents and daycare) that buildout of the proposed Precise Plan would introduce to the site. New sensitive receptors would be located in the proposed apartment buildings and daycare space. The on-site MEI was determined to be located on the west side of Parcel D. The same TAC sources discussed under Impact AIR-3 were used in this health risk assessment. A summary of this assessment is shown in Table 3.3-10.
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Table 3.3-10: Cumulative Community Risk Impacts at On-Site MEI Source
Cancer Risk
(per million)
PM2.5 Concentration
(μg/m3
)
Hazard
Index
Project Unmitigated 27.31 0.35 0.02
Mitigated 5.21 0.14 0.01
State Route 1 & 35 5.79 0.20 --
Callan Boulevard, ADT 13,950 0.23 0.03 <0.01
Hickey Boulevard, ADT 17,950 0.07 0.01 <0.01
Serramonte Boulevard, ADT 11,565 1.08 0.10 <0.01
KNK Petroleum Inc dba Triton Gas
(Facility ID #111517, Gas Station),
Project Site at 300 feet
3.09 -- 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? Unmitigated Yes Yes No
Mitigated No No No
Cumulative Total Unmitigated 35.57 0.69 <0.06
Mitigated 15.47 0.48 <0.05
BAAQMD Cumulative-Source
Threshold 100 0.8 10.0
Exceed Threshold? Unmitigated No No No
Mitigated No No No
As shown in Table 3.3-10, the project construction sources’ unmitigated cancer risk and PM2.5 concentrations exceed the BAAQMD single-source thresholds, but the project and cumulative sources combined would not exceed the cumulative-source thresholds. With implementation of MM AIR-2.1 and MM AIR-2.2, cancer risk and PM2.5 concentrations affecting future project residents due to project construction would be reduced to below the BAAQMD single-source thresholds, and no additional mitigation is needed to reduce cumulative health risks.
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3.4 BIOLOGICAL RESOURCES
The following discussion is based, in part, on a Biological Resource Assessment (dated October 2021) prepared by Environmental Collective, a Wetland Assessment (dated February 13,2023) prepared by Hanson Bridgett, LLP, and a Biological Peer Review (dated May 2023) prepared by WRA Environmental Consultants. Copies of these reports are attached to this EIR as Appendix D, Appendix E, and Appendix F, respectively.
3.4.1 Environmental Setting
3.4.1.1 Background Information
Sensitive Natural Communities
Sensitive natural communities are natural community types considered to be rare or of a “high inventory priority” by the California Department of Fish and Wildlife (CDFW). Although sensitive natural communities have no legal protective status under the Federal Endangered Species Act (FESA) or California Environmental Species Act (CESA) (refer to Section 3.4.1.2 Regulatory Framework), they are provided some level of consideration under CEQA. Appendix G of the CEQA Guidelines identifies potential impacts on a sensitive natural community as one of six criteria to consider in determining the significance of a proposed project. While no thresholds are established as part of this criterion, it serves as an acknowledgement that sensitive natural communities are an important resource and, depending on their rarity, should be recognized as part of the environmental review process. The level of significance of a project’s impact on any particular sensitive natural community will depend on that natural community’s relative abundance and rarity.
Species of Special Concern
The CDFW maintains an administrative list of Species of Special Concern (SSC), defined as a “species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
• Extirpated from the State, or, in the case of birds, in its primary seasonal or breeding role; • Listed as federally, but not State-, threatened or endangered; • Meets the State definition of threatened or endangered but has not formally been listed; • Experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status;
• Has naturally, small populations exhibiting high susceptibility to risk from any factor(s) that, if realized, could lead to declines that would qualify it for State threatened or endangered status.
The CDFW’s Nongame Wildlife Program is responsible for producing and updating SSC publications for mammals, birds, and reptiles and amphibians. Section 15380 of the CEQA Guidelines clearly indicates that SSC should be included in an analysis of project impacts if they can be shown to meet the criteria of sensitivity outline therein. In contrast to species listed under the federal ESA or CESA, however, SSC have no formal legal status.
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The California Native Plant Society (CNPS) is a non-profit conservation organization dedicated to the preservation of native flora in California. The CNPS has been involved in assembling, evaluating, and distributing information on special-status plant species in the state, as listed in the Inventory of Rare and Endangered Plants of California. CNPS has recently updated their rating system for the rarity of special-status plants, and now include both a California Rare Plant Rank and a Threat Rank.
CEQA requires government agencies to consider environmental impacts of discretionary projects and to avoid or mitigate them where possible. Under Section 15380, CEQA provides protection for both State-listed species and for any other species which can be shown to meet the criteria for State listing. The CDFW recognizes that special-status plants with a California Rare Plant Rank of 1A (Presumed extinct in California), 1B (Rare, threatened, or endangered in California and elsewhere), and 2 (Rare and endangered in California, but are more common elsewhere) in the CNPS Inventory consist of plants that, in a majority of cases, would qualify for listing and these species should be addressed under CEQA review. In addition, the CDFW recommends, and local governments may require, protection of species which are regionally significant, such as locally rare species, disjunct populations, essential nesting and roosting habitat for more common wildlife species, or plants with a CNPS California Rare Plant Rank of 3 (Plant species for which additional data is needed – a review list) and 4 (Plant species of limited distribution – a watch list).
3.4.1.2 Regulatory Framework
Federal and State
Endangered Species Act
Individual plant and animal species listed as rare, threatened, or endangered under federal and state Endangered Species Acts are considered special-status species. Federal and state endangered species legislation has provided the United States Fish and Wildlife Service (USFWS) and the CDFW with a mechanism for conserving and protecting plant and animal species of limited distribution and/or low or declining populations. Permits may be required from both the USFWS and CDFW if activities associated with a proposed project would result in the take of a species listed as threatened or endangered. To “take” a listed species, as defined by the State of California, is “to hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill” these species. Take is more broadly defined by the federal Endangered Species Act to include harm of a listed species.
In addition to species listed under state and federal Endangered Species Acts, Sections 15380(b) and (c) of the CEQA Guidelines provide that all potential rare or sensitive species, or habitats capable of supporting rare species, must be considered as part of the environmental review process. These may include plant species listed by the California Native Plant Society and CDFW-listed Species of Special Concern.
Clean Water Act
The United States Army Corps of Engineers (USACE) is responsible under Section 404 of the Clean Water Act to regulate the discharge of fill material into waters of the U.S. These waters, and their lateral limit, are defined in 33 CFR Part 328.3(a) and include streams that are tributaries to navigable waters and their adjacent wetlands. The lateral limits of jurisdiction for a non-tidal stream are measured at the line of the Ordinary High Water Mark (33 CFR Part 328.3[e]) or the limit of adjacent wetlands (33 CFR Part 328.3[b]). Any permanent extension of the limits of an existing water of the
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U.S., whether natural or man-made, results in a similar extension of Corps jurisdiction (33 CFR Part 328.5).
Waters of the U.S. fall into two broad categories: wetlands and other waters. Other waters include waterbodies and watercourses generally lacking plant cover such as rivers, streams, lakes, springs, ponds, coastal waters, and estuaries. Wetlands are aquatic habitats that support hydrophytic wetland plants and include marshes, wet meadows, seeps, floodplains, basins, and other areas experiencing extended seasonal soil saturation. Seasonally or intermittently inundated features, such as seasonal ponds, ephemeral streams, and tidal marshes, are categorized as wetlands if they have hydric soils and support wetland plant communities. Seasonally inundated waterbodies or watercourses that do not exhibit wetland characteristics are classified as other waters of the U.S.
Waters and wetlands that cannot trace a continuous hydrologic connection to a navigable water of the U.S. are not tributary to waters of the U.S. These are termed “isolated wetlands.” Isolated wetlands are jurisdictional when their destruction or degradation can affect interstate or foreign commerce (33 CFR Part 328.3[a]). The Corps may or may not take jurisdiction over isolated wetlands depending on the specific circumstances.
In general, a project proponent must obtain a Section 404 permit from the Corps before placing fill or grading in wetlands or other waters of the U.S. Prior to issuing the permit, the Corps is required to consult with the USFWS under Section 7 of the ESA if the project may affect federally listed species.
All Corps permits require water quality certification under Section 401 of the Clean Water Act. In the San Francisco Bay Area, this regulatory program is administered by the San Francisco Bay Regional Water Quality Control Board (RWQCB). Project proponents who propose to fill wetlands or other waters of the U.S. must apply for water quality certification from the RWQCB. The RWQCB has adopted a policy requiring mitigation for any loss of wetland, streambed, or other jurisdictional area.
Porter-Cologne Water Quality Control Act
Under this Act (California Water Code Sections 13000–14920), the RWQCB is authorized to regulate the discharge of waste that could affect the quality of the State’s waters. The RWQCB asserts jurisdiction over isolated waters and wetlands, as well as waters and wetlands that are regulated by the Corps. Therefore, even if a project does not require a federal permit, it may still require review and approval by the RWQCB. When reviewing applications, the RWQCB focuses on ensuring that projects do not adversely affect the “beneficial uses” associated with waters of the State. In most cases, the RWQCB seeks to protect these beneficial uses by requiring the integration of waste discharge requirements (WDRs) into projects that will require discharge into waters of the State. For most construction projects, the RWQCB requires the use of construction and postconstruction Best Management Practices (BMPs).
Migratory Bird Treaty Act
The federal Migratory Bird Treaty Act (MBTA) prohibits killing, capture, possession, or trade of migratory birds except in accordance with regulations prescribed by the Secretary of the Interior.
Hunting and poaching are also prohibited. The taking and killing of birds resulting from an activity is
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not prohibited by the MBTA when the underlying purpose of that activity is not to take birds.15 Nesting birds are considered special-status species and are protected by the USFWS. The CDFW also protects migratory and nesting birds under California Fish and Game Code Sections 3503, 3503.5, and 3800. The CDFW defines taking as causing abandonment and/or loss of reproductive efforts through disturbance.
Fish and Game Code
The CDFW is also responsible for enforcing the California Fish and Game Code, which contains several provisions potentially relevant to construction projects. For example, Section 1602 of the Fish and Game Code governs the issuance of Lake and Streambed Alteration Agreements by the CDFW.
Lake or Streambed Alteration Agreements are required whenever project activities substantially divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake designated as such by the CDFW.
The Fish and Game Code also lists animal species designated as Fully Protected or Protected, which may not be taken or possessed at any time. The CDFW does not issue licenses or permits for take of these species except for necessary scientific research, habitat restoration/species recovery actions, or live capture and relocation pursuant to a permit for the protection of livestock. Fully protected species are listed in Sections 3511 (birds), 4700 (mammals), 5050 (reptiles and amphibians), and 5515 (fish) of the Fish and Game Code, while Protected amphibians and reptiles are listed in Chapter 5, Sections 41 and 42.
Several provisions in the California Fish and Game code provide for the protection of birds and bird nests in active use. Unless the Fish and Game Code (FGC) or its implementing regulations provide otherwise, under California law it is unlawful to:
• Take a bird, mammal, fish, reptile, or amphibian (FGC Section2000); • Take, possess, or needlessly destroy the nest or eggs of any bird (FGC Section 3503); • Take, possess, or destroy any bird of prey in the orders Strigiformes (owls) and Falconiformes (such as falcons, hawks and eagles) or the nests or eggs of such bird (FGC Section 3503.5);
• Take or possess any of the thirteen fully protected bird species listed in FGC Section 3511; • Take any non-game bird (i.e., bird that is naturally occurring in California that is not a gamebird, migratory game bird, or fully protected bird) (FGC Section 3800); • Take or possess any migratory non-game bird as designated in the MBTA or any part of such bird, except as provided by rules or regulations adopted by the DOI under the MBTA (FGC Section 3513);
• Take, import, export, possess, purchase, or sell any bird (or products of a bird), listed as an endangered or threatened species under the CESA unless the person or entity possesses an Incidental Take Permit or equivalent authorization from CDFW (FGC Section 2050 et seq.). 15 United States Department of the Interior. “Memorandum M-37050. The Migratory Bird Treaty Act Does Not Prohibit Incidental Take.” Accessed December 6, 2021. https://www.doi.gov/sites/doi.gov/files/uploads/m37050.pdf.
