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through education, increases fruit and vegetable intake, increases physical activity through garden maintenance activities, reduces the risk of obesity and obesity-related diseases, improves mental health, promotes relaxation, provides needed biodiversity, includes hundreds of plant species including native plants, provides wildlife habitat, includes trees and shrubs of different densities and heights giving birds a places of retreat and safety, includes a number of redwood trees and fruit trees, the garden includes a seasonal wetland, reduces erosion from runoff, provides natural flood control, improves water quality and serves as a vital component of effective adaptation and resilience to climate change. Children’s toys within the garden point to widespread community use and the functioning of the garden like a park. All the public benefits will be lost with the project as currently conceived.
Not keeping public resource uses feasible results in significant equity issues such as nature-deficit disorder which contributes to a diminished use of the senses, attention difficulties, conditions of obesity, and higher rates of emotional and physical illnesses. Research also suggests that the nature-deficit weakens ecological literacy and stewardship of the natural world, resulting in apathy in the face of climate change disasters such as wildfires, sea level rise, and extreme heat which Daly City needs to counter. Accordingly, we support increasing community gardening opportunities on public lands in Daly City. Preserving public uses such as community gardens and parks serves public needs, safety, and recreation. The DEIR is deficient in not looking at the significant harms from the loss of public lands to privatization that could have been feasibly preserved and should be redone.
Response HH.18: Please refer to Master Response 1: Demonstration Garden and Master Response 6: Recreation. Public agencies regularly dispose of surplus public property to private entities for development. The conversion of public lands to private leases is addressed through the CEQA process by evaluating and disclosing the environmental impacts (e.g. air quality, noise, water usage, cultural resources, etc.) that would result from the proposed new use, however, the fact that a project involves a public property being conveyed to, and developed by, a private use is not in and of itself an environmental impact, and, therefore, is not discussed in the Draft EIR.
Comment HH.19: Section 3.11.2 Land Use
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)
Section 3.11.2 states that the project would not conflict with any land use plan, policy or regulation.
The report states (page 124) “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.” The report states that the Daly City Inclusionary Housing Ordinance is intended to address negative environmental impacts, by requiring construction of units for very low and low income households. Failure to follow the ordinance would have the
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following negative environmental impacts “(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.
In California, cities must develop plans to meet Residential Housing Needs Allocation (RHNA) plans for the community. In the Daly City Housing Element submitted in June 2023, during the period 2023-2031, Daly City is required to plan for 4838 units of which 1336 are very low income (to included 50 percent extremely low income), and an additional 769 are to be low income, and 762 are moderate income. According to the DEIR, the SDR project will provide only 10 percent “affordable” units (i.e. very low, low and moderate income), approximately 120 units of the approximately 1235 units planned for this project. None of the units are included in Plot B, which is the only part of the project specifically addressed in the DEIR.
The Daily City Inclusionary Housing ordinance requires that low and very low income units be constructed at the same time as other units, and be physically distributed throughout the development. This apparent non-compliance with City law was pointed out in the attached November 15 2021 memorandum from the City’s Director of Economic and Community Development, Housing and Community Development Supervisor, and Housing Coordinator.
As pointed out in the attached August 21 letter from Grassetti Environmental Consulting, this project will also make it extremely difficult for Daly City to achieve the RHNA allocation of low and very low income housing. The DEIR should be revised to reflect that this project is not in compliance with current land use policy and law.
Response HH.19: Please refer to Master Response 2: Regional Housing Needs Allocation and Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law above. In addition, the excerpted Draft EIR text in the comment notes the project would provide at least 10 percent affordable housing.
Since publication of the DEIR, it has been clarified the project would provide 20 percent affordable units. See Section 5.0 Draft EIR Text Revisions below.
Comment HH.20: 3.13 Noise
Shasta High School was not included in the table 3.13-6 on Noise Levels for Monthly test of the Emergency Generators.
Response HH.20: The receptors listed in Table 3.13-6 were chosen to provide a range of distances from the proposed emergency generators. Shasta High School is directly south of Parcel C, which was not assumed to have an emergency generator.
The school is, however, approximately 100 feet south of Parcel D, which would fall within the ranges identified in the table. Moreover, receptors of the apartment
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complexes, located directly south of Parcels E and F (and thus situated similarly as the high school students), were considered in evaluating noise impacts, and no significant noise impacts were identified. For informational purposes, impacts were even evaluated on project users, some of whom would be located as close as 60 feet to a generator and, even in these circumstances, no significant impacts were identified. Thus, noise impacts to the high school are accounted for. The Draft EIR concluded that emergency generator testing would not exceed ambient noise levels at any nearby sensitive receptors; therefore, the impact would be less than significant (see page 143 of the Draft EIR).
Comment HH.21: Operational Noise: Noise Impact Shasta High School pg 135 and Construction Noise pg 135
As stated: this type of construction equipment could generate noise ranging from 70 to 90 dBA at a distance of 50 feet.
Table 3.13-4 indicates that the South School (Shasta) is 290 ft from Parcel C/D. Parcel C is next to Shasta so not clear on what is the actual distance from noise generating construction equipment to receptors at Shasta, but some portions of the school may be closer than 290 feet. Since construction is planned M-F 8:00 to 5:00 weekdays, which are also scheduled school hours , more information should be specifically provided for Shasta High School on noise impact. Current impact is projected as 77 dBA during demolition and grading.
Excessive ambient noise levels interfere with classroom communication and learning. The American National Standards Institute recommends that ambient noise in a “core learning space” not exceed 35 dBA (not including noise generated by classroom activities). Insufficient information is provided regarding the outdoor-indoor transmission characteristics of the school building, but projected source noise levels indicate that the school will be significantly impacted. Mitigation measures providing 5 dBA reduction, presumably at the source, do not ensure that noise levels are maintained below recommended levels at the school. Given the long time-line for construction at the site. The EIR does not provide a sufficient analysis of noise impacts, and there is no assurance that the mitigation measures will produce sufficient reduction in noise at the school.
No mitigation measures on construction noise references Shasta High School. Pg 140-141.
Response HH.21: The distances stated in Table 3.13-4 are measured from the center of each parcel to the nearest sensitive receptor. As discussed in Section 3.13 Noise under Impact NOI-1 of the Draft EIR (page 140), the threshold for noise impacts during construction is 90 dBA Leq at residential land uses (which threshold is also used for classrooms) or 100 dBA Leq at commercial land uses surrounding the project site. These thresholds and modeling from the center of the parcels are based on the Federal Transit Administration’s Transit Noise and Vibration Impact Assessment Manual. As shown in Table 3.13-4, noise levels would not exceed these thresholds;
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however, the project would still be required to implement mitigation measure MM NOI-1.1 to further reduce construction noise. For these reasons, the Draft EIR concluded that the project would not result in significant construction noise impacts. For informational purposes, additional noise modeling was done to estimate noise levels at Shasta High School for the particular periods when construction equipment would be used at the southern property line of Parcel C, representing the most intense noise exposure for the school. Three phases of construction were modeled; grading/excavation, building exterior, and building interior. Construction noise levels were calculated utilizing the FTA’s General Construction Noise Assessment method in which the two noisiest pieces of construction equipment per phase were assumed to operate immediately adjacent to Shasta High School. The FTA has set a General Assessment Daytime Construction noise criterion of 90 dBA Leq (1-hr) for residential land-use, which is an appropriate threshold to apply to classroom activities. As shown in the table below, construction noise from equipment located 30 feet from Shasta High School would not exceed the 90 dBA Leq (1-hr) threshold. While the mitigation measures outlined in MM NOI-1.1 would reduce construction noise impacts to a less than significant level, an additional mitigation measure to construct a temporary noise barrier between Parcel C and Shasta High School was added to further reduce noise levels (please refer to Section 6.0 Draft EIR Text Revisions).
Phase Construction
Equipment
South Shasta
High School
(30 feet)
Leq(1-hr)
Grading/Excavation Grader
Dozer 87
Building - Exterior Forklift
Backhoe 81
Building - Interior Air Compressor
(2) 81
The American National Standards Institute’s 35 dBA recommendation for schools is intended to assist schools in designing new, and renovating existing, class rooms. In this 35 dBA recommendation, background noise refers to transportation noise such as aircraft, road vehicles, and trains, HVAC systems and other building services and utilities operating simultaneously, and plumbing equipment operating at their nosiest conditions. It does not apply to temporary construction noise; therefore, it was appropriately not used as a threshold in the Draft EIR for evaluation of the effects of construction noise.
Comment HH.22: 3.14 Population and Housing
The Daly City Community Garden Alliance agrees with the NAACP DEIR letter.
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Redlining makes it likely that there will be very few African Americans who will be able to afford to rent in the SDR. By limiting the affordable housing component to only 10%, and keeping the majority of the project market rate, this project ensures that historical inequities will be unaddressed in changing segregations legacies of redlining as required by the housing element and general plan. The project by preventing more diversity through affordability entrenches the racism that Donald Trump has been dog whistling through our contemporary politics and enters it in concrete. It’s ironic that the era of redlining started in Daly City in Westlake as Richrard Rothstein documents in Color Of Law (pages 73-90) and this project casts redlining into concrete by the JUHSD by not even meeting the RHNA that Sierra Club outlined in its letter to Daly City dated February 17th 2022. The letter also outlines a solution to increase affordability in line with the RHNA failures and feasibly mass taller buildings near Serramonte to feasibly remove cost burdens to residents from transportation. Additional cost burdens from utilities can be reduced by feasibly making the project a microgrid of batteries and solar panels including on a taller south and west facing vertical surface as Sierra Club outlined in its letter to the planning commission dated August 3rd 2021.
Through pricing and 90% market rate housing SDR ensures that racial segregation remains the de facto developmental model in Daly City. The EIR should be corrected to integrate housing as recommended by the general plan and housing element.
Response HH.22: Economic and socioeconomic topics are not considered CEQA issues; therefore, the Draft EIR does not include discussion of them. In addition, since publication of the Draft EIR, it has been clarified the project would provide 20 percent affordable units. See Section 5.0 Draft EIR Text Revisions below.
Comment HH.23: 3.16 Recreation
Demonstration Garden 2.2.1.1
1) The Garden has been maintained for +20 years by public community members and not JUHSD.
The land is surplus public land, not private property. It is a community garden that is located on the perimeter of the property with a hillside of full grown trees with a water inlet. Serramonte HS was closed 42 years ago. The Community Garden Alliance, Sierra Club, NAACP, Gay Shame, Pacifica Social Justice groups have clearly stated at all public meetings with JUHSD and the City of Daly City that the public has been in control of the Garden to grow vegetables, fruits and herbs. JUHSD has only disputed that the land was on school property and “provides limited access for members of the public” 2.2.1.1 pg 20.
The Impact is Significant (total destruction) and should be reviewed as a separate alternative to have no construction and remain as a public garden.
Response HH.23: Please refer to Master Response 1: Demonstration Garden and Master Response 6: Recreation above.
Comment HH.24: Existing Conditions
The Draft EIR does not recognize that current Recreation is provided on site with the Gymnasium for 2 major established groups. Year round basketball games are played at the gymnasium by Hundreds of youth and adults for the CYO and Homenetmen.
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Although it is stated pg 165 “that the project proposes to pay in-lieu fees to offset recreational demand for parkland not provided by the proposed project” –the loss to the community of the gymnasium has not been factored in.
This is a Significant impact to the Community that has not been addressed. From the Executive Board of Homenetmen one of two major renters of the gymnasium: Homenetmen is a non-profit organization and has been renting out the Serramonte Del Rey gym since 1997. The usage of the gym is for basketball practices for our 10-12 teams along with 2 other organizations from PBL and BullDawgs. The gym is also used for the OYAA Greek League. Hundreds of community members take part in basketball games and practices throughout the year. We have at least 30-40 games excluding practices. The facility is also used for Youth Scout purposes. It has been quite difficult to find and rent a gym and offices as a new home for our organization.
Response HH.24: Please refer to Master Response 6: Recreation above.
Comment HH.25: Pg. 164. “The nearest park(s) to the project site are Gellert Park located approximately 800 feet southeast of the project site.” That designation is not correct as Gellert Park is not a Park. It has a library and ballfields but it is not a park. It cannot be ADA accessed until the corner of the clubhouse and tennis courts or .8 mile or 4,224 feet.
Access is due to no stairs from the corner of Hickey and Callan and could be a recommendation as part of the Development agreement.
Response HH.25: The statement that Gellert Park is not in fact a park is without basis. Gellert Park is a City owned and maintained park listed in the City’s Parks and Open Space Master Plan.
As discussed in Section 2.2.2.1 of the Draft EIR (page 11), the City and applicant are in discussions about additional off-site improvements, including improved access to Gellert Park. However, as the commentor notes, Gellert Park currently has a designated access point for ADA access. The location of Gellert Park’s ADA accessible entrance does not alter or impact the Draft EIR’s analysis of the project’s impact on recreation.
Comment HH.26: Parcel B Open “Public” Space portion of Development Project—not visible or easily accessible to public
The Parcel B area includes what little green space is being proposed for the public as indicated as Overlook Park (large grass area and playground). Figure 2.2-8
2.2.2.2 Open Space and Landscaping
There is no public access to the park unless you walk the recreational trail around the frontage of Serramonte Blvd and the 73.5 foot high Parcel B building. It is not visible to the public.
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2.2.2 Does not indicate any public parking spaces other than reserved for retail customers and leasing, with and the remainder reserved for residential parking. No ADA parking is indicated for either the public park or playground. By isolating this park within the development, lack of access from Callan Blvd and lack of public parking, creates a privatized, not public space, as is claimed in the DEIR. or public parking this is not public open space but privatizing for the development residents. This does not meet public space or access guidelines.
Response HH.26: The proposed park on Parcel B would be built in accordance with City standards. While the park would not, due to slope, have direct visibility from Serramonte Boulevard, the park would have visibility and public access via sidewalks and recreational trails . It is noted the existing demonstration garden is not visible from Serramonte Boulevard, yet the community is aware of its existence. Parking on the project site and for Parcel B will be provided in accordance with City Code for a project of this type.
Comment HH.27: Transportation
Market rate housing doesn’t support transit.
The DEIR claims that the project will function as a Transit Oriented Development (TOD) . According to University of California Davis for National Center for Sustainable Transport (NCST) TOD is meant to change transit patterns to reduce air quality and greenhouse gasses impacts on society.
Research indicates that compact, mixed-use, mixed-income development located near transit can serve to reduce driving and associated harmful emissions, meaning TOD could help support state sustainability goals. (page iii). Many localities in California also support TOD goals, for reasons that include revitalization of downtown areas, mobility and accessibility improvements for residents, and provision of workforce housing. Now is a critical time to consider which planning and policy “packages” can be most effective in inducing TOD, and this research project helps address that question.
There are a number of factors that lead to ineffective TOD by the project. The DEIR admits ineffective TOD in a circular fashion, it says:
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.
The footnote 84 explains that the transit usage expected is no more than the region produces with its standard, i.e. non TOD, development pattern:
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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There are a number of feasible reasons why the project fails which we explained in various comment letters on the project to the project proponents.
The apartments proposed by Serramonte Del Rey are going to rent for an average of $3000/- per month according to Zillow. That is $36,000 per year. According to the 30 percent rule the income of the renter’s will exceed $120,000/-. People in this income bracket, renting from this project, based on the current subdivision map, will not use transit in general and buses in particular. See American Public Transportation Association report on who uses transit page 36 and 37. Page 37 on transit use by household income shows significantly declining transit use by income. Page 36 of use by mode shows higher income users prefer rail to bus.
Note that lower income people tend to use transit but they only make up 10% of this project.
Therefore 90% of this project will be contributing to public problems of air, water and GHG pollution, congestion, and increased VMT by driving instead of taking transit. These impacts are the opposite of what is required from public goals under SB32, SB 375 (40% reduction against a baseline of 1990 levels by 2030) and SB743 (using Vehicle Miles Traveled (VMT) analysis instead of Level Of Service to gauge lifetime impacts from the project due to transportation.) Response HH.27: It is incorrect to state residents of market rate housing do not use transit. The Draft EIR conservatively relies on the estimate that five percent of residents would regularly rely on transit, as reported by the U.S. Census Bureau. In addition, since publication of the Draft EIR, it has been clarified the project would provide 20 percent affordable units. See Section 5.0 Draft EIR Text Revisions below.
Comment HH.28: This DEIR fails to acknowledge the long term decline in transit on the project because of the project’s auto oriented development patterns. The Mercury News noted in 2010 that Samtrans would enact service cuts because of deficits caused by lower ridership. The service cuts were coming on top of service cuts enacted in 2009. San Mateo Daily Journal reported additional cuts in 2017. This year transit operators in the Bay Area are facing a huge fiscal cliff and additional service cuts.
The current development pattern that Serramonte Del Rey is utilizing is driving transit out of business.
Response HH.28: As discussed under Impact TRN-1 in Section 3.17 Transportation of the Draft EIR (pages 176-177), the project would improve access to transit in the project area and would not conflict with a program, plan, ordinance or policy regarding transit services. Future residents can be expected to use transit when their destination can be readily accessed using transit, such as utilizing nearby Colma BART for work trips to major employment centers such as Downtown San Francisco.
Comment HH.29: According to CCAG, slide 6, we must reduce VMT by shifting to other modes to meet CA goals in SB375 and SB743. According to RMI we must reduce VMT by 20% before the end of the decade to meet Paris. This subdivision layout should be returned because it’s designed to fail.
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Similar project layouts in San Mateo have not delivered the promised transit usage- See for example Bay Meadows in City of San Mateo which not only resulted in declining transit use but also contributed to increasing driving, leading to the expansion of 101 and the adjacent slip lanes because “when you continue to load the system, it starts to break down.” Impacts can be avoided if possible mitigations are adopted, within the subdivision map, also mentioned in our letter to planning commission:
A. the buildings should be massed closer to the street, without parking and (if possible) on a U bus travel loop to reduce time needed to catch a bus.
B. The U street should be for the Serramonte bus, a shuttle to major stops like BART and school, car and bike share, employer shuttles, and delivery to shorten trip times.
C. Parking allowed should be unbundled and located in a park once and walk location to encourage people not to own cars and create a safer walking environment that would decrease vehicle miles traveled. The parking can be further reduced like the City of Austin by replacing 20 spots with one car share spot.
Response HH.29: Please refer to Response HH.13: above regarding VMT reduction.
Comment HH.30: Samtrans bus use has been low compared to other agencies and has been steadily decreasing. See Metropolitan Transportation Agency report titled “How much are Bay Area residents relying on Transit” chart titled “Historical trend for daily transit ridership by operator” which shows Samtrans as poorly used and slightly declining for two decades. Overall transit use has declined by 11% in the same period.
Displacement also impacts transit use as the UCLA study says, primarily bus users, who are low income, are displaced for rail users. Long term transit use declines. Thus SamTrans bus service continues its long term decline with rising rents which in turn increases driving.
Worse, low income people who used to take the bus are part of an outmigration to far away places like Modesto where they commute from in older cars increasing VMT, bad AQ, and adding to the congestion which will be produced by this project.
The project proponent and Brookwood have not submitted any case studies to show why displacement and declining transit will not continue and the EIR has ignored this fact in trumpeting the dataless and unverified narrative of TOD.
These substantial impacts to dirty air, greenhouse gas increase, transit sustainability and displacement can be avoided with feasible measures that we recommend in our letter to the planning commission such as:
A. Increasing the total of affordable housing in the project to reduce displacement and increase transit use.
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B. There should be no parking or motor vehicles allowed in the development to increase the number of users committed to transit. This is an ideal location to eliminate parking because there are no adjacent streets for spillover. It will also significantly lower the cost of the construction and will result in lower rents and perhaps more units. San Francisco, Oakland, and other cities do projects without parking if located on transit and bike routes. No parking within the development will increase transit use because automobiles ownership decreases transit use. California Transit Association reported that transit use declined as auto ownership increased caused by “the shift of lower-income riders moving into owned automobiles” primarily due to displacement.
C. Lower overall rents due to no parking will increase people likely to take transit.
D. Increasing usefulness of transit to users at the site by reducing trip time via a U bus street and shuttles will make transit more viable.
Response HH.30: Please refer to Response HH.28: above regarding declining transit use. In addition, since publication of the Draft EIR, it has been clarified the project would provide 20 percent affordable units. See Section 5.0 Draft EIR Text Revisions below.
Comment HH.31: 3. Prior to the Covid19 Pandemic, bicycle, walking and transit use had not increased in Daly City, see Transportation, while drive alone remained the dominant commute mode. The DEIR is wrong to assume that “proximity to transit” and “pedestrian and bicycle facilities" will not waste energy (Page 83). The conclusion of Impact EN-1 is wrong and should be corrected with a redone EIR to avoid conflict with the CARB Scoping Plan of 2022, SB 375 and Plan Bay Area 2050 (page 94) to reduce VMT (significant impact from the study of only Parcel A and B) and GHG (improperly calculated by not considering the entire project as we show above). In addition the inability to reduce air pollution by not reducing VMT for the whole project (not studied in this EIR) will conflict with CEQA Air Quality Guidelines since the numbers on page 93 should be based on SB32 and not on AB32, another serious deficiency which should be corrected in a redone EIR. When we checked with Michael he said that the DEIR would comply with the CARB 2022 Scoping Plan which is based on SB32 (to meet the more aggressive target of 40 percent below 1990 levels by 2030- page 1). The DEIR does none of the recommendations on page 1 and 2 to decrease reliance on cars, install renewables like solar and batteries, electrifying everything, and aggressively reducing fossil fuel use.
Response HH.31: Please refer to Response HH.5: above regarding evaluating buildout of the project, Response HH.11: regarding energy use, and Response HH.13: regarding VMT reduction. Project GHG emissions were calculated and per capita emissions would be well below the threshold of significance derived from the state’s SB 32 GHG reduction target, as presented in Draft EIR Table 3.8-1.
Comment HH.32: The DEIR assumes no increased use of transit (page 176) since only 170 of 3403 residents or 5% will use transit which is a substantial decrease of the pre covid transit mode share.
That means that car friendly patterns of VMT increase, air pollution increase, and greenhouse gas
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increase, will continue in direct contradiction to the CARB 2022 Scoping Plan as this study from UC Davis says is likely. The DEIR is wrong to assume that current transit usage will persist. Instead they are more likely to continue declining, aligning with regional plans like SB375 and that covid patterns will persist leading to further declines in transit unless the CARB recommendations are followed. By not following our recommendations to mass the project closer to Serramonte in a taller more cohesive project not segregated by income the project proponents are ensuring that air quality will deteriorate, green house games will increase, and transit other social goods will fail. Other proven strategies mentioned in this UCLA paper, to increase transit use by pricing driving (unbundled parking, road charges, priced parking) and making transit free do not exist in Daly City thus requiring a redone EIR.
This paper which we mentioned earlier, says that transit is declining because transit users are being displaced by rising property and rental prices to cheaper locations like Tracy where transit is so bad that they have to buy a car. Rising car ownership and gentrification/displacement is leading to the decline in transit. The DEIR does not acknowledge the impact of increased rents increasing car ownership from its 90% new market rate housing on the city and region thus requiring a redone EIR to correct the transportation analysis by looking at current conditions mentioned earlier and studying the entire project as required by CEQA to inform policymakers.
The project design has ignored feasible solutions that we provided to the planning commission on this project and not studied the entire project as required by CEQA to properly inform policy makers. In doing so the DEIR provides unsubstantiated reliance on TDM to ignore major health impacts from dirty air due to declining transit and the development of the project with upper income residences that do not take transit.
Response HH.32: Please refer to Response HH.5: regarding evaluating buildout of the project, Response HH.15: regarding implementation of a TDM plan, and Response HH.28: regarding declining transit use. The project would not displace any housing from the site, nor is there evidence provided that the project, by providing market-rate units for 80 percent of the development and 20 percent affordable, would lead to an increase in rents generally within Daly City or the region. Rents and housing prices are high in the region due to a lack of housing supply generally (both market rate and affordable), and increasing the supply of housing for all income levels would help alleviate housing prices, not exacerbate them.
Comment HH.33: Transit DEIR page 164
Safety of Shasta Students walking to/from Serramonte Blvd Policy CE-16 Daly City 2030 General Plan
Where are the “Safe Routes to School” action points for Shasta HS? No mention is made on the walk safety for students at Shasta High School maneuvering through the development during construction to the bus stops at St Francis and Serramonte Blvd. (Parcel F which is the current walk route of the students to the front of Parcel A will be a crossing zone of soil movement and staging equipment).
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The recreational perimeter trail should be built all inclusive from Parcel B to Parcel C at the start of development of Parcel B to ensure a “Safe Route To School” to/from the bus stop.
Response HH.33: As discussed in Section 3.17 Transportation under Impact TRN-3 of the Draft EIR (pages 180-181), the project would be required to implement mitigation measure MM TRN-3.1, which requires preparation a Construction Traffic Management Plan. Implementation of this mitigation measures would ensure pedestrians and bicyclists, including Shasta High School students, would have safe access to and around the project site during project construction.
