Daly City City Council
February 26, 2024

Serramonte Del Rey Campus Redevelopment 58 Draft EIR
City of Daly City June 2023
• Non-native species, including European starling, house sparrow, and rock pigeon, are not afforded any protection under the MBTA or California Fish and Game Code.

Regional
San Bruno Mountain Habitat Conservation Plan
The San Bruno Mountain Habitat Conservation Plan (HCP) was executed as an Agreement in November 1982 with the US Fish and Wildlife Service, California Department of Fish and Game, County of San Mateo, the cities of Brisbane, Daly City and South San Francisco, and several private property owners. The HCP was created to provide for the indefinite perpetuation of the Mission blue butterfly and to protect habitat of the other Species of Concern. It includes the establishment of public ownership of sufficient habitat area to support the species as well as funding for the ongoing maintenance of the habitat. Funding is provided by limited development that was excluded from such habitat area and devoted to urban uses, including, among others, residential, community service, commercial and recreational uses.

Given that the San Bruno Mountain encompasses approximately 3,600 acres, with various ownerships and within various cities, the HCP presents a single unifying and coordinating document to provide protection, enhancement and funding for the entire San Bruno Mountain ecological community. The HCP provides for the perpetuation of conserved habitat areas through eradication of exotic species; re-vegetation with grassland species; effective yearly monitoring of the species of concern to control reintroduction of exotics; and patrol of the area to discourage destructive human activities.

Portions of three of the four HCP planning areas are located within the jurisdiction of Daly City (Saddle, Radio Ridge, and Guadalupe Hills). Within those areas, all designated development has been completed including Point Pacific, Village in the Park, South Hills Estates, Linda Vista, and Bay Ridge. All of this development resulted in a net gain of available habitat either through dedication, easements, or on-site restoration. Furthermore, all of these projects continue to contribute to a trust fund that is used to maintain and monitor the habitat in perpetuity.

The project site is approximately 1.5 miles southwest of the San Bruno HCP boundary.

Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to biological resources and are applicable to the proposed project.

Policy/Task Description
Policy LU-17 Ensure that private development is responsible for providing any on- or off-site improvements related to and/or mitigating the impacts it causes.

Serramonte Del Rey Campus Redevelopment 59 Draft EIR
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Policy LU-18 Development activities shall not be allowed to significantly disrupt the natural or urban environment and all reasonable measures shall be taken to identify and prevent or mitigate potentially significant effects.

Policy RME-16 The City shall continue to recognize the importance of the San Bruno Mountain HCP, uphold the integrity of the concepts behind the plan, and respect the agreements that serve to implement it.

Municipal Code Chapter 12.40 – Urban Forestry Ordinance The Municipal Code provides regulations to optimize the use of trees and other landscaping within the city. Chapter 12.40 requires plans submitted to the City for the construction, repair, or alteration of any building, housing, or structure to include provisions for sufficient guards or protectors to prevent injury to any existing publicly owned trees, shrubs, flowers, or vines. It also imposes conditions regarding the displacement of public trees, where a comparable size tree shall be planted, or a fee is paid to the City to cover the cost of replacing a removed tree.

3.4.1.3 Existing Conditions
The project site is located within an urbanized area of Daly City and is developed with the JUHSD campus, which is situated on an artificial flat that was created when the sloping property was graded and developed in 1969. The area has been extensively disturbed by past development, with most of the graded portion of project site occupied by buildings and pavement. Trees and landscaping are scattered throughout the area. The slopes located on the western, northern, and eastern portions of the area are occupied by non-native Monterey pine (Pinus radiata) and Monterey cypress (Hesperocyparis macrocarpa) trees, with an understory of non-native grasses and forbs, ivy (Hedera spp.), periwinkle (Vinca major), ice plant (Delosperma sp.), poison oak (Toxicodendron diversilobum), sour grass (Oxalis pes-caprae), and other species. Grassland species consist of annual grasses and forbs such as wild oats (Avena spp.), bromes (Bromus spp.), cut-leaf geranium (Geranium dissectum), bristly ox-tongue (Helminthotheca echioides), and bindweed (Convolvulus arvensis), among others.16
Sensitive Natural Communities
No riparian, native grassland, valley oak woodland, or other sensitive natural communities are present within the project site. As mentioned in Section 2.2.1.1, there is a demonstration garden in the southwest portion of the site. As documented in Appendix D, although native plant species are present in the Demonstration Garden as a result of being planted by gardeners (refer to Figure 3.4-1 and Photo 2), no rare or threatened plant species were found on-site; therefore, the garden does not meet CDFW’s definition of a sensitive natural community with special status under federal and state law (refer to Section 3.4.1.1 Environmental Setting and Section 3.4.1.2 Regulatory Framework). The project site is also occupied by two separate stands of native arroyo willow, including one located on the eastern slopes and another located to the south of the Demonstration Garden (refer to Figure

3.4-1).17
16 A forb is a herbaceous flowering plant. 17 Arroyo willow is considered a Facultative Wetland (FACW) species according to the National Wetland Plant List (NWPL) typically growing in riparian conditions indicative of available surface water. The NWPL is used by the

Service Layer Credits: Golden Gate National Parks Conservancy and San Mateo C
A
L
L
A
N
B
L
V
D

HIG ATE DR
KE
N
T
C
T

ST FRANCIS BLVD

SERRAMONTE B LVD
CAM
PUS
DR
W
M W W
0100
Feet
San
Mateo
County
Area
Enlarged
Jefferson Union High
School District
Parcel A
(65 M 68-69)
APN 091-211-230
Acreage: 22.3 acres
Meadow
Willow Thicket
Conifer Plantings
Existing Structures, Pavement, Ornamental Landscaping
Demostration
Garden
Source: Environmental Collaborative, July 14, 2021.

Project Boundary
Biological Land Cover FIGURE 3.4-1

Serramonte Del Rey Campus Redevelopment 61 Draft EIR
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Each stand is several hundred square feet in size and surrounded by non-native plantings and impervious surfaces. These stands are not indicative of riparian conditions since there are no natural drainages entering or leaving the willow stand locations, indicating they are likely formed by poor drainage following development of the property or irrigation runoff. This is particularly true for the willow stand located on the steep eastern slopes where water could not concentrate. Additionally, these willow stands are dominated by non-native upland species of grasses and shrubs, and are located in an area extensively disturbed by past development. Based on these facts, both the Biological Resources Assessment and Biological Peer Review (refer to Appendix D and Appendix F, respectively) concurred that these willow stands do not meet the definition of a sensitive natural community.

Special-Status Species
Special-status species are plants and animals that are legally protected under the Federal Endangered Species Act (FESA), California Endangered Species Act (CESA), or other regulations, and species that are considered sufficiently rare by the scientific community to qualify for such listing. For purposes of this analysis, special-status plant species include the following:
• Listed under FESA as threatened, endangered, proposed threatened, proposed endangered, or a candidate species.
• Listed under CESA as threatened, endangered, rare, or a candidate species. • Listed by the CNPS as California Rare Plant Rank (CRPR) 1A, 1B, 2, 3, or 4.

For purposes of this analysis, special-status wildlife species include the following:
• Listed under FESA as threatened, endangered, proposed threatened, proposed endangered, or a candidate species.
• Listed under CESA as threatened, endangered, or a candidate threatened or endangered species.
• Designated by the CDFW as a California species of special concern. • Listed in the California Fish and Game Code as fully protected species (fully protected birds are provided in Section 3511, mammals in Section 4700, reptiles and amphibians in Section 5050, and fish in Section 5515).

Special Status Plants
No special-status plant species were observed on the project site during surveys conducted by Environmental Collective and WRA. None of the special-status plants known to occur in Daly City are mapped within the project site according to the California Natural Diversity Database (CNDDB).

Suitable conditions for special-status plants are not present within the project site due to the extensive grading and development that the area has undergone, which precludes their occurrence within the area. While the Demonstration Garden includes some native plants planted by gardeners, none are classified as special-status.

Serramonte Del Rey Campus Redevelopment 62 Draft EIR
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Special-Status Wildlife
No special-status wildlife species were observed during the surveys conducted by Environmental Collective and WRA. Most special-status wildlife species known to occur in northern San Mateo County are associated with coastal salt marsh and riparian habitat, which are not present within the Precise Plan area. Due to a lack of larval host plant species or suitable habitat such as serpentine substrate or perennial aquatic habitat, special-status invertebrate species are unlikely to be present within the project site. The range of the western bumble bee, which is not a protected species under federal or state law but is being closely monitored due to declines in numbers and distribution over the past two decades, does not encompass the project site.

Bird nests of migratory bird species are protected under federal and state law (refer to Section 3.4.1.2 Regulatory Framework). No evidence of bird nests was observed during the aforementioned site visits, but suitable nesting habitat exists in the trees located along the project site perimeter.

There are no recorded occurrences of any special-status bat species within the project site and surrounding vicinity. However, trees and man-made building cavities, both of which are present onsite, are commonly used by bats, including the pallid bat (Antrozous pallidus) and Townsend’s western big-eared bat (Corynorhinus townsendii), for roosting.

Jurisdictional Waters
As noted above under Sensitive Natural Communities, arroyo willow is typically found growing in riparian conditions indicative of available surface water, but may occur in non-wetlands. The arroyo willow stands are not connected to a natural drainage and have likely been supported by poor drainage following site development or irrigation runoff. Further, soils present at the willow stands lack redoximorphic features and do not meet the hydric soil criteria used to delineate wetlands.18 Accordingly, both the Biological Resources Assessment and Biological Peer Review (refer to Appendix D and Appendix F, respectively) concurred that the willow stands do not meet the definition of a regulated wetland under federal and state law.

There is an approximately 865 square foot meadow located adjacent to the southwestern willow stand (see Photo 5 and Figure 3.4-1) that consists of facultative grasses including Italian ryegrass (Festuca perennis), bristly ox-tongue (Helminthotheca echioides), velvet grass (Holcus lanatus), annual beard grass (Polypogon monspeliensis), fringed willowherb (Epilobium ciliatum), and common rush (Juncus patens).19 Soils present within this meadow exhibit redoximorphic features, and met hydric soil indicators. The meadow, however, is a result of deferred maintenance on the project site’s drainage system and is not a naturally occurring wetland (see Appendix E and Appendix F); therefore, the meadow would not qualify as a jurisdictional wetland under the Clean Water Act or Porter-Cologne Act or as a sensitive natural community type. 18 Redoximorphic features are color patterns soils that indicate periodic or regular saturation with water. Hydric soil is soil that has formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part of the soil. 19 A facultative species is one that occurs in wetlands and non-wetlands.

Photo 5: View of meadow in southwest corner of the project site.

PHOTO 5

Serramonte Del Rey Campus Redevelopment 64 Draft EIR
City of Daly City June 2023

3.4.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on biological resources, would the project:
1) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or United States Fish and Wildlife Service (USFWS)?
2) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS? 3) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
4) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
5) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
6) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

3.4.2.1 Project Impacts
Impact BIO-1: The project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. (Less than Significant Impact with Mitigation Incorporated)
As discussed in Section 3.4.1.3 Existing Conditions, there are no known occurrences of special-status plants or wildlife within the project site. However, trees and buildings present on-site may provide suitable nesting and roosting habitat for protected and/or special-status birds and bats. The potential impacts of the project on these species are discussed below.

Special-Status Birds
As previously noted, trees located within and along the project site perimeter may provide nesting habitat for migratory birds as well as native nesting birds. If vegetation removal, demolition, and construction activities occur during the nesting season (February 1 through August 31), these activities could result in the destruction or abandonment of an active nest and loss of any eggs or younglings in the nest, which would constitute a significant adverse effect and a violation of the federal Migratory Bird Treaty Act and State Fish and Game code.