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• Non-native species, including European starling, house sparrow, and rock pigeon, are not afforded any protection under the MBTA or California Fish and Game Code.
Regional
San Bruno Mountain Habitat Conservation Plan
The San Bruno Mountain Habitat Conservation Plan (HCP) was executed as an Agreement in November 1982 with the US Fish and Wildlife Service, California Department of Fish and Game, County of San Mateo, the cities of Brisbane, Daly City and South San Francisco, and several private property owners. The HCP was created to provide for the indefinite perpetuation of the Mission blue butterfly and to protect habitat of the other Species of Concern. It includes the establishment of public ownership of sufficient habitat area to support the species as well as funding for the ongoing maintenance of the habitat. Funding is provided by limited development that was excluded from such habitat area and devoted to urban uses, including, among others, residential, community service, commercial and recreational uses.
Given that the San Bruno Mountain encompasses approximately 3,600 acres, with various ownerships and within various cities, the HCP presents a single unifying and coordinating document to provide protection, enhancement and funding for the entire San Bruno Mountain ecological community. The HCP provides for the perpetuation of conserved habitat areas through eradication of exotic species; re-vegetation with grassland species; effective yearly monitoring of the species of concern to control reintroduction of exotics; and patrol of the area to discourage destructive human activities.
Portions of three of the four HCP planning areas are located within the jurisdiction of Daly City (Saddle, Radio Ridge, and Guadalupe Hills). Within those areas, all designated development has been completed including Point Pacific, Village in the Park, South Hills Estates, Linda Vista, and Bay Ridge. All of this development resulted in a net gain of available habitat either through dedication, easements, or on-site restoration. Furthermore, all of these projects continue to contribute to a trust fund that is used to maintain and monitor the habitat in perpetuity.
The project site is approximately 1.5 miles southwest of the San Bruno HCP boundary.
Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to biological resources and are applicable to the proposed project.
Policy/Task Description
Policy LU-17 Ensure that private development is responsible for providing any on- or off-site improvements related to and/or mitigating the impacts it causes.
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Policy LU-18 Development activities shall not be allowed to significantly disrupt the natural or urban environment and all reasonable measures shall be taken to identify and prevent or mitigate potentially significant effects.
Policy RME-16 The City shall continue to recognize the importance of the San Bruno Mountain HCP, uphold the integrity of the concepts behind the plan, and respect the agreements that serve to implement it.
Municipal Code Chapter 12.40 – Urban Forestry Ordinance The Municipal Code provides regulations to optimize the use of trees and other landscaping within the city. Chapter 12.40 requires plans submitted to the City for the construction, repair, or alteration of any building, housing, or structure to include provisions for sufficient guards or protectors to prevent injury to any existing publicly owned trees, shrubs, flowers, or vines. It also imposes conditions regarding the displacement of public trees, where a comparable size tree shall be planted, or a fee is paid to the City to cover the cost of replacing a removed tree.
3.4.1.3 Existing Conditions
The project site is located within an urbanized area of Daly City and is developed with the JUHSD campus, which is situated on an artificial flat that was created when the sloping property was graded and developed in 1969. The area has been extensively disturbed by past development, with most of the graded portion of project site occupied by buildings and pavement. Trees and landscaping are scattered throughout the area. The slopes located on the western, northern, and eastern portions of the area are occupied by non-native Monterey pine (Pinus radiata) and Monterey cypress (Hesperocyparis macrocarpa) trees, with an understory of non-native grasses and forbs, ivy (Hedera spp.), periwinkle (Vinca major), ice plant (Delosperma sp.), poison oak (Toxicodendron diversilobum), sour grass (Oxalis pes-caprae), and other species. Grassland species consist of annual grasses and forbs such as wild oats (Avena spp.), bromes (Bromus spp.), cut-leaf geranium (Geranium dissectum), bristly ox-tongue (Helminthotheca echioides), and bindweed (Convolvulus arvensis), among others.16
Sensitive Natural Communities
No riparian, native grassland, valley oak woodland, or other sensitive natural communities are present within the project site. As mentioned in Section 2.2.1.1, there is a demonstration garden in the southwest portion of the site. As documented in Appendix D, although native plant species are present in the Demonstration Garden as a result of being planted by gardeners (refer to Figure 3.4-1 and Photo 2), no rare or threatened plant species were found on-site; therefore, the garden does not meet CDFW’s definition of a sensitive natural community with special status under federal and state law (refer to Section 3.4.1.1 Environmental Setting and Section 3.4.1.2 Regulatory Framework). The project site is also occupied by two separate stands of native arroyo willow, including one located on the eastern slopes and another located to the south of the Demonstration Garden (refer to Figure
3.4-1).17
16 A forb is a herbaceous flowering plant. 17 Arroyo willow is considered a Facultative Wetland (FACW) species according to the National Wetland Plant List (NWPL) typically growing in riparian conditions indicative of available surface water. The NWPL is used by the
Service Layer Credits: Golden Gate National Parks Conservancy and San Mateo C
A
L
L
A
N
B
L
V
D
HIG ATE DR
KE
N
T
C
T
ST FRANCIS BLVD
SERRAMONTE B LVD
CAM
PUS
DR
W
M W W
0100
Feet
San
Mateo
County
Area
Enlarged
Jefferson Union High
School District
Parcel A
(65 M 68-69)
APN 091-211-230
Acreage: 22.3 acres
Meadow
Willow Thicket
Conifer Plantings
Existing Structures, Pavement, Ornamental Landscaping
Demostration
Garden
Source: Environmental Collaborative, July 14, 2021.
Project Boundary
Biological Land Cover FIGURE 3.4-1
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Each stand is several hundred square feet in size and surrounded by non-native plantings and impervious surfaces. These stands are not indicative of riparian conditions since there are no natural drainages entering or leaving the willow stand locations, indicating they are likely formed by poor drainage following development of the property or irrigation runoff. This is particularly true for the willow stand located on the steep eastern slopes where water could not concentrate. Additionally, these willow stands are dominated by non-native upland species of grasses and shrubs, and are located in an area extensively disturbed by past development. Based on these facts, both the Biological Resources Assessment and Biological Peer Review (refer to Appendix D and Appendix F, respectively) concurred that these willow stands do not meet the definition of a sensitive natural community.
Special-Status Species
Special-status species are plants and animals that are legally protected under the Federal Endangered Species Act (FESA), California Endangered Species Act (CESA), or other regulations, and species that are considered sufficiently rare by the scientific community to qualify for such listing. For purposes of this analysis, special-status plant species include the following:
• Listed under FESA as threatened, endangered, proposed threatened, proposed endangered, or a candidate species.
• Listed under CESA as threatened, endangered, rare, or a candidate species. • Listed by the CNPS as California Rare Plant Rank (CRPR) 1A, 1B, 2, 3, or 4.
For purposes of this analysis, special-status wildlife species include the following:
• Listed under FESA as threatened, endangered, proposed threatened, proposed endangered, or a candidate species.
• Listed under CESA as threatened, endangered, or a candidate threatened or endangered species.
• Designated by the CDFW as a California species of special concern. • Listed in the California Fish and Game Code as fully protected species (fully protected birds are provided in Section 3511, mammals in Section 4700, reptiles and amphibians in Section 5050, and fish in Section 5515).
Special Status Plants
No special-status plant species were observed on the project site during surveys conducted by Environmental Collective and WRA. None of the special-status plants known to occur in Daly City are mapped within the project site according to the California Natural Diversity Database (CNDDB).
Suitable conditions for special-status plants are not present within the project site due to the extensive grading and development that the area has undergone, which precludes their occurrence within the area. While the Demonstration Garden includes some native plants planted by gardeners, none are classified as special-status.
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Special-Status Wildlife
No special-status wildlife species were observed during the surveys conducted by Environmental Collective and WRA. Most special-status wildlife species known to occur in northern San Mateo County are associated with coastal salt marsh and riparian habitat, which are not present within the Precise Plan area. Due to a lack of larval host plant species or suitable habitat such as serpentine substrate or perennial aquatic habitat, special-status invertebrate species are unlikely to be present within the project site. The range of the western bumble bee, which is not a protected species under federal or state law but is being closely monitored due to declines in numbers and distribution over the past two decades, does not encompass the project site.
Bird nests of migratory bird species are protected under federal and state law (refer to Section 3.4.1.2 Regulatory Framework). No evidence of bird nests was observed during the aforementioned site visits, but suitable nesting habitat exists in the trees located along the project site perimeter.
There are no recorded occurrences of any special-status bat species within the project site and surrounding vicinity. However, trees and man-made building cavities, both of which are present onsite, are commonly used by bats, including the pallid bat (Antrozous pallidus) and Townsend’s western big-eared bat (Corynorhinus townsendii), for roosting.
Jurisdictional Waters
As noted above under Sensitive Natural Communities, arroyo willow is typically found growing in riparian conditions indicative of available surface water, but may occur in non-wetlands. The arroyo willow stands are not connected to a natural drainage and have likely been supported by poor drainage following site development or irrigation runoff. Further, soils present at the willow stands lack redoximorphic features and do not meet the hydric soil criteria used to delineate wetlands.18 Accordingly, both the Biological Resources Assessment and Biological Peer Review (refer to Appendix D and Appendix F, respectively) concurred that the willow stands do not meet the definition of a regulated wetland under federal and state law.
There is an approximately 865 square foot meadow located adjacent to the southwestern willow stand (see Photo 5 and Figure 3.4-1) that consists of facultative grasses including Italian ryegrass (Festuca perennis), bristly ox-tongue (Helminthotheca echioides), velvet grass (Holcus lanatus), annual beard grass (Polypogon monspeliensis), fringed willowherb (Epilobium ciliatum), and common rush (Juncus patens).19 Soils present within this meadow exhibit redoximorphic features, and met hydric soil indicators. The meadow, however, is a result of deferred maintenance on the project site’s drainage system and is not a naturally occurring wetland (see Appendix E and Appendix F); therefore, the meadow would not qualify as a jurisdictional wetland under the Clean Water Act or Porter-Cologne Act or as a sensitive natural community type. 18 Redoximorphic features are color patterns soils that indicate periodic or regular saturation with water. Hydric soil is soil that has formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part of the soil. 19 A facultative species is one that occurs in wetlands and non-wetlands.
Photo 5: View of meadow in southwest corner of the project site.
PHOTO 5
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3.4.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on biological resources, would the project:
1) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or United States Fish and Wildlife Service (USFWS)?
2) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS? 3) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
4) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
5) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
6) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
3.4.2.1 Project Impacts
Impact BIO-1: The project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. (Less than Significant Impact with Mitigation Incorporated)
As discussed in Section 3.4.1.3 Existing Conditions, there are no known occurrences of special-status plants or wildlife within the project site. However, trees and buildings present on-site may provide suitable nesting and roosting habitat for protected and/or special-status birds and bats. The potential impacts of the project on these species are discussed below.
Special-Status Birds
As previously noted, trees located within and along the project site perimeter may provide nesting habitat for migratory birds as well as native nesting birds. If vegetation removal, demolition, and construction activities occur during the nesting season (February 1 through August 31), these activities could result in the destruction or abandonment of an active nest and loss of any eggs or younglings in the nest, which would constitute a significant adverse effect and a violation of the federal Migratory Bird Treaty Act and State Fish and Game code.
Serramonte Del Rey Campus Redevelopment 65 Draft EIR
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Mitigation Measures:
MM BIO-1.1:
• If construction is initiated during the non-breeding season (September 1 to January 31), then vegetation removal, building demolition and other construction may proceed with no restrictions.
• If initial building demolition, vegetation removal, and construction is proposed during the nesting season (February 1 to August 31), a focused survey for nesting raptors and other native birds shall be conducted by a qualified biologist within 14 days prior to the onset of construction in order to determine whether any active nests are present on the site and surrounding area within 250 feet of proposed construction. The survey shall be reconducted any time construction has been delayed or curtailed for more than 14 days during the nesting season.
• If no active nests are identified during the construction survey period, then building demolition, vegetation removal, and other construction may proceed with no restrictions.
• If active bird nests are found, an adequate setback shall be established by a qualified biologist, approved by the City Planning Division, around the nest location and construction activities restricted within this no-disturbance zone until the qualified biologist has confirmed that any young birds have fledged and are able to function outside the nest location. Required setback distances for the no-disturbance zone shall be based on input received from the CDFW and may vary depending on species and sensitivity to disturbance. As necessary, the no-disturbance zone shall be fenced with temporary orange construction fencing if construction is to be initiated elsewhere on the site outside this zone.