Comment HH.34: 3.18 Tribal Cultural Resources
Sacred Space and access to Native Foods and Medicines
Native Americans have been violently dispossessed and exterminated from the land (A Paradise Of Blood by Howard T. Weir; The Other Slavery by Andres Resendez) Through the boarding schools our culture has sought to displace them from their origin stories, diets, and healthy living conditions (An Indigenous People’s History Of The United States by Roxanne Dunbar Ortiz.) The resultant scattered survivors have had their health traumatized by homelessness, poverty, boarding schools, and state sanctioned violence in programs of environmental injustice (As Long As Grass Grows by Dina GilioWhitaker.) But the peoples have gathered in cities like Daly City and managed to propagate their culture from seeds and medicines to sacred places (See petition started by Debbie Santiago.) The garden functioned as a safe space where the diaspora could gather, celebrate their survival, tell stories, show Americans that indigenous still live off the land, and in celebrating the changing of the seasons, and harvesting food and medicines in sustainable ways, interact with the great spirits.
What’s especially galling is that the project is taking place on the unceded home land of the Ramaytush Ohlone. Once more this project maliciously raises the ugly head of settler colonialists to violently disrupt the indigenous relationship to the land. • The project, in paving over the garden, looks to displace and degrade the assembled diaspora, and eliminate their presence from the landscape, that provided the tribes with sustenance in food medicine and shelter from the pollution. • The DEIR is deficient in not preserving the garden as a cultural resource of native practitioners, who lack access to sacred spaces, as public spaces are privatized, and should be redone.
• The DEIR is also deficient in not pursuing a feasible strategy to mass the project near Serramonte and achieve multiple public policy goals mentioned earlier in this document and preserving the garden for community health.
From the Sierra Club’s NOP Letter on June 7
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5a. Religious, cultural, and spiritual significance of the area to Tribes be ascertained prior to the EIR for the purpose of protecting, or mitigating impacts to, cultural places by contacting the relevant groups.
5b. As mentioned earlier Indigenous people within the garden community farm native plants for herbal and spiritual needs, a use that should be preserved.
Debbie Santiago letter to the City Council on June 6, 2021, It’s attached to the Draft EIR:
The Jefferson Union High School only wants us to see the new grassland of where they want to put generic plants. We have agreed to look at the area. But lots of the plants, fruit and veggies plants will not survive the transferring and replanting. Especially when their employees are not giving the love, the attention and not a lot of water to keep surviving. We still need to save the Bog (swamp area) Coffee Tree, indigenous plants, herbs and all the different fruits and vegetables. With all these wonderful qualities, these plants and herbs bring in the dears, the butterflies, the bumblebees and other Bees to make Honey and Hummingbirds that help cultivate each plant to survive.
Response HH.34: Please refer to Response DD.3: through Response DD.9:, regarding special-status species, and Master Response 7: Tribal Cultural Resources above.
Comment HH.35: Historic Resources: Impact Discussion DEIR pg 75 confirms location:
“However, based on the site’s proximity to a historic freshwater source and the historic occupation of Daly City and the project site by the Ohlone/Costanoan people, the Cultural Resources Study identified a moderate sensitivity for subsurface archaeological resources to be encountered.” The Garden has been identified by community members as a meeting spot for the Ramaytush Ohlone tribe members to have spiritual meetings. JUHSD recognized these members and had meetings to discuss an alternative spot with the representative but provided no contact information to the City or consultants to contact them directly. The Draft EIR is deficient to not contact known sources directly to establish Historical Resource information for which the DEIR should be redone.
Response HH.35: Please refer to Master Response 7: Tribal Cultural Resources above.
Comment HH.36: 3.19 Utilities and Service Systems
Emergency Generators DEIR pg 142 Parcel C Omissions
As stated:” Emergency Generators are proposed to be located on Parcels B, D, E and F.” Why is Parcel C –which the Developer has called the “affordable” Building in discussions with prospective builders not going to get a generator? This is the same building that the Head Start building is planned for. Why is this building being excluded? The Sierra Club letter to the Planning Commission showed that all the buildings could be feasibly protected from power outages by being
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designed as microgrids for which there is considerable money available in the Inflation Reduction Act and through the state’s SGIP program. The DEIR is deficient in discriminately not feasibly protecting low income tenants from the effect of power outages such as the Public Safety Power Shutdowns.
Response HH.36: Please refer to Response GG.13: above.
Comment HH.37: Please attached the following 20 documents, petition, photos and videos as our additional comments on the DEIR:
1. July 21, 2023 - Community Garden Alliance NOP Comment Letter
2. Feb 7, 2022 - Community Garden Alliance Letter
3. Daly City Housing Element
4. June 7, 2021 - Daly City Planning Division Notice of Preparation Letter (NOP)
5. August 3, 2021 - Daly City Planning Commission Letter
6. August 13, 2021 - San Mateo County Board of Supervisors / David Canepa Letter
7. September 8, 2021 - Daly City Council Letter
8. February 17, 2022 - Daly City Council Letter
9. March 9, 2022 - Daly City Council Letter
10. Sept 7, 2023 - Draft EIR Letter
11. Petition to Save Daly City's Only Community Garden
12. Serramonte Del Rey Precise Plan
13. October 4, 2021 - JUHSD Real Property Advisory Committee 7-11 Report
14. 2018 City of Daly City Inclusionary Housing Ordinance
15. May 2023 - City of Daly City Housing Element 2023-2031
16. April 25, 2022 - JUHSD RFP FAQ for BMR Developer: Parcel C
17. State and Federal Endangered Species List
18. Wetland & Seasonal Creek Photos and Videos
19. Historic Photos
20. Garden Photos
Please let us know if you have any questions regarding our comments.
Response HH.37: Please refer to Appendix B Draft EIR Comment Letter Attachments for full printouts. The additional documents provided do not raise specific issues about the adequacy of the Draft EIR; therefore, no further response is required.
II. Nancy Lacsamana (dated September 8, 2023)
Comment II.1: Recreation for the Serramonte Del Rey project as well as the need to address inaccuracies shown in the existing conditions 3.16.1.2.
Location:
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The Project is bordered by housing on 3 sides and a cemetery on the East side. The DEIR has failed to convey that not only has the current location lost Recreation with the destruction of the garden but also the closure of the Gymnasium. The proposed Precise Plan has not noted the loss in Daly City recreation for tournament and community recreation for hundreds of athletes of various ages.
Response II.1: Please refer to Master Response 6: Recreation above.
Comment II.2: 3.16 Recreation
3.16.1.2 Existing Conditions
Omissions and Inaccuracies
• The full-size-year-round gymnasium is not mentioned.
• Gellert Park access is over 0.8 mile from the project vs 800 feet as stated in the dEIR. The physical location may be 800 feet but there is a steep hillside at the corner of Hickey and Callan. Gellert has a library, baseball fields, community room, tennis park. Gellert Park is not a park.
• The Garden is a publicly accessible community garden and is mislabeled as a Demonstration Garden. It provides recognized recreation benefits that are well documented. The issues and value of the Garden has been covered by the following letters from NAACP, Community Garden Alliance, Pacifica Social Justice, Sierra Club and community members.
Response II.2: Please refer to Master Response 1: Demonstration Garden and Master Response 6: Recreation. Please refer to Response HH.25: regarding Gellert Park.
Comment II.3: Gymnasium current ramifications of loss
The gymnasium was the home to over 500 community members especially children in basketball tournaments, practices, physical and scout activities. I was in this gym as a parent at least 5 times while my son was on a public middle school basketball team and there were over 50 people at each event. Practices have been held during the week and games every weekend.
The Gymnasium was leased out* to two different large organizations who have a well-known and respected reputation in youth sports and activities.
• CYO ---Catholic Youth Organization that allows public and private school basketball programs.
• Homenetmen --a long established Armenian community group who has for 24 years at this location for basketball and scout programs.
*Please find attached the following email from Tina confirming the lease to these 2 major organizations. Please print and include into the comments.
Please find attached the following email from Vahan Derounian and the frustration with having been at this location for over 24 years and having to relocate the recreational facility with no assistance or options from the JUHSD. Please print and include into the comments.
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It is undeniable that the planned destruction of the gym has impacted basketball programs and access to physical recreation for hundreds of students and it was not included in the DEIR.
Response II.3: Please refer to Master Response 6: Recreation above.
Comment II.4: Project Recreation need go forward
It is very clear that the 3,403 new residents are going to need recreation in the project and the Serramonte Del Rey project will not provide these residents adequate recreation.
3.16.2.1 Project Impacts
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. (Project will pay difference in lieu fees.) Overlook Park's location cannot be seen from Serramonte Blvd The publicly accessible park or Overlook Park cannot be seen or accessed directly by the public without walking the Recreational Trail. Parcel B side bordering Callan is on a steep hillside bordered with mature trees. From the West view, Parcel B Building at 75 Feet tall and will obstruct any downhill view of the park. There are no shown ADA parking or public parking spots other than for retail. Although this does create open space parkland it is most probably going to be used by the residents of the Parcel B and future building of ParcelC-F and not the public outside of the development.
Response II.4: Please refer to Response HH.26: above.
Comment II.5: 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.
In Summary, the DEIR does not consider the impact of the loss of the Gymnasium and Garden, and the isolation of the Overlook Park from public view. The DEIR has failed to adequately convey these even more significant negative impacts in Recreation for this project.
Response II.5: A cumulative impacts refers to the combined effects of multiple projects affecting the same resource or causing similar impacts within a defined geography. Here, the comment refers to several alleged impacts of the project, and not cumulative impacts from multiple other projects occurring in the vicinity of the project. Please refer to Master Response 6: Recreation above.
JJ. Erick Campbell (received September 8, 2023)
Comment JJ.1: I have been a resident at Serramonte Ridge for over 8 years and counting. I am also the caretaker of the “garden” at Serramonte Del Rey. I am writing you today express my concern
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with the 1 and a half acres located at the far end of the Serramonte Del Rey Campus. Known as the garden. My first concern is what is at stake here! This land is not only a green space, but an urban forest with over 100 native trees including over 25 California coast redwoods not the aptos blues either. Also Douglas fir, buckeyes, madrones, live oaks, white oak, California coffee berries, bay leave, elderberries, Monterey pines, Catalina ironwoods. According to project Green Space of Daly City this City “DC” has only 127 redwoods in its entirety. If that is the case then that would mean this green space has almost 20% of all the redwood trees in the whole city. How can this be to hire a crew to cut down 100 native trees in a city with less than 5% of a urban canopy just to dump their concrete and dirt on it is completely crazy. JUHSD are a bunch of lies as well. JUHSD has been trying to destroy this garden for years now and are for some reason willing to waste millions of our taxpayers money on things like security of the garden over a quarter of a million a year for 24 hours 7 days a week security that just sleeps in their cars and are always rude. One was fired for smoking dope at work in their car. JUHSD has 24 acres of property. They have promised a new garden with double the space, but if that were the case why would they even get rid of this one it doesn’t make any sense. Also, before JUHSD built their housing for teachers they cut down 120 trees to build.
They promised to replace 90 of them. As of today they have planted 6 cypress and commercial landscaping, not one native plant. This greenspace is also the only filter on the whole campus. It works as a rain garden filtering all the rain water mixing with the sludge of the road. JUHSD has not reached out to the communities about anything. Their one in control was fired from a different school district for taking funds. How she got this job I don’t know, but she is not honest. I have had many teachers from the new housing for JUHSD say they love the garden and that they won’t let them have plants in the building so they bring their plants here to plant. Why is this so hard for them to get JUHSD to do the right thing. They have wasted so much on the security cameras only to show pictures of coyotes. JUHSD has done nothing but try to make the garden into a bad place.
How can corruption exist so freely. Why should this greenspace be wiped out just because these crooks lied and gave away land that is not private property but public land to the blynn corps without any feedback from the public. We are not trying to stop their buildings. Just trying to save this little plot of goodness. Thank you for your time.
Response JJ.1: The existing conditions on the site, including the demonstration garden, have been documented in the Draft EIR, including assessments by professional biologists. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
KK. Nick Occhipinti (dated September 8, 2023)
Comment KK.1: This letter is being provided as public comment/input in reference to the Draft Environmental Impact Report (DEIR) of the proposed and yet-unapproved Serramonte Del Rey Campus Redevelopment Project. This input is based on my experience as a former Board Trustee of the Jefferson Union High School District and lifelong resident of Daly City. As the sole trustee in opposition to this project, given the multitude of its problems and misdirection from its inception, I speak from a perspective both informed by and grounded in direct involvement with reviewing this project since before its conceptualization, and a critical lens of its impact upon our school district
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community, public education funding and the larger scope of its engagement of environmental law, housing policy and urban development. An Environmental Impact Report (EIR) should center and elevate the issues relevant to mitigating and eliminating harmful impacts to our environment; this DEIR completely, and intentionally fails to do this. Daly City’s current role in navigation of urban development in San Mateo County compels a careful and acutely responsive approach to public policy, particularly with respect to public education, housing and infrastructure, and with a critical engagement of diversity, equity and inclusion in its policymaking. Any EIR under consideration at this level demands a clear professional and legal obligation to provide adequate research for its development, respect and careful attention to detail. It is the purpose of this letter to identify these fundamental and critical areas of need in this project, as well as its implications for future projects of any scale in the City of Daly City, San Mateo County and cities across the Bay Area moving forward.
Accordingly, this project - the largest housing project ever proposed in our city and North San Mateo County, requires due diligence in its evaluation and should not be fast-tracked under the pressure of private interests - which in this case have demonstrated a clear intent to silence the input of local community members, at the expense of one of the lowest-funded public school districts here in the SF Bay Area. Education is a human right, and housing is a human right; our schools are not for sale. I continue to extend my strongest recommendation and advising to public officials and city planning staff that this project, with its many clearly unethical and ambiguously legal and financial issues, be halted and completely redrawn at this point. With that, the public input process for this project and its DEIR should be restarted, with a more transparent, accountable and responsible engagement of public comment and input, and in step with the guidance of local, state and federal public agencies.
As the SF Bay Area begins to reimagine itself at the outset of an endemic stage of a global pandemic, local cities have the responsibility and opportunity to step back and consider the relevant and essential needs of our communities. It is incumbent upon public agencies and the public officials leading the duties of governance to research, reflect and seek consultation from other public institutions, nonprofit agencies and, most importantly, their constituents, the communities that they represent. Every city is different - and Daly City’s role in both San Mateo County, as well as the city directly adjacent to San Francisco - requires a departure from the problematic and discriminatory practices and abuses of public policy of the past, glaringly apparent in the development of San Mateo County for generations.
As a new generation of voices, leaders and community here in Daly City and San Mateo County, the test of our leadership will be to see what we are actually willing to do to make a change in how we see our community: is it simply for sale to the highest bidder - or do we value our culture, community and have any vision for our cities that goes beyond what we have seen for years? We should ask ourselves, and each other:
What do we want to see as the future of our city?
What do our students want to see as the future of their schools? What should our streets look like?
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What role can the malls play in public service to our community? Where are our public murals?
How can we ensure that our public libraries remain open to the public seven days of the week? How can we open up our brand new, outdoor school athletic fields and theaters to the public for community use in an accessible, organized and responsible way? How can we build on the strength of our community’s cultural diversity and provide spaces to celebrate that throughout the year?
How can we finally begin to acknowledge and honor our Native, Indigenous community here on Ramaytush Ohlone Land in a respectful, substantive and meaningful way? What is our city and county doing to promote and protect our environment, and in response to climate change?
What will our city look like if we never answer these questions? What can our city be if we start to actually listen to the voices of our youth, elders, families and community, and engage them in a way that sees them the way we want to see our city? If we are the change that we want to see in our community and world, then we have to accept that this change means that we have to change the way we do business - and public policy. If that begins anywhere in Daly City, it begins in Serramonte.
Response KK.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.2: The Serramonte Del Rey Development Project Draft EIR is littered with flaws throughout its 200+ page draft report. In an honest assessment of its contents, it is actually more questionable than the previously reviewed SDR Precise Plan. It should have included and made adjustments to this plan, based on the multitude of critical public comment provided on public record at live public meetings of the Daly City City Council and the Jefferson Union High School District. Instead, it appears to be a blueprint pushed by luxury developers with little to no regard for providing sufficient affordable housing or reasonable community benefits. It is the responsibility - and stated explicitly in our oath as public officials and employees - of our public agencies to act in the public interest, not the private interest. This DEIR falls painfully short of that. The list of infrastructural, environmental and community-based concerns is long and detailed, and has been voiced and cited on public record over the course of years by community member input - including many local high school students and generations of alumni, a petition of nearly 5,000 community members signing in support to Help Save Daly City's Only Community Garden on Ohlone Land and Territory and several community-based organizations, nonprofit and civil rights agencies, not limited to but including designated representatives of our local Native American / Indigenous community, the Daly City Community Garden Alliance, the Sierra Club Loma Prieta Chapter and the NAACP San Mateo Branch #1068.
Response KK.2: The comment states that the Draft EIR contains flaws, but does not provide examples of the stated flaws, and cites no specific pages or conclusions reached in the Draft EIR. Thus, no further response can be given.
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Comment KK.3: An immediate list of concerns that arise from the inception of this development, and continue to remain unaddressed, include:
- Logistics for building 1,235 apartments and creating parking, all on a public school site seem both inappropriate, outsized and completely negligent of the historic and projected environmental impacts facing Daly City and its surrounding area, including: pollution, lack of public green space and open space, extremely limited urban canopy and endangerment of local wildlife and remaining trees protecting the area (Daly City also continues to lack adoption of public policy regarding any substantive Heritage Tree Ordinance or formulated Urban Forest Plan protecting or promoting preservation and positive support of our local environment, as modeled by other cities our size, throughout the Bay Area and state of CA)
Response KK.3: This comment speaks generally to impacts regarding pollution, lack of open space, urban tree canopy, and wildlife, but does not raise any specific issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.4: - The net green space and open space numbers listed by the DEIR about this development are incorrect and misleading, given the net loss of green/open spaces resulting from the destruction of Westmoor Park, the office park development that this SDR DEIR is predicated, and effectively directly linked to; the projected net green space and open space should be reassessed and redrawn to include provision for those areas and services lost to these projected developments (preservation and promotion of existing Community Garden at SDR, indoor basketball gym and athletic facilities, space for community organizations and sports leagues, local martial arts programs nonprofit agencies, and auditorium/gallery/event center, etc.) Response KK.4: JUHSD’s adult education and district office project at 123 Edgemont Drive was approved as a separate project by the JUHSD Board of Director’s in August 2021 and its recreational impacts were disclosed as part of the environmental review process. Construction of the JUHSD adult education and district office project is not contingent on approval of the proposed project.
Please refer Master Response 6: Recreation above in regard to recreational impacts.
Comment KK.5: - No justifiable need for additional Retail space in what is in fact the largest concentrated retail complex in the SF/San Mateo County Peninsula (Serramonte) Response KK.5: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.6: - Language in Precise Plan/DEIR projecting “to create a neighborhood” in an existing neighborhood is both grossly misleading, and insulting; Daly City’s neighborhood is defined largely by its residential housing and population density, including historically low-income multi-unit apartment buildings located directly across the street from SDR, as well as the new JUHSD
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workforce housing, and the Serramonte Ridge apartment development previously built (and currently losing affordable units) already located at Serramonte Del Rey.
Response KK.6: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.7: - Problematic, discriminatory prioritization of luxury/market-rate apartments and extremely limited affordable housing units - which are also planned to be segregated from the market-rate buildings, in a repeated, blatant attempt to appeal a violation of longstanding civil rights law (also cited by the NAACP)
Response KK.7: Please refer to Master Response 2: Regional Housing Needs Allocation and Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.8: - The DEIR for the Serramonte Del Rey Development Project is also still in violation of the city’s own housing ordinance, which mandates that affordable housing units be included, and not segregated from the market-rate/luxury housing buildings by isolating them in a separate building; this is a violation of federal, state and even local civil rights / housing law and should not be allowed “exception” for any reason, or aggressive lobbying by private industry and real estate lobbyists
Response KK.8: Please refer to Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law above.
Comment KK.9: - The DEIR and SDR Development Project altogether neglects addressing the housing crisis at its actual needs: affordable housing and addressing homelessness and the needs of unhoused and low-income community enduring a high cost of living in the Bay Area, extremely high rent, possible eviction and ongoing financial hardship in our current economy.
Response KK.9: Please refer to Master Response 2: Regional Housing Needs Allocation above.
Comment KK.10: - The DEIR is informed by false statements made by JUHSD Board Members on record at live High School District Board meetings, constituting an intentional, concerted effort to misrepresent, isolate, exclude and disregard the contributions of the designated representatives of our local Native / Indigenous community to a public project impacting green space, open space and the environment, the largest of its scale proposed in decades in Daly City and North San Mateo County; no approval of this project’s planning has ever been expressed by the Native community involved in any stage of the development the SDR Project and its EIR.
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Response KK.10: Please refer to Master Response 7: Tribal Cultural Resources regarding the City’s compliance with obligations to consult under AB 52 and SB 18 with tribes culturally affiliated with the project area. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.11: - Lack of good faith communication and collaboration reflected in the current DEIR - requested explicitly on public record, at City Council Meetings as a prerequisite of continued consideration of this SDR Development Project through the EIR process – has defined the pattern of the JUHSD’s efforts to fast-track this project; this has included attempts to silence and exclude designated local Native / Indigenous leaders, community member input, and inclusion of critical public feedback, as well as active lobbying by JUHSD members of local public agencies and civil rights organizations to stop submitting letters of public input throughout the EIR process.
Response KK.11: Please refer to Response KK.10: above. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.12: While cities across the state like San Francisco, Oakland, San José and Los Angeles have undertaken initiatives to address the multiple overlapping crises of housing, poverty, unemployment and drugs facing our cities today with more critical and innovative approaches, Daly City and San Mateo County continue to hedge on social and economic measures stuck in the past.
That past is more than problematic. It is riddled with both inequity and a lack of imagination or inclusion. Best practices in urban planning, aligned with policy directives at the state and federal level, mandate a justifiable accounting of housing and urban development, underscored by state law, CEQA, and ranging from consideration of environmental and community based impacts to Native Land Rights and Public Land Use law, its community benefits and clearly designated restrictions.
At the core of this SDR DEIR Proposal is a controversial pattern of approval for unaffordable housing development at the expense of public resources, including public schools, recreational and Environmentally protected green spaces. Daly City can do better - we have to - not only for our community, but for our county. There are many other cities facing deep inequities in a lack of affordable housing and cost of living in San Mateo County, and while Daly City is the largest among them - it yet faces the greatest disparities in being able to support our majority immigrant, renter and diverse, low-income community, even when it comes to use of public school funding, public land use and apparently, even publicly-funded housing developments. This project is estimated to take 10-15 years and continues to fail to address any of these issues with due diligence. There is no justifiable proposal of any separate-but-equal public policy - in education, housing or any aspect of society - and glaring issues like this compel a complete, immediate reassessment and revision of this project. That vision must be based on sound legal and ethical, best practices in policymaking - and should begin its ultimate development with the community.
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Response KK.12: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.13: There is no complete or majority consensus over the highly controversial and incomplete DEIR Proposal for the Serramonte del Rey Development project. Nobody voted on this project despite its highly controversial and questionable appropriation of public school bond money to kickstart its development. This has yet to adequately address or negotiate the many disputed issues and discrepancies of this EIR process cited over the course of two years by numerous and ongoing public comments made by local residents, youth, public officials, nonprofit and public agencies and community-based organizations, including local Native / Indigenous leaders, high school and college students, alumni, teachers, the Daly City Community Garden Alliance, and our local chapters of the Sierra Club and the NAACP.
Response KK.13: The Draft EIR was prepared to inform a forthcoming decision by the City of Daly City regarding the requested land use entitlement applications. The Draft EIR is not a proposal, but rather evaluates the proposed project, and the information is to be considered by the decision-makers as they act on the pending application. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.14: Recommendations to specific changes to this DEIR can be found in additional public comment, input and letters submitted by the community noted here, in addition to a serious reconsideration of our city’s adherence, commitment and alignment with federal housing policy and Affirmatively Furthering Fair Housing (AFFH), which should be centered as a central, guiding tenet in the formulation of Daly City’s Housing Element. Daly City’s application of AFFH should be assessed in alignment with the City and County of San Francisco, with which it shares a strong overlap and affinity with respect to demography, geography, and urban development and housing conditions.
Disparities highlighted by US Census data, as well as that provided by the County of San Mateo Human Services Agency, are in the City of Daly City’s Housing Element as well - but often stop short of a full accounting of the housing issues and solutions being considered - and require stronger transparency, outreach, and engagement of community for public input.
Response KK.14: Please refer to Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law above. This comment does not raise any specific issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment KK.15: As a city leading San Mateo County with high profile demographic indicators and status across socioeconomic and political considerations, Daly City should be looking to larger city, state and national profiles of best practices and innovative reimagining of housing and urban development. To center our city’s Housing Element around housing goals projected by this SDR DEIR will fail to consider the past and present state of our city and effectively provide a critical analysis of our own community’s express needs. This would be a failure to learn from the inequity
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of the devastating legacy of Urban Renewal policy that has led to our current crises demanding housing, social and environmental justice today. Federal policy derived from the Green New Deal and local people's proposals have provided a template both for next generation public policy and the public process of civic and community engagement. Public comment is essential to public policy.
