Agenda, regular meeting, second session — San Bruno City Council, January 24, 2023 (part 3 of 8)

Control District, revised as follows:

San Mateo County Flood and Sea Level Rise Resiliency Control District The San Mateo County Flood and Sea Level Rise Resiliency District (formerly known as the San Mateo County Flood Control District) provides financing for flood control projects and manages the larger network of pipes, trenches, culverts, detention basins, and open channels throughout the district. There are three active flood control zones within this district: Colma Creek, San Bruno Creek, and San Francisquito Creek. The Colma and San Bruno zones intersect the City of San Bruno.

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San Bruno’s storm drain system prevents flooding by channeling stormwater runoff into San Mateo County Flood and Sea Level Rise Resiliency Control District channels, which then funnel the water to the San Francisco Bay. However, this runoff is not treated, and can deliver pollutants to the Bay from any impermeable surface within the City. Stormwater runoff accounts for up to 80 percent of the pollution entering San Francisco Bay, and can contain the following pollutants: oil, grease, or antifreeze from leaking cars or trucks; paint or paint products; leaves or yard waste; pesticides; 2023-2031 Housing Element Update 13 Responses to Comments Memorandum City of San Bruno January 2023
herbicides, or fertilizers from yards and gardens; solvents and household chemicals; animal wastes, litter, or sewer leakage; and construction debris such as fresh concrete, mortar, or cement.

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All of the Housing Opportunity Sites are located within AIA Area B of SFO and the associated ALUCP. As discussed in Section 4.13.1.1, residential land uses are considered conditionally compatible with noise levels between 65 and 70 dB CNEL, and generally incompatible with noise levels in excess of 70 dB CNEL. As shown on Figure 4.13-2, Housing Opportunity Sites 14, 15, 18, and 19, and 21 would be located within the 70-75 dB CNEL noise contour; the remaining sites are located outside of the boundary of the 70 dB CNEL noise contour and therefore would not be exposed to excessive noise levels.

Future residential development at Sites 14, 15, 18, and 19, and 21 would be required by the California Building Standards Code (Title 24), ALUCP (Policy NP-4) and San Bruno General Plan (Policy HS-35) to achieve an interior noise level of 45 dB CNEL or less. For residential structures exposed to aircraft noise above CNEL 60 dB, Title 24, Part 2 of the California Building Standards Code requires an acoustical analysis is required to demonstrate compliance with this requirement.

Since Sites 15, 18, and 21 were zoned for residential use as of the effective date of the SFO ALUCP (November 8, 2012), future residential development at these sites is considered compatible with the SFO ALUCP and residents at these sites would not be exposed to excessive noise levels with adherence to the aforementioned regulations. Although Sites 14 and 19 are located in the 70-75 dB CNEL contour and development of housing on these sites would require a Local Agency Override of the ALUCP (refer to the discussion in Section 2.5.3), the Noise and Vibration Assessment (refer to Appendix B and the discussion under Impact NOI-3 in Section 4.13 of this Initial Study) determined that future residential development at Sites 14 and 19 would be able to achieve a 45 dB CNEL interior as required by Airport Land Use Compatibility Policy NP-4 and General Plan Policy HS-35.

Furthermore, Title 24 and General Plan Policy HS-35 would prohibit the issuance of occupancy permits for residential development that would expose future residents to an interior noise level of greater than 45 dB CNEL. Accordingly, the Housing Element Update’s incompatibility with the noise compatibility policies provided in the ALUCP would not result in the exposure of future residents of Sites 14 and 19 to excessive noise levels.

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follows:

See Appendix C of this Memorandum for the revised version of Figure 4.13-2, which now shows the 2020 noise contours provided in the SFO ALUCP as opposed to the 2001 noise contours. 2023-2031 Housing Element Update 14 Responses to Comments Memorandum City of San Bruno January 2023
SECTION 4.0 CONCLUSION
The comments received on the IS/MND did not raise any new issues about the project’s environmental impacts or provide information indicating the project would result in new environmental impacts or impacts substantially greater in severity than disclosed in the IS/MND.

Minor revisions were added to the text of the IS/MND (refer to Section 3.0 IS/MND Text Revisions).

The text revisions do not constitute a “substantial revision” pursuant to CEQA Guidelines §15073.5 and recirculation of the MND is not required.

Appendix A: IS/MND Comment Letters
January 9, 2023

TRANSMITTED VIA E-MAIL
[email protected]
Michael Smith
Senior Planner
City of San Bruno
567 El Camino Real
San Bruno, California 94066
Subject: Comment Letter on IS/MND for City of San Bruno 2023-2031 Housing Element Update San Francisco International Airport (SFO or the Airport) staff have reviewed the City of San Bruno’s (City) Initial Study/Mitigated Negative Declaration for the 2023-2031 Housing Element Update (IS/MND). We appreciate this opportunity to provide comments on the IS/MND.

As required by state law, the City’s Housing Element establishes goals, policies, and programs to help address the City’s current and future housing needs and includes a list of Housing Opportunity Sites. It is the City’s blueprint for housing-related decisions and sets an action plan for how to meet housing goals over the coming years. Through the state-mandated Regional Housing Needs Allocation (RHNA) process, the Association of Bay Area Governments (ABAG) allocated to the City 3,165 new housing units, which are to be accommodated on Housing Opportunity Sites. To comply with the California Environmental Quality Act (CEQA) for approval of the Housing Element Update, the City prepared an initial study (IS) of environmental impacts and the City intends to adopt a Mitigated Negative Declaration of Environmental Impacts (MND).

The majority of the City is located within Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP) adopted in October 2012 by the City/County Association of Governments of San Mateo County (C/CAG), which serves as the Airport Land Use Commission (ALUC). The SFO ALUCP governs land use development within the Airport Influence Area and addresses issues related to compatibility between Airport operations and proposed new land use developments, considering noise impacts, safety of persons on the ground and in flight, height restrictions/airspace protection, and overflight notification.

NOISE COMPATIBILITY
Two of the Housing Opportunity Sites identified in the Housing Element Update – the Shops at Tanforan (Site 14) and San Bruno Pet Hospital (Site 19) – are located within the 70-75 decibel (dB) Community Noise Equivalent Level (CNEL) contour identified in the SFO ALUCP. Another five Housing Opportunity Sites identified in the Housing Element Update (Sites 7, 15, 18, 20, and 21) are located within the 65-70 dB CNEL contour. In addition, many Airport departure procedures are designed to ascend over these sites, and residents on the sites would experience extreme and persistent noise from aircraft departures.

SFO ALUCP Noise Contours
DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith, City of San Bruno
January 9, 2023

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The IS/MND presents noise contours for SFO in Figure 4.13-2. The cited source of the noise contours is the SFO ALUCP (2012). However, the title of Figure 4.13-2 is “SFO 2020 Noise Exposure Contours” and the noise contours depicted do not match the noise contours shown in Figure IV-6 of the SFO ALUCP. Thus, the contours used to prepare the IS/MND are not the appropriate contours to use for noise impact analysis with respect to Airport noise. Rather, the IS/MND should use the noise contours presented in the SFO ALUCP, which are representative of the future noise profile of the Airport and are used by the ALUC to evaluate projects for noise compatibility. Any other noise contours, particularly contours based on past data, do not account for future activity and are not representative of future noise exposure. Thus, the noise impacts at the Housing Opportunity Sites are not accurately characterized in the IS/MND.

Conditional Compatibility of Residential Uses within SFO ALUCP 65-70 dB Noise Contour According to the SFO ALUCP, housing is conditionally compatible within the 65-70 dB CNEL noise contour provided that sound insulation is provided to reduce interior noise levels from exterior sources to CNEL 45 dB or lower and that an avigation easement is granted to the City and County of San Francisco as operator of SFO. This avigation easement requirement for housing within the 65-70 dB CNEL noise contour and higher should be specifically identified as a mitigation measure for Impact NOI-3 and the impact statement conclusion should be revised to “Less than Significant with Mitigation Incorporated”.

Incompatibility of Residential Uses within SFO ALUCP 70-75 dB Noise Contour The SFO ALUCP also specifies that housing is an incompatible land use within the 70-75 dB CNEL noise contour except for an existing lot of record that was zoned solely for residential use as of the ALUCP’s effective date. We understand that when the current SFO ALUCP was adopted in November 2012, both the Shops at Tanforan lot and the San Bruno Pet Hospital lot (Housing Opportunity Sites 14 and 19, respectively) were zoned for commercial use; therefore, residential uses on those sites are incompatible with the SFO ALUCP Noise Compatibility Policies, creating an airport land use incompatibility with respect to noise on those sites. For this reason and because the Impact NOI-3 discussion only considers attenuation of indoor noise levels and does not address noise exposure of residents when windows are opened or when outdoors, Impact NOI-3’s impact conclusion of “Less than Significant Impact” is unsupported.

On November 10, 2022, the ALUC issued a determination that the City’s Draft 2023-2031 Housing Element Update was inconsistent with the SFO ALUCP’s Noise Compatibility Policies. On November 15, 2022, the San Bruno City Council adopted Resolution No. 2022-112 making draft findings (Draft Findings) and declaring an intent to consider overriding the ALUC determination. SFO sent a comment letter to the City on December 16, 2022 objecting to the override on the grounds that the Shops at Tanforan and the San Bruno Pet Hospital sites are located within the Airport’s 70-75 dB CNEL contour and therefore residential development is not appropriate on those sites. SFO’s comment letter is attached hereto as Attachment A and incorporated by reference. The key points made in that letter are summarized below:
• The City’s Draft Findings contain no findings of fact to support overriding the ALUC’s inconsistency determination. The Draft Findings only address residential land use within the 65-70 dB CNEL contour, but there is no discussion of residential land use within the 70-75 dB CNEL contour.
• The City’s Draft Findings discuss the RHNA allocations, the proposed sites’ proximity to mass transit, and the region’s and State’s housing affordability crisis, which are not germane to whether adoption of the Draft Housing Element would increase the public’s exposure to noise hazards.

DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith, City of San Bruno
January 9, 2023

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• The City should impose enforceable Conditions of Approval on new residential developments within the 70-75 dB CNEL contour as stated in the Draft Findings.

Finally, we emphasize that where residential development is sited within the 70-75 dB CNEL contour, grant of an avigation easement is essential to ensuring that an override of the ALUC’s inconsistency finding would comply with California Public Utilities Code section 21670, particularly its goal to “prevent the creation of new noise and safety problems.” Without a recorded easement, future owners and occupants of residential units within the 70-75 dB CNEL contour may not have notice of the override decision or of the Airport’s resulting immunity from liability. Consistent with the legislative findings in the Public Utilities Code, it is imperative that the City require the grant of an avigation easement for these residential developments. The avigation easement should state that the City overrode the ALUC’s inconsistency finding, describe the immunity granted to the Airport under California Public Utilities Code section 21678, and make clear that the avigation easement is in addition to, and does not limit, the Airport’s immunity.

As the largest employment center in San Mateo County, SFO recognizes the importance of increasing housing supply and affordability in the San Francisco Bay Area and throughout California. While the Airport believes that ABAG should have included airport noise criteria in its RHNA methodology, we acknowledge that the City’s RHNA allocation requires it to plan for an additional 3,165 housing units. The Airport again urges the City to consider alternative locations to meet RHNA requirements outside the 70-75 dB CNEL noise contour, including the 2101 Sneath Lane Residential Project, the Bayhill Specific Plan area, 1010 Admiral Court, and the transit-oriented development corridors along El Camino Real and San Mateo Avenue.

SAFETY COMPATIBILITY
If the Housing Element Update is adopted, Housing Opportunity Site 14 (The Shops at Tanforan) would be located in Safety Compatibility Zone 4 (Outer Approach/Departure Zone) and Housing Opportunity Sites 15 (170 San Bruno Avenue West) and 21 (104 San Bruno Avenue West) would be located in Safety Compatibility Zone 3 (Inner Turning Zone). Residential land use is not incompatible in either Safety Compatibility Zone. Therefore, the Housing Element Update does not appear to be incompatible with the Safety Compatibility Policies of the SFO ALUCP. However, we note that for both Safety Compatibility Zones 3 and 4, Biosafety Level 3 and 4 facilities, children’s schools, large child day care centers, hospitals, nursing homes, stadiums, and arenas are considered incompatible uses. Moreover, hazardous uses other than Biosafety Level 3 and 4 facilities and critical public utilities should be avoided in these zones.

AIRSPACE COMPATIBILITY
As described in Exhibit IV-17 of the SFO ALUCP (see Attachment B), the critical aeronautical surfaces at the Housing Opportunity Sites are as low as an elevation of approximately 125 feet above mean sea level (AMSL) as defined from the origin of the North American Vertical Datum of 1988 (NAVD88). This occurs at the southeast corner of Housing Opportunity Site 14 (The Shops at Tanforan). While specific elevations of buildings at the proposed housing sites are not identified in the IS/MND, the document states that building elevations at Housing Opportunity Site 14 are limited by Ordinance 1446 to 126 feet and 9 inches AMSL.

Moreover, the IS/MND states that future building heights would be required to comply with SFO ALUCP Policy AP-3, which limits maximum building heights to the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18 of the SFO ALUCP), or (2) the maximum height determined not to be a “hazard to air navigation” by the Federal Aviation Administration (FAA) in an DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith, City of San Bruno
January 9, 2023

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aeronautical study prepared pursuant to the developer’s filing of Form 7460-1. Thus, based on Ordinance 1446 and ALUCP Policy AP-3, the maximum height of residential development on Housing Opportunity Site 14 would be below SFO’s critical aeronautical surfaces and the Housing Element Update would not appear to be inconsistent with the SFO ALUCP’s Airspace Compatibility Policies, subject to the issuance of a Determination of No Hazard by the FAA (see below) and the ALUC for any proposed structures.

Notwithstanding that the Housing Element Update appears to be consistent with the SFO ALUCP’s Airspace Compatibility Policies, future proposed development projects in the City are still required to undergo FAA airspace review as described in 14 Code of Federal Regulations Part 77 for both (1) the permanent structures and (2) any equipment taller than the permanent structures required to construct those structures.

Due to the proximity of the Housing Element Update’s identified Housing Opportunity Sites to the Airport, Airspace Protection Policies (AP-1 through AP-4) from the SFO ALUCP are enclosed (Attachment B) as reminders of incompatible site characteristics, especially as it pertains to wildlife attractants, particularly large flocks of birds, that pose threats to safe aircraft operations, and building materials or features that reflect and create bright lights or glare.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not hesitate to contact me at (650) 821-6678 or at [email protected].

Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
Attachment: A. SFO Comment Letter – Objection to the Consideration of Override of ALUC Findings of Inconsistency with Respect to the Noise Policies for the Draft 2023-2031 Housing Element Update (December 16, 2022)
B. Excerpt from SFO ALUCP (Exhibit IV-17 and Airspace Protection Policies) cc: Geoff Neumayr, SFO
Sean Charpentier, Executive Director, C/CAG
Susy Kalkin, C/CAG Airport Land Use Committee
Tamara Swann, Western-Pacific Deputy Regional Administrator, FAA Faviola Garcia, Western-Pacific Deputy Regional Administrator, FAA Laurie Suttmeier, Manager, Western-Pacific Region, FAA San Francisco Airports District Office Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith, City of San Bruno
January 9, 2023

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Matthew Friedman, Chief, Office of Aviation Planning, Caltrans Airlines for America
San Francisco Airline Airport Affairs Committee
California Airports Council
United States Congresswoman Jackie Speier
San Mateo County Supervisor David Pine
San Mateo County Supervisor Dave Canepa
California State Assemblymember Kevin Mullin
California State Senator Josh Becker
Therese McMillan, Executive Director, Association of Bay Area Governments Mark Shorett, Principal Regional Planner, Association of Bay Area Governments Sam Hindi, Chairperson, SFO Airport/Community Roundtable Marisa Prasse, California Department of Housing and Community Development Hillary Prasad, California Department of Housing and Community Development DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892

ATTACHMENTS
• Attachment A: December 16, 2022 letter to San Bruno
o Attachment A to Dec 16 letter: September 30 letter
 Exhibit A to September 30 letter: May 6 SFO letter
• Attachment A to May 6 SFO letter: ALUCP noise policies • Attachment B to May 6 SFO letter: Density of housing
• Attachment C to May 6 SFO letter: ALUCP airspace policies • Attachment D to May 6 SFO letter: Clarification to Caltrans OEI letter • Attachment E to May 6 SFO letter: ALUCP safety policies  Exhibit B to September 30 letter: May 18 FAA letter
• Enclosure 1 to May 18 FAA letter: 2008 USDOT letter
• Enclosure 2 to May 18 FAA letter: 2019 NEM
• Enclosure 3 to May 18 FAA letter: 2022 photo
• Enclosure 4 to May 18 FAA letter: OCS map
• Enclosure 5 to May 18 FAA letter: 3D view of OCS map
 Exhibit C to September 30 letter: SFO ALUCP Exhibits IV-17 and IV-18 • Attachment B: Excerpt from SFO ALUCP (Exhibit IV-17 and Airspace Protection Policies) DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Attachment A
December 16, 2022 Letter to San Bruno
DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 December 16, 2022

TRANSMITTED VIA E-MAIL
[email protected]
Darcy Smith
Assistant City Manager
City of San Bruno
567 El Camino Real
San Bruno, California 94066
Subject: Objection to the Consideration of Override of ALUC Findings of Inconsistency with Respect to The Noise Policies for the Draft 2023-2031 Housing Element Update San Francisco International Airport (SFO or the Airport) staff have reviewed the City of San Bruno’s (City) Notice of Intent to Consider Override of ALUC Findings of Inconsistency with Respect to The Noise Policies for the Draft 2023-2031 Housing Element Update (Draft Housing Element). We appreciate this opportunity to provide comments on the proposed action by the San Bruno City Council.

The majority of the City is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP) adopted in October 2012 by the City/County Association of Governments of San Mateo County (C/CAG), which serves as the Airport Land Use Commission (ALUC). The SFO ALUCP governs land use development within the Airport Influence Area and addresses issues related to compatibility between Airport operations and proposed new land use developments, considering noise impacts, safety of persons on the ground and in flight, height restrictions/airspace protection, and overflight notification.

Two of the Housing Opportunity Sites identified in the Draft Housing Element – the Shops at Tanforan and San Bruno Pet Hospital sites – are located within the 70 decibel (dB) Community Noise Equivalent Level (CNEL) contour identified in the SFO ALUCP. Moreover, many Airport departure procedures are designed to ascend over the sites, and residents on these sites would experience extreme and persistent noise from aircraft departures.

SFO objects to the City’s override of the ALUC’s finding of inconsistency with respect to noise for the Draft Housing Element because the Shops at Tanforan and the San Bruno Pet Hospital sites are located within the Airport’s 70 dB CNEL contour, rendering residential uses on those sites incompatible with the SFO ALUCP noise policies. The Airport previously raised this SFO ALUCP compatibility issue in a comment letter to the City dated September 30, 2022, regarding the Draft Housing Element (on which the ALUC was copied).

That comment letter is attached hereto as Attachment A and incorporated by reference. In those comments, the Airport notified the City that most of the Shops at Tanforan site is within the Airport’s 70-75 decibel DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Darcy Smith, City of San Bruno
December 16, 2022

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(dB) Community Noise Equivalent Level (CNEL) contour. According to the SFO ALUCP, housing is an incompatible land use within this noise contour and would only be conditionally compatible based on an existing lot of record having been zoned solely for residential use as of the ALUCP’s effective date. We understand that when the current SFO ALUCP was adopted in November 2012, both the Shops at Tanforan lot and the San Bruno Pet Hospital lot were zoned for commercial use; therefore, residential uses on those sites are incompatible with the SFO ALUCP Noise Compatibility Policies, creating an airport land use incompatibility with respect to noise on those sites.

To override the ALUC, the City must find that the proposed action is consistent with California Public Utilities Code section 21760.1 The Draft Findings attached as Exhibit A to the Notice of Intent (“Draft Findings”) make no findings of fact to support overriding the ALUC’s inconsistency determination. The Draft Findings cite Table IV-1 of the ALUCP, which states that residential land uses are conditionally compatible in the 65-70 dB CNEL contour. This is irrelevant to uses within the 70-75 dB CNEL or higher contours, as residents within these contours would be exposed to much more noise than their counterparts within the 65-70 dB CNEL contour.2
The Draft Findings state that the Draft Housing Element would “promote the overall goals and objectives of the California airport noise standards … because the proposed Project provides much needed housing near transit on underutilized sites … and helping the City satisfy its large RHNA allocation and respond to the housing crisis facing the region and the State.” The City’s RHNA allocation, the proposed sites’ proximity to mass transit, and the region’s and State’s housing affordability crisis are not germane to whether adoption of the Draft Housing Element would increase the public’s exposure to noise hazards. Put simply, these factors do not affect where aircraft fly or how much noise they produce when they do.

Should the City decide to override the ALUC’s decision that the Draft Housing Element is inconsistent with the SFO ALUCP, the Airport renews its request that the City impose enforceable Conditions of Approval on any new residential developments within the 70-75 dB CNEL contour to mitigate noise for the health of future residents, including:

1. Require construction and design features to reduce interior noise to 45 dB;

2. Require central cooling and heating so that during warmer months, residents are not forced to open their windows for cooler air flow, which would negate the 45 dB interior noise levels achieved through sound insulation;

3. Require the developer to grant an avigation easement to the City and County of San Francisco, in accordance with ALUCP Policy NP-3, prior to issuance of building permits; and

4. Require the developer to include real estate disclosures in sale and lease documents, disclosing the presence of an airport within two miles of the property, as required by California Business and Professions Code section 11010.

The Airport is pleased that these recommended noise mitigation measures have been included in Section 5 of the Draft Findings.
1 Cal. Pub. Util. Code § 21676(b).
2 The decibel scale is logarithmic, so a 10 dB increase represents 10 times as much sound energy.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Darcy Smith, City of San Bruno
December 16, 2022

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Finally, we emphasize that the grant of an avigation easement is essential to ensuring that an override would be consistent with California Public Utilities Code section 21670, particularly its goal to “prevent the creation of new noise and safety problems.” Without a recorded easement, future owners and occupants of residential units within the 70-75 dB CNEL contour may not have notice of the override decision or of the Airport’s resulting immunity from liability. Consistent with the legislative findings in the Public Utilities Code, it is imperative that the City require the grant of an avigation easement. The avigation easement should state that the City overrode the ALUC’s inconsistency finding, describe the immunity granted to the Airport under California Public Utilities Code section 21678, and make clear that the avigation easement is in addition to, and does not limit, the Airport’s immunity.

As the largest employment center in San Mateo County, SFO recognizes the importance of increasing housing supply and affordability in the San Francisco Bay Area and throughout California. While the Airport believes that ABAG should have included airport noise criteria in its RHNA methodology, it also acknowledges that the City’s RHNA allocation requires it to plan for an additional 3,165 housing units. The Airport continues to urge the City to consider alternative locations to meet RHNA requirements outside the 70-75 dB CNEL noise contour, including the 2101 Sneath Lane Residential Project, the Bayhill Specific Plan area, 1010 Admiral Court, and the transit-oriented development corridor along El Camino Real and San Mateo Avenue.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not hesitate to contact me at (650) 821-6678 or at [email protected].

Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
Attachment: A. SFO Comment Letter - San Bruno 2022 Housing Element cc: Geoff Neumayr, SFO
Sean Charpentier, Executive Director, C/CAG
Susy Kalkin, C/CAG Airport Land Use Committee
Tamara Swann, Western-Pacific Regional Administrator, Acting, FAA Faviola Garcia, Western-Pacific Deputy Regional Administrator, Acting, FAA Laurie Suttmeier, Manager, Western-Pacific Region, FAA San Francisco Airports District Office Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans Matthew Friedman, Chief, Office of Aviation Planning, Caltrans DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Darcy Smith, City of San Bruno
December 16, 2022

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Airlines for America
San Francisco Airline Airport Affairs Committee
California Airports Council
United States Congresswoman Jackie Speier
San Mateo County Supervisor David Pine
San Mateo County Supervisor Dave Canepa
California State Assemblymember Kevin Mullin
California State Senator Josh Becker
Therese McMillan, Executive Director, Association of Bay Area Governments Mark Shorett, Principal Regional Planner, Association of Bay Area Governments Sam Hindi, Chairperson, SFO Airport/Community Roundtable Marisa Prasse, California Department of Housing and Community Development Hillary Prasad, California Department of Housing and Community Development DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 September 30, 2022

TRANSMITTED VIA E-MAIL
[email protected]
Michael Smith
Senior Planner
San Bruno Community & Economic Development Department | Planning Division City of San Bruno
567 El Camino Real
San Bruno, California 94066
Subject: 2023-2031 Draft Housing Element, San Bruno, California Thank you for notifying San Francisco International Airport (SFO or the Airport) regarding the preparation of the City of San Bruno’s draft 2023-2031 Housing Element (draft Housing Element). We appreciate this opportunity to coordinate with the City of San Bruno (the City) in considering and evaluating potential land use compatibility issues from the draft Housing Element.

The draft Housing Element establishes goals, policies, and programs to help address the City’s current and future housing needs and includes a list of recommended housing sites. It is the City’s blueprint for housingrelated decisions and sets an action plan for how to meet housing goals over the coming years. The City has been allocated 3,165 housing units through the Association of Bay Area Governments’ application of the State of California’s Regional Housing Needs Allocation (RHNA) process and the draft Housing Element includes a minimum of 1,000 housing units at the former Shops at Tanforan site. The Tanforan site has been identified by the City as a prime location for housing because of its designation within the City’s Transit Corridor Plan.

The majority of the City, including the Tanforan site, is inside Airport Influence Area B as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP). The Tanforan site is located within the 70 decibel (dBA) Community Noise Equivalent Level (CNEL) contour and Safety Compatibility Zone 4. Moreover, many airport departure procedures are designed to ascend over the Tanforan site, and residents would experience extreme and persistent noise from aircraft departures.

SFO remains deeply concerned about the City’s plan for adding housing units at the Tanforan site. On July 27, 2021, the City released the Reimagining Tanforan Fact Sheet, which describes proposed development at the Tanforan site. On May 6, 2022, we sent a letter to the City stating our concerns for the redevelopment of the Tanforan Shopping Center, which is attached hereto as Exhibit A and incorporated by reference. A summary of the concerns outlined in that letter are as follows:
• All residential developments within 70 dBA CNEL contour are determined to be incompatible (i.e., entirety of Tanforan site);
• Redevelopment of the Tanforan site to include high-density residential units would undermine decades of scientifically informed land use planning and millions of dollars expended to safeguard public health and safety;
DocuSign Envelope ID: E33C5440-0C7C-4F46-A8B2-F63004DD632A DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith
September 30, 2022

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• The Airport has spent hundreds of millions of dollars on insulating incompatible land uses. However, any future residences at the Tanforan site will not be eligible for Federal Aviation Administration/SFO grants for sound insulation or the subsequent repair or re-installation of insulation materials when they fail over time. (This is reiterated in a May 6, 2022 letter from FAA to the City attached hereto as Exhibit B and incorporated by reference.) • The proposed redevelopment would result in the densest population per square mile under the departure flight path near a major international airport; • Heights of buildings at the Tanforan site would need to be between 55 and 90 feet above ground level to be compatible with the Airspace Compatibility Policies of the SFO ALUCP. Otherwise, any penetrations of the critical aeronautical surfaces would result in real financial and economic impacts to air carriers, cargo operators, and SFO/City of County of San Francisco, and potentially reduce airlines’ ability to transport high-value cargo (e.g., biotechnology and high-technology cargo); • The Airport encourages the City to consider Safety Zone 4 compatibility policies during planning and site development to prevent development of incompatible uses (i.e., Biosafety Level 3 and 4 facilities, children’s schools, large child day care centers, hospitals, nursing homes, stadiums, and arenas) and avoid development of critical public utilities and hazardous uses other than Biosafety Level 3 and 4 facilities.

The Airport has reviewed the recently issued draft Housing Element, which will be sent to the California Department of Housing and Community Development (HCD) on October 3, 2022. In addition to the comments presented in our May 6, 2022 letter (Exhibit A), we have the following comments regarding the draft Housing Element:
• In Chapter 3 (Housing Constraints and Resources), it states that, “local governments may take steps, provided by law, to overrule part or all of the ALUCP as it relates to their jurisdiction.” This is not true. Local agencies cannot overrule any part of the ALUCP. Rather, local agencies may override an Airport Land Use Commission determination of proposed land use policy actions or development proposals based on the ALUCP. The process is described in Section 3.3.3 of the SFO ALUCP (Local Agency Override of an Airport Land Use Commission Determination). The local agency override process requires three steps: 1) holding a public hearing by the local agency of the proposed override action, 2) making specific findings by the governing body of the local agency that the proposed local action is consistent with the purposes of the airport land use commission statutes, and 3) approval of the override action by a two-thirds vote of the local agency’s governing body. • In Chapter 3 (Housing Constraints and Resources), Tables 3-2 and 3-3 present development regulations for residential and mixed-use districts, respectively. The Airport strongly encourages the City to also include maximum height restrictions reflective of the critical aeronautical surfaces as outlined in SFO ALUCP Exhibits IV-17 and IV-18 (see Exhibit C). The Airport also requests the following language be included in the draft Housing Element:

The City shall regulate land uses and building height within the Airport Influence Area of the San Francisco International Airport in compliance with SFO critical aeronautical surfaces (SFO ALUCP Exhibits IV-17 & IV-18), in accordance with Airport Land Use Commission guidelines to assure safety of aircraft, persons, and property near the Airport.

Additionally, all proposed structures must receive a Determination of No Hazard from the DocuSign Envelope ID: E33C5440-0C7C-4F46-A8B2-F63004DD632A DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith
September 30, 2022

Page 3 of 4 ends

FAA. For avoidance of doubt, the lower of the two heights identified by the ALUCP and the FAA shall be the controlling maximum height.
• In the City’s Application for Land Use Consistency Determination for the Housing Element update, the City presents the following proposed amendment to the General Plan, Health and Safety Policy HS-40:

Presupposing an override of an ALUC determination for noise compatibility within the General Plan undermines the purpose of the SFO ALUCP to protect the public health, safety, and welfare of residents and occupants of future noise-sensitive development, and short-circuits the due process built into Public Utilities Code Section 21675.1(d). Placing this language into the General Plan would, in essence, render incompatible the entire General Plan. If overrides are pursued, they should be pursued on a per-project basis and the City must make determinations of fact specific to that project rather than assuming a blanket override. The Airport requests that this new language be stricken and overrides continue to be considered on a per-project basis to meet the intent of the Public Utilities Code and the SFO ALUCP.

As the largest employment site in San Mateo County, SFO recognizes the importance of increasing housing supply in California and in the San Francisco Bay Area. While the Airport believes that ABAG erred in excluding airport noise criteria from its RHNA methodology, it also acknowledges that the City’s RHNA allocation requires it to plan for an additional 3,165 housing units. The Airport continues to urge the City to consider alternative locations to meet RHNA requirements, outside the 70 dBA CNEL noise contour, including the 2101 Sneath Lane Residential Project, the Bayhill Specific Plan area, and the transit-oriented development corridor along El Camino Real and San Mateo Avenue located outside of the CNEL 70 dBA contour.

Due to the proximity to the Airport, Airspace Protection Policies (AP1 through AP4) from the SFO ALUCP are enclosed (see Exhibit C) as reminders of incompatible site characteristics that pose threats to safe aircraft operations – especially as it pertains to wildlife attractants, particularly large flocks of birds – and building materials/features that reflect and create bright lights/glare. * * *
DocuSign Envelope ID: E33C5440-0C7C-4F46-A8B2-F63004DD632A DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Michael Smith
September 30, 2022

Page 4 of 4 ends

The Airport appreciates the City’s willingness to continue to have collaborative discussions, and your consideration of these concerns. If I can be of assistance, please do not hesitate to contact me at (650) 821- 6678 or at [email protected].

Sincerely,
Nupur Sinha
Director of Planning and Environmental Affairs
San Francisco International Airport
Attachments
cc: Tamara Swann, Western-Pacific Regional Administrator, Acting, FAA Faviola Garcia, Western-Pacific Deputy Regional Administrator, Acting, FAA Laurie Suttmeier, Manager, Western-Pacific Region, FAA San Francisco Airports District Office Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans Airlines for America
San Francisco Airline Airport Affairs Committee
California Airports Council
United States Congresswoman Jackie Speier
San Mateo County Supervisor David Pine
San Mateo County Supervisor Dave Canepa
California State Assemblymember Kevin Mullin
California State Senator Josh Becker
Therese McMillan, Executive Director, Association of Bay Area Governments Mark Shorett, Principal Regional Planner, Association of Bay Area Governments Sam Hindi, Chairperson, SFO Airport/Community Roundtable Marisa Prasse, California Department of Housing and Community Development Hillary Prasad, California Department of Housing and Community Development Sean Charpentier, Executive Director, City/County Association of Governments of San Mateo County Susy Kalkin, C/CAG Airport Land Use Committee
DocuSign Envelope ID: E33C5440-0C7C-4F46-A8B2-F63004DD632A DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Western-Pacific Region
Office of the Regional Administrator

777 S. Aviation Blvd.

El Segundo, CA 90245

May 18, 2022
Mr. Jovan D. Grogan
City Manager
City of San Bruno
567 El Camino Real
San Bruno, CA 94066-4247
RE: Concerns regarding the Reimagining Tanforan Redevelopment Project Dear Mr. Grogan:

The purpose of this letter is to advise the City of San Bruno that the Federal Aviation Administration (FAA) is concerned about potential impacts to San Francisco International Airport (SFO), land use changes, and the introduction of airport incompatible land use relating to the redevelopment of the Tanforan Shopping Mall (Tanforan Mall) in San Bruno, California. As currently planned, the proposed Reimagining Tanforan Redevelopment Project (Tanforan Project) would introduce new land use compatibility issues and increase noise incompatibility due to arrival and departure operations from SFO. The FAA’s mission is to provide the safest and most efficient aerospace system in the world. Within the context of our mission, the FAA continues to seek ways to mitigate the effects of aviation-related noise by providing financial and technical assistance to airport sponsors on airport compatible land use, noise reduction planning and abatement activities.

The Reimagining San Bruno Land Use Fact Sheet (San Bruno Fact Sheet) states, “...the goal of this early engagement is to identify redevelopment solutions that are financially viable and provide long term benefits to the San Bruno community by streamlining the entitlement approval process to mitigate risks and accelerate the investments.” While there are many benefits to living in a transit-oriented development that is closely connected to mass transit, the FAA is concerned about maintaining compatibility of the existing land use and introducing high-density residences within an area known to be adversely affected by aircraft noise within the Tanforan development.

The FAA is aware that the California Department of Transportation (Caltrans) shares similar concerns, as detailed in their January 20, 2022, letter to the City of San Bruno. We are also aware that SFO has expressed concerns regarding the proposed redevelopment. The FAA is additionally concerned about the environmental justice implications of affordable housing provided in noiseincompatible land.

The City of San Bruno is directly responsible for ensuring proper planning in partnership with state, local, and private entities, and notifying purchasers of real estate and prospective residents of their exposure to direct overflight and extreme and persistent airport noise. In the past, the City of San Bruno directly received federal funding for residential sound insulation to mitigate land use compatibility issues. On May 14, 2008, the FAA reminded the City of San Bruno, via enclosure 1, of the importance of taking appropriate action to adopt zoning and further restrict the introduction of additional non-compatible land uses adjacent to or in the vicinity of SFO. The DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 enclosure to that letter provides Appendix A, Table 1- Land Use Compatibility Guidelines from 14 Code of Federal Regulations Part 150 – Airport Noise Compatibility Planning (Part 150). As shown in enclosure 2, the 2019 Noise Exposure Map from the SFO Noise Compatibility Program1, a majority of the Tanforan Mall area is within the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour and is heavily affected by SFO departures from Runways 28L and 28R. The FAA continues to provide Airport Improvement Program (AIP) funding for qualified impacted City of San Bruno residences through the SFO Residential Sound Insulation Program. In accordance with FAA Final Policy on Part 150 Approval of Noise Mitigation Measures: Effect on the Use of Federal Grants for Noise Mitigation Projects (63 FR 16409), structures and new non-compatible development built after October 1, 1998, are not eligible for approval of remedial noise mitigation measures under Part 150 or AIP funding. In other words, residences in the Tanforan Project would not receive any AIP funding for residential sound insulation.

According to the San Bruno Fact Sheet, the city may add at least 1,000 and as many as 3,165 residential units. This plan would expose thousands of new residents to significant noise (above 65 dB CNEL), approximately 2,500 to 8,000 persons, using the average number of 2.62 persons per household according to the United States Census Bureau. Given that there are currently 440,000 persons nationwide exposed to significant noise, this development alone would increase the number of people exposed.

SFO primary operations use Runways 28L and 28R for landing and Runways 01R and 01L for departures. In this configuration, Runway 28R is also used for departures of heavy jets on long routes, which need the longest SFO runway (Runway 28R) due to the aircraft weight. The Tanforan Mall area aligns with the SFO Runways 28R and 28L. Use of Runway 28R for departures is not optional for these long-haul flights.

In 2019 there were an average of about 88 heavy jet departures per day; out of those heavy jet departures, 72% departed from Runway 28R or Runway 28L. On August 17, 2019, SFO’s peak departure was 209 heavy jets. Heavy jets were departing Runways 28R and 28L, from 0.5 nautical miles before the proposed development to 0.5 nautical miles after the proposed development. The proposed development is approximately 1.1 nautical miles from the end of Runways 28R and 28L. Therefore, the average altitude of departing heavy jets over the Tanforan site is 1300 to 1800 feet mean sea level.

Also, Runways 28R and 28L are used for departures when winds are strong enough from the West Southwest to no longer allow for Runways 01R and 01L to be used due to unacceptably high tailwinds/crosswinds. Use of SFO Runways 28R and 28L for all departures is not a preferred configuration for SFO. Instead, it is required based on the weather (winds), specific needs of longhaul departures, or aircraft types which require the longest possible runway. In 2019, all aircraft departed only Runway 28L or Runway 28R 7.9% of the time, the second-most-frequent runway configuration at SFO. Additionally, there are occasions when weather forces the use of Runways 10R and 10L for SFO arrivals. Such an occurrence happened on January 22, 2022; enclosure 3 is a photo of an aircraft preparing to land at SFO directly over the Tanforan Mall area. Proposed Tanforan residential units would be exposed to the type, frequency, and severity of aviation activity described above.
1 The San Francisco International Airport, Noise Compatibility Program (NCP) Update 2018 was prepared pursuant to 14 Code of Federal Regulations Part 150 requirements. The first FAA Record of Approval for a SFO NCP was issued on September 7, 1983.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 As shown in enclosures 4 and 5, Tanforan Mall is located within the footprint for the Approach/Departure Obstruction Clearance Surface (OCS)
2 for existing Runway 10R/28L and
Runway 10L/28R. Maintaining clearance and protection of the OCS is among critical safety factors for protecting the Nation’s airspace and aviation operations to and from SFO. Proposed structures’ heights must be below the OCS.

Noise and land use compatibility planning are complex issues that need active engagement by the City of San Bruno together in partnership with the City and County of San Francisco, Airport Commission; San Mateo County; aeronautical users such as United Airlines; the business community; and residences to establish a cohesive strategy for the health and well-being of the entire community. Please review the FAA Airport Noise Compatibility Planning Toolkit (Land Use Compatibility and Airports, A Guide for Effective Land Use Planning [PDF]). The City/County Association of Governments (C/CAG) also maintains an Airport Land Use Commission (ALUC) and Comprehensive Airport Land Use Compatibility Plan for the Environs of SFO. This government entity and legal document prepared under State of California Law may indicate further restrictions on the site to maintain airspace, noise, and safety compatibility.

Compliance with FAA guidelines and federal law does not exempt a project sponsor from complying with local regulations.

Should the City of San Bruno, known to be a noise-sensitive community representative in the SFO Airport/Community Roundtable, proceed with the Tanforan Project, exposing as many as 8,000 residents to significant aviation noise, there will be little if any mitigation the FAA would be able to implement for these residents because of the Tanforan Project’s proximity to SFO runways.

Therefore, we strongly encourage the City of San Bruno and San Mateo County officials to consider the FAA’s concerns and look to develop and maintain compatible land uses around SFO.

If you have any questions, please contact my office at (424) 405-7000.

Sincerely,
Tamara A. Swann
Regional Administrator (A)
Enclosures
cc:

Sam Hindi, Roundtable Chairperson, San Francisco
Tom Hamilton, Council member, City of San Bruno
Pamela Wu, Director, Community and Economic Development, City of San Bruno Therese McMillan, Executive Director, Association of Bay Area Governments United States Congresswoman Jackie Speier, CA – 14th District Phillip Miller, Acting, Chief Division of Aeronautics, Caltrans 2 Defined in FAA Advisory Circular (AC) 150/5300-13, Airport Design, and Engineering Brief 99A.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 U.S Department
of Transportation
Federal Aviation
Administration
Western-Pacific Region
Airports Division
San Francisco ADO
831 Mitten Road, Suite 210
Burlingame, CA 94010
May 14, 2008
Aaron Aknin
Community Development Director
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
Dear Mr. Aknin:

Subject: San Bruno General Plan 2025 and associated Draft Environmental Impact Report
The Federal Aviation Administration (FAA) has completed a cursory review of the subject documents. As a result of that review the FAA is concerned that the San Bruno General Plan (General Plan) and Environmental Impact Report did not consider the City of San Bruno’s (City) airport land use compatibility program obligations.