• A report of findings shall be prepared by the qualified biologist and submitted to the Director of Community Development or Director’s designee for review and approval prior to initiation of construction during the nesting season (February 1 to August 31). The report shall either confirm absence of any active nests or should confirm that any young are located within a designated no-disturbance zone and construction can proceed. No report of findings is required if construction is initiated during the non-nesting season (September 1 to January 31) and continues uninterrupted according to the above criteria.
With implementation of MM BIO-1.1, the project’s impact to birds nesting on or near the site would be less than significant.
Special-Status Bats
Trees located within and along the perimeter of the project site and cavities in the existing buildings may provide roosting habitat for special-status bats and other designated priority bat species, including the pallid bat and Townsend’s western big-eared bat. Tree trimming/removal and demolition of the existing buildings could displace any roosting bats, if present. Destruction of active
Serramonte Del Rey Campus Redevelopment 66 Draft EIR
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roosts, particularly a maternity roost of a special-status bat species with a high or medium-high priority by the Western Bat Working Group, would constitute a significant adverse effect.
Mitigation Measures:
MM BIO-1.2: Adequate measures shall be taken to avoid roosting by special-status bat species as a result of tree removal and building demolition, specifically:
• To the extent feasible, any tree removal or trimming that is deemed necessary by a certified arborist to maintain tree health shall be conducted outside of the bat maternity season (i.e. generally avoiding tree removal or trimming April through October).
• Building demolition shall, to the extent feasible, be conducted outside of the bat maternity season (i.e. generally avoiding demolition April through October).
• If tree removal, trimming, or building demolition occurs within bat maternity season (i.e. generally April through October), a pre-construction bat roost assessment shall be conducted by a qualified biologist at least 14 days and no more than 30 days prior to tree removal or building demolition to determine if bats roosts are present that may be impacted by project activities. • If special-status bat species or maternity roosts are detected during these surveys, a qualified biologist shall identify any additional measures required to protect the roosts, such as including avoidance of the roosts until the end of the maternity roosting season.
• Regardless of the timing of tree removal or trimming activities, all felled trees or large limbs shall remain on the ground for at least 24-hours prior to chipping, off-site removal, or other processing to allow any roosting individual bats to vacate the premises of their own volition. • A report of findings shall be prepared by the qualified biologist and submitted to the Director of Community Development or Director’s designee for review and approval prior to initiation of construction during the maternity roosting season (April through October). The report shall either confirm absence of any active maternity roosts or specify any additional measures necessary to protect roosts until the end of the maternity roosting season. No report of findings is required if construction is initiated during the non-maternity roosting season (November through March) and continues uninterrupted according to the above criteria.
With implementation of MM BIO-1.2, impacts to individual bats and non-special status individuals and colonies of bats would be avoided during project construction. (Less than Significant Impact with Mitigation Incorporated)
Serramonte Del Rey Campus Redevelopment 67 Draft EIR
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Impact BIO-2: The project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS. (No Impact) As discussed in Section 3.4.1.3 Existing Conditions, no riparian habitat or sensitive natural communities are present within the project site. Therefore, since construction and operation of the proposed project would be constrained to the project site, the project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community. (No Impact) Impact BIO-3: The project would not have a substantial adverse effect on state or federally protected wetlands through direct removal, filling, hydrological interruption, or other means. (No Impact)
Implementation of the project would result in the removal of the arroyo willow stands and meadow discussed in Section 3.4.1.3 Existing Conditions. Both willow stands are surrounded by upland plant species, located on steep slopes, and lack hydric soil conditions; therefore, they do not meet wetland criteria under federal or state wetland definitions. The Biological Resource Assessment (see Appendix D), Biological Peer Review (see Appendix F), and Wetland Assessment (see Appendix E) all agree that the approximately 865 square foot meadow in the southwest corner of the project site appears to contain wetland features; however, the Wetland Assessment documents that the small meadow is not a naturally occurring wetland, is isolated from natural drainages downstream, and is the result of deferred maintenance of the project site’s drainage system. While the Biological Resource Assessment identifies the presence of wetland features, it does not reach a definitive conclusion about the meadow qualifying as a jurisdictional wetland and recommends a formal wetland delineation be performed prior to project implementation to allow the US Army Corp and/or the Regional Water Quality Control Board to determine whether to assert jurisdiction over the meadow as a wetland. The Biological Peer Review, however, agrees with the findings of the Wetland Assessment and concludes that the meadow would not qualify as a jurisdictional wetland under the Clean Water Act or Porter-Cologne Act. Based on the information presented regarding the origin and nature of the meadow, and consistent with the findings of the Biological Peer Review and Wetland Assessment, the City concludes that the meadow is not a formal wetland and, therefore, the removal of the meadow would not constitute a significant impact under CEQA and no mitigation is required to offset its loss. Thus, the project would not have a substantial adverse effect on state or federally protected wetlands. (No Impact)
Serramonte Del Rey Campus Redevelopment 68 Draft EIR
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Impact BIO-4: The project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Less than Significant Impact)
As documented in Section 3.4.1.3 Existing Conditions, the project site is located in an urban area and has been extensively disturbed by past development, and is almost fully developed with buildings and impervious surfaces. No watercourses or other natural features are present that would serve as a movement corridor for migratory fish or wildlife species, or as a native wildlife nursery. The majority of trees and understory grasses, forbs, and other plants located on the perimeter of the project site would be preserved and continue to serve as habitat for local wildlife. Any wildlife present within the vicinity of the project site is already acclimated to human activity, and construction activities would not cause any significant impacts on wildlife movement in the area. For these reasons, the project would not interfere with fish and wildlife movement or in the use of native wildlife nursery sites. (Less than Significant Impact)
Impact BIO-5: The project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Less than Significant Impact)
As discussed under Impact BIO-1, the project would mitigate potential impacts to nesting birds and bats to a less than significant level (consistent with General Plan policies LU-17 and LU-18).
Additionally, the project would not conflict with the San Bruno Mountain Habitat Conservation Plan (refer to the discussion under Impact BIO-6), consistent with General Plan Policy RME-16. The project proposes to replace any trees removed during construction at a 2:1 ratio; however, since the trees are located on private property, the removal of these trees is not regulated by the City of Daly City and the City’s Urban Forestry Ordinance. Off-site improvements (see Section 2.2.2.1 above) related to the project could result in the removal of street trees; however, the project would comply with the City’s Urban Forestry Ordinance by replacing any removed street trees with a similar sized tree or through a fee payment directly to the City. Accordingly, the project would not conflict with any local policies or ordinances protecting biological resources. (Less than Significant Impact) Impact BIO-6: The project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (No Impact) The project site is approximately 1.5 miles southwest of the San Bruno HCP boundary. Therefore, the project would not conflict with the provisions of an adopted HCP. (No Impact)
Serramonte Del Rey Campus Redevelopment 69 Draft EIR
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3.4.2.2 Cumulative Impacts
Impact BIO-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant biological resources impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
The geographic area for cumulative impacts to biological resources includes the project site and its surrounding area because localized development would affect the same group of biological resources.
The only cumulative projects within the vicinity of the project site are the Serramonte Shopping Center Expansion, located at 3 Serramonte Center, and the Serramonte Condominiums and Hotel project, located at 525-595 Serramonte Boulevard, both of which are adjacent to the northeast corner of the project site.
Candidate, Sensitive, or Special Status Species
As discussed under Impact BIO-1, the project would have a less than significant impact on candidate, sensitive, and special-status species with implementation of MM BIO-1.1 and MM BIO-1.2. Similar to the project, trees located at 3 Serramonte Center and 525-595 Serramonte Boulevard and cavities in existing buildings at 3 Serramonte Center may provide nesting and roosting habitat for birds and bats. Both the Serramonte Center Expansion and Serramonte Condominiums and Hotel projects would be subject to the same federal (FESA, MBTA), state (CESA, Fish and Game Code), and local policies and regulations in the City’s General Plan protecting these species of birds and bats, and would be required to implement protective measures as warranted. Further, the project site, 3 Serramonte Center, and 525-595 Serramonte Boulevard are separated by a major intersection and intervening easements, which would reduce the potential for these projects to result in a cumulatively considerable impact to these species. Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact on candidate, sensitive, or specialstatus species. (Less than Significant Cumulative Impact with Mitigation Incorporated) Riparian Habitats or Sensitive Natural Communities
No riparian habitats or sensitive natural communities are present within the project site or adjacent parcels; therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact on riparian habitats or other sensitive natural communities. (Less than Significant Cumulative Impact)
Wetlands
As discussed under Impact BIO-3, the project would have no impact on state or federally protected wetlands. No wetlands are mapped within the cumulative project sites on the U.S. Fish and Wildlife National Wetlands Inventory, and these cumulative projects would be subject to the state and federal regulations protecting wetlands identified in Section 3.4.1.2 Regulatory Framework should any wetlands be discovered during the environmental review process.20 Accordingly, the project would 20 U.S. Fish and Wildlife Service. “National Wetlands Inventory”. Accessed December 22, 2021. https://www.fws.gov/wetlands/data/Mapper.html
Serramonte Del Rey Campus Redevelopment 70 Draft EIR
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not result in a cumulatively considerable contribution to a cumulatively significant impact on state or federally protected wetlands. (Less than Significant Cumulative Impact) Movement, Migration, or Use of Native Wildlife Nursery Sites No watercourses or natural features are present within the project site or adjacent parcels that would serve as a movement corridor for migratory fish or wildlife species, or as a native wildlife nursery.
Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact fish and wildlife movement or in the use of native wildlife nursery sites. (Less than Significant Cumulative Impact)
Policies or Ordinances Protecting Biological Resources
As discussed under Impact BIO-5, the project would be in compliance with policies and ordinances protecting biological resources, specifically those outlined in the City’s General Plan and Municipal Code. The cumulative projects identified in Table 3.0-1 would also be required to comply with these same policies, and therefore the project would not result in a cumulatively considerable contribution to a cumulatively significant conflict with local policies or ordinances protecting biological resources. (Less than Significant Cumulative Impact)
Habitat Conservation Plans
Neither the project site or other cumulative projects are located within an area covered by an adopted HCP, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (No Cumulative Impact)
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3.5 CULTURAL RESOURCES
The following discussion is based, in part, on a Historic Resources Evaluation prepared by Archaeological/Historical Consultants, dated October 2021. A copy of this report is attached to this EIR as Appendix G. The analysis is also based on a Cultural Resources Study prepared for the project by Tom Origer & Associates, dated February 2021. A copy of this report is on file at the City of Daly City Planning Division.
3.5.1 Environmental Setting
3.5.1.1 Regulatory Framework
Federal and State
National Historic Preservation Act
Federal protection is legislated by the National Historic Preservation Act of 1966 (NHPA) and the Archaeological Resource Protection Act of 1979. These laws maintain processes for determination of the effects on historical properties eligible for listing in the National Register of Historic Places (NRHP). Section 106 of the NHPA and related regulations (36 Code of Federal Regulations [CFR] Part 800) constitute the primary federal regulatory framework guiding cultural resources investigations and require consideration of effects on properties that are listed or eligible for listing in the NRHP. Impacts to properties listed in the NRHP must be evaluated under CEQA.
California Register of Historical Resources
The California Register of Historical Resources (CRHR) is administered by the State Office of Historic Preservation and encourages protection of resources of architectural, historical, archeological, and cultural significance. The CRHR identifies historic resources for state and local planning purposes and affords protections under CEQA. Under Public Resources Code Section 5024.1(c), a resource may be eligible for listing in the CRHR if it meets any of the NRHP criteria.21 Historical resources eligible for listing in the CRHR must meet the significance criteria described previously and retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. A resource that has lost its historic character or appearance may still have sufficient integrity for the CRHR if it maintains the potential to yield significant scientific or historical information or specific data.
