Daly City City Council
January 22, 2024

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dispatches, maintains, washes, and fuels a fleet of school buses at a maintenance garage located onsite, which uses a 2,000-gallon diesel fuel aboveground storage tank (AST), a 280-gallon motor oil AST, and a 280-gallon used oil AST. Additionally, Comcast operates an internet relay station that uses a 2,000-gallon diesel fuel AST.

On-Site Sources of Contamination
The project site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (the “Cortese List”). As discussed above, two USTs remain onsite, however, the Phase I did not identify any records of reported spills or find any direct evidence of spills during a site visit. Nevertheless, contamination of the project site from the presence of these USTs cannot be definitely ruled out. Thus, these USTs would be considered a Recognized Environmental Concern (REC). No other environmental concerns, vapor encroachment conditions, RECs, Historic RECs (HRECs), or Controlled RECs (CRECs) were identified by Strata Environmental Services, Inc. in connection with the project site and past uses.52 Lead-based paint was banned in 1978, ACMs were beginning to be phased out starting in 1973, and PCBs were banned in 1979. The existing buildings on-site were constructed in between 1966 and 1969; therefore, building materials could contain lead-based paint, ACMs, and PCBs.

Off-Site Sources of Contamination
A review of databases and files from federal, state, and local environmental regulatory agencies was used to determine the potential for the project site to be affected by releases from off-site sources of contamination within the appropriate ASTM search radius. Based on location, distance, regulatory status, and/or apparent groundwater gradient, the Phase I ESA determined these sites were not of environmental concern. Refer to Appendix I for more information regarding nearby off-site sources of contamination.

Airport Hazards
The project site is located within the SFO CLUP Airport Influence Area B, which requires projects to be consistent with the goals and policies of the CLUP. The project site is approximately five miles northwest from the runway termination point of the San Francisco International Airport, beyond the outer boundary of safety compatibility zones and outside of the Community Noise Equivalent Level (CNEL) noise contours for the airport, as delineated in the CLUP. 52 An REC is defined as the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. An HREC is defined as a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls. A CREC is defined as a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls.

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Wildland Fire Hazards
The project site is in a Local Responsibility Area (LRA) which has not been mapped by CAL FIRE as being within a Very High Fire Hazard Severity Zone (refer to Section 3.20 Wildfire).

3.9.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on hazards and hazardous materials, would the project:
1) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
2) 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?
3) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? 4) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
5) For a project located within an airport land use plan or, where such a plan can talk has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard or excessive noise for people residing or working in the project area? 6) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
7) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?

3.9.2.1 Project Impacts
Impact HAZ-1: The project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. (Less than Significant Impact)
Implementation of the project would result in the redevelopment of the project site with residential and commercial uses. Potentially hazardous materials, including vehicle fuels, oils, and fluids, would be used during construction. Residential and commercial uses do not involve the routine transport, use, or disposal of hazardous materials other than minor quantities required for emergency operations (e.g., diesel generators), cleaning, maintenance, or landscaping.

During construction, all hazardous materials would be transported, contained, stored, used, and disposed of in accordance with manufacturers’ instructions and would be handled in compliance with all applicable federal, state, and county standards and regulations (refer to Section 3.9.1.1 Regulatory Framework). Construction-related hazardous materials use would be temporary, and does not constitute routine transport, use, or disposal.

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Once operational, the project would be required by California Health and Safety Code 25507(a)(1)(A) to establish and implement a Hazardous Materials Business Plan if the amount of diesel fuel stored on-site for use of emergency generators exceeds 55 gallons. Cleaning supplies, maintenance chemicals, and herbicides and pesticides would be stored and managed in accordance with existing laws and regulations that ensure that the routine transport, storage, use, and disposal of these materials would not result in a significant hazard to the public or environment.

For the reasons stated above, the project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. (Less Than Significant Impact)
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)
Under/Above-Ground Storage Tanks
As discussed under Section 3.9.1.2 Existing Conditions, there are two USTs and three ASTs present on-site that would need to be removed prior to demolition, including 1,000-gallon and 500-gallon waste USTs, one 2,000-gallon diesel fuel ASTs, a 280-gallon motor oil AST, and a 280-gallon used oil AST. The 2,000-gallon diesel fuel AST used by the Comcast Relay Station will remain on-site during and after construction. Prior to the demolition of the existing JUHSD campus, these tanks would be removed. The removal of these USTs and the soil surrounding them has the potential to release hazardous materials into the environment and poses a risk to construction workers, and adjacent residents, and school. The release of hazardous materials contained in the USTs and any contaminated soils into the environment constitutes a significant impact.

Mitigation Measure:

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 with commonly accepted environmental protocols. If contaminants are identified at concentrations exceeding applicable screening levels published by the RWQCB, DTSC and/or EPA53, appropriate mitigation measures, such as, but not limited to, a Soil Management Plan and Health Safety Plan, shall be incorporated into the 53 Note that naturally occurring background concentrations of metals, such as arsenic, amongst others, in soil may exceed their respective screening levels. Regulatory agencies generally do not require cleanup of soil to below background concentrations. Thus, concentrations of metals are compared to regional published background concentrations to establish if regulatory agency approval is warranted.

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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.

With implementation of MM HAZ-2.1, impacts associated with the removal of existing USTs and ASTs would be less than significant.

Demolition
The project proposes to demolish the existing JUHSD campus, a portion of which was constructed prior to the phasing out of ACMs that occurred between 1973 and 1983 (refer to Section 3.9.1.1 Regulatory Framework). The JUHSD campus previously underwent asbestos abatement between 1989 and 1993, and again between 2000 and 2001. An Asbestos Hazard Emergency Response Act inspection was conducted in 2019 which found ACMs to be present throughout the site. Additionally, as a portion of the JUHSD campus was constructed prior to the prohibitions on the use of lead-based paint and PCBs, surfaces coated with lead-based paint and building materials containing PCBs may also be present.

Prior to demolition, NESHAP requires the removal of all regulated (i.e. friable) ACMs and certain non-friable ACMs which might be rendered friable before demolition activities that might disturb ACMs occurs.54 Additionally, BAAQMD requires all materials that contain more than one percent of asbestos are required to be removed prior to demolition in accordance with BAAQMD standards. All demolition activities would be completed in accordance with the California Division of Occupational Safety and Health standards contained in Title 8, California Code of Regulations, Section 1529, to protect workers from asbestos exposure.

In order to protect construction workers, nearby sensitive receptors, and the environment, the California Division of Occupational Safety and Health requires a building survey that includes sampling and testing to be completed prior to demolition that identifies and quantifies building materials containing lead-based paint. All building materials containing lead-based paint are required to be removed prior to demolition in accordance with the California Division of Occupational Safety and Health Title 8, California Code of Regulations, Section 1532.1. Any debris or soil containing lead-based paint or coatings shall be disposed of at landfills that meet acceptance criteria for the type of lead being disposed.

The project proposes to demolish the on-site buildings, which may have materials that contain PCBs.

During demolition, PCBs in building materials could be released and thereby exposed to stormwater runoff from the project site during rain events. To address this risk, applicants for a demolition permit must comply with the City’s PCB Demolition Program with their permit application.55 If onsite buildings do contain PCBs that exceed threshold limits, the project applicant must follow 54 Friable materials are easily crumbled and may become airborne during demolition activities if not removed prior to demolition.
55 City of Daly City. Green Infrastructure Program. Page 7. July 2019.

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applicable federal and state laws, which may include reporting to such agencies as the EPA, RWQCB, and DTSC, who may require additional sampling and abatement of PCBs consistent with state and federal requirements.

Compliance with state and regional regulations would ensure that all materials containing hazardous quantities of asbestos, lead-based paint, and PCBs are identified and removed prior to demolition. As such, the proposed demolition of the existing JUHSD campus would not create a significant hazard through the release of ACMs, lead-based paint, or PCBs into the environment.

Construction
As discussed under Section 3.9.1.2 Existing Conditions, the project site was historically used as pastureland up until 1966, at which point it was heavily graded and developed and then used for a variety of educational and religious services, bus storage, maintenance, and fueling, and as a Comcast relay station. The Phase I ESA identified one REC, associated with the existing USTs onsite. As such, ground-disturbing activities associated with implementation of the project (e.g. excavation, grading, etc.) could disturb potentially contaminated soil that could become airborne and pose a health hazard to construction workers, nearby sensitive receptors, or the environment. With implementation of MM HAZ-2.1, however, the impact would be reduced to a less than significant level.

Operation
As discussed under Impact HAZ-1, the proposed residential and commercial uses would not routinely transport, use, or dispose of hazardous materials beyond small quantities of diesel fuel, cleaning supplies, maintenance chemicals, and herbicides and pesticides, all of which would be stored and managed in accordance with existing federal and state laws and regulations (refer to Section 3.9.1.1 Regulatory Framework). Accordingly, operation of the project would not create a significant hazard to the public or the environment due to the release of hazardous materials into the environment. (Less than Significant Impact with Mitigation Incorporated) 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)
The project site is within a quarter mile of one existing school, the Summit Shasta Charter School, which is located at 905 Campus Drive adjacent to the plan area. The project’s proposed residential and commercial uses would not emit hazardous emissions, and as discussed under Impact HAZ-1 and Impact HAZ-2, compliance with federal, state, and county regulations (refer to Section 3.9.1.1 Regulatory Framework) and implementation of MM HAZ-2.1 would ensure that hazardous materials used during construction and operation of the project’s proposed residential and commercial uses would not create a significant hazard to the public or environment. (Less Than Significant Impact with Mitigation Incorporated)

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Impact HAZ-4: The project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment. (No Impact)
As discussed in Section 3.9.1.2 Existing Conditions, the project site is not on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. (No Impact) Impact HAZ-5: The project would be located within an airport land use plan. The project would not result in a safety hazard or excessive noise for people residing or working in the project area. (Less than Significant Impact) The project site is located approximately five miles northwest of SFO within Airport Influence Area B. As noted in Section 3.9.1.2 Existing Conditions, the proposed project would be required to be consistent with the goals and policies of the SFO ALUCP. Additionally, projects that would occur within mapped noise and safety compatibility zones would be subject to additional restrictions and requirements. The project is outside of the mapped noise and safety compatibility zones where new land uses may conflict with noise generated by airport operations or aircraft accidents are likely to occur.

As noted in Section 3.9.1.1 Regulatory Framework, 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 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 ground. The project site is located on terrain that is 200 feet or greater above ground level. As such, the project is required to file FAA Form 7460-1, Notice of Proposed Construction or Alteration with the FAA at least 30 days prior to construction so that the project can be reviewed for aviation compatibility, or a signed exemption form pursuant to 14 CFR Part 77.9(b) be submitted prior to construction. On July 22, 2021, the Board of Directors of the San Mateo County Airport Land Use Commission determined that the proposed Precise Plan (including the Parcel B Development project) is consistent with the SFO ALUCP and FAR Part 77 regulations. (Less Than Significant Impact)
Impact HAZ-6: The project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. (Less than Significant Impact)
The proposed project would not impair or physically interfere with any adopted emergency response or evacuation plan. All project development would be constructed to comply with all applicable state and local building and fire codes. During construction and operation, roadways would not be blocked such that emergency vehicles would be unable to access the site or surrounding properties. Existing pedestrian walkways, bike paths, and handicap access pathways would be maintained. During

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operation, emergency ingress and egress to the project site would be provided by the surrounding roadways. Therefore, the proposed project would not impair the implementation of or physically interfere with any emergency response or evacuation plan. (Less Than Significant Impact) Impact HAZ-7: The project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. (Less than Significant Impact)
As discussed in Section 3.9.1.2 Existing Conditions, the project site is located in an urbanized area of Daly City and is not located in or near state responsibility areas or lands classified as very high fire hazard severity zones. Further, as described above under Impact HAZ-6, all project development would be constructed in accordance with current state and local building and fire codes to ensure structural stability and safety and the final site design would be reviewed by the Daly City Fire Department for consistency with applicable fire department standards. (Less Than Significant Impact)

3.9.2.2 Cumulative Impacts
Impact HAZ-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant hazards and hazardous materials impact. (Less than Significant Cumulative Impact)
Projects in the cumulative scenario could be located on properties where hazardous materials may have been stored, used, and/or transported. These hazardous materials (such as gasoline, oil, propane, and various chemicals in manufacturing) may have been stored on these sites in aboveground or underground tanks. Storage tanks can leak, often resulting in soil and/or groundwater contamination.

If groundwater is affected, it can impact properties downgradient of the spill. In addition, development of some of the sites would require demolition of existing buildings that may contain ACMs and/or lead paint. Demolition of these structures could expose construction workers or other persons in the vicinity to harmful levels of asbestos or lead.

Based on these conditions, which are present on most cumulative project sites to varying degrees, impacts could occur in the cumulative scenario as a result of exposure of residents and/or workers to substances that have been shown to adversely affect health. However, the impacts would be limited to individual sites, and not have the potential to contribute to cumulative impacts unless other projects were occurring in the immediate vicinity. For all cumulative scenario projects, mitigation measures will be implemented as a condition of approval to lessen risks associated with exposure to hazardous materials. Further, adherence to applicable existing local, state, and federal laws and regulations related to hazardous materials would lessen the potential for cumulative impacts.

If chemical releases have occurred in the cumulative scenario, and depending upon the extent of the release, contaminated soils could be excavated and transported to appropriate landfills or treated onsite. If groundwater is affected, remediation and ongoing groundwater sampling both on the site and on surrounding downgradient properties could be warranted. However, these conditions would be localized and limited to a given project site, and not have the potential to combine with other projects

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unless they are adjacent. Finally, determining the extent of asbestos and lead paint contamination would also be required prior to building demolition and site grading and, if present, such substances would be handled and disposed of in a manner that minimizes human exposure. These impacts, too, would be limited to each project site or immediately surrounding sites under construction. Therefore, cumulative projects, including the proposed project, would not result in significant cumulative hazardous materials impacts. (Less than Significant Cumulative Impact)

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3.10 HYDROLOGY AND WATER QUALITY
The following discussion is based, in part, on a Stormwater Memo prepared by BKF Engineers, dated May 2021, and a Water Supply Assessment prepared for the project by Brown and Caldwell, on behalf of the Daly City Department of Water and Wastewater Resources and dated December 2021. Copies of these reports are attached to this EIR as Appendix J and Appendix M, respectively.

3.10.1 Environmental Setting

3.10.1.1 Regulatory Framework
Federal and State
The federal Clean Water Act and California’s Porter-Cologne Water Quality Control Act are the primary laws related to water quality in California. Regulations set forth by the Environmental Protection Agency (EPA) and the State Water Resources Control Board (SWRCB) have been developed to fulfill the requirements of this legislation. EPA regulations include the NPDES permit program, which controls sources that discharge pollutants into the waters of the United States (e.g., streams, lakes, bays, etc.). These regulations are implemented at the regional level by the Regional Water Quality Control Boards. The project site is within the jurisdiction of the San Francisco Bay RWQCB.

National Flood Insurance Program
The Federal Emergency Management Agency (FEMA) established the National Flood Insurance Program (NFIP) to reduce impacts of flooding on private and public properties. The program provides subsidized flood insurance to communities that comply with FEMA regulations protecting development in floodplains. As part of the program, FEMA publishes Flood Insurance Rate Maps (FIRMs) that identify Special Flood Hazard Areas (SFHAs). An SFHA is an area that would be inundated by the one-percent annual chance flood, which is also referred to as the base flood or 100- year flood.

Statewide Construction General Permit
The SWRCB has implemented an NPDES General Construction Permit for the State of California (Construction General Permit). For projects disturbing one acre or more of soil, a Notice of Intent (NOI) must be filed with the RWQCB by the project sponsor, and a Storm Water Pollution Prevention Plan (SWPPP) must be prepared by a qualified professional prior to commencement of construction and filed with the RWQCB by the project sponsor. The Construction General Permit includes requirements for training, inspections, record keeping, and, for projects of certain risk levels, monitoring. The general purpose of the requirements is to minimize the discharge of pollutants and to protect beneficial uses and receiving waters from the adverse effects of construction-related storm water discharges.

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Regional
San Francisco Bay Basin Plan
The San Francisco Bay RWQCB regulates water quality in accordance with the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan lists the beneficial uses that the San Francisco Bay RWQCB has identified for local aquifers, streams, marshes, rivers, and the San Francisco Bay, as well as the water quality objectives and criteria that must be met to protect these uses. The San Francisco Bay RWQCB implements the Basin Plan by issuing and enforcing waste discharge requirements, including permits for nonpoint sources such as the urban runoff discharged by a City’s stormwater drainage system. The Basin Plan also describes watershed management programs and water quality attainment strategies.

Municipal Regional Permit Provision C.3
The San Francisco Bay RWQCB re-issued the Municipal Regional Stormwater NPDES Permit (MRP) in 2015 to regulate stormwater discharges from municipalities and local agencies (copermittees) in Alameda, Contra Costa, San Mateo, and Santa Clara Counties, and the cities of Fairfield, Suisun City, and Vallejo.56 Under Provision C.3 of the MRP, new and redevelopment projects that create or replace 10,000 square feet or more of impervious surface area are required to implement site design, source control, and Low Impact Development (LID)-based stormwater treatment controls to treat post-construction stormwater runoff. LID-based treatment controls are intended to maintain or restore the site’s natural hydrologic functions, maximizing opportunities for infiltration and evapotranspiration, and using stormwater as a resource (e.g. rainwater harvesting for non-potable uses). The MRP also requires that stormwater treatment measures are properly installed, operated, and maintained.

In addition to water quality controls, the MRP requires new development and redevelopment projects that create or replace one acre or more of impervious surface to manage development-related increases in peak runoff flow, volume, and duration, where such hydromodification is likely to cause increased erosion, silt pollutant generation, or other impacts to local rivers, streams, and creeks.

Projects may be deemed exempt from these requirements if they do not meet the minimized size threshold, drain into tidally influenced areas or directly into the Bay, or drain into hardened channels, or if they are infill projects in subwatersheds or catchment areas that are greater than or equal to 65 percent impervious.

Construction Dewatering Waste Discharge Requirements
Each of the RWQCBs regulate construction dewatering discharges to storm drains or surface waters within its Region under the NPDES program and Waste Discharge Requirements. 56 MRP Number CAS612008

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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 hydrology and water quality and are applicable to the proposed project.

Policy/Task Description
Policy RME-8 Through the development of a Stormwater Management Program, ensure that all new development complies with the applicable Municipal Regional Stormwater Permit by incorporating controls that reduce water quality impacts over the life of the project in ways that are both technically and economically feasible, and reduce pollutants in stormwater discharges to the maximum extent practicable.

Task RME-8.5 Ensure the regular inspection of stormwater treatment facilities as required by the Municipal Regional Stormwater NPDES Permit.

Policy RME-9 Balance stormwater mitigation measures with the other inherent benefits of higher density development that is in close proximity to public transit, i.e., reduction of Vehicle Miles Traveled (VMT) on local and regional roadways to the extent permitted under the Municipal Regional Stormwater Permit.

Task RME-9.1 Continue to explore low-impact development credits for high density transit-oriented development within the City’s established Priority Development Areas with the Regional Water Quality Control Board.

Policy SE-2.1 Protect the City of Daly City from unreasonable risk to life and property caused by flood hazards by designing and constructing drainage facilities to improve the flow capacity of the City’s water system in order to accommodate the storm water runoff generated by a 100-year storm.

Daly City Municipal Code
Chapter 13.20 – Well Standards
Chapter 13.30 includes standards intended to ensure that groundwater beneath the City will not be polluted or contaminated. The chapter contains requirements for construction, reconstruction, repair and destruction of water wells, cathodic protection wells, and monitoring wells. Permits are also required for these activities as well as for excavations that may intersect groundwater.

Title 14 – Storm Water Management and Discharge Control Title 14, also known as the “City of Daly City Stormwater Management and Discharge Control Ordinance”, prohibits non-stormwater discharges to the City storm drain system. The purpose of the Ordinance is to eliminate non-stormwater discharges to the municipal separate storm drain system, control the discharge of spills, dumping or disposal of materials other than stormwater, and reduce pollutants in stormwater discharges into the storm drain system to the maximum extent practicable.

Chapter 14.12 gives the City the authority to inspect projects to enforce any of the provisions of Title

14.

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Chapter 15.62 – Grading, Erosion, and Sediment Control
Chapter 15.62, also known as the City of Daly City Grading, Erosion and Sediment Control Ordinance, sets forth rules and regulations to control site clearing, vegetation disturbances, land-fills, land excavations, soil storage, and other such activities which may cause sediments and other pollutants to enter the public drainage facilities. The chapter establishes the regulations, permit requirements, procedures for administration and enforcement of permits to properly control the aforementioned activities to preserve and enhance public health, safety and environment. Section

15.62.230 requires the permittee to maintain a copy of the permit, approved plans and reports and make these available for city inspection. Section 15.62.270 gives the City engineer authority to suspend or revoke a permit for violation or non-compliance with Chapter 15.62.

Chapter 17.41 – Water Conservation in Landscaping
Chapter 17.41 requires new construction projects with landscaping of 500 square feet or greater to complete a landscape project application and comply with the landscape and irrigation maintenance and stormwater management requirements outlined in this chapter.

3.10.1.2 Existing Conditions
Hydrology and Drainage
The project site is located within the Colma Creek Watershed, which drains to the San Francisco Bay Area via Colma Creek, the majority of which is either channelized or underground to allow for urban development.57
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. Surface runoff on-site is collected in drains or inlets and conveyed via below grade pipes to the storm drain outfall, which is located in the existing parking lot near the main vehicular entrance at Serramonte Boulevard. The outfall discharges to an existing 24-inch storm drain main in Serramonte Boulevard that flows northeast before being discharged into Colma Creek, approximately 1.3 miles east of the project site.

The approximately 22-acre project site currently consists of 413,505 square feet (50 percent) of impervious surfaces and 415,450 square feet (50 percent) of pervious surfaces.

Surface Water Quality
The water quality of streams, creeks, ponds, and other surface water bodies can be greatly affected by pollution carried in contaminated surface runoff. Pollutants from unidentified sources, known as “non-point” source pollutants, are washed from streets, construction sites, parking lots, and other exposed surfaces into storm drains. Surface runoff from the Precise Plan area is collected by storm drains and discharged to Colma Creek. Runoff often contains contaminants such as oil and grease, plant and animal debris (e.g., leaves, dust, and animal feces), pesticides, litter, and heavy metals. In 57 City of Daly City. General Plan Update, Final Environmental Impact Report. February 2013.

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sufficient concentration, these pollutants have been found to adversely affect the aquatic habitats to which they drain. Colma Creek is currently listed on the 303(d) list for trash.58, 59 Groundwater
The Colma Creek Watershed is located in the Westside Groundwater Basin, which has not been identified as a groundwater basin in a state of overdraft.60 As discussed in Section 3.8.1.1 Existing Conditions, groundwater in the project vicinity is projected to flow generally south and east towards the San Francisco Bay at a depth of greater than 50 feet bgs.61 Fluctuations in groundwater levels occur due to many factors including seasonal fluctuation, underground drainage patterns, regional fluctuations, and other factors.

Flooding and Other Hazards
The project site is designated as Flood Zone X according to FEMA Flood Insurance Rate Maps.

Areas within Flood Zone X have a 0.2 percent annual chance of flooding, with average depths of less than one foot or with drainage areas less than one square mile. No special flood hazard restrictions apply to Zone X.

Tsunami inundation maps prepared by the California Department of Conservation indicate that the project site is outside of tsunami hazard areas. Seiches can occur in semi- or fully-enclosed bodies of water and inundate adjacent areas; the nearest semi- or fully-enclosed water body is Lake Merced, located approximately 2.75 miles north of the Precise Plan area.

3.10.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on hydrology and water quality, would the project:
1) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
2) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
3) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
- result in substantial erosion or siltation on- or off-site; 58 The Clean Water Act (CWA), Section 303, establishes water quality standards and Total Maximum Daily Load (TMDL) programs. The 303(d) list is a list of impaired water bodies. 59 California Environmental Protection Agency, State Water Resources Control Board. “Impaired Water Bodies”.

Accessed September 29, 2021.
https://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2014_2016.shtml 60 California Department of Water Resources. “State Groundwater Management Act Basin Prioritization Dashboard”. Accessed September 29, 2021. https://gis.water.ca.gov/app/bp-dashboard/final/ 61 Strata Environmental Services, Inc. Phase I Environmental Site Assessment, Serramonte del Rey Campus.