As noted in the General Plan on page 7-9, the City has accepted federal funds for insulation projects in areas impacted by noise from San Francisco International Airport (SFO). The federal funds were made available to the City as a result of the City and County of San Francisco’s SFO Noise Compatibility Plan (NCP) prepared pursuant to 14 Code of Federal Regulations Part 150, Airport Noise Compatibility Planning (Part 150). The NCP identified noise impact areas and measures developed to achieve compatible land use with SFO operations.

When the City accepted the federal Airport Improvement Program (AIP) funds for the noise insulation projects, the City acknowledged its obligation to take appropriate action to adopt appropriate zoning and further restrict introduction of additional non-compatible land uses adjacent to or in the vicinity of the airport. The AIP grant obligations are identified in the Non-Airport Sponsors Grant Assurances.

The most recent AIP grant is 3-06-0021-29.

The General Plan Guiding Policies encourage additional residential housing in areas that are impacted by airport noise. The majority of the area designated for redevelopment is in the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour. Proposed high density residential and mixed use developments are located within the CNEL 65 dB contour.

Introduction of additional non-compatible development within the CNEL 65 dB through CNEL 70 dB is inconsistent with the NCP. Table 1 from Part 150 provides federal compatible and non-compatible land use guidelines (enclosed).

Development of local land use plans that are compatible with airport operations is key to ensuring consistency with the City’s grant obligations. The FAA encourages the City to take appropriate action to Enclosure (1)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 2 maintain compliance with its certification that it will comply with all applicable Federal laws, regulations, executive orders, policies, guidelines and requirements as they relate to use of federal funds for land use compatibility.

If you have any questions or concerns regarding this matter, I am available at (650) 876-2778 extension 613.

Sincerely,
(Original Signed by:)
Camille Garibaldi
Environmental Protection Specialist
Enclosure
cc:

Danielle Rinsler, San Francisco International Airport
Nixon Lam, San Francisco International Airport
Sandy Hesnard, California Department of Transportation
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND Land Use Yearly day-night average sound level (Ldn) in decibels < 65 65-70 70-75 75-80 80-85 > 85
Residential
Residential, other than mobile homes and
transient lodgings
Y N (1) N (1) N N N
Mobile home parks Y N N N N N
Transient lodgings Y N (1) N (1) N (1) N N

Public Use
Schools Y N (1) N (1) N N N
Hospitals, nursing homes Y 25 30 N N N
Churches, auditoriums, and concert halls Y 25 30 N N N
Government services Y Y 25 30 N N
Transportation Y Y Y (2) Y (3) Y (4) Y (4)
Parking Y Y Y (2) Y (3) Y (4) N

Commercial Use
Offices, business and professional Y Y 25 30 N N
Wholesale and retail- building materials,
hardware and farm equipment
Y Y Y (2) Y (3) Y (4) N
Retail trade-general Y Y 25 30 N N
Utilities Y Y Y (2) Y (3) Y (4) N
Communication Y Y 25 30 N N

Manufacturing and Production
Manufacturing, general Y Y Y (2) Y (3) Y (4) N
Photographic and optical Y Y 25 30 N N
Agriculture (except livestock) and forestry Y Y (6) Y (7) Y (8) Y (8) Y (8) Livestock farming and breeding Y Y (6) Y (7) N N N
Mining and fishing, resource production
and extraction

Y Y Y Y Y Y

Recreational
Outdoor sports arenas and spectator sports Y Y (5) Y (5) N N N Outdoor music shells, amphitheaters Y N N N N N
Nature exhibits and zoos Y Y N N N N
Amusements, parks, resorts, and camps Y Y Y N N N
Golf courses, riding stables and water
recreation
Y Y 25 30 N N
Numbers in parenthesis refer to notes; see continuation of Table 1 for notes and key.

The designations contained in this table do not constitute a Federal determination that any use of land covered by the program is acceptable or unacceptable under Federal, State, or local law. The responsibility for determining the acceptable and permissible land uses and the relationship between specific properties and specific noise contours rests with the local authorities. FAA determinations under Part 150 are not intended to substitute Federally determined land uses for those determined to be appropriate by local authorities in response to locally determined needs and values in achieving noise compatible land uses.
(more)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND LEVELS (CONTINUED) Key to Table 1
Y (YES) Land Use and related structures compatible without restrictions.

N (NO) Land Use and related structures are not compatible and should be prohibited.

NLR Noise Level Reduction (outdoor to indoor) to be achieved through incorporation of noise attenuation into the design and construction of the structure. 25, 30, or
35 Land use and related structures generally compatible; measures to achieve NLR of 25, 30 or 35 dB must be incorporated into design and construction of structure.

Notes for Table 1
(1) Where the community determines that residential or school uses must be allowed, measures to achieve outdoor to indoor Noise Level Reduction (NLR) of at least 25 dB and 30 dB should be incorporated into building codes and be considered in individual approvals. Normal residential construction can be expected to provide a NLR of 20 dB, thus, the reduction requirements are often stated as 5, 10 or 15 dB over standard construction and normally assume mechanical ventilation and closed windows year round. However, the use of NLR criteria will not eliminate outdoor noise problems.
(2) Measures to achieve NLR of 25 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(3) Measures to achieve NLR of 30 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(4) Measures to achieve NLR of 35 dB must be incorporated into the design and construction of portions of these buildings where the public is received, office areas, noise sensitive areas or where the normal noise level is low.
(5) Land use compatible provided special sound reinforcement systems are installed. (6) Residential buildings require an NLR of 25.
(7) Residential buildings require an NLR of 30.
(8) Residential buildings not permitted.
(end of Table 1)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 CNEL 70 dB
CNEL 75 dB
CNEL 65 dB
101

CALIFORNIA
92 380

CALIFORNIA
82 CALIFORNIA
1 280

CALIFORNIA
35 E 3rd Ave
Hillside Blvd
Grand Ave
Linda Mar Blvd
Trousdale Dr
Ocea
na Blvd
Skyline Dr
Westborough Blvd
Fleetwood Dr
Sharp Park Rd
Crestmoor Dr
evA oetaM naS
Hickey Blvd
Old Bayshore Hwy
Southgate Ave
Fassler Ave
Crystal Springs Rd
N Amphlett Blvd
Huntington Ave
Adeline Dr
Hillside Dr
Junipero Serra Blvd
S Airport Blvd
S Spruce Ave
Peninsula Ave
Carmelita Ave
Lomita Ave
San Bruno Ave W
Howard Ave
E Grand Ave
Gateway Dr
Callan Blvd
Manzanita Dr
Millbrae Ave
Serramonte Blvd
Ludeman Ln
Airport Blvd
Sneath Ln
El Camino Real

SOUTH SAN FRANCISCO

BRISBANE

SAN BRUNO

BURLINGAME

PACIFICA

MILLBRAE
COLMA

DALY CITY

HILLSBOROUGH
28L
San Francisco Bay
Pacific Ocean
San Andreas Lake
San Francisco International Airport
1L1R
1 L9
91 R
10L
10R
28R

SAN MATEO

UNINCORPORATED

FOSTER CITY
0 5,000
Feet
Airport Property Boundary
Aircraft Noise Contour
Municipal Boundary

NOISE SENSITIVE FACILITIES
School
Hospital
Place of Worship
Historic Structures

GENERALIZED EXISTING LAND USE
Single Family Residential
Multi-Family Residential
Commercial
Industrial
Public
Mixed Use
Open Space/Recreation/Preservation
Park/Golf Course/Cemetery
Water
Vacant/Unknown
CNEL – Community Noise Equivalent Level
dB – Decibel
SFO 14 CFR Part 150 Noise Exposure Map Report . 120832
SOURCES: ESRI, 2014; San Mateo County Planning and Building Department, 2014; BridgeNet International, 2014; ESA Airports, 2014 Exhibit 5-2 2019 Noise Exposure Map – San Francisco International Airport Enclosure (2)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 San Francisco International Airport
Arrival
Preparing for landing at SFO to Runway 10 end. Photo taken on January 22, 2022.

Enclosure (3)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Tanforan
ShoppingCenter
Airport Design Approach/Departure Obstruction Clearance Surface (OCS) for SFO Runway 10R/28L and Runway 10L/28R and Location of Current Tanforan Shopping Center Enclosure {4}
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Approach/Departure OCS Profiles
Enclosure {5}
TanforanShopping Center
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-34] Airport/Land Use Compatibility Policies
and associated with human disease of varying severity.
b. Biosafety Level 3 practices, safety equipment, and facility design and construction are applicable to clinical, diagnostic, teaching, research, or production facilities in which work is done with indigenous or exotic agents with a potential for respiratory transmission, and which may cause serious and potentially lethal infection. c. Biosafety Level 4 practices, safety equipment, and facility design and construction are applicable for work with dangerous and exotic agents that pose a high individual risk of life-threatening disease, which may be transmitted via the aerosol route and for which there is no available vaccine or therapy.

4.5 Airspace Protection
The compatibility of proposed land uses with respect to airspace protection shall be evaluated in accordance with the policies set forth in this section. These policies are established with a twofold purpose:

1. To protect the public health, safety, and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures.

2. To protect the public interest in providing for the orderly development of SFO by ensuring that new development in the Airport environs avoids compromising the airspace in the Airport vicinity. This avoids the degradation in the safety, utility, efficiency, and air service capability of the Airport that could be caused by the attendant need to raise visibility minimums, increase minimum rates of climb, or cancel, restrict, or redesign flight procedures.

4.5.1 FEDERAL REGULATIONS REGARDING TALL STRUCTURES
14 Code of Federal Regulations (CFR) Part 77, Safe, Efficient Use and Preservation of the Navigable Airspace, governs the FAA’s review of proposed construction exceeding certain height limits, defines airspace obstruction criteria, and provides for FAA aeronautical studies of proposed construction. Appendix F describes the FAA airspace review process and the extent of FAA authority related to airspace protection.

4.5.2 PART 77, SUBPART B, NOTIFICATION PROCESS
Federal regulations require any person proposing to build a new structure or alter an existing structure with a height that would exceed the elevations described in CFR Part 77, Subpart B, Section 77.9, to prepare an FAA Form 7460-1, Notice of Proposed Construction or Alteration, and submit the notice to the FAA. The regulations apply to buildings and other structures or portions of structures, such as mechanical equipment, flag poles, and other projections that may exceed the aforementioned elevations.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-35]
Exhibit IV-10 depicts the approximate elevations at which the 14 CFR Part 77 notification requirements would be triggered; see Exhibit IV-11 for a close-up view of the northern half and Exhibit IV-12 for a close-up view of the southern half of the area. These exhibits are provided for informational purposes only. Official determinations of the areas and elevations within which the federal notification requirements apply are subject to the authority of the FAA.

The FAA is empowered to require the filing of notices for proposed construction based on considerations other than height. For example, in some areas of complex airspace and high air traffic volumes, the FAA may be concerned about the potential for new construction of any height to interfere with electronic navigation aids. In these areas, the FAA will want to review all proposed construction projects.

The FAA has developed an on-line tool for project sponsors to use in determining whether they are required to file a Notice of Proposed Construction or Alteration. Sponsors of proposed projects are urged to refer to this website to determine whether they are required to file Form 7460-1 with the FAA:
https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm

4.5.3 AIRSPACE MAPPING
Part 77, Subpart C, establishes obstruction standards for the airspace around airports including approach zones, conical zones, transitional zones, and horizontal zones known as “imaginary surfaces.” Exhibit IV-13 depicts the Part 77 Civil Airport Imaginary Surfaces at SFO. The imaginary surfaces rise from the primary surface, which is at ground level immediately around the runways. The surfaces rise gradually along the approach slopes associated with each runway end and somewhat more steeply off the sides of the runways. The FAA considers any objects penetrating these surfaces, whether buildings, trees or vehicles travelling on roads and railroads, as obstructions to air navigation.

Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.

Close-up views of the north and south sides of the Part 77 surfaces are provided in Exhibit IV-14 and Exhibit IV-15, respectively. Additionally, Exhibit IV-16 provides an illustration of the outer approach and transitional surfaces located on the southeast side of the Part 77 surfaces.

Together with its tenant airlines, SFO has undertaken a mapping effort to illustrate the critical aeronautical surfaces that protect the airspace required for multiple types of flight procedures such as those typically factored into FAA aeronautical studies, as shown on Exhibit IV-17 and Exhibit IV-18. These aeronautical surfaces include those established in accordance with FAA Order 8260.3B, U.S. Standard for Terminal Instrument Procedures (TERPS), and a surface representing the airspace required for One-Engine Inoperative (OEI) departures from Runway 28L (to the west through the San Bruno Gap).16 The exhibits depict the lowest elevations from the combination of the OEI procedure surface and all TERPS surfaces. The surfaces are defined with Required Obstacle Clearance (ROC) criteria to ensure safe separation of aircraft using the procedures from the underlying obstacles. Any proposed structures penetrating these surfaces are likely to receive Determinations of Hazard (DOH) from the FAA through the 7460-1 aeronautical study process. These surfaces indicate the maximum height at which structures can be considered compatible with Airport operations.

16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 280
380
280
280
101
101
101
101
1 35
82 82
1 1
82 ROLLINS RD

HILLSIDE BLVD
E 3RD AVE

CALIFORNIA DR

BAYSHORE BLVD

EL CAMINO REAL MISSION RD
87TH ST

AIRPORT BL V D

CALLAN BLVD

GRAND AVE

MILLER AVE

SOUTHG ATE AVE

TRO USDALE DR

SHARP PA RK RD

SNEATH LN

PARK WY

C R ESPI DR

FLEETWOO D D R

MURCHISON D R

SULLIVAN AVE

ST FR ANCIS BLVD

JOHN DALY BLVD

RALSTON AVE

HE LEN DR

A RROYO DR

S AIRPORT BLVD

SKYLINE BO ULEVARD

GENEVA AVE

N HUMBOLDT ST

FASSLER AVE

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D
STATE HIGHWAY 35

HUNTINGTON AVE

LIN DA MAR BL VD

HICKEY BL V D

SHAW RD

ADELINE DR
E 4TH AVE

TERRA NOVA BLVD

HILLSIDE DR

LINDEN AVE

LO M ITA AVE

S SPR UCE AVE

SERRA M ONTE BL VD

CHESTNUT AVE

N DELAWARE ST

BELLEVUE AVE

E GRAND AVE

S NORFOLK ST

HOLLY A VE

CARMELITA AVE

S LINDEN AVE

UTAH AVE

LOYOLA DR
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

C RESTMOOR DR

JENEVEIN AVE

MADISON AVE

MILLBRAE AVE

SISTER CITIES BLVD

CRYSTA L S PRINGS RD

W SAN B RUNO A V E

SEBASTIAN DR ALTA MESA DR

LER ID A WY

PARK PLAZA DR

PAR K BLVD

JUNIPERO SERRA BLVD

ALICA N TE DR

MAGNOLIA AVE

SAN MATEO AVE

BROADWAY

HOFFMAN ST

RICHMOND DR

SE VILLE DR

MONTEREY RD

RIDGEWOOD DR

EASTON DR

EAR L AV E

SAN ANTONIO AVE

SHARON AVE

LARKSPUR DR

GATEWA Y DR

EL CERRITO AVE

CHATEAU DR

WESTLAKE AVE

BELLA VISTA DR

LIT T LEFIELD AVE

CROCKER AVE

E MARKET ST

LINCOLN AVE

OAKS DR

EL CAMINO REAL

ODDSTAD BLVD

HUNT DR

SUMMIT DR

EUCALYPTUS AVE

HELEN DR
STATE HIGHWAY 35

W SAN BRUNO AVE

EL CAM NI O REAL

SNEAT H LN

MAGNOLIA AVE

HILLSIDE BLVD
E 3RD AVE
Pacifica Pacifica
Daly City Daly City
San Bruno San Bruno
Brisbane Brisbane
San Mateo San Mateo
Colma Colma
Hillsborough Hillsborough
South San Francisco South San Francisco
Millbrae Millbrae Burlingame Burlingame
San Francisco San Francisco
Foster City Foster City
Broadmoor Broadmoor
Montara Montara
San Pedro Valley County Park San Pedro Valley County Park San Bruno Mt State & Cnty Park San Bruno Mt State & Cnty Park Golden Gate National Rec Area Golden Gate National Rec Area McNee Ranch State Park McNee Ranch State Park
San Andreas Lake San Andreas Lake

1. This map is intended for informational and conceptual planning purposes, generally representing the aeronautical surfaces considered most critical by San Francisco
International Airport (SFO) and its constituent airlines. It does not represent actual survey data, nor should it be used as the sole source of information regarding compatibility with airspace clearance requirements in the development of data for an FAA Form 7460-1, Notice of Proposed Construction or Alteration.

SFO does not certify its accuracy, information, or title to the properties contained in this plan. SFO does make any
warrants of any kind, express or implied, in fact or by law, with respect to boundaries, easements, restrictions, claims, overlaps, or other encumbrances affecting such properties.

2. This map does not replace the FAA's obstruction evaluation / airport airspace analysis (OE/AAA) review process. Proposing construction at elevations and heights that are lower than the critical aeronautical surfaces shown on this map, (a) does not relieve the construction sponsor of the obligation to file an FAA Form 7460-1, and (b) does not ensure that the proposal will be acceptable to the FAA, SFO, air carriers, or other agencies or stakeholders. SFO, San Mateo County, and local authorities having jurisdiction reserve the right to re-assess, review, and seek modifications to projects that may be consistent with this critical aeronautical surfaces map but that through the FAA OE/AAA process are found to have unexpected impacts to the safety or efficiency of operations at SFO.

Notes:

Exhibit IV-17

CRITICAL AERONAUTICAL SURFACES
-- NORTHWEST SIDE
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport C/CAG
City/County Association of Governments
of San Mateo County, California
Municipal Boundary
Road
Freeway
Railroad
Airport Property
BART Station
CALTRAIN Station
Regional Park or Recreation Area
Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
0 0.5 1 0.25
Miles
NORTH
Ground level
(Terrain)
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Height of Critical Aeronautical Surfaces, Feet Above
Ground Level (AGL)
LEGEND
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

AIRPORT
Mean sea level
Elevation, feet AMSL
100 200 300 400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces,feet AGL (represented on plan with color gradient) Calculated as - =
0 Ground level
(Terrain)
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 LEGEND
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Exhibit IV-18

CRITICAL AERONAUTICAL SURFACES
-- SOUTHEAST SIDE
Comprehensive Airport Land Use Plan
for the Environs of San Francisco International Airport C/CAG
City/County Association of Governments
of San Mateo County, California
Height of Critical Aeronautical Surfaces, Feet Above
Ground Level (AGL)
Municipal Boundary
Road
Freeway
Railroad
Airport Property
BART Station
CALTRAIN Station
Regional Park or Recreation Area
0 0.5 1 0.25
Miles
NORTH
SQL
82 280
101
101
101
92 82
92 92

ROLLINS RD
E 3RD AVE

CALIFORNIA DR

S NORFOLK ST

ALAMEDA DE LAS PULGAS

P A RRO TT DR

E HILLSDALE BLVD

AIRPORT B LVD

CRYSTAL SP RIN GS RD
31ST AVE
28TH AVE

S DELAWARE ST

S GRANT ST

W HILLSDALE BLVD

HA YNE R D

OLD COUNTY RD
ELM ST
9TH AVE

FOSTER CITY BLVD

TRO USDALE DR

HALL MA RK DR
42N D AVE

MURCHISON D R

SHELL BLVD

CHATEAU DR

SAN C A RLOS AVE

CANA D A R D

HILLER ST

M A RINE PKWY

BEACH PARK BLVD

RALSTON AVE

N HUMBOLDT ST

POLH EMUS RD

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D

EL CERRITO AVE

SHAW RD
22ND AVE
STATE HI GHWAY 92

CEDAR ST

ADELINE DR

HILLSIDE DR

N DELAWARE ST

BUNKER HILL DR

DE ANZA BLVD

S AIRPORT BLVD

SOUT H RD

CARMELITA AVE
E 40TH A VE

LOYOLA DR

EDINBURGH ST

REDWOOD SHORES PKWY
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

BOREL AVE

PALM AVE

SEAPORT BLVD

M A RINERS IS L A ND BLVD

MILLBRAE AVE

KEHOE AVE

SEBASTIAN DR

S AMPHLETT BLVD

VIRGINIA AVE

PA RK BLVD

SHELL PKWY

MAGNOLIA AVE

CURTISS ST

PASADENA DR

CHULA VISTA DR

W SANTA INEZ AVE

LEXINGTO N AVE

GLENDORA DR

LAUREL ST

LOS P RAD OS
ALLEY

BROADWAY

HELEN DR

RICHMOND DR

NORTE DAME AVE
W 25TH AVE

POR T ROYAL AVE

EASTON DR

TICOND E R O G A D R

SAN ANTONIO AVE

SWORDFISH ST

SHARON AVE

SANDERLING ST
W 5TH AVE

EL CAMINO REAL

FOREST VIEW AVE

BELLA VISTA DR

COLUMBIA DR

SAN MATEO AVE

OAKS DR

ARBOR AVE

TILIA ST

BARROILHET AVE
E 25TH AVE

HUNT DR

BERMUDA DR

SUMMIT DR

HELEN DR

BEACH PARK BLVD

MAGNOLIA AVE

PALM AVE
E 3RD AVE

RALSTON AVE
Lower Crystal Springs Rsvr Lower Crystal Springs Rsvr
Upper Crystal Reservoir Upper Crystal Reservoir
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

AIRPORT
Ground level
(Terrain)
Mean sea level
Elevation, feet AMSL
100 200 300 400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces, feet AGL (represented on plan with color gradient) Calculated as - =
0 1. This map is intended for informational and conceptual planning purposes, generally representing the aeronautical surfaces considered most critical by San Francisco
International Airport (SFO) and its constituent airlines. It does not represent actual survey data, nor should it be used as the sole source of information regarding compatibility with airspace clearance requirements in the development of data for an FAA Form 7460-1, Notice of Proposed Construction or Alteration.

Notes:

Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-55]
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace surfaces along the extended centerline of Runway 10L-28R – the TERPS Obstacle Departure Procedure (ODP) surface, representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace surfaces and various aircraft approach and departure profiles, based on varying operating assumptions. The exhibit illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always designed below the actual aircraft flight profile which they are designed to protect, thus providing a margin of safety.

Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.

4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.

AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED

CONSTRUCTION OR ALTERATION
AP-1.1 Local Government Responsibility to Notify Project Sponsors Local governments should notify sponsors of proposed projects at the earliest opportunity to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA for any proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10. Under Federal law, it is the responsibility of the project sponsor to comply with all notification and other requirements described in 14 CFR Part 77. This requirement applies independent of this ALUCP.

AP-1.2 FAA Aeronautical Study Findings Required Before Processing Development Application
The sponsor of a proposed project that would exceed the FAA notification heights, as shown approximately on Exhibit IV-10, shall present to the local government permitting agency with his or her application for a development permit, a copy of the findings of the FAA’s aeronautical study, or evidence demonstrating that he or she is exempt from having to file an FAA Form 7460-1. It is the responsibility of the local agency to consider the FAA determination study findings as part of its review and decision on the proposed project.

AP-2 COMPLIANCE WITH FINDINGS OF FAA AERONAUTICAL STUDIES Project sponsors shall be required to comply with the findings of FAA aeronautical studies with respect to any recommended alterations in the building design and height and any recommended marking and lighting of their structures for their proposed projects to be deemed consistent with this ALUCP.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-59]
AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or (2) the maximum height determined not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.

For the vast majority of parcels, the height limits established in local zoning ordinances are lower than the critical airspace surfaces. In those cases, the zoning district height regulations will control. Compliance with the zoning district height and the SFO critical aeronautical surfaces map, however, does not relieve the construction sponsor of the obligation to file a FAA Form 7460-1 Notice of Proposed Construction or Alteration, if required, and to comply with the determinations resulting from the FAA’s aeronautical study.

For a project to be consistent with this ALUCP, no local agency development permits shall be issued for any proposed structure that would penetrate the aeronautical surfaces shown on Exhibits IV-17 and IV-18 or the construction of which has not received a Determination of No Hazard from the FAA, or which would cause the FAA to increase the minimum visibility requirements for any instrument approach or departure procedure at the Airport.

AP-4 OTHER FLIGHT HAZARDS ARE INCOMPATIBLE
Proposed land uses with characteristics that may cause visual, electronic, or wildlife hazards, particularly bird strike hazards, to aircraft taking off or landing at the Airport or in flight are incompatible in Area B of the Airport Influence Area. They may be permitted only if the uses are consistent with FAA rules and regulations. Proof of consistency with FAA rules and regulations and with any performance standards cited below must be provided to the Airport Land Use Commission (C/CAG Board) by the sponsor of the proposed land use action.

Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a) Sources of glare, such as highly reflective buildings or building features, or bright lights, including search lights or laser displays, which would interfere with the vision of pilots making approaches to the Airport.
(b) Distracting lights that that could be mistaken by pilots on approach to the Airport for airport identification lighting, runway edge lighting, runway end identification lighting, or runway approach lighting.
(c) Sources of dust, smoke, or water vapor that may impair the vision of pilots making approaches to the Airport.
(d) Sources of electrical interference with aircraft or air traffic control communications or navigation equipment, including radar.
(e) Land uses that, as a regular byproduct of their operations, produce thermal plumes with the potential to rise high enough and at sufficient velocities to interfere with the control of aircraft in DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-60] Airport/Land Use Compatibility Policies
flight. Upward velocities of 4.3 meters (14.1 feet) per second at altitudes above 200 feet above the ground shall be considered as potentially interfering with the control of aircraft in flight.17 (f) Any use that creates an increased attraction for wildlife, particularly large flocks of birds, that is inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.5A, Waste Disposal Sites On or Near Airports, FAA Advisory Circular 150/5200-33B, Hazardous Wildlife Attractants On or Near Airports, and any successor or replacement orders or advisory circulars. Exceptions to this policy are acceptable for wetlands or other environmental mitigation projects required by ordinance, statute, court order, or Record of Decision issued by a federal agency under the National Environmental Policy Act.

4.5.5 iALP AIRSPACE TOOL
In consultation with C/CAG, SFO developed the iALP Airspace Tool, a web-based, interactive tool to evaluate the relationship of proposed buildings with the Airport’s critical airspace surfaces. The iALP Airspace Tool is designed to assist planners, developers, and other interested persons with the implementation of the airspace protection policies of the SFO ALUCP. The tool helps users determine: (1) the maximum allowable building height at a given site, and/or (2) whether a building penetrates a critical airspace surface, and by how much, given the proposed building height.

A more detailed description of the iALP Airspace Tool and a tutorial explaining how to use it is presented in Appendix J. Use of this tool, however, does not relieve a project sponsor of the duty to comply with all federal regulations, including the obligation to file Form 7460-1, Notice of Proposed Construction or Alteration, with the FAA. 17 This is a threshold established by the California Energy Commission in its review of power plant licensing applications. See Blythe Solar Power Project:

Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.

25. This criterion is based on guidance established by the Australian Government Civil Aviation Authority (Advisory Circular AC 139-05(0), June 2004). The FAA’s Airport Obstructions Standards Committee (AOSC) is studying this matter but has not yet issued specific guidance.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 Attachment B
Excerpt from SFO ALUCP (Exhibit IV-17 and Airspace Protection Policies)
DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-34] Airport/Land Use Compatibility Policies
and associated with human disease of varying severity.
b. Biosafety Level 3 practices, safety equipment, and facility design and construction are applicable to clinical, diagnostic, teaching, research, or production facilities in which work is done with indigenous or exotic agents with a potential for respiratory transmission, and which may cause serious and potentially lethal infection. c. Biosafety Level 4 practices, safety equipment, and facility design and construction are applicable for work with dangerous and exotic agents that pose a high individual risk of life-threatening disease, which may be transmitted via the aerosol route and for which there is no available vaccine or therapy.

1. To protect the public health, safety, and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures.

Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.

16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 280
380
280
280
101
101
101
101
1 35
82 82
1 1
82 ROLLINS RD

HILLSIDE BLVD
E 3RD AVE

CALIFORNIA DR

BAYSHORE BLVD

EL CAMINO REAL MISSION RD
87TH ST

AIRPORT BL V D

CALLAN BLVD

GRAND AVE

MILLER AVE

SOUTHG ATE AVE

TRO USDALE DR

SHARP PA RK RD

SNEATH LN

PARK WY

C R ESPI DR

FLEETWOO D D R

MURCHISON D R

SULLIVAN AVE

ST FR ANCIS BLVD

JOHN DALY BLVD

RALSTON AVE

HE LEN DR

A RROYO DR

S AIRPORT BLVD

SKYLINE BO ULEVARD

GENEVA AVE

N HUMBOLDT ST

FASSLER AVE

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D
STATE HIGHWAY 35

HUNTINGTON AVE

LIN DA MAR BL VD

HICKEY BL V D

SHAW RD

ADELINE DR
E 4TH AVE

TERRA NOVA BLVD

HILLSIDE DR

LINDEN AVE

LO M ITA AVE

S SPR UCE AVE

SERRA M ONTE BL VD

CHESTNUT AVE

N DELAWARE ST

BELLEVUE AVE

E GRAND AVE

S NORFOLK ST

HOLLY A VE

CARMELITA AVE

S LINDEN AVE

UTAH AVE

LOYOLA DR
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

C RESTMOOR DR

JENEVEIN AVE

MADISON AVE

MILLBRAE AVE

SISTER CITIES BLVD

CRYSTA L S PRINGS RD

W SAN B RUNO A V E

SEBASTIAN DR ALTA MESA DR

LER ID A WY

PARK PLAZA DR

PAR K BLVD

JUNIPERO SERRA BLVD

ALICA N TE DR

MAGNOLIA AVE

SAN MATEO AVE

BROADWAY

HOFFMAN ST

RICHMOND DR

SE VILLE DR

MONTEREY RD

RIDGEWOOD DR

EASTON DR

EAR L AV E

SAN ANTONIO AVE

SHARON AVE

LARKSPUR DR

GATEWA Y DR

EL CERRITO AVE

CHATEAU DR

WESTLAKE AVE

BELLA VISTA DR

LIT T LEFIELD AVE

CROCKER AVE

E MARKET ST

LINCOLN AVE

OAKS DR

EL CAMINO REAL

ODDSTAD BLVD

HUNT DR

SUMMIT DR

EUCALYPTUS AVE

HELEN DR
STATE HIGHWAY 35

W SAN BRUNO AVE

EL CAM NI O REAL

SNEAT H LN

MAGNOLIA AVE

Notes:

Exhibit IV-17

ROLLINS RD
E 3RD AVE

CALIFORNIA DR

S NORFOLK ST

ALAMEDA DE LAS PULGAS

P A RRO TT DR

E HILLSDALE BLVD

AIRPORT B LVD

CRYSTAL SP RIN GS RD
31ST AVE
28TH AVE

S DELAWARE ST

S GRANT ST

W HILLSDALE BLVD

HA YNE R D

OLD COUNTY RD
ELM ST
9TH AVE

FOSTER CITY BLVD

TRO USDALE DR

HALL MA RK DR
42N D AVE

MURCHISON D R

SHELL BLVD

CHATEAU DR

SAN C A RLOS AVE

CANA D A R D

HILLER ST

M A RINE PKWY

BEACH PARK BLVD

RALSTON AVE

N HUMBOLDT ST

POLH EMUS RD

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D

EL CERRITO AVE

SHAW RD
22ND AVE
STATE HI GHWAY 92

CEDAR ST

ADELINE DR

HILLSIDE DR

N DELAWARE ST

BUNKER HILL DR

DE ANZA BLVD

S AIRPORT BLVD

SOUT H RD

CARMELITA AVE
E 40TH A VE

LOYOLA DR

EDINBURGH ST

REDWOOD SHORES PKWY
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

BOREL AVE

PALM AVE

SEAPORT BLVD

M A RINERS IS L A ND BLVD

MILLBRAE AVE

KEHOE AVE

SEBASTIAN DR

S AMPHLETT BLVD

VIRGINIA AVE

PA RK BLVD

SHELL PKWY

MAGNOLIA AVE

CURTISS ST

PASADENA DR

CHULA VISTA DR

W SANTA INEZ AVE

LEXINGTO N AVE

GLENDORA DR

LAUREL ST

LOS P RAD OS
ALLEY

BROADWAY

HELEN DR

RICHMOND DR

NORTE DAME AVE
W 25TH AVE

POR T ROYAL AVE

EASTON DR

TICOND E R O G A D R

SAN ANTONIO AVE

SWORDFISH ST

SHARON AVE

SANDERLING ST
W 5TH AVE

EL CAMINO REAL

FOREST VIEW AVE

BELLA VISTA DR

COLUMBIA DR

SAN MATEO AVE

OAKS DR

ARBOR AVE

TILIA ST

BARROILHET AVE
E 25TH AVE

HUNT DR

BERMUDA DR

SUMMIT DR

HELEN DR

BEACH PARK BLVD

MAGNOLIA AVE

PALM AVE
E 3RD AVE

RALSTON AVE
Lower Crystal Springs Rsvr Lower Crystal Springs Rsvr
Upper Crystal Reservoir Upper Crystal Reservoir
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

Notes:

Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.

4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.

AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-59]
AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or (2) the maximum height determined not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.

Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 2BBAF045-616C-49AC-BF3A-E566D5C48892 January 9, 2023
Michael Smith, Senior Planner
Planning Division
City of San Bruno
567 El Camino Real
San Bruno, California, 94066
Subject: Comments on Initial Study/Mitigated Negative Declaration for the San Bruno 2023–2031 Housing Element Update
Dear Mr. Smith:

The San Mateo County Flood and Sea Level Rise Resiliency District (OneShoreline) and the County of San Mateo Department of Public Works, in its capacity as a consultant for OneShoreline, has reviewed the San Bruno 2023–2031 Housing Element Update and offer the following comments.

Comments

1. Effective January 1, 2020, A.B. 825 (C.A., 2019) amended the San Mateo County Flood Control District Act to expand the San Mateo County Flood Control District's responsibilities, create an independent governing board for the District, and rename the District the San Mateo County Flood and Sea Level Rise Resiliency District (OneShoreline). The flood zones (Colma Creek, San Bruno Creek, San Francisquito Creek, and Ravenswood Slough) that were formerly administered by the County of San Mateo Department of Public Works are now being managed by the new District. Therefore, where the former San Mateo County Flood Control District was used in the City’s IS-MND shall be updated to the San Mateo County Flood and Sea Level Rise Resiliency District.

2. For proposed developments in the Sea Level Rise Overlay District in San Bruno, OneShoreline would like to work with the City to review and comment on projects early in the development review process to ensure that flooding risks are evaluated and resilient design practices are incorporated into projects early.

OneShoreline defines the Sea Level Rise Overlay District as the composite area including:
a. The area within Flood Zone X or V of the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM); and
b. The area identified in the Our Coast, Our Future Hazard Map as the 100-year flood plus 6.6 feet of sea level rise (based on modeling results from the U.S. Geological Survey).

3. Proposed developments proximate to San Bruno Creek should expect that flood/sea level rise protection and other enhancements (Flood Protection Infrastructure) in this area will be improved on a regional scale to align with long-term sea level rise protection along adjoining areas of the shoreline. To avoid a scenario where a development site must be retrofitted to accommodate this Flood Protection Infrastructure in a way that disrupts the site in the future, developers should coordinate directly with staff of OneShoreline and other relevant stakeholders to ensure proposed development applications align with a comprehensive and specific plan for long-term sea level rise protection in the San Bruno watershed.

Comments on San Bruno Housing Element Update IS/MND
January 9, 2023

Page 2 ends

4. For proposed developments and adjacent public and private assets to function under long-term future climate-driven conditions, stormwater conveyance infrastructure for all proposed sites should be designed with future conditions in mind.
a. For stormwater conveyance infrastructure impacted by coastal hazards, infrastructure should be designed (e.g., through elevations, backflow valves) such that it can continue to function during a Bay water level equivalent to the Base Flood Elevation (BFE) defined by FEMA plus 6 feet. This is the OneShoreline Protection Standard.
b. As another aspect of climate change is the occurrence of infrequent, but more extreme, storm events, proposed developments should ensure that at least the first 1.25 inches of rainwater from an individual storm event remains on the development site.

5. For proposed developments in the San Bruno Creek Flood Control Zone and Colma Creek Flood Control Zone (Zones) that require modification of site storm drain systems and site runoffs, the City shall include OneShoreline in the project/plan review process.

6. For the proposed development sites that are located within the Zones, OneShoreline requires that the discharge rate from each of these development sites not exceed the existing rate prior to development, and drainage analyses and calculations showing existing and future discharge rates must be submitted for review and approval. If it is determined that the future discharge rate exceeds the existing rate, an on-site storm water detention system, which would release surface runoff at a rate comparable to the existing flow rate of the site, must be designed and incorporated into the project.

7. OneShoreline encourages trash management measures be incorporated into future projects’ design elements of the storm drainage system and appurtenances to keep trash out of local creeks, streams and OneShoreline’s flood channels. Please ensure that the trash collecting devices are installed at storm drain inlets and maintained by the property owner(s).

8. OneShoreline anticipates that the City will be reviewing any bio-retention facilities proposed by future projects for compliance with requirements of Provision C.3.d of the NPDES Municipal Regional Stormwater Permit (Order No. R2-2022-0018) from the San Francisco Bay Regional Water Quality Control Board.

Thank you for the opportunity to comment on this important document. Please let me know if you have any questions about our comments.

Sincerely,
Len Materman
Chief Executive Officer
2023-2031 Housing Element Update Responses to Comments Memorandum City of San Bruno January 2023
Appendix B: Revised Noise and Vibration Assessment (Revised January 17, 2023)

HOUSING ELEMENT UPDATE

NOISE AND VIBRATION ASSESSMENT
San Bruno, California
January 17, 2023
Prepared for:

Matthew Moore, MUP
Project Manager
David J. Powers & Associates, Inc.
1736 Franklin Street, Suite 400
Oakland, CA 94612
Prepared by:

Michael Thill
429 East Cotati Avenue
Cotati, CA 94931
(707) 794-0400
I&R Project: 22-117
1 INTRODUCTION
The purpose of this report is to assess potential noise and vibration impacts associated with the proposed 2023-2031 Housing Element Update (HEU). The proposed 2023-2031 Housing Element will replace the existing 2015-2023 Housing Element and serve as the City of San Bruno’s guiding policy document for meeting the City’s future housing needs at all economic levels. As a policy document, the Housing Element does not result in direct physical changes to the environment but would indirectly lead to physical environmental changes by enabling the development of approximately 2,708 additional housing units within the City’s jurisdiction. All future housing development in the City must comply with the General Plan, zoning ordinance, state and federal permits, and local development standards. In addition, future discretionary actions (i.e., use permits, site plan review) require independent and project-specific environmental review to comply with CEQA.

The Noise and Vibration Assessment includes a Setting section providing a brief description of the fundamentals of environmental noise and vibration, summarizes the applicable regulatory criteria, and discusses the results of ambient noise monitoring surveys completed to document existing conditions. The General Plan Consistency section evaluates the noise environment at each of the 23 housing opportunities sites. The Impacts and Mitigation Measures section describes the significance criteria used to evaluate potential impacts, provides a description of each impact, and presents mitigation measures where necessary to provide a guideline for the implementation of the HEU for the City of San Bruno.

SETTING
Fundamentals of Environmental Noise
Noise may be defined as unwanted sound. Noise is usually objectionable because it is disturbing or annoying. The objectionable nature of sound could be caused by its pitch or its loudness. Pitch is the height or depth of a tone or sound, depending on the relative rapidity (frequency) of the vibrations by which it is produced. Higher pitched signals sound louder to humans than sounds with a lower pitch. Loudness is intensity of sound waves combined with the reception characteristics of the ear. Intensity may be compared with the height of an ocean wave in that it is a measure of the amplitude of the sound wave.

In addition to the concepts of pitch and loudness, there are several noise measurement scales which are used to describe noise in a particular location. A decibel (dB) is a unit of measurement which indicates the relative amplitude of a sound. The zero on the decibel scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Sound levels in decibels are calculated on a logarithmic basis. An increase of 10 decibels represents a ten-fold increase in acoustic energy, while 20 decibels is 100 times more intense, 30 decibels is 1,000 times more intense, etc. There is a relationship between the subjective noisiness or loudness of a sound and its intensity. Each 10 decibel increase in sound level is perceived as approximately a doubling of loudness over a fairly wide range of intensities. Technical terms are defined in Table 1. 2 There are several methods of characterizing sound. The most common in California is the Aweighted sound level (dBA). This scale gives greater weight to the frequencies of sound to which the human ear is most sensitive. Representative outdoor and indoor noise levels in units of dBA are shown in Table 2. Because sound levels can vary markedly over a short period of time, a method for describing either the average character of the sound or the statistical behavior of the variations must be utilized. Most commonly, environmental sounds are described in terms of an average level that has the same acoustical energy as the summation of all the time-varying events.

This energy-equivalent sound/noise descriptor is called Leq. The most common averaging period is hourly, but Leq can describe any series of noise events of arbitrary duration.

The scientific instrument used to measure noise is the sound level meter. Sound level meters can accurately measure environmental noise levels to within about plus or minus 1 dBA. Various computer models are used to predict environmental noise levels from sources, such as roadways and airports. The accuracy of the predicted models depends upon the distance the receptor is from the noise source. Close to the noise source, the models are accurate to within about plus or minus 1 to 2 dBA.