The concept of integrity is essential to identifying the important physical characteristics of historical resources and, therefore, in evaluating adverse changes to them. Integrity is defined as “the authenticity of a historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource's period of significance.” The processes of determining integrity are similar for both the CRHR and NRHP and use the same seven variables or aspects to define integrity that are used to evaluate a resource's eligibility for listing. These seven characteristics include 1) location, 2) design, 3) setting, 4) materials, 5) workmanship, 6) feeling, and 7) association. 21 California Office of Historic Preservation. “CEQA Guidelines Section 15064.5(a)(3) and California Office of Historic Preservation Technical Assistance Series #6.” Accessed August 31, 2020. http://www.ohp.parks.ca.gov/pages/1069/files/technical%20assistance%20bulletin%206%202011%20update.pdf.
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Senate Bill 18
The intent of SB 18 is to aid in the protection of traditional tribal cultural places through local land use planning by requiring city governments to consult with California Native American tribes on projects which include adoption or amendment of general plans (defined in Government Code Section 65300 et seq.) and specific plans (defined in Government Code Section 65450 et seq.). SB 18 requires local governments to consult with tribes prior to making certain planning decisions and to provide notice to tribes at certain key points in the planning process.
Assembly Bill 52
AB 52, effective July 2015, established a new category of resources for consideration by public agencies called Tribal Cultural Resources (TCRs). AB 52 requires lead agencies to provide notice of projects to tribes that are traditionally and culturally affiliated with the geographic area if they have requested to be notified. Where a project may have a significant impact on a tribal cultural resource, consultation is required until the parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource or until it is concluded that mutual agreement cannot be reached.
Under AB 52, TCRs are defined as follows:
• Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are also either:
o Included or determined to be eligible for inclusion in the California Register of Historic Resources, or
o Included in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).
• A resource determined by the lead agency to be a TCR.
California Native American Historical, Cultural, and Sacred Sites Act The California Native American Historical, Cultural, and Sacred Sites Act applies to both state and private lands. The act requires that upon discovery of human remains, construction or excavation activity must cease and the county coroner be notified.
Public Resources Code Sections 5097 and 5097.98
Section 15064.5 of the CEQA Guidelines specifies procedures to be used in the event of an unexpected discovery of Native American human remains on non-federal land. These procedures are outlined in Public Resources Code Sections 5097 and 5097.98. These codes protect such remains from disturbance, vandalism, and inadvertent destruction, establish procedures to be implemented if Native American skeletal remains are discovered during construction of a project, and establish the Native American Heritage Commission (NAHC) as the authority to resolve disputes regarding disposition of such remains.
Pursuant to Public Resources Code Section 5097.98, in the event of human remains discovery, no further disturbance is allowed until the county coroner has made the necessary findings regarding the origin and disposition of the remains. If the remains are of a Native American, the county coroner must notify the NAHC. The NAHC then notifies those persons most likely to be related to the Native
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American remains. The code section also stipulates the procedures that the descendants may follow for treating or disposing of the remains and associated grave goods.
Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to cultural resources and are applicable to the proposed project.
Policy/Task Description
Policy LU-19.1 Archeological resources should be preserved where possible.
Task LU-19.1 Archeological resources are a valuable educational resource for the residents of the city. Every effort should be made to preserve them in their natural state when found or be excavated by professional archeologists for display in a museum.
Policy RME-19 Undertake measures to protect and preserve historic and archaeological resources.
Task RME-19.1 Comply with State statues related to historical and archaeological resources.
Task RME-19.1 Serve as a leader in historic preservation by preserving, restoring, and reusing City-owned historic resources where feasible.
3.5.1.2 Existing Conditions
Archaeological Resources
The San Francisco Bay Area was historically inhabited by a Native American group known as the “Costanoan” or Ohlone over a period of 5,000 to 8,000 years prior to Spanish exploration and colonization of the region. According to the Northwest Information Center (NWIC), Native American resources in the northern part of San Mateo County have been found in close proximity to sources of water (including perennial and intermittent streams and springs), near the bay margin and its associated wetlands, along the coastal terraces and sheltered valleys, and near ecotones and other productive environments. The tribelet which inhabited the Daly City area lived primarily in two main inland villages located on the Colma and San Bruno Creeks and a seasonal village along the coast at Mussel Rock. At the time of European settlement, the project site was controlled by the Ramaytush linguistic group of the Ohlone/Costanoan people.
The project site is within an urbanized area of Daly City and is developed with the JUHSD campus, which is situated on an artificial flat that was created when the property was developed in 1969. The project site is located at what was once the headwaters of a small drainage that flowed east into Colma Creek. Prior to development of the project site, this drainage would have been the closest source of freshwater for nearby Ohlone/Costanoan people. No archaeological resources have been documented within a half-mile of the project site.
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Historic Resources
The project site is currently developed with the JUHSD campus, which includes a main campus and storage bungalows (constructed in 1969), a General Education Department building (constructed in 1982), two one-story portables (constructed in 1998) and a Comcast relay station (constructed in 2002). Neither the project site or existing buildings are identified as a historic resource in the NRHP or CRHR, or identified as a property with potential historic value in the Daly City General Plan. The Historic Resources Evaluation prepared by Archaeological/Historical Consultants found none of the buildings to be an example of any unique architectural style or the work of a master architect or builder, nor were any structures determined to be associated with any significant person or local event in the area, and therefore the JUHSD campus does not meet the definition of an historic resource under CEQA. There are no documented historic resources within the vicinity of the JUHSD campus.
3.5.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on cultural resources, would the project:
1) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5?
2) Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?
3) Disturb any human remains, including those interred outside of dedicated cemeteries?
3.5.2.1 Project Impacts
Impact CUL-1: The project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. (No Impact)
The existing JUHSD campus is not listed in the National Register of Historic Places or the California Register of Historical Resources, or the local registry of historic resources reflected in the Daly City General Plan. While the main campus and storage bungalows are over 50 years in age, these buildings are of simple utilitarian design constructed with commonplace materials (steel, concrete, wood, tar, gravel) and are not an example of any unique architectural style or the work of a master architect or builder. Further, these buildings are not known to be associated with any significant person or local event in the area. There are no documented historic resources within the vicinity of the JUHSD campus. For these reasons, demolition of the JUHSD campus would not cause a substantial adverse change in the significance of a historical resource. (No Impact)
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Impact CUL-2: The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated) The project site has been previously disturbed and developed with the JUHSD campus as described under Section 3.5.1.2 Existing Conditions. No archaeological resources have been documented within a half-mile of the project site. However, based on the site’s proximity to a historic freshwater source and the historic occupation of Daly City and the project site by the Ohlone/Costanoan people, the Cultural Resources Study identified a moderate sensitivity for subsurface archaeological resources to be encountered during construction-related ground disturbing activities (demolition, grading, excavation, etc.). The project could result in significant impacts to undiscovered subsurface archaeological resources if encountered during construction-related ground disturbing activities.
Mitigation Measures:
MM CUL-2.1: Undiscovered Archaeological Resources. If evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5, including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g., worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation. The City’s Planning Manager shall consult with the archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-than-significant level through data recovery or other methods determined adequate by a qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.
MM CUL-2.2: Report of Archaeological Resources. If archaeological resources are identified, a final report summarizing the discovery of cultural materials shall be submitted to the City’s Planning Manager prior to issuance of certificate of occupancy. This report shall contain a description of the mitigation program that was implemented and its results, including a description of the monitoring and testing program, a list of the resources found and conclusion, and a description of the disposition/curation of the resources.
Implementation of MM CUL-2.1 would ensure that any potentially undiscovered archaeological resources are identified and appropriately treated and protected by a qualified archaeologist in accordance with the Secretary of the Interior’s standards. Mitigation addressing subsurface archaeological resources would be documented and enforced through implementation of MM CUL2.2. Therefore, the project would not cause a substantial adverse change in the significance of an
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archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated)
Impact CUL-3: The project would not disturb any human remains, including those interred outside of dedicated cemeteries. (Less than Significant Impact with Mitigation Incorporated)
Due to the project site’s history of prehistoric residential activities, human remains have the potential to be discovered during construction. If human remains are unearthed during project construction, damage to or destruction of human remains would be a potentially significant impact.
Mitigation Measures:
MM CUL-3.1: Human Remains. If human remains are discovered during project construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section 7050.5 of California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. The project sponsor shall also retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide professional assistance to the Most Likely Descendant, including the excavation and removal of the human remains. The City of Daly City shall be responsible for approval of recommended mitigation as it deems appropriate, taking account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement approved mitigation, to be verified by the City of Daly City, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.
By following the process set forth in MM CUL-3.1, the project would ensure that any human remains encountered during ground-disturbing activities are appropriately identified and treated. (Less than Significant Impact with Mitigation Incorporated)
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3.5.2.2 Cumulative Impacts
Impact CUL-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant cultural resources impact. (Less than Significant Cumulative Impact)
The project would not impact historic resources, and so would not contribute to cumulative impacts to historic resources. With regard to archaeological resources, most development projects in Daly City would require a level of excavation and grading or other activities that may affect archaeological resources, including human remains. Each project is to complete its own literature review, as applicable, to determine the level of archeological and cultural sensitivity of its project site.
However, all projects occurring within Daly City would be required to implement mitigation measures, as applicable, that would avoid impacts and/or reduce them to a less than significant level, consistent with CEQA requirements. Such measures consist of preliminary investigation prior to full excavation, avoidance measures during ground disturbance activities, and/or monitor during ground disturbance activities. Collection and evaluation of finds are also part of these conditions and/or mitigation measures. These projects would also be subject to federal, state, and county laws regulating cultural resources such as protocols of handling human remains, if found on the project site. For these reasons, the proposed project in combination with the cumulative scenario project would not result a significant cultural resources impact. (Less than Significant Cumulative Impact)
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3.6 ENERGY
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2022, is attached to this EIR as Appendix C.
3.6.1 Environmental Setting
3.6.1.1 Regulatory Framework
Federal and State
Energy Star and Fuel Efficiency
At the federal level, energy standards set by the EPA apply to numerous consumer products and appliances (e.g., the EnergyStar™ program). The EPA also sets fuel efficiency standards for automobiles and other modes of transportation.
Renewables Portfolio Standard Program
In 2002, California established its Renewables Portfolio Standard Program, with the goal of increasing the percentage of renewable energy in the state's electricity mix to 20 percent of retail sales by 2010. Governor Schwarzenegger issued Executive Order (EO) S-3-05, requiring statewide emissions reductions to 80 percent below 1990 levels by 2050. In 2008, EO S-14-08 was signed into law, requiring retail sellers of electricity serve 33 percent of their load with renewable energy by 2020. In October 2015, Governor Brown signed SB 350 to codify California’s climate and clean energy goals. A key provision of SB 350 requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from renewable sources by 2030. SB 100, passed in 2018, requires 100 percent of electricity in California to be provided by 100 percent renewable and carbon-free sources by 2045.
Executive Order B-55-18 To Achieve Carbon Neutrality
In September 2018, Governor Brown issued an executive order, EO-B-55-18 To Achieve Carbon Neutrality, setting a statewide goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” The executive order requires CARB to “ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.” EO-B-55-18 supplements EO S-3-05 by requiring not only emissions reductions, but also that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2 from the atmosphere through sequestration.
California Building Standards Code
The Energy Efficiency Standards for Residential and Nonresidential Buildings, as specified in Title 24, Part 6 of the California Code of Regulations (Title 24), was established in 1978 in response to a legislative mandate to reduce California’s energy consumption. Title 24 is updated approximately
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every three years.22 Compliance with Title 24 is mandatory at the time new building permits are issued by city and county governments.23
California Green Building Standards Code
CALGreen establishes mandatory green building standards for buildings in California. CALGreen was developed to reduce GHG emissions from buildings, promote environmentally responsible and healthier places to live and work, reduce energy and water consumption, and respond to state environmental directives. CALGreen covers five categories: planning and design, energy efficiency, water efficiency and conservation, material and resource efficiency, and indoor environmental quality.
Advanced Clean Cars Program
CARB adopted the Advanced Clean Cars program in 2012 in coordination with the EPA and National Highway Traffic Safety Administration. The program combines the control of smogcausing pollutants and GHG emissions into a single coordinated set of requirements for vehicle model years 2015 through 2025. The program promotes development of environmentally superior passenger cars and other vehicles, as well as saving the consumer money through fuel savings.24 Local
City of Daly City General Plan
The City of Daly City’s General Plan includes specific goals and policies to address energy conservation opportunities within the City. All new residential and nonresidential construction in the City must abide by the State of California’s residential building standards for energy efficiency (Title 24 of the California Administrative Code). Title 24 Standards were established in 1978 to ensure that all new construction meets a minimum level of energy efficiency.