February 2020.

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- substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
- create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
- impede or redirect flood flows?
4) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? 5) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

3.10.2.1 Project Impacts
Impact HYD-1: The project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. (Less than Significant Impact)
Construction Impacts
Implementation of the proposed project would temporarily impact surface water quality during construction. Future development would require demolition, grading, and paving of the project sites, activities that temporarily increase the amount of unconsolidated materials on the site. Construction of the below grade parking garages, new buildings, and other improvements (including utility connections) would require excavation. Grading and excavation activities could increase erosion and sedimentation, resulting in sediment, soil, and associated pollutants that could be carried by runoff into natural waterways and possibly increasing sedimentation impacts to local creeks or the San Francisco Bay.

All construction or demolition activity that results in land disturbances equal to or greater than one acre must obtain coverage under the Construction General Permit, which is administered by the SWRCB. The Parcel B Development project would disturb greater than one acre of land and, therefore, would require coverage under the Construction General Permit and submit a SWPPP and NOI to the SWRCB. Any future development on Parcels C-F disturbing more than one acre would similarly require coverage under the Construction General Permit. The City requires project applicants to submit a stormwater management plan that illustrates full compliance with the MRP.

This will require the project to include stormwater controls such as site design measures, source controls, treatment measures, low impact development, hydromodification management, and construction best management practices. These policies are reinforced by the discharge prohibitions and requirements for reducing pollutants in storm water in Title 14 and Title 15 of the Municipal Code. Adherence to regulations, policies and standards will ensure that impacts to water quality will be less than significant.

Post-Construction Impacts
As discussed above, the 22-acre project site currently consists of 413,505 square feet (50 percent) of impervious surfaces and 415,450 square feet (50 percent) of pervious surfaces. Full buildout of the

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proposed project would result in approximately 502,050 square feet (60 percent) of impervious surfaces and approximately 332,340 square feet (40 percent) of pervious surfaces, resulting in an overall increase of 88,545 square feet of impervious surfaces. To reduce water quality impacts postconstruction, the project is required to comply with the MRP including Provision C.3 of the MRP regarding LID site design. LID features could include self-treating and self-retaining areas to allow on-site retention, percolation, and evaporation of stormwater runoff.

The project proposes to satisfy the MRP and Provision C.3 of the MRP with an approach that would allow Parcel B to ‘overcompensate’ by incorporating additional treatment beyond what would otherwise be required of that Parcel, and accrue treatment ‘credits’ that can be applied to other parcels (Parcels C-F) that would have more difficulty meeting the requirement solely within the boundaries of each parcel. The proposed retention structure within Parcel B would provide a 12,830 square-foot self-retaining stormwater treatment area that would collect water from the entire project site. This would ensure that stormwater discharge from the project site, at full buildout during a 10- year storm event, would match pre-construction conditions and not increase stormwater runoff from the project site. In addition, the project proposes for each phase of development during buildout, preand post-construction areas of impervious surfaces would be calculated within the phase limits to determine if there would be an increase in the peak runoff rate compared to existing conditions. If there is a calculated increase in peak runoff rate, a temporary stormwater detention system, such as a detention basin or below-grade detention pipe, would be located within the footprint of the undeveloped parcels until the phase can be connected to the Parcel B retention structure. At no point during the development process would the project increase the peak rate of stormwater runoff leaving the site.

Based on the above discussion, future development under the proposed Precise Plan, with compliance with existing regulations (including the NPDES and City’s Grading, Erosion and Sediment Control Ordinance), would not result in significant water quality impacts. (Less Than Significant Impact with Mitigation Incorporated)
Impact HYD-2: The project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. (Less than Significant Impact)
Daly City receives a large portion of its water supply from the San Francisco Public Utilities Commission (SFPUC) and supplements the SFPUC supply with groundwater pumped from six local wells. During dry periods, groundwater makes up a larger proportion (up to 49 percent in fifth year consecutive dry year) of the City’s supply.62 The proposed project, consisting of 1,235 residential units and up to 14,000 square feet of neighborhood-serving retail/commercial uses, would not be expected to result in the need for excessive groundwater pumping from the local wells during normal years; however, during single and multiple dry-years, the City (with and without the project) is expected to experience shortfalls in water supply (see water supply discussion in Section 4.18 62 Brown and Caldwell. Water Supply Assessment for the Jefferson Union High School District Master Plan Project.

December 2021. Page 4-3.

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Utilities and Service Systems).63 While shortfalls may occur, groundwater pumping within the Westside Groundwater Basin would not increase beyond the City’ current allotment and water supplies would be procured from other sources.

There are no designated groundwater recharge areas within the Westside Groundwater Basin. The principal sources of recharge are direct infiltration of rainfall, infiltration of irrigation water, and leakage from water and sewer pipes.64 As discussed in Impact HYD-1 above, the project would increase impervious surfaces on the site by 88,545 square feet, resulting in a corresponding decrease in infiltration capacity. The project, however, would include numerous self-retaining, self-treating, and bioretention areas within the landscaping, consistent with the MRP and Provision C.3, that would provide opportunities for stormwater infiltration. The project would therefore not be expected to substantially interfere with groundwater recharge or impede groundwater management of the basin. (Less Than Significant Impact)
Impact HYD-3: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows. (Less than Significant Impact with Mitigation Incorporated) There are no waterways present on the project site; therefore, future development of the Precise Plan would not alter the course of a stream or river. As discussed above under Impact HYD-1, implementation of proposed Precise Plan would result in an increase in impervious surfaces compared to existing conditions by 88,545 square feet. An increase in impervious surfaces would result in a corresponding increase in surface runoff from the project site. The project, however, would comply with applicable regulations, including the statewide Construction General Permit, MRP (including Provisions C.3), and City ordinances for controlling pollutants. In addition, the proposed storm drain system would retain stormwater on-site to match pre-project flow conditions under the 10-year storm event. Thus, the project would not result in substantial erosion, siltation, flooding, significant water quality impacts, or exceed the capacity of existing or planned stormwater drainage systems. (Less than Significant Impact)
Impact HYD-4: The project would not risk release of pollutants due to project inundation in flood hazard, tsunami, or seiche zones. (No Impact)
The project site is not located in a 100-year floodplain and, therefore, would not place housing within a 100-year flood hazard area or impede or redirect flood flows within a 100-year flood hazard area. 63 Ibid. Page 4-7. 64 San Francisco Bay Hydrologic Region Westside Groundwater Basin, California’s Groundwater Bulletin 118, January 20, 2006.

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The project site, due to its topography, is not subject to seiche, tsunami, or mudslide hazards. (No Impact)
Impact HYD-5: The project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. (Less than Significant Impact)
As previously described, the project site is located within the Westside Groundwater Basin. There are existing groundwater management plans for the northwestern portion (North Westside Groundwater Basin Management Plan) and the southern portion (South Westside Basin Groundwater Management Plan) of the Basin. Although the project site technically lies outside of the boundaries of these two management plans, it is within the City of Daly City, which would be the water service provider for the project and is a participant in the South Westside Basin Groundwater Management Plan. The City would implement the groundwater protection and management goals and objectives of the Plan. The project, which proposes to redevelop the existing Serramonte Del Rey Campus into a multi-family housing development with ground-floor retail, would not conflict with or obstruct the implementation of the Plan in that the development of the site would not rely on groundwater beneath the site for water supply, nor would the project require dewatering. While the project would increase impervious surfaces by 88,545 square feet compared to existing conditions, it would not lead to a significant reduction in groundwater infiltration potential. (Less Than Significant Impact)

3.10.2.2 Cumulative Impacts
Impact HYD-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant hydrology and water quality impact. (Less than Significant Cumulative Impact)
Water Quality, Groundwater, and Drainage Impacts
The geographic area for cumulative hydrology and water quality impacts includes the project site and the surrounding area, as well as other development within the Colma Creek watershed. Several of the cumulative projects identified in Table 3.0-1 would involve redevelopment of existing or previously developed sites that contain substantial impervious surfaces, and these projects would be required to conform to applicable General Plan goals, policies, and strategies regarding stormwater runoff, infrastructure, and flooding. All projects within the City, including those identified in Table 3.0-1, would also be required to comply with applicable requirements in the statewide Construction General Permit, MRP (including Provisions C.3), City ordinances, and NPDES permits standards to avoid hydrology and water quality impacts or reduce them to a less than significant level. For these reasons, the project would not have a cumulatively considerable water quality, groundwater, or drainage impact.

Flooding and Inundation Impacts
As discussed under Impact HYD-4, the project site is not subject to significant flood or inundation hazards; therefore, the project would not result in a considerable contribution to significant

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cumulative impact related to release of pollutants due to flooding and inundation. (Less than Significant Cumulative Impact)

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3.11 LAND USE AND PLANNING

3.11.1 Environmental Setting

3.11.1.1 Regulatory Framework
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. All future development allowed by the project would be subject to conformance with applicable General Plan policies, including those listed below.

Policy/Task Description
Policy LU-4 Provide regulatory incentives for developers to construct higher-density mixed use development along Mission Street, Geneva Avenue, and any other locations within close proximity to public transit.

Policy LU-8 Ensure that landscape and hardscape improvements made to all residential properties are environmentally sound and do not negatively impact existing neighborhood aesthetics.

Daly City Municipal Code
The Zoning Ordinance is provided in Title 17 of the Daly City Municipal Code. The Zoning Ordinance helps promote public health, safety, morals, convenience, comfort, prosperity and general welfare of residents in the City.

3.11.1.2 Existing Conditions
General Plan Land Use Designation
The majority of the project site has a General Plan land use designation of C-O (Commercial – Office) while a smaller portion of the site in the northwest corner (Parcel A Development project) has a General Plan land use designation of R-HD (Residential-High Density). The C-O designation allows for office and locally serving commercial uses such as health and fitness centers, small scale printing and photocopying businesses, and eating and drinking establishments. The floor-to-area ratio (FAR) allowed for the C-O designation ranges from 1.0 to 3.5. The R-HD designation allows for multi-family residential buildings between 35.1 and 50 dwelling units per acre.

Zoning Ordinance
Similar to the General Plan Designation, the majority of the project site is zoned PD-31 (Planned Development District) while a smaller portion of the site in the northwest corner (Parcel A Development project) is zoned to PD-31A. 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 and approximately 700,000 square feet of office space. The PD-31A zoning was specifically created to allow for the

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construction of the Parcel A Development project, which has been developed with 122 multifamily units intended for Jefferson Union High School District (JUHSD) employees.

Existing Land Uses
The northwest corner of the project site has been developed with the approved Parcel A Development project (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 building that serves as the existing JUHSD district office and adult education buildings.

Surrounding Land Uses
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.

Southeast of the project site is the Summit Shasta High School, which is developed with one- to twostory concrete education buildings. East of the project site across Callan Boulevard is a Chinese cemetery consisting of mostly open space and gravestones.

3.11.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on land use and planning, would the project:
1) Physically divide an established community?
2) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

3.11.2.1 Project Impacts
Impact LU-1: The project would not physically divide an established community. (Less than Significant Impact)
The project site is located in a developed urban area with residential uses to the north and west, and a variety of institutional uses to the south and east. Implementation of the proposed project would result in the construction of 1,235 residential units (Parcel A has already been constructed) and up to 14,000 square feet of neighborhood-serving retail/commercial uses on the site. The layout and design of the project does not include any features that would physically divide the community (e.g., impeding roadways or sidewalks). In addition, implementation of the project would include right-ofway and pedestrian and bicycle improvements that would promote mobility in the project area. For

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these reasons, the project would not physically divide an established community. (Less Than Significant Impact)
Impact LU-2: The project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. (Less than Significant Impact)
The project site is located in the Serramonte Planning Area, which is the newest large-scale subdivision in Daly City. The project site is designated in the General Plan as C-O which allows for office and locally-serving commercial uses. In order for the proposed Precise Plan to comply with the General Plan, a General Plan Amendment is proposed to C-MU (Commercial – Mixed Use), which allows vertical mix of commercial and residential uses (e.g., retail or restaurant uses at the street level and residential uses at levels above the street). The FAR of C-MU designated areas generally ranges from 1.0 to 6.0.

The proposed project would comply with the City’s Inclusionary Housing Ordinance (Chapter 17.47 of the City’s Municipal Code), which requires 10 percent of rental units to be low-income units.

According to the Ordinance, a lack of new affordable units will have a substantial negative impact on the environment because: (1) housing will have to built elsewhere, far from employment centers and therefore commutes will increase, causing increased traffic and transit demand and consequent noise and air pollution; and (2) City businesses will find it more difficult to attract and retain the workers they need. Affordable housing policies contribute to a healthy job and housing balance by providing more affordable housing close to employment centers.

The proposed project would construct housing within the City of Daly City and it aligns with the City’s Inclusionary Housing Ordinance in providing at least 10 percent affordable housing. In addition, the proposed project is subject to mitigation measures to minimize environmental impacts as discussed throughout this EIR, and would be consistent with General Plan policies adopted to avoid or mitigate environmental effects as described in the individual resource sections of this EIR.

For these reasons, the proposed project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. (Less than Significant Impact)

3.11.2.2 Cumulative Impacts
Impact LU-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant land use and planning impact. (Less than Significant Cumulative Impact)
Cumulative scenario projects in the City are subject to General Plan goals, policies, and action statements that require appropriate buffers, edges, and transition areas between land uses. In addition, setback, design, and operational requirements of the City’s Zoning Ordinance minimize land use compatibility issues that might result in physical land divisions. For these reasons, a cumulative

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impact related to dividing an established community would not occur, consistent with the conclusions in the General Plan EIR.

Cumulative scenario projects in the City of Daly City would go through the City development review process. Projects would be analyzed for conformance with applicable policies adopted for the purpose of avoiding or mitigating an environmental impact though the CEQA review process. The project, therefore, in combination with cumulative development, would not result in significant policy conflict impacts and would not contribute to a significant cumulative land use impact as a result of conflict with policies to avoid a significant environmental impact. (Less than Significant Cumulative Impact)

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3.12 MINERAL RESOURCES

3.12.1 Environmental Setting

3.12.1.1 Regulatory Framework
State
Surface Mining and Reclamation Act
The Surface Mining and Reclamation Act (SMARA) was enacted by the California legislature in 1975 to address the need for a continuing supply of mineral resources, and to prevent or minimize the negative impacts of surface mining to public health, property, and the environment. As mandated under SMARA, the State Geologist has designated mineral land classifications in order to help identify and protect mineral resources in areas within the state subject to urban expansion or other irreversible land uses which would preclude mineral extraction. SMARA also allowed the State Mining and Geology Board (SMGB), after receiving classification information from the State Geologist, to designate lands containing mineral deposits of regional or statewide significance.

3.12.1.2 Existing Conditions
According to the Mineral Lands Classification Map of the SMGB, the City of Daly City does not include any mineral extraction areas of statewide importance.65

3.12.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on mineral resources, would the project:
1) Result in the loss of availability of a known mineral resource that would be of value to the region and residents of the state?
2) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?

3.12.2.1 Project Impacts
Impact MIN-1: The project would not result in the loss of availability of a known mineral resource that would be of value to the region and residents of the state. (No Impact)
The project site is currently developed with JUHSD district office buildings, surface parking, a demonstration garden, and the recently constructed Parcel A JUHSD Staff and Faculty Housing project. As discussed under Section 4.12.1.2 Existing Conditions, the project site does not contain any known mineral resources. Therefore, the project would have no impact on the availability of known, valuable mineral resources. (No Impact)
65 California Department of Conservation. Designated Areas Update San Francisco South Quadrangle. Map. 1996.

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Impact MIN-2: The project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. (No Impact)
See response to Impact MIN-1 above. (No Impact)

3.12.2.2 Cumulative Impacts
Impact MIN-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant mineral resources impact. (No Cumulative Impact) Since the project would not result in impacts to mineral resources, the project would not contribute to a cumulative impact to mineral resources. (No Cumulative Impact)

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3.13 NOISE
The following discussion is based, in part, on a noise and vibration assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 2022, is attached to this EIR as Appendix K.

3.13.1 Environmental Setting
Noise
Factors that influence sound as it is perceived by the human ear, include the actual level of sound, period of exposure, frequencies involved, and fluctuation in the noise level during exposure. Noise is measured on a decibel scale, which serves as an index of loudness. The zero on the decibel scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Each 10 decibel increase in sound level is perceived as approximately a doubling of loudness. Because the human ear cannot hear all pitches or frequencies, sound levels are frequently adjusted or weighted to correspond to human hearing. This adjusted unit is known as the A-weighted decibel, or dBA.

Since excessive noise levels can adversely affect human activities and human health, federal, state, and local governmental agencies have set forth criteria or planning goals to minimize or avoid these effects. Noise guidelines are generally expressed using one of several noise averaging methods, including Leq, DNL, or CNEL.66 These descriptors are used to measure a location’s overall noise exposure, given that there are times when noise levels are higher (e.g., when a jet is taking off from an airport or when a leaf blower is operating) and times when noise levels are lower (e.g., during lulls in traffic flows on freeways or in the middle of the night). Lmax is the maximum A-weighted noise level during a measurement period.

Vibration
Ground vibration consists of rapidly fluctuating motions or waves with an average motion of zero.

Vibration amplitude can be quantified using Peak Particle Velocity (PPV), which is defined as the maximum instantaneous positive or negative peak of the vibration wave. PPV has been routinely used to measure and assess ground-borne construction vibration. Studies have shown that the threshold of perception for average persons is in the range of 0.008 to 0.012 inches/second (in/sec) PPV.

3.13.1.1 Regulatory Framework
Federal
Federal Transit Administration Vibration Limits
The Federal Transit Administration (FTA) has developed vibration impact assessment criteria for evaluating vibration impacts associated with transit projects. The FTA has proposed vibration impact 66 Leq is a measurement of average energy level intensity of noise over a given period of time. Day-Night Level (DNL) is a 24-hour average of noise levels, with a 10 dB penalty applied to noise occurring between 10:00 PM and 7:00 AM. Community Noise Equivalent Level (CNEL) includes an additional five dB applied to noise occurring between 7:00 PM and 10:00 PM. Where traffic noise predominates, the CNEL and DNL are typically within two dBA of the peak-hour Leq.

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criteria based on maximum overall levels for a single event. The impact criteria for groundborne vibration are shown in Table 3.13-1 below. These criteria can be applied to development projects in jurisdictions that lack vibration impact standards.

Table 3.13-1: Groundborne Vibration Impact Criteria
Land Use Category
Groundborne Vibration Impact Levels
(VdB inch/sec)
Frequent
Event
Occasional
Events
Infrequent
Events
Category 1: Buildings where vibration would interfere
with interior operations 65 65 65
Category 2: Residences and buildings where people
normally sleep 72 75 80
Category 3: Institutional land uses with primarily
daytime use 75 78 83
Source: Federal Transit Administration. Transit Noise and Vibration Assessment Manual. September 2018.

State
California Building Standards Code
The CBC establishes uniform minimum noise insulation performance standards to protect persons within new buildings housing people, including hotels, motels, dormitories, apartments, and dwellings other than single-family residences. Title 24 mandates that interior noise levels attributable to exterior sources not exceed 45 Ldn/CNEL in any habitable room. Exterior windows must have a minimum Sound Transmission Class (STC) of 40 or Outdoor-Indoor Transmission Class (OITC) of 30 when the property falls within the 65 dBA DNL noise contour for a freeway or expressway, railroad, or industrial source.

California Green Building Standards Code
For commercial uses, CALGreen (Section 5.507.4.1 and 5.507.4.2) requires that wall and roofceiling assemblies exposed to the adjacent roadways have a composite STCrating of at least 50 or a composite OITC rating of no less than 40, with exterior windows of a minimum STC of 40 or OITC of 30 when the commercial property falls within the 65 dBA Ldn or greater noise contour for a freeway or expressway, railroad, or industrial or stationary noise source. The state requires interior noise levels to be maintained at 50 dBA Leq(1-hr) or less during hours of operation at a proposed commercial use.

Local
Comprehensive Airport Land Use Compatibility Plan for the Environs of the San Francisco International Airport
As discussed in more detail in Section 4.10 Land Use, the project site is located within the Airport

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Influence Area (AIA) of the San Francisco International Airport (SFO). Properties within the AIA may be subject to some of the annoyances or inconveniences associated with proximity to airport operations (e.g., noise, vibration, and odors). The airport/land use compatibility of a proposed development or land use policy action shall be determined by comparing the proposed development or land use policy action with the safety compatibility criteria, noise compatibility criteria, and airspace protection/height limitation criteria in the ALUCP. The site is located outside of the SFO 65 dB CNEL noise contour.

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 noise and vibration impacts and are applicable to the proposed project.

Policy/Task Description
Policy NE-1 Use the future noise contour map to identify existing and potential noise impact areas.

Task NE-2.1 Use the Noise Control Guidelines to assess the suitability of a site for new development in combination with the noise contours to accurately identify areas that may need additional noise study and mitigation. Noise mitigations include additional insulation, double glazing of windows and increasing building setbacks from the noise source. Mitigations should also be creative and attractive whenever possible and appropriate. Creative noise mitigation measures can include incorporation of fountains using water to mask freeway noise and noise walls of an appropriate scale painted with decorative murals.

Policy NE-3 Maintain a CNEL level of not more than 70 dBA Leq in residential areas Task NE-3.1 Continue to enforce the environmental noise requirements of the State Building Code (Title 24).

Policy NE-4 Maintain a noise level not in excess of 75 dBA CNEL in open space, parks, and tot lots, including outdoor activity areas such as outdoor entertainment or green space of multi-family projects.

Policy NE-5 Maintain the City’s current standard of 75 dBA CNEL for office, commercial, and professional areas.

Task NE-5.1 Additional noise studies should be conducted in “Conditionally Acceptable” noise environments to ensure adequate mitigation features are employed. Usually conventional construction with closed windows and fresh air supply systems will maintain a healthy noise environment.

Policy NE-6 Require new development to perform additional acoustical studies in noise environments that are identified as ‘Conditionally Acceptable’ or ‘Normally Unacceptable’ to the Guidelines.

Policy NE-9 Work to ensure that the expansion of or changes to existing land uses do not create additional noise impacts for sensitive receptors in the vicinity of the project from intensification or alteration of existing land uses by requiring applicants.

Task NE-9.1 Depending upon the hours of operation, intensity of use, and the location of sensitive receptors in the area, the expansion or change of use could cause noise impacts.

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Policy/Task Description
Acoustical studies should be performed, at the applicant’s expense, during the discretionary and environmental review processes and conditions should be placed on the project accordingly.

Task HE-4.2 For all development proposals with the 65dB CNEL noise contour, the City shall require a noise study that identifies the proposed project’s compliance with requirement of Task 4.1. If the project qualifies for review under the California Environmental Quality Act (CEQA), the City shall incorporate the noise study and any mitigation measures into the CEQA document and shall adopt findings that the project, as conditioned, complies with the interior noise level requirement.

Task NE-11.3 Require all future development within the Airport Influence Area B boundary for San Francisco International Airport to conform to the relevant height/airspace protection, aircraft noise, and safety policies and land use compatibility criteria contained within the most recent adopted version of the comprehensive airport/land use compatibility plan (ALUCP) for the environs of San Francisco International Airport.

Daly City Municipal Code
Title 9 – Public Peace, Morals and Welfare
Chapter 9.22 of the Daly City Municipal Code contains language to protect residents from excessive noise exposure. Section 9.22.010 prohibits an individual from causing a disturbance such that it disturbs the public peace off-site. Section 9.22.020 states that no person shall maintain, operate, or conduct any loudspeaker or amplifier in such a manner as to cause the sound to be projected outside any building or out of doors in any part of the City without first obtaining a permit to do so. Section

9.22.030 deals more specifically with noise and states that between the hours of 10:00 p.m. and 6:00 a.m. no person shall cause, create, or permit any noise which may be heard beyond the confines of the property of origin. The Police Department enforces Chapter 9.22 of the Municipal Code.

Title 15 – Buildings and Construction
Section 15.00.130 requires any home, constructed after January 1, 1993 or renovated at a cost equal to twenty-five percent or more of the value of the home and located within the 65 CNEL (FAA approved) contour map that is illustrated on the Aircraft Noise Soundproofing Project Area Map, must be insulated to meet standards applied in noise insulation programs supported by the Federal Aviation Administration. The project site is not within the 65 CNEL noise contour.