Since the sensitivity to noise increases during the evening and at night -- because excessive noise interferes with the ability to sleep -- 24-hour descriptors have been developed that incorporate artificial noise penalties added to quiet-time noise events. The Community Noise Equivalent Level (CNEL) is a measure of the cumulative noise exposure in a community, with a 5 dB penalty added to evening (7:00 pm - 10:00 pm) and a 10 dB addition to nocturnal (10:00 pm - 7:00 am) noise levels. The Day/Night Average Sound Level (Ldn or DNL) is essentially the same as CNEL, with the exception that the evening time period is dropped and all occurrences during this three-hour period are grouped into the daytime period.

Effects of Noise
Sleep and Speech Interference
The thresholds for speech interference indoors are about 45 dBA if the noise is steady and above 55 dBA if the noise is fluctuating. Outdoors the thresholds are about 15 dBA higher. Steady noises of sufficient intensity (above 35 dBA) and fluctuating noise levels above about 45 dBA have been shown to affect sleep. Interior residential standards for multi-family dwellings are set by the State of California at 45 dBA Ldn. Typically, the highest steady traffic noise level during the daytime is about equal to the Ldn and nighttime levels are 10 dBA lower. The standard is designed for sleep and speech protection and most jurisdictions apply the same criterion for all residential uses.

Typical structural attenuation is 12-17 dBA with open windows. With closed windows in good condition, the noise attenuation factor is around 20 dBA for an older structure and 25 dBA for a newer dwelling. Sleep and speech interference is therefore possible when exterior noise levels are about 57-62 dBA Ldn with open windows and 65-70 dBA Ldn if the windows are closed. Levels of 55-60 dBA are common along collector streets and secondary arterials, while 65-70 dBA is a typical value for a primary/major arterial. Levels of 75-80 dBA are normal noise levels at the first row of development outside a freeway right-of-way. In order to achieve an acceptable interior noise environment, bedrooms facing secondary roadways need to be able to have their windows closed, those facing major roadways and freeways typically need special glass windows. 3 Annoyance
Attitude surveys are used for measuring the annoyance felt in a community for noises intruding into homes or affecting outdoor activity areas. In these surveys, it was determined that the causes for annoyance include interference with speech, radio and television, house vibrations, and interference with sleep and rest. The Ldn as a measure of noise has been found to provide a valid correlation of noise level and the percentage of people annoyed. People have been asked to judge the annoyance caused by aircraft noise and ground transportation noise. There continues to be disagreement about the relative annoyance of these different sources. When measuring the percentage of the population highly annoyed, the threshold for ground vehicle noise is about 50 dBA Ldn. At a Ldn of about 60 dBA, approximately 12 percent of the population is highly annoyed.

When the Ldn increases to 70 dBA, the percentage of the population highly annoyed increases to about 25-30 percent of the population. There is, therefore, an increase of about 2 percent per dBA between a Ldn of 60-70 dBA. Between a Ldn of 70-80 dBA, each decibel increase increases by about 3 percent the percentage of the population highly annoyed. People appear to respond more adversely to aircraft noise. When the Ldn is 60 dBA, approximately 30-35 percent of the population is believed to be highly annoyed. Each decibel increase to 70 dBA adds about 3 percentage points to the number of people highly annoyed. Above 70 dBA, each decibel increase results in about a 4 percent increase in the percentage of the population highly annoyed. 4 TABLE 1 Definition of Acoustical Terms Used in this Report Term Definition
Decibel, dB A unit describing, the amplitude of sound, equal to 20 times the logarithm to the base 10 of the ratio of the pressure of the sound measured to the reference pressure. The reference pressure for air is 20 micro Pascals.

Sound Pressure Level Sound pressure is the sound force per unit area, usually expressed in micro Pascals (or 20 micro Newtons per square meter), where 1 Pascal is the pressure resulting from a force of 1 Newton exerted over an area of 1 square meter. The sound pressure level is expressed in decibels as 20 times the logarithm to the base 10 of the ratio between the pressures exerted by the sound to a reference sound pressure (e. g., 20 micro Pascals). Sound pressure level is the quantity that is directly measured by a sound level meter.

Frequency, Hz The number of complete pressure fluctuations per second above and below atmospheric pressure. Normal human hearing is between 20 Hz and 20,000 Hz. Infrasonic sound are below 20 Hz and Ultrasonic sounds are above 20,000 Hz.

A-Weighted Sound
Level, dBA
The sound pressure level in decibels as measured on a sound level meter using the A-weighting filter network. The A-weighting filter de-emphasizes the very low and very high frequency components of the sound in a manner similar to the frequency response of the human ear and correlates well with subjective reactions to noise.

Equivalent Noise Level,
Leq
The average A-weighted noise level during the measurement period.

Lmax, Lmin
The maximum and minimum A-weighted noise level during the measurement period.

L01, L10, L50, L90
The A-weighted noise levels that are exceeded 1%, 10%, 50%, and 90% of the time during the measurement period.

Day/Night Noise Level,
Ldn or DNL
The average A-weighted noise level during a 24-hour day, obtained after addition of 10 decibels to levels measured in the night between 10:00 pm and 7:00 am.

Community Noise
Equivalent Level,
CNEL
The average A-weighted noise level during a 24-hour day, obtained after addition of 5 decibels in the evening from 7:00 pm to 10:00 pm and after addition of 10 decibels to sound levels measured in the night between 10:00 pm and 7:00 am.

Ambient Noise Level The composite of noise from all sources near and far. The normal or existing level of environmental noise at a given location.

Intrusive That noise which intrudes over and above the existing ambient noise at a given location. The relative intrusiveness of a sound depends upon its amplitude, duration, frequency, and time of occurrence and tonal or informational content as well as the prevailing ambient noise level.

Source: Handbook of Acoustical Measurements and Noise Control, Harris, 1998. 5 TABLE 2 Typical Noise Levels in the Environment
Common Outdoor Activities Noise Level (dBA) Common Indoor Activities 110 dBA Rock band
Jet fly-over at 1,000 feet
100 dBA
Gas lawn mower at 3 feet
90 dBA
Diesel truck at 50 feet at 50 mph Food blender at 3 feet 80 dBA Garbage disposal at 3 feet
Noisy urban area, daytime
Gas lawn mower, 100 feet 70 dBA Vacuum cleaner at 10 feet Commercial area Normal speech at 3 feet
Heavy traffic at 300 feet 60 dBA
Large business office
Quiet urban daytime 50 dBA Dishwasher in next room
Quiet urban nighttime 40 dBA Theater, large conference room Quiet suburban nighttime
30 dBA Library
Quiet rural nighttime Bedroom at night, concert hall
(background)
20 dBA
Broadcast/recording studio
10 dBA
0 dBA
Source: Technical Noise Supplement (TeNS), California Department of Transportation, September 2013. 6 Fundamentals of Groundborne Vibration
Ground vibration consists of rapidly fluctuating motions or waves with an average motion of zero.

Several different methods are typically used to quantify vibration amplitude. One method is the Peak Particle Velocity (PPV). The PPV is defined as the maximum instantaneous positive or negative peak of the vibration wave. In this report, a PPV descriptor with units of mm/sec or in/sec is used to evaluate construction generated vibration for building damage and human complaints.

Table 3 displays the reactions of people and the effects on buildings that continuous or frequent intermittent vibration levels produce. The guidelines in Table 3 represent syntheses of vibration criteria for human response and potential damage to buildings resulting from construction vibration.

Construction activities can cause vibration that varies in intensity depending on several factors.

The use of pile driving and vibratory compaction equipment typically generates the highest construction related groundborne vibration levels. Because of the impulsive nature of such activities, the use of the PPV descriptor has been routinely used to measure and assess groundborne vibration and almost exclusively to assess the potential of vibration to cause damage and the degree of annoyance for humans.

The two primary concerns with construction-induced vibration, the potential to damage a structure and the potential to interfere with the enjoyment of life, are evaluated against different vibration limits. Human perception to vibration varies with the individual and is a function of physical setting and the type of vibration. Persons exposed to elevated ambient vibration levels, such as people in an urban environment, may tolerate a higher vibration level.

Structural damage can be classified as cosmetic only, such as paint flaking or minimal extension of cracks in building surfaces; minor, including limited surface cracking; or major, that may threaten the structural integrity of the building. Safe vibration limits that can be applied to assess the potential for damaging a structure vary by researcher. The damage criteria presented in Table 3 include several categories for ancient, fragile, and historic structures, the types of structures most at risk to damage. Most buildings are included within the categories ranging from “Historic and some old buildings” to “Modern industrial/commercial buildings.” Construction-induced vibration that can be detrimental to the building is very rare and has only been observed in instances where the structure is at a high state of disrepair and the construction activity occurs immediately adjacent to the structure.

The annoyance levels shown in Table 3 should be interpreted with care since vibration may be found to be annoying at lower levels than those shown, depending on the level of activity or the sensitivity of the individual. To sensitive individuals, vibrations approaching the threshold of perception can be annoying. Low-level vibrations frequently cause irritating secondary vibration, such as a slight rattling of windows, doors, or stacked dishes. The rattling sound can give rise to exaggerated vibration complaints, even though there is very little risk of actual structural damage. 7 TABLE 3 Reaction of People and Damage to Buildings from Continuous or Frequent Intermittent Vibration Levels
Velocity Level,
PPV (in/sec) Human Reaction Effect on Buildings

0.01 Barely perceptible No effect

0.04 Distinctly perceptible Vibration unlikely to cause damage of any type to any structure

0.08 Distinctly perceptible to
strongly perceptible
Recommended upper level of the vibration to which
ruins and ancient monuments should be subjected

0.1 Strongly perceptible Threshold at which there is a risk of damage to fragile buildings with no risk of damage to most buildings

0.25 Strongly perceptible to severe Threshold at which there is a risk of damage to historic and some old buildings.

0.3 Strongly perceptible to severe Threshold at which there is a risk of damage to older residential structures

0.5 Severe - Vibrations considered
unpleasant
Threshold at which there is a risk of damage to new
residential and modern commercial/industrial structures Source: Transportation and Construction Vibration Guidance Manual, California Department of Transportation, April 2020.

REGULATORY BACKGROUND
Regulatory Background - Noise & Vibration
This section describes the relevant guidelines, policies, and standards established by State Agencies and the City of San Bruno. The California Environmental Quality Act (CEQA) Guidelines, Appendix G, are used to assess the potential significance of impacts pursuant to local General Plan policies, Municipal Code standards, or the applicable standards of other agencies. A summary of the applicable regulatory criteria is provided below.

State CEQA Guidelines. CEQA contains guidelines to evaluate the significance of effects of environmental noise attributable to a proposed project. Under CEQA, noise impacts would be considered significant if the project would result in:
(a) 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;
(b) Generation of excessive groundborne vibration or groundborne noise levels; (c) 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, if the project would expose people residing or working in the project area to excessive noise levels.
8 2022 California Building Code, Title 24, Part 2. The current version of the California Building Code (CBC) requires interior noise levels in multi-family residential units attributable to exterior environmental noise sources to be limited to a level not exceeding 45 dBA Ldn in any habitable room.

Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport. Noise compatibility policies established in this document were designed to protect the public health, safety, and welfare by minimizing the exposure of residents and occupants of future noise-sensitive development to excessive noise and to protect the public interest in providing for the orderly development of SFO by ensuring that new development in the Airport environs complies with all requirements necessary to ensure compatibility with aircraft noise in the area. The intent is to avoid the introduction of new incompatible land uses into the Airport’s “noise impact area” so that the Airport will continue to be in compliance with the State Noise Standards for airports (California Code of Regulations, Title 21, Sections 5012 and 5014).1 The following noise compatibility policies (NP) shall apply to the ALUCP and are applicable to this project:

NP-1: Noise Compatibility Zones. For the purposes of this ALUCP, the projected 2020 CNEL noise contour map from the Draft Environmental Assessment for the Proposed Runway Safety Area Program shall define the boundaries within which noise compatibility policies described in this Section shall apply.2 Exhibit IV-5 depicts the noise compatibility zones. More detail is provided on Exhibit IV-6. The zones are defined by the CNEL 65, 70 and 75 dB contours.

NP-2: Airport Noise/Land Use Compatibility Criteria. The compatibility of proposed land uses located in the Airport noise compatibility zones shall be determined according to the noise/land use compatibility criteria shown in Table IV-1. The criteria indicate the maximum acceptable airport noise levels, described in terms of Community Noise Equivalent Level (CNEL), for the indicated land uses. The compatibility criteria indicate whether a proposed land use is “compatible,” “conditionally compatible,” or “not compatible” within each zone, designated by the identified CNEL ranges.
• “Compatible” means that the proposed land use is compatible with the CNEL level indicated in the table and may be permitted without any special requirements related to the attenuation of aircraft noise.
• “Conditionally compatible” means that the proposed land use is compatible if the conditions described in Table IV-1 are met.
• “Not compatible” means that the proposed land use is incompatible with aircraft noise at the indicated CNEL level.
1 In 2002, the San Mateo County Board of Supervisors declared that the Airport had eliminated its “noise impact area,” as defined under state law -- California Code of Regulations, Title 21, Sections 5012 and 5014. 2 URS Corporation and BridgeNet International. Draft Environmental Assessment, Proposed Runway Safety Area Program, San Francisco International Airport, June 2011. 9 10
NP-3: Grant of Avigation Easement. Any action that would either permit or result in the development or construction of a land use considered to be conditionally compatible with aircraft noise of CNEL 65 dB or greater shall be subject to this easement requirement. The determination of conditional compatibility shall be based on the criteria presented in Table IV-1 “Noise/Land Use Compatibility Criteria.”
The San Mateo County Airport Land Use Commission (the C/CAG Board) deems it necessary to:
(1) ensure the unimpeded use of airspace in the vicinity of SFO; (2) to ensure that new noisesensitive land uses within the CNEL 65 dB contour are made compatible with aircraft noise, in accordance with California Code of Regulations, Title 21, Section 5014; and (3) to provide notice to owners of real property near the Airport of the proximity to SFO and of the potential impacts that could occur on the property from airport/aircraft operations. Thus, C/CAG shall condition its approval of proposed development upon the owner of the subject property granting an avigation easement to the City and County of San Francisco, as the proprietor of SFO. The local government with the ultimate permitting and approval authority over the proposed development shall ensure that this condition is implemented prior to final approval of the proposed development. If the approval action for the proposed development includes construction of a building(s) and/or other structures, the local permitting authority shall require the grant of an avigation easement to the City and County of San Francisco prior to issuance of a building permit(s) for the proposed building or structure. If the proposed development is not built, then, upon notice by the local permitting authority, SFO shall record a notice of termination of the avigation easement.

The avigation easement to be used in fulfilling this condition is presented in Appendix G.

NP-4: Residential Uses Within CNEL 70 dB Contour. As described in Table IV-1, residential uses are not compatible in areas exposed to noise above CNEL 70 dB and typically should not be allowed in these high noise areas.

NP-4.1: Situations Where Residential Use Is Conditionally Compatible. Residential uses are considered conditionally compatible in areas exposed to noise above CNEL 70 dB only if the proposed use is on a lot of record zoned exclusively for residential use as of the effective date of the ALUCP. In such a case, the residential use must be sound-insulated to achieve an indoor noise level of CNEL 45 dB or less from exterior sources. The property owner also shall grant an avigation easement to the City and County of San Francisco in accordance with Policy NP-3 prior to issuance of a building permit for the proposed building or structure.

City of San Bruno General Plan. The City of San Bruno’s General Plan includes a Noise section within the Health and Safety Element which provides guidelines to achieve the goal of maintaining an acceptable community noise level. The following general plan policies are applicable to the project:

HS-32 Encourage developers to mitigate ambient noise levels adjacent to major noise sources by incorporating acoustical site planning into their projects. Utilize the City’s Building Code to implement mitigation measures, such as:
11 • Incorporating buffers and/or landscaped berms along high-noise roadways or railways;
• Incorporating traffic calming measures and alternative intersection design within and/or adjacent to the project;
• Using reduced-noise pavement (rubberized asphalt); and • Incorporating state-of-the-art structural sound attenuation measures.

HS-33 Prevent the placement of new noise-sensitive uses unless adequate mitigation is provided. Establish insulation requirements as mitigation measures for all development, per the standards in Table 7-1.

HS-35 Require developers to comply with relevant noise insulation standards contained in Title 24 of the California Code of Regulations (Part 2, Appendix Chapter 12A).

HS-36 Encourage developers of new residential projects to provide noise buffers other than sound walls, such as vegetation, storage areas, or parking, as well as site planning and locating bedrooms away from noise sources.

HS-37 Require that all sponsors of new housing (residential and senior housing units) record a notice of Fair Disclosure, regarding the proximity of the proposed development to San Francisco International Airport and of the potential impacts of aircraft operation, including noise impacts, per Ordinance 1646 and AB 2776.

HS-38 Require developers to mitigate noise exposure to sensitive receptors from construction activities. Mitigation may include a combination of techniques that reduce noise generated at the source, increase the noise insulation at the receptor, or increase the noise attenuation rate as noise travels from the source to the receptor.

Areas outside of 60 dB or greater airport noise contours are subject to land use compatibility noise standards shown in Table 7-2.

HS-40 Prohibit new residential development within the 70+ Airport CNEL areas, as dictated by Airport Land Use Commission infill criteria.

HS-42 Require new residential development within the 65 dBA CNEL SFO noise contour to submit an avigation easement to the airport. Specific avigation easement requirements shall be consistent with the County of San Mateo Comprehensive Airport-Land Use Compatibility Plan for SFO.
12 Source: San Bruno General Plan, 2009
1 City of San Bruno Municipal Code. San Bruno’s Noise Ordinance is contained in Title 6 of the San Bruno Municipal Code. The ordinance places limits on noise levels in residential zones, limits construction activity noise levels near residential zones, establishes machinery noise level limits, and addresses amplified sounds. The following ordinances are applicable to the project:

6.16.030 Ambient noise level limits. When the ambient noise level is less than designated in this section, the respective noise level in this section shall govern.

TABLE 4 San Bruno Municipal Code Ambient Noise Level Limits (dBA) Zone Daytime (7 a.m. to 10 p.m.) Nighttime (10 p.m. to 7 a.m.) Residential 60 45

6.16.050 Noise levels exceeding ambient base level. Any noise level exceeding the zone ambient base level at the property plane of any property, or exceeding the zone ambient base level on any adjacent residential area zone line or at any place of other property (or, if a condominium or apartment house, within any adjoining apartment) by more than ten decibels shall be deemed to be prima facie evidence of a violation of the provisions of this chapter. However, during the period of seven a.m. to ten p.m. the ambient base level may be exceeded by twenty decibels for a period not to exceed thirty minutes during any twentyfour-hour period.

6.16.060 Machinery noise levels. No person shall operate any machinery, equipment, pump, fan, air conditioning apparatus or similar mechanical device in any manner so as to create any noise which would cause the noise level at the property plane of any property to exceed the ambient base noise level by more than ten decibels. However, during the period of seven a.m. to ten p.m. the ambient noise level may be exceeded by twenty decibels for a period not to exceed thirty minutes during any twenty-four-hour period.

6.16.070 Construction of buildings and projects. No person shall, within any residential zone, or within a radius of five hundred feet therefrom, operate equipment or perform any outside construction or repair work on any building, structure, or other project, or operate any pile driver, power shovel, pneumatic hammer, derrick, power hoist, or any other construction-type device which shall exceed, between the hours of seven a.m. and ten p.m., a noise level of eighty-five decibels as measured at one hundred feet, or exceed between the hours of ten p.m. and seven a.m. a noise level of sixty decibels as measured at one hundred feet, unless such person shall have first obtained a permit therefor from the director of public works. No permit shall be required to perform emergency work.

NOISE MEASUREMENT SURVEY
A noise monitoring survey was performed from Wednesday, August 17, 2022, through Friday, August 19, 2022. The survey included four (4) long-term (LT) noise measurements and four (4) short-term (ST) noise measurements to quantify existing ambient noise levels in and around the identified housing opportunity sites. Long-term noise measurement data is provided in Appendix A. Noise measurement locations are shown in Figure 1.
2 FIGURE 1 Long-Term and Short-Term Noise Measurement Locations Source: Google Earth 2022
3 Long-Term Noise Measurements
Noise measurement LT-1 was at Housing Opportunity Site 21. LT-1 was located about 45 feet west of the Huntington Avenue centerline. Traffic along Huntington Avenue, railroad noise from the UPRR tracks, and aircraft noise from San Francisco International Airport were the primary sources of noise in the area. Hourly average noise levels ranged from 65 to 73 dBA Leq during the day and from 57 to 71 dBA Leq at night. The average noise exposure level at this location on Thursday, August 18, 2022 was 73 dBA Ldn. Figures A1 through A3 in Appendix A show the trend in noise levels throughout the measurement period from August 17, 2022 to August 19, 2022.

Noise measurement LT-2 was at Housing Opportunity Site 20. LT-2 was located about 140 feet west of the El Camino Real centerline. Traffic along El Camino Real and aircraft noise from San Francisco International Airport were the primary sources of noise in the area. Hourly average noise levels ranged from 64 to 68 dBA Leq during the day and from 58 to 68 dBA Leq at night. The average noise exposure level at this location on Thursday, August 18, 2022 was 71 dBA Ldn.

Figures A4 through A6 in Appendix A show the trend in noise levels throughout the measurement period from August 17, 2022 to August 19, 2022.

Noise measurement LT-3 was at Housing Opportunity Site 13. LT-3 was located about 65 feet north of the San Bruno Avenue centerline. Traffic along San Bruno Avenue was the primary source of noise in the area. Hourly average noise levels ranged from 64 to 72 dBA Leq during the day and from 56 to 65 dBA Leq at night. The average noise exposure level at this location on Thursday, August 18, 2022 was 69 dBA Ldn. Figures A7 through A9 in Appendix A show the trend in noise levels throughout the measurement period from August 17, 2022 to August 19, 2022.

Noise measurement LT-4 was made at a location representative of Housing Opportunity Site 14.

LT-4 was located about 165 feet north of the I-380 centerline. Traffic along I-380 was the primary source of noise in the area. Hourly average noise levels ranged from 68 to 72 dBA Leq during the day and from 62 to 71 dBA Leq at night. The average noise exposure level at this location on Thursday, August 18, 2022 was 75 dBA Ldn. Figures A10 through A12 in Appendix A show the trend in noise levels throughout the measurement period from August 17, 2022 to August 19, 2022.

Short-Term Noise Measurements
A series of four attended short-term (ST) 10 – minute duration measurements were also made to identify the noise sources that occurred during the measurement and to note the level of noise associated with these identifiable events. The attended measurements assist in quantitatively and qualitatively characterizing the noise environments along the major roadways and in the quieter areas of the city.

Short-term noise measurement ST-1 was conducted on Wednesday, August 17, 2022, between 11:40 a.m. and 11:50 a.m. to document typical noise levels expected at Housing Opportunity Site

19. This location was approximately 85 feet from the centerline of El Camino Real. El Camino Real traffic typically produced noise levels ranging from 58 to 81 dBA, and a jet flyover produced noise levels up to 82 dBA. The 10-minute Leq measured at ST-1 was 71 dBA. 4 Short-term noise measurement ST-2 was conducted on Wednesday, August 17, 2022, between 12:30 p.m. and 12:40 p.m. to document typical noise levels expected at Housing Opportunity Site

3. This location was approximately 50 feet from the centerline of San Bruno Avenue. San Bruno Avenue traffic typically produced noise levels ranging from 62 to 80 dBA. The 10-minute Leq measured at ST-2 was 70 dBA.

Short-term noise measurement ST-3 was conducted on Friday, August 19, 2022, between 9:20 a.m. and 9:30 a.m. to document typical noise levels expected at Housing Opportunity Site 9. This location was approximately 65 feet from the centerline of El Camino Real. El Camino Real traffic typically produced noise levels ranging from 57 to 76 dBA, and a jet flyover produced noise levels up to 76 dBA. The 10-minute Leq measured at ST-3 was 69 dBA.

Short-term noise measurement ST-4 was conducted on Friday, August 19, 2022, between 9:40 a.m. and 9:50 a.m. to document typical noise levels expected at Housing Opportunity Site 8. This location was approximately 55 feet from the centerline of Jenevein Avenue. Jenevein Avenue traffic typically produced noise levels ranging from 53 to 68 dBA, and two jets produced noise levels ranging from 53 to 55 dBA. The 10-minute Leq measured at ST-4 was 57 dBA. Data collected at short-term sites ST-1 through ST-4 are summarized in Table 5.

TABLE 5 Summary of Short-Term Noise Measurement Data
Noise Measurement Location
(Date, Time)
Measured Noise Level, dBA
Lmax Lmin L(1) L(10) L(50) L(90) Leq
ST-1: ~85 feet from El Camino Real centerline
(8/17/2022, 11:40 – 11:50 am) 82 58 80 74 68 60 71
ST-2: ~50 feet from San Bruno Avenue
centerline
(8/17/2022, 12:30 – 12:40 pm)
84 57 80 72 66 61 70
ST-3: ~65 feet from El Camino Real centerline
(8/19/2022, 9:20 – 9:30 am) 82 55 76 74 64 58 69
ST-4: ~55 feet from Jenevein Avenue
centerline
(8/19/2022, 9:40 – 9:50 am)
71 44 67 60 54 47 57

GENERAL PLAN CONSISTENCY ANALYSIS
The noise exposures of housing projects facilitated by the HEU are not considered under CEQA.

This section addresses Noise and Land Use Compatibility for consistency with the policies set forth in the City’s General Plan.

Noise and Land Use Compatibility
The applicable San Bruno General Plan policies were presented in detail in the Regulatory Background section. Noise and Land Use Compatibility guidelines for new development are identified in General Plan Table 7-2. Single-family residential is considered “Normally Acceptable” up to 60 dBA Ldn and multiple-family residential is considered “Normally 5 Acceptable” up to 65 dBA Ldn. In the following discussion, the noise and land use compatibility is evaluated for HEU site. Noise control measures are discussed including site planning, sound walls, and detailed analysis per the requirements of the State Building Code leading to building sound insulation treatments.

El Camino Real Corridor. Housing opportunity sites 1, 2, 4, 5, 7, 8, 9, 10, 11, 12, 14, 16, 17, 18, 19, 20, 22, and 23 are proposed along the El Camino Real corridor. The noise exposure produced by ground transportation at sites adjoining El Camino Real is 70 – 75 dBA Ldn. The noise and land use compatibility designation is “Normally Unacceptable” where “new construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise-insulation features must be included in the design.” The noise exposure at sites along the El Camino Real corridor, not immediately adjacent to the roadway, is 65 – 70 dBA Ldn. The noise and land use compatibility designation is “Conditionally Acceptable” where “new construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features have been included in the design.” San Bruno Avenue Corridor. Housing opportunity sites 1, 3, 13, 15, and 21 are proposed along the San Bruno Avenue corridor. The noise exposure produced by ground transportation at sites adjoining San Bruno Avenue is 70 – 75 dBA Ldn. The noise and land use compatibility designation is “Normally Unacceptable” where “new construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise-insulation features must be included in the design.”
I-280 Corridor. Housing opportunity sites 3 and 6 are proposed along the I-280 corridor, and the noise exposure produced by ground transportation at these sites is 70 – 75 dBA Ldn. The noise and land use compatibility designation is “Normally Unacceptable” where “new construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise-insulation features must be included in the design.”
I-380 Corridor. Housing opportunity sites 14, 18, and 19 are proposed along the I-380 corridor, and the noise exposure produced by ground transportation at these sites is 70 – 75 dBA Ldn. The noise and land use compatibility designation is “Normally Unacceptable” where “new construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noiseinsulation features must be included in the design.” General Plan policies HS-32, HS-33, HS-35, and HS-36 establish a framework that will result in new housing included in the HEU to be compatible with the noise environments where they would be located. The following measures, applied individually or in combination, are recommended to implement the policies:
1) Utilize site planning to minimize noise impacts to outdoor activity areas. Consider locating non-noise sensitive uses, such as parking (e.g., carports), adjacent to roadways, and using 6 the residential buildings to provide shielding for common outdoor use areas. Site planning is critical for sites proposed in “Normally Unacceptable” noise environments.

2) Construct noise barriers where necessary to shield outdoor activity areas from local street traffic noise. Barriers 6 - 10 feet high can provide the 5 – 10 dBA of the noise reduction necessary to make the “Conditionally Acceptable” noise environment compatible. The final location, heights, and designs of barriers will be determined during development of the site plan.
3) General Plan policy HS-35 stipulates that residential developers shall comply with relevant noise insulation standards to maintain indoor noise levels at or below 45 dBA Ldn. Where exterior noise levels would exceed 60 dBA Ldn, an analysis detailing the treatments incorporated into the building plans shall be prepared and submitted to the City Building Department prior to issuance of a building permit. The report shall demonstrate that the design would achieve an interior level of 45 dBA Ldn or less in all habitable residential areas.

NOISE IMPACTS AND MITIGATION MEASURES
This section describes the significance criteria used to evaluate project impacts under CEQA, provides a discussion of each project impact, and presents mitigation measures, where necessary, to provide a compatible project in relation to adjacent noise sources and land uses.

Significance Criteria
The following criteria were used to evaluate the significance of environmental noise and vibration resulting from the project:

1. Temporary or Permanent Noise Increases in Excess of Established Standards. A significant impact would be identified if project construction or operations would result in a substantial temporary or permanent increase in ambient noise levels at sensitive receivers in excess of the local noise standards contained in the San Bruno General Plan or Municipal Code, as follows:
o Temporary Noise Increase. A significant temporary noise impact would be identified if construction noise levels would exceed the noise limits specified in the San Bruno Municipal Code . Pursuant to Section 6.16.070, noise from construction activities within any residential zone, or within 500 feet of any residential zone, is limited to 85 dBA, as measured at 100 feet from the source between the hours of 7:00 a.m. and 10:00 p.m., unless a permit has been obtained to exceed this level.

Between the hours of 10:00 p.m. and 7:00 a.m., construction noise is limited to 60 dBA at 100 feet from the source, unless a permit is obtained. o Permanent Noise Increase. A significant impact would be identified if traffic or school activity noise generated by the project would substantially increase noise levels at sensitive receivers in the vicinity. A substantial increase would occur if:
a) the noise level increase is 5 dBA Ldn or greater, with a future noise level of less 7 than 60 dBA Ldn, or b) the noise level increase is 3 dBA Ldn or greater, with a future noise level of 60 dBA Ldn or greater.

2. Generation of Excessive Groundborne Vibration. A significant impact would be identified if the construction of the project would generate excessive vibration levels.

Groundborne vibration levels exceeding 0.25 in/sec PPV would be considered excessive as such levels would have the potential to result in cosmetic damage to historic and some old buildings. Groundborne vibration levels exceeding 0.3 in/sec PPV would have the potential to result in cosmetic damage to buildings that are found to be structurally sound but where structural damage is a major concern, and groundborne vibration levels exceeding 0.5 in/sec PPV would have the potential to result in cosmetic damage to buildings that are structurally sound and designed to modern engineering standards.

Impact 1: Permanent or Temporary Noise Increases in Excess of Established Standards.

Increased vehicle traffic due to the HEU would not result in a substantial permanent increase traffic noise levels along area roadways. Construction activities facilitated by the HEU would not result in substantial temporary noise increases that would be in excess of applicable local standards at nearby sensitive receptors. This is a lessthan-significant impact.

Permanent Noise Increases from Project Traffic
Increases in traffic noise gradually degrade the environment in areas sensitive to noise. According to CEQA, “a substantial increase” is necessary to cause a significant environmental impact. An increase of 3 dBA Ldn is considered substantial as it would represent a just-noticeable difference.

Vehicular traffic on roadways in the City would increase as development occurs and the City’s population increases. These projected increases in traffic would, over time, increase noise levels throughout the community.

The results presented in Table 6 indicate that project-generated traffic noise levels would generally increase by 0 to 1 dBA Ldn due to anticipated traffic volume increases along major roadways in San Bruno. The traffic noise increases attributable to the implementation of the HEU would not result in a substantial permanent increase noise levels in the community. This is a less-thansignificant impact. 8 TABLE 6 PM Peak Hour Traffic Volumes and Project-Generated Traffic Noise Increases Roadway Location PM Peak Hour Volumes Project Noise Increase (dBA)
Existing Existing
+ Project Background Background+ Project
Versus
Existing
Versus
Background
Sneath Lane W. of I-280 SB Ramp 896 986 1,335 1,425 0.4 0.3 Sneath Lane E. of I-280 NB Ramp 1,448 1,534 2,486 2,572 0.3 0.1 El Camino Real N. of I-380 WB Ramp 4,562 4,922 4,676 5,036 0.3 0.3 El Camino Real S. of I-380 EB Ramp 3,673 3,901 5,028 5,256 0.3 0.2 El Camino Real N. of Crystal Springs 3,180 3,349 3,978 4,147 0.2 0.2 El Camino Real S. of Crystal Springs 3,382 3,542 4,180 4,340 0.2 0.2 San Bruno Avenue W. of El Camino Real 1,607 1,899 3,068 3,360 0.7 0.4 San Bruno Avenue E. of El Camino Real 1,531 1,645 2,052 2,166 0.3 0.2 Huntington Avenue N. of San Mateo Avenue 1,226 1,232 1,229 1,235 0.0 0.0 San Mateo Avenue S. of Huntington 715 721 715 721 0.0 0.0 Crystal Springs W. of El Camino Real 802 811 802 811 0.0 0.0 Note: As of November 18, 2022, the project assumes 138 single-family detached, 835 low-rise apartment, and 1,735 mid-rise apartment units. This results in an increase of 356 daily trips distributed throughout the City. A new trip distribution analysis was not prepared, but this very minor increase in daily trips would not change the noise analysis or conclusions.
9 Temporary Noise Increases from Project Construction
Background Information on Construction Noise
Noise impacts resulting from construction depend upon the noise generated by various pieces of construction equipment, the timing and duration of noise-generating activities, and the distance between construction noise sources and noise-sensitive areas. Construction noise impacts primarily result when construction activities occur during noise-sensitive times of the day (e.g., early morning, evening, or nighttime hours), the construction occurs in areas near noise-sensitive land uses, or when construction lasts over extended periods of time.

Typically, construction activities would be carried out in stages. During each stage of construction, there would be a different mix of equipment operating, and noise levels would vary by stage and vary within stages, based on the amount of equipment in operation and the location at which the equipment is operating. Typical construction noise levels at a distance of 50 feet are shown in Tables 7 and 8. Table 7 shows the average noise level ranges, by construction phase, and Table 8 shows the maximum noise level ranges for different construction equipment. Most demolition and construction noise falls in the range of 80 to 90 dBA at 50 feet from the source. Constructiongenerated noise levels drop off/increase at a rate of about 6 dBA per doubling/halving of the distance between the source and receptor. Shielding by buildings or terrain can provide an additional 5 to 10 dBA noise reduction at distant receptors.

TABLE 7 Typical Ranges of Construction Noise Levels at 50 Feet, Leq (dBA) Domestic Housing
Office Building,
Hotel, Hospital,
School, Public
Works
Industrial Parking
Garage, Religious
Amusement &
Recreations, Store,
Service Station
Public Works
Roads & Highways,
Sewers, and
Trenches

I II I II I II I II
Ground
Clearing 83 83 84 84 84 83 84 84
Excavation 88 75 89 79 89 71 88 78
Foundations 81 81 78 78 77 77 88 88
Erection 81 65 87 75 84 72 79 78
Finishing 88 72 89 75 89 74 84 84
I – All pertinent equipment present at site.

II – Minimum required equipment present at site.

Source: U.S.E.P.A., Legal Compilation on Noise, Vol. 1, p. 2-104, 1973. 10 TABLE 8 Construction Equipment 50-foot Noise Emission Limits Equipment Category Lmax Level (dBA)1,2 Impact/Continuous Arc Welder
Auger Drill Rig
Backhoe
Ballast Equalizer3
Ballast Tamper3
Bar Bender
Chain Saw
Compressor (air)
Concrete Mixer
Concrete Pump
Concrete Saw
Concrete Vibrator
Crane
Dozer
Excavator
Front End Loader
Generator
Generator (25 KVA or less)
Gradall
Grader
Grinder Saw
Horizontal Boring Hydro Jack
Hydra Break Ram
Impact Pile Driver
Jackhammer
Mounted Impact Hammer (hoe ram)
Paver
Pneumatic Tools
Pumps
Rail Saw3
Rock Drill
Scraper
Slurry Trenching Machine
Soil Mix Drill Rig
Street Sweeper
Tie Cutter3
Tie Handler3
Tie Inserter3
Tractor
Truck
Vibratory Compactor
Vibratory Pile Driver
All other equipment with engines larger than 5 HP
73 85
80 82
83 80
85 80
85 82
90 80
85 85
85 80
82 70
85 85
85 80
90 105
85 90
85 85
77 90
85 85
82 80
80 84
80 85
84 84
80 95
85 Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Impact
Impact
Impact
Impact
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Notes: 1 Measured at 50 feet from the construction equipment, with a “slow” (1 sec.) time constant. 2Noise limits apply to total noise emitted from equipment and associated components operating at full power while engaged in its intended operation.3 Transit Noise and Vibration Impact Assessment Manual, Federal Transit Administration, Office of Planning and Environment, U.S. Department of Transportation, FTA Report No. 0123, September 2018., 4 Mitigation of Nighttime Construction Noise, Vibrations and Other Nuisances, National Cooperative Highway Research Program, 1999. 11 Construction Noise Criteria
A significant temporary noise impact would be identified if construction noise levels would exceed the noise limits specified in the Municipal Code. Pursuant to San Bruno Municipal Code Section

6.16.070, noise from construction activities within any residential zone, or within 500 feet of any residential zone, is limited to 85 dBA, as measured at 100 feet from the source between the hours of 7:00 a.m. and 10:00 p.m., unless a permit has been obtained to exceed this level. Between the hours of 10:00 p.m. and 7:00 a.m., construction noise is limited to 60 dBA at 100 feet from the source, unless a permit is obtained.

Construction Noise Impact Assessment
Federal Highway Administration’s (FHWA’s) Roadway Construction Noise Model (RCNM) was used to calculate the hourly average noise levels for each phase of construction, assuming the two loudest pieces of equipment would operate simultaneously, as recommend by the FTA for construction noise evaluations. This construction noise model includes representative sound levels for the most common types of construction equipment and the approximate usage factors of such equipment that were developed based on an extensive database of information gathered during the construction of the Central Artery/Tunnel Project in Boston, Massachusetts (CA/T Project or "Big Dig"). The usage factors represent the percentage of time that the equipment would be operating at full power.

For the purposes of analyzing a credible worst-case scenario, the construction equipment and phasing information of an example 90-unit multi-family project was used to calculate construction noise levels on an hourly basis (Hourly Leq). The construction noise levels would represent the majority of residential construction projects anticipated under the HEU, although the duration of the project would vary depending on the size of the project. Equipment expected to be used in each construction phase are summarized in Table 9, along with the quantity of each type of equipment, the reference noise level at 50 feet assuming the operation of the two loudest pieces of construction equipment, and the estimated noise levels at the nearest property lines projected from the center of the construction activity by phase. Construction noise levels were also calculated at distances of 100, 200, 400, and 500 feet. As shown in Table 9, credible worst-case construction noise levels are expected range from 71 to 80 dBA Leq at 100 feet from the noise source. These levels are below the City’s daytime construction noise standard of 85 dBA at a distance of 100 feet. 12 TABLE 9 Construction Noise Levels
Phase Construction
Equipment (Quantity)
Calculated Hourly Average Leq and Ldn (dBA) From Operation of Two Loudest Pieces of Construction Equipment
Noise Level
at 50 feet
Noise Level
at 100 feet
Noise Level
at 200 feet
Noise Level
at 400 feet
Noise Level
at 500 feet
Demolition
Concrete/Industrial Saw (1)*
Excavator (2)
Rubber-Tired Dozer (1)
Tractor/Loader/Backhoe (2)*
85 79 73 67 65
Site Preparation
Grader (2)*
Rubber-Tired Dozer (2)
Tractor/Loader/Backhoe (2)
84 78 72 66 64
Grading/
Excavation
Excavator (4)
Grader (2)
Rubber Tired Dozer (1)
Concrete/Industrial Saw (2)*
Tractor/Loader/Backhoe (2)
86 80 74 68 66
Trenching/
Foundation
Excavator (2)*
Tractor/Loader/Backhoe (2)* 82 76 70 64 62
Building
Exterior
Crane (3)
Forklift (2)
Generator Set (1)*
Tractor/Loader/Backhoe (2)*
Welders (2)
82 76 70 64 62
Building
Interior/
Architectural
Coating
Aerial Lift (2)
Air Compressor (10)* 77 71 65 59 57
Paving
Cement and Mortar Mixer (4)
Paver (4)
Paving Equipment (4)
Roller (4)
Tractor/Loader/Backhoe (4)*
83 77 71 65 63
*Denotes two loudest pieces of construction equipment per phase 13 Although, the impact resulting from project construction would be less-than-significant, a series of construction noise control best practices are included in order to reduce construction noise levels as low as possible:
• Require noise reduction measures during all phases of construction activity to minimize the exposure of neighboring properties to excessive noise levels. Construction activities shall be required to comply with the City’s Municipal Code noise level limitations during hours of operation;
• Construction equipment shall be well-maintained and used judiciously to be as quiet as practical;
• Equip all internal combustion engine-driven equipment with mufflers, which are in good condition and appropriate for the equipment;
• Utilize “quiet” models of air compressors and other stationary noise sources where technology exists;
• Locate all stationary noise-generating equipment, such as air compressors and portable power generators, away from noise-sensitive receptors;
• Locate staging areas and construction material areas away from noise-sensitive receptors; • Prohibit all unnecessary idling of internal combustion engines; • Consider temporary noise barriers during construction phases involving earth moving equipment (e.g., grading operations) where they would be effective in reducing the construction noise impact, when directly adjoining sensitive receptors. An eight-foot plywood noise barrier could reduce noise levels by at least 5 dBA. • Designate a "disturbance coordinator" who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator will determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and will require that reasonable measures warranted to correct the problem be implemented. Conspicuously post a telephone number for the disturbance coordinator at the construction site and include it in the notice sent to neighbors regarding the construction schedule.