Serramonte Del Rey Campus Redevelopment 65 Draft EIR
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Mitigation Measures:

MM BIO-1.1:
• If construction is initiated during the non-breeding season (September 1 to January 31), then vegetation removal, building demolition and other construction may proceed with no restrictions.
• If initial building demolition, vegetation removal, and construction is proposed during the nesting season (February 1 to August 31), a focused survey for nesting raptors and other native birds shall be conducted by a qualified biologist within 14 days prior to the onset of construction in order to determine whether any active nests are present on the site and surrounding area within 250 feet of proposed construction. The survey shall be reconducted any time construction has been delayed or curtailed for more than 14 days during the nesting season.
• If no active nests are identified during the construction survey period, then building demolition, vegetation removal, and other construction may proceed with no restrictions.
• If active bird nests are found, an adequate setback shall be established by a qualified biologist, approved by the City Planning Division, around the nest location and construction activities restricted within this no-disturbance zone until the qualified biologist has confirmed that any young birds have fledged and are able to function outside the nest location. Required setback distances for the no-disturbance zone shall be based on input received from the CDFW and may vary depending on species and sensitivity to disturbance. As necessary, the no-disturbance zone shall be fenced with temporary orange construction fencing if construction is to be initiated elsewhere on the site outside this zone.
• A report of findings shall be prepared by the qualified biologist and submitted to the Director of Community Development or Director’s designee for review and approval prior to initiation of construction during the nesting season (February 1 to August 31). The report shall either confirm absence of any active nests or should confirm that any young are located within a designated no-disturbance zone and construction can proceed. No report of findings is required if construction is initiated during the non-nesting season (September 1 to January 31) and continues uninterrupted according to the above criteria.

With implementation of MM BIO-1.1, the project’s impact to birds nesting on or near the site would be less than significant.

Special-Status Bats
Trees located within and along the perimeter of the project site and cavities in the existing buildings may provide roosting habitat for special-status bats and other designated priority bat species, including the pallid bat and Townsend’s western big-eared bat. Tree trimming/removal and demolition of the existing buildings could displace any roosting bats, if present. Destruction of active

Serramonte Del Rey Campus Redevelopment 66 Draft EIR
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roosts, particularly a maternity roost of a special-status bat species with a high or medium-high priority by the Western Bat Working Group, would constitute a significant adverse effect.

Mitigation Measures:

MM BIO-1.2: Adequate measures shall be taken to avoid roosting by special-status bat species as a result of tree removal and building demolition, specifically:
• To the extent feasible, any tree removal or trimming that is deemed necessary by a certified arborist to maintain tree health shall be conducted outside of the bat maternity season (i.e. generally avoiding tree removal or trimming April through October).
• Building demolition shall, to the extent feasible, be conducted outside of the bat maternity season (i.e. generally avoiding demolition April through October).
• If tree removal, trimming, or building demolition occurs within bat maternity season (i.e. generally April through October), a pre-construction bat roost assessment shall be conducted by a qualified biologist at least 14 days and no more than 30 days prior to tree removal or building demolition to determine if bats roosts are present that may be impacted by project activities. • If special-status bat species or maternity roosts are detected during these surveys, a qualified biologist shall identify any additional measures required to protect the roosts, such as including avoidance of the roosts until the end of the maternity roosting season.
• Regardless of the timing of tree removal or trimming activities, all felled trees or large limbs shall remain on the ground for at least 24-hours prior to chipping, off-site removal, or other processing to allow any roosting individual bats to vacate the premises of their own volition. • A report of findings shall be prepared by the qualified biologist and submitted to the Director of Community Development or Director’s designee for review and approval prior to initiation of construction during the maternity roosting season (April through October). The report shall either confirm absence of any active maternity roosts or specify any additional measures necessary to protect roosts until the end of the maternity roosting season. No report of findings is required if construction is initiated during the non-maternity roosting season (November through March) and continues uninterrupted according to the above criteria.

With implementation of MM BIO-1.2, impacts to individual bats and non-special status individuals and colonies of bats would be avoided during project construction. (Less than Significant Impact with Mitigation Incorporated)

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Impact BIO-2: The project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS. (No Impact) As discussed in Section 3.4.1.3 Existing Conditions, no riparian habitat or sensitive natural communities are present within the project site. Therefore, since construction and operation of the proposed project would be constrained to the project site, the project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community. (No Impact) Impact BIO-3: The project would not have a substantial adverse effect on state or federally protected wetlands through direct removal, filling, hydrological interruption, or other means. (No Impact)
Implementation of the project would result in the removal of the arroyo willow stands and meadow discussed in Section 3.4.1.3 Existing Conditions. Both willow stands are surrounded by upland plant species, located on steep slopes, and lack hydric soil conditions; therefore, they do not meet wetland criteria under federal or state wetland definitions. The Biological Resource Assessment (see Appendix D), Biological Peer Review (see Appendix F), and Wetland Assessment (see Appendix E) all agree that the approximately 865 square foot meadow in the southwest corner of the project site appears to contain wetland features; however, the Wetland Assessment documents that the small meadow is not a naturally occurring wetland, is isolated from natural drainages downstream, and is the result of deferred maintenance of the project site’s drainage system. While the Biological Resource Assessment identifies the presence of wetland features, it does not reach a definitive conclusion about the meadow qualifying as a jurisdictional wetland and recommends a formal wetland delineation be performed prior to project implementation to allow the US Army Corp and/or the Regional Water Quality Control Board to determine whether to assert jurisdiction over the meadow as a wetland. The Biological Peer Review, however, agrees with the findings of the Wetland Assessment and concludes that the meadow would not qualify as a jurisdictional wetland under the Clean Water Act or Porter-Cologne Act. Based on the information presented regarding the origin and nature of the meadow, and consistent with the findings of the Biological Peer Review and Wetland Assessment, the City concludes that the meadow is not a formal wetland and, therefore, the removal of the meadow would not constitute a significant impact under CEQA and no mitigation is required to offset its loss. Thus, the project would not have a substantial adverse effect on state or federally protected wetlands. (No Impact)

Serramonte Del Rey Campus Redevelopment 68 Draft EIR
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Impact BIO-4: The project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Less than Significant Impact)
As documented in Section 3.4.1.3 Existing Conditions, the project site is located in an urban area and has been extensively disturbed by past development, and is almost fully developed with buildings and impervious surfaces. No watercourses or other natural features are present that would serve as a movement corridor for migratory fish or wildlife species, or as a native wildlife nursery. The majority of trees and understory grasses, forbs, and other plants located on the perimeter of the project site would be preserved and continue to serve as habitat for local wildlife. Any wildlife present within the vicinity of the project site is already acclimated to human activity, and construction activities would not cause any significant impacts on wildlife movement in the area. For these reasons, the project would not interfere with fish and wildlife movement or in the use of native wildlife nursery sites. (Less than Significant Impact)
Impact BIO-5: The project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Less than Significant Impact)
As discussed under Impact BIO-1, the project would mitigate potential impacts to nesting birds and bats to a less than significant level (consistent with General Plan policies LU-17 and LU-18).

Additionally, the project would not conflict with the San Bruno Mountain Habitat Conservation Plan (refer to the discussion under Impact BIO-6), consistent with General Plan Policy RME-16. The project proposes to replace any trees removed during construction at a 2:1 ratio; however, since the trees are located on private property, the removal of these trees is not regulated by the City of Daly City and the City’s Urban Forestry Ordinance. Off-site improvements (see Section 2.2.2.1 above) related to the project could result in the removal of street trees; however, the project would comply with the City’s Urban Forestry Ordinance by replacing any removed street trees with a similar sized tree or through a fee payment directly to the City. Accordingly, the project would not conflict with any local policies or ordinances protecting biological resources. (Less than Significant Impact) Impact BIO-6: The project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (No Impact) The project site is approximately 1.5 miles southwest of the San Bruno HCP boundary. Therefore, the project would not conflict with the provisions of an adopted HCP. (No Impact)

Serramonte Del Rey Campus Redevelopment 69 Draft EIR
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3.4.2.2 Cumulative Impacts
Impact BIO-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant biological resources impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
The geographic area for cumulative impacts to biological resources includes the project site and its surrounding area because localized development would affect the same group of biological resources.

The only cumulative projects within the vicinity of the project site are the Serramonte Shopping Center Expansion, located at 3 Serramonte Center, and the Serramonte Condominiums and Hotel project, located at 525-595 Serramonte Boulevard, both of which are adjacent to the northeast corner of the project site.

Candidate, Sensitive, or Special Status Species
As discussed under Impact BIO-1, the project would have a less than significant impact on candidate, sensitive, and special-status species with implementation of MM BIO-1.1 and MM BIO-1.2. Similar to the project, trees located at 3 Serramonte Center and 525-595 Serramonte Boulevard and cavities in existing buildings at 3 Serramonte Center may provide nesting and roosting habitat for birds and bats. Both the Serramonte Center Expansion and Serramonte Condominiums and Hotel projects would be subject to the same federal (FESA, MBTA), state (CESA, Fish and Game Code), and local policies and regulations in the City’s General Plan protecting these species of birds and bats, and would be required to implement protective measures as warranted. Further, the project site, 3 Serramonte Center, and 525-595 Serramonte Boulevard are separated by a major intersection and intervening easements, which would reduce the potential for these projects to result in a cumulatively considerable impact to these species. Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact on candidate, sensitive, or specialstatus species. (Less than Significant Cumulative Impact with Mitigation Incorporated) Riparian Habitats or Sensitive Natural Communities
No riparian habitats or sensitive natural communities are present within the project site or adjacent parcels; therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact on riparian habitats or other sensitive natural communities. (Less than Significant Cumulative Impact)
Wetlands
As discussed under Impact BIO-3, the project would have no impact on state or federally protected wetlands. No wetlands are mapped within the cumulative project sites on the U.S. Fish and Wildlife National Wetlands Inventory, and these cumulative projects would be subject to the state and federal regulations protecting wetlands identified in Section 3.4.1.2 Regulatory Framework should any wetlands be discovered during the environmental review process.20 Accordingly, the project would 20 U.S. Fish and Wildlife Service. “National Wetlands Inventory”. Accessed December 22, 2021. https://www.fws.gov/wetlands/data/Mapper.html

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not result in a cumulatively considerable contribution to a cumulatively significant impact on state or federally protected wetlands. (Less than Significant Cumulative Impact) Movement, Migration, or Use of Native Wildlife Nursery Sites No watercourses or natural features are present within the project site or adjacent parcels that would serve as a movement corridor for migratory fish or wildlife species, or as a native wildlife nursery.

Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant impact fish and wildlife movement or in the use of native wildlife nursery sites. (Less than Significant Cumulative Impact)
Policies or Ordinances Protecting Biological Resources
As discussed under Impact BIO-5, the project would be in compliance with policies and ordinances protecting biological resources, specifically those outlined in the City’s General Plan and Municipal Code. The cumulative projects identified in Table 3.0-1 would also be required to comply with these same policies, and therefore the project would not result in a cumulatively considerable contribution to a cumulatively significant conflict with local policies or ordinances protecting biological resources. (Less than Significant Cumulative Impact)
Habitat Conservation Plans
Neither the project site or other cumulative projects are located within an area covered by an adopted HCP, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Therefore, the project would not result in a cumulatively considerable contribution to a cumulatively significant conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (No Cumulative Impact)

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3.5 CULTURAL RESOURCES
The following discussion is based, in part, on a Historic Resources Evaluation prepared by Archaeological/Historical Consultants, dated October 2021. A copy of this report is attached to this EIR as Appendix G. The analysis is also based on a Cultural Resources Study prepared for the project by Tom Origer & Associates, dated February 2021. A copy of this report is on file at the City of Daly City Planning Division.

3.5.1 Environmental Setting

3.5.1.1 Regulatory Framework
Federal and State
National Historic Preservation Act
Federal protection is legislated by the National Historic Preservation Act of 1966 (NHPA) and the Archaeological Resource Protection Act of 1979. These laws maintain processes for determination of the effects on historical properties eligible for listing in the National Register of Historic Places (NRHP). Section 106 of the NHPA and related regulations (36 Code of Federal Regulations [CFR] Part 800) constitute the primary federal regulatory framework guiding cultural resources investigations and require consideration of effects on properties that are listed or eligible for listing in the NRHP. Impacts to properties listed in the NRHP must be evaluated under CEQA.