Our community’s voices are vital to ensuring that governance is indeed diverse, equitable and inclusive - and those voices will continue to redefine what our cities need as we move into another election cycle with so many critical issues facing our country at stake. It is my hope and strong encouragement that we take this opportunity in reviewing the DEIR to engage the real issues at the heart of this development in Serramonte - and Daly City altogether - to reflect, renegotiate and reimagine housing and urban development in our city, county and the state of California forward together.
Response KK.15: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.
LL. Sabrina Brennan (dated September 8, 2023)
Comment LL.1: Please see the link below for images of Mission Blue butterflies at the Daly City Community Garden located at the Serramonte Del Rey project site. I have seen Mission Blue butterflies many times, over the years, at the Daly City Community Garden.
Here’s a link:
https://link.edgepilot.com/s/62c53fff/HQEcg7UYHkOkYASrBoxXrQ?u=https://chng.it/RrrVx8CJGZ Happy to provide more photos if you need them.
Response LL.1: Please refer to Response DD.6: above.
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Section 5.0 Refinements to the Precise Plan
Since the completion of the Draft EIR, there have been small refinements to the Precise Plan that the applicant, the Jefferson Union High School District, has made in response to feedback from the City and the community. The City has reviewed these refinements and finds, as documented below, that none of these refinements have resulted in any new significant environmental impacts not analyzed in the Draft EIR; any substantial increases in the severity of environmental impacts already analyzed in the Draft EIR; or any feasible project alternative or mitigation measure capable of reducing any significant environmental impacts that is considerably different from those alternatives already analyzed in the Draft EIR. Accordingly, the refinements to the Precise Plan do not require recirculation of the Draft EIR.
Many of the refinements to the Precise Plan concern the administrative process that future developments in the project area must undergo in order to receive necessary approvals and permits from the City. These administrative changes do not impact the physical layout, buildout, or timing of the project, and therefore will not have any impacts on the physical environment.
The following refinements to the Precise Plan may concern the physical layout or buildout of the project, but do not trigger the need for further environmental review:
• An increase in maximum building height to 90 feet for Parcels A, B, and C from the previous maximum of 77 feet.
• An increase in the permitted maximum residential units on Parcel C to 152 units from the previous maximum of 125 units; however, the total number of residential units across all parcels still shall not exceed 1,235, meaning that the total number of units within the project, and both its residential density and intensity, remain unchanged. • Elimination of the second level of parking (below-grade parking) on Parcel B and associated driveway, and a slightly reconfigured ground floor plan to reflect the elimination. Parking for Parcel B residents will be accommodated by installing mechanical lifts in the remaining ground level structure. Retail parking will be accommodated with street parking. • A refinement of a portion of the of the loop trail path on Parcel C to account for proposed building area.
• Addition of a community garden area to Overlook Park. • Modification of the Permitted Land Uses Table to reflect the use regulation in the Commercial Mixed Use (CMU) District.
• A modification to the layout of South Access Way to have 26 feet clear for emergency vehicle access by replacing diagonal parking along the street with parallel parking on southside of the street.
• A widening of Parcel C by 9', 4" along its northern boundary, with a corresponding reduction of Parcel D along its southern boundary.
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• Widened street sections to incorporate protected, Class IV bike lanes at Entry Drive, North Drive, East Drive, Campus Drive, North and South Access Way; added Class II bike lanes to the existing Campus Drive from the roundabout to Hickey Boulevard. • Select sidewalk widening, ADA and wood retaining wall improvements on Callan Boulevard sidewalk along portions of the east side of the plan area. • Establishing a connection between project stormwater infrastructure and the existing 24- inch storm drain at southern plan area that connects to the storm drain line in Callan Boulevard, which functions as a second storm drainage outfall for the project site. Modified storm drainage system to utilize this second outfall.
Below is a table of each modification to the Precise Plan that concerns the physical layout or buildout of the project. For each modification, there is an accompanying analysis of the modification effect on the Draft EIR's analysis of environmental impacts.
Modification Analysis of Potential Impact
An increase in maximum building height to 90
feet for Parcels A, B and C from the previous
maximum of 77 feet.
As discussed in Section 3.1 Aesthetics under
Impact AES-1 of the Draft EIR (page 27), the
project site is located on an infill site within a
transit priority area. Therefore, under Senate
Bill 743, aesthetic impacts of the project shall
not be considered significant impacts. The
Draft EIR concluded that the project would not
result in any significant aesthetic impacts, and
similarly, any changes to the physical design of
the project, including building heights, massing,
and layouts will not result in any new
significant aesthetic impacts pursuant to State
law.
The Draft EIR analyzed building heights with
respect to Impact HAZ-5, which studied
whether the project would result in a safety
hazard or excessive noise for people residing or
working in the project area given the project's
location within an airport use plan. As the Draft
EIR notes, the project site is located on terrain
that is 200 feet or greater above ground level.
As such, the project was already subject to a
requirement to file either (a) 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 (2) a
signed exemption form pursuant to 14 CFR Part
77.9(b) be submitted prior to construction.
(Draft EIR page 109). The project will remain
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Modification Analysis of Potential Impact
subject to this requirement. 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. (Draft
EIR page 109). This determination was based
on an assumption that buildings on Parcel D, E,
and F could potentially reach 150 feet in
height. Accordingly, an increase of maximum
building height for Parcels A, B and C to allow
for buildings to reach 90 feet will not be
inconsistent with the SFO ALUCP and FAR Part
77 regulations. The increase in height will not
result in any new safety hazard for people
residing or working in the project area, or any
increase in previously identified safety hazards
for people working or residing in the project
area.
Permitted building heights do not factor into or
impact analysis of Agriculture and Forestry
Resources, Air Quality, Biological Resources,
Cultural Resources, Energy, Geology and Soils,
Greenhouse Gas Emissions, Hazards and
Hazardous Materials (with the exception of
Impact HAZ-5 discussed above), Hydrology and
Water Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Transportation,
Tribal Cultural Resources, Utilities and Service
Systems, or Wildfire.
An increase in the permitted maximum
residential units on Parcel C to 152 units from
the previous maximum of 125 units. However,
the total number of residential units across all
parcels still shall not exceed 1,235, meaning
that the total number of units within the
project remains unchanged.
Calculations of the environmental impacts of
the project are based on the total project
population as a whole (i.e., 1,235 residential
units, 14,000 square feet of commercial uses,
and 2,400 square foot childcare facility), not
the number of units on any particular parcel.
The total number of units across the project
remains the same as studied under the Draft
EIR; therefore this modification will not alter
any of the analysis or conclusions in the Draft
EIR.
Serramonte Del Rey Campus Redevelopment 134 Final EIR
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Modification Analysis of Potential Impact
The potential for the construction of 27 more
units on Parcel C will not have any substantial
impact on construction timelines, intensity, or
required construction equipment.
Furthermore, the Draft EIR's air quality analysis
for construction impacts already conservatively
assumed a six-year construction period, since
compressing the total construction activity into
a shorter period of time results in higher daily
emissions than if the project were built over a
longer period of time. Any lengthening of the
construction timeline as a result of longer
Parcel C construction will further reduce
forecasted environmental impacts.
Meanwhile, the inclusion of slightly more units
on Parcel C does not alter the conservative
assumptions set forth in the health risk
assessment, which already assumes the
presence of generators near project
boundaries that are located near sensitive
receptors (e.g., Parcels E and F).
Further, any changes to the massing or design
of the Parcel C building shall not be considered
significant impacts under Senate Bill 743.
An increase in maximum permitted units on
Parcel C, while still staying within the overall
project unit count of 1,235 units upon which
the DEIR based its analysis, will have no impact
on Agriculture and Forestry Resources, Air
Quality, Biological Resources, Cultural
Resources, Energy, Geology and Soils,
Greenhouse Gas Emissions, Hazards and
Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Transportation,
Tribal Cultural Resources, Utilities and Service
Systems, or Wildfire.
Elimination of the second level of parking
(below-grade parking) on Parcel B and
associated driveway, and a slightly
reconfigured ground floor plan to reflect the
elimination. Parking for Parcel B residents will
Under Senate Bill 743, parking impacts of this
project shall not be considered significant
impacts.
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Modification Analysis of Potential Impact
be accommodated by installing mechanical lifts
in the remaining ground level structure. Retail
parking will be accommodated with street
parking.
Elimination of below-grade parking on Parcel B
will potentially lessen the extent of excavation
needed on Parcel B, thereby potentially
reducing impacts related to Air Quality
emissions from construction, Cultural
Resources, Geology and Soils, Hydrology and
Water Quality, Noise, and Tribal Cultural
Resources.
An elimination of below grade parking on
Parcel B will have no impact on Agriculture and
Forestry Resources, Biological Resources,
Energy, Greenhouse Gas Emissions, Hazards
and Hazardous Materials, Land Use and
Planning, Population and Housing, Public
Services, Recreation, Transportation, Utilities
and Service Systems, or Wildfire.
A refinement of a portion of the loop trail path
on Parcel C to account for proposed the
proposed building area.
The loop trail will continue to provide open
space and park access for project users, and
the project as a whole will continue to provide
approximately 6.5 acres of park space. The
project will continue to pay in-lieu fees to
offset recreational demand for parkland not
provided by the proposed project and/or
dedicate land pursuant to Daly City Municipal
Code Section 16.30.400. Accordingly, this
modification will not result in any new or
increased recreation impacts.
The modification of the loop trail path will have
no impact on Agriculture and Forestry
Resources, Air Quality, Biological Resources,
Cultural Resources, Energy, Geology and Soils,
Greenhouse Gas Emissions, Hazards and
Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Transportation, Tribal Cultural
Resources, Utilities and Service Systems, or
Wildfire.
Addition of a community garden area to
Overlook Park.
The addition of a community garden will not
impact the size of Overlook Park or access to
overlook park. The garden would replace an
area previously designed to be grass; thus,
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Modification Analysis of Potential Impact
there would be no change in anticipated water
use. The project as a whole will continue to
provide approximately 6.5 acres of park space.
The project will continue to pay in-lieu fees to
offset recreational demand for parkland not
provided by the proposed project and/or
dedicate land pursuant to Daly City Municipal
Code Section 16.30.400. Accordingly, this
modification will not result in any new or
increased recreation impacts.
The addition of a community garden to
Overlook Park will have no impact on
Agriculture and Forestry Resources, Air Quality,
Biological Resources, Cultural Resources,
Energy, Geology and Soils, Greenhouse Gas
Emissions, Hazards and Hazardous Materials,
Hydrology and Water Quality, Land Use and
Planning, Mineral Resources, Noise, Population
and Housing, Public Services, Transportation,
Tribal Cultural Resources, Utilities and Service
Systems, or Wildfire.
Modification of the Permitted Land Uses Table
to reflect the use regulation in the Commercial
Mixed Use (CMU) District.
The Draft EIR already studies the impact of a
General Plan Amendment to change the land
use designation of the project site from C-O
(Commercial – Office) to C-MU (Commercial –
Mixed Use). (Page 3, 124). The actual scope of
development, as documented elsewhere
herein, is not changing in any significant
manner, and the refinement of the General
Plan designation, as implemented through
virtually the same Precise Plan, is a "paper"
change that does not alter the environmental
analysis.
Accordingly, the modification of the Permitted
Land Uses Table to reflect the use regulation in
the Commercial Mixed Use (CMU) District will
have no effect on the environmental analysis
already contained in the Draft EIR.
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Modification Analysis of Potential Impact
A refinement to the layout of South Access
Way to have 26 feet clear for emergency
vehicle access by replacing diagonal parking
along the street with parallel parking on
southside of the street.
Under Senate Bill 743, parking impacts of this
project shall not be considered significant
impacts.
Modifying street layout to better
accommodate emergency vehicle access will
not negatively affect the project's
transportation impacts. In fact, the
modification is in accordance with MM TRN4.1, which requires all future development within the project site to provide even surface
pavement, appropriate signage, delineation,
and other features at all emergency access
points and internal roadways to accommodate
emergency vehicles.
The modification to the layout of South Access
Way will have no impact on Agriculture and
Forestry Resources, Air Quality, Biological
Resources, Cultural Resources, Energy, Geology
and Soils, Greenhouse Gas Emissions, Hazards
and Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Tribal Cultural
Resources, Utilities and Service Systems, or
Wildfire.
A widening of Parcel C by 9', 4" along its
northern boundary, with a corresponding
reduction of Parcel D along its southern
boundary.
A small alteration to the boundaries of Parcel C
and Parcel D, with no increase in the overall
project site, will have no impact on Agriculture
and Forestry Resources, Air Quality, Biological
Resources, Cultural Resources, Energy, Geology
and Soils, Greenhouse Gas Emissions, Hazards
and Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Transportation,
Tribal Cultural Resources, Utilities and Service
Systems, or Wildfire.
Widened street sections to incorporate
protected, Class IV bike lanes at Entry Drive,
North Drive, East Drive, Campus Drive, North
and South Access Way; added Class II bike
Incorporating protected bike lanes on project
streets is consistent with the analysis
conducted in the Draft EIR, which assumed
"new bike lanes and sidewalks […] throughout
the project site." (Page 11, 39). The
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Modification Analysis of Potential Impact
lanes to the existing Campus Drive from the
roundabout to Hickey Boulevard.
Transportation analysis of the project assumed
that the project would "provide Class I, Class II,
and Class III bicycle facilities on interior
roadways within the project site" and would
therefore comply with General Plan Policies CE13 and CE-20. Class IV bike lanes provide protection above and beyond the level
required under the General Plan, and would
remain consistent with those policies.
Inclusion of Class IV bike lanes will have no
impact on Agriculture and Forestry Resources,
Air Quality, Biological Resources, Cultural
Resources, Energy, Geology and Soils,
Greenhouse Gas Emissions, Hazards and
Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Tribal Cultural
Resources, Utilities and Service Systems, or
Wildfire.
Select sidewalk widening, ADA, and wood
retaining wall improvements on Callan
Boulevard sidewalk along portions of the east
side of the plan area.
Incorporating improved internal sidewalks is
consistent with the analysis conducted in the
Draft EIR, which assumed that the project may
be required to construct sidewalk
improvements on Callan Boulevard. (Page 11).
Sidewalk widening, ADA, and wood retaining
wall improvements on Callan Boulevard
sidewalk will have no effect on the
environmental analysis already contained in
the Draft EIR. In fact, if proposed in isolation,
these improvements would be subject to CEQA
exemptions covering improvements to
pedestrian networks.
Establishing a connection between project
stormwater infrastructure and the existing 24-
inch storm drain at southern plan area that
connects to the storm drain line in Callan
Boulevard, which functions as a second storm
drainage outfall for the project site. Modified
storm drainage system to utilize this second
outfall.
The connection of the project stormwater
infrastructure to existing infrastructure entails
only de minimis construction activity that
would not meaningfully affect the environment
compared to the construction impacts already
analyzed in the Draft EIR. The project's
performance standard still requires that postproject drainage is at or less than pre-project drainage.
Serramonte Del Rey Campus Redevelopment 139 Final EIR
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Modification Analysis of Potential Impact
This stormwater infrastructure refinement will
have no impact on Agriculture and Forestry
Resources, Air Quality, Biological Resources,
Cultural Resources, Energy, Geology and Soils,
Greenhouse Gas Emissions, Hazards and
Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing,
Public Services, Recreation, Tribal Cultural
Resources, Utilities and Service Systems, or
Wildfire.
As demonstrated in the foregoing analysis, the refinements to the Precise Plan will not result in any new significant environmental impacts not analyzed in the Draft EIR; any substantial increases in the severity of environmental impacts already analyzed in the Draft EIR; or any feasible project alternative or mitigation measure capable of reducing any significant environmental impacts that is considerably different from those alternatives already analyzed in the Draft EIR; therefore recirculation of the Draft EIR is not required due to these project refinements.
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Section 6.0 Draft EIR Text Revisions
This section contains revisions to the text of the Serramonte Del Rey Campus Redevelopment Draft EIR dated June 2023. Revised or new language is underlined. All deletions are shown with a line through the text.
Page iv REVISE the last sentence of the fourth paragraph under Summary of the Project as follows:
The building would include one level of at-grade parking. two levels of parking, with one level of below grade parking.
Page ix, 66 ADD the following text to the fourth bullet in mitigation measure MM BIO-1.2:
• If special-status bat species or maternity roosts are detected during these surveys, a qualified biologist shall identify any additional measures required to protect the roosts, such as including avoidance of the roosts until the end of the maternity roosting season. The qualified biologist shall also contact the California Department of Fish and Wildlife (CDFW) and coordinate with CDFW on measures to protect the roosts.
Page xii, 140 ADD the following measure after the first bullet to MM NOI-1.1:
MM NOI-1.1: The applicant shall develop a construction noise control plan for each construction phase, including, but not limited to, the following available controls:
• Construct temporary noise barriers, where feasible, to screen stationary noise-generating equipment. Temporary noise barrier fences would provide a 5 dBA noise reduction if the noise barrier interrupts the line-of-sight between the noise source and receptor and if the barrier is constructed in a manner that eliminates any cracks or gaps. • Construct a temporary noise barrier, where feasible, between Parcel C and Shasta High School to screen noise-generating equipment. Temporary noise barrier fences would provide a 7 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. To achieve a 7 dBA of noise reduction the temporary barrier shall block line of sight to the top of the Shasta High School building windows.
Page xvi DELETE MM TRN-3.2:
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:
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City of Daly City November 2023
• 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.
Table 4.1-1: Development Maximum Per Parcel
Parcel Number Maximum Residential Units1
Maximum
Retail/Commercial (square
feet)3
Parcel A2 122 0
Parcel B 210 8,000
Parcel C5 125152 6,0004
Parcel D 270 6,000
Parcel E 330 6,000
Parcel F 400 6,000
1. Shows maximum residential units per parcel; however, the total amount of residential units across all parcels shall not exceed 1,235 units.
2. Parcel A has been constructed and occupied and was approved under a separate application
3. Parcels C-F may provide retail/commercial space in addition to the 8,000 square feet assumed for Parcel B; however, the total amount across all parcels shall not exceed 14,000 square feet
4. Parcel C is permitted to build up to 1,400 square feet of childcare facilities in addition to the overall retail/commercial square footage
5. Parcel C would be subdivided into two parcels (C1 and C2)
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City of Daly City November 2023
Parcels A, B, and C would have maximum building heights of 7790 feet, and Parcels D, E, and F would have a maximum building height of 150 feet.
PARCEL A
PARCEL D
PARCEL C
PARCEL B
PARCEL F PARCEL E Entry Drive West Drive
East Drive
North Drive
St. FrancisBlvd.
Callan Blvd.
Serramonte Blvd.
Access Drive West Access Drive North
Access Drive South
PROPOSED PRECISE PLAN PARCELS FIGURE 2.2-5
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City of Daly City November 2023
Serramonte Del Rey Demonstration Garden:
JUHSD is providing raised planter beds at their new adult education building located at 123 Edgemont Drive, which was approved by the JUHSD Board on August 17, 2021 (see Figure 2.2-6), and at the proposed public park on Parcel B (see Section 2.2.2.2 below).
The proposed development would demolish the existing building and surface parking on-site and construct a seven-story (up to 73.5 feet to top of parapet and 8586.5 feet to top of elevator shaft, see Figure 2.2-9), mixed-use building with 201 residential units and approximately 8,000 square feet of retail space. The building would include two levels one level of ground-floor parking (one level of below grade parking). A total of 334 parking spaces would be provided, with 301 of the spaces serving the residential units and 33 of the spaces reserved for retail customers and leasing. The lower level of the parking garage would provide 212 parking spaces serving the residential units. An additional 133 parking spaces would be provided on the ground-floor, with 43 reserved for retail customers and leasing and the remainder reserved for residential parking.
Vehicular access to the Parcel B site would be provided via a new driveway and the existing entry drive on Serramonte Boulevard (see Figure 2.2-8). The new driveway would be located east of the existing entry drive and provide direct access to the lower parking level. Aan entry road wouldthat runs north-south between Parcels A and B from the existing driveway along Serramonte Boulevard.
An entrance to the proposed ground-floor parking (i.e. the upper level of the parking garage) would be located along this new road. A new road serving Parcels A and B would run west-east along the southern boundaries of Parcels A and B. A new multi-use pathway would be constructed around the perimeter of the proposed mixed-use building and Parcel B.
• Hickey Boulevard/Callan Boulevard right-turn lane addition
Source: Siedel Architects, Inc., August 25, 2023.
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6723
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PARCEL B CONCEPTUAL SITE PLAN FIGURE 2.2-8
Serramonte Del Rey Campus Redevelopment 146 Final EIR
City of Daly City November 2023
Source: Siedel Architects, Inc., August 25, 2023.
SOUTH ELEVATION (NORTH DRIVE)
EL. 481.0’73’-6” TO TOP OF PARAPET
AVG. GRADE ELEVATION ENTRY DRIVE
OVERLOOK PARK
WEST ELEVATION (ENTRY DRIVE)
EL. 481.0’
73’-6” TO TOP OF PARAPET AVG. GRADE ELEVATION
SERRAMONTE BLVD. NORTH DRIVE
PARCEL B CONCEPTUAL BUILDING ELEVATIONS FIGURE 2.2-9
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The proposed Parcel B development project would include three components of open space to be used by the public: 1) approximately 22,300 square-foot public park that would include a large grass area, and playground, and community garden with raised planter beds; 2) the first phase of the recreational trail (approximately 6,800 square feet) that would be located in the southeast corner of Parcel B; and 3) open space for public use at the retail plaza (approximately 7,000 square feet) facing the new entry road (see Figure 2.2-10).
follows:
Stormwater would be treated on-site with area drains, drop inlets, manholes, bioretention areas, and below-grade pipes, before being discharged to a 24-inch storm drain lines in Serramonte Boulevard and Callan Boulevard. The project would treat stormwater before entering the city’s storm drain system. In addition, an infiltration gallery is proposed to offset an increase in runoff generated from the proposed development.
Source: Siedel Architects, Inc., August 25, 2023.
NORTH ACCESS WAY
SERRAMONTE BOULEVARD
ENTRY DRIVE
KEY NAME AREA LEVEL
PEDESTRIAN STREETSCAPE 6,505 SF GROUND FLOOR
RETAIL PLAZA 6,965 SF GROUND FLOOR
LANDSCAPE (<10%) 5,390 SF GROUND FLOOR
COURTYARD & TERRACE 24,360 SF GROUND/2ND
*PRIVATE BALCONIES OR DECKS 2,585 SF ALL LEVELS
ROOF TERRACE 1,346 SF 6TH FLOOR
SUBTOTAL 47,151 SF
PARK (<10%) 22,295 SF GROUND FLOOR
RECREATION TRAIL 5,985 SF GROUND FLOOR
SUBTOTAL 28,280 SF
TOTAL 75,431 SF
*SEE ARCHITECTURE DRAWINGS FOR PRIVATE BALCONY & DECK AREAS
USEABLE OPEN SPACE SUMMARY
PARCEL B CONCEPTUAL OPEN SPACE PLAN FIGURE 2.2-10
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City of Daly City November 2023
Land Use Plan as follows:
San Mateo County Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport
Daly City is within the jurisdiction of the San Francisco Airport (SFO) Land Use Plan component of the San Mateo County Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP), adopted in December 1996 and updated in 2001 November 2012. Established in the CLUP SFO ALUCP are procedures used by the San Mateo City and County Association of Governments (C/CAG) to review land use decisions in the vicinity of San Mateo County airports Francisco International Airport. Airport planning boundaries define where height, noise and safety standards, policies, and criteria are applied to certain proposed land use policy actions.
The project site is located within the SFO CLUP ALUCP Airport Influence Area B, which requires projects to be consistent with the goals and policies of the CLUP SFO ALUCP. 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 SFO ALUCP.
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 20 percent affordable housing, which is double the required amount.
Plan for the Environs of the San Francisco International Airport as follows:
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, tThe project site is located within the Airport 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
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criteria, and airspace protection/height limitation criteria in the SFO ALUCP. The site is located outside of the SFO 65 dB CNEL noise contour.
The Parcel B Development project includes a public park with a community garden, a recreational trail, and a public retail plaza, totaling approximately 0.8-acre.
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. and Serramonte Condominiums is, however, within the boundary for Jefferson Union High School District. The Serramonte Condominiums project proposes 323 residential units, which would generate approximately 191 new K-8 students and 29 new high school students. Daniel Webster Elementary School currently has an available capacity of 290 students and Fernando Middle School currently has an available capacity of 309 students (see Table 3.15-1). Westmoor High School currently has 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.
The Parcel B Development project includes a privately owned, publicly accessible park with a community garden, a recreational trail, and a public retail plaza, totaling approximately 0.8-acre, which would partially off-set demand on nearby recreational facilities.
Facilities as follows:
Consistent with General Plan Policies CE-13 and CE-20, the project proposes to provide Class I, Class II, and Class III, and Class IV 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.