Policy/Task Description
Policy HE-23 Gradually increase energy and water efficiency standards for all new and existing housing while minimizing the costs of such standards.
Task HE23.1Develop enhanced residential energy efficiency standards (Title 24, California Administrative Code) in all new residential construction which exceeds Statemandated requirements by five percent in 2015, ten percent in 2020, and twenty percent in 2030.
Task HE23.2Establish energy and water efficiency upgrade programs that promote energy and water efficiency upgrades in all existing residential buildings. Energy efficiency upgrades promoted as part of this program could include upgrades such as attic 22 California Building Standards Commission. “California Building Standards Code.” Accessed December 1, 2021. https://www.dgs.ca.gov/BSC/Codes#@ViewBag.JumpTo. 23 California Energy Commission (CEC). “2019 Building Energy Efficiency Standards.” Accessed December 1, 2021. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2019- building-energy-efficiency. 24 California Air Resources Board. “The Advanced Clean Cars Program.” Accessed December 1, 2021. https://www.arb.ca.gov/msprog/acc/acc.htm.
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Policy/Task Description
insulation, programmable thermostats, heating duct insulation, and water heater insulation. Water efficiency upgrades could include the installation of low-flow shower heads, where feasible, and retrofit of existing toilets to meet low-flush requirements as established by the City. Examples of programs developed as a part of this task could provide financial incentives (e.g., rebates, appliance buy-back, and similar programs) aimed at providing strong incentives to residential building owners to use the programs.
Policy HE-24 Mandate the inclusion of green building techniques into most new construction.
Policy HE-28 Promote alternative sources of energy in all homes.
Daly City’s Green Vision
Daly City’s Green Vision, A Climate Action Plan (CAP) for 2011-2020 and Beyond, was adopted in December 2010. Daly City’s Green Vision guides the City towards a sustainable future that reduces GHG emissions from current levels, while promoting economic prosperity for present and future generations. The Green Vision identifies ten goals and seeks to achieve these goals through costeffective strategies by the year 2020. The GHG reduction goals include adopting a general plan with measurable policies for sustainable development, reducing energy use in buildings, reducing transportation emissions, reducing solid waste disposal, and GHG emissions reductions from municipal operations. Daly City completed an update to the General Plan which incorporated these goals in March 2013.
Daly City Municipal Code
The City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas.25 The City’s Recycling and Diversion of Construction and Demolition ordinance (Municipal Code 15.64) requires that construction and demolition projects recycle or reuse 60 percent of the waste generated from the project. This ordinance is consistent with the requirements for construction and demolition debris diversion in CALGreen. Many of the construction materials, such as concrete, asphalt, asphalt singles, gypsum wallboard, wood and metals, can be reused or recycled, thus prolonging our supply of natural resources and potentially saving money in the process.
3.6.1.2 Existing Conditions
Total energy usage in California was approximately 7,802 trillion British thermal units (Btu) in the year 2019, the most recent year for which this data was available.26 Out of the 50 states, California is ranked second in total energy consumption and 46th in energy consumption per capita. The breakdown by sector was approximately 19 percent (1,456 trillion Btu) for residential uses, 19 percent (1,468 trillion Btu) for commercial uses, 23 percent (1,805 trillion Btu) for industrial uses, 25 City of Daly City. Daly City Municipal Code Ordinance No. 1448. May 10, 2021. 26 United States Energy Information Administration. “State Profile and Energy Estimates, 2019.” Accessed December 1, 2021. https://www.eia.gov/state/?sid=CA#tabs-2.
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and 39 percent (3,073 trillion Btu) for transportation.27 This energy is primarily supplied in the form of natural gas, petroleum, nuclear electric power, and hydroelectric power.
Electricity
Electricity in San Mateo County in 2020 was consumed primarily by the non-residential sector (60 percent), with the residential sector consuming 40 percent. In 2020, a total of approximately 4,167 GWh of electricity was consumed in San Mateo County.28
Peninsula Clean Energy (PCE) is a public and locally controlled electricity provider for the County of San Mateo. Electricity provided by PCE is delivered through PG&E transmission lines.
Commercial and residential customers in San Mateo County are included in the PCE service area and can choose to have 50 to 100 percent of their electricity supplied from carbon-free and renewable sources. Customers are automatically enrolled in the ECOplus plan, which generates its electricity from 100 percent carbon-free sources, with at least 50 percent from renewable sources. Customers have the option to enroll in the ECO100 plan, which generates its electricity from 100 percent carbon-free, renewable sources. 29 The project site currently uses approximately 1.7 GWh of electricity per year.
Natural Gas
PG&E provides natural gas services within the City of Daly City In 2020, approximately two percent of California’s natural gas supply came from in-state production, while the remaining supply was imported from other western states and Canada.30 In 2019 residential and commercial customers in California used 33 percent of the state’s natural gas, power plants used 26 percent, the industrial sector used 35 percent, and other uses used six percent.31 Transportation accounted for one percent of natural gas use in California. In 2019, San Mateo County used approximately nine percent of the state’s total consumption of natural gas.32 The project site currently uses approximately 2,788,100 kBtu of natural gas per year.
Fuel for Motor Vehicles
In 2019 (pre-Covid), 15.4 billion gallons of gasoline were sold in California.33 The average fuel economy for light-duty vehicles (autos, pickups, vans, and sport utility vehicles) in the United States has steadily increased from about 13.1 miles per gallon (mpg) in the mid-1970s to 25.4 mpg in 27 Ibid. 28 California Energy Commission. Energy Consumption Data Management System. “Electricity Consumption by County.” Accessed December 1, 2021. http://ecdms.energy.ca.gov/elecbycounty.aspx. 29 Sources: 1) Peninsula Clean Energy. “Frequently Asked Questions.” Accessed December 1, 2021. https://www.peninsulacleanenergy.com/faq/. 2) Peninsula Clean Energy. “Energy Choices.” Accessed December 1, 2021. https://www.peninsulacleanenergy.com/faq/. 30 California Gas and Electric Utilities. 2020 California Gas Report. Accessed August 2, 2021. https://www.socalgas.com/sites/default/files/2020-
10/2020_California_Gas_Report_Joint_Utility_Biennial_Comprehensive_Filing.pdf. 31 United States Energy Information Administration. “State Profile and Energy Estimates, 2019.” Accessed August 2, 2021. https://www.eia.gov/state/?sid=CA#tabs-2. 32 California Energy Commission. “Natural Gas Consumption by County.” Accessed August 2, 2021. http://ecdms.energy.ca.gov/gasbycounty.aspx. 33 California Department of Tax and Fee Administration. “Net Taxable Gasoline Gallons.” Accessed December 1, 2021. https://www.cdtfa.ca.gov/dataportal/dataset.htm?url=VehicleTaxableFuelDist.
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2020.34 Federal fuel economy standards have changed substantially since the Energy Independence and Security Act was passed in 2007. That standard, which originally mandated a national fuel economy standard of 35 miles per gallon by the year 2020, was updated in March 2020 to require all cars and light duty trucks achieve an overall industry average fuel economy of 40.4 mpg by model year 2026. 35,36 The existing uses vehicles miles traveled (VMT) is estimated to be 1,904,889.37 Assuming a 25.4 mpg, the trips from existing uses require use approximately 75,000 gallons of fuel per year.
3.6.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on energy, would the project:
1) Result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? 2) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
3.6.2.1 Project Impacts
Impact EN-1: The project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. (Less than Significant Impact) Construction
Construction of the project would require energy for the manufacture and transportation of building materials, site preparation and grading, and construction of the proposed Parcel B Development project and future buildout of the proposed Precise Plan. Construction processes are generally designed to be efficient in order to avoid excess monetary costs. That is, equipment and fuel are not typically used wastefully on the site because of the added expense associated with renting the equipment, as well as maintenance and fuel. In addition, as discussed in Section 3.3 Air Quality, the project would implement mitigation measures to minimize the idling of construction equipment thus reducing the potential for energy waste. Further, the project would recycle at least 60 percent of construction and demolition waste. For these reasons, construction of the project would not use energy in a wasteful manner.
Operational
The proposed project would increase the density/intensity of uses on the site and would result in a net increase in energy use. Operation of the project would consume energy for multiple purposes 34 United States Environmental Protection Agency. “The 2021 EPA Automotive Trends Report: Greenhouse Gas Emissions, Fuel Economy, and Technology since 1975.” November 2021. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1010U68.pdf 35 United States Department of Energy. Energy Independence & Security Act of 2007. Accessed December 1, 2021. http://www.afdc.energy.gov/laws/eisa. 36 Public Law 110–140—December 19, 2007. Energy Independence & Security Act of 2007. Accessed December 1, 2021. http://www.gpo.gov/fdsys/pkg/PLAW-110publ140/pdf/PLAW-110publ140.pdf. 37 Illingworth & Rodkin, Inc. Serramonte Del Rey Campus Redevelopment Project Air Quality and Greenhouse Gas Assessment. June 17, 2022.
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including, building heating and cooling, lighting for the proposed buildings and parking garages, and operation of appliances and electronics. Energy would also be consumed during each vehicle trip generated by residents, visitors, and employees. The project’s estimated energy demand is summarized in Table 3.6-1.
Table 3.6-1: Estimated Annual Project Energy Demand
Net Electricity
(GWh)
Net Natural Gas
(kBtu)
Net Gasoline*
(gallons)
Existing 1.70 2,788,100 75,000
Project 7.65 63,840 734,326
Note: *Gasoline demand was calculated by dividing the project’s estimated VMT by 25.4 mpg (Source:
Illingworth & Rodkin, Inc. Serramonte Del Rey Campus Redevelopment Project Air Quality and Greenhouse Gas Assessment. June 17, 2022.)
To ensure that energy is not wasted or unnecessarily consumed, the project would comply with Title 24 and CALGreen energy efficiency measures, as well as City of Daly City Green Vision requirements and Recycling and Diversion of Construction and Demolition Ordinance. These various requirements would reduce project energy demand by ensuring that the project would be built to current energy efficiency standards, include energy efficient appliances, and reduce construction waste disposal trips. As noted above, the City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas. The project is also on an infill site that encourages alternatives to single-vehicle occupancy trips by being proximate to transit and being on a site adequately served by pedestrian and bicycle facilities. For these reasons, operation of the project would not use energy in a wasteful manner. (Less than Significant Impact) Impact EN-2: The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant Impact) According to the 2019 Integrated Energy Policy Report, the state is working towards decarbonizing the energy system and moving towards a 100 percent carbon-free system by 2045.38 The project would obtain energy from the PCE which provides 50 to 100 percent carbon free electricity to the project site. The project would result in an increase in demand on existing energy resources; however, the project is required to comply with applicable regulations and City policies that would conserve energy and water, and reduce fuel consumption and waste generation. For these reasons, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant Impact)
38 California Energy Commission. 2019 Integrated Energy Policy Report. 2019.
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3.6.2.2 Cumulative Impacts
Impact EN-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant energy impact. (Less than Significant Cumulative Impact)
By its nature, energy is a cumulative resource, and demands on energy supplies are cumulative. Past, present, and future development projects contribute to the state’s energy impacts. If the project is determined to have a significant energy impact, it is concluded that the impact is cumulatively considerable. As discussed under Impact EN-1 and Impact EN-2 above, the project itself would not result in significant energy impacts. Further, all projects in Daly City and adjacent cities are required to meet CALGreen and Title 24 energy efficiency requirements, thus lessening overall energy demand. Therefore, the project would not result in a considerable contribution to a significant cumulative energy impact. (Less than Significant Cumulative Impact)
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3.7 GEOLOGY AND SOILS
The following discussion is based, in part, on a Preliminary Geotechnical Investigation Report prepared for the project by Slate Geotechnical Consultants, Inc. A copy of this report, dated April 20, 2021, is attached to this EIR as Appendix H.