California Register of Historical Resources
The California Register of Historical Resources (CRHR) is administered by the State Office of Historic Preservation and encourages protection of resources of architectural, historical, archeological, and cultural significance. The CRHR identifies historic resources for state and local planning purposes and affords protections under CEQA. Under Public Resources Code Section 5024.1(c), a resource may be eligible for listing in the CRHR if it meets any of the NRHP criteria.21 Historical resources eligible for listing in the CRHR must meet the significance criteria described previously and retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. A resource that has lost its historic character or appearance may still have sufficient integrity for the CRHR if it maintains the potential to yield significant scientific or historical information or specific data.

The concept of integrity is essential to identifying the important physical characteristics of historical resources and, therefore, in evaluating adverse changes to them. Integrity is defined as “the authenticity of a historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource's period of significance.” The processes of determining integrity are similar for both the CRHR and NRHP and use the same seven variables or aspects to define integrity that are used to evaluate a resource's eligibility for listing. These seven characteristics include 1) location, 2) design, 3) setting, 4) materials, 5) workmanship, 6) feeling, and 7) association. 21 California Office of Historic Preservation. “CEQA Guidelines Section 15064.5(a)(3) and California Office of Historic Preservation Technical Assistance Series #6.” Accessed August 31, 2020. http://www.ohp.parks.ca.gov/pages/1069/files/technical%20assistance%20bulletin%206%202011%20update.pdf.

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Senate Bill 18
The intent of SB 18 is to aid in the protection of traditional tribal cultural places through local land use planning by requiring city governments to consult with California Native American tribes on projects which include adoption or amendment of general plans (defined in Government Code Section 65300 et seq.) and specific plans (defined in Government Code Section 65450 et seq.). SB 18 requires local governments to consult with tribes prior to making certain planning decisions and to provide notice to tribes at certain key points in the planning process.

Assembly Bill 52
AB 52, effective July 2015, established a new category of resources for consideration by public agencies called Tribal Cultural Resources (TCRs). AB 52 requires lead agencies to provide notice of projects to tribes that are traditionally and culturally affiliated with the geographic area if they have requested to be notified. Where a project may have a significant impact on a tribal cultural resource, consultation is required until the parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource or until it is concluded that mutual agreement cannot be reached.

Under AB 52, TCRs are defined as follows:
• Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are also either:
o Included or determined to be eligible for inclusion in the California Register of Historic Resources, or
o Included in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).
• A resource determined by the lead agency to be a TCR.

California Native American Historical, Cultural, and Sacred Sites Act The California Native American Historical, Cultural, and Sacred Sites Act applies to both state and private lands. The act requires that upon discovery of human remains, construction or excavation activity must cease and the county coroner be notified.

Public Resources Code Sections 5097 and 5097.98
Section 15064.5 of the CEQA Guidelines specifies procedures to be used in the event of an unexpected discovery of Native American human remains on non-federal land. These procedures are outlined in Public Resources Code Sections 5097 and 5097.98. These codes protect such remains from disturbance, vandalism, and inadvertent destruction, establish procedures to be implemented if Native American skeletal remains are discovered during construction of a project, and establish the Native American Heritage Commission (NAHC) as the authority to resolve disputes regarding disposition of such remains.

Pursuant to Public Resources Code Section 5097.98, in the event of human remains discovery, no further disturbance is allowed until the county coroner has made the necessary findings regarding the origin and disposition of the remains. If the remains are of a Native American, the county coroner must notify the NAHC. The NAHC then notifies those persons most likely to be related to the Native

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American remains. The code section also stipulates the procedures that the descendants may follow for treating or disposing of the remains and associated grave goods.

Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to cultural resources and are applicable to the proposed project.

Policy/Task Description
Policy LU-19.1 Archeological resources should be preserved where possible.

Task LU-19.1 Archeological resources are a valuable educational resource for the residents of the city. Every effort should be made to preserve them in their natural state when found or be excavated by professional archeologists for display in a museum.

Policy RME-19 Undertake measures to protect and preserve historic and archaeological resources.

Task RME-19.1 Comply with State statues related to historical and archaeological resources.

Task RME-19.1 Serve as a leader in historic preservation by preserving, restoring, and reusing City-owned historic resources where feasible.

3.5.1.2 Existing Conditions
Archaeological Resources
The San Francisco Bay Area was historically inhabited by a Native American group known as the “Costanoan” or Ohlone over a period of 5,000 to 8,000 years prior to Spanish exploration and colonization of the region. According to the Northwest Information Center (NWIC), Native American resources in the northern part of San Mateo County have been found in close proximity to sources of water (including perennial and intermittent streams and springs), near the bay margin and its associated wetlands, along the coastal terraces and sheltered valleys, and near ecotones and other productive environments. The tribelet which inhabited the Daly City area lived primarily in two main inland villages located on the Colma and San Bruno Creeks and a seasonal village along the coast at Mussel Rock. At the time of European settlement, the project site was controlled by the Ramaytush linguistic group of the Ohlone/Costanoan people.

The project site is within an urbanized area of Daly City and is developed with the JUHSD campus, which is situated on an artificial flat that was created when the property was developed in 1969. The project site is located at what was once the headwaters of a small drainage that flowed east into Colma Creek. Prior to development of the project site, this drainage would have been the closest source of freshwater for nearby Ohlone/Costanoan people. No archaeological resources have been documented within a half-mile of the project site.

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Historic Resources
The project site is currently developed with the JUHSD campus, which includes a main campus and storage bungalows (constructed in 1969), a General Education Department building (constructed in 1982), two one-story portables (constructed in 1998) and a Comcast relay station (constructed in 2002). Neither the project site or existing buildings are identified as a historic resource in the NRHP or CRHR, or identified as a property with potential historic value in the Daly City General Plan. The Historic Resources Evaluation prepared by Archaeological/Historical Consultants found none of the buildings to be an example of any unique architectural style or the work of a master architect or builder, nor were any structures determined to be associated with any significant person or local event in the area, and therefore the JUHSD campus does not meet the definition of an historic resource under CEQA. There are no documented historic resources within the vicinity of the JUHSD campus.

3.5.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on cultural resources, would the project:
1) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5?
2) Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?
3) Disturb any human remains, including those interred outside of dedicated cemeteries?

3.5.2.1 Project Impacts
Impact CUL-1: The project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. (No Impact)
The existing JUHSD campus is not listed in the National Register of Historic Places or the California Register of Historical Resources, or the local registry of historic resources reflected in the Daly City General Plan. While the main campus and storage bungalows are over 50 years in age, these buildings are of simple utilitarian design constructed with commonplace materials (steel, concrete, wood, tar, gravel) and are not an example of any unique architectural style or the work of a master architect or builder. Further, these buildings are not known to be associated with any significant person or local event in the area. There are no documented historic resources within the vicinity of the JUHSD campus. For these reasons, demolition of the JUHSD campus would not cause a substantial adverse change in the significance of a historical resource. (No Impact)

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Impact CUL-2: The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated) The project site has been previously disturbed and developed with the JUHSD campus as described under Section 3.5.1.2 Existing Conditions. No archaeological resources have been documented within a half-mile of the project site. However, based on the site’s proximity to a historic freshwater source and the historic occupation of Daly City and the project site by the Ohlone/Costanoan people, the Cultural Resources Study identified a moderate sensitivity for subsurface archaeological resources to be encountered during construction-related ground disturbing activities (demolition, grading, excavation, etc.). The project could result in significant impacts to undiscovered subsurface archaeological resources if encountered during construction-related ground disturbing activities.

Mitigation Measures:

MM CUL-2.1: Undiscovered Archaeological Resources. If evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5, including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g., worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation. The City’s Planning Manager shall consult with the archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-than-significant level through data recovery or other methods determined adequate by a qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.

MM CUL-2.2: Report of Archaeological Resources. If archaeological resources are identified, a final report summarizing the discovery of cultural materials shall be submitted to the City’s Planning Manager prior to issuance of certificate of occupancy. This report shall contain a description of the mitigation program that was implemented and its results, including a description of the monitoring and testing program, a list of the resources found and conclusion, and a description of the disposition/curation of the resources.

Implementation of MM CUL-2.1 would ensure that any potentially undiscovered archaeological resources are identified and appropriately treated and protected by a qualified archaeologist in accordance with the Secretary of the Interior’s standards. Mitigation addressing subsurface archaeological resources would be documented and enforced through implementation of MM CUL2.2. Therefore, the project would not cause a substantial adverse change in the significance of an

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archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated)
Impact CUL-3: The project would not disturb any human remains, including those interred outside of dedicated cemeteries. (Less than Significant Impact with Mitigation Incorporated)
Due to the project site’s history of prehistoric residential activities, human remains have the potential to be discovered during construction. If human remains are unearthed during project construction, damage to or destruction of human remains would be a potentially significant impact.

Mitigation Measures:

MM CUL-3.1: Human Remains. If human remains are discovered during project construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section 7050.5 of California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. The project sponsor shall also retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide professional assistance to the Most Likely Descendant, including the excavation and removal of the human remains. The City of Daly City shall be responsible for approval of recommended mitigation as it deems appropriate, taking account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement approved mitigation, to be verified by the City of Daly City, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.

By following the process set forth in MM CUL-3.1, the project would ensure that any human remains encountered during ground-disturbing activities are appropriately identified and treated. (Less than Significant Impact with Mitigation Incorporated)

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3.5.2.2 Cumulative Impacts
Impact CUL-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant cultural resources impact. (Less than Significant Cumulative Impact)
The project would not impact historic resources, and so would not contribute to cumulative impacts to historic resources. With regard to archaeological resources, most development projects in Daly City would require a level of excavation and grading or other activities that may affect archaeological resources, including human remains. Each project is to complete its own literature review, as applicable, to determine the level of archeological and cultural sensitivity of its project site.

However, all projects occurring within Daly City would be required to implement mitigation measures, as applicable, that would avoid impacts and/or reduce them to a less than significant level, consistent with CEQA requirements. Such measures consist of preliminary investigation prior to full excavation, avoidance measures during ground disturbance activities, and/or monitor during ground disturbance activities. Collection and evaluation of finds are also part of these conditions and/or mitigation measures. These projects would also be subject to federal, state, and county laws regulating cultural resources such as protocols of handling human remains, if found on the project site. For these reasons, the proposed project in combination with the cumulative scenario project would not result a significant cultural resources impact. (Less than Significant Cumulative Impact)

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3.6 ENERGY
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2022, is attached to this EIR as Appendix C.

3.6.1 Environmental Setting

3.6.1.1 Regulatory Framework
Federal and State
Energy Star and Fuel Efficiency
At the federal level, energy standards set by the EPA apply to numerous consumer products and appliances (e.g., the EnergyStar™ program). The EPA also sets fuel efficiency standards for automobiles and other modes of transportation.

Renewables Portfolio Standard Program
In 2002, California established its Renewables Portfolio Standard Program, with the goal of increasing the percentage of renewable energy in the state's electricity mix to 20 percent of retail sales by 2010. Governor Schwarzenegger issued Executive Order (EO) S-3-05, requiring statewide emissions reductions to 80 percent below 1990 levels by 2050. In 2008, EO S-14-08 was signed into law, requiring retail sellers of electricity serve 33 percent of their load with renewable energy by 2020. In October 2015, Governor Brown signed SB 350 to codify California’s climate and clean energy goals. A key provision of SB 350 requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from renewable sources by 2030. SB 100, passed in 2018, requires 100 percent of electricity in California to be provided by 100 percent renewable and carbon-free sources by 2045.

Executive Order B-55-18 To Achieve Carbon Neutrality
In September 2018, Governor Brown issued an executive order, EO-B-55-18 To Achieve Carbon Neutrality, setting a statewide goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” The executive order requires CARB to “ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.” EO-B-55-18 supplements EO S-3-05 by requiring not only emissions reductions, but also that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2 from the atmosphere through sequestration.