Title 17 – Zoning
Title 17 of the Daly City Municipal Code provides for discretionary review of projects through the use permit and variance process. An application for development is analyzed in light of many concerns including comparing the proposed use against the noise contours and Noise Compatibility Guidelines. The Planning Division attaches conditions of project approval to reduce noise impacts to future occupants of the proposed development as well as conditioning times construction activities may occur in order to reduce noise impacts to surrounding land uses.

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3.13.1.2 Existing Conditions
The project site is bounded by Serramonte Boulevard and residences to the north, a variety of institutional, quasi-public, and commercial uses to the east and south, and residences to the south and west. The primary noise source in the project area is traffic from the surrounding highways and roadways and aircraft departures from SFO.

A noise monitoring survey was conducted between December 7, 2021 and December 9, 2021 to document existing noise conditions within and around the project site. The noise monitoring survey included three long-term noise measurements (LT-1 through LT-3) and four short-term noise measurements (ST-1 through ST-4). Noise measurement locations are shown in Figure 3.13-1.

Long-term noise measurement LT-1 was made south of the proposed project, in the developed portion of the 1985 Precise Plan adjacent to the Serramonte Ridge Apartment Homes complex, about 66 feet west of the Campus Drive centerline and about 400 feet northwest of the Hickey Boulevard centerline. Hourly average noise levels typically ranged from 59 to 65 dBA Leq during daytime hours and from 49 to 61 dBA Leq at night.

Long-term noise measurement LT-2 was conducted just south of the proposed project near the eastern edge of the developed portion of the 1985 Precise Plan and adjacent to the Young World Preschool & Childcare parking lot, about 132 feet west of the Callan Boulevard centerline. Hourly average noise levels at this location typically ranged from 59 to 65 dBA Leq during the day and from 46 to 62 dBA Leq at night.

Long term noise measurement LT-3 was conducted at the northern portion of the proposed project in Parcel B, about 85 feet south of the Serramonte Boulevard centerline. Hourly average noise levels at this location typically ranged from 62 to 67 dBA Leq during the day and from 47 to 65 dBA Leq at night.

The results of the four short-term noise measurements and their locations are summarized in Table

3.13-2 below.

Table 3.13-2: Summary of Short-Term Measurements (dBA)
Noise Measurement Location Lmax L(1) L(10) L(50) L(90) Leq(10) ST-1: ~250 feet from Callan Boulevard
Centerline, 230 feet from the Serramonte
Boulevard Centerline
65 62 59 55 53 56
ST-2: ~40 feet from Serramonte Boulevard
Centerline 79 70 65 60 56 63
ST-3: ~80 feet from St. Francis Boulevard
Centerline 63 59 56 54 52 55
ST-4: ~100 feet from the Campus Drive
Centerline 75 74 62 52 47 61

LT-3
LT-1
ST-2
LT-2
ST-3 ST-4
ST-1
Higate Drive Serramonte Boulevard St. Francis Boulevard Callan Boulevard
Campus Drive
Hickey Boulevard
Serramonte Boulevard
St. Francis Boulevard
Callan Boulevard
C
a
m
pus Drive
Hickey Boulevard
1 35
NOISE MONITORING LOCATIONS FIGURE 3.13-1
Aerial Source: Google Earth Pro, Apr. 30, 2021. Photo Date: Sep. 2020 Project Boundary
LT-# Long-Term Noise Monitoring Location
ST-# Short-Term Noise Monitoring Location
0 100 400 600 800 Feet

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3.13.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on noise, would the project result in:
1) 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?
2) Generation of excessive groundborne vibration or groundborne noise levels? 3) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
For the purposes of this analysis, the City of Daly City relies on the following CEQA thresholds of significance as related to noise:
• A significant noise impact would be identified if the project would generate a substantial temporary or permanent noise level increase over ambient noise levels at existing noisesensitive receptors surrounding the project site and that would exceed applicable noise standards presented in the General Plan or Municipal Code at existing noise-sensitive receptors surrounding the project site.
o A potentially significant impact would occur if the project generated noise levels would result in a substantial temporary or periodic increase in ambient noise levels above current levels.
o A temporary construction noise impact would be considered significant if project construction activities produced noise levels exceeding 90 dBA Leq at residential land uses or 100 dBA Leq at commercial land uses surrounding the site.67 o A significant permanent noise level increase would occur if project-generated traffic generated by the project or project improvements/operations would substantially increase noise levels at sensitive receivers in the vicinity. A substantial increase would occur if: a) the noise level increase is five dBA CNEL or greater, with a future noise level of less than the “normally acceptable” standard, or b) the noise level increase is three dBA CNEL or greater, with a future noise level equal to or greater than the “normally acceptable” standard.
o A significant noise impact would be identified if the project would expose persons to or generate noise levels that would exceed applicable noise standards presented in the General Plan or Municipal Code.
• A significant impact would be identified if the construction of the project would generate excessive vibration levels surrounding receptors. Ground-borne vibration levels exceeding

0.3 in/sec PPV would have the potential to result in cosmetic damage to normal buildings. 67 Federal Transit Administration. Transit Noise and Vibration Impact Assessment Manual. 2018.

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• A significant noise impact would be identified if the project would expose people residing or working in the project area to excessive aircraft noise levels.

3.13.2.1 Project Impacts
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)
Construction Noise
Construction of the proposed project would include demolition of existing structures, excavation and grading, and construction of new buildings. The majority of construction noise would be generated by the operation of equipment and heavy machinery, such as bull dozers, backhoes, and auger drills.

This type of construction equipment could generate noise ranging from 70 to 90 dBA at a distance of 50 feet away. The project would be built out over several phases, with the Parcel B Development project being constructed first and taking approximately 24 months to complete. The remaining development on Parcels C-F are assumed to be built in two phases (Parcels C and D, followed by Parcels E and F).

Noise modeling for buildout of the Precise Plan (refer to Appendix K) assumed worst-case conditions, in that all equipment per phase of construction would be operating simultaneously. As discussed in Section 3.3 Air Quality, construction equipment assumed in the noise modeling was based on CalEEMod default equipment and schedule information for a project of this type and size per phase. For construction noise, the use of multiple pieces of equipment simultaneously would add together as a collective noise source. While every piece of equipment per phase would likely be scattered throughout the site, the noise-sensitive receptors surrounding the site would be subject to the collective noise source generated by all equipment operating at once. Therefore, to assess construction noise impacts at the receiving property lines of noise-sensitive receptors, the worst-case hourly average noise level for each phase was centered on the site and extrapolated to the nearest property line of the surrounding land uses.

The nearest noise sensitive receptors are residential buildings the north, west, and south, as well as a school to the south of the project site. Ambient noise levels in the project area range from 46 to 67 dBA Leq. Since the proposed project would be built out over phases, construction noise and location would vary by phase. Table 3.13-3 through Table 3.13-5 summarizes the equipment expected to be used for each construction phase (Parcels B-F), duration of construction, and estimated noise levels from the center of each phase to the property lines of the surrounding land uses. As each Parcel is proposed for development, the assumptions used for purposes of this analysis would be revisited to confirm they are accurate in evaluating and disclosing the impacts of constructing that phase, and to the extent the specific construction details differ from what was evaluated in this EIR, additional analysis would be completed to fully evaluate the proposed development to identify any additional noise controls that would be necessary, if at all, for the construction activity to avoid impacting

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nearby sensitive uses, including earlier phases of the Precise Plan that were at that point occupied and could be impacted by construction activity elsewhere under the Precise Plan.

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Table 3.13-3: Parcel B Construction Phase Noise Levels
Phase Time Duration Construction
Equipment (Quantity)
Calculated Hourly Average Leq at Residence, dBA
South
Parcel C/D
(215 ft)
North Multi-Family
Residential
(220 ft)
West Parcel A
(250 ft)
East
Cemetery
(505 ft)
Demolition 7/3/2021-
7/28/2023
Concrete/Industrial Saw (1)
Excavator (3)
Rubber-Tired Dozer (2)
80 79 78 72
Site Preparation 7/29/2023-
8/11/2023
Rubber-Tired Dozer (3)
Tractor/Loader/Backhoe (4) 74 74 73 66
Grading/
Excavation
8/12-2023-
9/8/2023
Excavator (1)
Grader (1)
Rubber Tired Dozer (1)
Tractor/Loader/Backhoe (3)
70 70 69 63
Trenching/
Foundation
9/9/2023-
10/6/2023
Tractor/Loader/Backhoe (1)
Excavator (1) 74 73 72 66
Building - Exterior 10/7/2023-
8/23/2024
Crane (1)
Forklift (3)
Generator set (1)
Tractor/Loader/Backhoe (1)
Welder (1)
77 77 76 70
Building-Interior/
Architectural coating
8/24/2024-
9/20/2024 Air Compressor (3) 58 to 77 a 58 to 77 a 56 to 76 a 50 to 70 a Paving 9/21/2024-
10/18/2024
Paver (2)
Paving Equipment (2)
Roller (2)
71 b 71 b 69 to 70 b 63 to 64 b
a. The range of construction noise levels represents the levels during the Building-Interior/Architectural Coating phase only and combined with the Building-Exterior phase. b. The range of construction noise levels represents the levels during the Paving phase only and combined with the Building-Interior/Architectural Coating and BuildingExterior phases.

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Table 3.13-4: Parcel C/D Construction Phase Noise Levels Phase Time Duration Construction
Equipment (Quantity)
Calculated Hourly Average Leq at Residence, dBA
East Parcel
E
(195 ft)
North Parcel B
(280 ft)
South School
(290 ft)
East
Cemetery
(500 ft)
Demolition 25 Days
Concrete/Industrial Saw (1)
Excavator (3)
Rubber-Tired Dozer (2)
80 77 77 72
Site Preparation 13 Days Rubber-Tired Dozer (3)
Tractor/Loader/Backhoe (4) 75 72 71 67
Grading/
Excavation 41 Days
Excavator (1)
Grader (1)
Rubber Tired Dozer (1)
Tractor/Loader/Backhoe (3)
80 77 77 72
Trenching/
Foundation 42 Days Tractor/Loader/Backhoe (1)Excavator (1) 67 64 64 59 Building - Exterior 61 Days
Crane (1)
Forklift (3)
Generator set (1)
Tractor/Loader/Backhoe (1)
Welder (1)
78 75 75 70
Building-Interior/
Architectural coating 34 Days Air Compressor (3) 59 to 78 a 55 to 75 a 55 to 75 a 50 to 70 a Paving 42 Days
Paver (2)
Paving Equipment (2)
Roller (2)
72 b 68 to 69 b 68 b 63 to 64 b
a. The range of construction noise levels represents the levels during the Building-Interior/Architectural Coating phase only and combined with the Building-Exterior phase. b. The range of construction noise levels represents the levels during the Paving phase only and combined with the Building-Interior/Architectural Coating and BuildingExterior phases.

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Table 3.13-5: Parcel E/F Construction Phase Noise Levels Phase Time Duration Construction
Equipment (Quantity)
Calculated Hourly Average Leq at Residence, dBA
North
Parcel A
(240 ft)
South Multi-Family
Residential
(280 ft)
East Parcel C/D
(250 ft)
West Single
Family
(465 ft)
Demolition 25 Days
Concrete/Industrial Saw (1)
Excavator (3)
Rubber-Tired Dozer (2)
75 73 69 69
Site Preparation 13 Days Rubber-Tired Dozer (3)
Tractor/Loader/Backhoe (4) 73 72 68 67
Grading/
Excavation 41 Days
Excavator (1)
Grader (1)
Rubber Tired Dozer (1)
Tractor/Loader/Backhoe (3)
71 70 66 65
Trenching/
Foundation 42 Days Tractor/Loader/Backhoe (1)Excavator (1) 65 64 60 59 Building - Exterior 61 Days
Crane (1)
Forklift (3)
Generator set (1)
Tractor/Loader/Backhoe (1)
Welder (1)
76 75 71 71
Building-Interior/
Architectural coating 34 Days Air Compressor (3) 57 to 76 a 55 to 75 a 51 to 71 a 51 to 71 a Paving 42 Days
Paver (2)
Paving Equipment (2)
Roller (2)
70 b 68 to 69 b 64 to 65 b 64 b
a. The range of construction noise levels represents the levels during the Building-Interior/Architectural Coating phase only and combined with the Building-Exterior phase. b. The range of construction noise levels represents the levels during the Paving phase only and combined with the Building-Interior/Architectural Coating and BuildingExterior phases.

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As shown in Table 3.13-3 through Table 3.13-5 above, construction of the proposed project during each phase (none overlapping) could generate noise levels that exceed ambient noise levels by five dBA Leq during construction; however, construction noise levels would not exceed 90 dBA Leq at residential land uses or 100 dBA Leq at commercial land uses surrounding the project site. The project would be required to implement Best Management Practices (BMPs). BMPs are required at the time of building permit issuance for all development and would reduce any impacts of additional noise level exposure to insignificance. Such BMPs include requirements for construction vehicles and equipment to be properly muffled. Construction hours would be limited to 8:00 AM to 5:00 PM, Mondays through Fridays. Construction on weekends and holidays will be prohibited to avoid inconveniencing neighbors. To ensure construction noise impacts do not exceed acceptable levels, the following mitigation measure would be implemented for each phase of development, i.e. each Parcel.

Mitigation Measure:

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 noisegenerating 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.
• Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noisesensitive 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.

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• 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 noisegenerating 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.

With implementation of MM NIO-1.1 above, the proposed project would reduce construction noise to a less than significant level.

Operational Noise
Traffic Noise
The ambient noise environment near the school areas as measured by LT-2 resulted in a noise level of 63 dBA CNEL. The existing ambient noise environment measured at LT-1 and LT-3 near multifamily residential areas resulted in noise levels ranging from 65-66 dBA CNEL. A significant impact would occur if project-generated traffic increased levels by three dBA CNEL or more. For reference, a three dBA CNEL noise increase would be expected if the project would double existing traffic volumes along a roadway.

As discussed further in Section 3.15 Transportation, implementation of the proposed project would result in an increase in traffic along surrounding streets. Based on these traffic changes, the project is estimated to result in a maximum noise level increase of two dBA CNEL along all roadways in the project area; therefore, project traffic noise would be below the three dBA CNEL impact threshold.

As a result, the traffic noise generated by the proposed project would have a less than significant impact.

Mechanical Equipment
The project would include various mechanical equipment such as air conditioners, exhaust fans, chillers, pumps, and air handling equipment located on the roofs of the proposed buildings.

Mechanical equipment on the roofs of future buildings on Parcels B, C, D, E, and F are estimated to produce noise levels of approximately 75 dBA at five feet. The nearest building façades to all parcels would be approximately 80 feet away. At this distance, unshielded noise levels would be approximately 51 dBA or 60 dBA CNEL. Existing ambient noise levels exceed 60 dBA CNEL;

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therefore, noise from mechanical equipment associated with the proposed project would be below ambient conditions and have a less than significant noise impact.

Emergency Generators
Emergency generators are proposed to be located on Parcels B, D, E, and F. Generators would be located either in the basement or on the ground floor. For the purposes of this analysis, it was conservatively assumed the generators would be located on the ground floor and would be rated at approximately 750 Kilowatts (kW), would be powered by a 60 hertz (Hz) diesel engine, and would be fitted with a manufacturer’s acoustical enclosure. Based on file data, sound pressure levels from the generator would be approximately 75 dBA at 5 feet assuming an acoustic enclosure.

Emergency generators are tested monthly for a period of one hour between 7:00 AM and 10:00 PM.

Table 3.13-6 below summarizes noise levels at surrounding receptors during the testing period for generators located on Parcels B, D, E, and F.

Table 3.13-6: Noise Levels for Monthly Tests of the Emergency Generators Receptor Distance from Center of the
Generator Room Leq, dBA CNEL, dBA
Parcel B
Parcel C/D, south 80 feet 51 47
Parcel A, west 100 feet 49 45
Multi-Family
Residential, north 135 feet 46 42
Cemetery, east 400 feet <40 <40
Parcel D
Parcel B, north 80 feet 51 47
Parcel E, west 100 feet 49 45
Cemetery, east 230 feet 42 <40
Parcel E
Parcel C/D, east 80 feet 51 47
Multi-Family, south 90 feet 50 46
Parcel F, west 100 feet 49 45
Parcel A, north 250 feet 41 <40
Parcel F
Parcel A, north 60 feet 53 49
Parcel E, east 80 feet 51 47

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Table 3.13-6: Noise Levels for Monthly Tests of the Emergency Generators Receptor Distance from Center of the
Generator Room Leq, dBA CNEL, dBA
Multi-Family, south 100 feet 48 44
Single Family, west 170 feet 44 40
As shown in Table 3.13-6 above, emergency generator noise during testing would not exceed 53 dBA Leq or 49 dBA CNEL at any adjacent receptor. This would be below the existing ambient noise levels at the surrounding receptors; therefore, emergency generator noise would be less than significant. (Less than Significant Impact with Mitigation Incorporated) Impact NOI-2: The project would not result in generation of excessive groundborne vibration or groundborne noise levels. (Less than Significant Impact) Future development under the project may generate perceptible vibration in the immediate vicinity when heavy equipment or impact tools (e.g. jackhammers, hoe rams) are used. Construction activities would include site demolition work, preparation work, excavation of below-grade levels, foundation work, and new building framing and finishing. Construction activities, such as the use of jackhammers, rock drills and other high-power or vibratory tools, and rolling stock equipment (tracked vehicles, compactors, etc.), may generate substantial vibration in the immediate vicinity.

Vibration levels would vary depending on soil conditions (e.g., rocks vs. soft soil), construction methods (the project does not propose pile driving), the equipment used (e.g., vibratory roller vs. small bulldozers and graders), and distance.

The City does not define quantitative vibration thresholds; therefore, a conservative vibration limit of

0.3 in/sec PPV has been used, consistent with California Department of Transportation guidelines.

Table 3.13-7 below summarizes the vibration levels at the nearest building facades around the project site.

Table 3.13-7: Vibration Source Levels for Construction Equipment Equipment
PPV at
25 ft.
(in/sec)
Vibration Levels at Nearest Surrounding Building Façades (in/sec PPV)
South
Residential
(20 ft)
East
Commercial
(60 ft)
Southeast
Residential
(75 ft)
West
Residential
(85 ft)
Clam shovel drop 0.202 0.258 0.077 0.060 0.053
Hydromill
(slurry wall)
In soil 0.008 0.010 0.003 0.002 0.002
In rock 0.017 0.022 0.006 0.005 0.004
Vibratory Roller 0.21 0.268 0.080 0.063 0.055
Hoe Ram 0.089 0.114 0.034 0.027 0.023
Large bulldozer 0.089 0.114 0.034 0.027 0.023
Caisson drilling 0.089 0.114 0.034 0.027 0.023

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Table 3.13-7: Vibration Source Levels for Construction Equipment Equipment
PPV at
25 ft.
(in/sec)
Vibration Levels at Nearest Surrounding Building Façades (in/sec PPV)
South
Residential
(20 ft)
East
Commercial
(60 ft)
Southeast
Residential
(75 ft)
West
Residential
(85 ft)
Loaded trucks 0.076 0.097 0.029 0.023 0.020
Jackhammer 0.035 0.045 0.013 0.010 0.009
Small bulldozer 0.003 0.004 0.001 0.001 0.001
As shown in Table 3.13-7, vibration levels at nearby buildings would not exceed 0.3 in/sec PPV.

Thus, construction vibration impacts would be less than significant. (Less than Significant Impact) Impact NOI-3: The project would not be located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport. The project would not expose people residing or working in the project area to excessive noise levels. (Less than Significant Impact)
The SFO airport is located approximately five miles southeast of the project site. The project site is located outside the 65 dBA CNEL noise contour of SFO; however, the project site is located within the 60 dBA CNEL noise contour. The interpolated CNEL noise levels due to aircraft flyovers is estimated to be 63 DBA, which is consistent with the City’s 65 dBA CNEL threshold for aircraft noise (General Plan Task HE-4.2). (Less than Significant Impact)

3.13.2.2 Cumulative Impacts
Impact NOI-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant noise impact. (Less than Significant Cumulative Impact)
Construction
While cumulative projects could be constructed at the same time as the proposed project and result in a temporary construction noise increase, all projects in the City would be required to comply with the City’s Municipal Code, as well as implement similar measures as those identified under Impact NOI1. Nevertheless, if the proposed project’s construction schedule were to overlap one or more of the cumulative projects’ construction schedules for a consecutive 12 months or more and if the same sensitive receptors were impacted, the project would have a cumulatively considerable contribution to a cumulative construction noise impact.

This would not occur, however, as the nearest cumulative project for which construction timeframes could overlap is the Serramonte Condominiums and Hotel project located at 525-595 Serramonte Boulevard, 500 feet northeast of the project site. These projects would have a similar nearest sensitive receptor, located across Serramonte Boulevard north of the project site; however, construction of the Serramonte Condominiums and Hotel project is anticipated to last only 18 months

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and start construction before the proposed project. Thus, construction schedules would not overlap one or more years and a significant noise and vibration impact would not occur. (Less than Significant Cumulative Impact)

3.13.3 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 because the City of Daly City has policies that address existing noise conditions affecting a proposed project.

Exterior Noise
The exterior noise threshold established in the City’s General Plan for new residential uses is 70 dBA CNEL, for commercial uses it is 75 dBA CNEL, and for open space it is 75 dBA CNEL. Noise affecting the project site under future conditions will continue to be vehicular traffic on Serramonte Boulevard and Callan Boulevard, and aircraft noise from SFO. Based on the transportation impact assessment prepared for the project, noise along Serramonte Boulevard and Callan Boulevard from growth in future traffic volumes is expected to increase by approximately one to two dBA CNEL above existing conditions. Existing ambient noise levels at the project site are at most 67 dBA CNEL; therefore, future noise levels at the project site would be at or below the 70 dBA CNEL threshold for residential uses and below the 75 dBA CNEL threshold for commercial and open space uses.

Parcel B Development Project
The Parcel B Development project includes a podium plaza and a rooftop terrace as outdoor uses for the residential units. The podium plaza would be bounded on three sides by the proposed building, to the north, west, and south, which would ensure noise levels at the plaza would be below the 70 dBA CNEL threshold. The rooftop terrace is located at the southeast corner of the building and would face Callan Boulevard. Noise levels at this height and location are estimated to be below the 70 dBA CNEL threshold as well.

The Parcel B Development Project also includes a public park and trail system along the eastern portion of Parcel B, facing Callan Boulevard. As discussed above, future ambient noise levels at the project site (with the addition of project traffic) would be 70 dBA CNEL or less; therefore, the noise levels at the public park would be below the 75 dBA CNEL noise threshold.

A retail plaza would also be located along the western side of the proposed Parcel B Development project. This retail plaza would be facing Serramonte Boulevard; however, future ambient noise levels at the project site (with the addition of project traffic) would be 70 dBA CNEL or less; therefore, the noise levels at the retail plaza would be below the 75 dBA CNEL noise threshold.

Precise Plan
Future development under the proposed Precise Plan on Parcels C, D, E, and F would include additional housing, commercial space, public parks, and trails along the perimeter of the project site.

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While specific development plans are currently unavailable, future noise levels at these locations are expected to be less than or equal to Parcel B because they are no closer to major noise sources than Parcel B. As discussed above, exterior noise levels at Parcel B would meet City thresholds for exterior noise levels for residential, commercial, and open space uses. Thus, future noise levels on Parcel C, D, E, and F would also meet City thresholds.

Interior Noise
The California Building Code establishes an interior noise threshold of 45 dBA CNEL for multifamily residential units. The California Green Building Standards Code (CALGreen) requires that interior noise levels be maintained at 50 dBA Leq(1-hr) or less during hours of operation within the proposed non-residential spaces within the proposed mixed-use buildings.

Parcel B Development Project
For the proposed residential portion of the Parcel B Development project, the residential building would be setback approximately 80 feet from the centerline of Serramonte Boulevard and have direct line-of-sight to the roadway. At this distance, units along the northern façade would be exposed to noise levels of 66 dBA CNEL. When aircraft noise is added, northern façade units would be exposed to noise levels of 68 dBA CNEL. The eastern façade of the proposed residential building would be setback approximately 330 feet from Callan Boulevard and have direct line-of-sight to the roadway.

At this distance, units along the east façade would be exposed to noise levels of 63 dBA CNEL.

When aircraft noise is added, eastern façade units would be exposed to noise levels of 66 dBA CNEL. The western and southern facades of the proposed residential building do not have direct line of sight to any surrounding roadways. The units along these facades would be exposed to future exterior roadway noise levels of up to 60 dBA CNEL. The combined roadway and aircraft noise level at the eastern façade of the proposed building would be 65 dBA CNEL.