Surface runoff from the project site is collected in area drains and conveyed to a 24-inch storm drain in Serramonte Boulevard and Callan Boulevard that flows to the east.
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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.
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
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technology. Queues at these parking garages could conflict with bicycle and pedestrian facilities if not designed properly.
Draft Environmental Impact Report
Serramonte Del Rey Campus Redevelopment
SCH# 2023060571
June 2023
In Consultation with
Prepared by
Serramonte Del Rey Campus Redevelopment i Draft EIR
City of Daly City June 2023
TABLE OF CONTENTS
Summary ........................................................................................................................................ iv Section 1.0 Introduction ..................................................................................................................... 1 Section 2.0 Project Information and Description ............................................................................... 3 Section 3.0 Environmental Setting, Impacts, and Mitigation .......................................................... 20
3.1 Aesthetics .............................................................................................................................. 23
3.2 Agriculture and Forestry Resources ..................................................................................... 30
3.3 Air Quality ............................................................................................................................ 33
3.4 Biological Resources ............................................................................................................ 54
3.5 Cultural Resources ................................................................................................................ 71
3.6 Energy ................................................................................................................................... 78
3.7 Geology and Soils ................................................................................................................. 85
3.8 Greenhouse Gas Emissions ................................................................................................... 93
3.9 Hazards and Hazardous Materials ...................................................................................... 100
3.10 Hydrology and Water Quality ............................................................................................ 112
3.11 Land Use and Planning ....................................................................................................... 122
3.12 Mineral Resources .............................................................................................................. 126
3.13 Noise ................................................................................................................................... 128
3.14 Population and Housing ...................................................................................................... 149
3.15 Public Services.................................................................................................................... 154
3.16 Recreation ........................................................................................................................... 163
3.17 Transportation ..................................................................................................................... 167
3.18 Tribal Cultural Resources ................................................................................................... 191
3.19 Utilities and Service Systems ............................................................................................. 194
3.20 Wildfire ............................................................................................................................... 203 Section 4.0 Growth-Inducing Impacts ........................................................................................... 204 Section 5.0 Significant and Irreversible Environmental Changes ................................................. 206 Section 6.0 Significant and Unavoidable Impacts ......................................................................... 208 Section 7.0 Alternatives ................................................................................................................. 209 Section 8.0 References ................................................................................................................... 217 Section 9.0 Lead Agency and Consultants ..................................................................................... 222 Section 10.0 Acronyms and Abbreviations ...................................................................................... 222
Serramonte Del Rey Campus Redevelopment ii Draft EIR
City of Daly City June 2023
Figures
Figure 2.2-1: Regional Map ................................................................................................................... 5 Figure 2.2-2: Vicinity Map .................................................................................................................... 6 Figure 2.2-3: Aerial Photograph and Surrounding Land Uses ............................................................... 7 Figure 2.2-4: Precise Plan Boundary ..................................................................................................... 8 Figure 2.2-5: Proposed Precise Plan Parcels .......................................................................................... 9 Figure 2.2-6: JUHSD District Office and Adult Education Site Plan .................................................. 12 Figure 2.2-7: Parcel A Development Project Site Plan ........................................................................ 13 Figure 2.2-8: Parcel B Conceptual Site Plan ........................................................................................ 14 Figure 2.2-9: Parcel B Conceptual Building Elevations ...................................................................... 15 Figure 2.2-10: Parcel B Conceptual Open Space Plan ......................................................................... 17 Figure 3.1-1: Transit Priority Area ...................................................................................................... 28 Figure 3.3-1: Location of Off-Site Receptors, MEIs, and Proposed Emergency Generators .............. 47 Figure 3.4-1: Biological Land Cover ................................................................................................... 60 Figure 3.13-1: Noise Monitoring Locations ...................................................................................... 133 Figure 3.17-1: Existing Transportation Facilities .............................................................................. 173 Photos
Photo 1 & 2 ....................................................................................................................................... 25 Photo 3 & 4 ....................................................................................................................................... 26 Photo 5 ....................................................................................................................................... 63 Tables
Table 2.2-1: Development Maximum Per Parcel ................................................................................... 4 Table 3.0-1: Cumulative Projects List ................................................................................................. 21 Table 3.0-2: Geographic Considerations in Cumulative Analysis ....................................................... 22 Table 3.3-2: BAAQMD Air Quality Significance Thresholds ............................................................ 38 Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures ............. 39 Table 3.3-4: Average Daily Construction Period Emissions - Unmitigated ........................................ 42 Table 3.3-5: Unmitigated Operational Period Emissions .................................................................... 45 Table 3.3-6: Construction Risk Impacts at Off-Site MEI .................................................................... 46 Table 3.3-7: Operational Risk Impacts at Off-Site MEI ...................................................................... 48 Table 3.3-8: Combined Mitigated Risk Impacts at Off-Site MEI ........................................................ 49
Serramonte Del Rey Campus Redevelopment iii Draft EIR
City of Daly City June 2023
Table 3.3-9: Cumulative Community Risk Impacts at Off-Site MEI .................................................. 51 Table 3.3-10: Cumulative Community Risk Impacts at On-Site MEI ................................................. 53 Table 3.6-1: Estimated Annual Project Energy Demand ..................................................................... 83 Table 3.8-1: Annual GHG Emissions (CO2e) in Metric Tons .............................................................. 97 Table 3.13-1: Groundborne Vibration Impact Criteria ...................................................................... 129 Table 3.13-2: Summary of Short-Term Measurements (dBA) .......................................................... 132 Table 3.13-3: Parcel B Construction Phase Noise Levels ................................................................. 137 Table 3.13-4: Parcel C/D Construction Phase Noise Levels ............................................................. 138 Table 3.13-5: Parcel E/F Construction Phase Noise Levels .............................................................. 139 Table 3.13-6: Noise Levels for Monthly Tests of the Emergency Generators .................................. 142 Table 3.13-7: Vibration Source Levels for Construction Equipment ................................................ 143 Table 3.15-1: School Enrollment and Capacity ................................................................................. 156 Table 3.17-1: Precise Plan VMT per Resident .................................................................................. 178 Table 3.17-2: Summary of Project Trip Generation .......................................................................... 185 Table 3.17-3: Existing Plus Project Intersection LOS at Adversely Affected Intersections ............. 186 Table 3.17-4: Cumulative Plus Project Intersection LOS at Adversely Affected Intersections ........ 187 Table 7.4-1: No Project – Existing Zoning Alternative VMT ........................................................... 215 Table 7.4-2: Summary of Project and Project Alternative Impacts ................................................... 216 Appendices
Appendix A: NOP Comments
Appendix B: Draft Serramonte Del Rey Precise Plan
Appendix C: Air Quality and Greenhouse Gas Emissions Assessment Appendix D: Biological Resources Assessment
Appendix E: Wetland Assessment
Appendix F: Biological Peer Review
Appendix G: Historic Resources Evaluation
Appendix H: Preliminary Geotechnical Investigation Report Appendix I: Phase I Environmental Site Assessment
Appendix J: Stormwater Memo
Appendix K: Noise and Vibration Assessment
Appendix L: Transportation Impact Assessment
Appendix M: Water Supply Assessment
Appendix N: Hydraulic Analysis
Appendix O: Sanitary Sewer Capacity Evaluation
Serramonte Del Rey Campus Redevelopment iv Draft EIR
City of Daly City June 2023
SUMMARY
The City of Daly City, as the Lead Agency, has prepared this Draft Environmental Impact Report (EIR) for the Serramonte Del Rey Campus Redevelopment project in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines.
As the CEQA Lead Agency for this project, the City of Daly City is required to consider the information in the EIR along with any other available information in deciding whether to approve the project. The basic requirements for an EIR include discussions of the environmental setting, significant environmental impacts (including growth-inducing impacts and cumulative impacts), mitigation measures, and alternatives. It is not the intent of an EIR to recommend either approval or denial of a project.
Summary of the Project
The approximately 22-acre project site is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard in the City of Daly City (APN 091-211-230). The site is currently developed with the Jefferson Union High School District offices and adult education buildings, Head Start, Parcel A Development project (JUHSD Faculty and Staff Housing project consisting of 122 units), surface parking lots, and associated landscaping.
The project consists of two primary components: (1) development of a new approximately 22-acre Serramonte Del Rey Precise Plan (Precise Plan), and (2) a specific development proposal for the approximately 4.3-acre Parcel B within a portion of the new Precise Plan.
The new Precise Plan would allow for the redevelopment of the project site area with up to 1,235 units (which includes the existing 122 units on Parcel A) of affordable and market-rate rental housing, up to 14,000 square feet of neighborhood-serving retail/commercial uses (in addition to 2,400 square feet for a Head Start childcare facility), and infrastructure improvements throughout the project area. Compared to the existing approved Precise Plan, the proposal would result in a net increase of 1,060 residential units and the elimination of planned office space.
The proposed Parcel B development would demolish an existing Adult Education building and surface parking on-site and construct a seven-story, mixed-use building with 201 residential units and approximately 8,000 square feet of retail space on a 4.3 acre portion of the site located at the northwest corner of the project site. The building would include two levels of parking, with one level of below grade parking.
Summary of Significant Impacts and Mitigation Measures
The following is a summary of the significant impacts and mitigation measures addressed within this EIR. The project description and full discussion of impacts and mitigation measures can be found in Section 2.0 Project Description and Section 3.0 Environmental Setting, Impacts, and Mitigation.
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Impact AIR-2: The project would not
result in a cumulatively considerable
net increase of any criteria pollutant
for which the project region is nonattainment under an applicable federal or state ambient air quality standard.
(Less than Significant Impact with
Mitigation Incorporated)
MM AIR-2.1: BAAQMD Best Management Practices: The
project shall implement the Bay Area Air Quality
Management District’s (BAAQMD’s) recommended best
management practices (BMPs) and additional measures to
reduce construction equipment exhaust emissions. These
measures shall include the following:
• All exposed surfaces (e.g., parking areas, staging
areas, soil piles, graded areas, and unpaved access
roads) shall be watered three times a day and at a
frequency adequate to maintain minimum soil
moisture of 12 percent. Moisture content shall be
verified by lab samples or moisture probe.
• All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed using a wet power vacuum
street sweeper at least once per day. The use of dry
power sweeping shall be prohibited.
• All vehicle speeds on unpaved roads shall be limited
to 15 mph.
• All roadways, driveways, and sidewalks to be paved
shall be completed as soon as possible. Building pads
shall be laid as soon as possible after grading unless
seeding or soil binders are used.
• All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
certified mechanic and determined to be running in
proper condition prior to operation.
• Post a publicly visible sign with the telephone
number and person to contact at the Lead Agency
regarding dust complaints. This person shall respond
and take corrective action within 48 hours. The Air
District’s phone number shall also be visible to
ensure compliance with applicable regulations.
• All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed
20 mph and visible dust extends beyond site
boundaries.
• Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of
construction adjacent to sensitive receptors. Wind
breaks should have at maximum 50 percent air
porosity.
• Vegetative ground cover (e.g., fast-germinating
native grass seed) shall be planted in disturbed areas
as soon as possible and watered appropriately until
vegetation is established.
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• The simultaneous occurrence of excavation, grading,
and ground-disturbing construction activities on the
same area at any one time shall be limited. Activities
shall be phased to reduce the amount of disturbed
surfaces at any one time.
• Avoid tracking of visible soil material on to public
roadways by employing the following measures if
necessary: (1) Site accesses to a distance of 100 feet
from public paved roads shall be treated with a 6 to
12-inch compacted layer of wood chips, mulch, or
gravel and (2) washing truck tires and construction
equipment of prior to leaving the site.
• Sandbags or other erosion control measures shall be
installed to prevent silt runoff to public roadways
from sites with a slope greater than one percent.
MM AIR-2.2: Selection of Construction Equipment: All
construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. Environmental Protection Agency (EPA) Tier 4
emission standards PM (PM10 and PM2.5), if feasible,
otherwise,
• Use equipment that meets U.S. EPA emission
standards for Tier 2 or 3 engines and include
particulate matter emissions control equivalent to
California Air Resources Board (CARB) Level 3
verifiable diesel emission control devices that
altogether achieve a 50-percent reduction in
particulate matter exhaust in comparison to
uncontrolled equipment; alternatively (or in
combination).
• Use of electrical or non-diesel fueled equipment.
Alternatively, the applicant may develop another construction operations plan demonstrating that the construction
equipment used on-site would achieve a reduction in
construction diesel particulate matter emissions by 70 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Implementation of Tier 4 or alternatively fueled
equipment,
• Installation of electric power lines during early
construction phases to avoid use of diesel generators
and compressors,
• Use of electrically-powered equipment,
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Significant Impact Mitigation Measures
• Forklifts and aerial lifts used for exterior and interior building construction shall be electric or
propane/natural gas powered,
• Change in construction build-out plans to lengthen
phases, and
• Implementation of different building techniques that
result in less diesel equipment usage.
Such a construction operations plan would be subject to review by an air quality expert and approved by the City prior to construction.
MM AIR-2.3: Low Volatile Organic Compounds (VOC)
Coating: The project shall use low volatile organic compound or VOC (i.e., ROG) coatings, that are below current
BAAQMD requirements (i.e., Regulation 8, Rule 3:
Architectural Coatings), for at least 50 percent of all residential and nonresidential interior paints and 50 percent of exterior paints. This includes all architectural coatings applied during both construction and reapplications
throughout the project’s operational lifetime. At least 50 percent of coatings applied must meet a “super-compliant” VOC standard of less than 10 grams of VOC per liter of
paint. For reapplication of coatings during the project’s operational lifetime, the Declaration of Covenants,
Conditions, and Restrictions shall contain a stipulation for low VOC coatings to be used.
Impact AIR-3: The project would not
expose sensitive receptors to
substantial pollutant concentrations.
(Less than Significant Impact with
Mitigation Incorporated)
See mitigation measures MM AIR-2.1 and MM AIR-2.2
above.
MM AIR-3.1: Prior to the issuance of a grading permit, the applicant shall provide the City with the most recent
construction phasing schedule by parcel for buildout of the proposed Precise Plan. If the most recent construction
phasing schedule increases the number of units per
construction phase compared to the construction phasing assumed in the air quality analysis of this EIR, the applicant shall prepare an updated community health risk assessment to confirm that the new phasing will not result in any new or more significant air quality impacts not previously disclosed in this EIR. The updated community health risk assessment shall be reviewed and approved by the Director of
Community Development or Director’s designee.
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Significant Impact Mitigation Measures
Impact AIR-C: The project would not
result in a cumulatively considerable
contribution to a cumulatively
significant air quality impact. (Less
than Significant Cumulative Impact
with Mitigation Incorporated)
See mitigation measures MM AIR-2.1 and MM AIR-2.2
above.
Impact BIO-1: The project would not
have a substantial adverse effect, either
directly or through habitat
modifications, on any species
identified as a candidate, sensitive, or
special status species in local or
regional plans, policies, or regulations,
or by the CDFW or USFWS. (Less
than Significant Impact with
Mitigation Incorporated)
MM BIO-1.1:
• If construction is initiated during the non-breeding
season (September 1 to January 31), then vegetation
removal, building demolition and other construction
may proceed with no restrictions.
• If initial building demolition, vegetation removal,
and construction is proposed during the nesting
season (February 1 to August 31), a focused survey
for nesting raptors and other native birds shall be
conducted by a qualified biologist within 14 days
prior to the onset of construction in order to
determine whether any active nests are present on the
site and surrounding area within 250 feet of proposed
construction. The survey shall be reconducted any
time construction has been delayed or curtailed for
more than 14 days during the nesting season.
• If no active nests are identified during the
construction survey period, then building demolition,
vegetation removal, and other construction may
proceed with no restrictions.
• If active bird nests are found, an adequate setback
shall be established by a qualified biologist, approved by the City Planning Division, around the nest
location and construction activities restricted within
this no-disturbance zone until the qualified biologist
has confirmed that any young birds have fledged and
are able to function outside the nest location.
Required setback distances for the no-disturbance
zone shall be based on input received from the
CDFW and may vary depending on species and
sensitivity to disturbance. As necessary, the nodisturbance zone shall be fenced with temporary orange construction fencing if construction is to be
initiated elsewhere on the site outside this zone.
• A report of findings shall be prepared by the
qualified biologist and submitted to the Director of
Community Development or Director’s designee for
review and approval prior to initiation of
construction during the nesting season (February 1 to
August 31). The report shall either confirm absence
of any active nests or should confirm that any young
are located within a designated no-disturbance zone
and construction can proceed. No report of findings
is required if construction is initiated during the nonPage 985 of 1358 Serramonte Del Rey Campus Redevelopment ix Draft EIR
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nesting season (September 1 to January 31) and
continues uninterrupted according to the above
criteria.
MM BIO-1.2: Adequate measures shall be taken to avoid
roosting by special-status bat species as a result of tree removal and building demolition, specifically:
• To the extent feasible, any tree removal or trimming
that is deemed necessary by a certified arborist to
maintain tree health shall be conducted outside of the
bat maternity season (i.e., generally avoiding tree
removal or trimming April through October).
• Building demolition shall, to the extent feasible, be conducted outside of the bat maternity season (i.e.,
generally avoiding demolition April through
October).
• If tree removal, trimming, or building demolition
occurs within bat maternity season (i.e., generally
April through October), a pre-construction bat roost
assessment shall be conducted by a qualified
biologist at least 14 days and no more than 30 days
prior to tree removal or building demolition to
determine if bats roosts are present that may be
impacted by project activities.
• If special-status bat species or maternity roosts are detected during these surveys, a qualified biologist
shall identify any additional measures required to
protect the roosts, such as including avoidance of the
roosts until the end of the maternity roosting season.
• Regardless of the timing of tree removal or trimming
activities, all felled trees or large limbs shall remain on the ground for at least 24-hours prior to chipping,
off-site removal, or other processing to allow any
roosting individual bats to vacate the premises of
their own volition.
• A report of findings shall be prepared by the
qualified biologist and submitted to the Director of
Community Development or Director’s designee for
review and approval prior to initiation of
construction during the maternity roosting season
(April through October). The report shall either
confirm absence of any active maternity roosts or
specify any additional measures necessary to protect
roosts until the end of the maternity roosting season.
No report of findings is required if construction is
initiated during the non-maternity roosting season
(November through March) and continues
uninterrupted according to the above criteria.
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Significant Impact Mitigation Measures
Impact BIO-C: The project would not
result in a cumulatively considerable
contribution to a cumulatively
significant biological resources impact.
(Less than Significant Cumulative
Impact with Mitigation
Incorporated)
See mitigation measures MM BIO-1.1 and MM BIO-1.2
above.
Impact CUL-2: The project would not
cause a substantial adverse change in
the significance of an archaeological
resource pursuant to CEQA Guidelines
Section 15064.5. (Less than
Significant Impact with Mitigation
Incorporated)
MM CUL-2.1: Undiscovered Archaeological Resources. If
evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5,
including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g.,
worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all grounddisturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation. the City’s Planning Manager shall consult with the archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-than-significant level through data recovery or other methods determined adequate by a
qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.
MM CUL-2.2: Report of Archaeological Resources. If
archaeological resources are identified, a final report summarizing the discovery of cultural materials shall be submitted to the City’s Planning Manager prior to issuance of certificate of occupancy. This report shall contain a
description of the mitigation program that was implemented and its results, including a description of the monitoring and testing program, a list of the resources found and conclusion, and a description of the disposition/curation of the resources.
Impact CUL-3: The project would not
disturb any human remains, including
those interred outside of dedicated
cemeteries. (Less than Significant
Impact with Mitigation
Incorporated)
MM CUL-3.1: Human Remains. If human remains are
discovered during project construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County
coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section
7050.5 of California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC
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shall be adhered to in the treatment and disposition of the remains. The project sponsor shall also retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide
professional assistance to the Most Likely Descendant,
including the excavation and removal of the human remains.
The City of Daly City shall be responsible for approval of recommended mitigation as it deems appropriate, taking
account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement
approved mitigation, to be verified by the City of Daly City, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.
Impact GEO-6: The project would
not directly or indirectly destroy a
unique paleontological resource or site
or unique geological feature. (Less
than Significant Impact with
Mitigation Incorporated)
MM GEO-6.1: Unique Paleontological and/or Geologic
Features and Reporting. Should a unique paleontological resource or site or unique geological feature be identified at the project site during any phase of construction, all ground disturbing activities within 25 feet shall cease and the City’s Planning Director notified immediately. A qualified
paleontologist shall evaluate the find and prescribe mitigation measures to reduce impacts to a less than significant level.
Work may proceed on other parts of the project site while mitigation for paleontological resources or geologic features is implemented. Upon completion of the paleontological
assessment, a report shall be submitted to the City and, if paleontological materials are recovered, a paleontological repository, such as the University of California Museum of Paleontology.
Impact GEO-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant geology and
soils impact. (Less than Significant
Cumulative Impact with Mitigation
Incorporated)
See mitigation measure MM GEO-6.1 above.
Impact HAZ-2: The project would not
create a significant hazard to the public
or the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment. (Less than Significant
Impact with Mitigation
Incorporated)
MM HAZ-2.1: Prior to the issuance of demolition, grading, or building permits for projects on Parcels C-E, the applicant shall remove the existing underground storage tanks (USTs) and aboveground storage tanks (ASTs) in accordance with the San Mateo County Department of Environmental
Health’s (SMCDEH) Underground Storage Tank Program
and Aboveground Petroleum Storage Tank Program. During
removal of the ASTs and USTs, contractors shall observe for staining and spilled contaminants. If stains and/or spills are observed, an Environmental Professional shall be retained to collect soil samples for laboratory analysis in accordance
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Significant Impact Mitigation Measures
with commonly accepted environmental protocols. If
contaminants are identified at concentrations exceeding applicable screening levels published by the RWQCB, DTSC and/or EPA , appropriate mitigation measures, such as, but not limited to, a Soil Management Plan and Health Safety Plan, shall be incorporated into the demolition permit.
Approval by an appropriate regulatory agency (i.e., RWQCB, DTSC or SMCDEH) shall be obtained prior to conducting
earthwork activities in the vicinity of the impacted soil. The applicant shall provide documentation of the safe removal of all existing USTs and ASTs consistent with SMCDEH
requirements to Director of Economic and Community
Development or Director’s designee for review and approval.
Impact HAZ-3: The project would not
emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
one-quarter mile of an existing or
proposed school. (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measure MM HAZ-2.1 above.
Impact NOI-1: The project would not
result in generation of a substantial
temporary or permanent increase in
ambient noise levels in the vicinity of
the project in excess of standards
established in the local general plan or
noise ordinance, or applicable
standards of other agencies. (Less
than Significant Impact with
Mitigation Incorporated)
MM NOI-1.1: The applicant shall develop a construction
noise control plan for each construction phase, including, but not limited to, the following available controls:
• Construct temporary noise barriers, where feasible, to screen stationary noise-generating equipment.
Temporary noise barrier fences would provide a 5
dBA noise reduction if the noise barrier interrupts the line-of-sight between the noise source and receptor
and if the barrier is constructed in a manner that
eliminates any cracks or gaps.
• Equip all internal combustion engine-driven
equipment with intake and exhaust mufflers that are
in good condition and appropriate for the equipment.
• Unnecessary idling of internal combustion engines
should be strictly prohibited.
• Locate stationary noise-generating equipment, such
as air compressors or portable power generators, as
far as possible from sensitive receptors as feasible. If they must be located near receptors, adequate
muffling (with enclosures where feasible and
appropriate) shall be used to reduce noise levels at
the adjacent sensitive receptors. Any enclosure
openings or venting shall face away from sensitive
receptors.
• Utilize "quiet" air compressors and other stationary
noise sources where technology exists.
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• Construction staging areas shall be established at
locations that will create the greatest distance
between the construction-related noise sources and
noise-sensitive receptors nearest the project site
during all project construction.
• Locate material stockpiles, as well as
maintenance/equipment staging and parking areas, as
far as feasible from residential receptors.
• Route construction-related traffic along major
roadways and as far as feasible from sensitive
receptors.
• Locate material stockpiles, as well as
maintenance/equipment staging and parking areas, as
far as feasible from residential receptors.
• Control noise from construction workers’ radios to a
point where they are not audible at existing
residences bordering the project site.
• The contractor shall prepare a detailed construction
schedule for major noise-generating construction
activities. The construction plan shall identify a
procedure for coordination with adjacent residential
land uses so that construction activities can be
scheduled to minimize noise disturbance.
• Designate a "disturbance coordinator" who would be
responsible for responding to any complaints about
construction noise. The disturbance coordinator will
determine the cause of the noise complaint (e.g., bad
muffler, etc.) and will require that reasonable
measures be implemented to correct the problem.
Conspicuously post a telephone number for the
disturbance coordinator at the construction site and
include in it the notice sent to neighbors regarding
the construction schedule.