Implementation of the best management practices above would limit construction hours and reduce construction noise levels at noise sensitive locations to the extent feasible. Since construction noise is expected to be below the applicable City limits during daytime hours, and construction activities would not be expected at night, daytime construction noise from the HEU would not result in a substantial temporary increase in noise levels that would be in excess of applicable local standards, resulting in a less-than-significant impact.

Mitigation Measures: No additional measures are required. 14 Impact 2: Exposure to Excessive Groundborne Vibration during Construction.

Construction activities occurring as part of the project could expose sensitive land uses to excessive groundborne vibration. This is a significant impact.

The California Department of Transportation recommends a vibration limit of 0.5 in/sec PPV to avoid damage to buildings that are structurally sound and designed to modern engineering standards, a vibration limit of 0.3 in/sec PPV for buildings that are found to be structurally sound but where structural damage is a major concern, and a vibration limit of 0.25 in/sec PPV for historic and some old buildings.

Construction equipment such as pile drivers are known to generate substantial vibration levels that if used in the vicinity of sensitive land uses may expose persons to excessive vibration levels as well as have the potential to damage buildings. Other construction equipment such as bulldozers and vibratory rollers do not create the vibration levels of pile drivers; however, these types of equipment are more likely to operate continuously and closer to sensitive receptors, and they may expose persons to excessive vibration levels. Foundation construction techniques involving impact or vibratory pile driving equipment, which can cause excessive vibration, are not expected with the proposed HEU.

Vibration levels would vary depending on soil conditions, construction methods, and equipment used. Table 10 presents typical vibration levels that could be expected from construction equipment at a distances of 25 feet to 100 feet. Vibration levels would be higher at distances less than 25 feet and lower at distances greater than 100 feet. Vibration levels would also vary depending on soil conditions, construction methods, and equipment used. Vibration levels are highest close to the source, and then attenuate with increasing distance at the rate (Dref/D)1.1, where D is the distance from the source in feet and Dref is the reference distance of 25 feet.

TABLE 10 Vibration Source Levels for Construction Equipment Equipment PPV at 25 ft.
(in/sec)
PPV at 50 ft.
(in/sec)
PPV at 100 ft.
(in/sec)
Clam shovel drop 0.202 0.094 0.044
Hydromill
(slurry wall)
in soil 0.008 0.004 0.002
in rock 0.017 0.008 0.004
Vibratory Roller 0.210 0.098 0.046
Hoe Ram 0.089 0.042 0.019
Large bulldozer 0.089 0.042 0.019
Caisson drilling 0.089 0.042 0.019
Loaded trucks 0.076 0.035 0.017
Jackhammer 0.035 0.016 0.008
Small bulldozer 0.003 0.001 0.001
Source: Transit Noise and Vibration Impact Assessment Manual, Federal Transit Administration, Office of Planning and Environment, U.S. Department of Transportation, September 2018, as modified by Illingworth & Rodkin, Inc., August 2022.
15 Table 11 summarizes the minimum safe setback distances to maintain in order to achieve the 0.25 in/sec PPV threshold for historical buildings and the 0.3 in/sec and 0.5 in/sec PPV thresholds for modern buildings.

TABLE 11 Vibration Source Levels for Construction Equipment and Minimum Safe Setbacks
Equipment
Minimum Safe
Setback (feet)

0.25 in/sec PPV
Minimum Safe
Setback (feet)

0.30 in/sec PPV
Minimum Safe
Setback (feet)

0.50 in/sec PPV
Clam shovel drop 21 18 11
Hydromill
(slurry wall)
in soil <1 <1 <1
in rock 3 2 2
Vibratory Roller 22 19 12
Hoe Ram 10 9 6
Large bulldozer 10 9 6
Caisson drilling 10 9 6
Loaded trucks 9 8 5
Jackhammer 5 4 3
Small bulldozer <1 <1 <1
Source: Transit Noise and Vibration Impact Assessment Manual, Federal Transit Administration, Office of Planning and Environment, U.S. Department of Transportation, September 2018, as modified by Illingworth & Rodkin, Inc., August 2022.

Figure 3 shows the location of the HEU sites and the mapped historic resources identified in the City’s General Plan EIR.
16 FIGURE 3 HEU Sites and Mapped Historic Resources
17 A review of Figure 3 shows that HEU Sites 15 and 21 would occupy the same site or replace an existing historic resource (Yeo Lai Sah Buddhist Temple) at the northwest corner of the Huntington Avenue/San Bruno Avenue West intersection. All other HEU sites would be 40 feet or further from existing historic resources, but would be bordered by modern buildings. Since specific future projects within the City are unknown at this time, it is conservatively assumed that the construction areas associated with these future projects could be located within the minimum safe setback distances identified in Table 11. For projects that produce vibration levels exceeding the thresholds, construction vibration would be expected to cause both human annoyance and the possibility of cosmetic damage, resulting in a significant impact.

Mitigation Measure 2:

Groundborne vibration studies shall be prepared by qualified professionals in accordance with industry-accepted methodology where heavy construction activities involving significant site grading, underground, or foundation work will occur within 25 feet of residential or other vibration sensitive uses. The industry-accepted methodologies include the recommended vibration assessment procedure and thresholds provided by public agencies such as Caltrans or the Federal Highway Administration. The studies should identify necessary construction vibration controls to reduce both human annoyance and the possibility of cosmetic damage. Controls shall include, but not be limited to, the following measures:
• A list of all heavy construction equipment to be used for this project known to produce high vibration levels (tracked vehicles, vibratory compaction, jackhammers, hoe rams, etc.) shall be submitted to the City by the contractor. This list shall be used to identify equipment and activities that would potentially generate substantial vibration and to define the level of effort for reducing vibration levels below the thresholds. • Place operating equipment on the construction site as far as possible from vibrationsensitive receptors. • Use smaller equipment to minimize vibration levels below the limits. • Avoid using vibratory rollers and tampers near sensitive areas. • Select demolition methods not involving impact tools. • Modify/design or identify alternative construction methods to reduce vibration levels below the limits.
• Avoid dropping heavy objects or materials.

With the implementation of mitigation, short-term construction activities would not expose persons to excessive vibration levels, resulting in a less-than-significant impact. 18 Impact 3: Excessive Aircraft Noise. Proposed housing opportunity sites would be subject to noise levels produced by San Francisco International Airport operations exceeding 65 dBA CNEL. This is a significant impact.

Figure 4 shows the proposed housing opportunity sites with respect to the noise exposure contours of San Francisco International Airport. Sites 14 and 19 would be located within the 70 dB CNEL noise contour, while Sites 7, 15, 18, 20, and 21 would be located between the 65 dB and 70 dB CNEL noise contours. Aircraft noise exposures at Sites 7, 14, 15, 18, 19, 20 and 21 would result in a significant noise impact due to aircraft noise exposures.

Sites 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 13, 16, 17, 22, and 23 would be located outside the 65 dB CNEL noise contour, which is considered compatible for residences. This is a less-than-significant noise impact.

Mitigation Measure 3:

Implement General Plan Policies HS-33, HS-35, HS-37, HS-40, and HS-42, and Airport Land Use Compatibility Plan Policies NP-1, NP-2, NP-3, and NP-4.

The required safe and compatible threshold for exterior noise levels due to aircraft would be at or below 65 dBA CNEL. Consistent with General Plan Policy HS-42 and Airport Land Use Compatibility Plan Policy NP-3, new residential development within the 65 dBA CNEL noise contour would be required to submit an avigation easement to the airport, and shall be consistent with the County of San Mateo Comprehensive Airport-Land Use Compatibility Plan for SFO.

General Plan Policy HS-40 and Airport Land Use Compatibility Plan Policy NP-4 would prohibit new residential development within the 70 dB CNEL noise contour, as dictated by Airport Land Use Commission infill criteria. However, Airport Land Use Compatibility Plan Policy NP-4.1 would allow residential uses in areas exposed to noise above CNEL 70 dB only if the proposed use is on a lot of record zoned exclusively for residential use as of the effective date of the ALUCP and if the residential use is sound-insulated to achieve an indoor noise level of CNEL 45 dB or less from exterior sources. Site 14 is not zoned exclusively for residential use, but noise insulation methods are available to reduce aircraft noise levels at sites within the 70 dB to 75 dB CNEL noise contours to achieve an indoor noise level of 45 dB CNEL or less. General Plan Policy HS-35 would require developers to comply with relevant noise insulation standards to achieve an indoor noise level of 45 dB CNEL or less. The implementation of General Plan and Airport Land Use Compatibility Plan policies and adequate noise insulation would reduce the impact to a less-thansignificant level. 19 FIGURE 4 Housing Opportunity Sites and San Francisco International Airport Noise Exposure Contours (dB, CNEL) Noise Contour Source: Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport, Exhibit IV-6, Noise Compatibility Zones – Detail, Rincondo Associates, November 2012. 70 70
65 65
75 75
20 Appendix A – Long-Term Noise Data
21 22
23 24
25 26
27 28
29 30
31 32
2023-2031 Housing Element Update Responses to Comments Memorandum City of San Bruno January 2023
Appendix C: Revised Figure 4.13-2
City of San Bruno
2023-2031 Housing Element Update 205 Initial Study
December 2022
Noise Contour Source: Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport, Rincondo Associates, November 2012.

Key to Boundaries
Key to Sites
Transit-Oriented Development Overlay
Bayhill Specific Plan Boundary
Large Site With One House (R-2)
Melody Toyota Lot
Melody Toyota Showroom
Office Building
Tanforan
Vacant Site
Vacant Site
Walgreens
Russo Dental
San Bruno Pet Hospital
Chili’s Restaurant
Vacant Site
Bedroom Express
San Bruno Gas
Prepared July 20, 2022
IHOP Restaurant
Former Edgemont ES
Former Budget Motel
Engvall MS
Citibank
Car Sales Lot
Bayhill Shopping Center
Bank of America
ATT Building
City Limits
0 0.25 0.5 1
Miles
N
65 65
70 75
75 70
65 HOUSING OPPORTUNITY SITES AND SFO 2020 NOISE EXPOSURE CONTOURS (DB, CNEL) FIGURE 4.13-2 RESOLUTION NO. 2023- ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN BRUNO MAKING

FINDINGS AND OVERRIDING SAN MATEO CITY / COUNTY ASSOCIATION OF GOVERNMENTS (C/CAG) AIRPORT LAND USE COMMISSION’S (ALUC)

DETERMINATION OF INCONSISTENCY WITH RESPECT TO NOISE POLICIES FOR THE DRAFT 2023-2031 HOUSING ELEMENT UPDATE
WHEREAS, Government Code Section 65580 et seq. (Housing Element Law) requires that every city prepare and periodically update the housing element of its general plan; every city is mandated to include statutory requirements in the housing element; and every city is required to submit a draft of its housing element to the California Department of Housing and Community Development (“HCD”) for review and comment as to whether the City’s draft 2023- 2031 Housing Element substantially complies with Housing Element Law; and WHEREAS, the City worked with its consultants, the community, Planning Commission and City Council to prepare its Draft 2023-2031 Housing Element Update (“Project”) as required by Housing Element Law; and
WHEREAS, the 6th Cycle Regional Housing Needs Allocation (“RHNA”) imposed on the City by the Association of Bay Area Governments (“ABAG”) included 3,165 housing units, which is a substantial increase in the number of affordable housing opportunities required in comparison to the 5th Cycle RHNA allocation of 1,155 units. As a result, the City was required to identify all available sites Citywide as potential housing opportunities, including some in proximity to the San Francisco International Airport; and WHEREAS, the Housing Element Suitable Sites Inventory includes Site 14, the Tanforan Shops (“Tanforan”) and Site 19, the San Bruno Pet Hospital (“Pet Hospital”) (collectively, the “Properties”) as potential future housing sites, along with other sites. The Tanforan Site is identified to accommodate at least 1,000 housing units. Additionally, up to 60 housing units are identified at the Pet Hospital site; and WHEREAS, the Tanforan site and the Pet Hospital site are located within Airport Influence Area B of the San Francisco International Airport (“SFO”), the area subject to formal C/CAG Airport Land Use Commission (“ALUC”) review, and within the 70 -75 decibel (dB) Community Noise Equivalent (CNEL) contour where housing is not a compatible use, with limited exceptions. The exception applies to existing lots of record zoned for residential use as of the effective date of the SFO ALUCP (November 8, 2012). In such cases, new residences must be sound-insulated to achieve an indoor noise level of CNEL 45 dB or less from exterior sources, and the property owner must grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building; and WHEREAS, two housing suitable sites, Sites 15 and 21, are in SFO ALUCP Safety Zone 3 (Inner Turning Zone) and the Tanforan Site is in Safety Zone 4 (Outer Approach / Departure Zone). Per SFO ALUCP Table IV- 2, Safety Compatibility Criteria, housing is a compatible use in Safety Zone 3 and Safety Zone 4. Therefore, the Draft Housing Element is consistent with the SFO ALUCP safety policies; and
WHEREAS, the SFO ALUCP airspace policies establish maximum heights for the compatibility of new structures. The policies also stipulate the need for compliance with federal regulations requiring notification of the Federal Aviation Administration of certain proposed construction or alterations of structures. Because the Draft Housing Element is a policy document and not a specific development proposal, the airspace compatibility policies of the SFO ALUCP do not directly apply. Consistency with the airspace compatibility policies would be required for future development proposals stemming from the Housing Element; and WHEREAS, the City proposed an amendment to its General Plan to recognize the Local Agency Override Process that is provided by State law, and referred this Amendment to the C/CAG Board, acting as the San Mateo County Airport Land Use Commission, for a determination of consistency with the SFO ALUCP; and
WHEREAS, the General Plan Amendment specifically addresses the “Local Agency Override” provision of State law [Public Utilities Code Section 21675.1(d)] which provides a process for jurisdictions to override an airport land use commission disapproval of a proposed land use policy or development action, and is consistent with the provisions of the SFO ALUCP Section 3.3.3, which directly acknowledges and describes the override process; and WHEREAS, in accordance with Public Utilities Code Section 21676(b), the City referred the Project to the ALUC to review consistency with the Comprehensive Land Use Compatibility Plan for the Environs of San Francisco International Airport (“SFO ALUCP”); and WHEREAS, on November 10, 2022, the ALUC, acting pursuant to Public Utilities Code Section 21670, determined that the Project is inconsistent with the noise compatibility policies of the SFO ALUCP. The associated General Plan Amendment was also reviewed, and determined to be consistent with the policies of the SFO ALUCP; and WHEREAS, as a final review authority under Public Utilities Code Sections 21670 and 21676, the City Council may, after a public hearing, override the ALUC determination by a twothirds vote, if the City makes specific findings that the proposed project is consistent with the purposes of the Public Utilities Code Section 21670 regarding the protection of public health, safety and welfare in the areas surrounding airports and by providing the ALUC and the Division of Aeronautics of the California Department of Transportation (“Division”) with notice of the City’s intent to consider overriding the ALUC determination along with supportive findings at least 45 days prior to the City’s action to override the ALUC; and WHEREAS, on November 15, 2022, the City Council adopted a resolution making draft findings and declaring an intent to override the C/CAG ALUC determination of inconsistency with respect to the noise policies for the Draft 2023-2031 Housing Element Update; and WHEREAS, the Public Utilities Code provides that the City must provide notice of intent and draft findings to the ALUC and Division at least forty-five (45) days prior to the decision to override the Commission;
WHEREAS, on November 15, 2022, the City Council authorized the City Manager to submit the resolution to the ALUC and the Division; and WHEREAS, on November 16, 2022, City staff provided a notice and associated draft findings to the ALUC and Division declaring the City’s intent to consider overriding the C/CAG ALUC determination;
WHEREAS, the City considered the override and made its final decision on January 24, 2023, which is more than forty-five (45) days after November 16, 2022, the date upon which the City transmitted its notice of intent to the ALUC and the Division; WHEREAS, the Public Utilities Code provides that the ALUC and the Division shall respond to the notifications of the findings of the proposed override within 30 days of receiving the proposed resolution and findings; and
WHEREAS, in the event that the ALUC or Division’s comments are not available within this timeframe, the City may act without them; and
WHEREAS, the comments by the ALUC and Division are advisory to the City under State law; and
WHEREAS, the City Council has received comments from the ALUC and the Division and those comments are attached to this resolution as part of the City’s final decision to override the ALUC.

NOW, THEREFORE, BE IT RESOLVED, the City Council of the City of San Bruno hereby takes the following actions:

1. Makes the findings attached hereto as Exhibit A and incorporated herein; and

2. Overrides the Airport Land Use Commission’s determination that the Draft 2023-2031 Housing Element Update is inconsistent with the Comprehensive Land Use Compatibility Plan for the Environs of San Francisco International Airport with respect to noise policies. In doing so, the City Council hereby specifically finds that approval of the Project is consistent with the purposes of the Public Utilities Code as stated in Section 21670 of the Public Utilities Code; and

3. Directs staff to take all other actions necessary to effectuate the purpose and intent of this resolution; and

4. The City Council finds that the adoption of this resolution is not subject to the California Environmental Quality Act (“CEQA”) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines, California Code of Regulations, Title 14, Division 6, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly. Specifically, the resolution does not have the potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment because it is limited to the City’s proposal to override the ALUC’s determination. The project is undergoing independent review and evaluation pursuant to CEQA.

Dated: January 24, 2023
-o0oI, Lupita Huerta, City Clerk, do hereby certify that the foregoing Resolution was duly and regularly passed and
adopted by the City Council of the City of San Bruno this 24th day of January 2023 by the following vote:

AYES: Councilmembers:

NOES: Councilmembers:

ABSENT: Councilmembers:

ATTEST:

Lupita Huerta, City Clerk

Exhibit A: Findings

1. The foregoing recitals are true and correct and made a part of this Resolution.

2. The Public Utilities Code Section 21676 and 21676.5 provides that a local governing body may override the Airport Land Use Commission if it makes specific findings that the proposed action is consistent with the purposes of Public Utilities Code Section 21670. The City Council therefore makes the following findings.

2. The first purpose of Section 21670 is to provide for the orderly development of each public use airport in this State, and the area surrounding these airports so as to promote the overall goals and objectives of California airport noise standards and to prevent the creation of new noise and safety problems. The second purpose of Section 21670 is to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses.

3. With respect to noise policies, SFO ALUCP Policy NP-1 Noise Compatibility Zones identifies the noise compatibility zones for the purposes of the ALUCP. As depicted in the City of San Bruno’s Draft 2023-2031 Housing Element, two housing sites (Site 14, the Shops at Tanforan (the “Tanforan” site); and Site 19, the San Bruno Pet Hospital (the “Pet Hospital” site) (collectively, the “Properties”) lie within the Community Noise Equivalent Level (“CNEL”) 70-75 decibel (“dB”) noise exposure contour range where housing development would be incompatible per SFO ALUCP Table IV, Noise/Land Use Compatibility Criteria.

4. Pursuant to SFO ALUCP, Table IV-1, residential land uses are conditionally compatible in the CNEL 65-70 dB noise exposure contour range and are acceptable if sound insulation is provided to reduce interior noise levels from exterior sources to CNEL 45 dB or lower and if an avigation easement is granted to the City and County of San Francisco as operator of SFO.

5. Any project at the Tanforan site or Pet Hospital site shall incorporate noise control measures and construction standards that will lessen noise impacts to residents as follows:
a. Prior to issuance of building permits, detailed acoustical analyses shall be completed as part of the final design for the proposed residential structures. The project shall incorporate construction methods, sound attenuation features, and sound reducing barriers that reduce noise impacts in accordance with Section 21670, State Building Code, and General Plan requirements to meet the interior noise levels of 45 dB CNEL. Sound control treatments shall include mechanical ventilation and central cooling and heating for all units so that windows can be kept closed at the resident’s discretion to control noise, and special building construction techniques (such as sound-rated windows and building façade treatments) for all units. b. The project shall include real estate disclosures in residential leases, disclosing the presence of an airport within two miles of the property, per Section 11010 of the Business and Professions Code.
c. The property owners shall grant an avigation easement to the City and County of San Francisco prior to issuance of a building permit for the proposed building or structure. The avigation easement must state that the City overrode the ALUC’s inconsistency finding, describe the immunity granted to the San Francisco International Airport (“Airport”) under Public Utilities Code section 21678, and make clear that the avigation easement is in addition to, and does not limit, the Airport’s immunity.
d. The project shall include an indemnification agreement with the City of San Bruno prior to issuance of building permits, ensuring that liability related to noise is assumed by the project.

6. Approval of the proposed Project as described above is consistent with the noise standards of the SFO ALUCP as it would provide for orderly development adjacent to the airport and promote the overall goals and objectives of the California airport noise standards and prevent the creation of new noise and safety problems because the proposed Project provides much needed housing near transit on underutilized sites, while also utilizing advanced construction techniques to minimize any noise impacts to residents, and helping the City satisfy its large RHNA allocation and respond to the housing crisis facing the region and the State.

Exhibit B

AGENCY COMMENTS

ON THE INTENT TO OVERRIDE
“Provide a safe and reliable transportation network that serves all people and respects the environment”

DIVISION OF AERONAUTICS
P.O. BOX 942874, MS–40 | SACRAMENTO, CA 94274
(916) 654-4959 | FAX (916) 653-9531 TTY 711
www.dot.ca.gov
December 14, 2022

Ms. Darcy Smith Electronically Sent
City of San Bruno [email protected]
567 El Camino Real,
San Bruno, CA 94066

Dear Ms. Smith,
Thank you for notifying the California Department of Transportation, Division of Aeronautics (Division), of the proposed overrule by the City of San Bruno (City). The Division has reviewed the proposed findings provided by the City and has determined the findings are insufficient to warrant this proposed overrule.

Specifically, the findings are not consistent with the purposes of the statutes set forth in the California Public Utilities Code (PUC) section 21670. These findings do not provide substantial evidence that the proposed Project will meet the requirements of PUC statutes set forth in PUC section 21670. These findings do not provide substantial evidence that the proposed Project will meet the requirements of PUC, section 21670(a) (1) and (2).

On November 16, 2022, the Division received an email notification that included City Resolution 2022-112 and draft findings, declaring an intent to consider overruling the Airport Land Use Commission’s (ALUC) inconsistency determination of the City’s Draft 2023-2031 Housing Element Update (Project). The Project identifies 23 housing opportunity sites for areas of development or redevelopment for mixed use or residential projects. Two of the proposed sites, the Shops at Tanforan (Site 14) and the Pet Hospital (Site 19) are located within the 70-75dB CNEL noise contour as depicted in the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP). The ALUC determined that these sites were inconsistent with the noise compatibility criteria outlined in the ALUCP as, with limited exceptions, residential land uses are not allowed in the 70-75db CNEL noise contour.

On January 25, 2022, the Division sent a letter to the City of San Bruno regarding the potential redevelopment plans for Site 14 as displayed in the City’s “Reimagining Tanforan Land Use Fact Sheet” adopted July 27, 2021. To summarize, the letter (included as an attachment) expressed Division’s concern for the City’s proposed plans to build a high-density residential development at Site 14. The letter cited safety, noise, and air space protection concerns including:
 Site 14 is approximately 1.2 miles from the departure of runways 28L and 28R at San Francisco International Airport (SFO). These runways are the primary departure paths for SFO
Ms. Darcy Smith
December 14, 2022

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment”  Site 14 is in the 70-75dB CNEL noise contour, where ALUCP noise compatibility policies prohibit residential land uses
 “Pursuant to the California Code of Regulations (CCR: Title 21 CCR, §5006), 65 CNEL is “the level of noise acceptable to a reasonable person residing in the vicinity of an airport.” While construction practices can reduce interior noise levels to 45 CNEL, residents would not be expected to remain indoors continuously. When outside or when opening windows or doors, they would remain subjected to 70 CNEL from regular aircraft overflights”  Site 14 is in Safety Zone 4, where ALUCP safety compatibility policies stipulate limiting residential uses to low density
 Site 14 is located beneath a portion of airspace that has One Engine Inoperative procedures
The City’s findings cite that due the City having potential housing opportunity sites located near transit, including Site 14 and Site 19, the City was prescribed a high Regional Housing Needs Assessment (RHNA) obligation; the recommendation being that the City needs to plan for an additional 3,165 residential units to be built through 2031. As previously stated in the Division’s letter sent on January 25th, 2022, the Division recognizes that the City is facing affordable housing supply shortages and is looking for new areas to accommodate residential developments. However, environmental justice and equity concerns should also be reviewed for consistency with goals identified in the California Transportation Plan of 2050 and the California Aviation System Plan of 2020. The Division notes that new laws regarding the provision of housing do not supersede existing laws, including Section 21670 of the California Public Utilities Code, which require counties to establish ALUCs and compatibility plans to protect public health, safety, and welfare.

Please note: The Division comments are to be included in the public record of any decision to overrule the ALUC. If you have questions or we may be of further assistance, please contact me at email at [email protected] or call (916) 879-7213
Sincerely,
Originally signed by
Gabrielle Sefranek
Associate Transportation Planner
Division of Aeronautics
c: Suzy Kalkin, Transportation Program Specialist, San Mateo County Association of Governments, [email protected]
Joseph Carroll, Attorney, CA Department of Transportation, Legal Division, [email protected]
Ms. Darcy Smith
December 14, 2022

Page 3 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment” Nupur Sinha, Acting Director, Planning & Environmental at San Francisco International Airport (SFO), [email protected]
Matt Friedman, Chief, Office of Aviation Planning, Division of Aeronautics [email protected]
bc: Jean Finney, Deputy District Director Planning, District 4; [email protected] Attachments: SanMateoCnty_TanforanSFORedevelop_Ltr_012522.pdf

December 16, 2022

Page 2 of 4 ends

1. Require construction and design features to reduce interior noise to 45 dB;

3. Require the developer to grant an avigation easement to the City and County of San Francisco, in accordance with ALUCP Policy NP-3, prior to issuance of building permits; and

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 Darcy Smith, City of San Bruno
December 16, 2022

Page 3 of 4 ends

As the largest employment center in San Mateo County, SFO recognizes the importance of increasing housing supply and affordability in the San Francisco Bay Area and throughout California. While the Airport believes that ABAG should have included airport noise criteria in its RHNA methodology, it also acknowledges that the City’s RHNA allocation requires it to plan for an additional 3,165 housing units. The Airport continues to urge the City to consider alternative locations to meet RHNA requirements outside the 70-75 dB CNEL noise contour, including the 2101 Sneath Lane Residential Project, the Bayhill Specific Plan area, 1010 Admiral Court, and the transit-oriented development corridor along El Camino Real and San Mateo Avenue.
* * *
The Airport appreciates your consideration of these comments. If I can be of assistance, please do not hesitate to contact me at (650) 821-6678 or at [email protected].

Page 4 of 4 ends

Page 2 of 4 ends

Page 3 of 4 ends

Page 4 of 4 ends

777 S. Aviation Blvd.

El Segundo, CA 90245

May 18, 2022
Mr. Jovan D. Grogan
City Manager
City of San Bruno
567 El Camino Real
San Bruno, CA 94066-4247
RE: Concerns regarding the Reimagining Tanforan Redevelopment Project Dear Mr. Grogan:

The City of San Bruno is directly responsible for ensuring proper planning in partnership with state, local, and private entities, and notifying purchasers of real estate and prospective residents of their exposure to direct overflight and extreme and persistent airport noise. In the past, the City of San Bruno directly received federal funding for residential sound insulation to mitigate land use compatibility issues. On May 14, 2008, the FAA reminded the City of San Bruno, via enclosure 1, of the importance of taking appropriate action to adopt zoning and further restrict the introduction of additional non-compatible land uses adjacent to or in the vicinity of SFO. The DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 enclosure to that letter provides Appendix A, Table 1- Land Use Compatibility Guidelines from 14 Code of Federal Regulations Part 150 – Airport Noise Compatibility Planning (Part 150). As shown in enclosure 2, the 2019 Noise Exposure Map from the SFO Noise Compatibility Program1, a majority of the Tanforan Mall area is within the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour and is heavily affected by SFO departures from Runways 28L and 28R. The FAA continues to provide Airport Improvement Program (AIP) funding for qualified impacted City of San Bruno residences through the SFO Residential Sound Insulation Program. In accordance with FAA Final Policy on Part 150 Approval of Noise Mitigation Measures: Effect on the Use of Federal Grants for Noise Mitigation Projects (63 FR 16409), structures and new non-compatible development built after October 1, 1998, are not eligible for approval of remedial noise mitigation measures under Part 150 or AIP funding. In other words, residences in the Tanforan Project would not receive any AIP funding for residential sound insulation.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 As shown in enclosures 4 and 5, Tanforan Mall is located within the footprint for the Approach/Departure Obstruction Clearance Surface (OCS)
2 for existing Runway 10R/28L and
Runway 10L/28R. Maintaining clearance and protection of the OCS is among critical safety factors for protecting the Nation’s airspace and aviation operations to and from SFO. Proposed structures’ heights must be below the OCS.

Compliance with FAA guidelines and federal law does not exempt a project sponsor from complying with local regulations.

Therefore, we strongly encourage the City of San Bruno and San Mateo County officials to consider the FAA’s concerns and look to develop and maintain compatible land uses around SFO.

If you have any questions, please contact my office at (424) 405-7000.

Sincerely,
Tamara A. Swann
Regional Administrator (A)
Enclosures
cc:

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 U.S Department
of Transportation
Federal Aviation
Administration
Western-Pacific Region
Airports Division
San Francisco ADO
831 Mitten Road, Suite 210
Burlingame, CA 94010
May 14, 2008
Aaron Aknin
Community Development Director
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
Dear Mr. Aknin:

The most recent AIP grant is 3-06-0021-29.

Development of local land use plans that are compatible with airport operations is key to ensuring consistency with the City’s grant obligations. The FAA encourages the City to take appropriate action to Enclosure (1)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 2 maintain compliance with its certification that it will comply with all applicable Federal laws, regulations, executive orders, policies, guidelines and requirements as they relate to use of federal funds for land use compatibility.

If you have any questions or concerns regarding this matter, I am available at (650) 876-2778 extension 613.

Sincerely,
(Original Signed by:)
Camille Garibaldi
Environmental Protection Specialist
Enclosure
cc:

Danielle Rinsler, San Francisco International Airport
Nixon Lam, San Francisco International Airport
Sandy Hesnard, California Department of Transportation
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND Land Use Yearly day-night average sound level (Ldn) in decibels < 65 65-70 70-75 75-80 80-85 > 85
Residential
Residential, other than mobile homes and
transient lodgings
Y N (1) N (1) N N N
Mobile home parks Y N N N N N
Transient lodgings Y N (1) N (1) N (1) N N

Y Y Y Y Y Y

The designations contained in this table do not constitute a Federal determination that any use of land covered by the program is acceptable or unacceptable under Federal, State, or local law. The responsibility for determining the acceptable and permissible land uses and the relationship between specific properties and specific noise contours rests with the local authorities. FAA determinations under Part 150 are not intended to substitute Federally determined land uses for those determined to be appropriate by local authorities in response to locally determined needs and values in achieving noise compatible land uses.
(more)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND LEVELS (CONTINUED) Key to Table 1
Y (YES) Land Use and related structures compatible without restrictions.

N (NO) Land Use and related structures are not compatible and should be prohibited.

CALIFORNIA
92 380

CALIFORNIA
82 CALIFORNIA
1 280

CALIFORNIA
35 E 3rd Ave
Hillside Blvd
Grand Ave
Linda Mar Blvd
Trousdale Dr
Oceana Blvd
Skyline Dr
Westborough Blvd
Fleetwood Dr
Sharp Park Rd
Crestmoor Dr
evA oetaM naS
Hickey Blvd
Old Bayshore Hwy
Southgate Ave
Fassler Ave
Crystal Springs Rd
N Amphlett Blvd
Huntington Ave
Adeline Dr
Hillside Dr
Junipero Serra Blvd
S Airport Blvd
S Spruce Ave
Peninsula Ave
Carmelita Ave
Lomita Ave
San Bruno Ave W
Howard Ave
E Grand Ave
Gateway Dr
Callan Blvd
Manzanita Dr
Millbrae Ave
Serramonte Blvd
Ludeman Ln
Airport Blvd
Sneath Ln
El Camino Real

SOUTH SAN FRANCISCO

BRISBANE

SAN BRUNO

BURLINGAME

PACIFICA

MILLBRAE
COLMA

DALY CITY

HILLSBOROUGH
28L
San Francisco Bay
Pacific Ocean
San Andreas Lake
San Francisco International Airport
1L1R
1 L9
91 R
10L
10R
28R

SAN MATEO

UNINCORPORATED

FOSTER CITY
0 5,000
Feet
Airport Property Boundary
Aircraft Noise Contour
Municipal Boundary

NOISE SENSITIVE FACILITIES
School
Hospital
Place of Worship
Historic Structures

GENERALIZED EXISTING LAND USE
Single Family Residential
Multi-Family Residential
Commercial
Industrial
Public
Mixed Use
Open Space/Recreation/Preservation
Park/Golf Course/Cemetery
Water
Vacant/Unknown
CNEL – Community Noise Equivalent Level
dB – Decibel
SFO 14 CFR Part 150 Noise Exposure Map Report . 120832
SOURCES: ESRI, 2014; San Mateo County Planning and Building Department, 2014; BridgeNet International, 2014; ESA Airports, 2014 Exhibit 5-2 2019 Noise Exposure Map – San Francisco International Airport Enclosure (2)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 San Francisco International Airport
Arrival
Preparing for landing at SFO to Runway 10 end. Photo taken on January 22, 2022.

Enclosure (3)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 Tanforan
ShoppingCenter
Airport Design Approach/Departure Obstruction Clearance Surface (OCS) for SFO Runway 10R/28L and Runway 10L/28R and Location of Current Tanforan Shopping Center Enclosure {4}
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 Approach/Departure OCS Profiles
Enclosure {5}
TanforanShopping Center
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-34] Airport/Land Use Compatibility Policies
and associated with human disease of varying severity.
b. Biosafety Level 3 practices, safety equipment, and facility design and construction are applicable to clinical, diagnostic, teaching, research, or production facilities in which work is done with indigenous or exotic agents with a potential for respiratory transmission, and which may cause serious and potentially lethal infection. c. Biosafety Level 4 practices, safety equipment, and facility design and construction are applicable for work with dangerous and exotic agents that pose a high individual risk of life-threatening disease, which may be transmitted via the aerosol route and for which there is no available vaccine or therapy.

1. To protect the public health, safety, and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY OCTOBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-35]
Exhibit IV-10 depicts the approximate elevations at which the 14 CFR Part 77 notification requirements would be triggered; see Exhibit IV-11 for a close-up view of the northern half and Exhibit IV-12 for a close-up view of the southern half of the area. These exhibits are provided for informational purposes only. Official determinations of the areas and elevations within which the federal notification requirements apply are subject to the authority of the FAA.

Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.

16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 280
380
280
280
101
101
101
101
1 35
82 82
1 1
82 ROLLINS RD

HILLSIDE BLVD
E 3RD AVE

CALIFORNIA DR

BAYSHORE BLVD

EL CAMINO REAL MISSION RD
87TH ST

AIRPORT BL V D

CALLAN BLVD

GRAND AVE

MILLER AVE

SOUTHG ATE AVE

TRO USDALE DR

SHARP PA RK RD

SNEATH LN

PARK WY

C R ESPI DR

FLEETWOO D D R

MURCHISON D R

SULLIVAN AVE

ST FR ANCIS BLVD

JOHN DALY BLVD

RALSTON AVE

HE LEN DR

A RROYO DR

S AIRPORT BLVD

SKYLINE BO ULEVARD

GENEVA AVE

N HUMBOLDT ST

FASSLER AVE

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D
STATE HIGHWAY 35

HUNTINGTON AVE

LIN DA MAR BL VD

HICKEY BL V D

SHAW RD

ADELINE DR
E 4TH AVE

TERRA NOVA BLVD

HILLSIDE DR

LINDEN AVE

LO M ITA AVE

S SPR UCE AVE

SERRA M ONTE BL VD

CHESTNUT AVE

N DELAWARE ST

BELLEVUE AVE

E GRAND AVE

S NORFOLK ST

HOLLY A VE

CARMELITA AVE

S LINDEN AVE

UTAH AVE

LOYOLA DR
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

C RESTMOOR DR

JENEVEIN AVE

MADISON AVE

MILLBRAE AVE

SISTER CITIES BLVD

CRYSTA L S PRINGS RD

W SAN B RUNO A V E

SEBASTIAN DR ALTA MESA DR

LER ID A WY

PARK PLAZA DR

PAR K BLVD

JUNIPERO SERRA BLVD

ALICA N TE DR

MAGNOLIA AVE

SAN MATEO AVE

BROADWAY

HOFFMAN ST

RICHMOND DR

SE VILLE DR

MONTEREY RD

RIDGEWOOD DR

EASTON DR

EAR L AV E

SAN ANTONIO AVE

SHARON AVE

LARKSPUR DR

GATEWA Y DR

EL CERRITO AVE

CHATEAU DR

WESTLAKE AVE

BELLA VISTA DR

LIT T LEFIELD AVE

CROCKER AVE

E MARKET ST

LINCOLN AVE

OAKS DR

EL CAMINO REAL

ODDSTAD BLVD

HUNT DR

SUMMIT DR

EUCALYPTUS AVE

HELEN DR
STATE HIGHWAY 35

W SAN BRUNO AVE

EL CAM NI O REAL

SNEAT H LN

MAGNOLIA AVE

Notes:

Exhibit IV-17

AIRPORT
Mean sea level
Elevation, feet AMSL
100 200 300 400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces,feet AGL (represented on plan with color gradient) Calculated as - =
0 Ground level
(Terrain)
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 LEGEND
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Exhibit IV-18

ROLLINS RD
E 3RD AVE

CALIFORNIA DR

S NORFOLK ST

ALAMEDA DE LAS PULGAS

P A RRO TT DR

E HILLSDALE BLVD

AIRPORT B LVD

CRYSTAL SP RIN GS RD
31ST AVE
28TH AVE

S DELAWARE ST

S GRANT ST

W HILLSDALE BLVD

HA YNE R D

OLD COUNTY RD
ELM ST
9TH AVE

FOSTER CITY BLVD

TRO USDALE DR

HALL MA RK DR
42N D AVE

MURCHISON D R

SHELL BLVD

CHATEAU DR

SAN C A RLOS AVE

CANA D A R D

HILLER ST

M A RINE PKWY

BEACH PARK BLVD

RALSTON AVE

N HUMBOLDT ST

POLH EMUS RD

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D

EL CERRITO AVE

SHAW RD
22ND AVE
STATE HI GHWAY 92

CEDAR ST

ADELINE DR

HILLSIDE DR

N DELAWARE ST

BUNKER HILL DR

DE ANZA BLVD

S AIRPORT BLVD

SOUT H RD

CARMELITA AVE
E 40TH A VE

LOYOLA DR

EDINBURGH ST

REDWOOD SHORES PKWY
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

BOREL AVE

PALM AVE

SEAPORT BLVD

M A RINERS IS L A ND BLVD

MILLBRAE AVE

KEHOE AVE

SEBASTIAN DR

S AMPHLETT BLVD

VIRGINIA AVE

PA RK BLVD

SHELL PKWY

MAGNOLIA AVE

CURTISS ST

PASADENA DR

CHULA VISTA DR

W SANTA INEZ AVE

LEXINGTO N AVE

GLENDORA DR

LAUREL ST

LOS P RAD OS
ALLEY

BROADWAY

HELEN DR

RICHMOND DR

NORTE DAME AVE
W 25TH AVE

POR T ROYAL AVE

EASTON DR

TICOND E R O G A D R

SAN ANTONIO AVE

SWORDFISH ST

SHARON AVE

SANDERLING ST
W 5TH AVE

EL CAMINO REAL

FOREST VIEW AVE

BELLA VISTA DR

COLUMBIA DR

SAN MATEO AVE

OAKS DR

ARBOR AVE

TILIA ST

BARROILHET AVE
E 25TH AVE

HUNT DR

BERMUDA DR

SUMMIT DR

HELEN DR

BEACH PARK BLVD

MAGNOLIA AVE

PALM AVE
E 3RD AVE

RALSTON AVE
Lower Crystal Springs Rsvr Lower Crystal Springs Rsvr
Upper Crystal Reservoir Upper Crystal Reservoir
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

Notes:

Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-55]
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace surfaces along the extended centerline of Runway 10L-28R – the TERPS Obstacle Departure Procedure (ODP) surface, representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace surfaces and various aircraft approach and departure profiles, based on varying operating assumptions. The exhibit illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always designed below the actual aircraft flight profile which they are designed to protect, thus providing a margin of safety.

Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.

4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.

AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-59]
AP-3 MAXIMUM COMPATIBLE BUILDING HEIGHT
In order to be deemed consistent with the ALUCP, the maximum height of a new building must be the lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV-18), or (2) the maximum height determined not to be a “hazard to air navigation” by the FAA in an aeronautical study prepared pursuant to the filing of Form 7460-1.

Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a) Sources of glare, such as highly reflective buildings or building features, or bright lights, including search lights or laser displays, which would interfere with the vision of pilots making approaches to the Airport.
(b) Distracting lights that that could be mistaken by pilots on approach to the Airport for airport identification lighting, runway edge lighting, runway end identification lighting, or runway approach lighting.
(c) Sources of dust, smoke, or water vapor that may impair the vision of pilots making approaches to the Airport.
(d) Sources of electrical interference with aircraft or air traffic control communications or navigation equipment, including radar.
(e) Land uses that, as a regular byproduct of their operations, produce thermal plumes with the potential to rise high enough and at sufficient velocities to interfere with the control of aircraft in DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-60] Airport/Land Use Compatibility Policies
flight. Upward velocities of 4.3 meters (14.1 feet) per second at altitudes above 200 feet above the ground shall be considered as potentially interfering with the control of aircraft in flight.17 (f) Any use that creates an increased attraction for wildlife, particularly large flocks of birds, that is inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.5A, Waste Disposal Sites On or Near Airports, FAA Advisory Circular 150/5200-33B, Hazardous Wildlife Attractants On or Near Airports, and any successor or replacement orders or advisory circulars. Exceptions to this policy are acceptable for wetlands or other environmental mitigation projects required by ordinance, statute, court order, or Record of Decision issued by a federal agency under the National Environmental Policy Act.

Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 Western-Pacific Region
Office of the Regional Administrator

777 S. Aviation Blvd.

El Segundo, CA 90245

May 18, 2022
Mr. Jovan D. Grogan
City Manager
City of San Bruno
567 El Camino Real
San Bruno, CA 94066-4247
RE: Concerns regarding the Reimagining Tanforan Redevelopment Project Dear Mr. Grogan:

The City of San Bruno is directly responsible for ensuring proper planning in partnership with state, local, and private entities, and notifying purchasers of real estate and prospective residents of their exposure to direct overflight and extreme and persistent airport noise. In the past, the City of San Bruno directly received federal funding for residential sound insulation to mitigate land use compatibility issues. On May 14, 2008, the FAA reminded the City of San Bruno, via enclosure 1, of the importance of taking appropriate action to adopt zoning and further restrict the introduction of additional non-compatible land uses adjacent to or in the vicinity of SFO. The DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 enclosure to that letter provides Appendix A, Table 1- Land Use Compatibility Guidelines from 14 Code of Federal Regulations Part 150 – Airport Noise Compatibility Planning (Part 150). As shown in enclosure 2, the 2019 Noise Exposure Map from the SFO Noise Compatibility Program1, a majority of the Tanforan Mall area is within the Community Noise Equivalent Level (CNEL) 70 decibel (dB) contour and is heavily affected by SFO departures from Runways 28L and 28R. The FAA continues to provide Airport Improvement Program (AIP) funding for qualified impacted City of San Bruno residences through the SFO Residential Sound Insulation Program. In accordance with FAA Final Policy on Part 150 Approval of Noise Mitigation Measures: Effect on the Use of Federal Grants for Noise Mitigation Projects (63 FR 16409), structures and new non-compatible development built after October 1, 1998, are not eligible for approval of remedial noise mitigation measures under Part 150 or AIP funding. In other words, residences in the Tanforan Project would not receive any AIP funding for residential sound insulation.

Compliance with FAA guidelines and federal law does not exempt a project sponsor from complying with local regulations.

Therefore, we strongly encourage the City of San Bruno and San Mateo County officials to consider the FAA’s concerns and look to develop and maintain compatible land uses around SFO.

If you have any questions, please contact my office at (424) 405-7000.

Sincerely,
Tamara A. Swann
Regional Administrator (A)
Enclosures
cc:

The most recent AIP grant is 3-06-0021-29.

Development of local land use plans that are compatible with airport operations is key to ensuring consistency with the City’s grant obligations. The FAA encourages the City to take appropriate action to Enclosure (1)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 2 maintain compliance with its certification that it will comply with all applicable Federal laws, regulations, executive orders, policies, guidelines and requirements as they relate to use of federal funds for land use compatibility.

If you have any questions or concerns regarding this matter, I am available at (650) 876-2778 extension 613.

Sincerely,
(Original Signed by:)
Camille Garibaldi
Environmental Protection Specialist
Enclosure
cc:

Danielle Rinsler, San Francisco International Airport
Nixon Lam, San Francisco International Airport
Sandy Hesnard, California Department of Transportation
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND Land Use Yearly day-night average sound level (Ldn) in decibels < 65 65-70 70-75 75-80 80-85 > 85
Residential
Residential, other than mobile homes and
transient lodgings
Y N (1) N (1) N N N
Mobile home parks Y N N N N N
Transient lodgings Y N (1) N (1) N (1) N N

Y Y Y Y Y Y

The designations contained in this table do not constitute a Federal determination that any use of land covered by the program is acceptable or unacceptable under Federal, State, or local law. The responsibility for determining the acceptable and permissible land uses and the relationship between specific properties and specific noise contours rests with the local authorities. FAA determinations under Part 150 are not intended to substitute Federally determined land uses for those determined to be appropriate by local authorities in response to locally determined needs and values in achieving noise compatible land uses.
(more)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 TABLE 1—LAND USE COMPATIBILITY WITH YEARLY DAY-NIGHT AVERAGE SOUND LEVELS (CONTINUED) Key to Table 1
Y (YES) Land Use and related structures compatible without restrictions.

N (NO) Land Use and related structures are not compatible and should be prohibited.

CALIFORNIA
92 380

CALIFORNIA
82 CALIFORNIA
1 280

CALIFORNIA
35 E 3rd Ave
Hillside Blvd
Grand Ave
Linda Mar Blvd
Trousdale Dr
Oceana Blvd
Skyline Dr
Westborough Blvd
Fleetwood Dr
Sharp Park Rd
Crestmoor Dr
evA oetaM naS
Hickey Blvd
Old Bayshore Hwy
Southgate Ave
Fassler Ave
Crystal Springs Rd
N Amphlett Blvd
Huntington Ave
Adeline Dr
Hillside Dr
Junipero Serra Blvd
S Airport Blvd
S Spruce Ave
Peninsula Ave
Carmelita Ave
Lomita Ave
San Bruno Ave W
Howard Ave
E Grand Ave
Gateway Dr
Callan Blvd
Manzanita Dr
Millbrae Ave
Serramonte Blvd
Ludeman Ln
Airport Blvd
Sneath Ln
El Camino Real

SOUTH SAN FRANCISCO

BRISBANE

SAN BRUNO

BURLINGAME

PACIFICA

MILLBRAE
COLMA

DALY CITY

HILLSBOROUGH
28L
San Francisco Bay
Pacific Ocean
San Andreas Lake
San Francisco International Airport
1L1R
1 L9
91 R
10L
10R
28R

SAN MATEO

UNINCORPORATED

FOSTER CITY
0 5,000
Feet
Airport Property Boundary
Aircraft Noise Contour
Municipal Boundary

NOISE SENSITIVE FACILITIES
School
Hospital
Place of Worship
Historic Structures

GENERALIZED EXISTING LAND USE
Single Family Residential
Multi-Family Residential
Commercial
Industrial
Public
Mixed Use
Open Space/Recreation/Preservation
Park/Golf Course/Cemetery
Water
Vacant/Unknown
CNEL – Community Noise Equivalent Level
dB – Decibel
SFO 14 CFR Part 150 Noise Exposure Map Report . 120832
SOURCES: ESRI, 2014; San Mateo County Planning and Building Department, 2014; BridgeNet International, 2014; ESA Airports, 2014 Exhibit 5-2 2019 Noise Exposure Map – San Francisco International Airport Enclosure (2)
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 San Francisco International Airport
Arrival
Preparing for landing at SFO to Runway 10 end. Photo taken on January 22, 2022.

1. To protect the public health, safety, and welfare by minimizing the public’s exposure to potential safety hazards that could be created through the construction of tall structures.

Obstructions may occur without compromising safe air navigation, but they must be marked, lighted, and noted on aeronautical publications to ensure that pilots can see and avoid them.

16 See Appendix F, Section F.3.2 for a discussion of one-engine inoperative procedures.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 280
380
280
280
101
101
101
101
1 35
82 82
1 1
82 ROLLINS RD

HILLSIDE BLVD
E 3RD AVE

CALIFORNIA DR

BAYSHORE BLVD

EL CAMINO REAL MISSION RD
87TH ST

AIRPORT BL V D

CALLAN BLVD

GRAND AVE

MILLER AVE

SOUTHG ATE AVE

TRO USDALE DR

SHARP PA RK RD

SNEATH LN

PARK WY

C R ESPI DR

FLEETWOO D D R

MURCHISON D R

SULLIVAN AVE

ST FR ANCIS BLVD

JOHN DALY BLVD

RALSTON AVE

HE LEN DR

A RROYO DR

S AIRPORT BLVD

SKYLINE BO ULEVARD

GENEVA AVE

N HUMBOLDT ST

FASSLER AVE

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D
STATE HIGHWAY 35

HUNTINGTON AVE

LIN DA MAR BL VD

HICKEY BL V D

SHAW RD

ADELINE DR
E 4TH AVE

TERRA NOVA BLVD

HILLSIDE DR

LINDEN AVE

LO M ITA AVE

S SPR UCE AVE

SERRA M ONTE BL VD

CHESTNUT AVE

N DELAWARE ST

BELLEVUE AVE

E GRAND AVE

S NORFOLK ST

HOLLY A VE

CARMELITA AVE

S LINDEN AVE

UTAH AVE

LOYOLA DR
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

C RESTMOOR DR

JENEVEIN AVE

MADISON AVE

MILLBRAE AVE

SISTER CITIES BLVD

CRYSTA L S PRINGS RD

W SAN B RUNO A V E

SEBASTIAN DR ALTA MESA DR

LER ID A WY

PARK PLAZA DR

PAR K BLVD

JUNIPERO SERRA BLVD

ALICA N TE DR

MAGNOLIA AVE

SAN MATEO AVE

BROADWAY

HOFFMAN ST

RICHMOND DR

SE VILLE DR

MONTEREY RD

RIDGEWOOD DR

EASTON DR

EAR L AV E

SAN ANTONIO AVE

SHARON AVE

LARKSPUR DR

GATEWA Y DR

EL CERRITO AVE

CHATEAU DR

WESTLAKE AVE

BELLA VISTA DR

LIT T LEFIELD AVE

CROCKER AVE

E MARKET ST

LINCOLN AVE

OAKS DR

EL CAMINO REAL

ODDSTAD BLVD

HUNT DR

SUMMIT DR

EUCALYPTUS AVE

HELEN DR
STATE HIGHWAY 35

W SAN BRUNO AVE

EL CAM NI O REAL

SNEAT H LN

MAGNOLIA AVE

Notes:

Exhibit IV-17

AIRPORT
Mean sea level
Elevation, feet AMSL
100 200 300 400
Elevation of critical aeronautical surfaces, feet AMSL (represented on plan with contours) Height of critical aeronautical surfaces,feet AGL (represented on plan with color gradient) Calculated as - =
0 Ground level
(Terrain)
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 LEGEND
Elevation of critical aeronautical surfaces, feet
Above Mean Sea Level (AMSL), North American
Vertical Datum of 1988 (NAVD88)
100
Exhibit IV-18

ROLLINS RD
E 3RD AVE

CALIFORNIA DR

S NORFOLK ST

ALAMEDA DE LAS PULGAS

P A RRO TT DR

E HILLSDALE BLVD

AIRPORT B LVD

CRYSTAL SP RIN GS RD
31ST AVE
28TH AVE

S DELAWARE ST

S GRANT ST

W HILLSDALE BLVD

HA YNE R D

OLD COUNTY RD
ELM ST
9TH AVE

FOSTER CITY BLVD

TRO USDALE DR

HALL MA RK DR
42N D AVE

MURCHISON D R

SHELL BLVD

CHATEAU DR

SAN C A RLOS AVE

CANA D A R D

HILLER ST

M A RINE PKWY

BEACH PARK BLVD

RALSTON AVE

N HUMBOLDT ST

POLH EMUS RD

BAYSHORE HWY

TILTON AVE

N AMPHLETT BLVD

N MCDONNELL R D

EL CERRITO AVE

SHAW RD
22ND AVE
STATE HI GHWAY 92

CEDAR ST

ADELINE DR

HILLSIDE DR

N DELAWARE ST

BUNKER HILL DR

DE ANZA BLVD

S AIRPORT BLVD

SOUT H RD

CARMELITA AVE
E 40TH A VE

LOYOLA DR

EDINBURGH ST

REDWOOD SHORES PKWY
RAY DR

DWIGHT RD

OCCIDENTAL AVE

N SAN MATEO DR

BOREL AVE

PALM AVE

SEAPORT BLVD

M A RINERS IS L A ND BLVD

MILLBRAE AVE

KEHOE AVE

SEBASTIAN DR

S AMPHLETT BLVD

VIRGINIA AVE

PA RK BLVD

SHELL PKWY

MAGNOLIA AVE

CURTISS ST

PASADENA DR

CHULA VISTA DR

W SANTA INEZ AVE

LEXINGTO N AVE

GLENDORA DR

LAUREL ST

LOS P RAD OS
ALLEY

BROADWAY

HELEN DR

RICHMOND DR

NORTE DAME AVE
W 25TH AVE

POR T ROYAL AVE

EASTON DR

TICOND E R O G A D R

SAN ANTONIO AVE

SWORDFISH ST

SHARON AVE

SANDERLING ST
W 5TH AVE

EL CAMINO REAL

FOREST VIEW AVE

BELLA VISTA DR

COLUMBIA DR

SAN MATEO AVE

OAKS DR

ARBOR AVE

TILIA ST

BARROILHET AVE
E 25TH AVE

HUNT DR

BERMUDA DR

SUMMIT DR

HELEN DR

BEACH PARK BLVD

MAGNOLIA AVE

PALM AVE
E 3RD AVE

RALSTON AVE
Lower Crystal Springs Rsvr Lower Crystal Springs Rsvr
Upper Crystal Reservoir Upper Crystal Reservoir
Elevation of terrain, feet AMSL
Critical
aeronautical
surfaces

Notes:

Sources: San Francisco International Airport, Jacobs
Consultancy, and Planning Technology Inc., 2009
A
B
C
A B C
A
B
C
A
C
35 and lower
35- 65
65 - 100
100 - 150
150 and more
DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport Airport/Land Use Compatibility Policies [IV-55]
Exhibit IV-19, which is provided for information purposes only, depicts a profile view of the lowest critical airspace surfaces along the extended centerline of Runway 10L-28R – the TERPS Obstacle Departure Procedure (ODP) surface, representing standard all-engines departures, and the approximate OEI surface developed by SFO through independent study in consultation with the airlines serving SFO. The exhibit also shows the terrain elevation beneath the airspace surfaces and various aircraft approach and departure profiles, based on varying operating assumptions. The exhibit illustrates a fundamental principle related to the design of airspace protection surfaces. The surfaces are always designed below the actual aircraft flight profile which they are designed to protect, thus providing a margin of safety.

Note that the ODP climb profile is above the ODP airspace surface, and the OEI climb profile is above the OEI airspace surface.

4.5.4 AIRSPACE PROTECTION POLICIES
The following airspace protection policies (AP) shall apply to the ALUCP.

AP-1 COMPLIANCE WITH 14 CFR PART 77, SUBPART B, NOTICE OF PROPOSED

Specific characteristics that may create hazards to aircraft in flight and which are incompatible include:
(a) Sources of glare, such as highly reflective buildings or building features, or bright lights, including search lights or laser displays, which would interfere with the vision of pilots making approaches to the Airport.
(b) Distracting lights that that could be mistaken by pilots on approach to the Airport for airport identification lighting, runway edge lighting, runway end identification lighting, or runway approach lighting.
(c) Sources of dust, smoke, or water vapor that may impair the vision of pilots making approaches to the Airport.
(d) Sources of electrical interference with aircraft or air traffic control communications or navigation equipment, including radar.
(e) Land uses that, as a regular byproduct of their operations, produce thermal plumes with the potential to rise high enough and at sufficient velocities to interfere with the control of aircraft in DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 THE CITY/COUNTY ASSOCIATION OF GOVERNMENTS OF SAN MATEO COUNTY NOVEMBER 2012 Comprehensive Airport Land Use Compatibility Plan
for the Environs of San Francisco International Airport [IV-60] Airport/Land Use Compatibility Policies
flight. Upward velocities of 4.3 meters (14.1 feet) per second at altitudes above 200 feet above the ground shall be considered as potentially interfering with the control of aircraft in flight.17 (f) Any use that creates an increased attraction for wildlife, particularly large flocks of birds, that is inconsistent with FAA rules and regulations, including, but not limited to, FAA Order 5200.5A, Waste Disposal Sites On or Near Airports, FAA Advisory Circular 150/5200-33B, Hazardous Wildlife Attractants On or Near Airports, and any successor or replacement orders or advisory circulars. Exceptions to this policy are acceptable for wetlands or other environmental mitigation projects required by ordinance, statute, court order, or Record of Decision issued by a federal agency under the National Environmental Policy Act.

Supplemental Staff Assessment, Part 2,. CEC-700-2010-004-REV1-SUP-PT2, July 2010. California Energy Commission. Docket Number 09-AFC-6, p.

DocuSign Envelope ID: 84EE0D0D-C4A8-4373-B86E-FA1F4B33C708 RESOLUTION NO. 2023 - __

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN

BRUNO ADOPTING A GENERAL PLAN AMENDMENT TO POLICY
HS-40, AND ADOPTING A GENERAL PLAN AMENDMENT TO

UPDATE THE HOUSING ELEMENT OF THE GENERAL PLAN FOR
THE PERIOD 2023-2031, REPLACING THE 2015-2023 HOUSING

ELEMENT, WITH FINDINGS OF SUBSTANTIAL COMPLIANCE WITH

STATE HOUSING ELEMENT LAW, PURSUANT TO GOVERNMENT
CODE SECTION 65585, AND AUTHORIZING STAFF TO SUBMIT THE

HOUSING ELEMENT UPDATE TO THE CALIFORNIA DEPARTMENT

OF HOUSING AND COMMUNITY DEVELOPMENT FOR REVIEW AND

CERTIFICATION
WHEREAS, the California legislature has found that “California has a housing supply and affordability crisis of historic proportions. The consequences of failing to effectively and aggressively confront this crisis are hurting millions of Californians, robbing future generations of the chance to call California home, stifling economic opportunities for workers and businesses, worsening poverty and homelessness, and undermining the state’s environmental and climate objectives.” (Gov. Code Section 65589.5.); and
WHEREAS, the legislature has further found that “Among the consequences of those actions are discrimination against low-income and minority households, lack of housing to support employment growth, imbalance in jobs and housing, reduced mobility, urban sprawl, excessive commuting, and air quality deterioration.” (Gov. Code Section 65589.5.); and
WHEREAS, the legislature adopted the Housing Crisis Act of 2019 (SB 330) which states that “In 2018, California ranked 49th out of the 50 states in housing units per capita… California needs an estimated 180,000 additional homes annually to keep up with population growth, and the Governor has called for 3.5 million new homes to be built over 7 years”; and
WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of San Bruno’s (City) regional housing need allocation (RHNA) of 3,165 housing units, comprised of 704 very-low-income units, 405 low-income units, 573 moderate-income units, and 1,483 above moderate-income units; and
WHEREAS, State law requires that the City take meaningful steps to promote and affirmatively further fair housing (Gov. Code Section 65583(c)(5)); and WHEREAS, State law requires that the City make zoning available for all types of housing, including multifamily housing (Gov. Code Sections 65583.2 and 65583(c)); and 691 of 1863
WHEREAS, the proposed 2023-2031 Housing Element will replace the existing 2015-2023 Housing Element and serve as the City of San Bruno’s guiding policy document for meeting the City’s future housing needs at all economic levels; and WHEREAS, as provided in Government Code Sections 65352 – 65352.5 San Bruno referred the Housing Element to all California Native American tribes on the contact list provided by the Native American Heritage Commission and to other entities listed; and
WHEREAS, no California Native American tribe requested consultation; and WHEREAS, the preparation, adoption, and implementation of the Housing Element requires a diligent effort to include all economic segments of the community; and
WHEREAS, the City conducted extensive community outreach over the last 24 months, including public meetings before the Planning Commission and City Council; and
WHEREAS, on May 24, 2022, the first draft of the Housing Element was published on the City’s website and made available for a 30-day public review period that closed on June 24, 2022, and the city considered public comments on the draft during a 10-day review period after the close of the comment period before submittal to the State Department of Housing and Community Development (HCD) for its review; and
WHEREAS, on July 8, 2022, the City submitted the draft Housing Element to the State Department of Housing and Community Development (HCD) for its 90-day review; and
WHEREAS, in September 2022, City staff contacted HCD to discuss preliminary feedback regarding the adequacy of the draft Housing Element, and based upon this conversation, City staff revised the draft Housing Element to include additional information and data; and
WHEREAS, on October 6, 2022, the City received a letter from HCD stating that the revised draft Housing Element was not in compliance with State Housing Element Law, and further changes were needed to bring it into compliance with State Housing Element Law before it is certified by HCD in accordance with Government Code Section 65585; and
WHEREAS, the City has considered the comments in HCD’s October 6, 2022 letter, and has made revisions to the draft Housing Element to address those comments; and,
WHEREAS, on December 30, 2022, the City published a revised draft Housing Element responding to HCD’s findings and requested public comment on the draft; and 692 of 1863
WHEREAS, on January 12, 2023, the Planning Commission conducted a duly noticed public hearing, reviewed the proposed 2023-2031 Housing Element, which includes revisions to address HCD’s review comments, and all pertinent maps, documents, and exhibits, including the comments made by HCD and public comments, and adopted Resolution No. 2023-02 recommending that the City Council adopt the document with certain recommended revisions, and forward it to HCD for review and certification; and
WHEREAS, on that same date, the Planning Commission reviewed a companion amendment to Policy HS-40 in the General Plan and adopted Resolution No. 2023-02 recommending that the City Council adopt the amendment; and WHEREAS, on that same date, the Planning Commission considered the Initial Study and Draft Mitigated Negative Declaration, public comments and responses, the application of all mitigation measures and a proposed Mitigation Monitoring and Reporting Program prepared for the 2023-2031 Housing Element update pursuant to the California Environmental Quality Act, and adopted Resolution No. 2023-01 recommending that the City Council adopt the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program; and
WHEREAS, a Notice of Public Hearing for the 2023-2031 Housing Element Update was duly posted in the San Mateo Daily Journal on Saturday, January 14, 2023; and
WHEREAS, on January 24, 2023, the City Council conducted a duly noticed public hearing to consider the Housing Element update, amendment of General Plan Policy HS-40, and the Initial Study/ Mitigated Negative Declaration and related CEQA review documentation; and
WHEREAS, the City Council adopted Resolution No. 2023-____, which is hereby incorporated by reference, finding, among other things, that the proposed Housing Element will not result in a significant effect upon the environment because the mitigation measures described in the MMRP have been added to the Project, and adopting the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of San Bruno, based on substantial evidence in the staff reports, written and oral testimony, and exhibits presented, hereby finds as follows:

1. The foregoing recitals are true and correct and are incorporated by reference into this action

2. The proposed General Plan Housing Element text and diagram amendment are consistent with the policies and intent of the General Plan. The proposed Housing Element amendment to the General Plan clarify and improve existing Housing Element policies and objectives and 693 of 1863
ensure internal consistency between the Housing Element and the Health and Safety Element. Further, the Housing Element amendment ensures consistency between the city’s General Plan and State law, and which achieve General Plan policies and objectives for equal access to housing, access to transportation improvement funds, and mixed use, transitoriented housing opportunities.

3. The proposed General Plan Housing Element amendment is in response to the requirements of the California Government Code to update the Housing Element every eight years. Adoption of an updated Housing Element is critical to address various requirements of State law and certification of the updated Housing Element is important to enhance the City’s eligibility for grant funds and to support the City’s local land use authority.

The proposed Housing Element Amendment, including amendment of existing Housing Element policies, is in response to extensive public outreach and analysis of housing trends and issues, including fair housing issues, within the City. As such, the Housing Element Amendment is prepared to address the public’s concerns and needs related to housing within the city.

Because several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria, the proposed Housing Element Amendment will facilitate the City’s ability to attract new grant funds to improve transportation, infrastructure, open space, and housing. The Housing Element Amendment will help ensure that households seeking different housing types and affordable housing will have opportunities to find housing in San Bruno.

4. The proposed Housing Element Amendment is in the public interest because maintaining consistency with State law requirements ensures that the City General Plan is adequate for City decision making, preserves access to State funding sources and reduces the risk to the community of lawsuits over the adequacy of the General Plan. The attached Exhibit B, which is hereby incorporated by reference, provides substantial evidence demonstrating how each requirement of Housing Element Law is addressed in the proposed Housing Element, in support of the finding that the proposed Housing Element is in substantial conformance with State law .

5. Based on substantial evidence in the record the properties listed in the Sites Inventory are located in the City’s commercial corridors within proximity to high quality transit, with existing uses that have low building to 694 of 1863
land value. Furthermore, the City has experienced increased development activity within the TCP as a result of the 2021 rezoning. For these reasons, and based on the additional evidence in the record, the City Council hereby finds that the existing uses on the non-vacant sites identified in the site inventory to accommodate the RHNA are likely to be discontinued during the planning period and therefore do not constitute an impediment to planned residential development on the sites during the planning period. Table 6-6 of the Housing Element, along with other evidence in the record, provides substantial evidence to support the finding that existing uses are likely to be discontinued during the planning period, and is hereby incorporated by reference.

6. As required by Government Code Section 65585(e), the City Council has considered the comments made by the Department of Housing and Community Development included in the Department’s letter to the City of San Bruno dated October 6, 2022, consistent with Government Code Section 65585(f), and as described in Exhibit C to this resolution, incorporated herein by this reference, the City has updated the Housing Element in response to the findings of the Department to substantially comply with the requirements of State Housing Element Law as interpreted by HCD.

7. The City Council, based on the evidence in the record, finds the proposed Housing Element to be in substantial conformance with State law and the General Plan of the City of San Bruno.

BE IT FURTHER RESOLVED, that the City Council hereby adopts the General Plan text amendment to Policy HS-40 to acknowledge the ALUC local override process as set forth in Exhibit D to this resolution which is incorporated herein by this reference, adopts the 2023–2031 Housing Element Update as set forth in Exhibit A to this resolution which is incorporated herein by this reference, replacing the 2015-2023 Housing Element, and findings that the Housing Element substantially complies with Housing Element Law for the reasons set forth in this Resolution and attachments hereto, and authorizes and directs Staff to submit the Housing Element to the California Department of Housing and Community Development for review and certification pursuant to Government Code Section 65585 (g).

BE IT FURTHER RESOLVED, that the City Council does hereby authorize the City Manager to make non-substantive changes to the 2023-2031 Housing Element related to any comments received from the California Department of Housing and Community Development to gain certification and concurrence that the Housing Element substantially complies with State Housing Element Law. 695 of 1863
Dated: January 24, 2023
-o0oI, Lupita Huerta, City Clerk, do hereby certify that the foregoing Resolution was duly and regularly passed and
adopted by the City Council of the City of San Bruno this 24th day of January 2023 by the following vote:

AYES: Councilmembers:

NOES: Councilmembers:

ABSENT: Councilmembers:

ATTEST:

Lupita Huerta, City Clerk
696 of 1863
Exhibit A
DRAFT 2023-2031 HOUSING ELEMENT
697 of 1863
698 of 1863
699 of 1863
San Bruno Housing
Element 2023 - 2031
Adopted by
San Bruno City Council
January 24, 2023
City of San Bruno

CITY COUNCIL
Rico E. Medina,
Mayor
Sandy Alvarez
Tom Hamilton
Marty Medina
Michael Salazar

PLANNING COMMISSION
Rick Biasotti
Marco Durazo
Auros Harman
Mary Lou Johnson
Thomas Kuhn
Kelly Lethin
Gerard Madden

CITY STAFF
Jovan D. Grogan,
City Manager
Darcy Smith
Assistant City Manager
Michael Laughlin,
Planning and Housing Manager
Michael Smith,
Senior Planner
Eliseo Amaya
Assistant Planner
Kristie Woo
Assistant Planner
Paul Chytla-Hinze
Planning Intern
700 of 1863
701 of 1863
CITY OF SAN BRUNO HOUSING ELEMENT 2023-2031 i

TABLE OF CONTENTS
1 INTRODUCTION .............................................................................................................. 1-1 A. Purpose .......................................................................................................................................................1-1 B. Organization ................................................................................................................................................1-2 C. Regional Housing Needs Determination......................................................................................................1-2 D. Regional Housing Needs Allocation ............................................................................................................1-3 E. Summary of Accomplishments in the Last Cycle.........................................................................................1-4 F. Relationship to Other General Plan Elements and Related Plans and Programs .......................................1-5 G. Data Sources...............................................................................................................................................1-8 H. Summary of Changes to State Housing Laws.............................................................................................1-8 2 HOUSING NEEDS ASSESSMENT ...................................................................................... 2-1 A. Population Growth.......................................................................................................................................2-1 B. Age ..............................................................................................................................................................2-3 C. Race and Ethnicity.......................................................................................................................................2-4 D. Income Characteristics ................................................................................................................................2-6 E. Housing Tenure...........................................................................................................................................2-8 F. Tenure by Income and Poverty ...................................................................................................................2-9 G. Housing .....................................................................................................................................................2-12 H. Employment and Unemployment ..............................................................................................................2-16 I. Industry Sector Composition .....................................................................................................................2-17 J. Balance of Jobs and Workers....................................................................................................................2-18 K. Rents and Rental Housing Affordability.....................................................................................................2-21 L. Renters and the COVID-19 Pandemic ......................................................................................................2-24 M. Home Prices and Sales Affordability .........................................................................................................2-25 N. Overpayment and Cost-Burdened Households.........................................................................................2-28 O. Housing Overcrowding ..............................................................................................................................2-31 P. Other Housing Issues ................................................................................................................................2-34 Q. Seniors ......................................................................................................................................................2-36 R. People with Disabilities..............................................................................................................................2-38 S. Female-Headed Households.....................................................................................................................2-41 T. Large Households .....................................................................................................................................2-42 U. Extremely Low-Income Households ..........................................................................................................2-44 V. Homeless Needs .......................................................................................................................................2-45 W. Farmworkers..............................................................................................................................................2-49 X. Non-English Speakers...............................................................................................................................2-51 Y. Assisted Housing Developments At-Risk of Conversion ...........................................................................2-53 Z. Energy Conservation.................................................................................................................................2-55 AA. Conclusion.................................................................................................................................................2-57 3 HOUSING CONSTRAINTS AND RESOURCES...................................................................... 3-1 A. Governmental Constraints...........................................................................................................................3-1 B. Funding Sources for Affordable Housing...................................................................................................3-28 C. Environmental Constraints ........................................................................................................................3-33 D. Market and Other Non-Governmental Constraints ....................................................................................3-35 702 of 1863

TABLE OF CONTENTS
ii
4 AFFIRMATIVELY FURTHERING FAIR HOUSING .................................................................. 4-1 A. What is Affirmatively Furthering Fair Housing? ...........................................................................................4-1 B. Fair Housing Assessment............................................................................................................................4-2 C. Resident Needs Fair Housing Survey .........................................................................................................4-3 D. Fair Housing Enforcement and Outreach Capacity .....................................................................................4-5 E. Integration and Segregation ........................................................................................................................4-8 F. Racially/ Ethnically Concentrated Area of Poverty (R/ECAP) or Affluence (R/ECAA)...............................4-26 G. Access to Opportunity ...............................................................................................................................4-28 H. Disproportionate Housing Needs...............................................................................................................4-39 I. Contributing Factors ..................................................................................................................................4-50 J. Goal 4 of the City’s Housing Element Policies and Programs: Promoting Equity in Housing....................4-51 5 PUBLIC OUTREACH ........................................................................................................ 5-1 A. Creating an Affordable Future Webinar Series............................................................................................5-2 B. Outreach Panels..........................................................................................................................................5-3 C. Equity Advisory Group.................................................................................................................................5-7 D. San Mateo County Fair Housing Survey .....................................................................................................5-7 E. Key Takeaways ...........................................................................................................................................5-8 6 SITES INVENTORY AND QUANTIFIED OBJECTIVES ............................................................ 6-1 A. No Net Loss Law .........................................................................................................................................6-1 B. Purpose of Sites Inventory ..........................................................................................................................6-2 C. Existing Land Use Summary .......................................................................................................................6-5 D. Summary of 2015-2023 Housing Entitlements ............................................................................................6-5 E. Assisted Housing Supply.............................................................................................................................6-7 F. Housing Production Underway ....................................................................................................................6-7 G. Additional Development Potential................................................................................................................6-7 H. Opportunity Sites and Realistic Capacity.....................................................................................................6-9 I. Quantified Objectives ................................................................................................................................6-23 7 GOALS, PROGRAMS, AND IMPLEMENTATION ACTIONS FOR 2023-2031............................. 7-1 A. Key Input and Directions .............................................................................................................................7-1 B. Goals ...........................................................................................................................................................7-2

APPENDICES
Appendix A Housing Element Accomplishments
Appendix B Housing Construction and Development Costs
Appendix C City of San Bruno Fair Housing Assessment
Appendix D AFFH Map and Data Packet
Appendix E San Bruno AFFH Seregation Report
Appendix F AFFH Resident Survey Analysis
Appendix G Sites Inventory AFFH Supplement
Appendix H Disparate Access to Educational Opportunities Appendix I State Fair Housing Laws and Regulations
Appendix J Summary of Public Engagement and Community Correspondence Appendix K Complete Site Inventory
Appendix L Housing Trust Fund Memo for San Bruno
703 of 1863

TABLE OF CONTENTS
CITY OF SAN BRUNO HOUSING ELEMENT 2023-2031 iii
List of Figures
Figure 2-1 Population Growth Trends ............................................................................................................................2-2 Figure 2-2 San Bruno Population by Race, 2000-2019 .................................................................................................2-4 Figure 2-3 San Bruno Senior and Youth Population by Race........................................................................................2-5 Figure 2-4 Households by Household Income Level .....................................................................................................2-7 Figure 2-5 Poverty Status by Race ................................................................................................................................2-7 Figure 2-6 Housing Tenure ............................................................................................................................................2-8 Figure 2-7 Housing Tenure by Race of Householder.....................................................................................................2-9 Figure 2-8 Household Income Level by Tenure...........................................................................................................2-10 Figure 2-9 Housing Tenure by Age..............................................................................................................................2-10 Figure 2-10 Housing Tenure by Housing Type ..............................................................................................................2-11 Figure 2-11 Housing Units by Year Structure Built ........................................................................................................2-12 Figure 2-12 Housing Type Trends .................................................................................................................................2-13 Figure 2-13 Vacant Units by Type..................................................................................................................................2-14 Figure 2-14 Household Type..........................................................................................................................................2-15 Figure 2-15 Jobs in a Jurisdiction ..................................................................................................................................2-16 Figure 2-16 Unemployment Rate...................................................................................................................................2-17 Figure 2-17 Resident Employment by Industry ..............................................................................................................2-18 Figure 2-18 Employed Residents and Jobs in San Bruno by Wage Group ...................................................................2-19 Figure 2-19 Jobs-Worker Ratios, By Wage Group.........................................................................................................2-20 Figure 2-20 Jobs-Household Ratio ................................................................................................................................2-21 Figure 2-21 Median Contract Rent.................................................................................................................................2-22 Figure 2-22 Contract Rents for Renter-Occupied Units .................................................................................................2-23 Figure 2-23 Home Values of Owner-Occupied Units .....................................................................................................2-26 Figure 2-24 Zillow Home Value Index (ZHVI) ................................................................................................................2-27 Figure 2-25 Cost Burden by Tenure...............................................................................................................................2-29 Figure 2-26 Cost Burden by Income Level.....................................................................................................................2-29 Figure 2-27 Cost Burden by Race..................................................................................................................................2-30 Figure 2-28 Cost-Burdened Senior Households by Income Level.................................................................................2-30 Figure 2-29 Cost Burden by Household Size.................................................................................................................2-31 Figure 2-30 San Bruno Overcrowding by Tenure and Severity .....................................................................................2-32 Figure 2-31 Overcrowding by Income Level and Severity .............................................................................................2-33 Figure 2-32 Overcrowding by Race ...............................................................................................................................2-33 Figure 2-33 Housing Units by Year Structure Built ........................................................................................................2-34 Figure 2-34 Substandard Housing Issues......................................................................................................................2-35 Figure 2-35 San Bruno Senior Households by Income and Tenure ..............................................................................2-37 Figure 2-36 Disability by Type........................................................................................................................................2-39 Figure 2-37 Household Type..........................................................................................................................................2-42 Figure 2-38 Female-Headed Households by Poverty Status.........................................................................................2-42 Figure 2-39 Household Size by Tenure .........................................................................................................................2-43 Figure 2-40 Housing Units by Number of Bedrooms .....................................................................................................2-44 Figure 2-41 Racial Group Share of General and Homeless Populations, San Mateo County.......................................2-46 Figure 2-42 Homelessness by Household Type and Shelter Status, San Mateo County..............................................2-46 Figure 2-43 Latino Share of General and Homeless Populations, San Mateo County ..................................................2-47 Figure 2-44 Characteristics for the Population Experiencing Homelessness, San Mateo County.................................2-47 Figure 2-45 Farm Operations and Farm Labor by County, San Mateo County .............................................................2-50 Figure 2-46 Population with Limited English Proficiency ...............................................................................................2-51 Figure 3-1 San Bruno 2025 General Plan Land Use Diagram.......................................................................................3-3 Figure 3-2 SFO ALUCP Map of Noise Compatibility Zones...........................................................................................3-7 Figure 4-1 Fair Housing Complaints and Inquiries.........................................................................................................4-6 Figure 4-2 Segregation and Integration Key Fair Housing Factors................................................................................4-8 Figure 4-3 Proposed RHNA Sites in Relation to Predominant Populations by Census Tract......................................4-11 Figure 4-4 Proposed RHNA Sites in Relation to Neighborhood Segregation Typologies............................................4-13 704 of 1863

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Figure 4-5 Proposed RHNA Sites in Relation to Median Income by Census Tract..................................................... 4-17 Figure 4-6 Proposed RHNA Sites in Relation to Percent of Population with a Disability by Census Tract ................. 4-20 Figure 4-7 Proposed RHNA Sites in Relation to the Percentage of Female Headed Households by Tract................ 4-22 Figure 4-8 Proposed RHNA Sites in Relation to Racially Concentrated Areas of Affluence ....................................... 4-27 Figure 4-9 Access to Opportunity Key Facts ............................................................................................................... 4-28 Figure 4-10 Proposed RHNA Sites in Relation to TCAC Education Opportunity by Tract ............................................ 4-30 Figure 4-11 Proposed RHNA Sites in Relation to Job Proximity ................................................................................... 4-32 Figure 4-12 Proposed RHNA Sites in Relation to Proximity to Transit Stops................................................................ 4-34 Figure 4-13 Proposed RHNA Sites in Relation to Environmental Health and Disadvantaged Communities ................ 4-35 Figure 4-14 Proposed RHNA Sites in Relation to TCAC Composite Opportunity Areas............................................... 4-38 Figure 4-15 Disproportionate Housing Needs Key Facts .............................................................................................. 4-40 Figure 4-16 Proposed RHNA Sites in Relation to Percentage of Cost Burdened Homeowners by Tract ..................... 4-42 Figure 4-17 Proposed RHNA Sites in Relation to Percentage of Cost Burdened Renters by Tract.............................. 4-43 Figure 4-18 Proposed RHNA Sites in Relation to the Percentage of Overcrowded Households by Tract.................... 4-45 Figure 4-19 Proposed RHNA Sites in Relation to Census Tracts Vulnerable to Displacement..................................... 4-46 Figure 6-1 Map of Housing Opportunity Sites ............................................................................................................. 6-10 705 of 1863

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List of Tables
Table 1-1 Regional Housing Needs Allocation .............................................................................................................1-3 Table 1-2 San Bruno’s RHNA.......................................................................................................................................1-4 Table 2-1 Population Growth Trends ............................................................................................................................2-2 Table 2-2 San Bruno Population by Age.......................................................................................................................2-3 Table 2-3 Regional Comparison – Population by Race................................................................................................2-4 Table 2-4 Income Category Definitions.........................................................................................................................2-6 Table 2-5 San Mateo County Income Limits (2022) .....................................................................................................2-6 Table 2-6 Tenure of Housing (2000, 2011 and 2019)...................................................................................................2-8 Table 2-7 Total Housing Units (2000, 2010 and 2019)...............................................................................................2-12 Table 2-8 Overall Occupancy Status and Vacancy Rates ..........................................................................................2-13 Table 2-9 Family Households with Children ...............................................................................................................2-15 Table 2-10 Employed Residents in San Bruno by Wage Group...................................................................................2-19 Table 2-11 Median Rents in October 2022 – San Bruno..............................................................................................2-23 Table 2-12 2022 San Mateo Maximum Affordable Rent Payments..............................................................................2-24 Table 2-13 Who Can Afford to Rent in San Mateo County ...........................................................................................2-25 Table 2-14 Median Single-Family and Condo Sales Prices (2010, 2015, 2020 and Fourth Quarter 2021)..................2-26 Table 2-15 Households by Household Size..................................................................................................................2-32 Table 2-16 Housing Permitting .....................................................................................................................................2-34 Table 2-17 San Mateo County Seniors in 2020 and 2030............................................................................................2-37 Table 2-18 Senior Households by Income and Tenure ................................................................................................2-38 Table 2-19 San Bruno Cost Burden of Senior Households by Income.........................................................................2-38 Table 2-20 Population with Developmental Disabilities by Residence .........................................................................2-40 Table 2-21 Students in Local Public Schools Experiencing Homelessness .................................................................2-48 Table 2-22 San Mateo County Point-in-Time Homeless Counts ..................................................................................2-48 Table 2-23 Migrant Worker Student Population............................................................................................................2-50 Table 2-24 Assisted Units at Risk of Conversion..........................................................................................................2-53 Table 2-25 Assisted Housing Developments in San Bruno ..........................................................................................2-54 Table 3-1 Residential Parking Requirements ...............................................................................................................3-5 Table 3-2 City of San Bruno Property Development Regulations for Residential Districts ...........................................3-9 Table 3-3 City of San Bruno Property Development Regulations for Mixed-Use Districts..........................................3-10 Table 3-4 Housing Types Permitted by Zoning District...............................................................................................3-17 Table 3-5 Timelines for Permit Procedures in San Bruno...........................................................................................3-17 Table 3-6 Typical San Bruno Processing Procedures by Residential Project Type ...................................................3-18 Table 3-7 Affordable Housing Linkage Fee ................................................................................................................3-20 Table 3-8 Other Development Fees, Projects Requiring Entitlement Application (2022) ...........................................3-22 Table 3-9 Development Impact Fees FY2022 - 2023.................................................................................................3-23 Table 3-10 San Mateo County Jurisdictions Total Fees (2022)....................................................................................3-24 Table 3-11 San Bruno Water Demand Comparison .....................................................................................................3-25 Table 4-1 Site Inventory in Census Tract 6041.02......................................................................................................4-23 Table 4-2 Site Inventory in Census Tracts 6041.03/6041.04......................................................................................4-24 Table 4-3 Site Inventory in Census Tract 6038.02......................................................................................................4-25 Table 4-4 Site Inventory in Census Tract 6039.00......................................................................................................4-25 Table 4-5 Site Inventory in Census Tract 6040.00......................................................................................................4-25 Table 4-6 Fair Housing Factors for Integration and Segregation and Site Inventory by Census Tract.......................4-26 Table 4-7 Fair Housing Factors for Access to Opportunity and Site Inventory by Census Tract................................4-39 Table 4-8 Disproportionate Housing Needs Fair Housing Factors and Site Inventory Summary by Census Tract....4-48 Table 6-1 San Bruno’s RHNA by Affordability ..............................................................................................................6-1 Table 6-2 Meeting San Bruno’s RHNA .........................................................................................................................6-2 Table 6-3 Summary of Housing Production under Last RHNA (2015-2023) ................................................................6-3 Table 6-4 Housing Production Underway and Approval Pipeline for 2023-2031 RHNA...............................................6-4 Table 6-5 Housing Opportunity Sites Zoned for Residential Development (Counted for RHNA) ...............................6-11 706 of 1863

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Table 6-6 Site Inventory Justification ......................................................................................................................... 6-17 Table 6-7 ADU Affordability Assumptions .................................................................................................................. 6-23 Table 6-8 Total Quantified Objectives ........................................................................................................................ 6-24 Table 7-1 Housing Element Goals Summary ............................................................................................................... 7-2 707 of 1863
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1 INTRODUCTION
A. PURPOSE
The Housing Element of the General Plan is designed to provide the City of San Bruno with a coordinated and comprehensive strategy for promoting the production of safe, decent, and affordable housing within the community. A priority of both state and local governments, Government Code Section 65580 states the intent of creating housing elements: The availability of housing is of vital statewide importance, and the early attainment of decent housing and a suitable living environment for every Californian, including farmworkers, is a priority of the highest order.