Assuming standard construction with windows open, the future interior level for the rooms facing the roadways is expected to be 53 dBA CNEL at the northern façade, 51 dBA CNEL at the eastern façade, and 50 dBA CNEL at the southern and western façades. With windows closed, the future interior level would range from 43 to 48 dBA CNEL at the northern façade, 41 to 46 dBA CNEL at the eastern façade, and 40 to 45 dBA CNEL at the southern and western façades. The proposed residential units would thus require noise insulation features and forced-air mechanical ventilation systems to meet the state’s interior noise threshold of 45 dBA CNEL to allow residents to maintain windows in the closed position. With implementation of the below condition of approval (specific to the Parcel B Development project), interior noise levels would meet the state’s interior noise standard of 45 dBA CNEL.

Parcel B Development Project Condition of Approval:
• Provide a suitable form of forced-air mechanical ventilation, as determined by the local building official, for all residential buildings, so that windows can be kept closed to control noise.
• Provide sound-rated windows and doors for the northern façade of the proposed building to maintain interior noise levels or below the City’s 45 dBA CNEL interior noise threshold.

Preliminary calculations show that sound-rated windows and doors with minimum STC

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ratings of 30 would be satisfactory for units facing Serramonte Boulevard to meet the interior noise threshold. Standard residential grade windows and doors (minimum STC 26) would be required for all remaining units.
• A qualified acoustical specialist shall prepare a detailed analysis of interior residential noise levels resulting from all exterior sources during the final design phase of the project pursuant to requirements set forth in the General Plan and State Building Code. The study will review the final site plan, building elevations, and floor plans prior to construction and confirm building treatments necessary to reduce interior noise levels to 45 dBA CNEL or less.

Treatments would include, but are not limited to, sound-rated windows and doors as specified above, acoustical caulking, protected ventilation openings, etc. The specific determination of what noise insulation treatments are necessary shall be conducted on a unit-by-unit basis during final design of the project. Results of the analysis, including the description of the necessary noise control treatments, shall be submitted to the City, along with the building plans and approved design, prior to issuance of a building permit.

The ground floor of the proposed residential building would be used for commercial purposes.

Standard construction materials for commercial uses would provide about 25 to 30 dBA of noise reduction in interior spaces assuming the inclusion of adequate forced-air mechanical ventilation systems. With a setback of about 80 feet from Serramonte Boulevard and 330 feet from Callan Boulevard, the future exterior roadway noise along the commercial use façades are expected to range from 64 to 67 dBA Leq(1-hr). The combined roadway and aircraft noise level at the eastern façade of the proposed building would range from 69 to 70 dBA Leq (1-hr). Using standard construction materials with the inclusion of forced-air mechanical ventilation, interior noise levels at the commercial use portion would range from 37 to 45 dBA Leq(1-hr) during the peak daytime hour. This would meet the CALGreen threshold of 50 dBA Leq(1-hr) or less during hours of operation.

Precise Plan
Parcels C and D have direct lines of sight to Callan Boulevard, with a setback of approximately 150 feet from the centerline. At this distance, the Parcels C and D would be exposed to a future exterior roadway noise level of up to approximately 66 dBA CNEL. The combined roadway and aircraft noise level at the eastern façade of future buildings on Parcels C and D would be 68 dBA CNEL.

Assuming standard construction with windows open, the future interior noise level for residential units facing the roadway is expected to be 53 dBA CNEL. With windows closed, the future interior level would range from 43 to 48 dBA CNEL. In order to allow residents to maintain windows in the closed position for noise control, the proposed residential units would thus require noise insulation features and forced-air mechanical ventilation systems to meet the City’s interior noise thresholds.

With implementation of the below condition of approval (specific to future development under the proposed Precise Plan), interior noise levels would meet the state’s interior noise standard of 45 dBA CNEL.

Precise Plan Condition of Approval:
• Provide a suitable form of forced-air mechanical ventilation, as determined by the local building official, for all residential buildings, so that windows can be kept closed to control noise.

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• Provide sound-rated windows and doors for Parcels C and D to maintain interior noise levels or below the City’s 45 dBA CNEL interior noise threshold. Preliminary calculations show that sound-rated windows and doors with minimum STC ratings of 30 would be satisfactory for units facing Callan Boulevard to meet the interior noise threshold. Standard residential grade windows and doors (minimum STC 26) would be required for all remaining units. • A qualified acoustical specialist shall prepare a detailed analysis of interior residential noise levels resulting from all exterior sources during the final design phase of the project pursuant to requirements set forth in the General Plan and State Building Code. The study will review the final site plan, building elevations, and floor plans prior to construction and confirm building treatments necessary to reduce interior noise levels to 45 dBA CNEL or less.

Treatments would include, but are not limited to, sound-rated windows and doors as specified above, acoustical caulking, protected ventilation openings, etc. The specific determination of what noise insulation treatments are necessary shall be conducted on a unit-by-unit basis during final design of the project. Results of the analysis, including the description of the necessary noise control treatments, shall be submitted to the City, along with the building plans and approved design, prior to issuance of a building permit.

Parcels E and F do not have direct line of sight to any surrounding roadways; thus, future development on these parcels would be exposed to a combined roadway and aircraft noise level of 64 dBA CNEL. Assuming standard construction with windows open, the future interior levels for the residential units is expected to be 49 dBA CNEL. With windows closed, the future interior noise level would range from 39 to 44 dBA CNEL, which would meet the state’s interior noise threshold of 45 dBA CNEL.

Parcels C, D, E, and F could also include commercial uses on the ground floor of future residential buildings. Commercial uses on Parcels C and D would be exposed to a combined roadway and aircraft noise level of 69 to 70 dBA Leq (1-hr). Using standard construction materials with the inclusion of forced-air mechanical ventilation, interior noise levels at the commercial use portion of Parcels C and D would range from 37 to 45 dBA Leq(1-hr) during the peak daytime hour. Commercial uses on Parcels E and F would be exposed to a combined roadway and aircraft noise level of up to 65 dBA Leq (1-hr). Using standard construction materials with the inclusion of forced-air mechanical ventilation, interior noise levels at the commercial use portion of Parcels E and F would range from 35 to 40 dBA Leq(1-hr) during the peak daytime hour. Based on the above discussion, future commercial uses on Parcel C, D, E, and F would meet the CALGreen threshold of 50 dBA Leq(1-hr) or less during hours of operation.

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3.14 POPULATION AND HOUSING

3.14.1 Environmental Setting

3.14.1.1 Regulatory Framework
State
Housing-Element Law
State requirements mandating that housing be included as an element of each jurisdiction’s general plan is known as housing-element law. The Regional Housing Need Allocation (RHNA) is the statemandated process to identify the total number of housing units (by affordability level) that each jurisdiction must accommodate in its housing element. California housing-element law requires cities to: 1) zone adequate lands to accommodate its RHNA; 2) produce an inventory of sites that can accommodate its share of the RHNA; 3) identify governmental and non-governmental constraints to residential development; 4) develop strategies and a work plan to mitigate or eliminate those constraints; and 5) adopt a housing element and update it on a regular basis.68 The City of Daly City Housing Element and related land use policies were last updated in 2015.

California Department of Housing and Community Development (HCD) conducted a Regional Housing Needs Determination for the Bay Area based on population projections and determined 441,176 new units must plan to be built in the region from 2023 to 2031. In 2021, ABAG in consultation with local jurisdictions and regional stakeholders, developed a methodology to assign the Bay Area’s 2023 to 2031 RHNA. Following the allocation of housing units to each jurisdiction, an appeals process was conducted for cities and counties to change their allocation. In December, ABAG certified the RHNA Plan for the San Francisco Bay Area. According to RHNA Plan, Daly City is allocated a total of 4,838 total housing units. This includes 1,336 very low income units, 769 low income units, 762 moderate income units, and 1,971 above moderate income units.69 The City is in the process of preparing an update to the Housing Element covering the timeframe from 2023- 2031.

Regional and Local
Plan Bay Area 2050
Plan Bay Area 2050 is a long-range plan for the nine-county San Francisco Bay Area that provides strategies that increase the availability of affordable housing, support a more equitable and efficient economy, improve the transportation network, and enhance the region’s environmental resilience.

Plan Bay Area 2050 promotes the development of a variety of housing types and densities within identified Priority Development Areas (PDAs). PDAs are areas generally near existing job centers or frequent transit that are locally identified for housing and job growth.70 68 California Department of Housing and Community Development. “Regional Housing Needs Allocation and Housing Elements” Accessed November 19, 2021. http://hcd.ca.gov/community-development/housingelement/index.shtml. 69 Association of Bay Area Governments. Final Regional Housing Needs Allocations (RHNA) Plan: San Francisco Bay Area, 2023-2031. March 2022. Page 27.
70 Association of Bay Area Governments and Metropolitan Transportation Commission. Plan Bay Area 2050.

October 21, 2021. Page 20.

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ABAG allocates regional housing needs to each city and county within the San Francisco Bay Area, based on statewide goals. These allocations are designed to lay the foundation for Plan Bay Area 2050’s long-term envisioned growth pattern for the region. ABAG also develops a series of forecasts and models to project the growth of population, housing units, and jobs in the Bay Area. ABAG, MTC, and local jurisdiction planning staff created the Forecasting and Modeling Report, which is a technical overview of the of the growth forecasts and land use models upon which Plan Bay Area 2050 is based.

Daly City 2030 General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating impacts on population and housing resulting from planned development within the City including the following:

Policy/Task Description
Policy HE-1 Maintain and, where possible, create larger housing development sites throughout the City.

Policy HE-6 Assure that adequate development sites exist on the Potential Housing Sites Inventory List to ensure compliance with the City’s Regional Housing Need Allocation Policy LU-4 Provide regulatory incentives for developers to construct higher-density mixed-use development along Mission Street, Geneva Avenue, and any other locations within close proximity to public transit.

3.14.1.2 Existing Conditions
The population of Daly City was estimated to be 108,599 in January 2021, with an average of 3.33 persons per household.71 Buildout of the City’s General Plan is anticipated to result in 2,157 new housing units and 3,990 new jobs through 2030. ABAG estimates that in 2035, the City’s population will grow to 115,015 people, while jobs will increase from approximately 18,370 (as of 2020) to 19,180 in 2035.72
The 1985 Precise Plan (described in greater detail in Section 2.2.1 Precise Plan) planned for the development of the project site with up to 175 residential units and approximately 700,000 square feet of office space in the project site area. The project site is identified as site number 15, “Serramonte Del Rey”, in the City’s current Housing Element, and consistent with the 1985 Precise Plan, was allocated 175 housing units, including 35 very low income, 18 low income, 70 moderate income, and 53 above moderate income units.

Parcel A has been developed with 122 multifamily units intended primarily for JUHSD employees.

The rest of the Precise Plan area (Parcels B through F) contains no residential units. 71 California Department of Finance. “E-5 City/County Population and Housing Estimates – January 1, 2021.” Accessed November 19, 2021.http://www.dof.ca.gov/Forecasting/Demographics/Estimates/E-5/. 72 Association of Bay Area Governments and Metropolitan Transportation Commission. “Projections 2040.” Accessed November 22, 2021. http://projections.planbayarea.org/.

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3.14.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on population and housing, would the project:
1) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
2) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

3.14.2.1 Project Impacts
Impact POP-1: The project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). (Less than Significant Impact)
A project can induce substantial population growth by: 1) proposing new housing beyond projected or planned development levels, 2) generating demand for housing as a result of new businesses, 3) extending roads or other infrastructure to previously undeveloped areas, or 4) removing obstacles to population growth (i.e., expanding capacity of a wastewater treatment plant beyond that necessary to serve planned growth).

Direct Impacts
As noted in Section 3.14.1.2 Existing Conditions, the adopted 1985 Precise Plan allows the project site to be developed with up to 175 residential units and 700,000 square feet of office uses.

Compared to what is allowed by the 1985 Precise Plan, the project would result in a net increase of 1,060 residential units and a net decrease of 684,000 square feet of employment uses (office and retail). This net change in development would result in approximately 3,403 additional residents.73 Compared to the buildout of the General Plan, the project would represent an approximately three percent net increase in the City’s population.74
While the project would result in an increase in population and housing compared to what is allowed in the adopted 1985 Precise Plan and General Plan, the project would be consistent with the City’s goal of maximizing opportunities for higher-density housing (General Plan Policy HE-1 and Policy LU-4) and meeting the City’s RHNA target (General Plan Policy HE-6). The project is also consistent with the intent of Plan Bay Area 2050 because it proposes additional residential units for 73 1,235 (number of housing units proposed) minus 175 (number of planned housing units) equals 1,060 housing units. Based on the City’s average number of persons per housing unit (3.21), the 1,060 units would generate 3,403 additional residents. As the majority of employment uses would be eliminated, demand for housing from new businesses was assumed to be zero. Source: State of California, Department of Finance. E-5 Population Estimates for Cities, Counties, and the State—January 1, 2021-2022. May 2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-countiesand-the-state-2020-2022/. 74 Buildout of the City’s General Plan would result in 106,388 residents.

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the City to meets its RHNA targets. For these reasons, the project would not directly induce substantial population growth in the area, and the environmental effects of the new population growth from the project have been disclosed throughout this EIR. (Less than Significant Impact) Indirect Impacts
As discussed in Section 3.17 Transportation, the project would require transportation infrastructure improvements to address intersection deficiencies and bicycle and pedestrian facilities. The transportation improvements would serve the proposed project, as well as existing and planned projects.

The project would also require connections to existing utility lines in the area. These standard connections to existing water, sewer, and storm drain systems to serve the project would not induce growth beyond the proposed project, as they are designed to serve the project population and not sized to serve additional growth, nor would they remove an existing constraint on development that would allow for unplanned growth. Based on the above discussion, the project would not indirectly induce substantial population growth through its infrastructure improvements. (Less than Significant Impact)
Impact POP-2: The project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. (No Impact)
The project site is currently developed with the existing Serramonte Del Rey JUHSD campus, which includes the main campus building, a General Education Department building, two one-story portables, storage bungalows, and a Comcast relay station. None of these structures are inhabited or provide housing. The 122 multifamily housing units recently constructed on Parcel A will continue to exist regardless of the remainder of the proposed Precise Plan being approved. Therefore, the proposed project would not displace substantial numbers of existing people or housing necessitating the construction of replacement housing elsewhere. (No Impact)

3.14.2.2 Cumulative Impacts
Impact POP-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant population and housing impact. (Less than Significant Cumulative Impact)
The geographic area for cumulative population and housing impacts is the City boundaries, and can be extended further to San Mateo County and the San Francisco Bay region. Past, present, and pending development projects contribute to the City’s, County’s, and region’s population and housing impact.

As discussed under Impact POP-1, compared to the City’s ABAG estimated population in 2035, the proposed project would result in an approximately three percent increase in residents citywide. This increase in growth citywide is not substantial, and it would not serve to create demand for additional housing within or outside the City. For these reasons, implementation of the project would not have a

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cumulatively considerable contribution to a significant cumulative population and housing impact. (Less than Significant Cumulative Impact)

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3.15 PUBLIC SERVICES

3.15.1 Environmental Setting

3.15.1.1 Regulatory Framework
State
Government Code Section 66477
The Quimby Act (included within Government Code Section 66477) requires local governments to set aside parkland and open space for recreational purposes. It provides provisions for the dedication of parkland and/or payment of fees in lieu of parkland dedication to help mitigate the impacts from new residential developments. The Quimby Act authorizes local governments to establish ordinances requiring developers of new residential subdivisions to dedicate parks, pay a fee in lieu of parkland dedication, or perform a combination of the two.

Government Code Section 65995 through 65998
California Government Code Section 65996 specifies that an acceptable method of offsetting a project’s effect on the adequacy of school facilities is the payment of a school impact fee prior to the issuance of a building permit. Government Code Sections 65995 through 65998 set forth provisions for the payment of school impact fees by new development by “mitigating impacts on school facilities that occur (as a result of the planning, use, or development of real property” (Section 65996[a]). The legislation states that the payment of school impact fees “are hereby deemed to provide full and complete school facilities mitigation” under CEQA (Section 65996[b]).

Developers are required to pay a school impact fee to the school district to offset the increased demands on school facilities caused by the proposed residential development project. The school district is responsible for implementing the specific methods for mitigating school impacts under the Government Code.

Local
Daly City 2030 General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating impacts on public services resulting from planned development within the City including the following:

Policy/Task Description
Policy RME-13 Require the dedication of parkland or the payment of an in-lieu fee in accordance with Subdivision Map Act.

Policy RME-14 Prioritize the dispersal of park in-lieu fees collected from the development of new subdivisions to ensure that the fees are spent in the appropriate areas (see Program RME-3)
Task SE-3.1 Support and maintain the City’s Insurance Service Office (ISO) rating of a Class 2, which establishes the fire insurance rates for the City.

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Task SE-3.2 Provide for a seven (7) minute total reflex time for arrival of a first due company to 90 percent of all emergency incidents.

Task SE-3.3 Provide for an eleven (11) minute total reflex time for arrival of multiple fire companies to 90 percent of all structure fires.

Task SE-3.4 Maintain fire company reliability, whereby 90 percent of all incidents are handled by the district fire company.

Daly City Municipal Code
Daly City Municipal Code Section 16.30.400 requires the dedication of park space of three acres per 1,000 people which can satisfied through either on-site park construction or land dedication. Public facility fees are described in Section 3.32.130 which are required upon issuance of a building permit to pay for municipally owned public facilities, including but not limited to city administrative facilities, fire facilities and equipment, libraries, police facilities and equipment, community recreation centers, street improvements and water and sewage facilities.

City of Daly City Capital Improvement Plan
In 2008, the City expanded its Capital Plan to cover a 20-year period. It was estimated that 2.8 million square feet of commercial space and 2,641 residential units would be added to the City, which is slightly more than projected with the 2013 General Plan. The study also projected the extent of capital improvements for public facilities which would be needed in the City over the same time period. The City identified the capital improvements which would be needed to provide City services to all areas over the next 20 years. The relationships between the additional projected commercial and residential development and the need for improvements in public facilities were analyzed. The City formulated impact fees that are based on the extent to which any need for new public facilities is attributed to new development.

City of Daly City Parks and Open Space Master Plan
The Parks and Open Space Master Plan is intended to guide decision making to help the City maintain, manage and develop the envisioned park and open space system and provide the community with the recreational opportunities. The Parks and Open Space Master Plan evaluates the existing park system and relies upon extensive community engagement to support the expansion, improvement, and protection of the park and open space system for the future.

3.15.1.2 Existing Conditions
Fire Protection Services
Fire protection services in Daly City are provided by a joint powers authority, the North County Fire Authority (NCFA). The NFCA consists of fire and emergency medical response services for the cities of Brisbane, Daly City, and Pacifica.75 The NCFA responds to all fires, hazardous material spills, and medical emergencies within the constituent cities. Pursuant to Daly City General Plan Policy SE-3.3, fire protection service performance is measured by total reflex time. Total reflex time 75 North County Fire Authority. “Frequently Asked Questions”. Accessed November 16, 2021. https://northcountyfire.org/ncfa-overview/frequently-asked-questions/

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refers to the total amount of time that passes from receipt of the emergency call to the arrival of the responding unit at the scene.

The nearest fire station to the project site is the City of Daly City Fire Station Number 94, located approximately 0.4 miles to the southeast at 444 Gellert Boulevard.

Police Protection Services
Police protection services are provided to the project site by the Daly City Police Department (DCPD). The DCPD is headquartered at 333 90th Street, approximately 1.5 mile north of the project site, and employs 111 sworn and 43 non-sworn personnel. Pursuant to Daly City General Plan Policy SE-3.2, police protection service performance is measured by total reflex time, as described above in Fire Protection Services.

Schools
The project site is located within the Jefferson Elementary Unified School District, and the Jefferson Union High School District. Students in the project area would attend Daniel Webster Elementary School and Fernando Rivera Middle School. Students would attend one of the four high schools, Terra Nova High School, Oceana High School, Westmoor High School, or Jefferson High School, depending on the capacity of each facility. The closest high school to the project site is Westmoor High School, approximately 1.7 miles from the project site. The current enrollment capacities for these schools are shown in Table 3.15-1 below. As shown in Table 3.15-1, there is currently available capacity at the schools.

Table 3.15-1: School Enrollment and Capacity
School Existing Capacity Current Enrollment Available Capacity Daniel Webster
Elementary School1 598 308 290
Fernando Rivera Middle
School1 808 499 309
Westmoor High School2 2,096 1,250 846
1 School data for the 2021-2022 school year. Source: Vidales, Bernardo. Superintendent, Jefferson Elementary School District. Personal Communication. July 7, 2022.
2 SchoolWorks, Inc. Jefferson Union High School District 2021/2022 Demographics and Enrollment Projections.

March 2022.

Parks and Recreational Facilities
The City currently has a number of public and private recreational open spaces. Public recreational open space consists of City parks and related facilities, and State and County parks. Private recreational open space consists of private golf and country clubs which limit access only to members.

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Thirteen municipal parks and twelve tot lots are located in Daly City, resulting in a total of 82.95 acres of developed public recreational open space. The City has 27 recreational facilities dispersed throughout the various City neighborhoods to serve residents.

The nearest parks to the project site are Gellert Park, located approximately 800 feet southeast of the project site, Edgewood Park and Fairmont Field located in Pacifica approximately 0.5 miles to the southwest of the project site, Mussel Rock Park approximately 0.5 miles to the west, and Cameo Tot Lot located approximately 0.6 miles to the south.

Libraries, Community Centers, and Other Public Services In addition to the aforementioned public services, Daly City also has four public libraries: the Serramonte Main Branch, John Daly, Westlake, and Bayshore. The nearest library to the project site is the Serramonte Main Branch, located approximately 0.4 miles to the southeast.

There are two community centers, one art center, and one public clubhouse in Daly City. The nearest public facility is the Teglia Community Center, located approximately two miles northeast of the project site.

3.15.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on public services, would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
1) Fire protection?
2) Police protection?
3) Schools?
4) Parks?
5) Other public facilities?

3.15.2.1 Project Impacts
Impact PS-1: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. (Less than Significant Impact) As discussed in Section 3.14 Population and Housing, buildout of the project would result in a net increase of 1,060 residential units and a net decrease of 684,000 square feet of employment uses (office and retail) compared to the adopted 1985 Precise Plan. The General Plan EIR (which includes

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buildout of the 1985 Precise Plan) concluded that buildout of the General Plan would not require the expansion of fire facilities and stated that new fire facilities were not included in the City’s Capital Improvement Plan.76 While the proposed project would increase the number of residential units on the project site, with the corresponding reduction in employment uses, the proposed project is not anticipated to generate additional demand for fire services. In addition, as part of the permitting process, the NCFA would review the proposed project before permits are issued to ensure compliance with all applicable fire and building code standards and to ensure that adequate fire and life safety measures are incorporated into the project in compliance with all applicable state and city fire safety regulations. For these reasons, the project’s potential impact on fire protection services would be less than significant. (Less than Significant) Impact PS-2: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services. (Less than Significant Impact) As discussed above under Impact PS-1with regard to fire protection services, the proposed project is similarly not anticipated to generate additional demand for police protection services, as the intensity of uses between the adopted 1985 Precise Plan and proposed project would be similar. The General Plan EIR (which includes buildout of the 1985 Precise Plan) concluded that buildout of the General Plan would not require the expansion of police facilities and stated that new police facilities were not included in the City’s Capital Improvement Plan.77 Developing the site with a substantially larger resident population and substantially smaller employment population would not require the expansion or alteration of police facilities. For these reasons, the project’s potential impact on police protection services would be less than significant. (Less than Significant) Impact PS-3: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools. (Less than Significant Impact)
Students generated from the project would likely attend Daniel Webster Elementary School and Fernando Rivera Middle School in the Jefferson Elementary School District, and Westmoor High School in the Jefferson Union High School District. Implementation of the project would result in a net increase of 1,235 residential units compared to existing conditions, including the recently constructed Parcel A units. According to the Developer Fee Justification Study for Jefferson Elementary School District published in 2014, the state-wide student generation factor which 76 City of Daly City. General Plan Update Draft Environmental Impact Report. October 2021. Page 3.11-9. 77 Ibid.