California Building Standards Code
The Energy Efficiency Standards for Residential and Nonresidential Buildings, as specified in Title 24, Part 6 of the California Code of Regulations (Title 24), was established in 1978 in response to a legislative mandate to reduce California’s energy consumption. Title 24 is updated approximately

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every three years.22 Compliance with Title 24 is mandatory at the time new building permits are issued by city and county governments.23
California Green Building Standards Code
CALGreen establishes mandatory green building standards for buildings in California. CALGreen was developed to reduce GHG emissions from buildings, promote environmentally responsible and healthier places to live and work, reduce energy and water consumption, and respond to state environmental directives. CALGreen covers five categories: planning and design, energy efficiency, water efficiency and conservation, material and resource efficiency, and indoor environmental quality.

Advanced Clean Cars Program
CARB adopted the Advanced Clean Cars program in 2012 in coordination with the EPA and National Highway Traffic Safety Administration. The program combines the control of smogcausing pollutants and GHG emissions into a single coordinated set of requirements for vehicle model years 2015 through 2025. The program promotes development of environmentally superior passenger cars and other vehicles, as well as saving the consumer money through fuel savings.24 Local
City of Daly City General Plan
The City of Daly City’s General Plan includes specific goals and policies to address energy conservation opportunities within the City. All new residential and nonresidential construction in the City must abide by the State of California’s residential building standards for energy efficiency (Title 24 of the California Administrative Code). Title 24 Standards were established in 1978 to ensure that all new construction meets a minimum level of energy efficiency.

Policy/Task Description
Policy HE-23 Gradually increase energy and water efficiency standards for all new and existing housing while minimizing the costs of such standards.

Task HE23.1Develop enhanced residential energy efficiency standards (Title 24, California Administrative Code) in all new residential construction which exceeds Statemandated requirements by five percent in 2015, ten percent in 2020, and twenty percent in 2030.

Task HE23.2Establish energy and water efficiency upgrade programs that promote energy and water efficiency upgrades in all existing residential buildings. Energy efficiency upgrades promoted as part of this program could include upgrades such as attic 22 California Building Standards Commission. “California Building Standards Code.” Accessed December 1, 2021. https://www.dgs.ca.gov/BSC/Codes#@ViewBag.JumpTo. 23 California Energy Commission (CEC). “2019 Building Energy Efficiency Standards.” Accessed December 1, 2021. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2019- building-energy-efficiency. 24 California Air Resources Board. “The Advanced Clean Cars Program.” Accessed December 1, 2021. https://www.arb.ca.gov/msprog/acc/acc.htm.

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Policy/Task Description
insulation, programmable thermostats, heating duct insulation, and water heater insulation. Water efficiency upgrades could include the installation of low-flow shower heads, where feasible, and retrofit of existing toilets to meet low-flush requirements as established by the City. Examples of programs developed as a part of this task could provide financial incentives (e.g., rebates, appliance buy-back, and similar programs) aimed at providing strong incentives to residential building owners to use the programs.

Policy HE-24 Mandate the inclusion of green building techniques into most new construction.

Policy HE-28 Promote alternative sources of energy in all homes.

Daly City’s Green Vision
Daly City’s Green Vision, A Climate Action Plan (CAP) for 2011-2020 and Beyond, was adopted in December 2010. Daly City’s Green Vision guides the City towards a sustainable future that reduces GHG emissions from current levels, while promoting economic prosperity for present and future generations. The Green Vision identifies ten goals and seeks to achieve these goals through costeffective strategies by the year 2020. The GHG reduction goals include adopting a general plan with measurable policies for sustainable development, reducing energy use in buildings, reducing transportation emissions, reducing solid waste disposal, and GHG emissions reductions from municipal operations. Daly City completed an update to the General Plan which incorporated these goals in March 2013.

Daly City Municipal Code
The City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas.25 The City’s Recycling and Diversion of Construction and Demolition ordinance (Municipal Code 15.64) requires that construction and demolition projects recycle or reuse 60 percent of the waste generated from the project. This ordinance is consistent with the requirements for construction and demolition debris diversion in CALGreen. Many of the construction materials, such as concrete, asphalt, asphalt singles, gypsum wallboard, wood and metals, can be reused or recycled, thus prolonging our supply of natural resources and potentially saving money in the process.

3.6.1.2 Existing Conditions
Total energy usage in California was approximately 7,802 trillion British thermal units (Btu) in the year 2019, the most recent year for which this data was available.26 Out of the 50 states, California is ranked second in total energy consumption and 46th in energy consumption per capita. The breakdown by sector was approximately 19 percent (1,456 trillion Btu) for residential uses, 19 percent (1,468 trillion Btu) for commercial uses, 23 percent (1,805 trillion Btu) for industrial uses, 25 City of Daly City. Daly City Municipal Code Ordinance No. 1448. May 10, 2021. 26 United States Energy Information Administration. “State Profile and Energy Estimates, 2019.” Accessed December 1, 2021. https://www.eia.gov/state/?sid=CA#tabs-2.

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and 39 percent (3,073 trillion Btu) for transportation.27 This energy is primarily supplied in the form of natural gas, petroleum, nuclear electric power, and hydroelectric power.

Electricity
Electricity in San Mateo County in 2020 was consumed primarily by the non-residential sector (60 percent), with the residential sector consuming 40 percent. In 2020, a total of approximately 4,167 GWh of electricity was consumed in San Mateo County.28
Peninsula Clean Energy (PCE) is a public and locally controlled electricity provider for the County of San Mateo. Electricity provided by PCE is delivered through PG&E transmission lines.

Commercial and residential customers in San Mateo County are included in the PCE service area and can choose to have 50 to 100 percent of their electricity supplied from carbon-free and renewable sources. Customers are automatically enrolled in the ECOplus plan, which generates its electricity from 100 percent carbon-free sources, with at least 50 percent from renewable sources. Customers have the option to enroll in the ECO100 plan, which generates its electricity from 100 percent carbon-free, renewable sources. 29 The project site currently uses approximately 1.7 GWh of electricity per year.

Natural Gas
PG&E provides natural gas services within the City of Daly City In 2020, approximately two percent of California’s natural gas supply came from in-state production, while the remaining supply was imported from other western states and Canada.30 In 2019 residential and commercial customers in California used 33 percent of the state’s natural gas, power plants used 26 percent, the industrial sector used 35 percent, and other uses used six percent.31 Transportation accounted for one percent of natural gas use in California. In 2019, San Mateo County used approximately nine percent of the state’s total consumption of natural gas.32 The project site currently uses approximately 2,788,100 kBtu of natural gas per year.

Fuel for Motor Vehicles
In 2019 (pre-Covid), 15.4 billion gallons of gasoline were sold in California.33 The average fuel economy for light-duty vehicles (autos, pickups, vans, and sport utility vehicles) in the United States has steadily increased from about 13.1 miles per gallon (mpg) in the mid-1970s to 25.4 mpg in 27 Ibid. 28 California Energy Commission. Energy Consumption Data Management System. “Electricity Consumption by County.” Accessed December 1, 2021. http://ecdms.energy.ca.gov/elecbycounty.aspx. 29 Sources: 1) Peninsula Clean Energy. “Frequently Asked Questions.” Accessed December 1, 2021. https://www.peninsulacleanenergy.com/faq/. 2) Peninsula Clean Energy. “Energy Choices.” Accessed December 1, 2021. https://www.peninsulacleanenergy.com/faq/. 30 California Gas and Electric Utilities. 2020 California Gas Report. Accessed August 2, 2021. https://www.socalgas.com/sites/default/files/2020-
10/2020_California_Gas_Report_Joint_Utility_Biennial_Comprehensive_Filing.pdf. 31 United States Energy Information Administration. “State Profile and Energy Estimates, 2019.” Accessed August 2, 2021. https://www.eia.gov/state/?sid=CA#tabs-2. 32 California Energy Commission. “Natural Gas Consumption by County.” Accessed August 2, 2021. http://ecdms.energy.ca.gov/gasbycounty.aspx. 33 California Department of Tax and Fee Administration. “Net Taxable Gasoline Gallons.” Accessed December 1, 2021. https://www.cdtfa.ca.gov/dataportal/dataset.htm?url=VehicleTaxableFuelDist.

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2020.34 Federal fuel economy standards have changed substantially since the Energy Independence and Security Act was passed in 2007. That standard, which originally mandated a national fuel economy standard of 35 miles per gallon by the year 2020, was updated in March 2020 to require all cars and light duty trucks achieve an overall industry average fuel economy of 40.4 mpg by model year 2026. 35,36 The existing uses vehicles miles traveled (VMT) is estimated to be 1,904,889.37 Assuming a 25.4 mpg, the trips from existing uses require use approximately 75,000 gallons of fuel per year.

3.6.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on energy, would the project:
1) Result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? 2) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?

3.6.2.1 Project Impacts
Impact EN-1: The project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. (Less than Significant Impact) Construction
Construction of the project would require energy for the manufacture and transportation of building materials, site preparation and grading, and construction of the proposed Parcel B Development project and future buildout of the proposed Precise Plan. Construction processes are generally designed to be efficient in order to avoid excess monetary costs. That is, equipment and fuel are not typically used wastefully on the site because of the added expense associated with renting the equipment, as well as maintenance and fuel. In addition, as discussed in Section 3.3 Air Quality, the project would implement mitigation measures to minimize the idling of construction equipment thus reducing the potential for energy waste. Further, the project would recycle at least 60 percent of construction and demolition waste. For these reasons, construction of the project would not use energy in a wasteful manner.

Operational
The proposed project would increase the density/intensity of uses on the site and would result in a net increase in energy use. Operation of the project would consume energy for multiple purposes 34 United States Environmental Protection Agency. “The 2021 EPA Automotive Trends Report: Greenhouse Gas Emissions, Fuel Economy, and Technology since 1975.” November 2021. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1010U68.pdf 35 United States Department of Energy. Energy Independence & Security Act of 2007. Accessed December 1, 2021. http://www.afdc.energy.gov/laws/eisa. 36 Public Law 110–140—December 19, 2007. Energy Independence & Security Act of 2007. Accessed December 1, 2021. http://www.gpo.gov/fdsys/pkg/PLAW-110publ140/pdf/PLAW-110publ140.pdf. 37 Illingworth & Rodkin, Inc. Serramonte Del Rey Campus Redevelopment Project Air Quality and Greenhouse Gas Assessment. June 17, 2022.

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including, building heating and cooling, lighting for the proposed buildings and parking garages, and operation of appliances and electronics. Energy would also be consumed during each vehicle trip generated by residents, visitors, and employees. The project’s estimated energy demand is summarized in Table 3.6-1.

Table 3.6-1: Estimated Annual Project Energy Demand
Net Electricity
(GWh)
Net Natural Gas
(kBtu)
Net Gasoline*
(gallons)
Existing 1.70 2,788,100 75,000
Project 7.65 63,840 734,326
Note: *Gasoline demand was calculated by dividing the project’s estimated VMT by 25.4 mpg (Source:

Illingworth & Rodkin, Inc. Serramonte Del Rey Campus Redevelopment Project Air Quality and Greenhouse Gas Assessment. June 17, 2022.)
To ensure that energy is not wasted or unnecessarily consumed, the project would comply with Title 24 and CALGreen energy efficiency measures, as well as City of Daly City Green Vision requirements and Recycling and Diversion of Construction and Demolition Ordinance. These various requirements would reduce project energy demand by ensuring that the project would be built to current energy efficiency standards, include energy efficient appliances, and reduce construction waste disposal trips. As noted above, the City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas. The project is also on an infill site that encourages alternatives to single-vehicle occupancy trips by being proximate to transit and being on a site adequately served by pedestrian and bicycle facilities. For these reasons, operation of the project would not use energy in a wasteful manner. (Less than Significant Impact) Impact EN-2: The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant Impact) According to the 2019 Integrated Energy Policy Report, the state is working towards decarbonizing the energy system and moving towards a 100 percent carbon-free system by 2045.38 The project would obtain energy from the PCE which provides 50 to 100 percent carbon free electricity to the project site. The project would result in an increase in demand on existing energy resources; however, the project is required to comply with applicable regulations and City policies that would conserve energy and water, and reduce fuel consumption and waste generation. For these reasons, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant Impact)
38 California Energy Commission. 2019 Integrated Energy Policy Report. 2019.