Impact TRN-2: The project would not
conflict or be inconsistent with CEQA
Guidelines Section 15064.3,
subdivision (b). (Less than
Significant Impact with Mitigation
Incorporated)
MM TRN-2.1: Prior to issuance of building permits, the
project applicant shall develop a transportation demand management (TDM) plan for the proposed project (except for the Parcel A development project which has already been occupied) in accordance with C/CAG’s Transportation
Demand Management Policy Implementation Guide,
including any anticipated phasing, and shall submit the TDM Plan to the City for review and approval. The TDM Plan shall identify trip reduction strategies as well as mechanisms for funding and overseeing the delivery of trip reduction
programs and strategies. The TDM Plan shall be designed to achieve the trip reduction, as required to reduce the VMT per resident from 12.0 to 11.6. The TDM Plan shall describe which measures apply to the entire site and which, if any, apply on a parcel-by-parcel basis.
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Significant Impact Mitigation Measures
Trip reduction strategies applicable to the proposed project may include, but are not limited to, the following:
• Provide Secure and Accessible Bike Parking
• Provide Bicycle Maintenance Facilities
• Price and Unbundle Parking
• Provide Carpooling Programs
• Implement Car-Sharing Program
• Implement Loaner Bike Program
• Provide a Transit Riders Guide
• Provide a Dedicated Transportation Coordinator
• Provide an Online TDM Information Center
• Free Trial Rides on Transit Services
• Implement a Subsidized or Discounted Transit
Program
The TDM plan shall indicate the estimated Vehicle Trip
Reduction (VTR) for each strategy proposed based on
published research or guidelines. For TDM measures
containing ongoing operational VTR strategies, the TDM
plan shall include an ongoing monitoring and enforcement program to ensure the Plan is implemented on an ongoing basis during project operation. For VTR strategies involving physical improvements, the project shall obtain the necessary permits/approvals from the City and install the improvements prior to building occupancy. Applicant will resubmit TDM Plan if there is a material adverse impact resulting from a change from the permitted uses (i.e., unit count, use type, phasing).
The TDM Plan shall require annual evaluation of the
program by the property owner, to determine if the program goals in reducing automobile travel are satisfied and to assess the effectiveness of the various strategies implemented. The property owner shall be required to conduct biennial selfcertification for the first six years of project occupancy per the C/CAG TDM Program. The property owner shall conduct annual travel surveys and driveway counts to monitor the amount of automobile travel generated by the project. The goal of the TDM Plan and programs shall be to reduce the project’s daily VMT per resident from 12.0 to 11.6. Based on the results of the surveys, the TDM programs shall be
increased if these requirements are not met. Annual travel surveys and driveway counts (TDM program monitoring)
shall be conducted for the first two years following project occupancy. The results of the monitoring program and travel surveys shall be submitted to the City for review and
Serramonte Del Rey Campus Redevelopment xv Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
approval. If the program VMT reduction goals are met in the first six years, annual monitoring and surveys shall be suspended. If the program’s VMT reduction goals are not satisfied, site management shall prepare and submit for City approval a Corrective Action Plan. The Corrective Action Plan shall detail the additional TDM measures to be
implemented on site and their expected travel/mode split reduction. Additional annual travel surveys and driveway counts shall be conducted for the two years following the implementation of the Corrective Action Plan to determine if the program’s VMT reduction goals are satisfied.
Impact TRN-3: The project would not
substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm
equipment). (Less than Significant
Impact with Mitigation
Incorporated)
MM TRN-3.1: A Construction Traffic Management Plan
shall be developed and implemented to minimize impacts to the transportation system. The Construction Traffic
Management Plan shall detail the Project’s construction schedule, vehicle type time-of-day plans, route planning, advanced public notices of partial or full street closures or traffic diversion, and other strategies to reduce potential conflicts during construction. The plan shall include, but not be limited to, the following:
• Identification of the traffic controls and methods
proposed during each phase of Project construction.
Provision of safe and adequate access for vehicles,
transit, bicycles, and pedestrians. Traffic controls and methods employed during construction shall be in
accordance with Daly City standards and the
requirements of the California Manual of Uniform
Traffic Control Devices (CA MUTCD 2014,
Revision 6).
• Provision of notice to relevant emergency services,
thereby avoiding interference with adopted
emergency plans, emergency vehicle access, or
emergency evacuation plans.
• A prohibition on all construction truck activity
during the weekday morning and evening peak
commute periods (7:00 a.m. to 9:00 a.m. and 4:00
p.m. to 6:00 p.m.).
• Preservation of emergency vehicle access.
• Identification of approved truck routes in
communication with Daly City staff.
• Location of staging areas and the location of
construction worker parking.
• Identification of the means and locations of the
separation (i.e. fencing) of construction areas and
adjacent active uses.
• The provision of flaggers at all on-site locations
where construction trucks and construction worker
Serramonte Del Rey Campus Redevelopment xvi Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
vehicles conflict with vehicle, bicycle, transit, or
pedestrian traffic.
• Provision of a point of contact for residents to obtain construction information, have questions answered
and convey complaints.
MM TRN-3.2: As part of the Parcel B Development
project’s final design, details of the Serramonte Boulevard parking garage driveway design would include the following as determined necessary by the City Traffic Engineer:
• Measures to prohibit vehicular left-turns – either
through the installation of a hard concrete median,
vertical delineators, or alternative means.
• Adequate sight distance – obstructions to sight
distance for all users should not be placed adjacent to the driveway and adequate throat distance to the
garage entry should be provided accordingly.
• Pedestrian and bicycle warning measures – adequate
warning measures for pedestrians and bicycles
should be provided on Serramonte Boulevard,
including the installation of tactile domes on the
sidewalk and green hatched bike lane striping on the
roadway.
• The Parcel B driveway along Serramonte Blvd. shall
provide satisfactory separation distance from the
intersection of Serramonte Blvd. and Highway 1 onand off-ramps to address merging and any turning movements.
• A separate traffic study shall be conducted to
determine if a new traffic signal at the Parcel B
driveway is warranted. The results of the study will
affect the City’s determination on whether a
driveway entry and exit shall be permitted along
Serramonte Blvd.
MM TRN-3.3: As part of the project’s final design, each residential facility’s garage entrance accessed via the public right of way shall be designed to provide adequate storage for expected vehicle queues. The amount of storage shall be calculated based on the individual garage size and forecast rates of arrival and departure. A minimum stacking distance of 25 feet shall be provided between the back of curb and gate installation at the entrance to each residential garage entrance. The purpose of this space is to minimize the
instance of vehicles queued across sidewalks and bicycle facilities. These queue calculations shall be performed for
Serramonte Del Rey Campus Redevelopment xvii Draft EIR
City of Daly City June 2023
Significant Impact Mitigation Measures
each garage and submitted to the City Engineer with
planning/building permit for review and approval.
Impact TRN-4: The project would not
result in inadequate emergency access.
(Less than Significant Impact with
Mitigation Incorporated)
MM TRN-4.1: In accordance with City and North County
Fire Authority requirements and design standards, all future development within the project site shall provide even
surface pavement, appropriate signage, delineation, and other features at all emergency access points and internal roadways to accommodate emergency vehicles. As part of the final design and permitting process, each proposed development shall seek and obtain approval from the North County Fire Authority.
Impact TRN-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant transportation
impact. (Less than Significant
Cumulative Impact with Mitigation
Incorporated)
See mitigation measure MM TRN-2.1 above.
Impact TCR-1: The project would not
cause a substantial adverse change in
the significance of a tribal cultural
resource that is listed or eligible for
listing in the California Register of
Historical Resources, or in a local
register of historical resources as
defined in Public Resources Code
Section 5020.1(k). (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Impact TCR-2: The project would not
cause a substantial adverse change in
the significance of a tribal cultural
resource that is determined by the lead
agency, in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth
in subdivision (c) of Public Resources
Code Section 5024.1. (Less than
Significant Impact with Mitigation
Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Impact TCR-C: The project would
not result in a cumulatively
considerable contribution to a
cumulatively significant tribal cultural
resources impact. (Less than
Significant Cumulative Impact with
Mitigation Incorporated)
See mitigation measures MM CUL-2.1, MM CUL-2.2, and
MM CUL-3.1 above.
Serramonte Del Rey Campus Redevelopment xviii Draft EIR City of Daly City June 2023
Summary of Project Alternatives
The California Environmental Quality Act (CEQA) requires that an EIR identify alternatives to the project as proposed. The CEQA Guidelines state that an EIR must identify alternatives that would feasibly attain the most basic objectives of the project, but avoid or substantially lessen significant environmental effects, or further reduce impacts that are considered less than significant with the incorporation of mitigation. A summary of project alternatives follows. The EIR considered three alternatives, beyond those presented below, but rejected them for further analysis. A full analysis of project alternatives is provided in Section 7.0 Alternatives.
No Project Alternative
The No Project Alternative assumes that the project site would remain as it is today with the existing buildings being reoccupied. All environmental impacts of the project would be avoided. However, this alternative would not achieve any of the project objectives.
No Project – Existing Zoning Alternative
The No Project – Existing Zoning Alternative is what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. This alternative assumes the project is not approved and the project site is redeveloped consistent with the current zoning of PD-31 (Planned Development District).1 The PD-31 zoning is the current 1985 Precise Plan for the project site, which allows for the development of up to 175 residential units (53 units in addition to the 122 units developed on Parcel A) and approximately 700,000 square feet of office space. Associated infrastructure and roadway improvements would also be required in order to construct the No Project – Existing Zoning Alternative. This alternative would lessen the project’s construction criteria pollutant, TAC health risk, construction noise, and construction traffic impacts because it would reduce overall building square footage by approximately 500,000 square feet, but result in slightly greater VMT impacts per resident. This alternative would result in the same or similar impacts to all other environmental resource areas as the project. This alternative does not meet the project objective of providing new market-rate and affordable housing given this alternative would yield 175 units, substantially below the 1,235 proposed. This alternative would result in substantial office space on the project site, which is not an objective of the project.
Environmentally Superior Alternative
The CEQA Guidelines state that an EIR shall identify an environmentally superior alternative. As described in Section 7.0 Alternatives, the environmentally superior alternative to the proposed project is the No Project Alternative because all of the project’s significant environmental impacts would be avoided. In addition to the No Project Alternative, the No Project – Existing Zoning Alternative would be an environmentally superior alternative. 1 A smaller portion of the of the site in the northwest corner (Parcel A Development project) is zoned to PD-31A.
The PD-31A zoning was specifically created to allow for the Parcel A Development project, which will construct 122 multifamily units. Since this project is already approved and under construction, the remainder of the project site would be developed consistent with the PD-31 zoning.
Serramonte Del Rey Campus Redevelopment xix Draft EIR
City of Daly City June 2023
Areas of Concern
Environmental concerns expressed thus far from local residents, property owners, organizations, and/or agencies about the project include the following:
• Air quality impacts
• Biological impacts (nesting birds, wetlands, trees)
• Tribal and cultural resources
• School impacts
• Airport safety
• Project-generated traffic on roadway and freeway capacity • Bicycle/Pedestrian impacts
• Required connections to existing utilities infrastructure and needed improvements • Loss of an informal community garden space
Serramonte Del Rey Campus Redevelopment 1 Draft EIR
City of Daly City June 2023
SECTION 1.0 INTRODUCTION
1.1 PURPOSE OF THE ENVIRONMENTAL IMPACT REPORT
The City of Daly City, as the Lead Agency, has prepared this Draft Environmental Impact Report (EIR) for the Serramonte Del Rey Campus Redevelopment project in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines.2
As described in CEQA Guidelines Section 15121(a), an EIR is an informational document that assesses potential environmental impacts of a proposed project, as well as identifies mitigation measures and alternatives to the proposed project that could reduce or avoid adverse environmental impacts (CEQA Guidelines 15121(a)). As the CEQA Lead Agency for this project, the City of Daly City is required to consider the information in the EIR along with any other available information in deciding whether to approve the project. The basic requirements for an EIR include discussions of the environmental setting, significant environmental impacts including growth-inducing impacts, cumulative impacts, mitigation measures, and alternatives. It is not the intent of an EIR to recommend either approval or denial of a project.
1.2 EIR PROCESS
1.2.1 Notice of Preparation and Scoping
In accordance with Section 15082 of the CEQA Guidelines, the City of Daly City prepared a Notice of Preparation (NOP) for this EIR. The NOP was circulated locally on May 7, 2021 and the standard 30-day comment period concluded on June 7, 2021. The NOP was circulated to state and federal agencies through the State Clearinghouse on June 21, 2023 and the 30-day comment period concluded on July 21, 2023. The NOP provided a general description of the proposed project and identified possible environmental impacts that could result from implementation of the project. City of Daly City also held a public scoping meeting on May 19, 2021 to discuss the project and solicit public input as to the scope and contents of this EIR. The meeting was held virtually through a video conference call due to COVID-19 restrictions. Appendix A of this EIR includes the NOP and comments received on the NOP.
1.2.2 Draft EIR Public Review and Comment Period
Publication of this Draft EIR will mark the beginning of a 45-day public review period. During this period, the Draft EIR will be available to the public and local, state, and federal agencies for review and comment. Notice of the availability and completion of this Draft EIR will be sent directly to every agency, person, and organization that commented on the NOP, as well as the Office of Planning and Research. Written comments concerning the environmental review contained in this Draft EIR during the 45-day public review period should be sent to:
2 The project site is owned and operated by the Jefferson Union High School District; however, since the project is proposing residential and commercial uses and not educational facilities, the City of Daly City is considered the Lead Agency for the project.
Serramonte Del Rey Campus Redevelopment 2 Draft EIR
City of Daly City June 2023
Michael Van Lonkhuysen, Planning Manager
City of Daly City – Planning Division
333 90th Street
Daly City, CA 94015
[email protected]
1.3 FINAL EIR/RESPONSES TO COMMENTS
Following the conclusion of the 45-day public review period, the City of Daly City will prepare a Final EIR in conformance with CEQA Guidelines Section 15132. The Final EIR will consist of:
• Revisions to the Draft EIR text, as necessary;
• List of individuals and agencies commenting on the Draft EIR; • Responses to comments received on the Draft EIR, in accordance with CEQA Guidelines (Section 15088);
• Copies of letters received on the Draft EIR.
Section 15091(a) of the CEQA Guidelines stipulates that no public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings. If the lead agency approves a project despite it resulting in significant adverse environmental impacts that cannot be mitigated to a less than significant level, the agency must state the reasons for its action in writing.
This Statement of Overriding Considerations must be included in the record of project approval.
1.3.1 Notice of Determination
If the project is approved, the City of Daly City will file a Notice of Determination (NOD), which will be available for public inspection and posted within 24 hours of receipt at the County Clerk’s Office and available for public inspection for 30 days. The filing of the NOD starts a 30-day statute of limitations on court challenges to the approval under CEQA (CEQA Guidelines Section 15094(g)).
Serramonte Del Rey Campus Redevelopment 3 Draft EIR
City of Daly City June 2023
SECTION 2.0 PROJECT INFORMATION AND DESCRIPTION
2.1 PROJECT LOCATION
The approximately 22-acre project site is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard in the City of Daly City (APN 091-211-230). The majority of the project site has a General Plan land use designation of C-O (Commercial – Office) and is zoned PD-31 (Planned Development District) while a smaller portion of the site in the northwest corner was rezoned to PD31A for a faculty and staff housing project that has been constructed and now is occupied and has a General Plan land use designation of R-HD (Residential-High Density). Regional, vicinity, and aerial maps of the project site are provided in Figure 2.2-1, Figure 2.2-2, Figure 2.2-3, and Figure 2.2-4, respectively.
2.2 PROJECT DESCRIPTION
The project consists of two primary components: (1) development of a new approximately 22-acre Serramonte Del Rey Precise Plan (Precise Plan), and (2) a specific development proposal for the approximately 4.3-acre Parcel B within a portion of the new Precise Plan.
2.2.1 Precise Plan
A Precise Plan was approved in 1985 for an approximately 50-acre area that includes the project site and extends south to Hickey Boulevard. Phase I of the 1985 Precise Plan has already been built and includes the apartment buildings, Summit Shasta High School, and office buildings located south of the project site along Campus Drive (see Figure 2.2-3). Phase II of the 1985 Precise Plan would redevelop the approximately 22-acre project site up to 175 residential units and approximately 700,000 square feet of office space. The proposed Precise Plan would replace Phase II of the 1985 Precise Plan for the approximately 22-acre project site and would leave the original Precise Plan in place for the portion outside of the project site. The zoning and General Plan land use designation of the portion outside of the project site would also remain as-is.
This EIR provides project-level environmental review for the full buildout of the Precise Plan as described below. The City will review future project applications at the time specific development is proposed on each Parcel to ensure each proposed project is consistent with the development assumptions analyzed in this EIR. The new Precise Plan would allow for the redevelopment of the project site area with up to 1,235 units (which includes the existing 122 units on Parcel A) of affordable and market-rate rental housing, up to 14,000 square feet of neighborhood-serving retail/commercial uses (in addition to 2,400 square feet for a Head Start childcare facility), and infrastructure improvements throughout the project area. Compared to the existing approved plan, the proposal would result in a net increase of 1,060 residential units and the elimination of planned office space.3
The new Precise Plan would require a General Plan Amendment from C-O (Commercial – Office) to C-MU (Commercial – Mixed Use). Table 2.2-1 below summarizes the proposed maximum development allowed per parcel, although the overall Precise Plan development totals would be as noted above, and less than the sum of what is possible on each parcel. 3 The total residential units in the proposed Precise Plan is inclusive of the already approved faculty and staff housing project located on Parcel A. 1,235 units – 175 units = 1,060 units.
Serramonte Del Rey Campus Redevelopment 4 Draft EIR
City of Daly City June 2023
Table 2.2-1: Development Maximum Per Parcel
Parcel Number Maximum Residential Units1
Maximum
Retail/Commercial (square
feet)3
Parcel A2 122 0
Parcel B 210 8,000
Parcel C5 125 6,0004
Parcel D 270 6,000
Parcel E 330 6,000
Parcel F 400 6,000
1. Shows maximum residential units per parcel; however, the total amount of residential units across all parcels shall not exceed 1,235 units.
2. Parcel A has been constructed and occupied and was approved under a separate application
3. Parcels C-F may provide retail/commercial space in addition to the 8,000 square feet assumed for Parcel B; however, the total amount across all parcels shall not exceed 14,000 square feet
4. Parcel C is permitted to build up to 1,400 square feet of childcare facilities in addition to the overall retail/commercial square footage
5. Parcel C would be subdivided into two parcels (C1 and C2) The proposed Precise Plan would divide the project site into six development parcels (with Parcel C further subdivided into two smaller parcels) and additional street parcels with public access easements (see Figure 2.2-5). Parcels A, B, and C would have maximum building heights of 77 feet, and Parcels D, E, and F would have a maximum building height of 150 feet. The 1985 Precise Plan allowed for 12-story building within the center of the project site, six-story buildings along the eastern property line, and 3.5-story buildings along the western property line. Build-out of the site and division of parcels is anticipated to be over an eight to 12 year period, but potentially up to 15 years. The proposed phasing for the Precise Plan is development of Parcel B first, followed by Parcels C and D, and finally Parcels E and F, although the phasing order may be adjusted by market conditions or other factors. The proposed Precise Plan would also establish a new Planned Development District, consistent with the City’s Municipal Code Chapter 17.28. A copy of the proposed Precise Plan is included in Appendix B.
San Francisco County
San Mateo County
Monterey Boulevard
John Daly Boulevard John Daly Boulevard
Geary Boulevard
Great Highway
Hillside Boulevard
Sister Cities Boulevard
Geneva Avenue
Ocean Avenue
Portol a Drive
Lincoln Way
Fell Street
Van Ness Avenue
Guerrero Street
Dolores Street
Mission Street
Sharp Park Rd.
Chestnut Ave
Geary Boulevard
Great Highway
Hillside Boulevard
Sister Cities Boulevard
Geneva Avenue
Ocean Avenue
Portol a
Drive
Lincoln Way
Fell Street
Van Ness Avenue
Guerrero Street
Dolores Street
Mission Street
Sharp Park Rd.
Chestnut Ave
1 1
1 1
35 82
82 35
35 101
101
80 280
280
280
380
Pacific
Ocean
Project Site
San Francisco
Daly City
South San Francisco
Pacifica
San Bruno
REGIONAL MAP FIGURE 2.2-1
Pacific
Ocean
San José
Fremont
Oakland
San Francisco
Mountain View
Sunnyvale
Fremont San Mateo
Redwood City
Oakland
San Francisco
Mountain View
Project SiteSan Francisco Bay
01 .5 3 Miles
Collins Avenue
Serramonte Boulevard
Serramonte
Boulevard
Junipero Serra Boulevard
Callan Boulevard
Hickey Boulevard Gellert Bou el va dr
St. Francis Boulevard
Callan Boulevard
Skyline Drive
Westline Drive
Collins Avenue Serramonte Boulevard
S
e
r
r
a
m
o
n
t
e
B
o
u
l
e
v
a
rd
Junipero Serra Boulevard
Callan Boulevard
Hickey Boulevard Gellert Bou el va dr
St. Francis Boulevard
Callan Boulevard
Skyline Drive
Westline Drive
1 1
35 35
280
280
VICINITY MAP FIGURE 2.2-2
Base Map: ESRI, ArcGIS
0 250 1,000 1,500 2,500 Feet
Project Site
Residential
Cemetery
Residential
Residential
Residential
& Commercial
School
Medical
Offices
Higate Drive Serramonte Boulevard St. Francis Boulevard Callan Boulevard
Campus Drive
Hickey Boulevard
Gellert Boulevard
Serramonte Boulevard
St. Francis Boulevard
C
allan Boulevard
C
a
m
pus Drive
Hickey Boulevard
G
ellert Boulevard
1 1
35 AERIAL PHOTOGRAPH AND SURROUNDING LAND USES FIGURE 2.2-3 Aerial Source: Google Earth Pro, Apr. 30, 2021. Photo Date: Sep. 2020 0 100 400 600 1,000 Feet
Project Boundary
Callan Blvd.
Campus Dr.
Hickey Blvd.
Higate Dr.
Callan Blvd.
etnomarreS .dvlB
St. Francis Blvd. St. Francis Blvd.
PRECISE PLAN BOUNDARY FIGURE 2.2-4
24 Chapter 3: Development Standards and Guidelines Serramonte Del Rey Precise Plan
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Plan Area Districts
Figure 3.1
PARCEL A
PARCEL D
PARCEL C
PARCEL B
PARCEL F PARCEL E
Parcel lines Commercial Mixed Use District (C-MU) Residential Very High Density (R-VHD) District Campus Drive
Entry Drive
West Drive
East Drive
North Drive
St. Francis Blvd.
Callan Blvd.
Serramonte Blvd.
Plan Area Districts
Figure 3.1
PARCEL A
PARCEL D
PARCEL C
PARCEL B
PARCEL F PARCEL E
Parcel lines Commercial Mixed Use District (C-MU) Residential Very High Density (R-VHD) District Campus Drive
Entry Drive
West Drive
East Drive
North Drive
St. Francis Blvd.
Callan Blvd.
Serramonte Blvd.
PROPOSED PRECISE PLAN PARCELS FIGURE 2.2-5
Serramonte Del Rey Campus Redevelopment 10 Draft EIR
City of Daly City June 2023
2.2.1.1 Serramonte Del Rey Demonstration Garden
There is an approximately 0.5-acre school demonstration garden located in the southwest corner of the Precise Plan area. This garden was started 20 years ago and used by JUHSD for adult education as a demonstration garden. In 2019, the garden was listed as a “community garden” by the County of San Mateo; however, the listing occurred without the knowledge or permission of JUHSD leadership, and therefore the garden was removed from the list. Since the garden is intended for use by JUHSD for educational purposes, JUHSD provides limited access for members of the public and is restricting hours of use during the interim period of campus utilization prior to the start of construction of Parcel B and the demolition of the existing high school building.
The proposed Precise Plan would remove the existing garden and use the space as a construction staging area until Parcel F is fully developed with up to 400 units and 6,000 square feet of retail uses.
JUHSD is providing raised planter beds at their new adult education building located at 123 Edgemont Drive, which was approved by the JUHSD Board on August 17, 2021 (see Figure 2.2-6).
2.2.1.2 Parcel A Development Project
The JUHSD Faculty and Staff Housing project is constructed and occupied on Parcel A of the proposed Precise Plan. The Parcel A development project was approved by the City of Daly City in January 2020 and consists of four-story (48 feet), 122 multi-family units for JUHSD faculty, staff, and their families on an approximately 3.9-acre site (see Figure 2.2-7). While the Parcel A development project was approved under a separate application, the 122 residential units are included in the proposed Precise Plan’s total unit count of 1,235.
2.2.2 Parcel B Development Project
The specific Parcel B development project would be located on the approximately 4.3-acre Parcel B, as shown in Figure 2.2-8. Parcel B is currently developed with surface parking and a one-story temporary education building in the southeast corner of the parcel.
The proposed development would demolish the existing building and surface parking on-site and construct a seven-story (up to 73.5 feet to top of parapet and 85 feet to top of elevator shaft, see Figure 2.2-9), mixed-use building with 201 residential units and approximately 8,000 square feet of retail space. The building would include two levels of parking (one level of below grade parking).