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identifies the number of students per housing unit is 0.5 for grades K-8.78 Therefore, using this rate, the proposed project would generate approximately 618 new students that would attend Daniel Webster Elementary School and Fernando Rivera Middle School. The Jefferson Union High School District has a student yield rate of 0.09 high school students per residential unit.79 Therefore, the project would generate approximately 112 new high school students attending Terra Nova High School, Oceana High School, Westmoor High School, or Jefferson High School depending on the capacity at each facility. Pursuant to Section 65996 of the State Government Code, payment of school impact fees established by SB 50 is deemed to constitute full and complete mitigation for school impacts from development. Fulfillment of this requirement would mitigate the development of residential uses’ impacts to schools to a less than significant level. (Less than Significant Impact) Impact PS-4: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for parks. (Less than Significant Impact)
City of Daly City Municipal Code Section 16.30.400 has a standard for parks of three acres per 1,000 residents. As discussed above in Section 3.14 Population and Housing, the proposed project would add approximately 3,403 new residents to the project site and would be required to provide 10.2- acres of new park space.80 The Parcel B Development project includes a public park, a recreational trail, and a public retail plaza, totaling approximately 0.8-acre. Additional park space is proposed as part of the buildout of the Precise Plan, but exact acreage is unknown at this time and will be determined as Parcels C-F are developed. The City of Daly City is served by several parks and recreational facilities, including 13 municipal parks and 12 tot lots, resulting in a total of 82.95 acres of developed public recreational open space which equals approximately 0.82 acres per 1,000 residents. However, according to the General Plan EIR, this parkland to population ratio does not take into account the numerous regional park facilities accessible to residents.

San Bruno Mountain State and County Park, a 2,063-acre park located in the Hillside Planning Area, includes multiple recreational facilities and trails. At the coastline, Thornton Beach State Park includes a panoramic overlook and parking lot adjacent to Highway 1, at the end of John Daly Boulevard. Lake Merced, which is adjacent to the city limits, north of the Westlake Planning Area, is a freshwater lake located in San Francisco but utilized by many Daly City residents due to its proximity. Lake Merced includes a circuit path all the way around as well as facilities such as picnic areas and barbeques. Additionally, the Fort Funston/Golden Gate National Recreation Area is also adjacent to the city limits, north of the Westlake Planning Area, and includes multiple trails. The abundance of regional open space around Daly City indicates that residents have access to more open 78 Jefferson Elementary School District. Developer Fee Justification Study for Jefferson Elementary School District.

February 2014. Accessed July 21, 2017. 79 SchoolWorks, Inc. Jefferson Union High School District 2021/2022 Demographics and Enrollment Projections.

March 2022.
80 The City’s General Plan park land dedication calculation is based on 3,403 residents/1,000 x 3 = 10.2 acres of parkland.

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space than shown in the above ratio, although these facilities are trail-oriented, rather than active facilities (such as those that include playfields).

Based on the City’s current parkland dedication ratio of three acres per 1,000 residents in the Municipal Code, the City will need to provide 15.8 acres of parkland to meet future need resulting from anticipated population growth (without ameliorating existing deficiencies). To meet this demand, the General Plan proposes a task to develop part of the 140-acre undeveloped Mussel Rock area into a park for community use. The program for the park will be further developed through the implementation the Parks and Recreation Analysis and Master Plan. The Parks and Recreation Analysis and Master Plan addresses existing and future opportunities for parks and recreational services for the city and guide the planning, selection, dedication and funding of future park land in the city. The Master Plan would allow priorities to be adopted and identify park site locations and development plans be determined at the time the acquisition and development process begins. The General Plan includes policies and programs to help parkland development to meet additional need which would reduce impact to a less than significant level.

In addition, the City of Daly City Municipal Code currently has parkland dedication standards within Title 16 – Subdivisions. Section 16.30.400 of the Municipal Code has a standard for parks of three acres per 1,000 people. In order to meet this requirement, the project would be required to allot 10.2- acres of land as parkland or pay an in-lieu fee equal to the value of the land (plus ten percent toward costs of off-site improvements) according to the Municipal Code parkland dedication standard. The payment of in-lieu fees is an accepted method to offset a project's impacts to park facilities in that it allows the lead agency to collect the in-lieu fees from a number of projects to acquire or improve parkland in the area to serve new residents. (Less than Significant Impact) Impact PS-5: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for other public facilities. (Less than Significant Impact) Implementation of the proposed project would generate new residents in the City. These new residents would increase the demand for libraries, community centers, and other public facilities in comparison with existing conditions. The project would be subject to the Daly City Municipal Code Section 3.32.130, which requires new developments to pay fees that support the maintenance of cityowned facilities, including administrative facilities, community centers, and the public library system. If it is determined expansion of a library (or other public facility such as a community center) is required, the expansion would be subject to its own separate environmental review. It is expected that any future library or other public facilities would be constructed on previously disturbed sites within the existing urban area of the City. Based on previous analyses for library facilities on previously disturbed sites on the San Francisco Bay peninsula, the impacts associated with the construction of library facilities can be mitigated to a less than significant level with implementation of standard mitigation measures (such as the ones identified in Sections 3.3 Air Quality, 3.4 Biological Resources, 3.5 Cultural Resources, 3.10 Hydrology and Water Quality, 3.13 Noise and Vibration in this EIR). (Less than Significant Impact).

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3.15.2.2 Cumulative Impacts
Impact PS-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant public services impact. (Less than Significant Cumulative Impact)
The geographic area for cumulative public services impacts is the City of Daly City.

Fire and Police Protection
As previously discussed under Impact PS-1, the General Plan EIR concluded that implementation of the General Plan would not necessitate the construction of new fire or police stations. The proposed project would not increase demand for fire or police services beyond what is anticipated in the General Plan EIR given the increased resident population on the site would be offset somewhat by a reduction in the substantial employment population that had been planned for the site under the current General Plan land use designation for the site. In addition, the proposed project would be constructed in accordance with current building codes and reviewed by NCFA to ensure appropriate safety features are incorporated to reduce fire hazards. For these reasons, the project would not result in significant cumulative impact to fire or police protection facilities and services.

Schools
Only one of cumulative projects from Table 3.0-1 (Serramonte Condominiums) is a residential project that would generate new students and it is located within the Brisbane Elementary School District; therefore, it would not have any impacts on the Jefferson Elementary School District.81 Serramonte Condominiums is, however, within the boundary for Jefferson Union High School District.
82 The Serramonte Condominiums project proposes 323 residential units, which would generate approximately 29 new high school students. Westmoor High School currently as available capacity of 846 students (see Table 3.15-1) and can easily accommodate the proposed project’s and the Serramonte Condominiums project’s new high school students.

As required by state law (Government Code 65996), the cumulative projects (including the proposed project) shall pay the appropriate school impact fees to impacted school districts to offset the increase demands on school facilities caused by the development. The cumulative projects (including the proposed project), in conformance with state law (Government Code 65996), would not result in significant cumulative impacts to schools.

Parks
The geographic area for cumulative park impacts is the City boundaries. The implementation of the cumulative projects (including the project) would incrementally increase the demand for park facilities. The cumulative projects would be required to construct new park space, pay in-lieu fees, 81 Jefferson Elementary School District. Boundary Book. Accessed November 18, 2021. https://www.jsd.k12.ca.us/District/Department/596-Enrollment-Information. 82 San Mateo County Office of Education. Elementary School Districts, Union High School Districts, and Unified School Districts Map. Accessed November 18, 2021. https://www.smcoe.org/about/districts-and-schools/schooldistrict-information/.

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and/or dedicate land pursuant to Daly City Municipal Code Section 16.30.400, thereby reducing their impacts on parks to a less than significant level.

Libraries
As previously discussed under Impact PS-4, the project would be required to pay all associated Public Facility Fees associated with the issuance of a building permit. Impacts associated with an increased demand on libraries requiring construction of new facilities would be subject to separate environmental review. For these reasons, the cumulative projects would not result in a significant cumulative impact on libraries and public facilities. (Less than Significant Cumulative Impact)

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3.16 RECREATION

3.16.1 Environmental Setting

3.16.1.1 Regulatory Framework
State
Government Code Section 66477
The Quimby Act (included within Government Code Section 66477) requires local governments to set aside parkland and open space for recreational purposes. It provides provisions for the dedication of parkland and/or payment of fees in lieu of parkland dedication to help mitigate the impacts from new residential developments. The Quimby Act authorizes local governments to establish ordinances requiring developers of new residential subdivisions to dedicate parks, pay a fee in lieu of parkland dedication, or perform a combination of the two.

Local
Daly City General Plan 2030
The following policies in the City’s General Plan have been adopted for the purpose of reducing or avoiding impacts related to recreation and are applicable to the project.

Policy/Task Description
Task RME-12.1 Program for and undertake improvements to develop Mussel Rock Park as a passive recreational area for community use (see also Task CST-1.4). All improvements within the park shall be in substantial conformance with a Public Access Management Plan prepared for the site which shall include the following:

1. Public access paths provided in such a way as to ensure connectivity, maximize utility, and provide access along the entirety of the park site.

2. Public access amenities (such as benches, table and chairs, bicycle racks, trash and recycling receptacles, etc.), including benches in the public view overlook at appropriate locations.

3. Public access signs to facilitate, manage, and provide public access to the park, including the provision of directional signs.

4. At a minimum, two interpretive panels relevant to the site shall be provided at locations that maximize their utility.

Policy RME-13 Require the dedication of parkland or the payment of an in-lieu fee in accordance with Subdivision Map Act.

Policy RME-14 Prioritize the dispersal of park in-lieu fees collected from the development of new subdivisions to ensure that the fees are spent in the appropriate areas (see Program RME-3).

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City of Daly City Parks and Open Space Master Plan
The Parks and Open Space Master Plan is intended to guide decision making to help the City maintain, manage and develop the envisioned park and open space system and provide the community with the recreational opportunities. The Parks and Open Space Master Plan evaluates the existing park system and relies upon extensive community engagement to support the expansion, improvement, and protection of the park and open space system for the future.

Daly City Municipal Code
The City of Daly City Municipal Code currently has parkland dedication standards within Title 16 – Subdivisions. Section 16.30.400 of the Municipal Code has a standard for parks of three acres per 1,000 people. This requirement may be satisfied through either on-site park construction, land dedication, or an in-lieu fee equal to the land value plus ten percent towards costs of off-site improvements.

3.16.1.2 Existing Conditions
The City currently has a number of public and private recreational open spaces. Public recreational open space consists of City parks and related facilities, and State and County parks. Private recreational open space consists of private golf and country clubs which limit access only to members.

Thirteen municipal parks and twelve tot lots are located in Daly City, resulting in a total of 82.95 acres of developed public recreational open space. The City has 27 recreational facilities dispersed throughout the various City neighborhoods to serve residents.

The nearest parks to the project site are Gellert Park, located approximately 800 feet southeast of the project site, Edgewood Park and Fairmont Field located in Pacifica approximately 0.5 miles to the southwest of the project site, Mussel Rock Park approximately 0.5 miles to the west, and Cameo Tot Lot located approximately 0.6 miles to the south. The demonstration garden located on the project site is not a recognized recreational facility by the City, as it is a private school garden used for classroom instruction. Thus, the removal of the garden as part of the project is not considered a CEQA impact requiring mitigation; however, as discussed in Section 2.2.1.1, JUHSD plans to provide a raised planter beds at their new district offices.

3.16.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on recreation:
1) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
2) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

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3.16.2.1 Project Impacts
Impact REC-1: The project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. (Less than Significant Impact)
The proposed project would add approximately 3,403 new residents (including the recently constructed Parcel A project) to the project site and would generate additional demand for parks in the project area. As discussed above in Section 3.15 Public Services under Impact PS-4, the project would be required to allot 10.2-acres of land as parkland or pay an in-lieu fee equal to the value of the land (plus ten percent toward costs of off-site improvements) according to the Daly City Municipal Code Section 16.30.400 parkland dedication standard.83 The Parcel B Development project includes a privately owned, publicly accessible park, a recreational trail, and a public retail plaza, totaling approximately 0.8-acre, which would partially off-set demand on nearby recreational facilities. Approximately 6.5 acres of park space is proposed as part of the buildout of the Precise Plan, and the exact acreage will be determined as Parcel C-F are developed. Thus, the project proposes to pay in-lieu fees to offset recreational demand for parkland not provided by the proposed project. The payment of in-lieu fees is an accepted method to offset a project's impacts to park facilities in that it allows the lead agency to collect the in-lieu fees from a number of projects to acquire or improve parkland in the area to serve new residents. (Less than Significant Impact) Impact REC-2: The project would include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. (Less than Significant Impact) The proposed project would construct approximately 0.8-acre of privately-owned, publicly accessible park space as part of the Parcel B Development project. Approximately 6.5 acres of park space is proposed in the plan area the environmental impacts of which are discussed throughout this EIR and determined to be less than significant with mitigation incorporated. The exact amount of park space and design will be determined as Parcel C-F are developed. Construction of the proposed project’s recreational facilities would have a less than significant impact on the environment. (Less than Significant Impact)
83 The City’s General Plan park land dedication calculation is based on 3,403 residents/1,000 x 3 = 10.2 acres of parkland.

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3.16.2.2 Cumulative Impacts
Impact REC-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant recreation impact. (Less than Significant Cumulative Impact)
The geographic area for cumulative park impacts is the City boundaries. The implementation of the cumulative projects (including the project) would incrementally increase the demand for park facilities. The cumulative projects would be required to construct new park space, pay in-lieu fees, and/or dedicate land pursuant to Daly City Municipal Code Section 16.30.400, thereby reducing their impacts on parks to a less than significant level. The payment of in-lieu fees is an accepted method to offset a project's impacts to park facilities in that it allows the lead agency to collect the in-lieu fees from a number of projects to acquire or improve parkland in the area to serve new residents. (Less than Significant Cumulative Impact)

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3.17 TRANSPORTATION
The following discussion is based, in part, on a Transportation Impact Assessment (TIA) prepared for the project by Fehr & Peers. A copy of this report, dated July 2022, is attached to this EIR as Appendix L.

3.17.1 Environmental Setting

3.17.1.1 Regulatory Framework
State and Regional
Regional Transportation Plan
MTC is the transportation planning, coordinating, and financing agency for the nine-county San Francisco Bay Area, including San Mateo County. MTC is charged with regularly updating the Regional Transportation Plan, a comprehensive blueprint for the development of mass transit, highway, airport, seaport, railroad, bicycle, and pedestrian facilities in the region. MTC and ABAG adopted Plan Bay Area 2050 in October 2021, which includes a Regional Transportation Plan to guide regional transportation investment for revenues from federal, state, regional and local sources through 2050.

Senate Bill 743
SB 743 establishes criteria for determining the significance of transportation impacts using a vehicle miles traveled (VMT) metric intended to promote the reduction of GHG emissions, the development of multimodal transportation networks, and a diversity of land uses. Specifically, SB 743 requires analysis of VMT in determining the significance of transportation impacts. Local jurisdictions were required by Governor’s Office of Planning and Research (OPR) to implement a VMT policy by July 1, 2020.

SB 743 did not authorize OPR to set specific VMT impact thresholds, but it did direct OPR to develop guidelines for jurisdictions to utilize. In December 2018, OPR released a technical advisory containing recommendations regarding the assessment of VMT, proposed thresholds of significance, and potential mitigation measures for lead agencies to use while implementing the required changes contained in Senate Bill 743 (SB 743). The recommendations were incorporated into CEQA Guidelines Section 15064.3(b), which among other things describes factors that might indicate whether a development project’s VMT may be significant.

Regional
San Mateo County Congestion Management Program
The City/County Association of Governments (C/CAG), as the Congestion Management Agency for San Mateo County, is required to prepare and adopt a Congestion Management Program (CMP) on a biennial basis. The purpose of the CMP is to identify strategies to respond to future transportation needs, develop procedures to alleviate and control congestion, and promote countywide solutions.

Also included in the CMP is the Traffic Impact Analysis (TIA) Policy, which provides uniform

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procedures to analyze traffic impacts. According to the CMP, an acceptable level of service at signalized intersections is LOS E.

San Mateo County Comprehensive Bicycle and Pedestrian Plan To support and encourage walking and bicycling in San Mateo County, the SMCTA on September 8, 2011, adopted the San Mateo County Comprehensive Bicycle and Pedestrian Plan (CBPP). The CBPP outlines goals and policies designed to support the implementation of the long-term vision for bicycling and walking in the county.

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 transportation and are applicable to the proposed project.

Policy/Task Description
Policy CE-6 Support regional efforts to improve traffic while accommodating future development.

Policy CE-7 Ensure an effective transit system by supporting the work of other agencies in their efforts to expand public transit in and around Daly City.

Policy CE-13 View transportation improvements (new and retrofit) as opportunities to improve safety, access, and mobility for all travelers and recognize bicycle, pedestrian, and transit modes as integral elements of the transportation system.

Policy CE-16 Strengthen pedestrian access between and within residential areas and schools, commercial areas, recreational facilities, transit centers, and major activity centers in the City.

Policy CE-20 Integrate Complete Streets infrastructure and design features into street design and private construction to create safe and inviting environments for people to walk, bicycle, and use public transportation.

Task CE-1.3 Require a traffic study as part of a complete application for discretionary projects which meet pre-determined criteria established by the City Engineer. The study shall determine the cumulative impact of the project on the City’s principal intersections together with approved projects and projects under construction in Daly City and adjacent jurisdictions.

Task CE-1.6 Incorporate a Level of Service (LOS) standard into Daly City’s Local Thresholds of Significance Guidelines and use the standard as an evaluation measure for the traffic impacts created by new discretionary projects and to identify future roadway and intersection improvements in the City’s Capital Improvement Program.

This standard shall be applied as follows:
• Require that a minimum LOS D be maintained at all principal intersections.

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Policy/Task Description
• Where a traffic study identifies that a discretionary project will degrade the Level of Service at any of the City’s principal intersections to below acceptable levels, the City shall, through the environmental review process, require measures to mitigate the anticipated impact to a level of insignificance.
• New vehicular traffic created by a discretionary project that causes any of the City’s principal intersections to degrade to LOS F during any traffic period shall be considered a significant impact subject to the preparation of an Environmental Impact Report (EIR). The EIR shall provide both mitigation measures and feasible project alternatives that would effectively mitigate anticipated traffic impacts to a level of insignificance. • Mitigation measures shall include construction of or financial contribution toward traffic improvements that can effectively mitigate the impact within a ten-year timeframe from the project approval date. Traffic impacts which are not fully mitigable within a ten-year timeframe shall be considered temporarily unmitigable and subject to the adoption of a Statement of Overriding Considerations in addition to mitigation measures.
• The City shall consider the potential for adoption of a Statement of Overriding considerations related to traffic in instances where there is substantial evidence that the project possesses qualities (including environmental, legal, technical, social, and economic factors) that merit the project’s approval despite the traffic impacts caused by the project.

The Local Thresholds of Significance Guidelines may provide additional detail and clarity.

Task CE-10.2 Amend the parking regulation to allow for a 30 percent parking reduction for all mixed-use development projects (as defined in the Zoning Ordinance) and clarify that the mixed-use parking reduction is allowed for buildings containing residential and retail components.

Task CE-13.3 Consider impacts to the existing and future bicycle and pedestrian network when completing environmental review for private development projects and require mitigation measures where necessary and reasonable to ensure that these systems are not impacted.

Task CE-16.9 Require as a condition of development/redevelopment project approval the provision of sidewalks and wheelchair ramps where lacking, repair or replacement of damaged sidewalks, and sidewalks that link directly to building entrances.

Task CE-20.1 In the design of any new roadway and as a part of any development review, ensure that adequate infrastructure is included that promotes a safe and convenient means of travel for all users. This shall include the provision of sidewalks, shared use paths, and, where practical, bicycle lanes.

Task CE-20.7 As a part of all new development, require, where appropriate, the provision of pedestrian-oriented signs, pedestrian-scale 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

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Policy/Task Description
may require additional sidewalk and/or right-of-way width to accommodate these amenities.

Walk Bike Daly City
The City of Daly City replaced its 2013 Bicycle and Pedestrian Master Plan in 2020 with Walk Bike Daly City, a new master plan for bicycle and pedestrian facilities within the Daly City. Walk Bike Daly City aims to expand the City’s network of pedestrian and bicycle facilities; close gaps in the existing system; enhance connections to key destinations; and, more generally, make walking and biking in Daly City safer, easier and more popular. Improvements identified by Walk Bike Daly City within the Precise Plan area include the construction of separated bikeways on Serramonte Boulevard from St. Francis Boulevard to Gellert Boulevard.

3.17.1.2 Existing Conditions
Roadway Network
Regional access to the project site is provided by Highway 1, Interstate (I-) 280, and SR-35 (also known as Skyline Boulevard). Local access to the Precise Plan area is provided via Serramonte Boulevard, Campus Drive, Hickey Boulevard, Callan Boulevard, Gellert Boulevard, Junipero Serra Boulevard, St. Francis Boulevard, and Clarinada Avenue. These roadways are described below.

Highway 1 is a north-south freeway located north of the project site. In the project area, it provides three to five mixed-flow vehicle lanes in each direction of travel. It provides immediate access to the project site via on- and off-ramps at Clarinada Avenue and Serramonte Boulevard.

I-280 is a north-south freeway located east of the project site that extends from San Francisco to San Jose. In the project area, it provides four vehicle lanes in each direction of travel with ramps located at Serramonte Boulevard, the intersection of Serramonte Boulevard and Junipero Serra Boulevard, and at Hickey Boulevard.

Skyline Boulevard is a north-south highway that extends from west San Francisco to San Bruno. It provides most immediate access to the project site at Hickey Boulevard and via the Skyline Boulevard and Highway 1 interchange.

Serramonte Boulevard is a four-lane east-west arterial that extends from St. Francis Boulevard to the west to El Camino Real to the east. Sidewalks are provided on the south side of the street west of Callan Boulevard and on the north side of the street west of Gellert Boulevard. Dedicated bike lanes are provided on both sides east of Callan Boulevard, which become on-street parking lanes to the west. The posted speed limit is 25 miles per hour (mph) in the vicinity of the Project site and 30 mph east of Callan Boulevard.

Campus Drive is currently a discontinuous roadway which is cut off by the project site. South of the project site Campus Drive is a two-lane divided collector roadway extending from Hickey Boulevard to just north of the Summit Shasta School. A complete pedestrian sidewalk is currently provided on the west side of Campus Drive from the project site to Hickey Boulevard; the sidewalk on the east

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side of this section of Campus Drive is discontinuous. On-street parking is prohibited. At the north border of the project site a short two-lane section of Campus Drive connects to Serramonte Boulevard opposite Kent Court. As part of the project, Campus Drive would be connected as a through roadway extending from Hickey Boulevard to Serramonte Boulevard.

Hickey Boulevard is a four-lane east-west collector that stretches from Monterey Road to the west to El Camino Real to the east. It crosses Skyline Boulevard and Interstate 280. Sidewalks on both sides and on-street parking on the north side are provided west of Gellert Boulevard. The posted speed limit in the study area is 35 mph.

Callan Boulevard is a north-south local street that alternates between one and two vehicle lanes in each direction of travel in the project vicinity. Sidewalks are provided on both sides and bike lanes are provided south of Hickey Boulevard. On-street parking is intermittent. The posted speed limit is 30 mph to the south of Hickey Boulevard and 35 mph to the north.

Gellert Boulevard is a six-lane north-south collector that extends from Serramonte Boulevard, terminating at Serramonte Center, south to Hickey Boulevard. It becomes a two- to four-lane road from Hickey Boulevard to Shannon Drive. Sidewalks are provided on both sides in the project area and bike lanes are provided south of Hickey Boulevard. The posted speed limit is 30 mph.

Junipero Serra Boulevard is a north-south arterial with two lanes in each direction of travel in the project area. Sidewalks are provided on both sides north of Serramonte Boulevard and on the east side between Serramonte Boulevard and Arlington Drive. Bike lanes on both sides are provided in the project area. The posted speed limit is 40 mph near the project site.

St. Francis Boulevard is a local two-lane road that extends from Eastmoor Avenue south to Hickey Boulevard, primarily serving residential land uses. Sidewalks and on-street parking are provided along the roadway. Bike lanes are provided north of Serramonte Boulevard. The posted speed limit is 25 mph.

Clarinada Avenue is an approximately 0.6-mile-long east-west local road connecting Higate Drive and Callan Boulevard. Two lanes of vehicle travel in each direction are provided east of the Highway 1 ramps and one travel lane in each direction to the west. On-street parking and sidewalks are provided along the entire road. The speed limit is not posted.