Per state law, the Housing Element has two main purposes:

1. To provide an assessment of both current and future housing needs and constraints in meeting these needs; and

2. To provide a strategy that establishes housing goals, policies, and programs.

In accordance with California Government Code (Title 7, Division 1, Chapter 3, Article 10.6), this Housing Element, presents a comprehensive set of housing policies and actions to address identified housing needs for the next eight years, from January 31, 2023, to January 31, 2031.

The Housing Element builds on an assessment of San Bruno’s housing needs (including the City’s regional housing needs allocation) and an evaluation of existing housing programs, available land, and constraints on housing production. Initiatives proposed to facilitate ongoing provision of affordable and market-rate housing in the city include conservation of residential neighborhoods, reuse of former school sites, redevelopment of transit corridors into mixed-use areas with residential components, and reduction of parking standards for housing units along transit corridors. All of these major initiatives are consistent with San Bruno’s adopted General Plan, Transit Corridors Plan (TCP), U.S. Navy Site Specific Plan, and Bayhill Specific Plan.
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B. ORGANIZATION
This Housing Element addresses all of the topics required by state law (Government Code sections 65583 through 65589.7). Specifically, the Element describes:
 population and employment trends (Chapter 2);
 household characteristics and housing stock characteristics (Chapter 2);  existing assisted housing and potential risk of conversion to market rates (Chapter 2);  energy conservation (Chapter 2);
 special housing needs (Chapters 2 and 4);
 governmental and non-governmental constraints (Chapter 3);  affirmatively furthering fair housing (AFFH) (Chapter 4);  public engagement to all segments of the community and description of how input will be incorporated into the housing element (Chapter 5);
 a detailed site inventory addressing availability and suitability for affordable housing development (Chapter 6);
 quantified objectives that estimate the maximum number of units, by income level, to be constructed, rehabilitated or conserved over the planning period (Chapter 6);  a new eight-year housing program with goals, programs, and implementation actions (Chapter 7); and  detailed accomplishments during the last Housing Element cycle (Appendix A).

C. REGIONAL HOUSING NEEDS DETERMINATION
The Bay Area continues to see growth in both population and jobs, which means more housing of various types and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call home. While the number of people drawn to the region over the past 30 years has steadily increased, housing production has not kept pace, contributing to the housing shortage that communities are experiencing today. In many cities, the limited housing supply has resulted in residents being priced out, increased traffic congestion caused by longer commutes, and fewer people across incomes being able to purchase homes or meet rising rents.

The Plan Bay Area 2050 Final Blueprint forecasts that the nine-county Bay Area will add 1.4 million new households between 2015 and 2050.1 For the eight-year timeframe covered by this Housing Element (2023- 2031), the California Department of Housing and Community Development (HCD) has identified the Bay Area region’s housing need as 441,176 units. The total number of housing units assigned by HCD for a region is separated into four income categories that cover housing types for all income levels, from very lowincome households to market rate housing.2 This total number of housing units assigned to the region, 1 Plan Bay Area 2050 is a long-range plan charting the course for the future of the nine-county San Francisco Bay Area. The Plan was adopted in October 2021 by the Metropolitan Transportation Commission. It covers four key issues: the economy, the environment, housing, and transportation. 2 HCD divides the RHND into the following four income categories:

Very Low-income: 0-50% of Area Median Income
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known as the Regional Housing Needs Determination (RHND), is based on population projections produced by the California Department of Finance as well as adjustments that result from recent legislation requiring HCD to incorporate the region’s existing housing need and additional adjustment factors to the baseline growth projection to get closer to healthy housing markets. To this end, adjustments focus on the region’s vacancy rate, level of overcrowding and the share of cost burdened households and seek to bring the region more in line with comparable regions. New laws governing the methodology for how HCD calculates the RHND resulted in a significantly higher number of housing units for which the Bay Area must plan compared to previous Regional Housing Needs Allocation or RHNA cycles.

D. REGIONAL HOUSING NEEDS ALLOCATION
A starting point for the Housing Element process for every California jurisdiction is RHNA or the share of the number of regional housing units needed assigned to each jurisdiction by the Association of Bay Area Governments (ABAG), the Bay Area’s regional planning agency3. State Housing Element Law requires ABAG to develop a methodology that calculates the number of housing units assigned to each city and county and distributes each jurisdiction’s housing unit allocation among four affordability levels (Very LowIncome, Low-Income, Moderate-Income, and Above Moderate-Income). For this cycle, the RHND for the Bay Area increased by 135%, from 187,990 to 441,176. In December 2021, ABAG adopted a Final RHNA Methodology, which was subsequently approved by HCD in January 2022.4 For San Bruno, the proposed RHNA is 3,165 units, an increase from the previous cycle which proposed 1,155 units in San Bruno. The total number of housing units and the distribution by income category requires the city choices, types and densities. Table 1-1 identifies the RHNA that San Bruno must provide by affordability level:

TABLE 1-1 REGIONAL HOUSING NEEDS ALLOCATION
Income Group
San Bruno
Units
San Mateo County
Units
Bay Area
Units
San Bruno
Percent
San Mateo County
Percent
Bay Area
Percent
Very Low-Income
(<50% of AMI) 704 12,196 114,442 22.2% 25.6% 25.9%
Low-Income
(50%-80% of AMI) 405 7,023 65,892 12.8% 14.7% 14.9%
Moderate-Income
(80%-120% of AMI) 573 7,937 72,712 18.1% 16.6% 16.5%
Above Moderate-Income
(>120% of AMI) 1,483 20,531 188,130 46.9% 43.1% 42.6%
Total 3,165 47,687 441,176 100.0% 100.0% 100.0%
Source: Association of Bay Area Governments.

Low-income: 50-80% of Area Median Income
Moderate-income: 80-120% of Area Median Income
Above Moderate-income: 120% or more of Area Median Income 3 For more information on the RHNA process this cycle, see ABAG’s website: https://abag.ca.gov/our-work/housing/rhna-regionalhousing-needs-allocation. 4 Methodology was approved by ABAG’s Executive board on December 16, 2021 (Resolution No. 02-2021). HCD approved the ABAG Regional Housing Needs Allocation (RHNA) Plan on January 12, 2022. 710 of 1863
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E. SUMMARY OF ACCOMPLISHMENTS IN THE LAST CYCLE

1. MEETING THE 2015-2023 REGIONAL HOUSING NEEDS ALLOCATION (RHNA) The most recent cycle (fifth cycle) covers the 2015 to 2023 period. The City’s most recent Housing Element, which covered the fifth cycle, identified adequate sites available to satisfy its RHNA obligation as well as policies and programs to help encourage and facilitate housing production at all income levels. However, the City fell short of meeting its RHNA obligation, even while removing several critical housing constraints.

Many more housing development projects were entitled but few received building permits during the time period. Several major projects that submitted development applications and received approvals did not move forward with processing of building permits or construction contributing to the RHNA obligation shortage.

Through 2021, San Bruno has issued building permits for 286 dwelling units over the fifth planning cycle.

The summary table below shows the City’s current housing production against the RHNA obligation of 1,155 new units for the eight-year period from 2015-2023. Leaving a remaining obligation of 868 housing units.

Table 1-2 details how many building permits were issued by each income level against the RHNA target. It is worth noting the City has entitled 521 additional housing units over the course of the planning cycle which are not reflected in the housing production table below because only issued building permits count towards the RHNA obligation.

TABLE 1-2 SAN BRUNO’S RHNA
Income Level RHNA 2015 2016 2017 2018 2019 2020 2021 Total Remaining Very Low 358 0 0 0 0 0 0 20 20 338
Low 161 1 4 14 6 42 7 23 97 64
Moderate 205 1 41 0 0 5 0 21 68 135
Above Moderate 431 9 42 1 0 2 28 18 100 331
Total Units 1,155 11 87 15 6 49 35 82 286 868
Source: Association of Bay Area Governments
Although San Bruno did not satisfy its RHNA obligation, the City entitled 521 new residential units during the fifth planning cycle. These projects are listed below and are currently pending building permit issuance.  111 San Bruno Avenue – 62 for-sale dwelling units in a mixed-use project. Since project entitlement, the applicant has submitted a revised project for 46 dwelling units in a mixed-use building. The City is currently reviewing the application.
 500 Sylvan Avenue – Nine multi-family rental units. This project was approved in May 2019. The project was first extended in 2020 and then qualified for an automatic entitlement extension pursuant to Assembly Bill (AB) 1561. Building permits for the project are ready for issuance.  Mills Park Center (601-611 and 643-799 El Camino Real; 701-751 Camino Plaza; 711-777 Kains Avenue) – 427 multi-family residential units in a mixed-use building. The project with a ground floor commercial space was approved in August 2020. The project includes a total of 64 on-site affordable units, including 26 very-low-income units, 19 low-income units and 19 moderate units. Building permits have yet to be submitted.
 271 El Camino Real – 23 multi-family for-sale condominium units. The project was approved in September 2021 and is pending building permit submittal. The project will provide three affordable units on-site and pay a partial in-lieu affordable housing fee. 711 of 1863
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The Sites Inventory and Analysis in Chapter 6 provides a more detailed discussion of the housing production accomplished during the last Housing Element cycle.

2. REMOVING CONSTRAINTS
During the last Housing Element cycle, San Bruno made important progress in removing governmental constraints to the production of housing. Examples include:
 Amended the Zoning Ordinance to permit housing in areas of the city that were once reserved for commercial uses.
 Amended the Zoning Ordinance to classify transitional and supportive housing as residential care facilities, which are allowed by right in residential zones, in accordance with Senate Bill (SB) 2.  Amended the Zoning Ordinance to implement state density bonus regulations.  Amended the Zoning Ordinance to implement state accessory dwelling unit regulations.  Adopted the Bayhill Specific Plan (BSP) in 2021 that includes a housing overlay within a portion of the Bayhill Office Park to allow for new housing units to promote residential uses near a major employment center.
 Amended the Zoning Ordinance to adopt affordable housing impact fees in 2016.

A program-by-program account of accomplishments of the last Housing Element, as well as recommendations for keeping, modifying, or removing programs based on staff’s experience with implementation over the last eight years is included in Chapter 3 Governmental and Nongovernmental Constraints and in Appendix A. The evaluation was used as the basis for the housing programs contained in this Element.

F. RELATIONSHIP TO OTHER GENERAL PLAN ELEMENTS AND

RELATED PLANS AND PROGRAMS

1. GENERAL PLAN 2025
The San Bruno 2025 General Plan was adopted on March 24, 2009. This updated Housing Element for 2023- 2031 is fully consistent with the other elements in the San Bruno 2025 General Plan, and in fact is designed as an integral step in the implementation of General Plan goals and policies.

For instance, Chapter 3: Governmental and Nongovernmental Constraints describes the General Plan Land Use Designations, provides maps of both the General Plan land uses and existing zoning, and explains how the designations work hand-in-hand with Housing Element programs. Several General Plan policies are consistent with and support the goals of the Housing Element. Some examples include General Plan Policy LUD-F: Promote infill and revitalization of the City’s shopping centers—including the continued improvement of The Shops at Tanforan and Towne Center—to attract shoppers from throughout the region using convenient BART and Caltrain access. Another example is General Plan Policy LUD-I: Promote development of single-family housing on former school sites owned by public school districts. Retain existing recreation facilities for public use, whenever possible. As these examples highlight, this Housing Element is carefully tuned to the policy priorities of the General Plan, and whenever possible the programs provided herein refer to the General Plan and other important guidance documents such as the Residential Design Guidelines and the Transit Corridors Plan, when describing implementation. The City will continue to review and revise the Housing Element as necessary to maintain General Plan consistency. Concurrently with the 712 of 1863
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Housing Element update, the City is amending the Health and Safety Element of the General Plan to resolve an inconsistency between the policy and the planning for housing within the 70-75 dB noise contour from the San Francisco International Airport. The City is also working on an environmental justice element, consistent with Government Code Section 65302(h).

2. RELATED PLANS AND PROGRAMS

TRANSIT CORRIDORS SPECIFIC PLAN (TCP)
The San Bruno Transit Corridors Plan (TCP) was adopted on February 12, 2013, following extensive public engagement, including the work of a 17-member Steering Committee and several community workshops. The TCP builds on the General Plan vision for mixed-use transit-oriented development in proximity to the new San Bruno Caltrain station and a revitalized downtown. The TCP seeks to promote economic development and private investment while implementing measures to transition new projects into the existing City. The majority of new residential development in San Bruno will likely occur in the TCP area during the housing element cycle, with plans for up to 1,610 new units.

The approximately 155-acre TCP area includes San Bruno’s principal streets of El Camino Real, San Bruno Avenue, Huntington Avenue, and San Mateo Avenue within about ½-mile of the new San Bruno Avenue Caltrain station. The TCP vision and development framework were crafted during two community workshops. The TCP development standards and design guidelines were refined in response to public comments about the impacts of new projects on existing low-density residential uses. To minimize these potential impacts, “Mixed-use to Residential Transition Measures” were included in the adopted plan.

BAYHILL SPECIFIC PLAN
The Bayhill Specific Plan, adopted on September 28, 2021, is a regulatory long-range planning document that outlines a cohesive, long-term plan for the Bayhill Office Park, which is home to the largest cluster of offices in San Bruno, including Walmart.com, the Police Credit Union, the headquarters of YouTube, and other commercial uses. The City anticipates that adoption of the Specific Plan will result in further intensification of land uses beyond what currently exists today. The Specific Plan allows for the following land uses:
commercial/retail, office, residential, hotel, civic, and open space.

URBAN WATER MANAGEMENT PLAN
San Bruno updated its Urban Water Management Plan (UWMP) in 2021 in accordance with the requirements of the California Urban Water Management Act. San Bruno receives water from three supply sources:
wholesale surface water from the San Francisco Public Utilities Commission (SFPUC), retail surface water purchased from the North Coast County Water District, and local groundwater from the South Westside Groundwater Basin. San Bruno owns and operates a water utility that supplies approximately 50% of water needs annually to the homes and businesses in San Bruno. The primary infrastructure constraint for new housing in San Bruno is related to the availability of water.

The UWMP estimated future water demand using population and employment projections from the General Plan including growth attributable to the Transit Corridors Plan. The UWMP quantifies projected water demands to the year 2035, and the existing and planned sources of water available to the City to meet those demands. San Bruno has a contracted water allotment with the SFPUC but has the ability to purchase additional required supply as a result of other customers not using their full contractual supply. In recent years, San Bruno has purchased less than the contractually allowed amount of water from SFPUC, largely due 713 of 1863
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to successful water conservation efforts and the implementation of the City’s recycled water project. Based on SFPUC and City projections of future potable water demands, San Bruno is not expected to exceed its available water supply by 2035.

PRIORITY DEVELOPMENT AREAS
Priority Development Areas (PDAs) are places near public transit planned for new homes, jobs and community amenities. Located in downtowns, along main streets and around rail stations, PDAs are planned to help the Bay Area reduce greenhouse gas emissions while increasing the supply of housing. All PDAs are created and planned by local governments, which nominate eligible areas to ABAG for adoption.

PDAs promote greater equity for all by increasing access to housing, economic and cultural opportunities, regardless of race or income. With a variety of mobility options, PDAs enable residents to live a car-free or car-light lifestyle. PDAs are located in places served by existing infrastructure, making the most of public investments and minimizing development impacts on communities and the environment.

The City’s TCP Area is designated as a PDA under the ABAG FOCUS program. The types of development envisioned in the TCP will contribute to the regional strategy to promote development near transit stations and enhancements to existing neighborhoods.

PLAN BAY AREA2050
Plan Bay Area 2050 is a long-range regional plan that was adopted in 2021 by the Metropolitan Transportation Commission and the Association of Bay Area Governments (ABAG). The plan charts the course for the future of the nine-county San Francisco Bay Area, focusing on four key elements — housing, the economy, transportation, and the environment — and identifies a path to make the Bay Area more equitable for all residents and more resilient in the face of unexpected challenges. The plan builds on the work of ABAG’s , a regional plan which explored the challenges and opportunities the Bay Area is likely to face between 2018 and 2050. Plan Bay Area outlines strategies for growth and investment through the year 2050 through 35 strategies, which are public policies or investments that can be implemented in the Bay Area at the city, county, regional or state level over the next 30 years.

GRAND BOULEVARD INITIATIVE
The Grand Boulevard Initiative (GBI) is a coordinated effort of 19 cities (including San Bruno), San Mateo County and Santa Clara County, as well as local and regional agencies united to improve the performance, safety, and aesthetics of El Camino Real. Starting at the northern Daly City boundary (where it is named Mission Street) and ending near the Diridon Caltrain Station in central San Jose (where it is named The Alameda), the initiative brings together for the first time all of the agencies having responsibility for the condition, use, and performance of the street. The Grand Boulevard Initiative looks to transform El Camino Real from a suburban, low-density strip commercial highway to vibrant, mixed-use pedestrian-friendly boulevard and destination that links regional transportation improvements and local economic development efforts. San Bruno has been an active participant in the GBI task force and working committee and is one of four case study cities for the preliminary design of complete streets improvements along a segment of El Camino Real. San Bruno has also incorporated the GBI Guiding Principles in its General Plan. The GBI is relevant to the Housing Element because it seeks to target housing and job growth in strategic areas along the corridor.
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21ELEMENTS
21 Elements is a collaboration of San Mateo County jurisdictions to share resources and work together to update local housing elements. 21 Elements is co-sponsored and coordinated by the San Mateo County Department of Housing and City/County Association of Governments. 21 Elements provides opportunities for municipalities to share resources, successful strategies, and best practices, and has resulted in stronger local partnerships as well as higher-quality certified Housing Elements. 21 Elements has hired the planning firm of Baird & Driscoll to provide assistance to jurisdictions in preparing the Housing Element and coordination with HCD. In addition, this group is working together to complete a County-Wide Housing Nexus Study to inform future policies as they relate to the City’s housing needs and requirements.

G. DATA SOURCES
The housing and demographic data reported in this Housing Element has been collected from a variety of sources, including:
 United States Census and American Community Surveys (ACS)  Association of Bay Area Governments (ABAG)
 Metropolitan Transportation Commission (MTC)
 State of California, Departments of Finance, Employment Development, Social Services, and Developmental Services
 United States Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS)
 Specific data sources used are identified in each table or figure.  California Department of Housing and Community Development (HCD)  City of San Bruno
 County of San Mateo
H. SUMMARY OF CHANGES TO STATE HOUSING LAWS
The following items represent substantive changes to state housing law since the City’s last Housing Element was adopted and certified in 2015. The development of the 2023–2031 Housing Element included an analysis of changes to state housing laws which were incorporated into the process and applied throughout the following chapters.

Affordable Housing Streamlined Approval Process: SB 35 (2017), AB 168 (2020), and AB 831 (2020) – SB 35 created a streamlined, ministerial review process for qualifying multifamily, urban infill projects in jurisdictions that have failed to approve housing projects sufficient to meet their state‐mandated RHNA.

Among other requirements, to qualify for streamlining under SB 35, a project must incorporate specific threshold levels of affordable housing based on a jurisdiction’s inability to approve housing projects sufficient to meet their RHNA at the specified affordability levels or have failed to submit an annual progress report as required under state law. AB 168 added a requirement to provide a formal notice to each California Native American tribe that is affiliated with the area of the proposed project. The Housing Element must describe the City’s processing procedures related to SB 35.
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Additional Housing Element Sites Analysis Requirements: AB 879 (2017) and AB 1397 (2017) – These bills require additional analysis and justification of the sites included in the sites inventory of the City’s Housing Element.

The Housing Element may only count non‐vacant sites included in one previous housing element inventory and vacant sites included in two previous housing elements if the sites are subject to a program that allows affordable housing by right. Additionally, the bills require additional analysis of non‐vacant sites and additional analysis of infrastructure capacity, and place size restrictions on all sites.

Affirmatively Furthering Fair Housing: AB 686 (2017) – AB 686 requires the City to administer its housing programs and activities in a manner to AFFH and not take any action that is inconsistent with this obligation.

The Housing Element must include an assessment of fair housing practices, an examination of the relationship of available sites to areas of high opportunity, and actions to AFFH.

No‐Net‐Loss Zoning: SB 166 (2017) – SB 166 amended the No‐Net‐Loss rule to require that the land inventory and site identification programs in the Housing Element include sufficient sites to accommodate the unmet RHNA. When a site identified in the Housing Element as available to accommodate the lower‐income portion of the RHNA is actually developed for a higher income group, the City must either (1) identify and rezone, if necessary, an adequate substitute site; or (2) demonstrate that the land inventory already contains an adequate substitute site.

Safety Element to Address Adaptation and Resiliency: SB 1035 (2018) – SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the housing element.

By Right Transitional and Permanent Supportive Housing: AB 2162 (2018) and AB 101 (2019) – AB 2162 requires the City to change its zoning to provide a “by right” process and expedited review for supportive housing.

The bill prohibits the City from applying a conditional use permit or other discretionary review to the approval of 100% affordable developments that include a percentage of supportive housing units, either 25% or 12 units, whichever is greater. The change in the law applies to sites in zones where multifamily and mixed uses are permitted, including in nonresidential zones permitting multifamily use. Additionally, AB 101 requires that a Low Barrier Navigation Center development be a use by right in mixed-use zones and nonresidential zones permitting multifamily uses if it meets specified requirements.

Accessory Dwelling Units (ADU): AB 2299 (2016), SB 1069 (2016), AB 494 (2017), SB 229 (2017), AB 68 (2019), AB 881 (2019), Assembly 587 (2019), SB 13 (2019), AB 670 (2019), AB 671 (2019), AB 3182 (2020) – In recent years, multiple bills have added requirements for local governments related to ADU ordinances. The 2016 and 2017 updates to state law included changes pertaining to the allowed size of ADUs, permitting ADUs by right in at least some areas of a jurisdiction, and limits on parking requirements related to ADUs.

More recent bills reduce the time to review and approve ADU applications to 60 days, remove lot size requirements and replacement parking space requirements and require local jurisdictions to permit junior ADUs. AB 68 allows an ADU and a junior ADU to be built on a single-family lot, if certain conditions are met. The state has also removed owner-occupancy requirements for ADUs, created a tiered fee structure that charges ADUs based on their size and location, prohibits fees on units of less than 750 square feet, and permits ADUs at existing multi-family developments. AB 671 requires the Housing Element to include plans to incentivize and encourage affordable ADU rentals. AB 3182 prohibits homeowner’s associations from imposing rental restrictions on ADUs.

Density Bonus: AB 1763 (2019) and AB 2345 (2020) – AB 1763 amended California’s density bonus law to authorize significant development incentives to encourage 100% affordable housing projects, allowing developments with 100% affordable housing units to receive an 80% density bonus from the otherwise maximum allowable density on the site. If the project is within ½-mile of a major transit stop the City may not apply any density limit to the project, and it can also receive a height increase of up to three additional 716 of 1863
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stories (or 33 feet). In addition to the density bonus, qualifying projects will receive up to four regulatory concessions. Additionally, the City may not impose minimum parking requirements on projects with 100% affordable housing units that are dedicated to special needs or supportive housing. AB 2345 created additional density bonus incentives for affordable housing units provided in a housing development project.

It also requires that the annual report include information regarding density bonuses that were granted.

Housing Crisis Act of 2019: SB 330 (2019) – SB 330 enacts changes to local development policies, permitting, and processes that will be in effect through January 1, 2025. SB 330 places new criteria on the application requirements and processing times for housing developments; prevents localities from decreasing the housing capacity of any site, such as through downzoning or increasing open space requirements, if such a decrease would preclude the jurisdiction from meeting its RHNA housing targets; prohibits localities from imposing a moratorium or similar restriction or limitation on housing development; prevents localities from establishing non-objective standards; and requires that any proposed demolition of housing units be accompanied by a project that would replace or exceed the total number of units demolished. Additionally, any demolished units that were occupied by lower-income households must be replaced with new units affordable to households with those same income levels. The Housing Element must describe the City’s processing procedures related to SB 330.

Surplus Land Act Amendments: AB 1486 and AB 1255 (2019) – AB 1486 refines the Surplus Land Act to provide clarity and further enforcement to increase the supply of affordable housing. The bill requires the City to include specific information relating to surplus lands in the Housing Element and Housing Element Annual Progress Reports, and to provide a list of sites owned by the city or county that have been sold, leased, or otherwise disposed of in the prior year. AB 1255 requires the City to create a central inventory of surplus and excess public land each year. The City is required to transmit the inventory to the Department of Housing and Community Development and to provide it to the public upon request.

Housing Impact Fee Data: AB 1483 (2019) – AB 1483 requires the City to publicly share information about zoning ordinances, development standards, fees, exactions, and affordability requirements. The City is also required to update such information within 30 days of changes. This Housing Element describes governmental constraints on the production of housing, including a look at zoning requirements, development standards, fees, exactions, and affordability requirements. Changes in requirements made during the Housing Element planning period will also be reported as part of the City’s annual Housing Element Progress Report.

Standardization of Sites Inventory Analysis and Reporting: SB 6 (2019) – SB 6 requires the City to electronically submit the sites inventory to HCD starting in 2021. The bill further provides streamlined, ministerial approval processes for certain housing developments and further makes housing an allowable use on “neighborhood lots”.
“Just Cause” Eviction: AB 1482 (2019) – AB 1482 restricts rents from being increased more than 5% plus inflation annually for the next 10 years and requires landlords to demonstrate “just cause” prior to evicting tenants of at least one year. Property owners evicting tenants for renovations or condo constructions must provide relocation fee equal to one month’s rent.

Housing Discrimination: SB 329 (2019) – SB 329 prohibits discrimination against tenants paying for housing with public assistance, such as Section 8 vouchers.

Navigation Centers: AB 101 (2019) – AB 101 requires jurisdictions to approve navigation centers by-right in mixed use and nonresidential zones that allow multifamily uses. Additionally, if a locality has been designated “prohousing” by HCD—compliant with housing element requirements and enacted policies that advance the planning, approval, and construction of housing—extra points will be given on IIG, AHSC and TTC grant 717 of 1863
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program applications. Awards will be based on categories including favorable zoning, faster processing, reducing costs and financial subsidies.

Additional Density Bonus: AB 1763 (2019) – AB 1763 provides enhanced density bonus for 100% affordable developments including 80% density bonus and no density limit if within ½-mile of a major transit stop under State Density Bonus Law.

Evacuation Routes: SB 99 and AB 747 (2019) – Two recent bills, AB 747 and SB 99, require the General Plan Safety Element to be updated to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios and to include information identifying residential developments in hazard areas that do not have at least two emergency evacuation routes. The bill requires these updates to occur with this Housing Element.

Housing Crisis Act Clean-up Bill: SB 8 (2021) – SB 8 is a clean-up bill impacting several previous housing initiatives. Notably, it extends key provisions of SB 330, also known as the Housing Crisis Act of 2019 (previously set to expire in 2025), until January 1, 2030. The bill further states that affordable and market rate residential projects with two or more units; mixed-use projects of which two-thirds of the square footage is residential; emergency shelters; and transitional or supportive housing may qualify for review pursuant to the Housing Accountability Act.

SB 8 further amends the Government Code to state that with respect to land where housing is an allowable use, an affected jurisdiction, as defined by HCD, cannot change the general plan land use designation, specific plan land use designation, or zoning of a parcel or parcels of property to a less intensive use or reducing the intensity of land use within an existing general plan land use designation, specific plan land use designation, or zoning district in effect at the time of the proposed change. “Reducing the intensity of land use” includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or any other action that would individually or cumulatively reduce the site’s residential development capacity.

Additionally, SB 8 provides that a city or county may not approve a housing development project that will require the demolition of occupied or vacant protected rental units unless all requirements are met. These requirements include that the project will replace all existing or demolished protected units and that the housing development project will include at least as many residential dwelling units as the greatest number of residential dwelling units that existed on the project site within the last five years.

Duplexes and Urban Lot Splits: SB 9 (2021) – This bill allows property owners to subdivide a single-family residential property into two lots, where two units can be built on each newly created lot. This would allow up to a total of four units in an existing R-1 zoned property with a ministerial review process.

CEQA Streamlining for Rezoning up to 10 Units: SB 10 (2021) – This legislation creates a voluntary process for local governments to pass ordinances prior to January 1, 2029, to zone any parcel for up to 10 residential units if located in transit rich areas and urban infill sites. Adopting a local ordinance or a resolution to amend a general plan consistent with such an ordinance would be exempt from review under the California Environmental Quality Act (CEQA). This provides cities an increased ability to upzone property for housing without the processing delays and litigation risks associated with CEQA. However, if the new housing authorized by the general plan would require a discretionary approval to actually build the housing (for example, a subdivision map or design review), CEQA review would be required for those subsequent approvals.
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Housing Element Regional Housing Need Relative Progress Determination: AB 215 (2021) – This bill would require a local government to make the first draft revision of a housing element available for public comment for at least 30 days and, if any comments are received, take at least 10 additional business days to consider and incorporate public comments into the draft revision before submitting it to HCD for review. Furthermore, a jurisdiction is required to post any subsequent draft revision on its internet website and to email a link to the draft revision to individuals and organizations that have requested notices relating to the local government's housing element, as specified. This bill also expands the attorney general's authority to independently seek action and grants HCD the ability to hire or appoint other counsel if the attorney general does not pursue action against a local agency that has violated certain housing laws, inclusive of the HCA, AFFH policies (AB 686), SB 35 Streamlining, Permanent Supportive Housing streamlining (AB 2162) and Low Barrier Navigation Center streamlining (AB 101). As such, this law strengthens the enforcement tools that may be used against noncompliant jurisdictions. As a result of this bill, HCD established the Housing Accountability Unit and the Attorney General established the Housing “Strike Force” to actively monitor compliance with state housing laws.
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2 HOUSING NEEDS ASSESSMENT
The 2023-2031 Housing Element provides a roadmap for how to meet San Bruno’s growth and housing challenges. The Housing Needs Assessment identifies what the existing housing conditions and community needs are. This chapter provides demographic and housing market information to evaluate existing and future housing needs. The COVID-19 Pandemic has resulted in unprecedented changes in many data series, making analysis and predictions for the economy and housing markets more challenging. The main purpose of this assessment is to provide a basic profile of existing conditions and historical trends in San Bruno as a starting point for identifying housing needs. It will also identify population groups with the greatest housing needs and to provide direction and focus for future housing initiatives.

A. POPULATION GROWTH
The Bay Area is the fifth-largest metropolitan area in the nation and has seen a steady increase in population since 1990, except for a dip during the 2007-2009 Great Recession and the recent unprecedented impacts of the COVID-19 Pandemic. Many cities in the region have experienced a strong economy drawing new residents and significant growth in jobs and population. While these trends have led to a corresponding increase in demand for housing across the region, the regional housing production has not kept pace with job and population growth.

In 2020, the population of San Bruno was estimated to be 45,454 and made-up 6% of the population in San Mateo County. While the population of San Bruno, San Mateo County and the Bay Area has steadily increased over the last two decades, the rate of growth has been cyclical and most recently slowing (Figure 2--1), with a slight decline during the COVID-19 pandemic. The graph below and the table that follows, show population trends in San Bruno in comparison to the rate of population growth in San Mateo County and the Bay Area.
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Figure 2-1 Population Growth Trends
Source: California Department of Finance, E-5 series.

TABLE 2-1 POPULATION GROWTH TRENDS
Number Percent Change
San Bruno
San Mateo
County Bay Area San Bruno
San Mateo
County Bay Area
1990 38,961 649,623 6,020,147
2000 40,165 707,163 6,784,348 3% 9% 13%
2010 41,114 718,451 7,150,739 2% 2% 5%
2020 45,454 773,244 7,790,537 11% 8% 9%
Source: California Department of Finance, E-5 series.1
In the last two decades, the fastest rate of population growth across the region occurred from 2010 to 2016 in the aftermath of the 2007-2009 Great Recession. Following the recession from 2011 through 2019, the economy recovered strongly, in part due to the rapid growth of the Silicon Valley technology sector. In addition to the strong job growth, lower housing prices following the 2007 housing crash fueled new inmigration. After 2016, population growth began to gradually slow throughout the region. Both San Mateo County and San Bruno saw a population decline between 2018 and 2019. Despite strong economic conditions, population growth has slowed significantly since the mid-2010s, as rising housing costs have resulted in increased numbers of domestic residents relocating to more affordable housing markets. 1 To compare the rate of growth across various geographic scales, Figure 2-1 shows population for the jurisdiction, county, and region indexed to the population in the year 1990. This means that the data points represent the population growth (i.e., percent change) in each of these geographies relative to their populations in 1990. 721 of 1863
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Because of the COVID-19 Pandemic, the region has experienced significant net out-migration to more affordable areas, spurred by an increase in remote working arrangements.2 According to the California Department of Transportation, approximately 4,000 net migrants left the San Mateo County in 2020 and an average of 2,800 will leave between 2021 and 2026.3 In the “San Francisco-San Mateo-Redwood City, California Comprehensive Housing Market Analysis as of December 1, 2020”, the U.S. Department of Housing and Urban Development (HUD), estimates population growth is expected to continue during the 3--year forecast period (2021-2023), but at a significantly slower rate given weak economic conditions and continued net out-migration due to continued high housing costs.

B. AGE
The distribution of age groups in a city shapes what types of housing the community may need in the future.

An increase in the older population may mean there is a developing need for more senior housing options, while higher numbers of children and young families can point to the need for more family housing options and related services. There has also been a move by many to age-in-place or downsize to stay within their communities, which can mean more multi-family and accessible units are also needed.

San Bruno, like other cities in San Mateo County, can expect to see a dramatic increase in the number of seniors as the baby boomer generation ages. In 2019, San Bruno’s senior population 65 and older made-up 15% of the population. From 2000 to 2019, the 85-and-over population increased by 36% and the 65 to 74 population increased by 66% (Table 2-2). A key challenge in the coming years will be how to accommodate the housing needs of aging residents. In 2019, San Bruno’s youth population under the age of 18 made up 19% of the city and from 2000 to 2019, the population of those under 24 has decreased by 6-12% depending on the age group (Table 2-2). As a result of these demographic shifts, the median age in San Bruno increased from 36.2 in 2000 to 39 in 2019.

TABLE 2-2 SAN BRUNO POPULATION BY AGE
Age Group
2000
% of Total
2010
% of Total
2019
% of Total
% Increase
2000–2019
Age 0-4 6% 6% 5% -10%
Age 5-14 13% 11% 11% -12%
Age 15-24 12% 12% 11% -6%
Age 25-34 16% 15% 17% 11%
Age 35-44 18% 14% 15% -13%
Age 45-54 15% 16% 15% 8%
Age 55-64 9% 13% 12% 57%
Age 65-74 6% 7% 9% 66%
Age 75-84 4% 4% 4% 8%
Age 85+ 1% 2% 2% 36%
Totals 100% (40,165) 100% (41,114) 100% (43,083)
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002. 2 Comprehensive Housing Market Analysis for San Francisco-San Mateo-Redwood City, California (huduser.gov). 3 California Department of Transportation: San Mateo County Economic Forecast. 722 of 1863
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C. RACE AND ETHNICITY
Understanding the racial makeup of a city and region is important for designing and implementing effective housing policies and programs. These patterns are shaped by both market factors and government actions, such as exclusionary zoning, discriminatory lending practices and displacement that has occurred over time and continues to impact communities of color today.

According to the American Community Survey, approximately 33% of San Bruno residents are White, declining from about half of residents in the last two decades. The percentage of Asian San Bruno residents has grown from 22% to 34% in the same period. The Hispanic or Latino population has remained more stable, growing from 25% to 27% in the same period (Figure 2-2).

Figure 2-2 San Bruno Population by Race, 2000-2019
Source: U.S. Census Bureau, Census 2000, Table P004; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002.

The overall racial and ethnic composition of San Bruno, San Mateo County and the Bay Area are similar with small differences between them (Table 2-3). San Bruno has a slightly larger proportion of Asian and Hispanic residents as well as a smaller proportion of White and Black residents than the county and region.

TABLE 2-3 REGIONAL COMPARISON – POPULATION BY RACE
American
Indian or
Alaska Native,
Non-Hispanic
Asian/API,
Non-Hispanic
Black or
African
American,
Non-Hispanic
White,
NonHispanic
Other Race
or Multiple
Races,
Non-Hispanic
Hispanic
or Latino
Total
Population
San Bruno <1% 34% 1% 33% 6% 27% 43,083
San Mateo County <1% 30% 2% 39% 4% 24% 767,423
Bay Area <1% 27% 6% 39% 5% 24% 7,710,026
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002. 723 of 1863
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Looking at the senior and youth population by race can add an additional layer of understanding, as families and seniors of color are even more likely to experience challenges finding affordable housing. In San Bruno, people of color (non-white racial groups) make up 38% of seniors and 60% of youth under 18 (Figure 2-3).

Figure 2-3 San Bruno Senior and Youth Population by Race Universe: Total population.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-G).

KEY POINTS: POPULATION GROWTH AND DEMOGRAPHICS
 While population growth has significantly increased throughout the Bay Area, San Mateo County, and San Bruno over the last two decades, the rate of growth has been cyclical and began to slow down in 2016.
 Despite strong economic conditions, population growth has begun to slow partly due to rising housing costs as residents relocate to more affordable housing markets. The COVID-19 Pandemic has contributed to slower population growth in recent years.  In San Bruno, from 2000 to 2019, the population of those under 14 has decreased by 11%, while the 65- and-over population has increased by 36%. These trends are mirrored in the region. A key challenge in the coming years will be how to accommodate the needs of aging residents.  From 2000 to 2019, the fastest growing race/ethnic group in San Bruno was Asian. San Bruno also has a large Hispanic population which has remained stable over the same period. The White population has steadily decreased from half in 2000 to 33% in 2019.
 In San Bruno, people of color (non-white racial groups) make up 38% of seniors and 60% of youth under 18.
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D. INCOME CHARACTERISTICS
The U.S. Department of Housing and Urban Development (HUD) and the California Department of Housing and Community Development (HCD) use household income categories to help standardize analysis of housing needs. HCD divides the Regional Housing Needs Determination (RHND) into the four income categories identified in Table 2-4.