The lower level of the parking garage would provide 212 parking spaces serving the residential units.
An additional 133 parking spaces would be provided on the ground-floor, with 43 reserved for retail customers and leasing and the remainder reserved for residential parking.
2.2.2.1 Site Access and Circulation
Vehicular access to the Parcel B site would be provided via a new driveway and the existing entry drive on Serramonte Boulevard (see Figure 2.2-8). The new driveway would be located east of the existing entry drive and provide direct access to the lower parking level. An entry road would run north-south between Parcels A and B from the existing driveway along Serramonte Boulevard. An entrance to the proposed ground-floor parking (i.e. the upper level of the parking garage) would be located along this new road. A new road serving Parcels A and B would run west-east along the
Serramonte Del Rey Campus Redevelopment 11 Draft EIR
City of Daly City June 2023
southern boundaries of Parcels A and B. A new multi-use pathway would be constructed around the perimeter of the proposed mixed-use building and Parcel B.
In addition to the proposed Parcel B development project’s on-site transportation improvements (i.e., new roads, bike paths, and pedestrian paths), the City of Daly City and applicant are in discussions regarding potential additional transportation improvements that may be included in the project or possibly required as conditions of approval. Potential off-site improvements that the project may be required to construct include the following:
• Bicycle and pedestrian improvements on Campus Drive
• Serramonte Boulevard bicycle and pedestrian improvements • Serramonte Boulevard/Highway 1 Traffic Signal
• Clarinada Avenue/Highway 1 Traffic Signal
• Sidewalk on Callan Boulevard
• Bicycle and pedestrian improvements within the proposed Precise Plan • Improved access pathways to Gellert Park
• Serramonte Pavement Reconstruction
• Stormwater infrastructure
This EIR evaluates the potential implementation of the above improvements to ensure their environmental effects, if any, are disclosed and mitigated, where needed, to inform the City’s decision whether to require some or all of the improvements to be implemented by the project. Any improvements ultimately to be implemented would be attached to the project as conditions of approval.
The development project would signalize the Serramonte Boulevard and project driveway intersection and add pedestrian improvements (i.e., crosswalks, pedestrian signals) to serve the future residents on Parcel B, as well as residents on constructed Parcel A. Intersections at St. Francis Boulevard/Serramonte Boulevard, St. Francis Boulevard/Callan Boulevard, Hickey Boulevard/Callan Boulevard, and Hickey Boulevard/Campus Drive would also be improved with new bike and pedestrian connections. New bike lanes and sidewalks would also be provided on Serramonte Boulevard along the project frontage and throughout the project site. Potential off-site improvements that the project may be required to construct in connection with Parcels C-F will be evaluated when they are identified and at the time the City completes the subsequent or supplemental environmental review pursuant to Guidelines Section 15162.
Source: HKIT Architects, March 4, 2021.
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PARKING
NO
PARKING
NO
PARKING
NO
PARKING
HDEI
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ADULT EDUCATION
DISTRICT OFFICE
GROSS BUILDING AREA 39,000 SF
FOOTPRINT 21,300 SF
GROSS BUILDING AREA 30,000 SF
FOOTPRINT 20,000 SF
NEW IMPERVIOUS
AREA
110,000 SF
NEW BUILDING
FOOTPRINT AREA
41,300 SF
SITE TOTAL PARKING:
237 SPACES
26' WIDE FIRE
LANE
AFFECTED TREE
DRIP LINE
EXISTING TREE
DRIP LINE
758(
1257+
DEMONSTRATION
GARDEN
26’ WIDE FIRE
LANE
NEW IMPERVIOUS
AREA
110,000 SF
NEW BUILDING
FOOTPRINT AREA
41,300 SF
AFFECTED TREE
DRIP LINE
EXISTING TREE
DRIP LINE
JUHSD DISTRICT OFFICE AND ADULT EDUCATION SITE PLAN FIGURE 2.2-6
Source: Seidel Architects, June 14, 2019.
PARCEL A DEVELOPMENT PROJECT SITE PLAN FIGURE 2.2-7
PARCEL B CONCEPTUAL SITE PLAN FIGURE 2.2-8
Source: Seidel Architects, April 21, 2021.
SOUTH ELEVATION (NORTH DRIVE)
WEST ELEVATION (ENTRY DRIVE)
73’-6” TO TOP OF PARAPET
73’-6” TO TOP OF PARAPET
EL. 481.0’
AVG. GRADE ELEVATION
EL. 481.0’
AVG. GRADE ELEVATION
PARCEL B CONCEPTUAL BUILDING ELEVATIONS FIGURE 2.2-9
Serramonte Del Rey Campus Redevelopment 16 Draft EIR
City of Daly City June 2023
2.2.2.2 Open Space and Landscaping
The proposed Parcel B development project would include three components of open space to be used by the public: 1) approximately 22,300 square-foot public park that would include a large grass area and playground; 2) the first phase of the recreational trail (approximately 6,800 square feet) that would be located in the southeast corner of Parcel B; and 3) open space for public use at the retail plaza (approximately 7,000 square feet) facing the new entry road (see Figure 2.2-10). Open space serving the residents of the building would include both the ground floor terrace and the roof terrace, up to 20 private balconies for individual units, and an approximately 20,300 square-foot courtyard located on the roof of the parking deck of the mixed-use building which includes amenities such as a hot tub, fire pit, lounge furniture, and an outdoor kitchen. The open space reserved for residential use plus the retail open space for public use at Parcel B would exceed the City’s requirement for open space of 150 square feet per unit and is consistent with the proposed Precise Plan.
Parcel B currently contains limited landscaping consisting of grasses, shrubs, and trees within the existing surface parking lot and adjacent to the existing education building. Mature trees are located along the perimeter of Parcel B to the north and east. The proposed development would preserve the mature trees along the perimeter of Parcel B and replace the trees that are determined to be in poor condition by a certified arborist. The project proposes to plant 82 new trees throughout the project site.
2.2.2.3 Utility, Drainage, and Off-Site Improvements
The proposed Parcel B development project would connect to existing utilities within Serramonte Boulevard and the Precise Plan area itself. The Parcel B development project would connect to an existing 10-inch sanitary sewer line within Serramonte Boulevard and a 10-inch water line along the southern edge of Parcel B.
Stormwater would be treated on-site with area drains, drop inlets, manholes, bioretention areas, and below-grade pipes, before being discharged to a 24-inch storm drain line in Serramonte Boulevard.
The project would treat stormwater before entering the city’s storm drain system. In addition, an infiltration gallery is proposed to offset an increase in runoff generated from the proposed development.
KEY NAME AREA LEVEL
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OPEN SPACE SUMMARY
PARCEL B CONCEPTUAL OPEN SPACE PLAN FIGURE 2.2-10
Serramonte Del Rey Campus Redevelopment 18 Draft EIR
City of Daly City June 2023
2.2.2.4 Construction Schedule
Construction of the proposed Parcel B development project is expected to last approximately 24 months. As noted previously, full build out of the entire Precise Plan would take approximately eight-12 years, but could take up to 15 years. The proposed Parcel B development project would result in a net export of approximately 33,220 cubic yards (cy) of soil; however, the development project is proposing to store that soil on-site for use during development of the rest of the Precise Plan (i.e., Parcels C through F).
2.3 PROJECT OBJECTIVES
• Advance an innovative land use master plan to attract investment, stabilize District finances, increase funding for student education and attract and retain highly qualified teachers and staff.
• Permit development consistent with the City’s General Plan that enables redevelopment of underutilized properties with higher-density, transit supportive development that facilitates bicycle and pedestrian access along an established, highly utilized transit corridor, as outlined in the 2020 Walk Bike Daly City Master Plan.
• Create a pedestrian scale neighborhood with an attractive public realm of park and outdoor spaces, inviting to the surrounding community and people of all ages. • Maximize the number of new high-quality market-rate and affordable housing units as a well-designed, economically feasible, urban residential neighborhood with sufficient density to create a safe, active neighborhood, with development phasing subject to market conditions that provides flexibility with the sequence of construction of buildings, open space, streets, and infrastructure.
• Create opportunities to connect people with nature through open space design, a new recreational trail and immediate proximity to wooded hillside areas. • Encourage alternative transportation with safe on- and off-street bike routes and pedestrianoriented urban design that encourages bicycle, pedestrian, and transit access to, from and through the site.
• Design traffic-calmed residential streets for low volume, slow vehicle access between the intersection of Highway 1 and Serramonte Boulevard and the existing Campus Drive south of the Plan Area.
2.4 USES OF THE EIR
This EIR provides decision makers in the City of Daly City, CalTrans (as a responsible agency) and the general public with environmental information to use in considering the proposed project. It is intended that this EIR be used for the discretionary approvals necessary to implement the project, as proposed. These discretionary actions may include, but are not limited to, the following:
City Actions
Precise Plan
• General Plan Amendment
• Planned Development Rezoning and Permit
Serramonte Del Rey Campus Redevelopment 19 Draft EIR
City of Daly City June 2023
• Major Subdivision
• Design Review for future development projects
Parcel B Development Project
• Design Review Permit
Ministerial permits would subsequently be obtained from the City, which could include demolition permits, grading permits, and building permits, in order to complete the projects and construct necessary infrastructure improvements, including any off-site improvements.
Caltrans Actions
• Encroachment Permit
Serramonte Del Rey Campus Redevelopment 20 Draft EIR
City of Daly City June 2023
SECTION 3.0 ENVIRONMENTAL SETTING, IMPACTS, AND
MITIGATION
This section presents the discussion of impacts related to the following environmental subjects in their respective subsections:
3.1 Aesthetics
3.2 Agriculture and Forestry Resources
3.3 Air Quality
3.4 Biological Resources
3.5 Cultural Resources
3.6 Energy
3.7 Geology and Soils
3.8 Greenhouse Gas Emissions
3.9 Hazards and Hazardous Materials
3.10 Hydrology and Water Quality
3.11 Land Use and Planning
3.12 Mineral Resources
3.13 Noise
3.14 Population and Housing
3.15 Public Services
3.16 Recreation
3.17 Transportation
3.18 Tribal Cultural Resources
3.19 Utilities and Service Systems
3.20 Wildfire
The discussion for each environmental subject includes the following subsections:
Environmental Setting – This subsection 1) provides a brief overview of relevant plans, policies, and regulations that compose the regulatory framework for the project and 2) describes the existing, physical environmental conditions at the project site and in the surrounding area, as relevant.
Impact Discussion – This subsection includes the recommended checklist questions from Appendix G of the CEQA Guidelines to assess impacts.
• Project Impacts – This subsection discusses the project’s impact on the environmental subject as related to the checklist questions. For significant impacts, feasible mitigation measures are identified. “Mitigation measures” are measures that will minimize, avoid, or eliminate a significant impact (CEQA Guidelines Section 15370). Each impact is numbered to correspond to the checklist question being answered. For example, Impact BIO-1 answers the first checklist question in the Biological Resources section. Mitigation measures are also numbered to correspond to the impact they address. For example, MM BIO-1.3 refers to the third mitigation measure for the first impact in the Biological Resources section. • Cumulative Impacts – This subsection discusses the project’s cumulative impact on the environmental subject. Cumulative impacts, as defined by CEQA, refer to two or more individual effects, which when combined, compound or increase other environmental impacts. Cumulative impacts may result from individually minor, but collectively significant effects taking place over a period of time. CEQA Guideline Section 15130 states that an EIR should discuss cumulative impacts “when the project’s incremental effect is cumulatively considerable.” The discussion does not need to be in as great detail as is necessary for project impacts, but is to be “guided by the standards of practicality and reasonableness.” The purpose of the cumulative analysis is to allow decision makers to better understand the
Serramonte Del Rey Campus Redevelopment 21 Draft EIR
City of Daly City June 2023
impacts that might result from approval of past, present, and reasonably foreseeable future projects, in conjunction with the proposed project addressed in this EIR.
The CEQA Guidelines advise that a discussion of cumulative impacts should reflect both their severity and the likelihood of their occurrence (CEQA Guidelines Section 15130(b)). To accomplish these two objectives, the analysis should include either a list of past, present, and probable future projects or a summary of projections from an adopted general plan or similar document (CEQA Guidelines Section 15130(b)(1)). This EIR uses the list of projects approach.
The analysis must determine whether the project’s contribution to any cumulatively significant impact is cumulatively considerable, as defined by CEQA Guideline Section 15065(a)(3). The cumulative impacts discussion for each environmental issue accordingly addresses the following issues: 1) would the effects of all of past, present, and probable future (pending) development result in a significant cumulative impact on the resource in question; and, if that cumulative impact is likely to be significant, 2) would the contribution from the proposed project to that significant cumulative impact be cumulatively considerable?
Table 3.0-1 identifies the approved (but not yet constructed or occupied) and pending projects in the project vicinity that are evaluated in the cumulative analysis.
Table 3.0-1: Cumulative Projects List
Name Address Description Status
Serramonte Shopping
Center Expansion –
Northwest Quadrant
3 Serramonte
Center, Daly City
70,000 sq. ft. Cinema, 75,000 sq. ft.
Hotel, 28,000 sq. ft. Retail, 12,000
sq. ft. Restaurants
Approved
Serramonte Shopping
Center Expansion –
Northeast Quadrant
3 Serramonte
Center, Daly City
Two drive-through restaurants (5,100
sq. ft. and 2,100 sq. ft.)
Under
Construction
Seton Medical Center
Expansion
1900 Sullivan
Avenue, Daly
City
Four hospital buildings totaling
433,385 sq. ft. of new hospital space.
Overall net increase of 200,385 sq.
ft. of building space
Under
Construction
Serramonte
Condominiums
525-595
Serramonte
Boulevard, Daly
City
323 total units - 17-story 133-unit
170,164 GSF condo building and
two 13-story 95-unit 181,806 GSF
condo buildings
Approved
Serramonte Hotel
525-595
Serramonte
Boulevard, Daly
City
12-story, 176-room 153,886 GSF
hotel Approved
Serramonte Del Rey Campus Redevelopment 22 Draft EIR
City of Daly City June 2023
For each resource area, cumulative impacts may occur over different geographic areas. For example, the project effects on air quality would combine with the effects of projects in the entire air basin, whereas noise impacts would primarily be localized to the surrounding area.
The geographic area that could be affected by the proposed project varies depending upon the type of environmental issue being considered. Section 15130(b)(3) of the CEQA Guidelines states that lead agencies should define the geographic scope of the area affected by the cumulative effect. Table 3.0-2 provides a summary of the different geographic areas used to evaluate cumulative impacts.
Table 3.0-2: Geographic Considerations in Cumulative Analysis Resource Area Geographic Area
Aesthetics Project site and adjacent parcels
Agriculture and Forestry Resources Countywide
Air Quality San Francisco Bay Area Air Basin
Biological Resources Project site and adjacent parcels
Cultural Resources Project site and adjacent parcels
Energy Energy provider’s territory
Geology and Soils Project site and adjacent parcels
GHGs Planet-wide
Hazards and Hazardous Materials Project site and adjacent parcels Hydrology and Water Quality Colma Creek watershed
Land Use and Planning/Population and Housing Citywide
Minerals Identified mineral recovery or resource area
Noise and Vibration Project site and adjacent parcels
Public Services and Recreation Citywide
Transportation/Traffic Citywide
Tribal Cultural Resources Project site and adjacent parcels Utilities and Service Systems Citywide
Wildfire Within or adjacent to the wildfire hazard zone
Serramonte Del Rey Campus Redevelopment 23 Draft EIR
City of Daly City June 2023
3.1 AESTHETICS
3.1.1 Environmental Setting
3.1.1.1 Regulatory Framework
State
Senate Bill 743
Senate Bill (SB) 743 was adopted in 2013 and, among other changes, SB 743 specifies that aesthetic impacts of qualifying transit oriented developments are not considered significant impacts on the environment if:
1. The project is a residential, mixed-use residential, or employment center project, and
2. The project is located on an infill site within a transit priority area.4 The exemption for aesthetic impacts does not include impacts to historic or cultural resources, however. In addition, local governments retain their ability to regulate a project’s transportation, aesthetics, and parking impacts outside of the CEQA process.
Scenic Highways Program
The California Scenic Highway Program is managed by the California Department of Transportation (Caltrans). The program is intended to protect and enhance the natural scenic beauty of California highways and adjacent corridors through special conservation treatment. State laws governing the Scenic Highway Program are found in the Streets and Highway Code, Sections 260 through 263.
There are three eligible State scenic highways within the City of Daly City, although none are officially designated; Skyline Boulevard (State Route (SR) 35), Cabrillo Highway (SR 1), and Junipero Serra (I-280).
Local
Daly City 2030 General Plan
The City of Daly City General Plan includes a Visual Quality section under the Resources Management Element. General Plan policies and tasks relevant to the project with regards to aesthetics are listed below.
4 An “infill site” is defined as “a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right-ofway from, parcels that are developed with qualified urban uses.” A “transit priority area” is defined as “an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations.” A “major transit stop” means “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” Source: Office of Planning and Research. “Changes to CEQA for Transit Oriented Development – FAQ.” October 14, 2014. Accessed: August 24, 2021. http://www.opr.ca.gov/ceqa/updates/sb-743/transit-oriented.html.
Serramonte Del Rey Campus Redevelopment 24 Draft EIR
City of Daly City June 2023
Policy/Task Description
Task CE-20.7 As a part of all new development, require, where appropriate, the provision of pedestrian-oriented signs, pedestrian-scaled lighting, benches, and other street furniture so as to make non-motorized forms of travel comfortable and attractive alternatives to the automobile. Where necessary in new development, the City may require additional sidewalk and/or right-of-way width to accommodate these amenities.
Policy LU-16 Regulate the size, quantity, and location of signs to maintain and enhance the visual appearance of Daly City.
Policy RME-20 Recognize the physical differences between different parts of the City and regulate land uses within these areas accordingly.
Task RME-20.4 Incorporate design features in new development that reflect the character of the neighborhood, to ensure that new construction is compatible with existing development.
Policy LU-17 Ensure that private development is responsible for providing any on-or off-site improvements related to and/or mitigating the impacts it causes.
3.1.1.2 Existing Conditions
Project Site
The 22-acre project site is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard (see Figure 2.2-3). The northwest corner of the project site (Parcel A) is developed with the Jefferson Union High School District (JUHSD) Faculty and Staff Housing project. The northeast corner of the project site (Parcel B) is currently developed with a surface parking lot and portable building units (see Photo 1). The southwest corner of the project site is developed with the JUHSD demonstration garden (see Photo 2). The remainder of the project site it developed with surface parking lots and a one- to two-story concrete building that serves as the existing JUHSD district office and adult education buildings (see Photo 3). The project site meets the definition of an infill site per SB 743.
Surrounding Visual Character
The project site is surrounded by residential development to the north, northeast, south, and west.
The residences to the north and northeast are two- to three-story apartment buildings made of stucco and wood construction. The residences to the south (Serramonte Ridge Apartment Homes) are threeto four-story apartment buildings also made of stucco and wood construction. The residences to the west are two-story, single-family homes made of wood construction (see Photo 4).
Southeast of the project site is the Summit Shasta High School, which is developed with one- to twostory concrete education buildings (see Photo 4). East of the project site across Callan Boulevard is a Chinese cemetery consisting of mostly open space and gravestones.
Photo 1: View from Serramonte Boulevard looking south.
Photo 2: View of Demonstration Garden looking northwest.
PHOTOS 1 & 2
Photo 3: View of administration building looking north.
Photo 4: View looking south of project site down Campus Drive.
PHOTOS 3 & 4
Serramonte Del Rey Campus Redevelopment 27 Draft EIR
City of Daly City June 2023
Scenic Vistas and Resources
San Bruno Mountain reaches approximately 1,000 feet in elevation and is visible from various locations throughout the City, including the project site, which is about a 2.6 miles southwest of San Bruno Mountain. Views of the coastline are not visible from the project site. The project site is comprised of surface parking lots and commercial buildings and no scenic resources, such as rock outcroppings or historic buildings (refer to Section 4.5 Cultural Resources), are present on the site or in the project area, other than numerous mature trees. The project site is not visible from any state or County designated scenic highways or roadways.
Locations within a Transit Priority Area
The project site is located within a transit priority area as defined in SB 743. The Serramonte Shopping Center bus stop, and the multiple bus lines serving that location, qualifies as a major transit stop and the project site is within one-half mile (see Figure 3.1-1).
3.1.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on aesthetics, except as provided in Public Resources Code Section 21099, would the project:
1) Have a substantial adverse effect on a scenic vista? 2) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
3) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings?5
If the project is in an urbanized area, would the
project conflict with applicable zoning and other regulations governing scenic quality? 4) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
3.1.2.1 Project Impacts
Impact AES-1: The project would not have a substantial adverse effect on a scenic vista. (Less than Significant Impact)
Implementation of the project would result in changes to the built environment; however, the proposed project would consist of mixed-use residential land uses and is located on an infill site within a transit priority area. Pursuant to SB 743 (Public Resources Code section 21099[d][1]) “aesthetic and parking impacts of a residential, mixed-use residential, or employment center on an infill site within a transit priority area shall not be considered significant impacts on the environment;” therefore, the aesthetics impacts of the project are not considered significant. (Less than Significant Impact)
5 Public views are those that are experienced from publicly accessible vantage points.
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Serramonte Del Rey Campus Redevelopment 29 Draft EIR
City of Daly City June 2023
3.1.2.2 Cumulative Impacts
Impact AES-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant aesthetics impact. (Less than Significant Cumulative Impact)
Precise Plan and Parcel B Development Project
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Serramonte Del Rey Campus Redevelopment 30 Draft EIR
City of Daly City June 2023
3.2 AGRICULTURE AND FORESTRY RESOURCES
3.2.1 Environmental Setting
3.2.1.1 Regulatory Framework
State
Farmland Mapping and Monitoring Program
The California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP) assesses the location, quality, and quantity of agricultural land and conversion of these lands over time. Agricultural land is rated according to soil quality and irrigation status. The best quality land is identified as Prime Farmland. In CEQA analyses, the FMMP classifications and published county maps are used, in part, to identify whether agricultural resources that could be affected are present on-site or in the project area.6
California Land Conservation Act
The California Land Conservation Act (Williamson Act) enables local governments to enter into contracts with private landowners to restrict parcels of land to agricultural or related open space uses.
In return, landowners receive lower property tax assessments. In CEQA analyses, identification of properties that are under a Williamson Act contract is used to also identify sites that may contain agricultural resources or are zoned for agricultural uses.7 Fire and Resource Assessment Program
The California Department of Forestry and Fire Protection (CAL FIRE) identifies forest land, timberland, and lands zoned for timberland production that can (or do) support forestry resources.8 Programs such as CAL FIRE’s Fire and Resource Assessment Program and are used to identify whether forest land, timberland, or timberland production areas that could be affected are located on or adjacent to a project site.9
3.2.1.2 Existing Conditions
The approximately 22-acre project site is not used for agricultural or timberland purposes. A demonstration garden is located in the southwest corner of the project site (see Photo 2); however, this garden is not considered an agricultural resource under CEQA as it does not meet the definition 6 California Department of Conservation. “Farmland Mapping and Monitoring Program.” Accessed December 6, 2021. http://www.conservation.ca.gov/dlrp/fmmp/Pages/Index.aspx. 7 California Department of Conservation. “Williamson Act.” http://www.conservation.ca.gov/dlrp/lca. 8 Forest Land is land that can support 10 percent native tree cover and allows for management of forest resources (California Public Resources Code Section 12220(g)); Timberland is land not owned by the federal government or designated as experimental forest land that is available for, and capable of, growing trees to produce lumber and other products, including Christmas trees (California Public Resources Code Section 4526); and Timberland Production is land used for growing and harvesting timber and compatible uses (Government Code Section 51104(g)).
9 California Department of Forestry and Fire Protection. “Fire and Resource Assessment Program.” Accessed December 6, 2021. http://frap.fire.ca.gov/.
Serramonte Del Rey Campus Redevelopment 31 Draft EIR
City of Daly City June 2023
of agricultural land.10 Surrounding land uses include residences to the north, west, and south, a shopping mall to the northeast, and a cemetery and park to the east. The San Mateo County Important Farmlands 2018 Map designates the project site as “Urban and Built-Up Land”, defined as land with at least six structures per 10 acres. Common examples of “Urban and Built-Up Land” are residential, institutional, industrial, commercial, landfill, golf course, airports, and other utility uses. The site is not under a Williamson Act contract and there are no existing agricultural or forestry resources on or in the vicinity of the site.
The project site is zoned as a Planned Development. A Planned Development district allows various types of development such as neighborhood shopping centers, professional and administrative areas, commercial service centers, industrial parks, single-family, multi-family residential, or a combination of any of the above-mentioned uses.
3.2.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on agriculture and forestry resources, would the project:
1) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? 2) Conflict with existing zoning for agricultural use, or a Williamson Act contract? 3) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
4) Result in a loss of forest land or conversion of forest land to non-forest use? 5) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
3.2.2.1 Project Impacts
Impact AG-1: The project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. (No Impact)
As discussed under Section 3.2.1.2, the project site is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Therefore, the project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use. (No Impact)
10 Agricultural land is means prime farmland, farmland of statewide importance, or unique farmland, as defined by the United States Department of Agriculture land inventory and monitoring criteria, as modified for California (California Public Resources Code Section 21060.1).