Transit Services
Existing transit service within the vicinity of the project site is provided by the San Mateo County Transit District (SamTrans) and Bay Area Rapid Transit (BART). Existing transit facilities in the area are shown on Figure 3.17-1.

SamTrans
Local transit service in the vicinity of the project site is provided by SamTrans, which operates 14 fixed bus routes in Daly City and a total of 82 routes in San Mateo County and the cities of San Francisco and Palo Alto. The project site is served by Routes 24, 49, 112, 120, and 121.

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Route 24 runs service on school days from Brisbane to Colma to Summit Shasta High School in the morning, and the reverse route in the afternoon. The closest bus stop is located by the St. Francis Boulevard and Serramonte Boulevard intersection.

Route 49 runs service on school days from the Serramonte Center to Terra Nova High School in the morning, and the reverse route in the afternoon. The closest bus stop is by the Callan Boulevard and Serramonte Boulevard intersection.

Route 112 runs from the Linda Mar Park and Ride to the Colma BART station via Hickey Boulevard and Gellert Boulevard. It provides hourly service from 6:00 a.m. to 9:45 p.m. on weekdays, and from 7:55 a.m. to 8:45 p.m. on weekends. The closest bus stop is at the Callan Boulevard and Hickey Boulevard intersection.

Route 120 runs between the Daly City BART station to the north and Colma and South San Francisco BART stations to the South. It provides service from 4:05 a.m. to 11:45 p.m. with about 10-minute peak headways on weekdays and about 15-minute peak headways on weekends. The closest bus stop is at the Highway 1 and Serramonte Boulevard intersection.

Route 121 runs between Skyline College Transit Center to the intersection of Bellevue Avenue and Pope Street in Daly City via Hickey Boulevard and Gellert Boulevard, passing Serramonte Center and the Colma BART station. It provides hourly service from 6:25 a.m. to 10:40 p.m. on weekdays, from 7:25 a.m. to 10:40 p.m. on Saturdays, and from 7:25 a.m. to 9:00 p.m. on Sundays. The closest bus stop is by the Callan Boulevard and Serramonte Boulevard intersection.

SamTrans also provides paratransit service throughout San Mateo County. Daly City is served specifically by its Redi-Wheels on-demand service.

Bay Area Rapid Transit
Regional transit service is provided by BART. The closest BART station is the Colma BART station, located approximately 1.2 miles to the northeast of the project site. The South San Francisco BART station is located approximately 1.5 miles to the southeast of the project site. Both stations are served by the Red and Yellow lines. The Red Line runs from Richmond to Millbrae with service at 30- minute headways or less on weekdays and Saturdays. The Yellow Line runs from Antioch to the San Francisco International Airport (SFO) with at 30-minute headways or less every day of the week. As mentioned above, SamTrans routes 112, 120, and 121 connect to the Colma, Daly City, and SFO BART stations. SamTrans bus route 120 has stops in front of the Precise Plan area on Serramonte Boulevard and provides service to the Colma BART station with 10-minute headways during peak weekday and weekend hours.

Source: Fehr & Peers, 2023.

Serramonte
Center
Serramo
Plaza
Fairmont
Neighborhood
Gellert
Park Fairmont Park
118
112
118
110
24 24
120
120
16 16
110
130
130
121
121
121
122
112
112
5-minute
walk
5-minute
walk
Callan Blvd.

Campus Dr.

Hickey Blvd.

Higate Dr.

Gellert Blvd.

Callan Blvd.

Serramonte Blvd.

Serramonte Blvd. Se
St. Francis
Neighborhood
Off Ramp On Ramp
Evergreen
Trees & Steep
Hillside Slopes
Serramonte Views
(14 and 17 stories high)
Approved but not yet built
Campus currently closed,
would be opened by project
Serramonte
Ridge
Apartment
Homes
Summit
Shasta
Public
School
Physician
Medical
Center
St. Francis Blv St. Francis Blvd.

Chinese
Cemetery
On Ramp Off Ramp
Project Site Entry SamTrans Bus Lines & Stops Existing/In-progress Class II Bicycle Lane
Existing/In-progress Class III
Bicycle Route
Boundaries PD31 Boundary Project Boundary Parcel Boundaries Immediate Surrounding Neighborhoods Transportation
EXISTING TRANSPORTATION FACILITIES FIGURE 3.17-1

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Bicycle Facilities
Bicycle facilities within the vicinity of the project site include Class II bike lanes and Class III bike routes. These facilities are discussed below, and shown on Figure 3.17-1 above.

Class II Bike Lanes
Bike lanes provide designated street space for bicyclists, typically adjacent to the outer vehicle travel lanes. Bike lanes include special lane markings, pavement legends, and signage. Existing and proposed bicycle facilities are described below. Bike lanes may be enhanced with painted buffers between vehicle lanes and/or parking, and green paint at conflict zones (such as driveways or intersections). Class II bicycle lanes are currently provided along:
• Callan Boulevard south of Serramonte Boulevard
• Serramonte Boulevard between Callan Boulevard and the south entrance to Serramonte Center
• Junipero Serra Boulevard between Amelia M Teglia Boulevard and Hickey Boulevard Class III Bike Routes
Class III bikeways are shared bikeways where the cyclist occupies the same right-of-way with either motor vehicles or pedestrians. Signs are used to designate that the street or path also is to be used by cyclists. While this type of bikeway is least expensive to install, it is the most hazardous. Class III bikeways are currently provided along:
• Serramonte Boulevard west of Callan Boulevard and in the vicinity of Gellert Boulevard • Hickey Boulevard
• Callan Boulevard between Southgate Avenue and Serramonte Boulevard Pedestrian Facilities
Pedestrian facilities in the vicinity of the Precise Plan area include sidewalks, crosswalks, and pedestrian signals. All local, collector, and arterial roads provide crosswalks on at least one side of the roadway. All signalized intersections either provide a marked crosswalk, or, in the case of threelegged intersections, a continuing sidewalk on the missing approach. Sidewalks are provided on both sides of all nearby roadways, with the exception of Serramonte Boulevard between Callan Boulevard and south entrance to Serramonte Center and portions east of Gellert Boulevard, Junipero Serra Boulevard south of Serramonte Boulevard, and the majority of Hickey Boulevard east of Gellert Boulevard, which provide sidewalks on one side of the roadway.

Vehicle Miles Traveled
VMT was modeled using the C/CAG-VTA travel demand model, which covers the entire ninecounty MTC region and provides information regarding the characteristics of home-based vehicle trips made by residents throughout the Bay Area. More information on the assumptions and methodology behind the modeling of existing VMT is provided in Appendix L. The C/CAG-VTA

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travel demand model indicates that the average Bay Area VMT per resident is 14.6, and the countywide VMT per resident is 13.6.

3.17.1.3 Methodology
At the time of this report, the City of Daly City is undertaking a process of updating its significance thresholds to be consistent with SB 743, and the CEQA 2019 Update Guidelines Section 15064.3, subdivision (b). The City has not released draft significance thresholds to determine project VMT impacts. In the absence of an adopted City policy or draft numeric thresholds, this study utilized the OPR guidelines in analyzing VMT.

3.17.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on transportation, would the project:
1) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian facilities? 2) Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? 3) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? 4) Result in inadequate emergency access?

3.17.2.1 Project Impacts
Impact TRN-1: The project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian facilities. (Less than Significant Impact) Circulation System
The City of Daly City does not currently have an adopted VMT policy. Per SB 743, the City’s LOS standards cannot be used in CEQA analysis for transportation impacts, although any physical improvements to the roadway system to maintain acceptable LOS must be evaluated as physical changes to the environment related to the project. A summary of the project’s consistency with City LOS standards is discussed in Section 3.17.3 Non-CEQA, below. The project’s VMT impact is discussed in Impact TRN-2.

Vehicles would access the project site through a northern access point at the intersection of Serramonte Boulevard and the Highway 1 on-ramps, or through a southern access point accessible from Hickey Boulevard via Campus Drive. The project proposes the following improvements to the Serramonte Boulevard/Highway 1 intersection:
• Installation of traffic signal
• Installation of high-visibility crosswalks on all four legs

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• Installation of ADA compliant curb ramps and associated sidewalk improvements in the intersection’s four corners
• Installation of Class II bike-lanes on the north and south sides of Serramonte Boulevard at the Highway 1 Ramps/Entry Drive intersection consistent with the concepts presented in WalkBike Daly City • Restriping the eastbound approach to include dedicated left and shared through-right turn lanes
• Restriping the westbound approach to include a 200-foot-long left turn pocket into the project site and a shared through-right turn lane
• Restriping the southbound (off-ramp) approach to include dedicated left and shared throughright turn lanes • Provision of a shared bike-lane/bus stop in the intersection’s southwest corner • Provision of a shared cycle track bus stop in the intersection’s northwest corner, consistent with the concepts presented in Walk-Bike Daly City
• Elimination of the westbound left turn lane on Serramonte Boulevard into the removed property driveway across from Kent Court
Implementation of the improvements identified above would be considered an improvement to existing conditions as it would increase vehicle, bicycle, and pedestrian safety. In addition, all the improvements identified above would be constructed within the existing right-of-way and no expansion of roadways would be necessary. Limited tree trimming or removal would be required for some of the improvements; however, any street trees removed would be replaced in accordance with the City’s Urban Forestry Ordinance (see Impact BIO-5 in Section 3.4 Biological Resources). Thus, the construction of these improvements would not result in any significant environmental impacts.

As shown in Figure 2.2-5, the Precise Plan’s internal public roadway network would consist of Entry Drive, which would extend south to North Drive, which would branch off into East and West Drive, each of which would extend south to Campus Drive. Entry Drive would be a four-lane roadway, while all other drives would be two lanes. An intersection operations analysis was conducted for the internal roadways that concluded that all intersections and driveways would operate at LOS A or B, indicative of acceptable traffic operations (refer to Appendix L).

Transit Services
Implementation of the proposed project (including the Parcel A development project) would introduce 3,403 net new residents to the project site in comparison with planned development levels (refer to the discussion in Section 3.14.2.1 under Impact POP-1) and would generate approximately 170 new transit users.84 It is not anticipated that the increase in transit users would exceed the capacity of existing bus and BART services within the project area.

As discussed under Section 3.17.1.1 Regulatory Framework above, SamTrans routes 24 and 120 operate along Serramonte Boulevard with stops located on both sides of Serramonte Boulevard. The 84 Assumes five percent of residents use public transit. Source: U.S. Census Bureau. Commuting by Public Transportation in the United States: 2019. April 2021.

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Parcel A Development project was recently completed and installed bus stop amenities, including improved sidewalks and a new bus shelter on Serramonte Boulevard. The project proposes to complete sidewalk corner improvements and install crosswalks at all four legs of the Serramonte Boulevard/Entry Drive/Highway 1 intersection, which would improve access to existing transit facilities. Beyond these improvements, the project does not propose any modifications to existing transit circulation system (roadways, sidewalks, etc.) that could conflict with existing or planned transit services.

Based on the above, the proposed project would not conflict with a program, plan, ordinance or policy regarding transit services.

Bicycle and Pedestrian Facilities
Planned improvements to the existing bicycle and pedestrian circulation systems are identified in the City’s General Plan and Walk Bike Daly City (refer to Section 3.17.1.1 Regulatory Framework).

Various General Plan policies and actions have been adopted to implement planned improvements and ensure that future developments do not impact existing and future bicycle and pedestrian facilities.

As discussed in Section 3.17.1.2 Existing Conditions, Class II and Class III bicycle facilities are located adjacent to the project site and within the project vicinity. The bicycle facilities within the vicinity of the project site would remain unchanged post-implementation of the project, and the project would not result in increases to cyclists that would exceed the carrying capacity of existing facilities. Consistent with General Plan Policies CE-13 and CE-20, the project proposes to provide Class I, Class II, and Class III bicycle facilities on interior roadways within the project site and Class II bicycle facilities along eastbound and westbound Serramonte Boulevard that would improve bicycle access to and from the site. Additionally, the project would be consistent with the City’s bicycle parking requirements. As discussed under Impact TRN-3 below, implementation of MM TRN-3.2 would ensure that the proposed right-in right-out driveway on Serramonte Boulevard would allow bicycles to cross safely.

The project proposes to improve pedestrian facilities at the Serramonte Boulevard/Highway 1 intersection by installing high visibility crosswalks on all four approaches along with ADA compliant ramps and associated sidewalk improvements at all four corners. Otherwise, implementation of the project would leave pedestrian facilities adjacent and within the project vicinity unchanged.

Consistent with General Plan Policies CE-13, CE-16, CE-20 and Tasks CE-16.9, CE-20.1, and CE20.7, implementation of the project would provide sidewalks on both sides of all internal roadways and high-visibility crosswalks at all internal stop-controlled intersections, as well as on the three legs of the proposed roundabout, which would improve pedestrian access to and from the site.

Implementation of MM TRN-3.2 would ensure that the proposed right-in right-out driveway on Serramonte Boulevard would allow pedestrians to cross safely.

Based on the above, the proposed project would not conflict with a program, plan, ordinance or policy regarding bicycle and/or pedestrian facilities. (Less than Significant Impact)

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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)
For purposes of this analysis, the City of Daly City is relying on the guidelines provided in OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA (dated December 2018), and uses a threshold of 15 percent below the baseline regionwide (the nine-county San Francisco Bay Area) and countywide (San Mateo County) average home-based VMT per resident. As discussed in Section 3.17.1.2 Existing Conditions, the regionwide VMT per resident is 14.6, and the countywide VMT per resident is 13.6. As the significance threshold is 15 percent below these averages, the corresponding regionwide threshold is 12.4 VMT per resident, and the corresponding countywide threshold is 11.6 VMT per resident.

Consistent with OPR’s Technical Advisory, since the retail component of the proposed project is expected to redistribute shopping trips rather than create new trips (i.e., people will drive to the closest retail store, thereby reducing VMT), the proposed retail uses are presumed to have a less than significant VMT impact.

The VMT generated by the residential component of the project was modeled using the same C/CAG-VMT travel demand model used to determine the VMT generated by the existing development. More information on the methodology used to determine the project’s VMT impacts can be found in Appendix L of this EIR. The project’s total VMT per resident (including the Parcel A development project), in comparison with the existing VMT per resident and the significant thresholds identified above, is shown below in Table 3.17-1.

Table 3.17-1: Precise Plan VMT per Resident
Level of
Analysis
Existing VMT
per resident
Significance
Threshold1
Precise Plan
VMT per
resident
Significant
Impact?2
Countywide 13.6 11.6 12.0 Yes
Regionwide 14.6 12.4 12.0 No
Notes:
1 The significant threshold is 15 percent below the existing VMT per resident. 2 Significant impacts shown in bold.

Source: Fehr & Peers, Inc. Transportation Impact Assessment for the Serramonte Del Rey Precise Plan. July 2022.

As shown above in Table 3.17-1, the residential component of the project is projected to generate 12 VMT per resident, which is below the regionwide significance threshold of 12.4 VMT per resident, but in excess of the countywide threshold of 11.6 VMT per resident.

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Mitigation Measures:

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.

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 self-certification for the

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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 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.

Based on current literature regarding project-level TDM strategies, implementation of MM TRN-2.1 would result in an approximately 20 percent reduction in the project’s VMT per resident. 85 Thus the
project’s VMT per resident would be reduced from 12 to 10.8 VMT per resident, which is below the countywide significance threshold of 11.6 VMT per resident. Therefore, with implementation of MM TRN-2.1, the project would be consistent with CEQA Guidelines Section 15064.3(b). (Less than Significant Impact with Mitigation Incorporated)
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)
Construction Traffic
Buildout of the project would be phased and occur over the course of eight to 15 years. Construction staging and worker parking would occur on-site, and construction trucks would access the site via the northern and southern access points. The presence of construction truck and worker vehicle traffic on-site concurrent with operation of existing and adjacent uses could create potential safety conflicts with public transit, vehicles, bicycle, and pedestrian traffic.

Mitigation Measures:

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 85 Fehr & Peers. Transportation Impact Assessment Serramonte Del Rey Precise Plan. July 2022. Pages 37-38.

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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 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.

With implementation of MM TRN-3.1, safety conflicts between construction traffic and public transit, vehicles, bicycle, and pedestrian traffic would be reduced to a less than significant level.

Geometric Design
As discussed under Impact TRN-1, vehicles would access the project site through a northern access point at the intersection of Serramonte Boulevard and the Highway 1 on-ramps, or through a southern access point accessible from Hickey Boulevard via Campus Drive. The project would also include a right-in/right-out driveway onto Serramonte Boulevard approximately 200 feet east of Entry Drive; this driveway would provide access to the Parcel B garage. Since the driveway to the Parcel B garage as designed would be unsignalized, it could potentially conflict with vehicle, bicycle, and pedestrian traffic on Serramonte Boulevard.

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Mitigation Measure:

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 on- and 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.

Implementation of MM TRN-3.2 would ensure that vehicles exiting the driveway would have adequate sight distance and would not be able to make illegal left-turns which could create hazards for other vehicles, bicycles, and pedestrians. Additionally, MM TRN-3.2 would alert vehicles entering and exiting the driveway of the presence of bicycles and pedestrians. As such, implementation of MM TRN-3.2 would ensure that the proposed driveway does not substantially increase hazards.

The project also proposes to construct residential buildings that would each have their own gated parking garages, which residents would be able to access through the use of a keycard or equivalent technology. Queues at these parking garages could conflict with bicycle and pedestrian facilities if not designed properly.

Mitigation Measure:

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 each garage and

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submitted to the City Engineer with planning/building permit for review and approval.

Implementation of MM TRN-3.3 would ensure that entrances with adequate storage capacity are provided at each residential garage, which in turn would prevent vehicle queuing backing up into bicycle and pedestrian facilities. Accordingly, with implementation of MM TRN-3.3, the proposed residential garages would not increase hazards.

Incompatible Land Uses
Implementation of the project would redevelop the project site with residential and commercial uses.

As shown on Figure 2.2-3, residential uses are present to the south, west, and north, and commercial uses are present to the northeast. Therefore, the Precise Plan does not propose any uses incompatible with the surrounding area that could result in increased hazards. (Less than Significant Impact with Mitigation Incorporated)
Impact TRN-4: The project would not result in inadequate emergency access. (Less than Significant Impact with Mitigation Incorporated)
Emergency vehicles would access the project site via the northern access point at the intersection of Serramonte Boulevard and the Highway 1 on-ramps, or via the southern access point accessible from Hickey Boulevard via Campus Drive. The northern access point would provide two travel lanes in each direction, while the southern access point would provide one travel lane in each direction. In order to ensure that emergency vehicles have adequate access to and within the project site, the project would be required to implement the following mitigation measures.

Mitigation Measure:

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.

Implementation of MM TRN-4.1 would ensure that the streets used by emergency vehicles to access the Precise Plan area are in good condition and facilitate the safe and efficient movement of emergency vehicles. As part of the review process, the North County Fire Authority would confirm that adequate emergency vehicle access is provided to each parcel and individual building within the Precise Plan area. (Less than Significant Impact with Mitigation Incorporated)

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3.17.2.2 Cumulative Impacts
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)
The current General Plan and 1985 Precise Plan allow up to 175 residential units and approximately 700,000 square feet of office space within the boundaries of the Precise Plan. The daily trip generation for this amount of development would be approximately 8,099 daily trips.86 In comparison, the proposed project would generate approximately 8,433 net new trips, which results in a difference of 334 additional trips. Therefore, the project would result in a greater VMT than what is expected for the project site under the current General Plan. However, as discussed under Impact TRN-2 above, the project’s VMT per resident would be reduced from 12 to 10.8 VMT per resident with implementation of MM TRN-2.1, which is below the countywide significance threshold of 11.6 VMT per resident. Therefore, the project would not have a cumulatively considerable contribution to a significant cumulative VMT impact.

The projects listed under Table 3.0-1 would be required to comply with state, regional, and local regulations addressing safe project design, emergency access, and roadway, transit, bicycle, and pedestrian facilities. Therefore, the projects would not combine to form a significant cumulative transportation impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)

3.17.3 Non-CEQA Effects
With the advent of SB 743 (refer to Section 3.17.1.1 Regulatory Framework), the effect of a project on automobile delay is no longer considered an impact on the environment. Nonetheless, local agencies retain their right to assess and regulate a project’s impact on the circulation system outside of the CEQA process. In accordance with General Plan Policy CE-1.3 and the County’s CMP, the TIA prepared by Fehr & Peers (refer to Appendix L) included an analysis of non-CEQA transportation issues, including intersection operations and parking.

Intersection Operations
Pursuant to the City of Daly City General Plan’s Circulation Element, a project is considered to violate the City’s LOS policy when the addition of project traffic degrades an existing intersection’s operation from acceptable LOS (D or better) to unacceptable LOS (E or F), or adds substantial traffic to intersections already operating at LOS E or F. In the event a project causes an LOS deficiency, the City has discretion whether to require a project to address the deficiency by implementing roadway or other transportation improvements to restore or improve the level of service, and the relevant question under CEQA now that LOS degradation is not considered an environmental impact is whether those improvements would result in adverse physical changes to the environment, not whether LOS has degraded below the condition considered acceptable. 86 Multifamily Housing Units (Land Use Code 220): 175 dwelling units x 7.32 = 1,281 daily trips. General Office (Land Use Code 710): 700,000 square feet/1,000 x 9.74 = 6,818 daily trips. Total daily trips = 8,099. Source:

Institute of Transportation Engineers. Trip Generation Manual (10th Edition). 2017.

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In accordance with standard City practice and methodology, the project’s effect on LOS was analyzed at the following 15 intersections during the weekday morning (7:00 a.m. to 9:00 a.m.) and evening (4:00 p.m. to 6:00 p.m.) peak periods:
• Highway 1 Ramps/Clarinada Avenue
• Callan Boulevard/Clarinada Avenue
• St. Francis Boulevard/Serramonte Boulevard
• Highway 1 Ramps-Project Driveway/Serramonte Boulevard • Callan Boulevard/Serramonte Boulevard (Signalized)
• Gellert Boulevard/Serramonte Boulevard (Signalized)
• I-280 Southbound Ramps/Serramonte Boulevard (Signalized) • I-280 Northbound Ramps/Serramonte Boulevard (Signalized) • Junipero Serra Boulevard/Serramonte Boulevard (Signalized) • Skyline Boulevard/Hickey Boulevard (Signalized)
• Hickey Boulevard/Campus Drive (Signalized)
• Callan Boulevard/Hickey Boulevard (Signalized)
• Gellert Boulevard/Hickey Boulevard (Signalized)
• I-280 Southbound Ramps/Hickey Boulevard (Signalized)
• I-280 Northbound Ramps/Hickey Boulevard (Signalized)
Trip Generation
The number of vehicle trips that would be generated by the project were estimated using trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition. Project trip generation estimates are presented in Table 3.17-2 below.

Table 3.17-2: Summary of Project Trip Generation
Land Use Daily
Trips
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Multifamily Housing
(1,113 dwelling units)1 8,147 118 394 512 393 231 624
Retail (14,000 square
feet)2 529 8 5 13 26 28 54
Mixed-Use Reduction
(15 percent)3 -79 -1 -1 -2 -4 -4 -8
Subtotal Project Trips 8,597 125 398 523 415 255 670
Existing Trips4 -1,053 -115 -78 -193 -71 -108 -179
Parcel A Development
Project (122 dwelling
units)
889 12 80 92 53 13 69

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Table 3.17-2: Summary of Project Trip Generation
Land Use Daily
Trips
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Total Net New Trips 8,433 22 400 422 399 160 559
Notes:
1 Multifamily Housing (ITE Land Use Code 220) Daily Rate: 7.32; AM rate: 0.46 (23% in/77% out); PM rate:

0.56 (63% in/37% out)
2 Shopping Center (ITE Land Use Code 820) Daily Rate: 37.75; AM rate: 0.94 (62% in/38% out); PM rate:

3.81 (48% in/52% out)
3 Internal Trip Capture – 15% of Retail Trips Associated with Residential Users (ITE Trip Generation Handbook, 3rd Edition)
4 Based on existing driveway counts and trip generation estimates of existing uses to be removed.

Source: Fehr & Peers. Transportation Impact Assessment for the Serramonte Del Rey Precise Plan. July 2022.

Extensive detail about the Non-CEQA LOS analysis, including methodology, trip distribution, trip assignment, and City standards is included in Appendix L.