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3.6.2.2 Cumulative Impacts
Impact EN-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant energy impact. (Less than Significant Cumulative Impact)
By its nature, energy is a cumulative resource, and demands on energy supplies are cumulative. Past, present, and future development projects contribute to the state’s energy impacts. If the project is determined to have a significant energy impact, it is concluded that the impact is cumulatively considerable. As discussed under Impact EN-1 and Impact EN-2 above, the project itself would not result in significant energy impacts. Further, all projects in Daly City and adjacent cities are required to meet CALGreen and Title 24 energy efficiency requirements, thus lessening overall energy demand. Therefore, the project would not result in a considerable contribution to a significant cumulative energy impact. (Less than Significant Cumulative Impact)

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3.7 GEOLOGY AND SOILS
The following discussion is based, in part, on a Preliminary Geotechnical Investigation Report prepared for the project by Slate Geotechnical Consultants, Inc. A copy of this report, dated April 20, 2021, is attached to this EIR as Appendix H.

3.7.1 Environmental Setting

3.7.1.1 Regulatory Framework
State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act was passed following the 1971 San Fernando earthquake. The act regulates development in California near known active faults due to hazards associated with surface fault ruptures. Alquist-Priolo maps are distributed to affected cities, counties, and state agencies for their use in planning and controlling new construction. Areas within an Alquist-Priolo Earthquake Fault Zone require special studies to evaluate the potential for surface rupture to ensure that no structures intended for human occupancy are constructed across an active fault.

Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (SHMA) was passed in 1990 following the 1989 Loma Prieta earthquake. The SHMA directs the California Geological Survey (CGS) to identify and map areas prone to liquefaction, earthquake-induced landslides, and amplified ground shaking. CGS has completed seismic hazard mapping for the portions of California most susceptible to liquefaction, landslides, and ground shaking, including the central San Francisco Bay Area. The SHMA requires that agencies only approve projects in seismic hazard zones following site-specific geotechnical investigations to determine if the seismic hazard is present and identify measures to reduce earthquake-related hazards.

California Building Standards Code
The CBC prescribes standards for constructing safe buildings. The CBC contains provisions for earthquake safety based on factors including occupancy type, soil and rock profile, ground strength, and distance to seismic sources. The CBC requires that a site-specific geotechnical investigation report be prepared for most development projects to evaluate seismic and geologic conditions such as surface fault ruptures, ground shaking, liquefaction, differential settlement, lateral spreading, expansive soils, and slope stability. The CBC is updated every three years.

California Division of Occupational Safety and Health Regulations Excavation, shoring, and trenching activities during construction are subject to occupational safety standards for stabilization by the California Department of Industrial Relations, Division of Occupational Safety and Health (Cal/OSHA) under Title 8 of the California Code of Regulations and Excavation Rules. These regulations minimize the potential for instability and collapse that could injure construction workers on the site.

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Public Resources Code Section 5097.5
Paleontological resources are the fossilized remains of organisms from prehistoric environments found in geologic strata. They range from mammoth and dinosaur bones to impressions of ancient animals and plants, trace remains, and microfossils. These materials are valued for the information they yield about the history of the earth and its past ecological settings. California Public Resources Code Section 5097.5 specifies that unauthorized removal of a paleontological resource is a misdemeanor. Under the CEQA Guidelines, a project would have a significant impact on paleontological resources if it would disturb or destroy a unique paleontological resource or site or unique geologic feature.

Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to hazards and hazardous materials and are applicable to the proposed project.

Policy Description
Policy SE-1.1 Continue to investigate the potential for seismic and geologic hazards as part of the development review process and maintain this information for the public record.

Update Safety Element maps as appropriate.

Policy SE-1.2 Require site specific geotechnical, soils, and foundation reports for development proposed on sites identified in the Safety Element and its Geologic and Hazard Maps as having moderate or high potential for ground failure.

Policy SE-1.3 Permit development in areas of potential geologic hazards only where it can be demonstrated that the project will not be endangered by, nor contribute to, the hazardous condition on the site or on adjacent properties. All proposed development is subject to the City's Zoning Ordinance and Building Codes.

Policy SE-1.4 Prohibit development—including any land alteration, grading for roads and structural development—in areas of slope instability or other geologic concerns unless mitigation measures are taken to limit potential damage to levels of acceptable risk.

Policy SE-6.1 Regulate building construction practices to prevent hazardous structures and assure structural safety. Measures may include requiring conformance to an accepted set of construction standards, authorizing inspection of suspected dangerous structures, discontinuing improper construction activities, and eliminating hazardous conditions.

Daly City Municipal Code
Title 15 of the Daly City Municipal Code includes Chapter 15.62 “Grading, Erosion, and Sediment Control”, which is intended to provide for safe grading operations, to safeguard public health and property, and to preserve and enhance the natural environment, including, but not limited to, water quality, by regulating site clearing, grading and erosion control on all public and private properties.

Among other conditions, Chapter 15.62 requires projects to prepare an erosion and sediment control

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plan, an engineering geology report, and when requested, a soil/geotechnical engineering report in order to address geological and soils related hazards and engineering issues.

3.7.1.2 Existing Conditions
Regional Geology
The project site and surrounding area is located within the Coast Ranges physiographic province, a series of northwest-trending mountain ranges and valleys that extend along much of the coastal region of California. Geologic mapping indicates that the project site is underlain by the late Pliocene- to early Pleistocene-age Merced Formation, which consists of weak, friable sandstone, siltstone, and claystone, with local fossiliferous beds that are well-cemented.

Seismicity and Seismic Hazards
The entire San Francisco Bay Area is located within the San Andreas Fault Zone, a complex of active faults with the potential to generate earthquakes of magnitude 7.0 or greater. The overall probability of a magnitude 6.7 or greater earthquake on a fault in the greater Bay Area in the next 30 years is estimated at 63 percent. The closest major active fault segments include the San Andreas Fault Peninsula segment, located 0.6 miles southwest of the project site, the Pilarcitos Fault (located 4.5 miles southwest), the San Gregorio Fault North segment (located five miles southwest), and the Point Reyes Fault (located 6.3 miles west).

The project site is not within an Alquist-Priolo Fault Zone.39 Based on hazard maps prepared for the Daly City General Plan, the project site is projected to experience very violent shaking during a seismic event, is at very low risk of liquefaction, and at moderate risk of landsliding.40 Additionally, as the project site is considered to be at very low risk of liquefaction, it is also considered to be at low risk of lateral spreading.41
Soils and Topography
Based on subsurface borings and cone penetration tests completed in 2019 for the project site, underlying soils are a mixture of fill materials and native soil and weathered rock. Fill materials on site consist of variable compositions of sand, clayey sand, and sandy clay ranging in density from medium dense to very dense and consistency from medium stiff to hard. Fill materials are expected to be up to 140 feet in thickness in areas to the west and south of the existing buildings on-site. The native soil and weathered rock encountered consisted of clayey sand and sandy clay ranging in density and consistency from dense to very dense and stiff to hard. Soils tested during subsurface borings had a Plasticity Index (PI) of six.
39 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Date accessed September 22, 2020. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 40 Liquefaction is a temporary loss of shear strength as a result of increased pore pressure due to strong ground shaking or cyclic loading. Liquefaction is defined by saturation of soil and loss of cohesion. It is associated with loose, high-plasticity soils and near-surface groundwater levels. 41 Lateral spreading typically occurs as a form of horizontal displacement of relatively flat-lying soil toward an open or “free” face such as an open body of water, channel, or excavation. This movement is often associated with liquefaction and commonly occurs on gentle slopes in seismically active regions. Lateral spread presents a significant hazard to the integrity of buildings and other structures.

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The project site underwent mass grading during the original development of the site between 1966 and 1969, with significant cut and leveling of a high knoll on the eastern half of the site, and mass excavation of existing ravine walls up to 80 feet deep and hillside cuts along the western boundary of the site. As a result, the project site overall is southeast sloping, with the western portion of the site featuring a 100-foot high moderately sloped hillside cut that descends to the relatively flat existing Serramonte Del Rey campus, which extends east to a 65- to 50-foot high slope that descends to Callan Boulevard.

Groundwater
No groundwater was encountered during the subsurface borings completed in 2019 on the project site, which extended between 29 and 50 feet below ground surface (bgs). For purposes of this EIR, groundwater in the project area vicinity is projected to flow generally south and east towards the San Francisco Bay at a depth of greater than 50 feet bgs.42 Fluctuations in groundwater levels occur due to many factors including seasonal fluctuation, underground drainage patterns, regional fluctuations, and other factors.

Paleontological Resources
The project site is within the Merced Formation of the Franciscan complex, which was formed during the early to late Pliocene age of the Neogene period, and has a high sensitivity for paleontological resources. At a regional level, the project site is within the Pilarcitos stratigraphic area, which has approximately nine historic fossil collection sites, the closest of which is Mussel Rock, approximately one mile west of the project site. Fossils have been discovered elsewhere in Daly City along the coastline and on the shores of Lake Merced, but have not been discovered inland within Daly City.43 As discussed above, the project site underwent mass grading and is underlain by fill, therefore, paleontological resources are unlikely to be found near the ground surface.

3.7.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on geology and soils, would the project:
1) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
- Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (refer to Division of Mines and Geology Special Publication 42)?
- Strong seismic ground shaking?
- Seismic-related ground failure, including liquefaction? - Landslides?
2) Result in substantial soil erosion or the loss of topsoil? 42 Strata Environmental Services, Inc. Phase I Environmental Site Assessment, Serramonte del Rey Campus.

February 2020.
43 Macrostrat. “Macrostrat Geologic Map”. Accessed September 14, 2021. https://macrostrat.org/map/#/z=1.5/x=16/y=23/bedrock/lines/

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3) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
4) Be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property? 5) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? 6) Directly or indirectly destroy a unique paleontological resource or site or unique geological feature?

3.7.2.1 Project Impacts
Impact GEO-1: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic-related ground failure, including liquefaction; or landslides. (Less than Significant Impact)
Fault Rupture
As discussed under Section 3.7.1.2 Existing Conditions, the project site is not within an AlquistPriolo Fault Zone. As the nearest major active fault segment is located 0.6 miles southwest and no known faults intersect the study area, fault rupture is not anticipated to occur within the project site.

As such, the project would not result in any substantial adverse effects associated with fault ruptures.

Seismic Ground Shaking
As discussed under Section 3.7.1.2 Existing Conditions, the project site is located within the seismically active San Andreas Fault Zone. During a seismic event, the project site may experience very violent ground shaking. Consistent with the findings of the Daly City 2030 General Plan Environmental Impact Report (General Plan EIR), compliance with the building codes and construction standards established by the CBC as required by law would be sufficient to protect against building collapse and major injuries during a seismic event.44 The project would comply with current CBC building codes and standards and be constructed in accordance with the recommendations of a site-specific geotechnical investigation (as required by the CBC) and the engineering geology report prepared as required by Chapter 15.62 of the Daly City Municipal Code.

For these reasons, the project would not result in substantial adverse effects associated with seismic ground shaking.
44 City of Daly City. General Plan Update Draft Environmental Impact Report. October 2012. Page 3.5-15.

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Liquefaction and Lateral Spreading
As discussed under Section 3.7.1.2 Existing Conditions, the project site is at a very low risk of liquefaction, and therefore at low risk of lateral spreading. The Geotechnical Investigation concluded that due to presence of stiff clay zones and the depth of groundwater (> 50 feet bgs), the project site was not at risk of liquefaction and associated effects. Further, the project as previously mentioned would comply with current CBC building codes and standards and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report.

As such, the project would not result in substantial adverse effects associated with liquefaction, lateral spreading, and other related phenomenon.

Landslides
As discussed under Section 3.7.1.2 Existing Conditions, the project site is mapped within an area with a moderate landslide risk. However, no landslide areas or landslide deposits have been mapped in the vicinity of the project site, and debris flow probability maps prepared by San Mateo County show that the area has a very low probability (< five percent) for debris flow failures. Based on bedrock type, landslide susceptibility, and lack of observed landslides in the vicinity, the Geotechnical Investigation (refer to Appendix H) concluded that the site-specific potential for seismically-induced landsliding to occur was low, and provided recommendations addressing the western and eastern slopes. As noted above, the project would comply with current CBC building codes and standards, and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report. The General Plan EIR concluded that compliance with aforementioned codes, standards, and reports would reduce adverse effects associated with seismically induced landslides to a less than significant level.45 (Less than Significant Impact)
Impact GEO-2: The project would not result in substantial soil erosion or the loss of topsoil. (Less than Significant Impact)
Construction-related ground disturbing activities (demolition, grading, excavation, etc.) proposed by the project are expected to result in the exposure of soil to wind and water erosion. If managed improperly, construction could result in substantial soil erosion or loss of topsoil.