3.7.1 Environmental Setting
3.7.1.1 Regulatory Framework
State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act was passed following the 1971 San Fernando earthquake. The act regulates development in California near known active faults due to hazards associated with surface fault ruptures. Alquist-Priolo maps are distributed to affected cities, counties, and state agencies for their use in planning and controlling new construction. Areas within an Alquist-Priolo Earthquake Fault Zone require special studies to evaluate the potential for surface rupture to ensure that no structures intended for human occupancy are constructed across an active fault.
Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (SHMA) was passed in 1990 following the 1989 Loma Prieta earthquake. The SHMA directs the California Geological Survey (CGS) to identify and map areas prone to liquefaction, earthquake-induced landslides, and amplified ground shaking. CGS has completed seismic hazard mapping for the portions of California most susceptible to liquefaction, landslides, and ground shaking, including the central San Francisco Bay Area. The SHMA requires that agencies only approve projects in seismic hazard zones following site-specific geotechnical investigations to determine if the seismic hazard is present and identify measures to reduce earthquake-related hazards.
California Building Standards Code
The CBC prescribes standards for constructing safe buildings. The CBC contains provisions for earthquake safety based on factors including occupancy type, soil and rock profile, ground strength, and distance to seismic sources. The CBC requires that a site-specific geotechnical investigation report be prepared for most development projects to evaluate seismic and geologic conditions such as surface fault ruptures, ground shaking, liquefaction, differential settlement, lateral spreading, expansive soils, and slope stability. The CBC is updated every three years.
California Division of Occupational Safety and Health Regulations Excavation, shoring, and trenching activities during construction are subject to occupational safety standards for stabilization by the California Department of Industrial Relations, Division of Occupational Safety and Health (Cal/OSHA) under Title 8 of the California Code of Regulations and Excavation Rules. These regulations minimize the potential for instability and collapse that could injure construction workers on the site.
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Public Resources Code Section 5097.5
Paleontological resources are the fossilized remains of organisms from prehistoric environments found in geologic strata. They range from mammoth and dinosaur bones to impressions of ancient animals and plants, trace remains, and microfossils. These materials are valued for the information they yield about the history of the earth and its past ecological settings. California Public Resources Code Section 5097.5 specifies that unauthorized removal of a paleontological resource is a misdemeanor. Under the CEQA Guidelines, a project would have a significant impact on paleontological resources if it would disturb or destroy a unique paleontological resource or site or unique geologic feature.
Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to hazards and hazardous materials and are applicable to the proposed project.
Policy Description
Policy SE-1.1 Continue to investigate the potential for seismic and geologic hazards as part of the development review process and maintain this information for the public record.
Update Safety Element maps as appropriate.
Policy SE-1.2 Require site specific geotechnical, soils, and foundation reports for development proposed on sites identified in the Safety Element and its Geologic and Hazard Maps as having moderate or high potential for ground failure.
Policy SE-1.3 Permit development in areas of potential geologic hazards only where it can be demonstrated that the project will not be endangered by, nor contribute to, the hazardous condition on the site or on adjacent properties. All proposed development is subject to the City's Zoning Ordinance and Building Codes.
Policy SE-1.4 Prohibit development—including any land alteration, grading for roads and structural development—in areas of slope instability or other geologic concerns unless mitigation measures are taken to limit potential damage to levels of acceptable risk.
Policy SE-6.1 Regulate building construction practices to prevent hazardous structures and assure structural safety. Measures may include requiring conformance to an accepted set of construction standards, authorizing inspection of suspected dangerous structures, discontinuing improper construction activities, and eliminating hazardous conditions.
Daly City Municipal Code
Title 15 of the Daly City Municipal Code includes Chapter 15.62 “Grading, Erosion, and Sediment Control”, which is intended to provide for safe grading operations, to safeguard public health and property, and to preserve and enhance the natural environment, including, but not limited to, water quality, by regulating site clearing, grading and erosion control on all public and private properties.
Among other conditions, Chapter 15.62 requires projects to prepare an erosion and sediment control
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plan, an engineering geology report, and when requested, a soil/geotechnical engineering report in order to address geological and soils related hazards and engineering issues.
3.7.1.2 Existing Conditions
Regional Geology
The project site and surrounding area is located within the Coast Ranges physiographic province, a series of northwest-trending mountain ranges and valleys that extend along much of the coastal region of California. Geologic mapping indicates that the project site is underlain by the late Pliocene- to early Pleistocene-age Merced Formation, which consists of weak, friable sandstone, siltstone, and claystone, with local fossiliferous beds that are well-cemented.
Seismicity and Seismic Hazards
The entire San Francisco Bay Area is located within the San Andreas Fault Zone, a complex of active faults with the potential to generate earthquakes of magnitude 7.0 or greater. The overall probability of a magnitude 6.7 or greater earthquake on a fault in the greater Bay Area in the next 30 years is estimated at 63 percent. The closest major active fault segments include the San Andreas Fault Peninsula segment, located 0.6 miles southwest of the project site, the Pilarcitos Fault (located 4.5 miles southwest), the San Gregorio Fault North segment (located five miles southwest), and the Point Reyes Fault (located 6.3 miles west).
The project site is not within an Alquist-Priolo Fault Zone.39 Based on hazard maps prepared for the Daly City General Plan, the project site is projected to experience very violent shaking during a seismic event, is at very low risk of liquefaction, and at moderate risk of landsliding.40 Additionally, as the project site is considered to be at very low risk of liquefaction, it is also considered to be at low risk of lateral spreading.41
Soils and Topography
Based on subsurface borings and cone penetration tests completed in 2019 for the project site, underlying soils are a mixture of fill materials and native soil and weathered rock. Fill materials on site consist of variable compositions of sand, clayey sand, and sandy clay ranging in density from medium dense to very dense and consistency from medium stiff to hard. Fill materials are expected to be up to 140 feet in thickness in areas to the west and south of the existing buildings on-site. The native soil and weathered rock encountered consisted of clayey sand and sandy clay ranging in density and consistency from dense to very dense and stiff to hard. Soils tested during subsurface borings had a Plasticity Index (PI) of six.
39 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Date accessed September 22, 2020. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 40 Liquefaction is a temporary loss of shear strength as a result of increased pore pressure due to strong ground shaking or cyclic loading. Liquefaction is defined by saturation of soil and loss of cohesion. It is associated with loose, high-plasticity soils and near-surface groundwater levels. 41 Lateral spreading typically occurs as a form of horizontal displacement of relatively flat-lying soil toward an open or “free” face such as an open body of water, channel, or excavation. This movement is often associated with liquefaction and commonly occurs on gentle slopes in seismically active regions. Lateral spread presents a significant hazard to the integrity of buildings and other structures.
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The project site underwent mass grading during the original development of the site between 1966 and 1969, with significant cut and leveling of a high knoll on the eastern half of the site, and mass excavation of existing ravine walls up to 80 feet deep and hillside cuts along the western boundary of the site. As a result, the project site overall is southeast sloping, with the western portion of the site featuring a 100-foot high moderately sloped hillside cut that descends to the relatively flat existing Serramonte Del Rey campus, which extends east to a 65- to 50-foot high slope that descends to Callan Boulevard.
Groundwater
No groundwater was encountered during the subsurface borings completed in 2019 on the project site, which extended between 29 and 50 feet below ground surface (bgs). For purposes of this EIR, groundwater in the project area vicinity is projected to flow generally south and east towards the San Francisco Bay at a depth of greater than 50 feet bgs.42 Fluctuations in groundwater levels occur due to many factors including seasonal fluctuation, underground drainage patterns, regional fluctuations, and other factors.
Paleontological Resources
The project site is within the Merced Formation of the Franciscan complex, which was formed during the early to late Pliocene age of the Neogene period, and has a high sensitivity for paleontological resources. At a regional level, the project site is within the Pilarcitos stratigraphic area, which has approximately nine historic fossil collection sites, the closest of which is Mussel Rock, approximately one mile west of the project site. Fossils have been discovered elsewhere in Daly City along the coastline and on the shores of Lake Merced, but have not been discovered inland within Daly City.43 As discussed above, the project site underwent mass grading and is underlain by fill, therefore, paleontological resources are unlikely to be found near the ground surface.
3.7.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on geology and soils, would the project:
1) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
- Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (refer to Division of Mines and Geology Special Publication 42)?
- Strong seismic ground shaking?
- Seismic-related ground failure, including liquefaction? - Landslides?
2) Result in substantial soil erosion or the loss of topsoil? 42 Strata Environmental Services, Inc. Phase I Environmental Site Assessment, Serramonte del Rey Campus.
February 2020.
43 Macrostrat. “Macrostrat Geologic Map”. Accessed September 14, 2021. https://macrostrat.org/map/#/z=1.5/x=16/y=23/bedrock/lines/
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3) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
4) Be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property? 5) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? 6) Directly or indirectly destroy a unique paleontological resource or site or unique geological feature?
3.7.2.1 Project Impacts
Impact GEO-1: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic-related ground failure, including liquefaction; or landslides. (Less than Significant Impact)
Fault Rupture
As discussed under Section 3.7.1.2 Existing Conditions, the project site is not within an AlquistPriolo Fault Zone. As the nearest major active fault segment is located 0.6 miles southwest and no known faults intersect the study area, fault rupture is not anticipated to occur within the project site.
As such, the project would not result in any substantial adverse effects associated with fault ruptures.
Seismic Ground Shaking
As discussed under Section 3.7.1.2 Existing Conditions, the project site is located within the seismically active San Andreas Fault Zone. During a seismic event, the project site may experience very violent ground shaking. Consistent with the findings of the Daly City 2030 General Plan Environmental Impact Report (General Plan EIR), compliance with the building codes and construction standards established by the CBC as required by law would be sufficient to protect against building collapse and major injuries during a seismic event.44 The project would comply with current CBC building codes and standards and be constructed in accordance with the recommendations of a site-specific geotechnical investigation (as required by the CBC) and the engineering geology report prepared as required by Chapter 15.62 of the Daly City Municipal Code.
For these reasons, the project would not result in substantial adverse effects associated with seismic ground shaking.
44 City of Daly City. General Plan Update Draft Environmental Impact Report. October 2012. Page 3.5-15.
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Liquefaction and Lateral Spreading
As discussed under Section 3.7.1.2 Existing Conditions, the project site is at a very low risk of liquefaction, and therefore at low risk of lateral spreading. The Geotechnical Investigation concluded that due to presence of stiff clay zones and the depth of groundwater (> 50 feet bgs), the project site was not at risk of liquefaction and associated effects. Further, the project as previously mentioned would comply with current CBC building codes and standards and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report.
As such, the project would not result in substantial adverse effects associated with liquefaction, lateral spreading, and other related phenomenon.
Landslides
As discussed under Section 3.7.1.2 Existing Conditions, the project site is mapped within an area with a moderate landslide risk. However, no landslide areas or landslide deposits have been mapped in the vicinity of the project site, and debris flow probability maps prepared by San Mateo County show that the area has a very low probability (< five percent) for debris flow failures. Based on bedrock type, landslide susceptibility, and lack of observed landslides in the vicinity, the Geotechnical Investigation (refer to Appendix H) concluded that the site-specific potential for seismically-induced landsliding to occur was low, and provided recommendations addressing the western and eastern slopes. As noted above, the project would comply with current CBC building codes and standards, and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report. The General Plan EIR concluded that compliance with aforementioned codes, standards, and reports would reduce adverse effects associated with seismically induced landslides to a less than significant level.45 (Less than Significant Impact)
Impact GEO-2: The project would not result in substantial soil erosion or the loss of topsoil. (Less than Significant Impact)
Construction-related ground disturbing activities (demolition, grading, excavation, etc.) proposed by the project are expected to result in the exposure of soil to wind and water erosion. If managed improperly, construction could result in substantial soil erosion or loss of topsoil.