Existing and Existing Plus Project Conditions
Under existing plus project (full Precise Plan buildout) conditions, three intersections would violate the City’s LOS policy (see Table 3.17-3 below). All other intersections would operate at acceptable levels (see Appendix L for additional intersection calculations).

Table 3.17-3: Existing Plus Project Intersection LOS at Adversely Affected Intersections Intersection Peak
Hour1
Existing Existing Plus Project
Delay2 LOS Delay2 LOS
Highway 1/Clarinada
Avenue*
AM 13.2 B 14.2 B
PM 41.4 E 45.9 E
Highway 1/Serramonte
Boulevard*
AM 24.6 C 45.3 E
PM 19.2 C 58.8 F
Callan Boulevard/Hickey
Boulevard
AM 24.9 C 25.1 C
PM 54.5 D 63.4 E
Notes:
1 AM = Weekday morning peak hour (7:00-9:00 a.m.); PM = Weekday afternoon peak hour (4:00-6:00 p.m.) 2 Whole intersection average delay reported for signalized and all-way stop controlled intersections. Delay calculated per HCM 6th methodologies.

Bolded text indicates unacceptable operations pursuant to City standards. Bolded and underlined text indicates Project-related policy violation.
* Indicates an unsignalized intersection.

Source: Fehr & Peers. Transportation Impact Assessment for the Serramonte Del Rey Precise Plan. July 2022.

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The following improvements would reduce project-related violations of the City’s LOS policy under existing plus project conditions and could be accommodated within the existing right-of-way. In addition, the following improvements would be required to implement all construction-related standard permit conditions, conditions of approval, and mitigation measures identified in this EIR.

Thus, construction of the improvements would have a less than significant impact on the environment.

Highway 1/Clarinda Avenue Improvement: Installation of a traffic signal is currently warranted at this intersection prior to the addition of any project traffic (including Parcel A traffic). The addition of project traffic would increase delay at this location while functioning at LOS E. The installation of a traffic signal at this location would result in acceptable operations (LOS A during both the morning and evening peak hours).

Highway 1/Serramonte Boulevard Improvement: Installation of a traffic signal is currently warranted at this intersection prior to the addition of any project traffic (including Parcel A traffic).

While current volumes meet signal warrants, the intersection functions at an acceptable level of service prior to the addition of project traffic (LOS C in the AM and PM peak hours). The addition of project traffic would increase delay at this location and result in the level of service deteriorating to LOS E and F during the morning and evening peak hours, respectively. The installation of a traffic signal at this location would result in acceptable operations (LOS B during both the morning and evening peak hours).

Callan Boulevard/Hickey Boulevard Improvement: Stripe an exclusive westbound right-turn lane on the Hickey Boulevard approach to Callan Boulevard. This modification would be accomplished within the existing roadway cross section through the elimination of on-street parking for approximately 200 feet approaching the intersection. This modification would result in acceptable intersection operations within the City’s LOS policy during the affected PM peak hour.

Cumulative and Cumulative Plus Project Conditions
Under cumulative plus project conditions, seven intersections would violate the City’s LOS policy (see Table 3.17-4 below). All other intersections would operate at acceptable levels (see Appendix L for additional intersection calculations).

Table 3.17-4: Cumulative Plus Project Intersection LOS at Adversely Affected Intersections Intersection Peak
Hour1
Cumulative Cumulative Plus Project
Delay2 LOS Delay2 LOS
Highway 1/Clarinada
Avenue*
AM 18.0 C 21.8 C
PM 60.3 F 72.1 F
Callan Boulevard/
Clarinada Avenue*
AM 21.7 C 24.3 C
PM 69.6 F 86.7 F
Highway 1/Serramonte
Boulevard*
AM 49.6 E 115.0 F
PM 56.1 F 129.6 F

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Table 3.17-4: Cumulative Plus Project Intersection LOS at Adversely Affected Intersections Intersection Peak
Hour1
Cumulative Cumulative Plus Project
Delay2 LOS Delay2 LOS
Gellert Boulevard/
Serramonte Boulevard
AM 17.0 B 17.8 B
PM 53.1 D 69.2 E
Junipero Serra Boulevard/
Serramonte Boulevard
AM 35.4 D 36.9 D
PM 87.5 F 88.1 F
Skyline Boulevard/
Hickey Boulevard
AM 32.8 C 45.5 D
PM 77.9 E 85.5 F
Callan Boulevard/Hickey
Boulevard
AM 38.5 D 38.5 D
PM 112.9 F 129.5 F
Notes:
1 AM = Weekday morning peak hour (7:00-9:00 a.m.); PM = Weekday afternoon peak hour (4:00-6:00 p.m.) 2 Whole intersection average delay reported for signalized and all-way stop controlled intersections. Delay calculated per HCM 6th methodologies.

Bolded text indicates unacceptable operations pursuant to City standards. Bolded and underlined text indicates Project-related policy violation.
* Indicates an unsignalized intersection.

Source: Fehr & Peers. Transportation Impact Assessment for the Serramonte Del Rey Precise Plan. July 2022.

The following improvements would reduce project-related violations of the City’s LOS policy under cumulative plus project conditions and could be accommodated within the existing right-of-way. In addition, the following improvements would be required to implement all construction-related standard permit conditions, conditions of approval, and mitigation measures identified in this EIR.

Thus, construction of the improvements would have a less than significant impact on the environment.

Highway 1/Clarinada Avenue Improvement: Installation of a traffic signal. This improvement was identified as a remedy for existing plus Project conditions; it would also eliminate the Cumulative plus Project violation of the City’s LOS policies. The addition of project traffic to cumulative conditions would increase delay at this location while functioning at LOS F. The installation of a traffic signal at this location would result in acceptable operations (LOS B or better during both the morning and evening peak hours).

Highway 1/Serramonte Boulevard Improvement: Installation of a traffic signal. This improvement was identified as a remedy for Existing plus Project conditions; it would also eliminate the Cumulative plus Project violation of the City’s LOS policies. The addition of project traffic to cumulative conditions would increase delay at this location while functioning at LOS F in the PM peak hour and a degradation from LOS D to E in the AM peak hour. The installation of a traffic signal at this location would result in acceptable operations (LOS B under Existing plus Project conditions and LOS C under Cumulative plus Project conditions during both the morning and evening peak hours).

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Callan Boulevard/Clarinada Avenue Improvement: Installation of a traffic signal would be warranted at this intersection under cumulative conditions prior to the addition of project traffic. The addition of project traffic to the cumulative scenario would increase delay at this location while functioning at LOS F during the PM peak hour. The installation of a traffic signal at this location would result in acceptable operations (LOS B during both the morning and evening peak hours) under Cumulative plus Project conditions.

Gellert Boulevard/Serramonte Boulevard Improvement: Optimize the intersection’s traffic signal timing by increasing the cycle length to 120 seconds and optimizing splits to provide more time to the EB and WB approaches. This modification would improve the intersection’s operation to better than pre-project levels in the cumulative condition during the PM peak hour where the policy violation was identified.

Junipero Serra Boulevard/Serramonte Boulevard Improvement: Optimize the intersection’s traffic signal timing by increasing the cycle length to 130 seconds and optimizing splits to provide more time to all approaches. This modification would improve the intersection’s operation to better than pre-project levels in the cumulative condition during the PM peak hour where the policy violation was identified.

Skyline Boulevard/Hickey Boulevard Improvement: Optimize the intersection’s traffic signal timing by increasing the cycle length to 130 seconds and optimizing splits to provide more time to all approaches. This modification would improve the intersection’s operation to better than pre-project levels in the cumulative condition during the PM peak hour where the policy violation was identified.

Callan Boulevard/Hickey Boulevard Improvement: Stripe an exclusive westbound right turn lane on the Hickey Boulevard approach to Callan Boulevard. This modification would be accomplished within the existing roadway cross section through the elimination of on-street parking for approximately 200 feet approaching the intersection. This improvement was identified as a remedy for Existing plus Project conditions. This modification would improve the intersection’s operation to better than pre-project levels in the cumulative condition during the PM peak hour where the policy violation was identified. Optimize the intersection’s traffic signal timing by shortening the cycle length to 120 seconds and optimizing splits. This modification would improve the intersection’s operation to better than pre-project levels in the cumulative condition during the PM peak hour where the policy violation was identified.

Parking
Pursuant to Daly City Municipal Code Section 17.34.020, the City requires one parking space per studio/junior one-bedroom unit, 1.5 spaces per one-bedroom unit, two spaces for every unit with two bedrooms or more, and one parking space per 300 square feet of retail space, which equates to a City code requirement of 2,052 residential spaces and 47 retail spaces. 87 The proposed project would
construct a total of 1,853 residential spaces and 70 retail spaces, which would be 199 parking spaces below the minimum number of Code required residential parking spaces. 87 Buildout of the project is assumed to have a unit mix of 188 studio/junior one-bedroom units, 461 one-bedroom units, 586 two-bedroom units, and 14,000 square feet of retail space.

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The project’s residential parking requirements were also calculated using The Institute of Transportation Engineer’s (ITE) Parking Generation Manual, 5th Edition. ITE uses a rate of 1.23 and

1.37 parking spaces per low- to mid-rise apartments and high-rise apartments, respectively.88 Based on these generation rates, the project would generate a residential parking demand of 1,519 to 1,692 spaces. As discussed above, the proposed project would provide 1,853 residential parking spaces, which would exceed the ITE generation rates.
88 Institute of Transportation Engineer’s. Parking Generation Manual, 5th Edition. 2018.

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3.18 TRIBAL CULTURAL RESOURCES
The following discussion is based, in part, on a Cultural Resources Study prepared for the project by Tom Origer & Associates, dated February 26, 2021. A copy of this report is on file at the City of Daly City Planning Division.

3.18.1 Environmental Setting

3.18.1.1 Regulatory Framework
State
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.

3.18.1.2 Existing Conditions
As discussed in Section 3.5 Cultural Resources, based on a site-specific records search and literature review, there are no known archaeological sites on the project site or nearby. The NAHC was contacted on December 29, 2020 to conduct a Sacred Lands File search. On January 19, 2021, the NAHC responded and determined there were no known sacred lands on the project site or within the project area. The NAHC provided a list of five Native American organizations to reach out to for additional information. These organizations were contacted on December 29, 2020 and February 25, 2021. No responses were received from any of the organizations.

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On June 30, 2021, the City sent out notifications to the Amah Mutsun Tribal Band of Mission San Juan Bautista, Costanoan Rumsen Carmel Tribe, Indian Canyon Mutsun Band of Costanoan, Muwekma Ohlone Indian Tribe of the San Francisco Bay Area, and Ohlone Indian Tribe per SB 18 and AB 52. No responses were received from any of the tribes within 90 days of notice; therefore, tribal consultation was determined to be concluded as of September 28, 2021.

3.18.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on tribal cultural resources, would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
1) 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)? 2) A resource 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? In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

3.18.2.1 Project Impacts
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)
As documented under Section 3.18.1.2 Existing Conditions, there are no known TCRs within the Precise Plan area. As discussed in Section 3.5 Cultural Resources, the project site has a moderate potential to encounter subsurface tribal cultural resources. Construction-related ground disturbing activities could result in a significant impact to such resources if encountered. In the event that an inadvertent discovery of a tribal cultural resource is made, mitigation measures MM CUL-2.1, MM CUL-2.2, and MM CUL-3.1 would be implemented. Implementation of these mitigation measures would ensure that any subsurface tribal cultural resources encountered during construction are appropriately treated and protected. (Less than Significant Impact with Mitigation Incorporated)

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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 response to Impact TCR-1 above. (Less than Significant Impact with Mitigation Incorporated)

3.18.2.2 Cumulative Impacts
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) As discussed under Impact TCR-1, there are no known TCRs on the project site. In the event an unknown TCR is discovered, the mitigation measures identified in Section 3.5 Cultural Resources would reduce impacts to a less than significant level. The projects listed under Table 3.0-1 would be required to comply with state, regional, and local regulations addressing TCRs. Therefore, the projects would not combine to form a significant cumulative tribal cultural resources impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)

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3.19 UTILITIES AND SERVICE SYSTEMS
The following discussion is based, in part, on a Water Supply Assessment (WSA) and hydraulic analysis prepared by Brown and Caldwell, dated December 2021 and September 2021, and a sanitary sewer capacity evaluation memo prepared by Woodard & Curran, dated October 2021. Copies of these reports are attached to this EIR as Appendix M, Appendix N, and Appendix O respectively.

3.19.1 Environmental Setting

3.19.1.1 Regulatory Framework
State
State Water Code
Pursuant to the State Water Code, water suppliers providing water for municipal purposes to more than 3,000 customers or supplying more than 3,000 acre-feet (approximately 980 million gallons) of water annually must prepare and adopt an urban water management plan (UWMP) and update it every five years. As part of a UWMP, water agencies are required to evaluate and describe their water resource supplies and projected needs over a 20-year planning horizon, water conservation, water service reliability, water recycling, opportunities for water transfers, and contingency plans for drought events. The City of Daly City adopted its most recent UWMP in June 2021.

Senate Bill 610
SB 610 amended state law, effective January 1, 2002, to improve the link between information on water supply availability and certain land use decisions made by cities and counties. SB 610 requires preparation of a WSA containing detailed information regarding water availability to be provided to the decision-makers prior to approval of specified large development projects that also require a General Plan Amendment. This WSA must be included in the administrative record that serves as the evidentiary basis for an approval action by the city or county on such projects. Under SB 610, WSAs must be furnished to local governments for inclusion in any environmental documentation for certain projects subject to CEQA. Pursuant to the California Water Code (Section 10912[a]), projects that require a WSA include any of the following:
• A proposed residential development of more than 500 dwelling units; • A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space;
• A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space;
• A proposed hotel or motel, or both, having more than 500 rooms; • A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area;
• A mixed-use project that includes one or more of the projects identified in this list; or • A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.

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Assembly Bill 939
The California Integrated Waste Management Act of 1989, or AB 939, established the Integrated Waste Management Board, required the implementation of integrated waste management plans, and mandated that local jurisdictions divert at least 50 percent of solid waste generated (from 1990 levels), beginning January 1, 2000, and divert at least 75 percent by 2010. Projects that would have an adverse effect on waste diversion goals are required to include waste diversion mitigation measures.

Assembly Bill 341
AB 341 sets forth the requirements of the statewide mandatory commercial recycling program.

Businesses that generate four or more cubic yards of garbage per week and multi-family dwellings with five or more units in California are required to recycle. AB 341 sets a statewide goal for 75 percent disposal reduction by the year 2020.

Senate Bill 1383
SB 1383 establishes targets to achieve a 50 percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2020 and a 75 percent reduction by 2025. The bill grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that at least 20 percent of currently disposed edible food is recovered for human consumption by 2025.

California Green Building Standards Code
The California Green Building Standards Code (CALGreen) establishes mandatory green building standards for all buildings in California. The code covers five categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resources efficiency, and indoor environmental quality. These standards include the following mandatory set of measures, as well as more rigorous voluntary guidelines, for new construction projects to achieve specific green building performance levels:
• Reducing indoor water use by 20 percent;
• Reducing wastewater by 20 percent;
• Recycling and/or salvaging 50 percent of nonhazardous construction and demolition debris; and
• Providing readily accessible areas for recycling by occupants.

Local
City of Daly City General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from planned development projects with the City. The following policies are specific to utilities and service systems and are applicable to the proposed project.

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Policy/Task Description
Policy RME-1 Reduce average per capita demand by implementing cost effective water conservation programs that address all applicable methods of water conservation.

Task RME-1.1 Enforce the provisions of the Indoor Water Use Efficiency Ordinance through an extensive public outreach campaign to residents and contractors, to be completed by 2014.

Policy RME-2 Require drought resistant landscaping and water conserving irrigation methods in new development, and encourage the replacement of existing water-intensive landscaping.

Task RME-2.1 Enforce the provisions of the Water Conservation in Landscaping Ordinance and conduct a public education effort to ensure that residents, businesses, and contractors are aware of the Ordinance provisions.

Policy RME-3 Continue to use recycled wastewater for irrigating and explore opportunities to expand capacity to accommodate its use in development projects, landscaped medians, golf courses, cemeteries, parks, and school playgrounds.

Policy RME-4 For development projects which will create water demand exceeding a pre-defined amount, require that developers provide a water supply analysis for the project to demonstrate water availability to adequately serve the proposed project.

Task RME-4.1 Develop a water supply questionnaire for inclusion with any application involving 50 or more residential units, 50,000 square feet or commercial or industrial development, or other pre-defined development intensity that constitutes a significance threshold under CEQA.

Policy RME-8 Through the development of a Stormwater Management Program, ensure that all new development complies with applicable municipal stormwater Municipal Regional Stormwater NPDES Permit by incorporating controls that reduce water quality impacts over the life of the project in way that is both technically and economically feasible, and reduces pollutants in stormwater discharges to the maximum extent practicable.

Task RME-8.2 Evaluate acceptable development standards for stormwater treatment mechanisms and publish such standards for distribution to developers. Such standards shall be based on a thorough evaluation of modern stormwater control mechanisms and shall, to the extent feasible, consider soil conditions in various parts of Daly City.

Task RME-8.4 Assess projected stormwater impacts from new development in conformance with the San Mateo County Water Pollution Prevention Program, CEQA Guidelines and relative to state and federal standards.

Policy RME-9 Balance stormwater mitigation measures with the other inherent benefits of higher density development that is in close proximity to public transit, i.e., reduction of Vehicle Miles Traveled (VMT) on local and regional roadways, to the extent permitted under the Municipal Regional Stormwater Permit.

Policy IN-3.7 Design new projects to minimize potential damage due to stormwaters and flooding to the site and other properties.

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Daly City 2020 Urban Water Management Plan
The Urban Water Management Plan (UWMP) is a long-range plan that assesses the city’s water supply over a 25-year planning horizon (2045) to ensure adequate water supplies to meet existing and future demands for water. The UWMP presents forecasted supplies and demands, describes conservation programs, and includes a water shortage contingency analysis.

Daly City Municipal Code
Chapter 17.41, Water Conservation, establishes regulations to implement water conservation practices on existing and new landscapes. For projects containing more than 1,000 square feet of irrigated landscape, a landscape permit is required which requires irrigation design review. Further, this Chapter mandates that any owner of landscape of over one (1) acre in size shall comply with local agency programs that may be instituted relating to irrigation audits, surveys and water use analysis, and shall maintain landscape irrigation facilities to prevent water waste and runoff.

Chapter 15.64, Recycling and Diversion of Construction and Demolition Debris establishes that sixty percent of waste tonnage from construction, demolition, and alteration projects shall be diverted from disposal. This may be accomplished by delivering mixed debris to a recycling facility approved by the city, separating recyclables at the job site and delivering them to reuse and recycling facilities approved by the city, and/or reusing concrete or other waste materials at the jobsite. All new construction projects greater than twenty-five thousand dollars and all complete demolition projects within the city shall comply with the provisions of this chapter.

Daly City Sewer System Management Plan
The purpose of the Sewer System Management Plan (SSMP) is to provide guidance to the City in the operation, maintenance, and rehabilitation of the sewer assets of the City of Daly City. The SSMP includes construction standards and specifications for the installation and repair of the collection system and its associated infrastructure.

3.19.1.2 Existing Conditions
Water Service and Supply
Water service to the project site is provided by the Daly City Department of Water and Wastewater Resources (DWWR). The City relies on local groundwater pumping from five municipal wells, which extracts groundwater from the Westside Groundwater Basin, and water supply purchases from the San Francisco Public Utilities Commission (SFPUC).89 The City also uses tertiary recycled water from the North San Mateo County Sanitation District wastewater treatment plant, to offset potable/aquifer water demands. Currently recycled water is used to water five golf courses, two city parks, and road median strips. Recycled water is not a source of water proposed for the project site. 89 Brown and Caldwell. Daly City 2020 Urban Water Management Plan. June 2021. Page 6-8.

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The project site is currently served by a six-inch water main in Serramonte Boulevard and a 10-inch water main in at the northern terminus of Campus Drive and running north through the project site.

The project site used approximately 33,000 gallons per day (gpd) of water in 2020. 90 Sanitary Sewer/Wastewater Treatment
Sanitary sewer lines in the project area are inspected and maintained by the City of Daly City Department of Water and Wastewater Resources. A 10-inch sanitary sewer line is located in Serramonte Boulevard. Wastewater collection and treatment for Daly City is managed by the North San Mateo County Sanitation District (NSMCSD), which is a subsidiary of the City of Daly City.

Wastewater produced within the District is treated at the NSMCSD Treatment Plant (WWTP), which is located at the corner of John Daly Boulevard and Lake Merced Boulevard.

The City of Daly City’s WWTP has an average dry weather flow design capacity of 10.3 million gallons per day (gpd). However, the NSMCSD discharges and operates the WWTP at or below the permitted average dry weather flow rate of eight million gpd (averaged over three consecutive dry months) and does not anticipate a need to increase the permitted flow rate in the next five years.

The project site currently generates approximately 28,050 gpd of wastewater.91 Storm Drainage
As discussed in Section 3.10 Hydrology and Water Quality, the project site is located within the Colma Creek Watershed which extends from San Bruno Mountain to its outlet at the San Francisco Bay just north of the San Francisco Airport and south of Point San Bruno. The northwest portion of the project has been developed with the approved Parcel A Development project (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 buildings. Surface runoff from the project site is collected in area drains and conveyed to a 24-inch storm drain in Serramonte Boulevard that flows to the east.

Solid Waste
Solid waste is collected from Daly City homes and businesses and is processed by Republic Services of Daly City and transferred to the Ox Mountain Sanitary Landfill near Half Moon Bay. In 2001, Browning-Ferris Industries, owner of the Ox Mountain Landfill, obtained a revised solid waste facility permit for Ox Mountain to increase the permitted disposal acreage from 173 acres to 191 acres. According to CalRecycle, the landfill has a remaining capacity of 22,180,000 cubic yards and an estimated closure date of 2034.92
90 Brown and Caldwell. Water Supply Assessment for Jefferson Union High School District Master Plan Project.

December 2021. Page 2-2. 91 Sewage demand is estimated to be 85 percent of potable water demand (0.03 mgy). 92 CalRecyle. SWIS Facility Detail. Cordina Los Trancos (Ox Mtn) (41-AA-0002). Accessed on August 4, 2022. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223.

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Electric, Telecommunication, and Natural Gas Facilities 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. PG&E supplies natural gas services to the project area. Telecommunication services are also provided through underground infrastructure by various service providers.

3.19.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on utilities and service systems, would the project:
1) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
2) Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? 3) Result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
4) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? 5) Be noncompliant with federal, state, or local management and reduction statutes and regulations related to solid waste?

3.19.2.1 Project Impacts
Impact UTL-1: The project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. (Less than Significant Impact)
Water
The proposed project would connect to an existing 10-inch water main located in Entry Drive.

Additional 10-inch water mains would be installed along the new streets within the project site.

Water service to the entire project site would be provided via the newly constructed water lines.

Construction of this new water line would be subject to construction-related mitigation measures within this EIR and therefore, would not result in a significant environmental effect.

Wastewater/Sanitary Sewer
The project proposes to connect to the existing 10-inch sanitary sewer line in Serramonte Boulevard and six-inch sewer line in Callan Boulevard. In addition, the project would reroute existing 10-inch

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sewer lines running through the project site to better align with future development under the proposed project. Woodard & Curran estimated the average daily wastewater flow to be generated by the proposed project and its effects on the existing wastewater system (see Appendix O). The proposed project’s wastewater would not cause any capacity deficiencies in the rerouted on-site sewers or in the sewers on Serramonte Boulevard downstream, however, the project flows would contribute to capacity deficient sewers in the Serramonte Center and the 21-inch trunk sewer crossing the I-280 freeway to Junipero Serra Boulevard. The need for a 30-inch relief sewer line parallel to the 21-inch sewer crossing I-280 was identified in the 2009 Collection System Evaluation and Improvement Plan, and the project would be required to contribute a proportional fair share contribution toward the construction of the relief sewer line.

Stormwater Drainage
As discussed in Section 3.10 Hydrology and Water Quality, future development of the proposed Precise Plan would result in an overall increase of 88,545 square feet of impervious surfaces compared to existing conditions; however, the project would be designed to retain stormwater on-site and not exceed pre-project stormwater flows during a 10-year design storm. Thus, future development implementing the proposed Precise Plan, in conformance with applicable regulations, would not result in significant impacts to the storm drain system.