Serramonte Del Rey Campus Redevelopment 32 Draft EIR
City of Daly City June 2023
Impact AG-2: The project would not conflict with existing zoning for agricultural use, or a Williamson Act contract. (No Impact)
As discussed under Section 3.2.1.2, the project site is neither zoned for agricultural use or under a Williamson Act contract; therefore, the proposed project would not conflict with zoning for agricultural uses or a Williamson Act contract. (No Impact) Impact AG-3: The project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. (No Impact)
As discussed under Section 3.2.1.2, the project site is not zoned as timberland or forest land. For this reason, the project would have not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. (No Impact) Impact AG-4: The project would not result in a loss of forest land or conversion of forest land to non-forest use. (No Impact)
See response to Impact AG-3. (No Impact)
Impact AG-5: The project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use. (No Impact)
See responses to Impact AG-1 through Impact AG-4. In addition, as discussed above in Section
3.2.1.2 Existing Conditions, the demonstration garden on the project site is not considered an agricultural resource and its removal would not result in a significant impact. The school district, however, is providing a substitute demonstration garden at their new district offices next to Westmoor High School (see Section 2.2.1.1 for more details). (No Impact)
3.2.2.2 Cumulative Impacts
Impact AG-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant agricultural and forestry resources impact. (No Cumulative Impact)
As discussed above, the implementation of the proposed project would not impact agricultural, forestry, and/or timberland; therefore, implementation of the project would not contribute to a cumulative impact to those resources. (No Cumulative Impact)
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3.3 AIR QUALITY
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2022, is attached to this EIR as Appendix C.
3.3.1 Environmental Setting
3.3.1.1 Background Information
Criteria Pollutants
Air quality in the Bay Area is assessed related to six common air pollutants (referred to as criteria pollutants), including ground-level ozone (O3), nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), sulfur oxides (SOx), and lead.11 Criteria pollutants are regulated because they result in health effects. An overview of the sources of criteria pollutants and their associated health effects are summarized in Table 3.3-1. The most commonly regulated criteria pollutants in the Bay Area are discussed further below.
Table 3.3-1: Health Effects of Air Pollutants
Pollutants Sources Primary Effects
Ozone (O3) Atmospheric reaction of organic gases
with nitrogen oxides in sunlight
• Aggravation of respiratory and
cardiovascular diseases
• Irritation of eyes
• Cardiopulmonary function impairment
Nitrogen
Dioxide (NO2)
Motor vehicle exhaust, high
temperature stationary combustion,
atmospheric reactions
• Aggravation of respiratory illness
• Reduced visibility
Fine
Particulate
Matter (PM2.5)
and Coarse
Particulate
Matter (PM10)
Stationary combustion of solid fuels,
construction activities, industrial
processes, atmospheric chemical
reactions
• Reduced lung function, especially in
children
• Aggravation of respiratory and
cardiorespiratory diseases
• Increased cough and chest discomfort
• Reduced visibility
Toxic Air
Contaminants
(TACs)
Cars and trucks, especially dieselfueled; industrial sources, such as chrome platers; dry cleaners and service
stations; building materials and
products
• Cancer
• Chronic eye, lung, or skin irritation
• Neurological and reproductive
disorders
High O3 levels are caused by the cumulative emissions of reactive organic gases (ROG) and NOX.
These precursor pollutants react under certain meteorological conditions to form high O3 levels.
Controlling the emissions of these precursor pollutants is the focus of the Bay Area’s attempts to 11 The area has attained both state and federal ambient air quality standards for CO. The project does not include substantial new emissions of sulfur dioxide or lead. These criteria pollutants are not discussed further.
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reduce O3 levels. The highest O3 levels in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources.
PM is a problematic air pollutant of the Bay Area. PM is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM10) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM2.5). Elevated concentrations of PM10 and PM2.5 are the result of both region-wide emissions and localized emissions.
Toxic Air Contaminants
TACs are a broad class of compounds known to have health effects. They include but are not limited to criteria pollutants. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, diesel fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter [DPM] near a freeway).
Diesel exhaust is the predominant TAC in urban air and is estimated to represent about three-quarters of the cancer risk from TACs. Diesel exhaust is a complex mixture of gases, vapors, and fine particles. Medium- and heavy-duty diesel trucks represent the bulk of DPM emissions from California highways. The majority of DPM is small enough to be inhaled into the lungs. Most inhaled particles are subsequently exhaled, but some deposit on the lung surface or are deposited in the deepest regions of the lungs (most susceptible to injury).12 Chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the California Air Resources Board (CARB).
Sensitive Receptors
Some groups of people are more affected by air pollution than others. CARB has identified the following persons who are most likely to be affected by air pollution: children under 16, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, and elementary schools.
3.3.1.2 Regulatory Framework
Federal and State
Clean Air Act
At the federal level, the United States Environmental Protection Agency (EPA) is responsible for overseeing implementation of the Clean Air Act and its subsequent amendments. The federal Clean Air Act requires the EPA to set national ambient air quality standards for the six common criteria pollutants (discussed previously), including PM, O3, CO, SOx, NOx, and lead. 12 California Air Resources Board. “Overview: Diesel Exhaust and Health.” Accessed December 6, 2021. https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health.
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CARB is the state agency that regulates mobile sources throughout the state and oversees implementation of the state air quality laws and regulations, including the California Clean Air Act.
The EPA and the CARB have adopted ambient air quality standards establishing permissible levels of these pollutants to protect public health and the climate. Violations of ambient air quality standards are based on air pollutant monitoring data and are determined for each air pollutant.
Attainment status for a pollutant means that a given air district meets the standard set by the EPA and/or CARB.
Risk Reduction Plan
To address the issue of diesel emissions in the state, CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. In addition to requiring more stringent emission standards for new on-road and off-road mobile sources and stationary diesel-fueled engines to reduce particulate matter emissions by 90 percent, the plan involves application of emission control strategies to existing diesel vehicles and equipment to reduce DPM (in additional to other pollutants). Implementation of this plan, in conjunction with stringent federal and CARB-adopted emission limits for diesel fueled vehicles and equipment (including off-road equipment), will significantly reduce emissions of DPM and NOX.
Regional
2017 Clean Air Plan
The Bay Area Air Quality Management District (BAAQMD) is the agency primarily responsible for assuring that the federal and state ambient air quality standards are maintained in the San Francisco Bay Area. Regional air quality management districts, such as BAAQMD, must prepare air quality plans specifying how state and federal air quality standards will be met. BAAQMD’s most recently adopted plan is the Bay Area 2017 Clean Air Plan (2017 CAP). The 2017 CAP focuses on two related BAAQMD goals: protecting public health and protecting the climate. To protect public health, the 2017 CAP describes how BAAQMD will continue its progress toward attaining state and federal air quality standards and eliminating health risk disparities from exposure to air pollution among Bay Area communities. To protect the climate, the 2017 CAP includes control measures designed to reduce emissions of methane and other super-greenhouse gases (GHGs) that are potent climate pollutants in the near-term, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.13
CEQA Air Quality Guidelines
The BAAQMD CEQA Air Quality Guidelines are intended to serve as a guide for those who prepare or evaluate air quality impact analyses for projects and plans in the San Francisco Bay Area.
Jurisdictions in the San Francisco Bay Area Air Basin utilize the thresholds and methodology for assessing air quality impacts developed by BAAQMD within their CEQA Air Quality Guidelines.
The guidelines include information on legal requirements, BAAQMD rules, methods of analyzing impacts, and recommended mitigation measures.
13 BAAQMD. Final 2017 Clean Air Plan. April 19, 2017. http://www.baaqmd.gov/plans-and-climate/air-qualityplans/current-plans.
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Local
Daly City 2030 General Plan
The Daly City 2030 General Plan (General Plan) includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to air quality and are applicable to the proposed project.
Policy/Task Description
Policy RME-5 Assess projected air emissions from new development and associated construction and demolition activities in conformance with the BAAQMD CEQA Guidelines, and relative to state and federal standards.
Task RME-5.1 Amend the Planning Division’s development review procedures to include a formal step that would help identify how a development project can incorporate design or functional changes that will minimize air quality impacts.
Task RME-5.3 Consider cumulative air quality impacts consistent with the region's Clean Air Plan and State law.
Task RME-5.4 Require the preparation of a Transportation Systems Management plan for new development that has been determined to contribute to a reduction in location air quality.
Task RME-5.5 Consult with BAAQMD to identify stationary and mobile TAC sources and determine the need for and requirements of a health risk assessment for proposed developments.
Policy RME-6 Minimize exposure of residents to objectionable smoke and odors by proactively regulating potential sources.
Task RME-6.2 Require new residential development projects and projects categorized as sensitive receptors to be located an adequate distance from facilities that are existing and potential sources of odor. An adequate separate distance will be determined based upon the type, size and operations of the facility.
3.3.1.3 Existing Conditions
The project is located in San Mateo County, which is in the San Francisco Bay Area Air Basin. The project area’s proximity to both the Pacific Ocean and the San Francisco Bay has a moderating influence on the climate. The Bay Area is considered a nonattainment area for ground-level O3 and PM2.5 under both the federal Clean Air Act and state Clean Air Act. The area is also considered in nonattainment for PM10 under the state act, but not the federal act. The area has attained both state and federal ambient air quality standards for CO. As part of an effort to attain and maintain ambient air quality standards for O3 and PM10, BAAQMD has established thresholds of significance for these air pollutants and their precursors. These thresholds are for O3 precursor pollutants (ROG and NOX), PM10, and PM2.5, and apply to both construction period and operational period impacts.
The northwest corner of the project site (Parcel A) has been developed with the Jefferson Union High School District (JUHSD) Faculty and Staff Housing project. The northeast corner of the project site (Parcel B) is currently developed with a surface parking lot and portable building units. The southwest corner of the project site is developed with the JUHSD demonstration garden. The remainder of the project site it developed with surface parking lots and a one- to two-story concrete
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building that serves as the existing JUHSD district office and adult education buildings. The nearest sensitive receptors to the project site are single- and multi-family residences adjacent the west and south, across Serramonte Boulevard to the north, and the Summit Shasta High School adjacent to the south.
3.3.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on air quality, would the project:
1) Conflict with or obstruct implementation of the applicable air quality plan? 2) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
3) Expose sensitive receptors to substantial pollutant concentrations? 4) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
3.3.2.1 Thresholds of Significance
Impacts from the Project
As discussed in CEQA Guidelines Section 15064(b), the determination of whether a project may have a significant effect on the environment calls for judgment on the part of the lead agency and must be based, to the extent possible, on scientific and factual data. The City of Daly City has considered the air quality thresholds updated by BAAQMD in May 2017 and regards these thresholds to be based on the best information available for the San Francisco Bay Area Air Basin and conservative in terms of the assessment of health effects associated with TACs and PM2.5. The BAAQMD CEQA Air Quality thresholds used in this analysis are identified in Table 3.3-2 below.
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Table 3.3-2: BAAQMD Air Quality Significance Thresholds Pollutant
Construction
Thresholds Operation Thresholds
Average Daily
Emissions
(pounds/day)
Average Daily
Emissions
(pounds/day)
Annual Average
Emissions (tons/year)
Criteria Air Pollutants
ROG, NOx 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
CO Not Applicable 9.0 ppm (eight-hour) or 20.0 ppm (one-hour) Fugitive Dust
Dust Control
Measures/Best
Management Practices
Not Applicable
Health Risks and Hazards for New Sources (within a 1,000-foot Zone of Influence) Health Hazard Single Source Combined Cumulative Sources Excess Cancer Risk 10 per one million 100 per one million Hazard Index 1.0 10.0
Incremental Annual PM2.5 0.3 µg/m3 0.8 μg/m3 (average)
3.3.2.2 Project Impacts
Impact AIR-1: The project would not conflict with or obstruct implementation of the applicable air quality plan. (Less than Significant Impact) The proposed project will not conflict with the latest Clean Air planning efforts since; (1) the project’s operational emissions would be well below the BAAQMD thresholds of significance for air pollutants as discussed below in Impact AIR-2 and development of the project site would be considered urban infill. (Less than Significant Impact) Impact AIR-2: The project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. (Less than Significant Impact with Mitigation Incorporated)
The California Emissions Estimator Model (CalEEMod) Version 2020.4.0 was used to estimate emissions from construction and operation of the project. The project land use types and size, and anticipated construction schedule were input to CalEEMod. The model output from CalEEMod along with construction and operational inputs can be found in Appendix C.
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BAAQMD is the regional agency responsible for overseeing compliance with State and Federal laws, regulations, and programs within the San Francisco Bay Area Air Basin. As previously stated, BAAQMD’s most recently adopted plan is the 2017 CAP. The primary goals of the 2017 CAP are to attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions and protect the climate. The BAAQMD has also developed CEQA guidelines to assist lead agencies in evaluating the significance of air quality impacts. In formulating compliance strategies, BAAQMD relies on planned land uses established by local general plans. Land use planning affects vehicle travel, which in turn affects region-wide emissions of air pollutants and GHGs.
The 2017 CAP includes control measures that are intended to reduce air pollutant emissions in the Bay Area either directly or indirectly. Plans must show consistency with the control measures listed within the 2017 CAP. As shown in Table 3.3-3 below, the proposed project would generally be consistent with the 2017 CAP measures to reduce automobile trips, as well as energy and water use.
Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
Transportation Measures
TR2 - Trip Reduction Programs: Implement the regional
Commuter Benefits Program (Rule 14-1) that requires
employers with 50 or more Bay Area employees to provide commuter benefits. Encourage trip reduction policies and programs in local plans, e.g., general and specific plans while providing grants to support trip reduction efforts. Encourage local governments to require mitigation of vehicle travel as part of new development approval, to adopt transit benefits ordinances in order to reduce transit costs to employees, and to develop innovative ways to encourage rideshare, transit, cycling, and walking for work trips. Fund various employerbased trip reduction programs.
Consistent: The project is required to
implement a Transportation Demand
Management (TDM) program (see
mitigation measure MM TRN-2.1) to
reduce vehicle miles traveled by at
approximately three percent. The
program measures could include, but
are not limited to, carpool incentives,
carshare memberships, additional
last-mile services, and vanpools. The
project sites are also in proximity to
regional transit.
TR8 - Ridesharing, Last-Mile Connection: Promote
carpooling and vanpooling by providing funding to continue regional and local ridesharing programs, and support the expansion of carsharing programs. Provide incentive funding for pilot projects to evaluate the feasibility and costeffectiveness of innovative ridesharing and other last-mile solution trip reduction strategies. Encourage employers to promote ridesharing and carsharing to their employees.
TR9 - Bicycle and Pedestrian Access and Facilities:
Encourage planning for bicycle and pedestrian facilities in local plans, e.g., general and specific plans, fund bike lanes, routes, paths and bicycle parking facilities.
Consistent: As discussed in Section
3.17 Transportation, the existing
bicycle and pedestrian facilities
provide adequate access to the project
site. The project would construct
additional bicycle/pedestrian facilities
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Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
as part of the project and include
bicycle parking facilities on-site.
TR13 - Parking Policies: Encourage parking policies and programs in local plans, e.g., reduce minimum parking
requirements; limit the supply of off-street parking in transitoriented areas; unbundle the price of parking spaces; support implementation of demand-based pricing in high-traffic areas.
Consistent: The project proposes a
lower parking supply than required by
the City’s Municipal Code (see
Section 3.17.3). In addition, as
required by mitigation measure MM
TRN-2.1, the project shall implement
TDM measures to promote
alternatives to single-occupancy
vehicle trips.
Building Measures
BL1 - Green Buildings: Collaborate with partners such as KyotoUSA to identify energy-related improvements and
opportunities for onsite renewable energy systems in school districts; investigate funding strategies to implement upgrades.
Identify barriers to effective local implementation of the California Green Building Standards Code (CALGreen;
Title 24) statewide building energy code; develop solutions to improve implementation/enforcement. Work with ABAG’s
BayREN program to make additional funding available for energy-related projects in the buildings sector. Engage with additional partners to target reducing emissions from specific types of buildings.
Consistent: The project would be
constructed consistent with
CALGreen and Title 24 requirements.
BL2 - Decarbonize Buildings: Explore potential Air District rulemaking options regarding the sale of fossil fuel-based space and water heating systems for both residential and commercial use. Explore incentives for property owners to replace their furnace, water heater or natural-gas powered appliances with zero-carbon alternatives. Update Air District guidance documents to recommend that commercial and
multi-family developments install ground source heat pumps and solar hot water heaters.
Consistent: Electricity is provided to
the site by Peninsula Clean Energy
(PCE). PCE customers are
automatically enrolled in the
ECOplus plan, which generates its
electricity from 100 percent carbonfree sources, with at least 50 percent from renewable sources. Customers
have the option to enroll in the
ECO100 plan, which generates its
electricity from 100 percent carbonfree, renewable sources
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Table 3.3-3: Project Consistency with Applicable 2017 BAAQMD CAP Control Measures Control Measure Project Consistency with Measure
Intent
Waste Management Measures
WA4 - Recycling and Waste Reduction: Develop or identify and promote model ordinances on community-wide zero
waste goals and recycling of construction and demolition materials in commercial and public construction projects.
Consistent: The project shall recycle
and/or salvage for reuse a minimum
of 60 percent of nonhazardous
construction and demolition waste,
consistent with Chapter 15.64,
Recycling and Diversion of
Construction and Demolition Debris
of the City’s Municipal Code.
Water Measures
WR2 - Support Water Conservation: Develop a list of best practices that reduce water consumption and increase on-site water recycling in new and existing buildings; incorporate into local planning guidance.
Consistent: The project would be
constructed consistent with
CALGreen and Title 24 requirements,
which require incorporation of water
conservation measures.
As described above in Table 3.3-3, the project would be consistent with the applicable 2017 CAP control measures by reducing project generated trips, including bicycle parking facilities on-site, complying with CALGreen and Title 24, using 100 percent carbon free electricity, and recycling. The project, therefore, would not conflict with or obstruct the implementation of the 2017 CAP.
At the project-level, there are no consistency measures or thresholds. The proposed project would not conflict with the latest Clean Air planning efforts because the project would have operational emissions below the BAAQMD thresholds and would be an urban infill development.
Construction Period Emissions
CalEEMod provided annual emissions for construction including both on-site and off-site construction activities for full buildout of the proposed Precise Plan. Construction emissions were based on land use, construction start dates, and soil hauling information provided by the applicant to then generate CalEEMod default equipment and schedule information for a project of this type and size per phase. On-site activities are primarily made up of construction equipment emissions, while off-site activity includes worker, hauling, and vendor traffic. As noted previously in the Project Description, full build out of the entire Precise Plan would take approximately eight-12 years, but could take up to 15 years. However, for purposes of the air quality analysis, the project construction schedule and equipment usage assume the project would be constructed over a period of six years (1,110 workdays). In disclosing construction air quality impacts, it is more conservative to evaluate a shorter construction period, since compressing the total construction activity into a shorter period of time results in higher daily emissions than if the project were built over a longer period of time, so assuming six years rather than eight to 12 years would overstate the construction emissions. The project’s average daily emissions were computed by dividing the total construction emissions by the number of construction days.
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Table 3.3-4 shows average daily construction emissions of ROG, NOX, PM10 exhaust, and PM2.5 exhaust during construction of the project.
Table 3.3-4: Average Daily Construction Period Emissions - Unmitigated Year ROG (lbs./day) NOX (lbs./day) PM10 (lbs./day) PM2.5 (lbs./day) 2023 (130 workdays) 2.03 18.60 0.92 0.75
2024 (209 workdays) 18.62 15.99 0.79 0.64
2025-2026 (304
workdays) 2.03 16.63 0.80 0.63
2027 (126 workdays) 48.07 12.66 0.65 0.49
2028 (219 workdays) 2.17 16.46 0.87 0.63
2029 (122 workdays) 81.00 13.27 0.74 0.52
BAAQMD
Thresholds (lbs./day) 54 54 82 54
Exceed Threshold? Yes (2029) No No No
As shown in Table 3.3-4 above, the project would generate significant levels of average daily ROG (ROG is primarily emitted from architectural coatings) in 2029 during construction. Additionally, construction activities, particularly during site preparation and grading, would temporarily generate fugitive dust in the form of PM10 and PM2.5. Sources of fugitive dust would include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site would deposit mud on local streets, which could be an additional source of airborne dust after it dries. The BAAQMD CEQA Air Quality Guidelines consider these impacts to be less than significant if best management practices (BMPs) are implemented to reduce these emissions.
Mitigation Measures: The project will be required to implement the following mitigation measures to reduce reactive organic gas (ROG) and fugitive dust generation to a less than significant level:
MM AIR-2.1: BAAQMD Best Management Practices: The project shall implement the Bay Area Air Quality Management District’s (BAAQMD’s) recommended best management practices (BMPs) and additional measures to reduce construction equipment exhaust emissions. These measures shall include the following:
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered three times a day and at a frequency adequate to maintain minimum soil moisture of 12 percent.
Moisture content shall be verified by lab samples or moisture probe. • All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
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• All visible mud or dirt track-out onto adjacent public roads shall be removed using a wet power vacuum street sweeper at least once per day. The use of dry power sweeping shall be prohibited.
• All vehicle speeds on unpaved roads shall be limited to 15 mph. • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
• All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
• Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations. • All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph and visible dust extends beyond site boundaries.
• Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of construction adjacent to sensitive receptors. Wind breaks should have at maximum 50 percent air porosity.
• Vegetative ground cover (e.g., fast-germinating native grass seed) shall be planted in disturbed areas as soon as possible and watered appropriately until vegetation is established.
• The simultaneous occurrence of excavation, grading, and ground-disturbing construction activities on the same area at any one time shall be limited.
Activities shall be phased to reduce the amount of disturbed surfaces at any one time.
• Avoid tracking of visible soil material on to public roadways by employing the following measures if necessary: (1) Site accesses to a distance of 100 feet from public paved roads shall be treated with a 6 to 12-inch compacted layer of wood chips, mulch, or gravel and (2) washing truck tires and construction equipment of prior to leaving the site.
• Sandbags or other erosion control measures shall be installed to prevent silt runoff to public roadways from sites with a slope greater than one percent.
MM AIR-2.2: Selection of Construction Equipment: All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. Environmental Protection Agency (EPA) Tier 4 emission standards PM (PM10 and PM2.5), if feasible, otherwise,
• Use equipment that meets U.S. EPA emission standards for Tier 2 or 3 engines and include particulate matter emissions control equivalent to
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California Air Resources Board (CARB) Level 3 verifiable diesel emission control devices that altogether achieve a 50-percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination).
• Use of electrical or non-diesel fueled equipment.
Alternatively, the applicant may develop another construction operations plan demonstrating that the construction equipment used on-site would achieve a reduction in construction diesel particulate matter emissions by 70 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Implementation of Tier 4 or alternatively fueled equipment, • Installation of electric power lines during early construction phases to avoid use of diesel generators and compressors,
• Use of electrically-powered equipment,
• Forklifts and aerial lifts used for exterior and interior building construction shall be electric or propane/natural gas powered,
• Change in construction build-out plans to lengthen phases, and • Implementation of different building techniques that result in less diesel equipment usage.
Such a construction operations plan would be subject to review by an air quality expert and approved by the City prior to construction.
MM AIR-2.3: Low Volatile Organic Compound (VOC) Coating: The project shall use low volatile organic compound or VOC (i.e., ROG) coatings, that are below current BAAQMD requirements (i.e., Regulation 8, Rule 3: Architectural Coatings), for at least 50 percent of all residential and nonresidential interior paints and 50 percent of exterior paints. This includes all architectural coatings applied during both construction and reapplications throughout the project’s operational lifetime.
At least 50 percent of coatings applied must meet a “super-compliant" VOC standard of less than 10 grams of VOC per liter of paint. For reapplication of coatings during the project’s operational lifetime, the Declaration of Covenants, Conditions, and Restrictions shall contain a stipulation for low VOC coatings to be used.
MM AIR-2.1 through MM AIR-2.3 would reduce ROG emissions by 50 percent, to 40.74 lbs./day, resulting in ROG emissions below the BAAQMD threshold. Therefore, with implementation of MMAIR-2.1 through MM-AIR-2.3, project construction would not exceed BAAQMD’s thresholds of significance.