The City’s National Pollutant Discharge Elimination System (NPDES) Municipal Permit and Chapter 15.62 of the City’s Municipal Code are the City’s primary means of enforcing erosion control measures through the grading and building permit process. Consistent with the findings of the General Plan EIR, compliance with the erosion control provisions included in the NPDES Municipal Permit and the erosion and sediment control plan required by Chapter 15.62 of the Municipal Code would ensure that the project would not result in substantial soil erosion or loss of topsoil.46 (Less than Significant Impact)
45 Ibid. 46 Ibid. Page 3.5-17.

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Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. (Less than Significant Impact)
As discussed under Impact GEO-1, the Geotechnical Investigation (refer to Appendix H) concluded that the project site is not unstable or likely to become unstable during a seismic event. Furthermore, the project would be required by law to comply with current CBC building codes and standards and be constructed in accordance with the recommendations of the site-specific geotechnical investigation and engineering geology report, which would ensure that the project would not exacerbate the risk of ground failure, including liquefaction, lateral spreading, landsliding, and other related phenomenon. As such, the project would not result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. (Less than Significant Impact) Impact GEO-4: The project would not be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property. (Less than Significant Impact)
Pursuant to the CBC, soils with a PI of 15 or less are not considered expansive, therefore the project would not be located on expansive soil. Additionally, as discussed under Impact GEO-1, the geologic foundation of the project site is at a less than substantial risk of ground failure. By conforming with current CBC building codes and standards and the recommendations of the site-specific geotechnical investigation and the engineering geology report, the project would not create direct or indirect risks to life or property. (Less than Significant Impact)
Impact GEO-5: The project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. (No Impact)
The proposed project would dispose of wastewater via lateral connections to the City’s sewer system and would not require the use of septic tanks or alternative wastewater disposal systems. (No Impact)
Impact GEO-6: The project would not directly or indirectly destroy a unique paleontological resource or site or unique geological feature. (Less than Significant Impact with Mitigation Incorporated)
The project site has previously been extensively developed with the JUHSD campus. Additionally, the project site is not on or adjacent to the Pacific coastline or the shores of Lake Merced where fossils have been previously encountered in Daly City, and there is no evidence of paleontological resources (e.g. the presence of rock outcroppings) on the site. As such, there is a low probability of that the project would result in the discovery of subsurface paleontological resources. Nonetheless, construction-related ground disturbing activities could result in significant impacts, if any unknown unique paleontological resource or site or unique geological feature resources were encountered.

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Mitigation Measure: The project will be required to implement the following mitigation measure to reduce potential impacts to paleontological resources to a less than significant level:

MM GEO-6.1: Unique Paleontological and/or Geologic Features and Reporting. Should a unique paleontological resource or site or unique geological feature be identified at the project site during any phase of construction, all ground disturbing activities within 25 feet shall cease and the City’s Planning Director notified immediately.

A qualified paleontologist shall evaluate the find and prescribe mitigation measures to reduce impacts to a less than significant level. Work may proceed on other parts of the project site while mitigation for paleontological resources or geologic features is implemented. Upon completion of the paleontological assessment, a report shall be submitted to the City and, if paleontological materials are recovered, a paleontological repository, such as the University of California Museum of Paleontology.

Implementation of MM GEO-6.1 would ensure that any paleontological resource or unique geological feature encountered during project construction would be identified and subsequently evaluated and protected in accordance with California Public Resources Code Section 5097.5. As such, impacts to unique paleontological resources would be less than significant. (Less than Significant Impact with Mitigation Incorporated)

3.7.2.2 Cumulative Impacts
Impact GEO-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant geology and soils impact. (Less than Significant Cumulative Impact with Mitigation Incorporated)
The cumulative projects shown in Table 3.0-1 would be subject to similar geology, soils, and seismicity conditions as the proposed project. All cumulative projects occurring within Daly City would implement standard permit conditions related to geologic hazards and would be constructed consistent with the CBC and site-specific geotechnical investigations in order to avoid impacts from seismicity and geology and soils hazards, and/or reduce them to a less than significant level. Projects in the cumulative scenario would also be subject to similar CEQA requirements and mitigation measures as the proposed project with regard to avoidance and lessening of paleontological impacts.

For these reasons, the cumulative projects, including the proposed project, would not result in significant cumulative geology and soils impacts. (Less than Significant Cumulative Impact with Mitigation Incorporated)

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3.8 GREENHOUSE GAS EMISSIONS
The following discussion is based, in part, on an air quality and greenhouse gas assessment prepared for the project by Illingworth & Rodkin, Inc. A copy of this report, dated June 17, 2021, is attached to this EIR as Appendix C.

3.8.1 Environmental Setting

3.8.1.1 Background Information
Gases that trap heat in the atmosphere, GHGs, regulate the earth’s temperature. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate. In GHG emission inventories, the weight of each gas is multiplied by its global warming potential (GWP) and is measured in units of CO2 equivalents (CO2e). The most common GHGs are carbon dioxide (CO2) and water vapor but there are also several others, most importantly methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These are released into the earth’s atmosphere through a variety of natural processes and human activities.

Sources of GHGs are generally as follows:
• CO2 and N2O are byproducts of fossil fuel combustion. • N2O is associated with agricultural operations such as fertilization of crops. • CH4 is commonly created by off-gassing from agricultural practices (e.g., keeping livestock) and landfill operations.
• Chlorofluorocarbons (CFCs) were widely used as refrigerants, propellants, and cleaning solvents, but their production has been stopped by international treaty. • HFCs are now used as a substitute for CFCs in refrigeration and cooling. • PFCs and SF6 emissions are commonly created by industries such as aluminum production and semiconductor manufacturing.

An expanding body of scientific research supports the theory that global climate change is currently causing changes in weather patterns, average sea level, ocean acidification, chemical reaction rates, and precipitation rates, and that it will increasingly do so in the future. The climate and several naturally occurring resources within California are adversely affected by the global warming trend.

Increased precipitation and sea level rise will increase coastal flooding, saltwater intrusion, and degradation of wetlands. Mass migration and/or loss of plant and animal species could also occur.

Potential effects of global climate change that could adversely affect human health include more extreme heat waves and heat-related stress; an increase in climate-sensitive diseases; more frequent and intense natural disasters such as flooding, hurricanes and drought; and increased levels of air pollution.

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3.8.1.2 Regulatory Framework
State
Assembly Bill 32
Under the California Global Warming Solutions Act, also known as AB 32, CARB established a statewide GHG emissions cap for 2020, adopted mandatory reporting rules for significant sources of GHGs, and adopted a comprehensive plan, known as the Climate Change Scoping Plan, identifying how emission reductions would be achieved from significant GHG sources.

In 2016, SB 32 was signed into law, amending the California Global Warming Solution Act. SB 32, and accompanying Executive Order B-30-15, require CARB to ensure that statewide GHG emissions are reduced to 40 percent below the 1990 level by 2030. CARB updated its Climate Change Scoping Plan in December of 2017 to express the 2030 statewide target in terms of million metric tons of CO2e (MMTCO2e). Based on the emissions reductions directed by SB 32, the annual 2030 statewide target emissions level for California is 260 MMTCO2e.

Senate Bill 375
SB 375, known as the Sustainable Communities Strategy and Climate Protection Act, was signed into law in September 2008. SB 375 builds upon AB 32 by requiring CARB to develop regional GHG reduction targets for automobile and light truck sectors for 2020 and 2035. The per capita GHG emissions reduction targets for passenger vehicles in the San Francisco Bay Area include a seven percent reduction by 2020 and a 15 percent reduction by 2035.

Consistent with the requirements of SB 375, the Metropolitan Transportation Commission (MTC) partnered with the Association of Bay Area Governments (ABAG), BAAQMD, and the Bay Conservation and Development Commission to prepare the region’s Sustainable Communities Strategy (SCS) as part of the Regional Transportation Plan process. The SCS is referred to as Plan Bay Area 2050. Plan Bay Area 2050 establishes a course for reducing per capita GHG emissions through the promotion of compact, high-density, mixed-use neighborhoods near transit, particularly within identified Priority Development Areas (PDAs).

Regional
2017 Clean Air Plan
To protect the climate, the 2017 CAP (prepared by BAAQMD) includes control measures designed to reduce emissions of methane and other super-GHGs that are potent climate pollutants in the nearterm, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.

CEQA Air Quality Guidelines
The BAAQMD’s CEQA Air Quality Guidelines do not use quantified thresholds for projects that are in a jurisdiction with a qualified GHG reductions plan (i.e., a Climate Action Plan). The plan has to address emissions associated with the period that the project would operate (e.g., beyond year 2020).

For quantified emissions, the guidelines recommended a GHG threshold of 1,100 metric tons or 4.6 metric tons (MT) per capita. These thresholds were developed based on meeting the 2020 GHG

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targets set in the scoping plan that addressed AB 32. Development of the project would occur beyond 2020, so a threshold that addresses a future target is appropriate. Although BAAQMD has not published a quantified threshold for 2030 yet, this EIR utilizes an efficiency metric of 2.8 MT CO2e/year/service population and a bright-line threshold of 660 MT CO2e/year based on the GHG reduction goals of EO B-30-15. The service population metric of 2.8 is calculated for 2030 based on the 1990 inventory and the projected 2030 statewide population and employment levels. The 2030 bright-line threshold is a 40 percent reduction of the 2020 1,100 MT CO2e/year threshold.

Local
Daly City General Plan
The Housing Element of the City’s General Plan contains policies, recommendations, and actions to promote energy conservation. Through energy conservation, GHG emissions are reduced. All future development allowed by the project would be subject to conformance with applicable General Plan policies, including the policy listed below.

Policy Description
Policy HE-23 Gradually increase energy and water efficiency standards for all new and existing housing while minimizing the costs of such standards.

Policy HE-24 Mandate the inclusion of green building techniques into most new construction.

Policy HE-28 Promote alternative sources of energy in all homes.

Daly City’s Green Vision
Daly City’s Green Vision, A Climate Action Plan (CAP) for 2011-2020 and Beyond, was adopted in December 2010. Daly City’s Green Vision guides the City towards a sustainable future that reduces GHG emissions from current levels, while promoting economic prosperity for present and future generations. The Green Vision identifies ten goals and seeks to achieve these goals through costeffective strategies by the year 2020. The GHG reduction goals include adopting a general plan with measurable policies for sustainable development, reducing energy use in buildings, reducing transportation emissions, reducing solid waste disposal, and GHG emissions reductions from municipal operations. Daly City completed an update to the General Plan which incorporated these goals in March 2013.

Daly City Municipal Code
The following ordinances consistent with the goals of Daly City’s Green Vision were adopted by the City Council in order to protect the environment and health of the community:

Ordinance 1448: This ordinance requires all new residential buildings to be all electric and use no natural gas.47
47 City of Daly City. Daly City Municipal Code Ordinance No. 1448. May 10, 2021.

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Green Building Standards Code (Municipal Code 15.22): The purpose of the ordinance is to adopt and incorporate the California Green Building Standards Code, 2013 edition, for the protection of the public health and safety of its inhabitants.

Recycling and Diversion of Construction and Demolition (Municipal Code 15.64): This ordinance requires that construction and demolition projects recycle or reuse 60 percent of the waste generated from the project. This ordinance is consistent with the requirements for construction and demolition debris diversion in CALGreen. Many of the construction materials, such as concrete, asphalt, asphalt singles, gypsum wallboard, wood and metals, can be reused or recycled, thus prolonging our supply of natural resources and potentially saving money in the process.