Electricity, Telecommunication, and Natural Gas Facilities The project would tie-in to the existing electricity, telecommunication, and natural gas lines throughout the project site. Any conductor upsizing work would be performed by PG&E as needed.

All project construction associated with relocating existing facilities and extending connections to existing facilities would be subject to the construction-related mitigation measures within this EIR and conditions of approval typically applied to development project entitlements. Therefore, any needed relocation of existing facilities and extension of connections to existing facilities would not result in a significant environmental effect. (Less than Significant Impact) Impact UTL-2: The project would not have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. (Less than Significant Impact)
Based on the WSA prepared for the project, in the event the Bay Delta Plan is implemented,93 water demand would exceed supply in normal, single-dry, and multiple-dry year scenarios by 2023.

Without implementation of the Bay Delta Plan, water demand would not exceed supply in normal, single-dry, and multiple-dry year scenarios through 2045. The project would increase water use on the site by approximately 202,600 gpd.94 The project would result in a population increase that is within the estimated population projections used in the City’s UWMP. The City identifies demand 93 The implementation of the Bay Delta Plan is currently in litigation which creates uncertainty in the available supply for Daly City.
94 Brown and Caldwell. Hydraulic Analysis for the Westlake South Project. April 2021. 712 net new residents x 60 gallons per capita per day = 42,720 gpd; 10,800 sf x 0.0450 gallons per sf per day = 486 gpd. Total project water use estimate: 42,720 gpd + 486 gpd = 43,206 gpd.

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reduction actions in the UWMP that could be used to reduce water demand, ranging from voluntary reductions to prohibiting landscape irrigation. The use of demand reduction measure, which could be required City-wide in single-dry and multiple-dry year scenarios, ensures the City would have adequate water supply under all scenarios. The City, therefore, would have sufficient water supplies to serve the project and cumulative water demand during normal, dry, and multiple dry years. (Less than Significant Impact)
Impact UTL-3: The project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. (Less than Significant Impact)
The WWTP has an average dry weather flow design capacity of 10.3 million gallons per day (mgd).

The General Plan EIR determined that full buildout of the General Plan would generate approximately 6.66 mgd which is below the permitted flow rate of eight mgd, leaving 1.34 mgd of unused capacity at buildout. The project would add approximately 191,793 gpd (0.19 mgd) of wastewater to be treated at the WWTP, or approximately 14 percent of the unused capacity.95 The project, therefore, results in a less than significant increase in wastewater flow. In addition, the WWTP monitors its wastewater to ensure that it meets all requirements and the RWQCB routinely inspects treatment facilities to ensure permit requirements are met. For these reasons, there would be adequate capacity at the WWTP. (Less than Significant Impact) Impact UTL-4: The project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. (Less than Significant Impact)
Waste generation and disposal data for Daly City is maintained by CalRecycle. According to CalRecycle, the total amount of solid waste landfilled from Daly City in 2021 was 45,636 tons.96 The project would generate approximately 530 tons of solid waste per year.97 The Ox Mountain Landfill has a remaining capacity of approximately 22,180,000 cubic yards of solid waste.98 The project would increase solid waste generation in the City by approximately one percent and, therefore, would not generate solid waste in excess of local standards or capacity and would not impair the attainment of solid waste reduction goals. (Less than Significant Impact) 95 Woodard & Curran. Sanitary Sewer Capacity Evaluation for JUHSD Precise Plan. October 2021. Page 2. 96 CalRecycle. “Disposal Rate Calculator”. Accessed August 15, 2022. https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/DisposalRateCalculator. 97 Illingworth & Rodkin, Inc. Serramonte Del Rey Campus Redevelopment Project Air Quality and Greenhouse Gas Assessment. June 17, 2022. Attachment 2: CalEEMod Modeling Inputs and Outputs. 98 CalRecycle. “Solid Waste Information Sheet: Corinda Los Trancos Landfill (Ox Mtn) (41-AA-0002).” Accessed August 4, 2022. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223

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Impact UTL-5: The project would not be noncompliant with federal, state, or local management and reduction statutes and regulations related to solid waste. (Less than Significant Impact)
The project would comply with solid waste management and reductions statutes and regulations including CALGreen requirements and Chapter 15.64 of the Daly City Municipal Code for recycling and salvaging of construction and demolition waste. (Less than Significant Impact)

3.19.2.2 Cumulative Impacts
Impact UTL-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant utilities and service systems impact. (Less than Significant Cumulative Impact)
Relocation or construction of new or expanded utility facilities by other projects would also be subject to similar construction-related mitigation measures as the proposed project. The City’s UWMP and the WSA prepared for the project, which accounts for cumulative demand, both concluded the City will have sufficient water supplies to accommodate growth within its service jurisdiction and will meet any potential supply shortfalls experienced during dry year conditions, through a combination of a short-term conservation program. With regard to wastewater treatment, the WWTP has an available capacity of approximately 1.34 mgd after full buildout of the General Plan. The Serramonte Shopping Center Expansion and Seton Medical Center Expansion projects are consistent with the City’s General Plan and, therefore, their wastewater generation is already accounted for. The Serramonte Condominiums and Hotel project would generate approximately 88,660 gdp (0.09 mgd) of wastewater, which could be accommodated by the remaining capacity at the WWTP, in addition to the proposed project. Other projects would also be required to comply with CALGreen and Chapter 15.64 of the Daly City Municipal Code, thereby also reducing their construction and demolition waste by at least 60 percent. As previously discussed, Ox Mountain Landfill has a remaining capacity of approximately 22,180,000 cubic yards and an estimated closure date of 2034. Therefore, the Ox Mountain landfill could sufficiently accommodate the proposed project and the cumulative projects listed in Table 3.0-1. Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant utilities and service systems impact. (Less than Significant Cumulative Impact)

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3.20 WILDFIRE

3.20.1 Environmental Setting

3.20.1.1 Existing Conditions
The California Department of Forestry and Fire Protection (Cal Fire) is required by law to map areas of significant fire hazards based on fuels, terrain, weather, and other relevant factors. Referred to as Fire Hazard Severity Zones (FHSZ), these maps influence how people construct buildings and protect property to reduce risk associated with wildland fires. The project site is not located in a FHSZ.99

3.20.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on wildfire, if located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
1) Substantially impair an adopted emergency response plan or emergency evacuation plan? 2) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
3) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? 4) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

3.20.2.1 Project Impacts
The project site is not located in or near state responsibility areas or lands classified as very high fire hazard severity zones; therefore, the project would not result in wildfire impacts. (No Impact)

3.20.2.2 Cumulative Impacts
The project site is not located in or near state responsibility areas or lands classified as very high fire hazard severity zones; therefore, the project would not result in cumulative wildfire impacts. (No Cumulative Impact)
99 CALFire. San Mateo County Fire Hazard Severity Zones in SRA. Adopted by CALFire on November 7, 2007.

Map. Accessed August 15, 2022. https://osfm.fire.ca.gov/media/6802/fhszs_map41.pdf

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SECTION 4.0 GROWTH-INDUCING IMPACTS
For the purposes of this project, a growth-inducing impact is considered significant if the project would:
• Cumulatively exceed official regional or local population projections; • Directly induce substantial growth or concentration of population. The determination of significance shall consider the following factors: the degree to which the project would cause growth (i.e., new housing or employment generators) or accelerate development in an undeveloped area that exceeds planned levels in local land use plans; or • Indirectly induce substantial growth or concentration of population (i.e., introduction of an unplanned infrastructure project or expansion of a critical public facility (road or sewer line) necessitated by new development, either of which could result in the potential for new development not accounted for in the Daly City 2030 General Plan).

Impact GRO-1: The project would not foster or stimulate significant economic or population growth in the surrounding environment. (Less than Significant Impact) Under the existing General Plan and 1985 Precise Plan, the project site would be allowed to be developed with up to 175 residential units and 700,000 square feet of office uses. Compared to what is allowed by the 1985 Precise Plan, the project would result in a net increase of 1,060 residential units and a net decrease of 684,000 square feet of employment uses (office and retail). This net change in development would result in approximately 3,403 additional residents.100 Compared to the buildout of the General Plan, the project would represent an approximately three percent net increase in the City’s population.101 While the project would result in an increase in population and housing compared to what is allowed in the adopted 1985 Precise Plan and General Plan, the project would be consistent with the City’s goal of maximizing opportunities for higher-density housing (General Plan Policy HE-1 and Policy LU-4) and meeting the City’s RHNA target (General Plan Policy HE-6). In addition, the project would result in a minimal increase in population (three percent increase) compared to the City’s estimated ABAG 2035 population of 115,015. The project, therefore, would not induce growth in an area that is not already planned for increased development.

The project site is located in an urban area on an already developed site that is served by existing infrastructure, including roadways and utilities. The growth resulting from the implementation of the proposed project would incrementally increase the use of existing community service facilities (refer to Sections 3.15 Public Services and 3.16 Recreation). Utility improvements would be sized to serve the proposed development, and would not be sized to have excess capacity that would induce growth in the area. In addition, the project would pay all applicable impact fees and taxes, which would 100 1,235 (number of housing units proposed) minus 175 (number of planned housing units) equals 1,060 housing units. Based on the City’s average number of persons per housing unit (3.21), the 1,060 units would generate 3,403 additional residents. As the majority of employment uses would be eliminated, demand for housing from new businesses was assumed to be zero. Source: State of California, Department of Finance. E-5 Population Estimates for Cities, Counties, and the State—January 1, 2021-2022. May 2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-countiesand-the-state-2020-2022/. 101 Buildout of the City’s General Plan would result in 106,388 residents.

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offset fiscal and service impacts to public facilities and services, including police and fire. As a result, growth associated with the implementation of the project would not have a significant impact on community service facilities, nor would it make a cumulatively considerable contribution to such impacts, requiring construction of new facilities that could cause significant environmental effects.

For the reasons discussed above, the project would not result in significant indirect growth-including impacts. (Less than Significant Impact)

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SECTION 5.0 SIGNIFICANT AND IRREVERSIBLE

ENVIRONMENTAL CHANGES
This section was prepared pursuant to CEQA Guidelines Section 15126.2(c), which requires a discussion of the significant irreversible changes that would result from the implementation of a proposed project. Significant irreversible changes include the irretrievable use of nonrenewable resources, the commitment of future generations to similar use, and irreversible damage resulting from environmental accidents associated with the project.

5.1.1 Irretrievable Use of Nonrenewable Resources
During construction and operation of the project, nonrenewable resources would be consumed.

Unlike renewable resources, nonrenewable resources cannot be regenerated over time. Nonrenewable resources include fossil fuels and metals. Renewable resources, such as lumber and other wood byproducts, could also be used.

Energy, as discussed in more detail in Section 3.6 Energy, would be consumed during both the construction and operational phases of the project. The construction phase would require the use of nonrenewable construction material, such as concrete, metals, plastics, and glass. Nonrenewable resources and energy would also be consumed during the manufacturing and transportation of building materials, site preparation, and construction of the buildings. The operational phase would consume energy for multiple purposes including building heating and cooling, lighting, appliances, and electronics. Energy, in the form of fossil fuels, would be used to fuel vehicles traveling to and from the site.

The project would result in a substantial increase in demand for nonrenewable resources; however, the project is subject to the standard California Code of Regulations Title 24 Part 6, CALGreen standards, City of Daly City Green Building requirements, and Recycling and Diversion of Construction and Demolition Ordinance. In addition, as discussed in Section 3.6 Energy, the electricity for the project would be provided by Peninsula Clean Energy from sources that are 100 percent carbon-free. For these reasons, future projects would minimize the use of nonrenewable energy resources.

5.1.2 Commitment of Future Generations to Similar Use
The project would redevelop a currently developed site surrounded by urban uses. Development of the proposed project would commit a substantial amount of resources to prepare the site, construct the buildings, and operate them, but it would not result in development in an area where urban development does not already exist.

5.1.3 Irreversible Damage Resulting from Environmental Accidents The project proposes a residential, mixed-use development that is not a uniquely hazardous use nor likely to cause environmental accidents that impact adjacent areas. As discussed in Section 3.9 Hazards and Hazardous Materials, there are no significant unmitigable hazards and hazardous materials conditions on-site or off-site that would substantially affect the public and surrounding environment. Additionally, there are no significant unmitigable geology and soils impacts which

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would result from implementation of the project. For these reasons, the project would not result in irreversible damage that may result from environmental accidents.

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SECTION 6.0 SIGNIFICANT AND UNAVOIDABLE IMPACTS
A significant unavoidable impact is an impact that cannot be mitigated to a less than significant level if the project is implemented as it is proposed. The proposed project would not result any significant and unavoidable impacts, as all significant impacts are capable of being mitigated to acceptable levels by feasible mitigation measures included in the project.

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SECTION 7.0 ALTERNATIVES
The California Environmental Quality Act (CEQA) requires that an EIR identify and evaluate alternatives to a project as it is proposed. Two key provisions from the CEQA Guidelines pertaining to the discussion of alternatives are included below:

Section 15126.6(a). Consideration and Discussion of Alternatives to the Proposed Project.

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.

Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Section 15126.6(b). Purpose. Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede, to some degree, the attainment of the project objectives, or be more costly.

Other elements of the CEQA Guidelines discuss that alternatives should include enough information to allow a meaningful evaluation and comparison with the proposed project. The CEQA Guidelines state that if an alternative would cause one or more additional impacts, compared to the proposed project, the discussion should identify the additional impact, but in less detail than the significant effects of the proposed project.

The three critical factors to consider in selecting and evaluating alternatives are: (1) the significant impacts from the proposed project that could be reduced or avoided by an alternative, (2) consistency with the project’s objectives, and (3) the feasibility of the alternatives available. Each of these factors is discussed below.

7.1 SIGNIFICANT IMPACTS FROM THE PROJECT

7.1.1 Significant Unavoidable Impacts
As mentioned above, the CEQA Guidelines advise that the alternatives analysis in an EIR should be limited to potentially feasible alternatives that would avoid or substantially lessen any of the significant effects of the project and would achieve most of the project objectives. The project would not result in any significant, unavoidable impacts.

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7.1.2 Less than Significant Impacts with Mitigation Incorporated Alternatives may also be considered if they would further reduce impacts that are already less than significant because of required or proposed mitigation. Impacts that would be significant, but for which the mitigation is available to reduce them to less than significant levels include:
• Air Quality (construction criteria pollutants, TAC health risk) • Biological Resources (bats, nesting birds)
• Cultural Resources (archaeological resource/human remains) • Geology and Soils (paleontological resources)
• Hazards and Hazardous Materials (underground/aboveground storage tanks) • Noise (construction noise)
• Transportation (vehicle miles traveled, construction traffic, pedestrian/bicycle safety, emergency access)
• Tribal Cultural Resources (unknown buried tribal cultural resources) Table 7.4-2 summarizes the project and project alternatives impacts, including less than significant impacts with mitigation incorporated.

7.2 PROJECT OBJECTIVES
Pursuant to CEQA Guidelines Section 15124, the EIR must include a statement of the objectives sought by the proposed project. While CEQA does not require that alternatives be capable of meeting all of the project objectives, their ability to meet most of the objectives is considered relevant to their consideration. The stated objectives of the project proponent include the following:
• 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 active 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.

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• 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.

7.3 FEASIBILITY OF ALTERNATIVES
CEQA, the CEQA Guidelines, and the case law on the subject have found that feasibility can be based on a wide range of factors and influences. The CEQA Guidelines advise that such factors can include (but are not necessarily limited to) the suitability of an alternate site, economic viability, availability of infrastructure, consistency with a general plan or with other plans or regulatory limitations, jurisdictional boundaries, and whether the project proponent can “reasonably acquire, control or otherwise have access to the alternative site (Section 15126.6[f][1]).”

7.4 ALTERNATIVES ANALYSIS

7.4.1 Alternatives Considered But Rejected

7.4.1.1 Location Alternative
CEQA encourages consideration of an alternative site when significant effects of the project might be avoided or substantially lessened. Only locations that would avoid or substantially lessen any of the significant impacts of the project and meet most of the project objectives need be considered for inclusion in the EIR. In order to identify an alternative site that might reasonably be considered to “feasibly accomplish most of the basic purposes” of the project, and would also mitigate some or all of the significant impacts of the project, it is assumed that such a site would need to have the following characteristics:
• Approximately 20-acres or more in size;
• Located on land owned by the Jefferson Union High School District (JUHSD); • Located on an underutilized, already developed property; • Served by available infrastructure and nearby commercial amenities; and • Immediately available.

The project objectives focus on developing residential uses on land owned by JUHSD to help stabilize JUHSD finances. JUHSD currently operates five high schools, including three in the City of Daly City (Westmoor, Jefferson, and Thornton High Schools) and two in the City of Pacifica (Oceana and Terra Nova High Schools), and the Serramonte Del Rey campus located on the project site. While these high school sites may have undeveloped space that meets the size requirement, they do not include underutilized facilities that would benefit from redevelopment to higher-density residential and commercial uses. In addition, JUHSD recently received approval for construction of a new district office and adult education building located adjacent to Westmoor High School (see Figure 2.2-6). This new building would replace the existing district office uses on the project site, rendering the current project site vacant and allowing for new tenants or redevelopment. Further, location alternatives were rejected because the potentially suitable sites located on JUHSD land would not reduce the identified less than significant construction criteria pollutant, TAC health risk, and construction noise impacts because construction would occur on these alternative sites in a

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similar manner to the proposed project site and the surrounding mix of uses is similar (with sensitive residential and/or school receptors in the immediate vicinity). Other construction related impacts, such as disturbance of nesting or water quality impacts, would be similar and require the same mitigation identified for the subject site. Since no feasible alternative site was identified that would avoid or lessen the project impacts, a location alternative was not further analyzed.

7.4.1.2 Mixed-Use Alternative
The project proposes a mostly residential development with 1,035 residential units and 14,000 square feet of commercial uses. The Mixed-Use Alternative was considered to reduce the VMT per resident below the countywide threshold by introducing office uses to the site and creating a mixed-use live/work community to avoid or lessen the need for ongoing mitigation in the form of a TDM program that reduces project trips. The Mixed-Use Alternative includes 1,035 residential units and 230,000 square feet of office space. The modeling results, however, show that this alternative’s VMT per resident would remain at 12 VMT and continue to exceed the countywide threshold of 11.6 VMT per resident. In addition, this alternative would generate 17.9 VMT per office employee, which would exceed the countywide threshold of 14.3 VMT and regionwide threshold of 13.1.102 Further, this alternative would result in an additional 230,000 square feet of building square footage, resulting in greater construction impacts compared to the proposed project. Since the Mixed-Use Alternative would not reduce the VMT per resident and create a new office VMT impact, this alternative was rejected.

7.4.1.3 Reduced Housing Alternative
The purpose of a Reduced Housing Alternative would be to reduce the project’s impacts that result from the overall scale of the development by developing a smaller program of development. Of the project’s significant impacts, only air quality, noise, and transportation impacts could potentially benefit from a reduced housing alternative. All other impacts are related to site/ground disturbance, which any amount of development would incur. VMT is expressed as a per resident number; therefore, while a reduced housing alternative would reduce overall trips, it would not cause a change in the amount of VMT per resident. Thus, the VMT impact of the Reduced Housing Alternative would be the same as the proposed project. Construction criteria pollutant air quality emissions and construction noise impacts tied to the amount of building construction activity could be further reduced with a reduced housing alternative; however, the project’s construction ROG emissions are related to architectural coatings applied in the last year of project construction. The Reduced Housing Alternative would have similar ROG emissions, as architectural coatings, during the last year of construction; therefore, this alternative would not result in similar ROG emissions impacts as the proposed project. This alternative would partially meet the project’s objectives to redevelop underutilized properties with high-density development and maximize the number of market-rate housing units in order to stabilize JUHSD’s finances; however, the cost of land improvement (i.e., demolition, grading, infrastructure, off-site improvements) would remain unchanged and the reduced housing would lower revenue generated to off-set those costs. In addition, the No Project – Existing Zoning Alternative is another reduced development alternative (see Section 7.4.2.2 below). For these reasons, this alternative was rejected.
102 Fehr & Peers, Inc. Serramonte Del Rey Precise Plan – Alternatives VMT. April 2023.

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7.4.2 Analyzed Alternatives
In addition to a “No Project” Alternative, the CEQA Guidelines advise that the range of alternatives discussed in the EIR should be limited to those that “would avoid or substantially lessen any of the significant effects of the project” (Section 15126.6[f]). The discussion below addresses alternatives which could reduce project impacts and are feasible from a physical land use, infrastructure, site suitability, and general plan consistency perspective, and whether the proponent can reasonably acquire, control, or otherwise have alternative access to the site. This Draft EIR does not evaluate the financial or economic feasibility of the alternatives. The components of these alternatives are described below, followed by a discussion of their impacts and how they would differ from those of the proposed project.

7.4.2.1 No Project Alternative
The CEQA Guidelines specifically require consideration of a “No Project” Alternative. The purpose of including a No Project Alternative is to allow decision makers to compare the impacts of approving the project with the impacts of not approving the project. The Guidelines specifically advise that the No Project 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.” The Guidelines emphasize that an EIR should take a practical approach, and not “…create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment (Section 15126.6[e][3][B]).” The No Project Alternative assumes that the project site would remain as it is today with the existing buildings being reoccupied.

Comparison of Environmental Impacts
The No Project Alternative would avoid all the project’s environmental impacts.

Relationship to Project Objectives
The No Project Alternative would not meet most of the project objectives as no change would be made to the existing land uses at the site and the current land uses do not provide any residential facilities. In addition, the current project site design is low density and not transit oriented. The No Project Alternative could potentially partially meet the project’s objective to attract investment and stabilize District finances by renovating the existing buildings and leasing them to new tenants, although the market for new office or other tenants to occupy the existing JUHSD headquarters campus is unknown.

Conclusion
Because the No Project Alternative would not result in any new development on the site, this alternative would avoid all environmental impacts of the project. This alternative would not, however, meet most of the project’s objectives, in particular those related to providing substantial new housing opportunities on the site.

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7.4.2.2 No Project – Existing Zoning Alternative
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).103 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 (in addition to the units developed on Parcel A) and approximately 700,000 square feet of office space, resulting in approximately one millions square feet of building space.104 Associated infrastructure and roadway improvements would also be required in order to construct the No Project – Existing Zoning Alternative. Based on the City’s average number of persons per housing unit (3.21), the 175 residential units would generate 562 additional residents.105 The 700,000 square feet of office space is estimated to generate approximately 2,100 employees (using an estimate of three employees per 1,000 square feet).

Comparison of Environmental Impacts
The No Project – Existing Zoning Alternative would result in the development of approximately 175 residential units and 700,000 square feet of office, while the proposed project would develop the site with 1,235 residential units (including Parcel A units) and up to 14,000 square feet of neighborhoodserving retail/commercial uses (in addition to 1,400 square feet for a Head Start childcare facility).

Overall the No Project – Existing Zoning Alterative would result in approximately one million square feet of building space, while the proposed project would result in approximately 1.5 million square feet of building space. The No Project – Existing Zoning Alternative would trade residential density for office density; however, the intensity and duration of construction required in order to construct 700,000 square feet of office space and 175 residential units would less than the proposed project, as this alternative reduces the overall building square footage by approximately 500,000 square feet less. Given that the overall building square footage would be smaller than the proposed project, the No Project – Existing Zoning Alternative would result in lesser construction criteria pollutant, TAC health risk, construction noise, and construction traffic impacts.

As discussed above, the No Project – Existing Zoning Alternative would trade residential density for office density. As a result, VMT for this alternative is calculated based on a per resident and per employee metric. As shown in Table 7.4-1 below, the residential component of the No Project – Existing Zoning Alternative is projected to generate 12.2 VMT per resident (0.2 VMT higher than the proposed project), which is below the regionwide significance threshold of 12.4 VMT per resident, but in excess of the countywide threshold of 11.6 VMT per resident. The office component of this alternative is projected to generate 17.5 VMT per employee, which exceeds the regionwide significance threshold of 14.3 VMT and the countywide significance threshold of 13.1 VMT. As a result, the No Project – Existing Zoning Alternative would result in more significant VMT impacts than the proposed project in that it would increase the per resident VMT and introduce a significant office VMT impact.
103 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. 104 Assumes a total of 297 residential units (Parcel A project [122] + existing zoning[175]) and each residential unit requires approximately 1,000 square feet of building space. 700,000 + 297,000 = 997,000. 105 State of California, Department of Finance. E-5 Population Estimates for Cities, Counties, and the State— January 1, 2021-2022. May 2022.