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Operational Period Emissions
Operational period emissions from full buildout of the proposed Precise Plan would be generated primarily from vehicles driven by future residents, employees, customers, and vendors.14 Evaporative emissions from architectural coatings and maintenance products (classified as consumer products) are also typical emissions from these types of uses. The proposed project also would include four 750-kilowatt (kW) diesel-fueled emergency generators. The emergency generators would be tested periodically and would power the proposed buildings in the event of a power failure. For modeling purposes, it was assumed that the generators would be operated primarily for testing and maintenance purposes. CARB and BAAQMD requirements limit these engine operations to 50 hours each per year of non-emergency operation. During testing periods, the engine would typically be run for less than one hour. CalEEMod was used to estimate emissions from operation of the proposed project. As discussed in Section 3.17 Transportation, the proposed project would implement a Transportation Demand Management (TDM) plan to achieve a three percent reduction in vehicle miles traveled (VMT); therefore, mobile emissions were reduced by three percent to reflect the effectiveness of the TDM plan. A summary of the calculated annual operational emissions is provided in Table 3.3-5, below. It was assumed that the earliest year of full project buildout and operation would occur in 2030 (in the event full buildout occurs later in time beyond 2030, emissions would be even lower as fuel efficiency gains would further reduce emissions), and as individual parcels are built and occupied, emissions would remain below the table values presented below.
Table 3.3-5: Unmitigated Operational Period Emissions
Scenario ROG NOX PM10 PM2.5
2022 Existing Emissions 1.02 0.49 0.65 0.17
2030 Project Operational Emissions (tons/year) 10.83 2.94 6.81 1.78 2030 Net Project Operational Emissions (tons/year) 9.81 2.44 6.16 1.60 BAAQMD Thresholds (tons/year) 10 10 15 10
Exceed Threshold? No No No No
2030 Net Project Operational Emissions (lbs./day)1 53.77 13.38 33.76 8.79 BAAQMD Thresholds (lbs./day)1 54 54 82 54
Exceed Threshold? No No No No
1 Assumes 365-day operation
As shown in Table 3.3-5, above, the project would not exceed annual or daily BAAQMD significance thresholds during project operation. (Less than Significant Impact with Mitigation Incorporated)
14 Vehicle trips from the already built Parcel A project were included in the operational analysis to accurately reflect full buildout of the proposed Precise Plan.
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Impact AIR-3: The project would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant Impact with Mitigation Incorporated)
This project would introduce new sources of TACs during construction (i.e., on-site construction activity and truck hauling emissions) and operation (i.e., emergency diesel generators). Sensitive receptors within the project vicinity include residences to the south, west, and north of the project site and the Summit Shasta High School adjacent to the southern boundary of the project site.
Construction Toxic Air Contaminants
Project construction activity would generate dust and equipment exhaust that would affect nearby sensitive receptors. Community risk impacts were addressed by predicting increased cancer risk, the increase in annual PM2.5 concentrations and computing the Hazard Index (HI) for non-cancer health risks. The maximally exposed individual (MEI) for construction cancer risk was determined to be located on the first floor at a multi-family residence across Serramonte Boulevard north of the project site (see Figure 3.3-1). The maximum annual PM2.5 concentration from construction was shown to occur on the first floor at the Summit Shasta High School, adjacent to the southern boundary of the project (as seen in Figure 3.3-1) and was estimated to be 0.29 μg/m3 . Table 3.3-6 summarizes the
community health risk impacts associated with project construction.
Table 3.3-6: Construction Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Project
Construction
Unmitigated 19.28 (infant) 0.15 0.01
Mitigated3 3.33 (infant) 0.05 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold?
Unmitigated Yes No No
Mitigated No No No
Most Affected Student Receptor – Summit Shasta High School Project
Construction
Unmitigated 11.96 (child) 0.29 0.02
Mitigated 2.13 (child) 0.11 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold?
Unmitigated Yes No No
Mitigated3 No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
3. Assumes implementation of mitigation measures MM AIR-2.1 and MM AIR-2.2.
Source: Illingworth & Rodkin, Inc., June 17, 2022.
Legend
Cancer Risk MEI
Off-Site Residential Receptors
Off-Site School Receptors
Project Generators
Project Traffic Area Model
PM2.5 Concentration MEI
1 35
St. Francis Blvd
Serramonte Blvd
Callan Blvd
St. Francis Blvd
Serramonte Blvd
Callan Blvd
Campus Dr Campus Dr
LOCATION OF OFF-SITE RECEPTORS, MEIS, AND PROPOSED EMERGENCY GENERATORS FIGURE 3.3-1
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As shown in Table 3.3-6, unmitigated project construction would exceed the BAAQMD singlesource threshold for cancer risk at the residential and student MEI. However, implementation of MM AIR-2.1 and MM AIR-2.2 would reduce the project’s cancer risk impacts to less than significant levels. Both the unmitigated and mitigated maximum annual PM2.5 concentration and HI value from project construction would not exceed their respective BAAQMD single-source thresholds.
The community health risk impacts summarized in Table 3.3-6 are based on the proposed construction phasing of developing Parcel B first, followed by Parcels C and D, and finally Parcels E and F (see Section 2.2.1 Precise Plan). Any deviations from this phasing could result in different community health risk impacts than analyzed in this EIR. If construction phasing were to change during buildout of the proposed Precise Plan, the project would be required to implement the following mitigation measure.
Mitigation Measures: The project will be required to implement the following mitigation measure if construction phasing changes in order to confirm community health risk impacts are reduced to a less than significant level:
MM AIR-3.1: Prior to the issuance of a grading permit, the applicant shall provide the City with the most recent construction phasing schedule by parcel for buildout of the proposed Precise Plan. If the most recent construction phasing schedule increases the number of units per construction phase compared to the construction phasing assumed in the air quality analysis of this EIR, the applicant shall prepare an updated community health risk assessment to confirm that the new phasing will not result in any new or more significant air quality impacts not previously disclosed in this EIR. The updated community health risk assessment shall be reviewed and approved by the Director of Community Development or Director’s designee.
Operational Toxic Air Contaminants
As previously stated, operation of the full buildout of the Precise Plan would have long-term emissions from the proposed emergency generators and project generated traffic. Figure 3.3-1 shows the proposed locations of the generators throughout the project site. The MEI for project operation was determined to be the same as the construction MEI for cancer risk and PM2.5. CalEEMod was used to calculate the health risk impacts from the emergency generators and CalTrans version of the EMFAC2017 emissions model was used to calculate health risk impacts from project generated traffic. The results are summarized in Table 3.3-7 below.
Table 3.3-7: Operational Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Project Traffic 0.48 (child) 0.10 <0.01
Emergency Generators 1.37 (child) <0.01 <0.01
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Table 3.3-7: Operational Risk Impacts at Off-Site MEI
Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Unmitigated Project Total 1.85 (child) 0.1 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
Most Affected Student Receptor – Summit Shasta High School Project Traffic 0.26 (child) 0.11 <0.01
Emergency Generators 0.09 (child) <0.01 <0.01
Unmitigated Project Total 0.35 (child) 0.11 0.02
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
As shown in Table 3.3-7, the proposed emergency generators and project generated traffic would not exceed BAAQMD single-source thresholds at the location of the MEI. Additionally, diesel engines are subject to CARB’s Stationary Diesel Airborne Toxics Control Measure and the proposed generator would require permits from the BAAQMD since it would be larger than 50 horsepower. As part of the BAAQMD permit requirements for toxics screening analysis, the engine emissions will have to meet Best Available Control Technology for Toxics and pass the toxic risk screening level of less than ten in a million. The risk assessment would be prepared by the BAAQMD. Depending on results, the BAAQMD would set limits for DPM emissions (e.g., more restrictive engine operation periods). Sources of air pollutant emissions complying with all applicable BAAQMD regulations generally will not be considered to have a significant air quality community risk impact.
Combined Project Toxic Air Contaminants
As shown in Table 3.3-6 and Table 3.3-7 above, unmitigated project construction would exceed the BAAQMD single-source threshold for cancer risk at the residential and student MEI and unmitigated operational emissions would not exceed BAAQMD single-source thresholds. Table 3.3-8 summarizes the mitigated cancer risks, annual PM2.5 concentrations, and HI values associated with construction and operation of the proposed project.
Table 3.3-8: Combined Mitigated Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Most Affected Residential Receptor
Construction (Years 0 – 6)3 3.33 (infant) 0.05 <0.01
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Table 3.3-8: Combined Mitigated Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Traffic (Years 3 – 30) 0.48 (child) 0.10 <0.01
Emergency Generators (Years 3 – 30) 1.37 (child) <0.01 <0.01 Mitigated Project Total 5.18 (infant) 0.10 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
Most Affected Student Receptor – Summit Shasta High School Construction (Years 0 – 6) 3 2.13 (child) 0.11 <0.01
Traffic (Years 3 – 9) 0.26 (child) 0.11 <0.01
Emergency Generators (Years 3 – 9) 0.09 (child) <0.01 <0.01 Mitigated Project Total 2.48 (child) 0.11 <0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure.
2. Maximum annual concentration for any year.
3. Assumes implementation of mitigation measures MM AIR-2.1 and MM AIR-2.2.
As shown in Table 3.3-8, with implementation of MM AIR-2.1 and MM AIR-2.2, cancer risks would be reduced to less than significant levels. Both the unmitigated and mitigated annual PM2.5 concentration and HI value from construction and operation activities would not exceed the singlesource significance thresholds.
In a 2018 decision (Sierra Club v. County of Fresno), the state Supreme Court determined CEQA requires that when a project’s criteria air pollutant emissions would exceed applicable thresholds and contribute a cumulatively considerable contribution to a significant cumulative regional criteria pollutant impact, the potential for the project’s emissions to affect human health in the air basin must be disclosed. State and federal ambient air quality standards are health-based standards, and exceedances of those standards result in continued unhealthy levels of air pollutants. As stated in the 2017 BAAQMD CEQA Air Quality Guidelines, air pollution by its nature is largely a cumulative impact. No single project is sufficient in size, by itself, to result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. In developing thresholds of significance for air pollutants, BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project has a less than significant impact for criteria pollutants, it is assumed to have no adverse health effect. (Less than Significant Impact with Mitigation Incorporated)
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Impact AIR-4: The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. (Less than Significant Impact)
The project would generate localized emissions of diesel exhaust during construction equipment operation and truck activity. These emissions may be noticeable from time to time by adjacent receptors. However, they would be localized and not likely to adversely affect people off-site by resulting in confirmed odor complaints. Occupancy of the residential buildings and the ground floor retail spaces would not generate odors that would result in complaints. There were no identified odor sources that would affect the project in terms of generating frequent odor complaints. (Less Than Significant Impact)
3.3.2.3 Cumulative Impacts
Impact AIR-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant air quality impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
Cumulative Exposure of Sensitive Receptors
Community health risk assessments typically look at all substantial sources of TACs that can affect sensitive receptors that are located within 1,000 feet of the project site (i.e., influence area). These sources include railroads, freeways or highways, busy surface streets, and stationary sources identified by BAAQMD. A review of the project area indicated that State Route (SR) 1, SR 35 (Skyline Boulevard), Callan Boulevard, Hickey Boulevard, and Serramonte Boulevard have an average daily traffic (ADT) over 10,000 vehicles per day. Other nearby streets all have ADT less than 10,000 vehicles and are not considered sources of TACs. Additionally, a review of the BAAQMD’s Permitted Stationary Sources 2018 GIS website map indicates there is one stationary source within the project site’s 1,000-foot influence area. Table 3.3-9 shows the project and cumulative community risk impacts at the off-site MEI. The off-site MEI is the same as those identified under Impact AIR-3 above.
Table 3.3-9: Cumulative Community Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
Project3 Unmitigated 21.13 0.29 0.02
Mitigated 5.18 0.11 <0.01
State Route 1 & 35 5.71 0.09 --
Callan Boulevard, ADT 13,950 0.29 0.02 <0.01
Hickey Boulevard, ADT 17,950 0.02 0.01 <0.01
Serramonte Boulevard, ADT 11,565 2.01 0.01 <0.01
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Table 3.3-9: Cumulative Community Risk Impacts at Off-Site MEI Source
Cancer Risk
(per million)1
PM2.5 Concentration
(μg/m3
)
2 Hazard
Index 2
KNK Petroleum Inc dba Triton Gas
(Facility ID #111517, Gas Station), MEI
at 325 feet
2.61 -- 0.01
Cumulative Total Unmitigated 31.77 0.42 <0.06
Mitigated 15.82 0.24 <0.05
BAAQMD Cumulative-Source
Threshold 100 0.8 10.0
Exceed Threshold? Unmitigated No No No
Mitigated No No No
1. Maximum assuming third-trimester fetus, infant, child exposure for construction and child/adult exposure during operation for 30-year exposure for residential receptors and 9-year exposure for student receptors.
2. Maximum annual concentration for any year.
3. Cancer risk MEI occurred at residential receptor to the north and PM2.5 Concentration MEI occurred at high school receptor to the south.
As shown in Table 3.3-9, the combined effect of all TAC sources in the project area (with implementation of MM AIR-2.1 and MM AIR-2.2) would be less than significant because the cumulative threshold of significance would not be exceeded. Thus, the project would not make a considerable contribution to a cumulative impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
3.3.3 Non-CEQA Effects
Per California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal. 4th 369 (BIA v. BAAQMD), effects of the environment on the project are not considered CEQA impacts. The following discussion is included for informational purposes only because the City of Daly City has policies (Policy RME-5) that address existing air quality conditions affecting a proposed project.
On-site Community Health Risk – New Project Residents
A health risk assessment was completed to analyze the impact of existing and new TAC sources (i.e., emergency diesel generator, project generated traffic) would have on the new proposed sensitive receptors (i.e., residents and daycare) that buildout of the proposed Precise Plan would introduce to the site. New sensitive receptors would be located in the proposed apartment buildings and daycare space. The on-site MEI was determined to be located on the west side of Parcel D. The same TAC sources discussed under Impact AIR-3 were used in this health risk assessment. A summary of this assessment is shown in Table 3.3-10.
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Table 3.3-10: Cumulative Community Risk Impacts at On-Site MEI Source
Cancer Risk
(per million)
PM2.5 Concentration
(μg/m3
)
Hazard
Index
Project Unmitigated 27.31 0.35 0.02
Mitigated 5.21 0.14 0.01
State Route 1 & 35 5.79 0.20 --
Callan Boulevard, ADT 13,950 0.23 0.03 <0.01
Hickey Boulevard, ADT 17,950 0.07 0.01 <0.01
Serramonte Boulevard, ADT 11,565 1.08 0.10 <0.01
KNK Petroleum Inc dba Triton Gas
(Facility ID #111517, Gas Station),
Project Site at 300 feet
3.09 -- 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? Unmitigated Yes Yes No
Mitigated No No No
Cumulative Total Unmitigated 35.57 0.69 <0.06
Mitigated 15.47 0.48 <0.05
BAAQMD Cumulative-Source
Threshold 100 0.8 10.0
Exceed Threshold? Unmitigated No No No
Mitigated No No No
As shown in Table 3.3-10, the project construction sources’ unmitigated cancer risk and PM2.5 concentrations exceed the BAAQMD single-source thresholds, but the project and cumulative sources combined would not exceed the cumulative-source thresholds. With implementation of MM AIR-2.1 and MM AIR-2.2, cancer risk and PM2.5 concentrations affecting future project residents due to project construction would be reduced to below the BAAQMD single-source thresholds, and no additional mitigation is needed to reduce cumulative health risks.
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3.4 BIOLOGICAL RESOURCES
The following discussion is based, in part, on a Biological Resource Assessment (dated October 2021) prepared by Environmental Collective, a Wetland Assessment (dated February 13,2023) prepared by Hanson Bridgett, LLP, and a Biological Peer Review (dated May 2023) prepared by WRA Environmental Consultants. Copies of these reports are attached to this EIR as Appendix D, Appendix E, and Appendix F, respectively.
3.4.1 Environmental Setting
3.4.1.1 Background Information
Sensitive Natural Communities
Sensitive natural communities are natural community types considered to be rare or of a “high inventory priority” by the California Department of Fish and Wildlife (CDFW). Although sensitive natural communities have no legal protective status under the Federal Endangered Species Act (FESA) or California Environmental Species Act (CESA) (refer to Section 3.4.1.2 Regulatory Framework), they are provided some level of consideration under CEQA. Appendix G of the CEQA Guidelines identifies potential impacts on a sensitive natural community as one of six criteria to consider in determining the significance of a proposed project. While no thresholds are established as part of this criterion, it serves as an acknowledgement that sensitive natural communities are an important resource and, depending on their rarity, should be recognized as part of the environmental review process. The level of significance of a project’s impact on any particular sensitive natural community will depend on that natural community’s relative abundance and rarity.
Species of Special Concern
The CDFW maintains an administrative list of Species of Special Concern (SSC), defined as a “species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
• Extirpated from the State, or, in the case of birds, in its primary seasonal or breeding role; • Listed as federally, but not State-, threatened or endangered; • Meets the State definition of threatened or endangered but has not formally been listed; • Experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status;
• Has naturally, small populations exhibiting high susceptibility to risk from any factor(s) that, if realized, could lead to declines that would qualify it for State threatened or endangered status.
The CDFW’s Nongame Wildlife Program is responsible for producing and updating SSC publications for mammals, birds, and reptiles and amphibians. Section 15380 of the CEQA Guidelines clearly indicates that SSC should be included in an analysis of project impacts if they can be shown to meet the criteria of sensitivity outline therein. In contrast to species listed under the federal ESA or CESA, however, SSC have no formal legal status.
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The California Native Plant Society (CNPS) is a non-profit conservation organization dedicated to the preservation of native flora in California. The CNPS has been involved in assembling, evaluating, and distributing information on special-status plant species in the state, as listed in the Inventory of Rare and Endangered Plants of California. CNPS has recently updated their rating system for the rarity of special-status plants, and now include both a California Rare Plant Rank and a Threat Rank.
CEQA requires government agencies to consider environmental impacts of discretionary projects and to avoid or mitigate them where possible. Under Section 15380, CEQA provides protection for both State-listed species and for any other species which can be shown to meet the criteria for State listing. The CDFW recognizes that special-status plants with a California Rare Plant Rank of 1A (Presumed extinct in California), 1B (Rare, threatened, or endangered in California and elsewhere), and 2 (Rare and endangered in California, but are more common elsewhere) in the CNPS Inventory consist of plants that, in a majority of cases, would qualify for listing and these species should be addressed under CEQA review. In addition, the CDFW recommends, and local governments may require, protection of species which are regionally significant, such as locally rare species, disjunct populations, essential nesting and roosting habitat for more common wildlife species, or plants with a CNPS California Rare Plant Rank of 3 (Plant species for which additional data is needed – a review list) and 4 (Plant species of limited distribution – a watch list).
3.4.1.2 Regulatory Framework
Federal and State
Endangered Species Act
Individual plant and animal species listed as rare, threatened, or endangered under federal and state Endangered Species Acts are considered special-status species. Federal and state endangered species legislation has provided the United States Fish and Wildlife Service (USFWS) and the CDFW with a mechanism for conserving and protecting plant and animal species of limited distribution and/or low or declining populations. Permits may be required from both the USFWS and CDFW if activities associated with a proposed project would result in the take of a species listed as threatened or endangered. To “take” a listed species, as defined by the State of California, is “to hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill” these species. Take is more broadly defined by the federal Endangered Species Act to include harm of a listed species.
In addition to species listed under state and federal Endangered Species Acts, Sections 15380(b) and (c) of the CEQA Guidelines provide that all potential rare or sensitive species, or habitats capable of supporting rare species, must be considered as part of the environmental review process. These may include plant species listed by the California Native Plant Society and CDFW-listed Species of Special Concern.
Clean Water Act
The United States Army Corps of Engineers (USACE) is responsible under Section 404 of the Clean Water Act to regulate the discharge of fill material into waters of the U.S. These waters, and their lateral limit, are defined in 33 CFR Part 328.3(a) and include streams that are tributaries to navigable waters and their adjacent wetlands. The lateral limits of jurisdiction for a non-tidal stream are measured at the line of the Ordinary High Water Mark (33 CFR Part 328.3[e]) or the limit of adjacent wetlands (33 CFR Part 328.3[b]). Any permanent extension of the limits of an existing water of the
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U.S., whether natural or man-made, results in a similar extension of Corps jurisdiction (33 CFR Part 328.5).
Waters of the U.S. fall into two broad categories: wetlands and other waters. Other waters include waterbodies and watercourses generally lacking plant cover such as rivers, streams, lakes, springs, ponds, coastal waters, and estuaries. Wetlands are aquatic habitats that support hydrophytic wetland plants and include marshes, wet meadows, seeps, floodplains, basins, and other areas experiencing extended seasonal soil saturation. Seasonally or intermittently inundated features, such as seasonal ponds, ephemeral streams, and tidal marshes, are categorized as wetlands if they have hydric soils and support wetland plant communities. Seasonally inundated waterbodies or watercourses that do not exhibit wetland characteristics are classified as other waters of the U.S.
Waters and wetlands that cannot trace a continuous hydrologic connection to a navigable water of the U.S. are not tributary to waters of the U.S. These are termed “isolated wetlands.” Isolated wetlands are jurisdictional when their destruction or degradation can affect interstate or foreign commerce (33 CFR Part 328.3[a]). The Corps may or may not take jurisdiction over isolated wetlands depending on the specific circumstances.
In general, a project proponent must obtain a Section 404 permit from the Corps before placing fill or grading in wetlands or other waters of the U.S. Prior to issuing the permit, the Corps is required to consult with the USFWS under Section 7 of the ESA if the project may affect federally listed species.
All Corps permits require water quality certification under Section 401 of the Clean Water Act. In the San Francisco Bay Area, this regulatory program is administered by the San Francisco Bay Regional Water Quality Control Board (RWQCB). Project proponents who propose to fill wetlands or other waters of the U.S. must apply for water quality certification from the RWQCB. The RWQCB has adopted a policy requiring mitigation for any loss of wetland, streambed, or other jurisdictional area.
Porter-Cologne Water Quality Control Act
Under this Act (California Water Code Sections 13000–14920), the RWQCB is authorized to regulate the discharge of waste that could affect the quality of the State’s waters. The RWQCB asserts jurisdiction over isolated waters and wetlands, as well as waters and wetlands that are regulated by the Corps. Therefore, even if a project does not require a federal permit, it may still require review and approval by the RWQCB. When reviewing applications, the RWQCB focuses on ensuring that projects do not adversely affect the “beneficial uses” associated with waters of the State. In most cases, the RWQCB seeks to protect these beneficial uses by requiring the integration of waste discharge requirements (WDRs) into projects that will require discharge into waters of the State. For most construction projects, the RWQCB requires the use of construction and postconstruction Best Management Practices (BMPs).
Migratory Bird Treaty Act
The federal Migratory Bird Treaty Act (MBTA) prohibits killing, capture, possession, or trade of migratory birds except in accordance with regulations prescribed by the Secretary of the Interior.
Hunting and poaching are also prohibited. The taking and killing of birds resulting from an activity is
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not prohibited by the MBTA when the underlying purpose of that activity is not to take birds.15 Nesting birds are considered special-status species and are protected by the USFWS. The CDFW also protects migratory and nesting birds under California Fish and Game Code Sections 3503, 3503.5, and 3800. The CDFW defines taking as causing abandonment and/or loss of reproductive efforts through disturbance.
Fish and Game Code
The CDFW is also responsible for enforcing the California Fish and Game Code, which contains several provisions potentially relevant to construction projects. For example, Section 1602 of the Fish and Game Code governs the issuance of Lake and Streambed Alteration Agreements by the CDFW.
Lake or Streambed Alteration Agreements are required whenever project activities substantially divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake designated as such by the CDFW.
The Fish and Game Code also lists animal species designated as Fully Protected or Protected, which may not be taken or possessed at any time. The CDFW does not issue licenses or permits for take of these species except for necessary scientific research, habitat restoration/species recovery actions, or live capture and relocation pursuant to a permit for the protection of livestock. Fully protected species are listed in Sections 3511 (birds), 4700 (mammals), 5050 (reptiles and amphibians), and 5515 (fish) of the Fish and Game Code, while Protected amphibians and reptiles are listed in Chapter 5, Sections 41 and 42.
Several provisions in the California Fish and Game code provide for the protection of birds and bird nests in active use. Unless the Fish and Game Code (FGC) or its implementing regulations provide otherwise, under California law it is unlawful to:
• Take a bird, mammal, fish, reptile, or amphibian (FGC Section2000); • Take, possess, or needlessly destroy the nest or eggs of any bird (FGC Section 3503); • Take, possess, or destroy any bird of prey in the orders Strigiformes (owls) and Falconiformes (such as falcons, hawks and eagles) or the nests or eggs of such bird (FGC Section 3503.5);
• Take or possess any of the thirteen fully protected bird species listed in FGC Section 3511; • Take any non-game bird (i.e., bird that is naturally occurring in California that is not a gamebird, migratory game bird, or fully protected bird) (FGC Section 3800); • Take or possess any migratory non-game bird as designated in the MBTA or any part of such bird, except as provided by rules or regulations adopted by the DOI under the MBTA (FGC Section 3513);
• Take, import, export, possess, purchase, or sell any bird (or products of a bird), listed as an endangered or threatened species under the CESA unless the person or entity possesses an Incidental Take Permit or equivalent authorization from CDFW (FGC Section 2050 et seq.). 15 United States Department of the Interior. “Memorandum M-37050. The Migratory Bird Treaty Act Does Not Prohibit Incidental Take.” Accessed December 6, 2021. https://www.doi.gov/sites/doi.gov/files/uploads/m37050.pdf.