3.8.1.3 Existing Conditions
GHG emissions are generated from vehicles entering and leaving the site and from heating, cooling, and lighting of the existing buildings, as well as water used by current site users and wastewater generated on-site. The project site currently generates approximately 1,093 MT of CO2e annually.

For the purposes of this analysis, the Parcel A development project is assumed to be not built/occupied; therefore, it is not included in existing conditions. Parcel A is included as part of the operational emissions for the proposed project.

3.8.2 Impact Discussion
For the purpose of determining the significance of the project’s impact on greenhouse gas emissions, would the project:
1) Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
2) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs?

3.8.2.1 Project Impacts
Impact GHG-1: The project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant Impact)
GHG emissions associated with the project would occur over the short-term from construction activities, as well as operational emissions over the long term (associated with vehicular traffic within the project vicinity, the generator, energy and water usage, wastewater, and solid waste disposal). GHG emissions for the proposed project were analyzed using the methodology recommended in the BAAQMD CEQA Air Quality Guidelines. CalEEMod was used to predict GHG emissions from the project (as detailed in Appendix C).

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Construction Emissions
GHG emissions associated with construction of Parcel B-F, based on construction data provided by the project applicant, were computed by CalEEMod to be 3,101 MT of CO2e. These are the emissions from on-site operation of construction equipment, vendor and hauling truck trips, and worker trips. Neither the City nor BAAQMD have an adopted threshold of significance for construction-related GHG emissions, though BAAQMD recommends quantifying emissions and disclosing that GHG emissions would occur during construction. For these reasons, any impact would be less than significant.

Operational Emissions
Project operation would generate GHGs primarily through electricity generation/use and generation of vehicle trips. At full buildout and occupancy of the Precise Plan Parcels A-F, net operational GHG emissions from the project are estimated to be 5,585 MT of CO2e for 2030, which exceeds the 2030 BAAQMD threshold of 660 MT/year of CO2e (see Table 3.8-1). Land use projects with emissions above the 660 MT/year threshold are then subject to the GHG efficiency threshold of 2.8 MT per year per capita (MT/year/capita) to determine impact significance. For purposes of calculating per service population emissions, gross project GHG emissions are used, rather than the net GHGs used for establishing ‘brightline’ emissions. The project service population efficiency rate is based on the number of future residents. For this project, the number of future residents was estimated by multiplying the total number of units (i.e., 1,235 units) by the persons per household rate for the City of Daly City found in the California Department of Finance Population and Housing Estimate report.48 Using the 3.33-person per household 2020 rate, the number of future residents was estimated to be 4,113 residents.

Table 3.8-1: Annual GHG Emissions (CO2e) in Metric Tons Source Category Existing Conditions
in 2022
Proposed Project
in 2030
Area 0 15
Energy Consumption 311 3
Mobile 684 6,315
Solid Waste Generation 55 295
Water Usage 43 50
Total 1,093 6,678
Net Emissions 5,585
Significance Threshold 660
Per Service Population Emissions
(MT of CO2e/year/service population)

1.62 Significance Threshold 2.8
48 State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2021 with 2010 Census Benchmark. Sacramento, California. Accessed May 5, 2022. https://dof.ca.gov/forecasting/demographics/estimates/estimates-e5-2010-2021/.

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Table 3.8-1: Annual GHG Emissions (CO2e) in Metric Tons Source Category Existing Conditions
in 2022
Proposed Project
in 2030
(MT of CO2e/year/service population)
Threshold Exceeded? No
As shown in Table 3.8-1, the proposed project would not exceed the per capita 2030 threshold of 2.8 MT of CO2e/year/service population; therefore, the project would meet the GHG reduction target set by SB 32 and not result in a significant GHG emissions impact. (Less than Significant Impact) Impact GHG-2: The project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. (Less than Significant Impact)
2017 Climate Action Plan
As discussed in Section 3.3 Air Quality, the project is consistent with the 2017 CAP because it supports the primary goals of the 2017 CAP (by providing increased density in a transit priority area) and does not exceed thresholds for greenhouse gas emissions (see Table 3.8-1 above).

Daly City General Plan
The project would be consistent with the City’s General Plan policies [specifically Policy HE-23 of increasing energy efficiency standards in new and existing housing developments], Green Vision, and Green Building Ordinance because the project proposes to be constructed in compliance with the current California Green Building Standards Code (Title 24), which requires efficient windows, insulation, lighting, ventilation systems, and other features that reduce water and energy consumption. As noted previously, the City recently adopted Ordinance 1448, which requires all new residential buildings to be all electric and use no natural gas, which would further reduce GHG emissions.

The project would comply with the requirements of the Green Building Ordinance and the Title 24 Building Code, which requires proposed buildings to be constructed with various measures that would reduce GHG emissions from the project. For this reason, the project would be consistent with the City’s General Plan, Green Vision, and Green Building Ordinance. (Less Than Significant Impact)

3.8.2.2 Cumulative Impacts
Impact GHG-C: The project would not result in a cumulatively considerable contribution to a cumulatively significant GHG emissions impact. (Less than Significant Cumulative Impact)
GHG emissions have a broader, global impact; therefore, if a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable. As discussed in Impact

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GHG-1, the project would not result in significant GHG impacts by the year 2030 and would meet the GHG reduction target set by SB 32. Therefore, the project would not have a cumulatively considerable contribution to a significant cumulative GHG emissions impact. (Less than Significant Cumulative Impact)

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3.9 HAZARDS AND HAZARDOUS MATERIALS
The following discussion is based, in part, on a Phase I Environmental Site Assessment (ESA) prepared for the project by Strata Environmental Services, Inc. A copy of this report, dated February 2020, is attached to this EIR as Appendix I.

3.9.1 Environmental Setting

3.9.1.1 Regulatory Framework
Overview
The storage, use, generation, transport, and disposal of hazardous materials and waste are highly regulated under federal and state laws. In California, the EPA has granted most enforcement authority over federal hazardous materials regulations to the California Environmental Protection Agency (CalEPA). In turn, local agencies have been granted responsibility for implementation and enforcement of many hazardous materials regulations under the Certified Unified Program Agency (CUPA) program.

Worker health and safety and public safety are key issues when dealing with hazardous materials.

Proper handling and disposal of hazardous material is vital if it is disturbed during project construction. Cal/OSHA enforces state worker health and safety regulations related to construction activities. Regulations include exposure limits, requirements for protective clothing, and training requirements to prevent exposure to hazardous materials. Cal/OSHA also enforces occupational health and safety regulations specific to lead and asbestos investigations and abatement.

Federal and State
Federal Aviation Regulations Part 77
Federal Aviation Regulations, Part 77 Objects Affecting Navigable Airspace (FAR Part 77) sets forth standards and review requirements for protecting the airspace for safe aircraft operation, particularly by restricting the height of potential structures and minimizing other potential hazards (such as reflective surfaces, flashing lights, and electronic interference) to aircraft in flight. These regulations require that the Federal Aviation Administration (FAA) be notified of certain proposed construction projects located within an extended zone defined by an imaginary slope radiating outward for several miles from an airport’s runways, or which would otherwise stand at least 200 feet in height above the ground.

Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, is the principal federal law in the United States governing the disposal of solid waste and hazardous waste. RCRA gives the EPA the authority to control hazardous waste from the "cradle to the grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also sets forth a framework for the management of non-hazardous solid wastes.

The Federal Hazardous and Solid Waste Amendments (HSWA) are the 1984 amendments to RCRA that focused on waste minimization, phasing out land disposal of hazardous waste, and corrective

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action for releases. Some of the other mandates of this law include increased enforcement authority for the EPA, more stringent hazardous waste management standards, and a comprehensive underground storage tank program.49
Government Code Section 65962.5
Section 65962.5 of the Government Code requires CalEPA to develop and update a list of hazardous waste and substances sites, known as the Cortese List. The Cortese List is used by state and local agencies and developers to comply with CEQA requirements. The Cortese List includes hazardous substance release sites identified by the Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB).50
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) of 1976 provides the EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics, and pesticides. The TSCA addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon, and leadbased paint.

California Accidental Release Prevention Program
The California Accidental Release Prevention (CalARP) Program aims to prevent accidental releases of regulated hazardous materials that represent a potential hazard beyond the boundaries of a property. Facilities that are required to participate in the CalARP Program use or store specified quantities of toxic and flammable substances (hazardous materials) that can have off-site consequences if accidentally released. The San Mateo County Environmental Health Department reviews CalARP risk management plans as the CUPA.

Asbestos-Containing Materials
Friable asbestos is any asbestos-containing material (ACM) that, when dry, can easily be crumbled or pulverized to a powder by hand, allowing the asbestos particles to become airborne. Common examples of products that have been found to contain friable asbestos include acoustical ceilings, plaster, wallboard, and thermal insulation for water heaters and pipes. Common examples of nonfriable ACMs are asphalt roofing shingles, vinyl floor tiles, and transite siding made with cement.

The EPA phased out use of friable asbestos products between 1973 and 1978. National Emission Standards for Hazardous Air Pollutants (NESHAP) guidelines require that potentially friable ACMs be removed prior to building demolition or remodeling that may disturb the ACMs. 49 United States Environmental Protection Agency. “Summary of the Resource Conservation and Recovery Act.” Accessed May 11, 2020. https://www.epa.gov/laws-regulations/summary-resource-conservation-and-recovery-act. 50 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed May 28, 2020. https://calepa.ca.gov/sitecleanup/corteselist/.

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CCR Title 8, Section 1532.1
The United States Consumer Product Safety Commission banned the use of lead-based paint in 1978.

Removal of older structures with lead-based paint is subject to requirements outlined by the Cal/OSHA Lead in Construction Standard, CCR Title 8, Section 1532.1 during demolition activities.

Requirements include employee training, employee air monitoring, and dust control. If lead-based paint is peeling, flaking, or blistered, it is required to be removed prior to demolition.

Regional and Local
Municipal Regional Permit Provision C.12.f
Polychlorinated biphenyls (PCBs) were produced in the United States between 1955 and 1978 and used in hundreds of industrial and commercial applications, including building and structure materials such as plasticizers, paints, sealants, caulk, and wood floor finishes. In 1979, the EPA banned the production and use of PCBs due to their potential harmful health effects and persistence in the environment. PCBs can still be released to the environment today during demolition of buildings that contain legacy caulks, sealants, or other PCB-containing materials.

With the adoption of the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit (MRP) by the San Francisco Bay Regional Water Quality Control Board on November 19, 2015, Provision C.12.f requires that permittees develop an assessment methodology for applicable structures planned for demolition to ensure PCBs do not enter municipal storm drain systems.51 Municipalities throughout the Bay Area are currently modifying demolition permit processes and implementing PCB screening protocols to comply with Provision C.12.f. Buildings constructed between 1950 and 1980 that are proposed for demolition must be screened for the presence of PCBs prior to the issuance of a demolition permit. Single family homes and wood-frame structures are exempt from these requirements.

San Mateo County Comprehensive Airport Land Use Plan
Daly City is within the jurisdiction of the San Francisco Airport (SFO) Land Use Plan component of the San Mateo County Comprehensive Airport Land Use Compatibility Plan (ALUCP), adopted in December 1996 and updated in 2001. Established in the CLUP are procedures used by the San Mateo City and County Association of Governments (C/CAG) to review land use decisions in the vicinity of San Mateo County airports. Airport planning boundaries define where height, noise and safety standards, policies, and criteria are applied to certain proposed land use policy actions.

Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to hazards and hazardous materials and are applicable to the proposed project.
51 California Regional Water Quality Control Board. San Francisco Bay Region Municipal Regional Stormwater NPDES Permit. November 2015.

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Policy/Task Description
Policy LU-18 Development activities shall not be allowed to significantly disrupt the natural or urban environment and all reasonable measures shall be taken to identify and prevent or mitigate potentially significant effects.

Task LU-18.1 Ensure that potentially significant environmental impacts associated with development proposals are properly mitigated through conditions of approval, mitigation measures, project design, or project denial. In cases where the impacts may not be completely preventable but will not significantly disrupt the community, the City may recognize that the benefits of a project may outweigh the environmental consequences. In no case shall the City approve a project that endangers the health, safety, or welfare of the public.