TABLE 2-4 INCOME CATEGORY DEFINITIONS
Extremely Low-Income 0% - 30% of area median income
Very Low-Income 30% - 50% of area median income
Low-Income 50% - 80% of area median income
Moderate-Income 80% -120% of area median income
Above Moderate-Income >120% of area median income
The income categories are summarized below and are based on a household’s percentage of San Mateo County’s Area Median Income (AMI). HCD uses these categories to establish the annual income limits for San Mateo County, as shown in the Table 2-5.4
TABLE 2-5 SAN MATEO COUNTY INCOME LIMITS (2022)
Income Category
Number of Persons Per Household
(Maximum Income)
1 2 3 4 5
Extremely Low $39,150 $44,750 $50,350 $55,900 $60,400
Very Low $65,250 $74,600 $83,900 $93,200 $100,700
Low-Income $104,400 $119,300 $134,200 $149,100 $161,050 Median-Income $116,200 $132,800 $149,400 $166,000 $179,300 Moderate-Income $139,450 $159,350 $179,300 $199,200 $215,150 Source: HCD State Income Limits 2022 and State CDBG and HOME Income Limits.

The graph below shows the distribution of households by income in San Bruno, San Mateo County and the Bay Area.5 Almost half San Bruno’s households are lower income (45%): approximately 14% are extremely low-income, 11% are very low-income, and 20% are low-income. In San Bruno, 42% of households earn more than 100% of the AMI, compared to 14% making less than 30% of AMI, which is considered extremely low-income (Figure 2-4). These residents are particularly at risk for overpaying for housing.

Similar trends occur regionally, for example, in San Mateo County and the Bay Area, approximately half of all households make more than 100% AMI, while 13%-15% make less than 30% AMI. In San Mateo County, 30% AMI is the equivalent to the annual income of $54,800 for a family of four. Many households with multiple wage earners – including food service workers, full-time students, teachers, farmworkers, and healthcare professionals – can fall into lower AMI categories due to relatively stagnant wages in many 4 According to the U.S. Census Bureau, Population Estimates Program, the overall median household income in San Bruno is $113,100, lower than the countywide median of $128,090 (2020 estimates). Estimate is based on Income in the Past 12 Months and based on data collected in the American Community Survey (ACS). 5 Income groups are based on HUD calculations for Area Median Income (AMI). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. Households making between 80 and 120 percent of the AMI are moderate-income, those making 50 to 80 percent are low-income, those making 30 to 50 percent are very low-income, and those making less than 30 percent are extremely low-income. This is then adjusted for household size. 725 of 1863
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industries. Despite the economic and job growth experienced throughout the region since 1990, the income gap has continued to widen. California is one of the most economically unequal states in the nation.6 Figure 2-4 Households by Household Income Level
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Currently, people of color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to white residents.7 These economic disparities also leave communities of color at higher risk for housing insecurity, displacement or homelessness. In San Bruno, American Indian or Alaska Native (Hispanic and Non-Hispanic) residents experience the highest rates of poverty, followed by Black or African American (Hispanic and Non-Hispanic) residents (Figure 2-5).

Figure 2-5 Poverty Status by Race
Universe: Population for whom poverty status is determined Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17001(A-I). 6 Bohn, S.et al. 2020. Income Inequality and Economic Opportunity in California. Public Policy Institute of California. 7 Moore, E., Montojo, N. and Mauri, N., 2019. Roots, Race & Place: A History of Racially Exclusionary Housing the San Francisco Bay Area. Hass Institute.
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E. HOUSING TENURE
The number of residents who own their homes compared to those who rent their homes can help identify the level of housing insecurity – ability for individuals to stay in their homes – in a city and region. Generally, renters may be displaced more quickly if prices increase. In San Bruno there are a total of 15,063 housing units, and fewer residents rent than own their homes: 41% versus 59% (Figure 2-6). This trend is similar in the overall region where 40% of San Mateo County households and 45% of Bay Area households rent their homes.

Figure 2-6 Housing Tenure
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003.

Table 2-6 compares the City of San Bruno distribution of owner and renter housing in 2000 and 2011 and 2019 with San Mateo County and the Bay Area. The proportion of homeowners to renters in San Bruno, San Mateo County and the Bay Area has remained relatively stable over the last two decades.

TABLE 2-6 TENURE OF HOUSING (2000, 2011 AND 2019)
City of San Bruno San Mateo County Bay Area
2000
Percent Owners 63% 61% 58%
Percent Renters 37% 39% 42%
2011
Percent Owners 58% 59% 56%
Percent Renters 42% 41% 43%
2019
Percent Owners 59% 60% 56%
Percent Renters 41% 40% 44%
Source: 2010 US Census SF1, 2009-2011 American Community Survey.

Homeownership rates often vary considerably across race/ethnicity in the Bay Area and throughout the country. These disparities not only reflect differences in income and wealth but also stem from federal, state, and local policies that limited access to homeownership for communities of color while facilitating homebuying for white residents. While many of these policies, such as redlining, have been formally 727 of 1863
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disbanded, the impacts of race-based policy are still evident across Bay Area communities.8 In San Bruno, 35% of Black households owned their homes, while homeownership rates were 60% for Asian households, 64% for White households and 52% for Latino households (Figure 2-7).

Figure 2-7 Housing Tenure by Race of Householder
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003(A-I).

F. TENURE BY INCOME AND POVERTY
Throughout the region, there are disparities between the incomes of homeowners and renters. Typically, the number of low-income renters greatly outpaces the amount of housing available that is affordable for these households. Because of the high cost of housing for both renters and homeowners in the Bay Area, San Mateo County, and San Bruno, most renters and homeowners earn above 100% AMI to afford housing at all ($149,600 for a family of four) (Figure 2-8). Specifically, 49% of owner-occupied housing units and 33% of renter occupied housing units in San Bruno are occupied by households that earn more than 100% of AMI.

In San Bruno, low-income households that are below 80% AMI are just as likely to include renters as well as homeowners. However, lower income renters are more likely to be impacted when rents increase due to their income and the limited availability of choices in the rental housing market. There are 2,023 extremely lowincome households in San Bruno. Of these, 893 are owner-occupied and 1,130 renter-occupied extremely low-income households. Fifty-six percent of extremely low-income households are renter-occupied and 44% are owner-occupied. Local jurisdictions are required to provide an estimate for their projected extremely lowincome households. San Bruno projects that the city’s extremely low-income households will be 50% of its very low-income RHNA or 352 housing units over the next housing element cycle. 8 See, for example, Rothstein, R. (2017). The color of law: a forgotten history of how our government segregated America. New York, NY & London, UK: Liveright Publishing.
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Figure 2-8 Household Income Level by Tenure
Universe: Occupied housing units
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

The age of residents who rent or own their home can also signal the housing challenges a community is experiencing. Younger households tend to rent and may struggle to buy a first home in the Bay Area due to high housing costs. At the same time, senior homeowners seeking to downsize may have limited options in an expensive housing market. In San Bruno, 62% of householders between the ages of 25 and 44 are renters, while only 17% of householders 65-74 are renters (see Figure 2-9).

Figure 2-9 Housing Tenure by Age
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25007. 729 of 1863
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In many cities, homeownership rates for households in single-family homes are substantially higher than the rates for households in multi-family housing. In San Bruno, 83% of households in detached single-family homes are homeowners, while 19% of households in multi-family housing are homeowners (Figure 2-10).

Figure 2-10 Housing Tenure by Housing Type
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25032.

KEY POINTS: INCOME, TENURE AND POVERTY
 Almost half San Bruno’s households are lower income (45%).  In San Bruno, 42 percent of households earn more than 100 percent AMI and 14 percent make less than 30 percent of AMI, which is considered extremely low-income. Similar trends occur regionally.  Many households fall into lower AMI categories due to relatively stagnant wages in many industries.

Despite the economic and job growth experienced throughout the region since 1990, the income gap has continued to widen.
 In San Bruno, American Indian or Alaska Native (Hispanic and Non-Hispanic) residents experience the highest rates of poverty, followed by Black or African American (Hispanic and Non-Hispanic) residents.  In San Bruno fewer residents rent than own their homes: 41 percent versus 59 percent. This trend is similar in the overall region and has remained stable over the last two decades.  In San Bruno, 35 percent of Black households, 60 percent of Asian households, 64 percent of White households and 52 percent for Latinx households owned their homes. These disparities reflect differences in income and wealth stemming from federal, state, and local policies that limited access to homeownership for communities of color while facilitating homebuying for white residents. While many of these policies, such as redlining, have been formally disbanded, the impacts of race-based policy are still evident across Bay Area communities.
 Low-income households that are below 80 percent AMI are just as likely to include renters as well as homeowners, but lower income renters are more likely to be impacted when rents increase due to their income and the limited availability of choices in the rental housing market.  In San Bruno, 83 percent of households in detached single-family homes are homeowners, while 19 percent of households in multi-family housing are homeowners. 730 of 1863
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G. HOUSING

1. HOUSING UNITS
According to California Department of Finance (DOF) estimates, San Bruno had a total of 16,159 housing units as of 2019, which is a 5% increase since 2010 (Table 2-7).

TABLE 2-7 TOTAL HOUSING UNITS (2000, 2010, AND 2019)
City of San Bruno San Mateo County Bay Area
Number % Change Number % Change Number % Change
2000 14,980 260,576 2,552,402
2010 15,356 2.5% 271,031 4.0% 2,785,948 9.2%
2019 16,159 5.2% 277,773 2.5% 2,904,094 4.2%
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25002 and California Department of Finance, E-5 series.

Production has not kept up with housing demand for several decades in the Bay Area, as the total number of units built and available has not yet come close to meeting the population and job growth experienced throughout the region. In San Bruno, the largest proportion of the housing stock was built 1940 to 1959, with 6,203 units constructed during this period (Figure 2-11). Since 2010, 2.4% of the current housing stock was built, a total of 379 units.

Figure 2-11 Housing Units by Year Structure Built
Universe: Housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25034.

The chart below shows the distribution of housing units by residential building type in San Bruno in 2010 and 2020 (Figure 2-12). The housing stock of San Bruno in 2020 was primarily made up of single-family detached buildings (56%). Another 35% of the housing stock are multi-unit buildings of five units or more. The remaining housing stock include 6% multi-family homes with 2 to 4 units, and 4% single-family attached 731 of 1863
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homes such as townhouses and condos. In San Bruno, the housing type that experienced the most growth between 2010 and 2020 was multi-unit buildings of five units or more.

Figure 2-12 Housing Type Trends
Universe: Housing units
Source: California Department of Finance, E-5 series.

2. HOUSING OCCUPANCY
The demand for both rental and ownership housing in San Bruno, San Mateo County and the Bay Area is strong. According to American Community Survey (2015-2019), the vacancy rate in San Bruno for owneroccupied homes was just about 1%, and the vacancy rate for rentals was 3.9%. Vacant units make up 3.7% of the overall housing stock in San Bruno (Table 2-8).9
TABLE 2-8 OVERALL OCCUPANCY STATUS AND VACANCY RATES
Occupied
Housing Units
Vacant
Housing Units
Total
Housing Units Vacancy Rate
San Bruno 15,063 571 15,634 3.7%
San Mateo County 263,543 14,230 277,773 5.1%
Bay Area 2,731,434 172,660 2,904,094 5.5%
Universe: Housing Units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25002.

A housing market with a vacancy rate under 5% is considered to be tight and contributes to concerns about overcrowding, housing availability and choice, and housing affordability. The recent increases in rents and construction of new rental housing in San Mateo County are indicative of the high demand for rental housing relative to the supply of available rental units. In the Bay Area, the vacancy rate excluding units used for 9 The vacancy rates by tenure are for a smaller universe than the total vacancy rate reported in Table 2-8 which includes the full stock (4%). The vacancy by tenure counts are rates relative to the rental stock (occupied and vacant) and ownership stock (occupied and vacant) – but exclude a significant number of vacancy categories, including the numerically significant other vacant. 732 of 1863
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recreational or occasional use, and units classified and other vacant, is actually 2.6% of the total housing units that are listed for rent.10 In a region with a thriving economy and housing market like the Bay Area, units being renovated/repaired and prepared for rental or sale are likely to represent a large portion of the “other vacant” category. Additionally, the need for seismic retrofitting in older housing stock could also influence the proportion of “other vacant” units in some jurisdictions.11 Figure 2-13 shows a large proportion of vacant units in the region are categorized as “other vacant”, with 34% in San Bruno, 28% in San Mateo County and 36% in the Bay Area.

Out of the 571 vacant units in San Bruno, almost half or 251 units (44%) are “for rent” and only 6.5% or 37 are “for sale.” In the Bay Area and the county, there is a much larger proportion of vacant units that are listed as “Seasonal, Recreational or Occasional Use” (22% and 23% compared to only 7% in San Bruno). The region also has far fewer vacant units listed for rent than San Bruno, with only 24% in the Bay Area and 31% in San Mateo County listed for rent compared to 44% in San Bruno (Figure 2-13).

Figure 2-13 Vacant Units by Type
Universe: Vacant housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25004.

Most of the occupied households in San Bruno are married-couple family households (53%), followed by single-person households (25%) (male or female), female-headed family household (10%) and male-headed family household (5%) (Figure 2-14). Households headed by one person are often at greater risk of housing insecurity, particularly female-headed households, who may be supporting children or a family with only one income. Of all family households in San Bruno (married, female-headed and male-headed households) 46% are households with children (Table 2-9).
10 The Census Bureau classifies vacant units as “for recreational or occasional use” are those that are held for short-term periods of use throughout the year such as vacation rentals and short-term rentals like AirBnB. The Census Bureau classifies units as “other vacant” if they are vacant due to foreclosure, personal/family reasons, legal proceedings, repairs/renovations, abandonment, etc. For more information, see definitions prepared by the Census Bureau: https://www.census.gov/housing/hvs/definitions.pdf. 11 See Dow, P., 2018. Unpacking the Growth in San Francisco’s Vacant Housing Stock: Client Report for the San Francisco Planning Department. University of California, Berkeley.
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Figure 2-14 Household Type
Universe: Households
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B11001.

TABLE 2-9 FAMILY HOUSEHOLDS WITH CHILDREN
Family Households with
1 or More Children Under 18
Total Family
Households
Total Households
(Includes Single & Other)
San Bruno 4,668 (46%) 10,183 15,063
San Mateo County 86,818 (47%) 184,744 263,543
Bay Area 873,704 (48%) 1,813,672 2,731,434
KEY POINTS: HOUSING UNITS AND OCCUPANCY
 San Bruno had a total of 16,159 housing units as of 2019, which is a 5% increase since 2010. Production has not kept up with housing demand for several decades in the Bay Area, as the total number of units built and available has not yet come close to meeting the population and job growth experienced throughout the region.
 In San Bruno, the housing type that experienced the most growth between 2010 and 2020 was Multifamily Housing: Five-plus Units.
 The housing stock of San Bruno in 2020 was primarily made up of single-family detached buildings (56%) and multi-unit buildings of 5 units or more (35%).  Despite the dominance of single family and multi-unit buildings of 5 units or more, policymakers are interested in “missing middle housing” – including duplexes, triplexes, townhomes, cottage clusters and accessory dwelling units (ADUs). These housing types may open more options across incomes and tenure, from young households seeking homeownership options to seniors looking to downsize and agein-place.  Out of the 571 vacant units in San Bruno in 2019, almost half or 251 units (44%) are “for rent” and only

6.5 percent or 37 are “for sale.”
 In the Bay Area and the county 22 percent and 23 percent of vacant units are listed as “Seasonal, Recreational or Occasional Use” compared to only 7% in San Bruno. The county and region have fewer vacant units listed as “for rent” rent than San Bruno, with only 24% in the Bay Area and 31% in San Mateo County and 44% in San Bruno.
 Households headed by one person are often at greater risk of housing insecurity, particularly femaleheaded households who may be supporting children or a family with only one income. Ten percent of households in San Bruno are female-headed family households. 734 of 1863
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H. EMPLOYMENT AND UNEMPLOYMENT
San Bruno is largely a residential city, with approximately 16,500 jobs located in the city, or approximately one job for every three residents. Thirty-seven percent of jobs in San Bruno pay more than $75,000 a year or more and 63% of jobs pay less than $75,000 annually.12 Between 2006 and 2009, the number of jobs located in San Bruno dipped below 12,000 jobs from a peak of 16,000 in 2002 (Figure 2-15). Since 2010, the number of jobs located in San Bruno has continued to increase as San Bruno recuperated the job losses of the previous decades’ economic recession. Between 2010 and 2018, the economic recovery due in part to rapid growth in the technology industry, resulted in an additional 4,440 jobs in San Bruno or (37% increase). San Bruno’s fastest growing industries during this time-period are Professional & Managerial Services and Information Services and one of the slowest was Retail, with 0% growth between 2010 and 2018. Job growth has been strong, although cyclical, over the past 10 years, with a slight dip leading into the pandemic but is projected to continue its upward trajectory.

Figure 2-15 Jobs in a Jurisdiction
Universe: Jobs from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files, 2002-2018.

San Bruno’s unemployment rate is similar to the unemployment rate for the region and the state. The unemployment rate reached its nadir in April 2020 at the beginning of the COVID-19 Pandemic and climbed steadily since. The unemployment rate in the San Bruno area has largely improved since the height of the pandemic, in January 2022, San Bruno’s unemployment rate was 3.5%. 12 Source: U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519. 735 of 1863
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Figure 2-16 Unemployment Rate
Universe: Civilian noninstitutional population ages 16 and older.

Source: California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates, 2010-2021.

I. INDUSTRY SECTOR COMPOSITION

1. JOBS AT SAN BRUNO JOB SITES
There are 16,229 jobs located at San Bruno job sites.13 Jobs located in the City of San Bruno are primarily jobs in Professional & Managerial Services industry (28%), and Arts, Recreation and Other Services (18%), and Health & Educational Services (16%), together representing more than 60% of all jobs in San Bruno. The remaining jobs are in Retail (15%), Information Services (11%), Manufacturing and Wholesale (3%) and Transportation and Utilities (3%), Financial and Leasing (3%), Government (2%) and Construction (2%).

While Information Services makes up only 11% of all San Bruno Jobs, the industry grew by 721% between 2010 and 2018, from 215 to 1,765 jobs (an additional 1,550 new jobs). Jobs in the city’s Information Services and Professional & Managerial Services are largely related to the technology industry.14 San Bruno’s top employers include YouTube (2,565 employees), Walmart (2,000 employees), Skyline College (402 employees), Artichoke Joe’s Casino (384 employees), City of San Bruno (232 employees), San Bruno Park School District (215 employees), Target (208 employees), Lucky Supermarkets (188 employees), Lowe’s (170 employees), and Church of the Highlands (100 employees).15

2. JOBS HELD BY SAN BRUNO RESIDENTS
There are 24,082 employed residents in San Bruno who work at multiple locations across jurisdictional lines.

The composition of the industry sectors where San Bruno residents are employed mirrors the composition of 13 Employed residents in a jurisdiction is counted by place of residence (they may work elsewhere) while jobs in a jurisdiction are counted by place of work (they may live elsewhere).
14 Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files, 2002-2018. 15 City of San Bruno Annual Comprehensive Financial Reports for the Fiscal Year Ended June 30, 2021 736 of 1863
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the industry sectors regionally. Most Bay Area, San Mateo County and San Bruno residents work in Health & Educational Services (Figure 2-17) followed by Financial & Professional Services.

Figure 2-17 Resident Employment by Industry
Universe: Civilian employed population age 16 years and over.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table C240304.

J. BALANCE OF JOBS AND WORKERS
San Bruno houses approximately 24,000 employed residents (workers) who either work in San Bruno or work elsewhere in the region. San Bruno has job sites that provide jobs to 16,000 workers who are either San Bruno residents or workers who commute to San Bruno from other cities.16 A city with a surplus of employed residents (workers) “exports” workers to other parts of the region, while a city that has a surplus of jobs must conversely “import” workers to its job sites. The ratio of jobs to employed residents (or workers) is 0.67; therefore, San Bruno is a net exporter of workers. Figure 2-17 shows that in San Bruno, there are more employed residents (workers) labeled “Place of Residence” (~24,000), than jobs labeled “Place of Work” (~16,000) in every wage group indicating that San Bruno is a net exporter of workers in all wage groups. Smaller cities like San Bruno typically will have fewer jobs within the city limits and residents will commute to other areas for employment.

Surpluses of workers in a wage group relative to jobs means the community will export those workers to other jurisdictions. This dynamic can contribute to long commutes and traffic congestion.

Table 2-10 shows that 61% of San Bruno’s employed residents earn less than $75,000 annually, significantly less than the AMI. Similarly, 63% of jobs located at San Bruno job sites also pay less than $75,000. Regardless of whether a person works in San Bruno or lives in San Bruno and commutes for work, ~60% of workers cannot cover the cost of living for a family of four (two adults and two children will need to earn $150,620 a year, in 2021, to live and sustain themselves in San Mateo County).17 Such relationships may cast light on potentially pent-up demand for housing in particular price categories. When there is high demand for housing relative to supply, many workers may be unable to afford to live where they work. In San Bruno, these ratios 16 Employed residents in a jurisdiction is counted by place of residence (they may work elsewhere) while jobs in a jurisdiction are counted by place of work (they may live elsewhere).
17 Home - Self Sufficiency Standard.
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indicate there is demand for housing options at prices that are affordable to households where individual workers make less than $75,000 annually.18 These figures have implications when looking at the cost of living and income inequality in San Bruno.

TABLE 2-10 EMPLOYED RESIDENTS IN SAN BRUNO BY WAGE GROUP Earnings Group Employed Residents: Jobs at San Bruno Job Sites Less than $9,999 2,126
61%
1,745
63%
$10,000 to $24,999 3,185 2,143
$25,000 to $49,999 4,894 3,686
$50,000 to $74,999 4,554 2,636
$75,000 or more 9,323 39% 6,019 37%
Totals 24,082 16,229
Source: U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519.

Figure 2-18 compares San Bruno’s employed residents (workers) to the jobs located at San Bruno job sites over time, for different wage groups as a ratio—a value of 1 means that city job sites have the same number of jobs in a wage group as it has employed residents in that wage group. Values below indicate the jurisdiction will need to export workers for jobs in a given wage group. San Bruno has been a longtime net exporter of workers for all wage groups since 2005.

Figure 2-18 Employed Residents and Jobs in San Bruno by Wage Group Universe: Workers 16 years and over with earnings.

Source: U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519. 18 The source table is top-coded at $75,000, precluding more fine grained analysis at the higher end of the wage spectrum. 738 of 1863
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Figure 2-19 Jobs-Worker Ratios, By Wage Group
Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state, and local government) plus United States Office of Personnel Management-sourced Federal employment.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence Area Characteristics (RAC) files (Employed Residents), 2010-2018.

Jobs-household ratio compares the number of jobs in an area to the number of occupied housing units in an area and is an indication of how the number of jobs (surplus or deficit) impacts housing availability. From 2004 to 2016, the jobs-household ratio in San Bruno was below 1.0, indicating fewer jobs as a proportion of occupied housing units and that housing units were available for the number of workers in the area. Beginning in 2016, the jobs-household surpassed 1.0 indicating a surplus of jobs for the number of occupied housing units, and that adequate housing may be more unaffordable or unavailable to workers in that area. Because of the cyclical nature of the jobs market, the jobs—household ratio remained relatively stable over time from 1.09 in 2002 to 1.07 jobs per household in 2018 (Figure 2-19).19 Figure 2-20 shows the Bay Area and San Mateo County jobs-household ratios consistently above 1.2 since 2005 and increasing upwards of 1.5 in recent years.

This indicates that regionally, there has been a steady surplus of jobs for the number of occupied housing units for decades, and that adequate housing may be more unaffordable or unavailable to workers. 19 A similar measure is the ratio of jobs to housing units. However, this jobs-household ratio serves to compare the number of jobs in a jurisdiction to the number of housing units that are actually occupied. The difference between a jurisdiction's jobs-housing ratio and jobs-household ratio will be most pronounced in jurisdictions with high vacancy rates, a high rate of units used for seasonal use, or a high rate of units used as short-term rentals.
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Figure 2-20 Jobs-Household Ratio
Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment; households in a jurisdiction.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs), 2002-2018; California Department of Finance, E-5 (Households).

K. RENTS AND RENTAL HOUSING AFFORDABILITY
Similar to home values, rents have also increased across the Bay Area in the last decade. Many renters have been priced out, evicted or displaced. Residents finding themselves in one of these situations may have had to choose between commuting long distances to their jobs and schools or moving out of the region. Since 2009, KEY POINTS: WORKFORCE, EMPLOYMENT AND INDUSTRY
 Though San Mateo County has a robust economy and low unemployment rate, various cost of living indexes show that much of its workforce cannot afford to live and sustain themselves in San Mateo County.
 Regardless of whether you live in San Bruno and commute or whether you work in San Bruno, approximately 60 percent of all workers earn less than $75,000 annually.  San Bruno’s fastest growing industries are Professional & Managerial Services and Information Services largely attributed to the technology industry. One of the slowest was Retail, with zero percent growth between 2010 and 2018.
 San Bruno has been a net exporter of workers for all wage groups since 2005. Smaller cities like San Bruno typically will have fewer jobs within the city limits and hence export workers to other communities.

This dynamic contributes to long commutes and traffic congestion. Without choices and the availability of affordable housing in San Bruno, lower-income people may choose to live elsewhere and commute into the city to work.
 In San Bruno the jobs-household ratio indicates that there is demand for housing options at prices that are affordable to households where individual workers make less than $75,000 annually.  While San Bruno, San Mateo County, and the Bay area, all have jobs-household ratios exceeding 1.0 today, San Bruno’s ratio only exceeded 1.0 beginning in 2016. The region ratio has been over 1.2 for decades, indicating a longstanding surplus of jobs for the number of occupied housing units regionally and that adequate housing may be more unaffordable or unavailable. 740 of 1863
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the median rent has increased by 66% in San Bruno, from $1,580 to $2,240 per month (Figure 2-21). 20 In San Mateo County, the median rent has increased 41%, from $1,560 to $2,200. The median rent in the region has also increased significantly during this time from $1,200 to $1,850, a 54% increase.21 Figure 2-21 Median Contract Rent
Universe: Renter-occupied housing units paying cash rent.

Source: U.S. Census Bureau, American Community Survey 5-Year Data releases, starting with 2005-2009 through 2015-2019, B25058, B25056 (for unincorporated areas). County and regional counts are weighted averages of jurisdiction median using B25003 rental unit counts from the relevant year.

COVID-19-related economic contraction has led many renters to search for more affordable rental housing or, for those with the means and ability to work-from-home, to transition into homeownership in more affordable markets. The COVID-19 Pandemic and the subsequent shift to widescale remote work, has resulted in a rise in vacancy rates and a decline in rents in the region. According to a housing market analysis completed by HUD, between the third quarter of 2020 and the third quarter of 2019, the average apartment rent in San Mateo County declined by 10-percent. 22 Prior to the recent decline, year-over-year rent growth had been positive since 2009.

Figure 2-22 shows the distribution of rentals at various prices in San Bruno, San Mateo County and the Bay Area. Between 2015 – 2019 most units in San Bruno rented between $1,500 and $2,500 per month, followed by units in the >$2,500 per month price range. This trend is similar in San Mateo County and the Bay Area except that there are more units in the Bay Area priced below $1,500 than in San Mateo County and San Bruno.

More recent rental data, shown in Table 2-11, indicates rents have only continued to increase in San Bruno.

The data indicates rentals in San Bruno are only affordable to moderate-income households and above 20 Note that contract rents may differ significantly from, and often being lower than, current listing prices. 21 While the data on home values shown in Figure 2-21 comes from Zillow, Zillow does not have data on rent prices available for most Bay Area jurisdictions. To have a more comprehensive dataset on rental data for the region, the rent data in this document comes from the U.S. Census Bureau’s American Community Survey. 22 Comprehensive Housing Market Analysis for San Francisco-San Mateo-Redwood City, California:
https://www.huduser.gov/portal/publications/pdf/SanFranciscoSanMateoRedwoodCityCA-CHMA-20.pdf 741 of 1863
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moderate-income households, with the largest rental units only affordable to above moderate-income households.

TABLE 2-11 MEDIAN RENTS IN OCTOBER 2022 – SAN BRUNO
Source Studio 1 Bed 2 Beds 3 Beds 4/4+ Beds
Zumper $2,071 $2,901 $3,258 $4,462 $4,800
Zillow $2,100 $2,400 $3,250 $4,500 **$5,869
Rent. $2,195 $2,935 $3,507 $4,821 N/A
Apartments.com $2,119 $2,720 $2,816 $4,525 N/A
Average $2,121 $2,739 $3,208 $4,577 N/A
**Zillow does not display rents for 4 bedrooms, it displays rents for 4+ bedrooms.

Source: Zumper: Average Rent in San Bruno, CA and Cost Information ZumperZillow: Average Rental Price in San Bruno, CA and Market Trends | Zillow Rental Manager | Rent.: Rental Market Trends & Average Rent in San Bruno, CA | Rent. Apartment.com: Apartments for Rent in San Bruno CA | Apartments.com:

September 13, 2022.

Figure 2-22 Contract Rents for Renter-Occupied Units
Universe: Renter-occupied housing units paying cash rent.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25056.

Forty-five percent of households in San Bruno are extremely low-income, very low-income, or low-income (defined as earning less than 80% AMI) and may have difficulty competing for the limited number of rental units that are available at an affordable price. A single-person household earning 80% AMI (maximum of $102,450), can afford a monthly rent of about $2,560. A four-person household earning 80% AMI ($146,350) can afford a monthly rent of about $3,650. Average rents do not reflect the higher cost of units with additional bedrooms to accommodate larger families. Many workers in lower wage jobs such as retail, service, home healthcare, teaching, and childcare, may not be able to live in the community where they work. The 742 of 1863
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following chart from the California Housing Needs Partnership, shows that renters need to earn 3.2 times the minimum wage to afford the average asking rent in San Mateo County.23 TABLE 2-12 2022 SAN MATEO MAXIMUM AFFORDABLE RENT PAYMENTS Income Category
Maximum Affordable Rent Payment ($)
Studio 1 BR 2 BR 3 BR 4 BR
Extremely Lowa $978 $1,048 $1,258 $1,454 $1,622
Very Lowa $1,631 $1,748 $2,097 $2,423 $2,703
High HOME Limit (65%)a
HERA Special Very Low (50% AMI)b
HERA Special Limit (60% AMI)b
$2,101
$1,742
$1,091
$2,253
$1,866
$2,240
$2,704
$2,240
$2,688
$3,116
$2,588
$3,106
$3,456
$2,887
$3,465
Lowc $2,610 $2,797 $3,356 $3,878 $4,326
HUD Fair Market Rent $2,115 $2,631 $3,198 $4,111 $4,473 Medianc $3,262 $3,496 $4,194 $4,846 $5,406
a Income figures provided by HUD for following San Mateo County federal entitlement programs: CDBG, HOME, ESG. b For San Mateo County, the Housing and Economic Recovery Act of 2008 (HERA) and the HUD 2010 HOME hold-harmless provision permit multi-family tax subsidy projects (MTSPs) and HOME projects placed in service before January 1, 2009 to continue to use HOME/tax credit/tax exempt bond rents based on the highest income levels that project ever operated under.

Once these units are placed in service, the rents will not adjust downward should HUD establish lower incomes/rents in any subsequent year. Marketing of vacant units should be targeted to the current year's income schedule. However, HUD's Section 8 income limits are larger than those defined by Section 3009(a)(E)(ii) of HERA (Public Law 110-289). Therefore, for FY2018 no special income limits are necessary. c CA Tax Credit Rent Limits for Low- and Median-Income Group.

Notes (Generic): Maximum affordable rent based on 30% of monthly income and all utilities paid by landlord unless further adjusted by HUD. Utility allowances for tenant-paid utilities may be established by Housing Authority of County of San Mateo Section 8 Program.

High HOME Limit rent set at lower of: (a) 30% of 60% AMI, or (b) FMR (HUD Fair Market Rent).

Household Size Assumptions: For purposes of calculating the maximum rents, the following household assumptions are made using the definitions in California Health and Safety Code Section 50053 and Section 50052.5. Studio: 1 person, 1-Bedroom: 2 persons, 2- Bedroom: 3 persons, 3-Bedroom: 4 persons, 4-Bedroom: 5 persons.

Source: San Mateo County Department of Housing.

L. RENTERS AND THE COVID-19 PANDEMIC
The emergence of the COVID‑19 Pandemic added to the financial stress of renters who struggled to find housing that was affordable even before the pandemic began. Low‑wage workers were already in a difficult financial position before state and local public health restrictions shut down parts of the economy in the spring of 2020, leaving many without jobs. Renters and low-income residents also tend to work in industries that were most affected by public health restrictions and closures such as retail, services, and healthcare.

While the state economy has experienced a rebound since that time, pandemic‑induced job loss added further financial stress to low-income households.

According to the California Legislatures Nonpartisan Fiscal and Policy Advisory Report (January 2021) more than half of California workers who lost their jobs are members of lower‑income households (less than $50,000 in annual earnings). During the height of the pandemic, the estimated unemployment rate for workers in lower‑income households (15%) was five times higher than the estimated unemployment rate for workers in higher‑income households (3%).24 The report also highlights unprecedented actions of the state 23 California Housing Partnership Housing Needs Dashboard: https://chpc.net/housingneeds/. 24 How Has COVID‑19 Affected Renters and Homeowners? Legislative Analyst's Office of the California Legislatures Nonpartisan Fiscal and Policy Advisory Report January 2021 (https://lao.ca.gov/Publications/Report/4312). 743 of 1863
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and federal governments to boost incomes and provide rental relief that have helped many households who otherwise would have faced eviction. The CA COVID-19 Rent Relief program, which provides rent relief to California landlords and renters who have faced financial hardships due to the COVID-19, provided almost $70 million in rental assistance to San Mateo County renters and landlords and served more than 5,000 households in the county as of March 2022. Approximately 70% of households receiving CA COVID-19 rental relief in San Mateo County are considered extremely low-income earning less than 30% AMI.25 The program no longer accepted applications after March 2022.

TABLE 2-13 WHO CAN AFFORD TO RENT IN SAN MATEO COUNTY
Average Asking Rent = $2,631 / month
Income Needed to Afford Average Rent $50.60 / hour $8,770 / month San Bruno Minimum Wage $14.00 / hour $2,422 / month
Home Health & Personal Care Aides $16.58 / hour $2,873 / month Retail Salespersons $18.15 / hour $3,146 / month
Childcare Workers $18.31 / hour $3,174 / month
Janitors and Cleaners $20.31 / hour $3,521 / month
Medical Assistants $25.94 / hour $4,497 / month
Source: California Housing Partnership Housing Needs Dashboard: https://chpc.net/housingneeds/.

M. HOME PRICES AND SALES AFFORDABILITY
Home prices reflect a complex mix of supply and demand factors, including an area’s demographic profile, labor market, prevailing wages and job outlook, coupled with land and construction costs. In the Bay Area, the costs of housing have long been among the highest in the nation. The typical home value in San Bruno was estimated at $1,203,420 in December of 2020, per data from Zillow. In San Bruno, most homes cost between $750k-$1M and $1M-$1.5M (Figure 2-23). By comparison, the county has a significantly higher share of homes in the > $1.5M price range than the Bay Area in general. The Bay Area has a much larger share of homes priced under $500,000 than San Mateo County. The typical home value is $1,418,330 in San Mateo County and $1,077,230 in the Bay Area. San Mateo County has a lower share of homes priced under $500,000, while San Bruno has slightly more units priced under $500,000 than the county in general. 25 California COVID-19 Rent Relief Program Dashboard – Housing Is Key. 744 of 1863
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Figure 2-23 Home Values of Owner-Occupied Units
Universe: Owner-occupied units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25075.

The region’s home values have increased dramatically since 2000, besides a temporary decrease during the Great Recession 2007-2011 (Figure 2-24). The rise in home prices has been especially steep since 2012. From 2010 to 2020, the typical single-family home value in San Bruno increased from $549,000 to $1,203,420. The Table 2-14 is from the San Mateo County Association of Realtors (SAMCAR) and show average and median single-family and condominium home prices between 2010 and the fourth quarter of 2021. The median and average prices of both single-family homes and condos in San Mateo County and the Bay Area increased by more than 100% from 2010 to 2021.26 In San Bruno home and condo prices increased the most, with increases upwards of 150%.

TABLE 2-14 MEDIAN SINGLE-FAMILY AND CONDO SALES PRICES (2010, 2015, 2020 AND FOURTH QUARTER 2021) 2010
Annual
2015
Annual
2020
Annual
Fourth Quarter
of 2021
Actual / % Change
(2010-2021)
San Bruno (Single-Family) $549,000 $880,000 $1,205,000 $1,375,000 +$826,000 / (+150%) San Mateo County (Single-Family) Avg. $934,680 $1,250,000 $1,700,000 $1,900,000 +$965,320 / (103%) San Bruno (Condo) $199,500 $368,000 $525,000 $510,000 +$310,500 / (156%) San Mateo County (Condo) Avg. $449,467 $702,000 $925,000 $900,000 +$450,533 / (100%) Source: https://www.zillow.com/home-values/, June 2022. 26 In 2010, SAMCAR calculated average for San Mateo County totals and median for municipalities. In later years, median was calculated for both municipality and county indicators: Market Data (San Mateo County Association of REALTORS®) (samcar.org).

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Figure 2-24 Zillow Home Value Index (ZHVI)
Universe: Owner-occupied housing units.

Source: Zillow, Zillow Home Value Index (ZHVI).

The impact of pursuing the collective programs (total programs) included under Goal 1 ”Remove constraints to housing development and improve the development review process” (9 programs) and Goal 2 “Increase the availability of housing throughout the city, especially affordable housing” (13 programs) will help increase the availability of housing in the city, especially affordable housing, both rental and for-sale, as well as protect residents from displacement. Some of the impacts of these policies include lowering financing costs for affordable projects (Programs 1-C, 1-G, 2-F, 2-G, and 3-B), increasing density in transit corridors (Programs 2-A and 2-E) and increasing density in high resource residential areas (Programs 2-A, 2-D, 2-E, and 4-P).

Programs 3-A, 3-G, 3-H and 3-I aim to help protect current residents from displacement and help mitigate the impacts of increasing rents and high cost of living. These programs explore the possibility of establishing an ordinance that provides for tenant and community first right of purchase or right of first refusal (TOPA and COPA) and also examine giving displaced residents preferential access to new affordable housing units.

KEY POINTS: HOUSING AFFORDABILITY FOR OWNERS AND RENTERS  The median and average prices of both single-family homes and condos in San Mateo County and the Bay Area increased by more than 100 percent from 2010 to 2021. In San Bruno home and condo prices increased the most, with increases upwards of 150 percent.  Like home values, rents have also increased across the Bay Area in the last decades. Many renters have been priced out, evicted or displaced.
 San Bruno’ workforce made up of forty-five percent of households who are extremely low-income, very low-income, or low income may have difficulty competing for the limited number of rental units that are available at an affordable price.
 The COVID-19 Pandemic and the subsequent shift to widescale remote work, has resulted in a rise in vacancy rates and small decline in rents in the region most recently. Prior to the recent decline, yearover-year rent growth had been positive since 2009.  Renters and low-income residents also tend to work in industries that were most affected by public health restrictions. While the state economy has experienced a rebound since that time, pandemic‑induced job loss added further financial stress to low-income households.  Through the California COVID-19 Rent Relief program, almost $70 million in rental assistance has been delivered to San Mateo County renters and landlords serving more than 5,000 households as of March 2022. Most of the households served are considered extremely low-income. 746 of 1863
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N. OVERPAYMENT AND COST-BURDENED HOUSEHOLDS
The U.S. Department of Housing and Urban Development considers housing to be affordable for a household if the household spends less than 30% of its income on housing costs. A household is considered “cost-burdened” if it spends more than 30% of its monthly income on housing costs, while those who spend more than 50% of their income on housing costs are considered “severely cost-burdened.” In San Bruno, 20% of households are cost burdened spending 30%-50% of their income on housing, while an additional 17% of households are severely cost burdened and use the majority of their income for housing. Low-income residents are the most impacted by high housing costs and experience the highest rates of cost burden.

Spending such large portions of income on housing puts low-income households at higher risk of displacement, eviction, or homelessness.

Renters are more likely to be overpaying for housing than homeowners. While the housing market has resulted in home prices increasing dramatically, homeowners often have mortgages with fixed rates, whereas renters are more likely to be impacted by rental market increases. When looking at the cost burden across tenure in San Bruno, 19% of renters spend 30% to 50% of their income on housing and 25% of renters spend more than half of their income on housing (totaling 44% either cost burdened or severely cost burdened). For homeowners, 31% are either cost burdened or severely cost burdened (Figure 2-25).

Households who live in San Bruno may live in overcrowded homes and have limited money to dedicate towards other necessities such as food, transportation, and medical care.

In the City of San Bruno there are a total of 5,549 cost burdened households (spending more than 30% if income for housing), 2,845 are owner-occupied and 2,704 are renter-occupied. Thirty-eight percent of all households in San Bruno are cost-burdened or severely cost-burdened, 32% of all owner-occupied households in San Bruno cost-burdened or severely cost-burdened households, and 44% of all renteroccupied households in San Bruno are cost-burdened or severely cost-burdened.