The City’s National Pollutant Discharge Elimination System (NPDES) Municipal Permit and Chapter 15.62 of the City’s Municipal Code are the City’s primary means of enforcing erosion control measures through the grading and building permit process. Consistent with the findings of the General Plan EIR, compliance with the erosion control provisions included in the NPDES Municipal Permit and the erosion and sediment control plan required by Chapter 15.62 of the Municipal Code would ensure that the project would not result in substantial soil erosion or loss of topsoil.46 (Less than Significant Impact)
45 Ibid. 46 Ibid. Page 3.5-17.
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Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. (Less than Significant Impact)
As discussed under Impact GEO-1, the Geotechnical Investigation (refer to Appendix H) concluded that the project site is not unstable or likely to become unstable during a seismic event. Furthermore, the project would be required by law to comply with current CBC building codes and standards and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report, which would ensure that the project would not exacerbate the risk of ground failure, including liquefaction, lateral spreading, landsliding, and other related phenomenon. As such, the project would not result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. (Less than Significant Impact) Impact GEO-4: The project would not be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property. (Less than Significant Impact)
Pursuant to the CBC, soils with a PI of 15 or less are not considered expansive, therefore the project would not be located on expansive soil. Additionally, as discussed under Impact GEO-1, the geologic foundation of the project site is at a less than substantial risk of ground failure. By conforming with current CBC building codes and standards and the recommendations of the site-specific geotechnical investigation and the engineering geology report, the project would not create direct or indirect risks to life or property. (Less than Significant Impact)
Impact GEO-5: The project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. (No Impact)
The proposed project would dispose of wastewater via lateral connections to the City’s sewer system and would not require the use of septic tanks or alternative wastewater disposal systems. (No Impact)
Impact GEO-6: The project would not directly or indirectly destroy a unique paleontological resource or site or unique geological feature. (Less than Significant Impact with Mitigation Incorporated)
The project site has previously been extensively developed with the JUHSD campus. Additionally, the project site is not on or adjacent to the Pacific coastline or the shores of Lake Merced where fossils have been previously encountered in Daly City, and there is no evidence of paleontological resources (e.g. the presence of rock outcroppings) on the site. As such, there is a low probability of that the project would result in the discovery of subsurface paleontological resources. Nonetheless, construction-related ground disturbing activities could result in significant impacts, if any unknown unique paleontological resource or site or unique geological feature resources were encountered.
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Mitigation Measure: The project will be required to implement the following mitigation measure to reduce potential impacts to paleontological resources to a less than significant level:
MM GEO-6.1: Unique Paleontological and/or Geologic Features and Reporting. Should a unique paleontological resource or site or unique geological feature be identified at the project site during any phase of construction, all ground disturbing activities within 25 feet shall cease and the City’s Planning Director notified immediately.
A qualified paleontologist shall evaluate the find and prescribe mitigation measures to reduce impacts to a less than significant level. Work may proceed on other parts of the project site while mitigation for paleontological resources or geologic features is implemented. Upon completion of the paleontological assessment, a report shall be submitted to the City and, if paleontological materials are recovered, a paleontological repository, such as the University of California Museum of Paleontology.
Implementation of MM GEO-6.1 would ensure that any paleontological resource or unique geological feature encountered during project construction would be identified and subsequently evaluated and protected in accordance with California Public Resources Code Section 5097.5. As such, impacts to unique paleontological resources would be less than significant. (Less than Significant Impact with Mitigation Incorporated)
3.7.2.2 Cumulative Impacts
Impact GEO-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant geology and soils impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
The cumulative projects shown in Table 3.0-1 would be subject to similar geology, soils, and seismicity conditions as the proposed project. All cumulative projects occurring within Daly City would implement standard permit conditions related to geologic hazards and would be constructed consistent with the CBC and site-specific geotechnical investigations in order to avoid impacts from seismicity and geology and soils hazards, and/or reduce them to a less than significant level. Projects in the cumulative scenario would also be subject to similar CEQA requirements and mitigation measures as the proposed project with regard to avoidance and lessening of paleontological impacts.
For these reasons, the cumulative projects, including the proposed project, would not result in significant cumulative geology and soils impacts. (Less than Significant Cumulative Impact with Mitigation Incorporated)
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3.8 GREENHOUSE GAS EMISSIONS
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2021, is attached to this EIR as Appendix C.
3.8.1 Environmental Setting
3.8.1.1 Background Information
Gases that trap heat in the atmosphere, GHGs, regulate the earth’s temperature. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate. In GHG emission inventories, the weight of each gas is multiplied by its global warming potential (GWP) and is measured in units of CO2 equivalents (CO2e). The most common GHGs are carbon dioxide (CO2) and water vapor but there are also several others, most importantly methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These are released into the earth’s atmosphere through a variety of natural processes and human activities.
Sources of GHGs are generally as follows:
• CO2 and N2O are byproducts of fossil fuel combustion. • N2O is associated with agricultural operations such as fertilization of crops. • CH4 is commonly created by off-gassing from agricultural practices (e.g., keeping livestock) and landfill operations.
• Chlorofluorocarbons (CFCs) were widely used as refrigerants, propellants, and cleaning solvents, but their production has been stopped by international treaty. • HFCs are now used as a substitute for CFCs in refrigeration and cooling. • PFCs and SF6 emissions are commonly created by industries such as aluminum production and semiconductor manufacturing.
An expanding body of scientific research supports the theory that global climate change is currently causing changes in weather patterns, average sea level, ocean acidification, chemical reaction rates, and precipitation rates, and that it will increasingly do so in the future. The climate and several naturally occurring resources within California are adversely affected by the global warming trend.
Increased precipitation and sea level rise will increase coastal flooding, saltwater intrusion, and degradation of wetlands. Mass migration and/or loss of plant and animal species could also occur.
Potential effects of global climate change that could adversely affect human health include more extreme heat waves and heat-related stress; an increase in climate-sensitive diseases; more frequent and intense natural disasters such as flooding, hurricanes and drought; and increased levels of air pollution.
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3.8.1.2 Regulatory Framework
State
Assembly Bill 32
Under the California Global Warming Solutions Act, also known as AB 32, CARB established a statewide GHG emissions cap for 2020, adopted mandatory reporting rules for significant sources of GHGs, and adopted a comprehensive plan, known as the Climate Change Scoping Plan, identifying how emission reductions would be achieved from significant GHG sources.
In 2016, SB 32 was signed into law, amending the California Global Warming Solution Act. SB 32, and accompanying Executive Order B-30-15, require CARB to ensure that statewide GHG emissions are reduced to 40 percent below the 1990 level by 2030. CARB updated its Climate Change Scoping Plan in December of 2017 to express the 2030 statewide target in terms of million metric tons of CO2e (MMTCO2e). Based on the emissions reductions directed by SB 32, the annual 2030 statewide target emissions level for California is 260 MMTCO2e.
Senate Bill 375
SB 375, known as the Sustainable Communities Strategy and Climate Protection Act, was signed into law in September 2008. SB 375 builds upon AB 32 by requiring CARB to develop regional GHG reduction targets for automobile and light truck sectors for 2020 and 2035. The per capita GHG emissions reduction targets for passenger vehicles in the San Francisco Bay Area include a seven percent reduction by 2020 and a 15 percent reduction by 2035.
Consistent with the requirements of SB 375, the Metropolitan Transportation Commission (MTC) partnered with the Association of Bay Area Governments (ABAG), BAAQMD, and the Bay Conservation and Development Commission to prepare the region’s Sustainable Communities Strategy (SCS) as part of the Regional Transportation Plan process. The SCS is referred to as Plan Bay Area 2050. Plan Bay Area 2050 establishes a course for reducing per capita GHG emissions through the promotion of compact, high-density, mixed-use neighborhoods near transit, particularly within identified Priority Development Areas (PDAs).
Regional
2017 Clean Air Plan
To protect the climate, the 2017 CAP (prepared by BAAQMD) includes control measures designed to reduce emissions of methane and other super-GHGs that are potent climate pollutants in the nearterm, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.
CEQA Air Quality Guidelines
The BAAQMD’s CEQA Air Quality Guidelines do not use quantified thresholds for projects that are in a jurisdiction with a qualified GHG reductions plan (i.e., a Climate Action Plan). The plan has to address emissions associated with the period that the project would operate (e.g., beyond year 2020).
For quantified emissions, the guidelines recommended a GHG threshold of 1,100 metric tons or 4.6 metric tons (MT) per capita. These thresholds were developed based on meeting the 2020 GHG
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targets set in the scoping plan that addressed AB 32. Development of the project would occur beyond 2020, so a threshold that addresses a future target is appropriate. Although BAAQMD has not published a quantified threshold for 2030 yet, this EIR utilizes an efficiency metric of 2.8 MT CO2e/year/service population and a bright-line threshold of 660 MT CO2e/year based on the GHG reduction goals of EO B-30-15. The service population metric of 2.8 is calculated for 2030 based on the 1990 inventory and the projected 2030 statewide population and employment levels. The 2030 bright-line threshold is a 40 percent reduction of the 2020 1,100 MT CO2e/year threshold.
Local
Daly City General Plan
The Housing Element of the City’s General Plan contains policies, recommendations, and actions to promote energy conservation. Through energy conservation, GHG emissions are reduced. All future development allowed by the project would be subject to conformance with applicable General Plan policies, including the policy listed below.
Policy Description
Policy HE-23 Gradually increase energy and water efficiency standards for all new and existing housing while minimizing the costs of such standards.
Policy HE-24 Mandate the inclusion of green building techniques into most new construction.
Policy HE-28 Promote alternative sources of energy in all homes.
Daly City’s Green Vision
Daly City’s Green Vision, A Climate Action Plan (CAP) for 2011-2020 and Beyond, was adopted in December 2010. Daly City’s Green Vision guides the City towards a sustainable future that reduces GHG emissions from current levels, while promoting economic prosperity for present and future generations. The Green Vision identifies ten goals and seeks to achieve these goals through costeffective strategies by the year 2020. The GHG reduction goals include adopting a general plan with measurable policies for sustainable development, reducing energy use in buildings, reducing transportation emissions, reducing solid waste disposal, and GHG emissions reductions from municipal operations. Daly City completed an update to the General Plan which incorporated these goals in March 2013.
Daly City Municipal Code
The following ordinances consistent with the goals of Daly City’s Green Vision were adopted by the City Council in order to protect the environment and health of the community:
Ordinance 1448: This ordinance requires all new residential buildings to be all electric and use no natural gas.47
47 City of Daly City. Daly City Municipal Code Ordinance No. 1448. May 10, 2021.
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Green Building Standards Code (Municipal Code 15.22): The purpose of the ordinance is to adopt and incorporate the California Green Building Standards Code, 2013 edition, for the protection of the public health and safety of its inhabitants.
Recycling and Diversion of Construction and Demolition (Municipal Code 15.64): This ordinance requires that construction and demolition projects recycle or reuse 60 percent of the waste generated from the project. This ordinance is consistent with the requirements for construction and demolition debris diversion in CALGreen. Many of the construction materials, such as concrete, asphalt, asphalt singles, gypsum wallboard, wood and metals, can be reused or recycled, thus prolonging our supply of natural resources and potentially saving money in the process.
3.8.1.3 Existing Conditions
GHG emissions are generated from vehicles entering and leaving the site and from heating, cooling, and lighting of the existing buildings, as well as water used by current site users and wastewater generated on-site. The project site currently generates approximately 1,093 MT of CO2e annually.
For the purposes of this analysis, the Parcel A development project is assumed to be not built/occupied; therefore, it is not included in existing conditions. Parcel A is included as part of the operational emissions for the proposed project.
3.8.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on greenhouse gas emissions, would the project:
1) Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
2) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs?
3.8.2.1 Project Impacts
Impact GHG-1: The project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant Impact)
GHG emissions associated with the project would occur over the short-term from construction activities, as well as operational emissions over the long term (associated with vehicular traffic within the project vicinity, the generator, energy and water usage, wastewater, and solid waste disposal). GHG emissions for the proposed project were analyzed using the methodology recommended in the BAAQMD CEQA Air Quality Guidelines. CalEEMod was used to predict GHG emissions from the project (as detailed in Appendix C).
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Construction Emissions
GHG emissions associated with construction of Parcel B-F, based on construction data provided by the project applicant, were computed by CalEEMod to be 3,101 MT of CO2e. These are the emissions from on-site operation of construction equipment, vendor and hauling truck trips, and worker trips. Neither the City nor BAAQMD have an adopted threshold of significance for construction-related GHG emissions, though BAAQMD recommends quantifying emissions and disclosing that GHG emissions would occur during construction. For these reasons, any impact would be less than significant.