Policy SE-4.1 Support efforts to locate, regulate, and maintain information regarding hazardous materials located or transported within the City.

Policy SE-4.2 Cooperate with the County of San Mateo in the regulation of hazardous materials and transportation in the Fire Prevention Services Bureau within the City.

Policy SE-4.6 Require the preparation of a risk assessment to determine site suitability for applications for hazardous materials waste management facilities. Establish the distance requirements for these facilities from public assembly, residential or immobile population and recreation areas and structures. Access impacts from seismic, geologic, and flood hazards, impacts on wetlands, endangered species, air quality and emergency response capabilities; and proximity to major transport routes.

3.9.1.2 Existing Conditions
Strata Environmental Services, Inc. conducted a review of aerial photographs, County Assessor’s Office records, historical city directories, and agency records to obtain information about the historical uses of the project site. As part of the Phase I Environmental Assessment, records from federal, state, and local agencies were reviewed, and a site reconnaissance was completed to determine any potentially hazardous materials conditions affecting the project site. The historical uses and potential sources of contamination on the project site are discussed below.

Site History
Prior to 1966, the project site was pastureland. Between 1966 and 1969, the site was graded heavily and developed with a portion of the existing JUHSD campus, including the main campus, storage bungalows, and one 1,000-gallon and one 500-gallon underground storage tanks (USTs) that were used for storing waste products, including acid. The use of these USTs ceased in 1979 but remain onsite. Between 1969 and 2002, the site was developed with a General Education Department building (constructed in 1982), two one-story portables (constructed in 1998) and a Comcast relay station (constructed in 2002).

The JUHSD currently uses the site to provide administrative services and teach English and General/Adult Education classes. Other users of the site include Delucca’s Tae Kwon Do, Headstart, Young World Preschool, Nemenzo Performing Arts, the Homenetmen Armenian General Athletic Union and Scouts, and religious groups including the Catholic Youth Organization (CYO). The CYO

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

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

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

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

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

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

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

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

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

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

Mitigation Measure:

MM HAZ-2.1: Prior to the issuance of demolition, grading, or building permits for projects on Parcels C-E, the applicant shall remove the existing underground storage tanks (USTs) and aboveground storage tanks (ASTs) in accordance with the San Mateo County Department of Environmental Health’s (SMCDEH) Underground Storage Tank Program and Aboveground Petroleum Storage Tank Program. During removal of the ASTs and USTs, contractors shall observe for staining and spilled contaminants. If stains and/or spills are observed, an Environmental Professional shall be retained to collect soil samples for laboratory analysis in accordance with commonly accepted environmental protocols. If contaminants are identified at concentrations exceeding applicable screening levels published by the RWQCB, DTSC and/or EPA53, appropriate mitigation measures, such as, but not limited to, a Soil Management Plan and Health Safety Plan, shall be incorporated into the 53 Note that naturally occurring background concentrations of metals, such as arsenic, amongst others, in soil may exceed their respective screening levels. Regulatory agencies generally do not require cleanup of soil to below background concentrations. Thus, concentrations of metals are compared to regional published background concentrations to establish if regulatory agency approval is warranted.

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demolition permit. Approval by an appropriate regulatory agency (i.e., RWQCB, DTSC or SMCDEH) shall be obtained prior to conducting earthwork activities in the vicinity of the impacted soil. The applicant shall provide documentation of the safe removal of all existing USTs and ASTs consistent with SMCDEH requirements to Director of Economic and Community Development or Director’s designee for review and approval.

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

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

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

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

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

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

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

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

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

Operation
As discussed under Impact HAZ-1, the proposed residential and commercial uses would not routinely transport, use, or dispose of hazardous materials beyond small quantities of diesel fuel, cleaning supplies, maintenance chemicals, and herbicides and pesticides, all of which would be stored and managed in accordance with existing federal and state laws and regulations (refer to Section 3.9.1.1 Regulatory Framework). Accordingly, operation of the project would not create a significant hazard to the public or the environment due to the release of hazardous materials into the environment. (Less than Significant Impact with Mitigation Incorporated) Impact HAZ-3: The project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. (Less than Significant Impact with Mitigation Incorporated)
The project site is within a quarter mile of one existing school, the Summit Shasta Charter School, which is located at 905 Campus Drive adjacent to the plan area. The project’s proposed residential and commercial uses would not emit hazardous emissions, and as discussed under Impact HAZ-1 and Impact HAZ-2, compliance with federal, state, and county regulations (refer to Section 3.9.1.1 Regulatory Framework) and implementation of MM HAZ-2.1 would ensure that hazardous materials used during construction and operation of the project’s proposed residential and commercial uses would not create a significant hazard to the public or environment. (Less Than Significant Impact with Mitigation Incorporated)

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

As noted in Section 3.9.1.1 Regulatory Framework, FAR Part 77 sets forth standards and review requirements for protecting the airspace for safe aircraft operation, particularly by restricting the height of potential structures and minimizing other potential hazards (such as reflective surfaces, flashing lights, and electronic interference) to aircraft in flight. These regulations require that the FAA be notified of certain proposed construction projects located within an extended zone defined by an imaginary slope radiating outward for several miles from an airport’s runways, or which would otherwise stand at least 200 feet in height above ground. The project site is located on terrain that is 200 feet or greater above ground level. As such, the project is required to file FAA Form 7460-1, Notice of Proposed Construction or Alteration with the FAA at least 30 days prior to construction so that the project can be reviewed for aviation compatibility, or a signed exemption form pursuant to 14 CFR Part 77.9(b) be submitted prior to construction. On July 22, 2021, the Board of Directors of the San Mateo County Airport Land Use Commission determined that the proposed Precise Plan (including the Parcel B Development project) is consistent with the SFO ALUCP and FAR Part 77 regulations. (Less Than Significant Impact)
Impact HAZ-6: The project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. (Less than Significant Impact)
The proposed project would not impair or physically interfere with any adopted emergency response or evacuation plan. All project development would be constructed to comply with all applicable state and local building and fire codes. During construction and operation, roadways would not be blocked such that emergency vehicles would be unable to access the site or surrounding properties. Existing pedestrian walkways, bike paths, and handicap access pathways would be maintained. During

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

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

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

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

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

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

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

3.10.1 Environmental Setting

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

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

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

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

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

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

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

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

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Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to hydrology and water quality and are applicable to the proposed project.

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

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

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

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

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

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

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

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

14.

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

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

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

3.10.1.2 Existing Conditions
Hydrology and Drainage
The project site is located within the Colma Creek Watershed, which drains to the San Francisco Bay Area via Colma Creek, the majority of which is either channelized or underground to allow for urban development.57
The project site overall is southeast sloping, with the western portion of the site featuring a 100-foot high moderately sloped hillside cut that descends to the relatively flat existing Serramonte Del Rey campus, which extends east to a 65- to 50-foot high slope that descends to Callan Boulevard. Surface runoff on-site is collected in drains or inlets and conveyed via below grade pipes to the storm drain outfall, which is located in the existing parking lot near the main vehicular entrance at Serramonte Boulevard. The outfall discharges to an existing 24-inch storm drain main in Serramonte Boulevard that flows northeast before being discharged into Colma Creek, approximately 1.3 miles east of the project site.

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

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

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

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

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

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

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

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

February 2020.

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

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

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

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

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

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

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

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

December 2021. Page 4-3.

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

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

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

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

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

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

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3.11 LAND USE AND PLANNING

3.11.1 Environmental Setting

3.11.1.1 Regulatory Framework
Local
Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. All future development allowed by the project would be subject to conformance with applicable General Plan policies, including those listed below.

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

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

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

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

Zoning Ordinance
Similar to the General Plan Designation, the majority of the project site is zoned PD-31 (Planned Development District) while a smaller portion of the site in the northwest corner (Parcel A Development project) is zoned to PD-31A. The PD-31 zoning is the current 1985 Precise Plan for the project site, which allows for the development of up to 175 residential units and approximately 700,000 square feet of office space. The PD-31A zoning was specifically created to allow for the

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

Existing Land Uses
The northwest corner of the project site has been developed with the approved Parcel A Development project (JUHSD Faculty and Staff Housing project). The northeast corner of the project site (Parcel B) is currently developed with a surface parking lot and portable building units. The southwest corner of the project site is developed with the JUHSD demonstration garden. The remainder of the project site it developed with surface parking lots and a one- to two-story concrete building that serves as the existing JUHSD district office and adult education buildings.

Surrounding Land Uses
The project site is surrounded by residential development to the north, northeast, south, and west.

The residences to the north and northeast are two- to three-story apartment buildings made of stucco and wood construction. The residences to the south (Serramonte Ridge Apartment Homes) are threeto four-story apartment buildings also made of stucco and wood construction. The residences to the west are two-story, single-family homes made of wood construction.

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

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

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

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

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

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

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

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

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

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

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

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3.12 MINERAL RESOURCES

3.12.1 Environmental Setting

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Daly City 2030 General Plan
The General Plan includes policies for the purpose of avoiding or mitigating impacts resulting from development projects within the City. The following policies are specific to noise and vibration impacts and are applicable to the proposed project.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.13-2 below.

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

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

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

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

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

3.13.2.1 Project Impacts
Impact NOI-1: The project would not result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant Impact with Mitigation Incorporated)
Construction Noise
Construction of the proposed project would include demolition of existing structures, excavation and grading, and construction of new buildings. The majority of construction noise would be generated by the operation of equipment and heavy machinery, such as bull dozers, backhoes, and auger drills.

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

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

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

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

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

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

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

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

Mitigation Measure:

MM NOI-1.1: The applicant shall develop a construction noise control plan for each construction phase, including, but not limited to, the following available controls:
• Construct temporary noise barriers, where feasible, to screen stationary noisegenerating equipment. Temporary noise barrier fences would provide a 5 dBA noise reduction if the noise barrier interrupts the line-of-sight between the noise source and receptor and if the barrier is constructed in a manner that eliminates any cracks or gaps.
• Equip all internal combustion engine-driven equipment with intake and exhaust mufflers that are in good condition and appropriate for the equipment.
• Unnecessary idling of internal combustion engines should be strictly prohibited.
• Locate stationary noise-generating equipment, such as air compressors or portable power generators, as far as possible from sensitive receptors as feasible. If they must be located near receptors, adequate muffling (with enclosures where feasible and appropriate) shall be used to reduce noise levels at the adjacent sensitive receptors. Any enclosure openings or venting shall face away from sensitive receptors.
• Utilize "quiet" air compressors and other stationary noise sources where technology exists.
• Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noisesensitive receptors nearest the project site during all project construction. • Locate material stockpiles, as well as maintenance/equipment staging and parking areas, as far as feasible from residential receptors. • Route construction-related traffic along major roadways and as far as feasible from sensitive receptors.

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• Locate material stockpiles, as well as maintenance/equipment staging and parking areas, as far as feasible from residential receptors. • Control noise from construction workers’ radios to a point where they are not audible at existing residences bordering the project site. • The contractor shall prepare a detailed construction schedule for major noisegenerating construction activities. The construction plan shall identify a procedure for coordination with adjacent residential land uses so that construction activities can be scheduled to minimize noise disturbance. • Designate a "disturbance coordinator" who would be responsible for responding to any complaints about construction noise. The disturbance coordinator will determine the cause of the noise complaint (e.g., bad muffler, etc.) and will require that reasonable measures be implemented to correct the problem. Conspicuously post a telephone number for the disturbance coordinator at the construction site and include in it the notice sent to neighbors regarding the construction schedule.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.13.3 Non-CEQA Effects
Per California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal. 4th 369 (BIA v. BAAQMD), effects of the environment on the project are not considered CEQA impacts. The following discussion is included for informational purposes because the City of Daly City has policies that address existing noise conditions affecting a proposed project.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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3.14 POPULATION AND HOUSING

3.14.1 Environmental Setting

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

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

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

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

October 21, 2021. Page 20.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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3.15 PUBLIC SERVICES

3.15.1 Environmental Setting

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

March 2022.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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3.16 RECREATION

3.16.1 Environmental Setting

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.17.1 Environmental Setting

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

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

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

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

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