Operational Emissions
Project operation would generate GHGs primarily through electricity generation/use and generation of vehicle trips. At full buildout and occupancy of the Precise Plan Parcels A-F, net operational GHG emissions from the project are estimated to be 5,585 MT of CO2e for 2030, which exceeds the 2030 BAAQMD threshold of 660 MT/year of CO2e (see Table 3.8-1). Land use projects with emissions above the 660 MT/year threshold are then subject to the GHG efficiency threshold of 2.8 MT per year per capita (MT/year/capita) to determine impact significance. For purposes of calculating per service population emissions, gross project GHG emissions are used, rather than the net GHGs used for establishing ‘brightline’ emissions. The project service population efficiency rate is based on the number of future residents. For this project, the number of future residents was estimated by multiplying the total number of units (i.e., 1,235 units) by the persons per household rate for the City of Daly City found in the California Department of Finance Population and Housing Estimate report.48 Using the 3.33-person per household 2020 rate, the number of future residents was estimated to be 4,113 residents.
Table 3.8-1: Annual GHG Emissions (CO2e) in Metric Tons Source Category Existing Conditions
in 2022
Proposed Project
in 2030
Area 0 15
Energy Consumption 311 3
Mobile 684 6,315
Solid Waste Generation 55 295
Water Usage 43 50
Total 1,093 6,678
Net Emissions 5,585
Significance Threshold 660
Per Service Population Emissions
(MT of CO2e/year/service population)
1.62 Significance Threshold 2.8
48 State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark. Sacramento, California. Accessed May 5, 2022. https://dof.ca.gov/forecasting/demographics/estimates/estimates-e5-2010-2021/.
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Table 3.8-1: Annual GHG Emissions (CO2e) in Metric Tons Source Category Existing Conditions
in 2022
Proposed Project
in 2030
(MT of CO2e/year/service population)
Threshold Exceeded? No
As shown in Table 3.8-1, the proposed project would not exceed the per capita 2030 threshold of 2.8 MT of CO2e/year/service population; therefore, the project would meet the GHG reduction target set by SB 32 and not result in a significant GHG emissions impact. (Less than Significant Impact) Impact GHG-2: The project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. (Less than Significant Impact)
2017 Climate Action Plan
As discussed in Section 3.3 Air Quality, the project is consistent with the 2017 CAP because it supports the primary goals of the 2017 CAP (by providing increased density in a transit priority area) and does not exceed thresholds for greenhouse gas emissions (see Table 3.8-1 above).
Daly City General Plan
The project would be consistent with the City’s General Plan policies [specifically Policy HE-23 of increasing energy efficiency standards in new and existing housing developments], Green Vision, and Green Building Ordinance because the project proposes to be constructed in compliance with the current California Green Building Standards Code (Title 24), which requires efficient windows, insulation, lighting, ventilation systems, and other features that reduce water and energy consumption. As noted previously, the City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas, which would further reduce GHG emissions.
The project would comply with the requirements of the Green Building Ordinance and the Title 24 Building Code, which requires proposed buildings to be constructed with various measures that would reduce GHG emissions from the project. For this reason, the project would be consistent with the City’s General Plan, Green Vision, and Green Building Ordinance. (Less Than Significant Impact)
3.8.2.2 Cumulative Impacts
Impact GHG-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant GHG emissions impact. (Less than Significant Cumulative Impact)
GHG emissions have a broader, global impact; therefore, if a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable. As discussed in Impact
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GHG-1, the project would not result in significant GHG impacts by the year 2030 and would meet the GHG reduction target set by SB 32. Therefore, the project would not have a cumulatively considerable contribution to a significant cumulative GHG emissions impact. (Less than Significant Cumulative Impact)
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3.9 HAZARDS AND HAZARDOUS MATERIALS
The following discussion is based, in part, on a Phase I Environmental Site Assessment (ESA) prepared for the project by Strata Environmental Services, Inc. A copy of this report, dated February 2020, is attached to this EIR as Appendix I.
3.9.1 Environmental Setting
3.9.1.1 Regulatory Framework
Overview
The storage, use, generation, transport, and disposal of hazardous materials and waste are highly regulated under federal and state laws. In California, the EPA has granted most enforcement authority over federal hazardous materials regulations to the California Environmental Protection Agency (CalEPA). In turn, local agencies have been granted responsibility for implementation and enforcement of many hazardous materials regulations under the Certified Unified Program Agency (CUPA) program.
Worker health and safety and public safety are key issues when dealing with hazardous materials.
Proper handling and disposal of hazardous material is vital if it is disturbed during project construction. Cal/OSHA enforces state worker health and safety regulations related to construction activities. Regulations include exposure limits, requirements for protective clothing, and training requirements to prevent exposure to hazardous materials. Cal/OSHA also enforces occupational health and safety regulations specific to lead and asbestos investigations and abatement.
Federal and State
Federal Aviation Regulations Part 77
Federal Aviation Regulations, Part 77 Objects Affecting Navigable Airspace (FAR Part 77) sets forth standards and review requirements for protecting the airspace for safe aircraft operation, particularly by restricting the height of potential structures and minimizing other potential hazards (such as reflective surfaces, flashing lights, and electronic interference) to aircraft in flight. These regulations require that the Federal Aviation Administration (FAA) be notified of certain proposed construction projects located within an extended zone defined by an imaginary slope radiating outward for several miles from an airport’s runways, or which would otherwise stand at least 200 feet in height above the ground.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, is the principal federal law in the United States governing the disposal of solid waste and hazardous waste. RCRA gives the EPA the authority to control hazardous waste from the "cradle to the grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also sets forth a framework for the management of non-hazardous solid wastes.
The Federal Hazardous and Solid Waste Amendments (HSWA) are the 1984 amendments to RCRA that focused on waste minimization, phasing out land disposal of hazardous waste, and corrective
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action for releases. Some of the other mandates of this law include increased enforcement authority for the EPA, more stringent hazardous waste management standards, and a comprehensive underground storage tank program.49
Government Code Section 65962.5
Section 65962.5 of the Government Code requires CalEPA to develop and update a list of hazardous waste and substances sites, known as the Cortese List. The Cortese List is used by state and local agencies and developers to comply with CEQA requirements. The Cortese List includes hazardous substance release sites identified by the Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB).50
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) of 1976 provides the EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics, and pesticides. The TSCA addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon, and leadbased paint.
California Accidental Release Prevention Program
The California Accidental Release Prevention (CalARP) Program aims to prevent accidental releases of regulated hazardous materials that represent a potential hazard beyond the boundaries of a property. Facilities that are required to participate in the CalARP Program use or store specified quantities of toxic and flammable substances (hazardous materials) that can have off-site consequences if accidentally released. The San Mateo County Environmental Health Department reviews CalARP risk management plans as the CUPA.
Asbestos-Containing Materials
Friable asbestos is any asbestos-containing material (ACM) that, when dry, can easily be crumbled or pulverized to a powder by hand, allowing the asbestos particles to become airborne. Common examples of products that have been found to contain friable asbestos include acoustical ceilings, plaster, wallboard, and thermal insulation for water heaters and pipes. Common examples of nonfriable ACMs are asphalt roofing shingles, vinyl floor tiles, and transite siding made with cement.
The EPA phased out use of friable asbestos products between 1973 and 1978. National Emission Standards for Hazardous Air Pollutants (NESHAP) guidelines require that potentially friable ACMs be removed prior to building demolition or remodeling that may disturb the ACMs. 49 United States Environmental Protection Agency. “Summary of the Resource Conservation and Recovery Act.” Accessed May 11, 2020. https://www.epa.gov/laws-regulations/summary-resource-conservation-and-recovery-act. 50 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed May 28, 2020. https://calepa.ca.gov/sitecleanup/corteselist/.
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CCR Title 8, Section 1532.1
The United States Consumer Product Safety Commission banned the use of lead-based paint in 1978.
Removal of older structures with lead-based paint is subject to requirements outlined by the Cal/OSHA Lead in Construction Standard, CCR Title 8, Section 1532.1 during demolition activities.
Requirements include employee training, employee air monitoring, and dust control. If lead-based paint is peeling, flaking, or blistered, it is required to be removed prior to demolition.
Regional and Local
Municipal Regional Permit Provision C.12.f
Polychlorinated biphenyls (PCBs) were produced in the United States between 1955 and 1978 and used in hundreds of industrial and commercial applications, including building and structure materials such as plasticizers, paints, sealants, caulk, and wood floor finishes. In 1979, the EPA banned the production and use of PCBs due to their potential harmful health effects and persistence in the environment. PCBs can still be released to the environment today during demolition of buildings that contain legacy caulks, sealants, or other PCB-containing materials.
With the adoption of the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit (MRP) by the San Francisco Bay Regional Water Quality Control Board on November 19, 2015, Provision C.12.f requires that permittees develop an assessment methodology for applicable structures planned for demolition to ensure PCBs do not enter municipal storm drain systems.51 Municipalities throughout the Bay Area are currently modifying demolition permit processes and implementing PCB screening protocols to comply with Provision C.12.f. Buildings constructed between 1950 and 1980 that are proposed for demolition must be screened for the presence of PCBs prior to the issuance of a demolition permit. Single family homes and wood-frame structures are exempt from these requirements.
San Mateo County Comprehensive Airport Land Use Plan
Daly City is within the jurisdiction of the San Francisco Airport (SFO) Land Use Plan component of the San Mateo County Comprehensive Airport Land Use Compatibility Plan (ALUCP), adopted in December 1996 and updated in 2001. Established in the CLUP are procedures used by the San Mateo City and County Association of Governments (C/CAG) to review land use decisions in the vicinity of San Mateo County airports. Airport planning boundaries define where height, noise and safety standards, policies, and criteria are applied to certain proposed land use policy actions.
Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to hazards and hazardous materials and are applicable to the proposed project.
51 California Regional Water Quality Control Board. San Francisco Bay Region Municipal Regional Stormwater NPDES Permit. November 2015.
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Policy/Task Description
Policy LU-18 Development activities shall not be allowed to significantly disrupt the natural or urban environment and all reasonable measures shall be taken to identify and prevent or mitigate potentially significant effects.
Task LU-18.1 Ensure that potentially significant environmental impacts associated with development proposals are properly mitigated through conditions of approval, mitigation measures, project design, or project denial. In cases where the impacts may not be completely preventable but will not significantly disrupt the community, the City may recognize that the benefits of a project may outweigh the environmental consequences. In no case shall the City approve a project that endangers the health, safety, or welfare of the public.
Policy SE-4.1 Support efforts to locate, regulate, and maintain information regarding hazardous materials located or transported within the City.
Policy SE-4.2 Cooperate with the County of San Mateo in the regulation of hazardous materials and transportation in the Fire Prevention Services Bureau within the City.
Policy SE-4.6 Require the preparation of a risk assessment to determine site suitability for applications for hazardous materials waste management facilities. Establish the distance requirements for these facilities from public assembly, residential or immobile population and recreation areas and structures. Access impacts from seismic, geologic, and flood hazards, impacts on wetlands, endangered species, air quality and emergency response capabilities; and proximity to major transport routes.
3.9.1.2 Existing Conditions
Strata Environmental Services, Inc. conducted a review of aerial photographs, County Assessor’s Office records, historical city directories, and agency records to obtain information about the historical uses of the project site. As part of the Phase I Environmental Assessment, records from federal, state, and local agencies were reviewed, and a site reconnaissance was completed to determine any potentially hazardous materials conditions affecting the project site. The historical uses and potential sources of contamination on the project site are discussed below.
Site History
Prior to 1966, the project site was pastureland. Between 1966 and 1969, the site was graded heavily and developed with a portion of the existing JUHSD campus, including the main campus, storage bungalows, and one 1,000-gallon and one 500-gallon underground storage tanks (USTs) that were used for storing waste products, including acid. The use of these USTs ceased in 1979 but remain onsite. Between 1969 and 2002, the site was developed with a General Education Department building (constructed in 1982), two one-story portables (constructed in 1998) and a Comcast relay station (constructed in 2002).
The JUHSD currently uses the site to provide administrative services and teach English and General/Adult Education classes. Other users of the site include Delucca’s Tae Kwon Do, Headstart, Young World Preschool, Nemenzo Performing Arts, the Homenetmen Armenian General Athletic Union and Scouts, and religious groups including the Catholic Youth Organization (CYO). The CYO