There are 2,580 occupied housing units in San Bruno that are considered severely cost-burdened (spending more than 50% of income for housing). Of these severely cost-burdened households, (1,049) are owneroccupied and (1,531) are renter-occupied. There are 2,960 occupied housing units in San Bruno that are considered cost burdened (spending between 30%-50% of income for housing). Of these cost-burdened households, (1,796) are owner-occupied and (1,173) are renter-occupied.

Figure 2-26 shows that 67% of San Bruno households making less than 30% of AMI spend the majority of their income on housing (severely cost-burdened). For San Bruno residents making more than 100% of AMI, just 1% are severely cost-burdened, and 91% of those making more than 100% of AMI spend less than 30% of their income on housing.

Currently, people of color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to white residents. As a result, they often pay a greater percentage of their income on housing, and in turn, are at a greater risk of housing insecurity (Figure 2-27).
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Figure 2-25 Cost Burden by Tenure
Universe: Occupied housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25070, B25091.

Figure 2-26 Cost Burden by Income Level
Universe: Occupied housing units.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.
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Figure 2-27 Cost Burden by Race
Universe: Occupied housing units.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

When cost-burdened seniors are no longer able to make house payments or pay rents, displacement from their homes can occur, putting further stress on the local rental market or forcing residents out of the community they call home. Understanding how seniors might be cost-burdened is of particular importance due to their special housing needs, particularly for low-income seniors. For example, 48% of seniors making less than 30% of AMI are spending the majority of their income on housing. For seniors making more than 100% of AMI, 98% are not cost-burdened and spend less than 30% of their income on housing (Figure 2-28).

Figure 2-28 Cost-Burdened Senior Households by Income Level Universe: Senior households.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.
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Large family households often have special housing needs due to a lack of adequately sized affordable housing available. The higher costs required for homes with multiple bedrooms can result in larger families experiencing a disproportionate cost burden than the rest of the population and can increase the risk of housing insecurity. In San Bruno, 33% of large family households experience a cost burden of 30%-50%, while 10% of households spend more than half of their income on housing (Figure 2-29). Large households often have different housing needs than smaller households. If a city’s rental housing stock does not include larger apartments, large households who rent could end up living in overcrowded conditions.

Figure 2-29 Cost Burden by Household Size
Universe: Occupied housing units.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

O. HOUSING OVERCROWDING
Overcrowding occurs when the number of people living in a household is greater than the home was designed to hold. There are several different standards for defining overcrowding, but this report uses the Census Bureau definition, which is more than one occupant per room (not including bathrooms or kitchens).

Additionally, the Census considers units with more than 1.5 occupants per room to be severely overcrowded.

The total number of occupied housing units that are considered overcrowded or severely overcrowded in the City of San Bruno is 1,209 (738 overcrowded and 471 severely overcrowded); these units make up 8% of overall total occupied housing units in the city. Overcrowding increases health and safety concerns and stresses the condition of the housing stock and infrastructure. Overcrowding correlates strongly with household size, particularly for large households. Table 2-15 shows that most households throughout the region are 2-person to 4-person households and 10% to 11% of households are 5-person or more households.
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TABLE 2-15 HOUSEHOLDS BY HOUSEHOLD SIZE
1-Person
Household
2-Person
Household
3-4-Person
Household
5-Person or More
Household
Total
Households
San Bruno 25% 31% 34% 10% 15,063
San Mateo County 22% 32% 35% 11% 263,543
Bay Area 25% 32% 33% 11% 2,731,434
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25002.

Figure 2-30 San Bruno Overcrowding by Tenure and Severity Universe: Occupied housing units.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Overcrowding is often related to the cost of housing and can occur when demand in a city or region is high.

In many cities, overcrowding is seen more amongst those that are renting, with multiple households sharing a unit to make it possible to stay in their communities. In San Bruno, 5% of households that rent are severely overcrowded (763 occupied housing units out of approximately 15,000 total occupied housing units have more than 1.5 occupants per room), compared to 2% of households that own (Figure 2-30). Six percent of renters (924 occupied housing units out of approximately 15,000 total occupied housing units have between 1 to 1.5 occupants per room) experience moderate overcrowding, compared to 4% for those own.

Overcrowding often disproportionately impacts low-income households. Five percent or 744 households very low-income households (below 50% AMI) experience severe overcrowding, while 1% or 156 households above 100% AMI experience this level of overcrowding (Figure 2-31).

Communities of color are more likely to experience overcrowding similar to how they are more likely to experience poverty, financial instability, and housing insecurity. People of color tend to experience overcrowding at higher rates than White residents. In San Bruno, Hispanic or Latino households experience the highest rate of overcrowding (Figure 2-32).
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Figure 2-31 Overcrowding by Income Level and Severity
Universe: Occupied housing units.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Figure 2-32 Overcrowding by Race
Universe: Occupied housing units.

Note: The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per room. Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B2501.

Several programs in this Housing Element will specifically help address cost burdened households which make up 44% of renters and 31% of homeowners in San Bruno. This Housing Element includes Program 2- D to implement SB 9 which will allow duplexes and lot splits on applicable single-family sites. This will increase the production of lower-cost housing options across the city and also in high resource neighborhoods. Increasing the number of units affordable to moderate- and lower-income households will help lower the rates of cost burden in San Bruno. Other programs aim to help address overcrowding, for example, by helping to provide more options for affordable intergenerational housing for single family homeowners. Program 4-P will promote the Accessory Dwelling Unit Ordinance, making it easier to build ADUs including pre-approved ADU plans and encouraging ADUs in new single-family development with a goal of issuing building permits for 44 accessory dwelling units per year. 752 of 1863
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P. OTHER HOUSING ISSUES

1. AGING HOUSING STOCK
Production has not kept up with housing demand for several decades in the Bay Area, as the total number of units built and available has not yet come close to meeting the population and job growth experienced throughout the region. In San Bruno, the largest proportion of the housing stock was built 1940 to 1959, with 6,203 units constructed during this period (Figure 2-33). Since 2010, 2.4% of the current housing stock was built, which is only 379 units. Additionally, older housing can be more expensive to maintain and renovate.

Figure 2-33 Housing Units by Year Structure Built
Universe: Housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25034.

Between 2015 and 2019, 168 housing units were issued permits in San Bruno. Thirty-three percent of permits issued in San Bruno were for above moderate-income housing, 28% were for moderate-income housing, and 39% were for low- or very low-income housing (Table 2-16).

TABLE 2-16 HOUSING PERMITTING
Low-Income Permits 66
Above Moderate-Income Permits 55
Moderate-Income Permits 47
Very Low-Income Permits 0
Universe: Housing permits issued between 2015 and 2019.

Source: California Department of Housing and Community Development (HCD), 5th Cycle Annual Progress Report Permit Summary (2020).

2. SUBSTANDARD HOUSING
Housing costs in the region are among the highest in the country, which could result in households, particularly renters, needing to live in substandard conditions in order to afford housing. Generally, there is limited data on the extent of substandard housing issues in the community. However, the Census Bureau data included in the graph below gives a sense of some of the substandard conditions that may be present in San Bruno. For example, 0.4% (58 occupied housing units) of renters in San Bruno reported lacking a kitchen and 753 of 1863
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0.1% (19 occupied housing units) of renters lack plumbing, compared to 0.0% of owners who lack a kitchen and 0.1% (15 occupied housing units) of owners who lack plumbing (Figure 2-34).27 The American Community Survey tracks other housing problems, including a lack of plumbing and kitchen facilities. Homes in San Bruno have a very small number of other housing problems. Approximately 92 homes are lacking either complete plumbing facilities or complete kitchen facilities. Approximately 6,203 housing units or 40% of San Bruno’s housing units are older than 60 years (built in 1959 or earlier). Thirty six percent of housing units (5,678 units) were built between 1960-1979. Seventy-six percent of housing units in San Bruno are more than 40 years old. At this age, many units are in need of at least minor repairs.. The city’s code enforcement department estimates that the number of units in need of rehabilitation in the city is 5% of the city’s housing stock. Furthermore, most of the city’s substandard housing is concentrated in the neighborhoods east of El Camino Real where there the housing stock is generally older and the neighborhoods have a higher percentage of renters and housing overcrowding.

This Housing Element includes programs and actions, such as Program 3-E, to help renovate and retrofit existing housing stock, especially for naturally occurring affordable units.

3. SPECIAL HOUSING NEEDS
Certain groups have greater difficulty in finding decent, affordable housing due to their special circumstances.

Special circumstances may be related to employment and income, family characteristics, disability, and household characteristics.

In addition to overall housing needs, cities and counties must plan for the special housing needs of certain groups. State law (65583(b)(7)) requires that several populations with special needs be addressed — homeless people, seniors, people living with a disability, large families, female headed households and farmworkers.

This section provides a discussion of the housing needs facing each group.

Figure 2-34 Substandard Housing Issues
Universe: Occupied housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25053, Table B25043, Table B25049. 27 The US Census Bureau uses the definition of a complete kitchen as including a sink with piped water, range or cook stove and a refrigerator.
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Q. SENIORS
According to American Community Survey 2021 estimates, there are currently approximately 6,674 seniors living in San Bruno. As the large baby boomer generation ages, San Bruno, like the rest of San Mateo County, is expected to see a growing senior population. According to California Department of Finance, by 2030 there will be 242,838 seniors over the age of 60 in San Mateo County.28 This would be a 26% increase in the number of seniors between 2020 and 2030. For seniors over the age of 80, the projection is a 56% increase from 2020 to 2030 (Table 2-17).
28 California Department of Finance Population Estimates and Projections by Age, 2012 – 2020; With Projections for 2021, 2025, and 2030: Projections | Department of Finance (ca.gov).

KEY POINTS: COMMON HOUSING PROBLEMS

COST-BURDEN
 In San Bruno, 37 percent of households are cost burdened or severely cost burdened.  The following are the most cost-burdened residents in San Bruno:
 67 percent households making less than 30 percent of AMI.  Hispanic or Latinx residents.
 American Indian or Alaska Native.
 48 percent of seniors making less than 30 percent of AMI.  43 percent of large family households.
 Spending such large portions of income on housing puts households at higher risk of displacement, eviction, or homelessness.
 Cost-burdened households live in overcrowded homes and have limited money to dedicate towards other necessities such as food, transportation, and medical care.  Understanding how seniors might be cost-burdened is of particular importance due to their special housing needs, particularly for low-income seniors.

OVERCROWDING
 Overcrowding increases health and safety concerns and stresses the condition of the housing stock and infrastructure.
 Overcrowding is often related to the cost of housing and can occur when demand in a city or region is high. In many cities, overcrowding is seen more amongst those that are renting, with multiple households sharing a unit to make it possible to stay in their communities.

SUBSTANDARD HOUSING
 The City estimates that 10% of its housing units are substandard with higher concentrations of substandard housing in the neighborhoods east of El Camino Real.  Housing costs in the region are among the highest in the country, which could result in households, particularly renters, needing to live in substandard conditions in order to afford housing. 755 of 1863
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TABLE 2-17 SAN MATEO COUNTY SENIORS IN 2020 AND 2030
2020 Estimate 2030 Projection Percent Increase
Age 60-69 95,247 103,152 8.3%
Age 70-79 61,304 83,215 36%
Age 80+ 36,162 56,471 56%
Totals 192,713 242,838 26%
Source: California Department of Finance Population Estimates and Projections by Age, 2012 – 2020; With Projections for 2021, 2025, and 2030.

Seniors who rent may be at even greater risk for housing challenges than those who own, due to income differences between these groups. The largest proportion of senior households who rent make 0%-30% of AMI, while the largest proportion of senior households who are homeowners falls in the income group Greater than 100% of AMI (Figure 2-35). Often, homeownership means greater housing security. Senior renters are particularly at risk for displacement because their incomes are decreasing while their housing expenses are increasing. Tables 2-16 and 2-17 show a comparison of income and home ownership for seniors living in San Bruno. This Housing Element proposes programs that will directly target the housing challenges of San Bruno’s seniors. For example, Program 4-M supports home sharing programs through the Senior Center and other local agencies and Program 2-G provides expedited review applications for housing for seniors.

Figure 2-35 San Bruno Senior Households by Income and Tenure Universe: Senior households.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Seniors’ income tends to decline as they age. Young seniors often have some retirement savings or employment income that can supplement social security. Older seniors are more likely to use up their savings and therefore are more likely to live in poverty. Twenty-six percent of senior households in San Bruno earn 0%-30% of AMI, and 44% of senior households earn below 50% AMI (Table 2-18). 756 of 1863
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TABLE 2-18 SENIOR HOUSEHOLDS BY INCOME AND TENURE
Income Group
Owner
Occupied
Renter
Occupied
Total by AMI
Group
0%-30% of AMI 585 (23%) 225 (34%) 810 (26%)
31%-50% of AMI 474 (19%) 89 (14%) 563 (18%)
51%-80% of AMI 500 (20%) 79 (12%) 579 (18%)
81%-100% of AMI 280 (11%) 145 (22%) 425 (13%)
Greater than 100% of AMI 680 (27%) 115 (18%) 795 (25%)
Totals 2,519 (100%) 653 (100%) 3,172 (100%)
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Senior households often experience a combination of factors that can make accessing or keeping affordable housing a challenge. They often live on fixed incomes and are more likely to have disabilities, chronic health conditions and/or reduced mobility. Table 2-19 shows that 48% and 21% (69% total) of extremely lowincome (less than 30% AMI) seniors are severely cost burdened or cost burdened . A key challenge in the coming years will be how to accommodate the needs of aging residents.

TABLE 2-19 SAN BRUNO COST BURDEN OF SENIOR HOUSEHOLDS BY INCOME Income Group
0%-30% of Income
Used for Housing
(Not Cost Burdened)
30%-50% of Income
Used for Housing
(Cost Burdened)
50%+ of Income
Used for Housing
(Severely Cost Burdened)
Total
by AMI
0%-30% of AMI 250 (31%) 170 (21%) 390 (48%) 810
31%-50% of AMI 350 (62%) 114 (20%) 99 (18%) 563
51%-80% of AMI 365 (63%) 124 (21%) 90 (16%) 579
81%-100% of AMI 330 (78%) 75 (18%) 20 (5%) 425
Greater than 100% of AMI 780 (98%) 15 (2%) 0 (0%) 795
Total by Level of Cost Burden 2,075 498 599 3172
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013- 2017 release.

Housing concerns for seniors in San Bruno might include retrofits to allow seniors to age in place (stay in their current home as they get older) or stay in the community but in a smaller unit or with services available.

Younger seniors need less support and may benefit from programs to help them rehabilitate their homes to make them better for people to age in place. Older seniors often are unable to maintain a single-family home and look to move to a smaller home or some type of senior living development.

R. PEOPLE WITH DISABILITIES
People with disabilities face additional housing challenges. Encompassing a broad group of individuals living with a variety of physical, cognitive and sensory impairments, many people with disabilities live on fixed incomes and are in need of specialized care, yet often rely on family members for assistance due to the high cost of care. In addition to their specific housing needs people with disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they lose aging caregivers. Figure 2-36 757 of 1863
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shows the rates at which different disabilities are present among residents of San Bruno. Overall, 8% of people in San Bruno have a disability of any kind.29
Special needs of individuals with disabilities vary depending on the particular disability. For example, the needs of a blind person differ greatly from those of a person confined to a wheelchair. Special facilities, such as ramps, elevators, or specially designed restrooms necessary for wheelchair access are architectural features needed to make dwellings suitable for persons confined to wheelchairs. Special features needed by ambulatory persons constrained by other disabilities may not be architectural; rather, these might be simple alternatives to conventional dwelling units or furnishings and appliances that make ordinary tasks of housekeeping and home life less trying and more enjoyable. In families, the needs of persons with disabilities, in terms of special features, are fewer than those of a single person. Nevertheless, a person with a disability in a family would still have special needs. Special architectural features or contrivances could be valuable in giving this person greater independence, dignity, and quality of living.

Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is transition from the person’s living situation as a child to an appropriate level of independence as an adult.

More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is transition from the person’s living situation as a child to an appropriate level of independence as an adult.

Figure 2-36 Disability by Type
Universe: Civilian noninstitutionalized population 18 years and over.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B18102, Table B18103, Table B18104, Table B18105, Table B18106, Table B18107.
29 These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed.
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The California Department of Developmental Services (DDS) currently provides community-based services to approximately 350,000 persons with developmental disabilities and their families through a statewide system of 21 regional centers. The Golden Gate Regional Center is 1 of 21 regional centers in California that provide point of entry to services for people with developmental disabilities. The center is a private, nonprofit community agency that contracts with businesses to offer services to individuals with developmental disabilities and their families.

TABLE 2-20 POPULATION WITH DEVELOPMENTAL DISABILITIES BY RESIDENCE Residence Type Value
Home of Parent / Family / Guardian 216
Community Care Facility 68
Intermediate Care Facility 22
Other 5
Foster /Family Home 5
Independent /Supported Living 5
Universe: Population with developmental disabilities.

Source: California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2020).

In San Bruno, of the population with a developmental disability, children under the age of 18 make up 36.5%, while adults account for 63.5%. The most common living arrangement for individuals with disabilities in San Bruno is the home of parent /family /guardian. When it comes to housing, people with disabilities are not only in need of affordable housing but accessibly designed housing, which offers greater mobility and opportunity for independence. There is a limited supply of handicap accessible, affordable housing generally, and the supply is especially tight near transit. Some people with developmental disabilities are unable to work, rely on Supplemental Security Income, and live with family members. People with disabilities are also often extremely low-income due to the challenge of securing long-term employment, and due to higher medical bills.30
The availability of accessible housing is critical to enable persons with disabilities to live independent lives with minimal support. It is also essential to enable persons with disabilities to participate in society by visiting the homes of friends and family. Housing that meets the needs of persons with disabilities is increasingly important as the population ages.

According to the 2019 American Housing Survey administered by HUD, households of lower socioeconomic status (as measured by income and education) and households that include veterans or someone 65 years of age or older were more likely to include someone with accessibility needs.31 The California Building Code (CBC) requires that publicly funded housing meet certain accessibility Standards, but there hasn’t been a public funded housing project constructed in San Bruno. Most of the housing anticipated to be built will be privately funded. To meet the housing needs of persons with physical and mental disabilities, the City added Program 3-E to develop requirements that increase the number of housing units with accessibility features.
30 For more information or data on developmental disabilities in your jurisdiction, contact the Golden Gate Regional Center for Marin, San Francisco and San Mateo Counties; the North Bay Regional Center for Napa, Solano and Sonoma Counties; the Regional Center for the East Bay for Alameda and Contra Costa Counties; or the San Andreas Regional Center for Santa Clara County. 31 Accessibility in Housing: Findings from the 2019 American Housing Survey (huduser.gov) 759 of 1863
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In addition to the removal of architectural barriers and provision of special accessibility features, persons with physical and developmental disabilities may also need supportive services to help them maintain an independent lifestyle. Individuals with moderate to severe physical or developmental disabilities may need access to assisted living facilities. These facilities are principally permitted in all zoning districts where housing is permitted.

1. FAIR HOUSING LAWS AND STATE LEGISLATION
Fair housing laws and subsequent federal and state legislation require all cities and counties to further housing opportunities by identifying and removing constraints to the development of housing for individuals with disabilities, including local land use and zoning barriers, and to also provide reasonable accommodation as one method of advancing equal access to housing.

The Fair Housing laws require that cities and counties provide flexibility or even waive certain requirements when it is necessary to eliminate barriers to housing opportunities for people with disabilities. An example of such a request might be to place a ramp in a front yard to provide access from the street to the front door.

San Bruno received one reasonable accommodation request since January 2015.

Chapter 7 (Goals, Programs and Implementation Actions) includes several programs and actions that strengthens the city’s ability to promote fair housing and addresses the housing challenges of residents with disabilities by making it easier to develop housing for people with physical and developmental disabilities., including Programs 2-G, 2-H, 3-A, 3-E, 4-A, 4-B, 4-C, 4-D, 4-E, 4-G, 4-H 5-E, and 8-B, among others specifically address these challenges. Programs 2-E and 4-O, for example, both provide for an affordable unit set aside for tenants with physical and developmental disabilities. Programs 4-A, 4-B, 4-C, and 4-E support education and training for landlords and tenants about fair housing laws and the rights of people with disabilities.

S. FEMALE-HEADED HOUSEHOLDS
Households headed by one person are often at greater risk of housing insecurity, particularly female-headed households, who may be supporting children or a family with only one income. In San Bruno, the largest proportion of households is Married-couple Family Households at 53% of total, while Female-Headed Family Households (who live with and support other family members) make up 10% of all households.

Female-headed households with children may face particular housing challenges, with pervasive gender inequality resulting in lower wages for women. Moreover, the added need for childcare can make finding a home that is affordable more challenging. In San Bruno, 16% of female-headed households with children fall below the Federal Poverty Line, while 4% of female-headed households without children live in poverty (Figure 2-38). The special needs of female-headed households can include low-cost housing, suitable for children and located near schools and childcare facilities. The most vulnerable households can be single parent female-headed households; San Bruno has 770 such households. 760 of 1863
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Figure 2-37 Household Type
Universe: Households.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B11001.

Figure 2-38 Female-Headed Households by Poverty Status
Universe: Female Households.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17012.

T. LARGE HOUSEHOLDS
Large households are defined as households with five or more members living in the same home. Large households are a special needs group because of the difficulty in finding adequate and affordable housing.

Many jurisdictions have few large homes, and often these larger homes are significantly more expensive.

Large households throughout San Mateo County are much more likely than smaller households to live in a 761 of 1863
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home with some type of housing problem, such as high cost, or problems with the physical condition of the home. San Bruno has approximately 1,500 households with five or more members.

Large households often have different housing needs than smaller households. If a city’s rental housing stock does not include larger apartments, large households who rent could end up living in overcrowded conditions. In San Bruno, for large households with 5 or more persons, most units (69%) are owner occupied (Figure 2-39). In 2017, 20% of large households were very low-income, earning less than 50% of the AMI.

Programs 2-G and 2-H in this Housing Element includes encouraging the housing construction to enhance access to large families by reducing development constraints to encourage diversity in unit size. Program-2-G seeks to increase housing by pursuing additional ways to streamline development of or granting fee waivers for affordable housing projects. Program 2-H seeks to lower parking requirements for 2-bedroom or larger units. These programs aim to increase the percentage of housing to accommodate residents with disproportionate housing needs, including large families.

Figure 2-39 Household Size by Tenure
Universe: Occupied housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25009.

The unit sizes available in a community affect the household sizes that can access that community. Large families are generally served by housing units with three or more bedrooms, of which there are 7,608 units in San Bruno. Among these large units with three or more bedrooms, 15% are owner-occupied and 85% are renter occupied (Figure 2-40).
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Figure 2-40 Housing Units by Number of Bedrooms
Universe: Housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25042.

U. EXTREMELY LOW-INCOME HOUSEHOLDS
California is one of the most economically unequal states in the nation, and the Bay Area has the highest income inequality between high- and low-income households in the state32. In San Bruno, 42% of households make more than 100% of the AMI, compared to 13.5% making less than 30% of AMI, which is considered extremely low-income.33 Regionally, more than half of all households make more than 100% AMI, while 15% make less than 30% AMI. Many households with multiple wage earners—including food service workers, full-time students, teachers, farmworkers and healthcare professionals—can fall into lower AMI categories due to relatively stagnant wages in many industries.

Extremely Low-Income (ELI) households earn 30% of the AMI or less. There are 2,023 ELI households in San Bruno according to 2017 CHAS data (~5% of the population for whom poverty status is determined in San Bruno). More than half of these households live in rental units. Most of San Bruno’s ELI households face some kind of housing problem: Approximately 48% of all ELI households face overcrowding, and 80% face overpayment. Some ELI households are recipients of public assistance such as social security insurance or disability insurance. Housing types available and suitable for ELI households include affordable rentals, secondary dwelling units, emergency shelters, supportive housing and transitional housing.

The effects of COVID-19 have disparately harmed low-income households. In San Bruno, the effects were felt across all communities but exceedingly affected Native American, Multi-racial, and African American 32 Bohn, S.et al. 2020. Income Inequality and Economic Opportunity in California. Public Policy Institute of California. 33 Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. Households making between 80% and 120% of the AMI are moderate-income, those making 50% to 80% are low-income, those making 30% to 50% are very low-income, and those making less than 30 percent are extremely low-income. This is then adjusted for household size. 763 of 1863
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households. These communities experience, on average, double the overall poverty rate. Across the country, systemic inequalities in employment, wage-earning, health, and well-being have strained individuals, families and communities facing poverty or near-poverty conditions.

Goals 2, 3 and 4 include programs that supports the needs of households with low and extremely low incomes, such as continuing City support the Housing Investment Partnership (HIP) Home Sharing program which facilitates living arrangements among two or more unrelated people (Program 4-M) or continuing to participate in San Mateo County Housing Authority’s Housing Choices Voucher program (formerly Section 8 under HUD) (Program 4-N). The five programs under Goal 3 “Improve the city’s management of its affordable housing portfolio and its affordable housing funds” will collectively help the city better support and monitor housing programs that serve extremely low-income residents in the city.

V. HOMELESS NEEDS
Homelessness remains an urgent challenge in many communities across the state, reflecting a range of social, economic, and psychological factors. Rising housing costs result in increased risks of community members experiencing homelessness. Far too many residents who have found themselves housing insecure have ended up unhoused or homeless in recent years, either temporarily or longer term. Addressing the specific housing needs for the unhoused population remains a priority throughout the region, particularly since homelessness is disproportionately experienced by people of color, people with disabilities, those struggling with addiction and those dealing with traumatic life circumstances. The homeless in San Mateo County are both sheltered, meaning they live in emergency shelters, transitional housing, treatment centers or other similar institutions; and unsheltered, meaning they live on the street, in encampments or in a vehicle.

The vast majority of homeless people are single adults (who may be living with another adult, but no children). Most homeless people are male (a range between 60%-71% depending on sheltered and unsheltered). In San Mateo County, White (Hispanic and Non-Hispanic) residents represent the largest proportion of residents experiencing homelessness and account for 67% of the homeless population, while making up 51% of the overall population (Figure 2-41). Latino residents represent 38% of the population experiencing homelessness, while Latino residents comprise 25% of the general population (Figure 2-41). In 2017, 89% of households were either single individuals or couples without children and 13% were households with children. 34 Of homeless households with children, most are sheltered in transitional housing (Figure 2-43).
34 San Mateo County Health Care for the Homeless and Farmworker Health Program 2019 Needs Assessment: 2019_hchfh_needs_ assessment_report_final_9.1.2020.pdf (smchealth.org).
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Figure 2-41 Racial Group Share of General and Homeless Populations, San Mateo County Universe: Population experiencing homelessness.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I).

Figure 2-42 Homelessness by Household Type and Shelter Status, San Mateo County Universe: Population experiencing homelessness.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019).
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Figure 2-43 Latino Share of General and Homeless Populations, San Mateo County Universe: Population experiencing homelessness.

Many of those experiencing homelessness are dealing with severe issues—including mental illness, substance abuse and domestic violence—that are potentially life threatening and require additional assistance. In San Mateo County, homeless individuals are commonly challenged by severe mental illness, with 305 reporting this condition (Figure 2-44). Of those, some 62% are unsheltered, further adding to the challenge of handling the issue.

Figure 2-44 Characteristics for the Population Experiencing Homelessness, San Mateo County
Universe: Population experiencing homelessness.

Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019).
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In San Bruno, there were no reported students experiencing homeless in the 2019-20 school year. By comparison, San Mateo County has seen a 37.5% decrease in the population of students experiencing homelessness since the 2016-17 school year, and the Bay Area population of students experiencing homelessness decreased by 8.5%. During the 2019-2020 school year, there were still some 13,718 students experiencing homelessness throughout the region, adding undue burdens on learning and thriving, with the potential for longer term negative effects.

TABLE 2-21 STUDENTS IN LOCAL PUBLIC SCHOOLS EXPERIENCING HOMELESSNESS Academic Year San Bruno San Mateo County Bay Area
2016-17 0 1,910 14,990
2017-18 0 1,337 15,142
2018-19 0 1,934 15,427
2019-20 0 1,194 13,718
Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public schools.

Source: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018- 2019, 2019-2020).

1. ONE-DAY HOMELESS COUNT
The San Mateo County Human Services Agency
(HSA), in close collaboration with community
partners, conducts the bi-annual One Day Homeless
Count and Survey. The purpose of the One Day
Homeless Count and Survey is to gather information
to help the community understand homelessness in
San Mateo County. This is one data set, among
others, that provides information for effective
planning of services to assist people experiencing
homelessness and people at risk of homelessness.

According to the 2022 San Mateo County One Day
Homeless Count35 conducted in the early morning hours of February 24, 2022, there were 1,808 people experiencing homelessness in San Mateo County. This number includes: 1,092 people experiencing unsheltered homelessness staying on streets, in cars, in recreational vehicles (RVs), or in tents. 716 people experiencing sheltered homelessness staying in emergency shelters and transitional housing programs This finding of 1,808 people experiencing homelessness is higher than the counts in 2015, 2017, and 2019, but lower than the counts in 2011 and 2013. The number of people experiencing unsheltered homelessness in 2022 is an increase of 191 (21%) compared to 2019. The number of people staying in shelters in 2022 is an increase of 105 (17%) compared to 2019.

Although the sheltered count has varied over time (including shifts due to HUD’s definitional changes), it is the unsheltered count that has largely contributed to the overall number of homeless people in the county.

According to the 2022 San Mateo County One Day Homeless Count and Survey, the number of people 35 https://www.smcgov.org/media/130616/download?inline= TABLE 2-22 SAN MATEO COUNTY POINT-IN-TIME

HOMELESS COUNTS
Year Point-in-Time Count
2013 2,002
2015 1,483
2017 1,253
2019 1,512
2022 1,808
Source: San Mateo County Human Services Agency, 2022.Public Health. 767 of 1863
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experiencing unsheltered homelessness in San Bruno in 2022 was 63. This is an increase from the same count conducted in 2019 of 12 unsheltered homeless, and 26 unsheltered homeless in 2017. The sixty-three unsheltered homeless persons that were counted in San Bruno in 2022, make up 6% of the 1,092 homeless unsheltered in the San Mateo County as a whole.

In 2006, San Mateo County developed a 10-Year Plan to Prevent and End Homelessness (HOPE Plan).36 Key accomplishments of the HOPE Plan included the creation and expansion of Homeless Outreach Teams (HOT), new funding sources for homelessness prevention, Homeless Connect events, the creation of 994 new affordable housing units as well as the creation of 96 new units of permanent supportive housing, including projects developed by the Mental Health Association and units in projects developed by Mid-Pen Housing. The HOPE Plan focused on creation of new housing inventory as a key strategy to reduce homelessness, but these goals were not achievable given the local housing market.

In 2016 the county adopted a new San Mateo Homelessness Strategic Plan, Ending Homelessness in San Mateo County.37 The 2016 plan draws on best practices to reduce homelessness given the existing supply of housing and focusing on short- and long-term housing assistance prioritized for people who are unsheltered.

Expansion of the affordable housing supply remains a key priority for the community, but this work is being spearheaded by the Department of Housing along with other stakeholders and workgroups, including the Jobs/Housing Gap Task Force, Housing Leadership Council of San Mateo County, HEART of San Mateo and other efforts.

The County and its partners have expanded homeless services in recent years, including expansions in shelters, as well as expansions in homeless outreach services, rapid rehousing services, and enhancing connections between health services and homeless services. The County is also working on additional noncongregate shelter that will open later this year, including the Navigation Center and Stone Villa Shelter, which will both provide additional shelter capacity to provide safe shelter along with intensive support services to help residents move into permanent housing.

In addition, the County recently launched its Working Together to End Homelessness initiative, bringing together a wide array of stakeholders to collaborate on innovative strategies to provide housing and services to people experiencing homelessness. More information on Working Together to End Homelessness is available at SMCEndingHomelessness.org.

W. FARMWORKERS
Across the state, housing for farmworkers has been recognized as an important and unique concern.

Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary housing needs. Finding decent and affordable housing can be challenging, particularly in the current housing market. In San Bruno, there were no reported students of migrant workers in the 2019-20 school year. The trend for the region for the past few years has been a decline of 2.4% in the number of migrant worker students since the 2016-17 school year. The change at the county level is a 57.1% decrease in the number of migrant worker students since the 2016-17 school year.
36 Housing our People Effectively (HOPE) Ending Homelessness in San Mateo County: HOPE 10-Year Plan.pdf (sanmateo.ca.us). 37 Ending Homelessness in San Mateo County (July 2016): download (smcgov.org). 768 of 1863
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TABLE 2-23 MIGRANT WORKER STUDENT POPULATION
Academic Year San Bruno San Mateo County Bay Area
2016-17 0 657 4.630
2017-18 0 418 4.607
2018-19 0 307 4.075
2019-20 0 282 3.976
Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public schools.

Source: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019-2020).

According to the U.S. Department of Agriculture Census of Farmworkers, the number of permanent farm workers in San Mateo County has decreased since 2002, totaling 978 in 2017, while the number of seasonal farm workers has decreased, totaling 343 in 2017 (Figure 2-45).

There are migrant worker students in the locality (282 in the entire county in 2019-2020 school year), permanent farmworkers (978 in the county in 2017) and seasonal farmworkers (343 in the county in 2017).

All these numbers have been trending downward.

Figure 2-45 Farm Operations and Farm Labor by County, San Mateo County Universe: Hired farm workers (including direct hires and agricultural service workers who are often hired through labor contractors).

Source: U.S. Department of Agriculture, Census of Farmworkers (2002, 2007, 2012, 2017), Table 7: Hired Farm Labor.

Farm workers who are migrant or seasonal workers have special housing needs because of their relatively low-income and the unstable nature of their job (i.e., having to move throughout the year from one harvest to the next). These workers generally face higher rates of overcrowding and other substandard housing conditions. Continued efforts to provide affordable housing, especially affordable housing 769 of 1863
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Farmworkers in San Bruno are often very low or extremely low-income households. Per the USDA, today’s farmworkers can commute up to 75 miles to the workplace. They are also more likely to have families and are looking for schools, employment for a spouse/partner and a location to live in that provides a community.

Because of this, they will benefit from the existing affordable housing programs in San Bruno. Additionally, San Bruno’s participation in Doorway will ensure that new affordable housing listings are publicized in Spanish and that vacancy searches are mobile-friendly.

X. NON-ENGLISH SPEAKERS
California has long been an immigration gateway to the United States, which means that many languages are spoken throughout the Bay Area. Since learning a new language is universally challenging, it is not uncommon for residents who have immigrated to the United States to have limited English proficiency. This limit can lead to additional disparities if there is a disruption in housing, such as an eviction, because residents might not be aware of their rights or they might be wary to engage due to immigration status concerns. In San Bruno, 6.2% of residents 5 years and older identify as speaking English not well or not at all, which is below the proportion for San Mateo County. Throughout the region the proportion of residents 5 years and older with limited English proficiency is 8%.

Several programs in the Housing Element help address the gap in support to non-English speakers in the community. Goal 4 “Promote equity in housing, protect residents from displacement, and support the needs of households with low incomes or special needs” includes Program 4-A which calls for to multi-lingual marketing materials and ensuring bilingual interpretation services are available for fair housing outreach to landlords as well as renters as well as on the city’s website.

Figure 2-46 Population with Limited English Proficiency Universe: Population 5 years and over.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B16005.

For the data table behind this figure, please refer to the Data Packet Workbook, Table AFFH-03. 770 of 1863
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KEY POINTS SPECIAL HOUSING NEEDS: SENIORS, PEOPLE WITH DISABILITIES, FEMALE-HEADED

HOUSEHOLDS, LARGE HOUSEHOLDS, EXTREMELY LOW-INCOME HOUSEHOLDS, HOMELESS,

FARMWORKERS, NON-ENGLISH SPEAKERS

SENIORS
 The county can expect to see a 26 percent increase in the number of seniors between 2020 and 2030.

For seniors over the age of 80, the percent increase is 56 percent. A key challenge in the coming years will be how to accommodate the needs of aging residents.  26 percent of senior households in San Bruno earn 0 percent-30 percent of AMI, and 44 percent of households earn below 50 percent AMI. Affordable housing options for these seniors are crucial.  Seniors are significantly more likely to be homeowners than renters. Seniors need retrofits to allow them to age in place or stay in the community but in a smaller unit or with services available.

PEOPLE WITH DISABILITIES
 8 percent of the total San Bruno population in the city has some kind of disability. In San Bruno, almost a third of the senior population has some kind of disability.  There is a limited supply of handicap accessible, affordable housing generally, and the supply is especially tight near transit. People with disabilities are also often extremely low income due to the challenge of securing long-term employment, and to higher medical bills.

FEMALE HEADED HOUSEHOLDS
 Female-headed households, who may be supporting children or a family with only one income experience more housing insecurity (10 percent of the total households in San Bruno). San Bruno has 770 female-headed, single-parent households.
 The special needs of female-headed households can include low-cost housing, suitable for children and located near schools and childcare facilities.

LARGE HOUSEHOLDS
 If a city’s rental housing stock does not include larger apartments, large households who rent could end up living in overcrowded conditions. San Bruno has approximately 1,500 households with five or more members. In 2017, 19.7 percent of large households were very low-income, earning less than 50 percent of the area median income (AMI).

EXTREMELY LOW-INCOME HOUSEHOLDS
 In San Bruno, 13.5 percent households EARN less than 30 percent of AMI are considered extremely lowincome (ELI) and 2,023 households live below the poverty line.  ELI are most likely facing overpayment, overcrowding or substandard housing conditions. The effects of COVID-19 have disparately harmed ELI households.

HOMELESSNESS
 According to the 2019 countywide homeless survey, there are 1,512 people experiencing homeless on a single night in San Mateo County. Of those, more than 900 were unsheltered and a significant number lived in RVs.
 The vast majority of homeless people are single adults. Most homeless people are white and male.

MIGRANT WORKERS
 In San Bruno, there were no reported students of migrant workers in the 2019-20 school year.

NON-ENGLISH SPEAKERS
 In San Bruno, 6.2 percent of residents 5 years and older identify as speaking English not well or not at all. This limit can lead to additional disparities if there is a disruption in housing, such as an eviction, because residents might not be aware of their rights, or they might be wary to engage due to immigration status concerns.
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Y. ASSISTED HOUSING DEVELOPMENTS AT-RISK OF

CONVERSION
While there is an immense need to produce new affordable housing units, ensuring that the existing affordable housing stock remains affordable is equally important. Additionally, it is typically faster and less expensive to preserve currently affordable units that are at risk of converting to market-rate than it is to build new affordable housing. The data in the table below comes from the California Housing Partnership’s Preservation Database, the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing. However, this database does not include all deed-restricted affordable units in the state, so there may be at-risk assisted units in a jurisdiction that are not captured in this data table. Table 2-24 shows there are 323 assisted units in San Bruno in the Preservation Database. Of these units, 0.0% are at High Risk or Very High Risk of conversion.38 TABLE 2-24 ASSISTED UNITS AT RISK OF CONVERSION
Income San Bruno San Mateo County Bay Area
Low 323 4,656 110,177
Moderate 0 191 3,375
High 0 359 1,854
Very High 0 58 1,053
Total Assisted Units in Database 323 5,264 116,459
Universe: HUD, Low-Income Housing Tax Credit (LIHTC), USDA, and CalHFA projects. Subsidized or assisted developments that do not have one of the aforementioned financing sources may not be included.

Source: California Housing Partnership, Preservation Database (2020).

In 1989, the California Government Code was amended to include a requirement that localities identify and develop a program in their housing elements for the preservation of assisted, affordable multi-family units.

Section 65583(a)(8) requires an analysis of existing housing units that are eligible to change from low-income housing uses during “the next 10 years” due to termination of subsidy contracts, mortgage prepayment, or expiration of restrictions on use. In the context of this Housing Element update, assisted units are considered “at-risk” of conversion to market rate if the expiration date of their financing program falls before 2033 (i.e., 10 years from the beginning of the housing element planning period—2023).

Assisted housing units are those that offer financial aid or provide extra services for people in need of financial or basic living assistance. San Bruno has three assisted housing developments, all of which were built during the 2000s: Archstone I (Meridian), completed in 2005; Archstone II (Paragon), completed in 2007; and Village at the Crossing, also completed in 2007. All three projects are rental apartments; the two Archstone developments are for all household types and the Village at the Crossing is for senior households only. The three projects received funding through a variety of sources including state bond tax-exempt financing, San 38 California Housing Partnership uses the following categories for assisted housing developments in its database:

Very-High Risk: affordable homes that are at-risk of converting to market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

High Risk: affordable homes that are at-risk of converting to market rate in the next 1-5 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Moderate Risk: affordable homes that are at-risk of converting to market rate in the next 5-10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Low Risk: affordable homes that are at-risk of converting to market rate in 10+ years and/or are owned by a large/stable non-profit, mission-driven developer.
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Bruno Redevelopment Agency subsidies, and 4% tax credits. None of these developments is considered to be at-risk of conversion within the next 10 years. Sixty units at Archstone I will be affordable through 2060 and 37 units at Archstone II will be affordable through 2062. All units at the Village at the Crossing have 30-year affordability restrictions. Once those expire, there will be 105 units that have continued affordability restrictions through 2062 (11 low- and 94 moderate-income). The table below provides a summary of assisted affordable units in San Bruno today.

TABLE 2-25 ASSISTED HOUSING DEVELOPMENTS IN SAN BRUNO
Project Address
Affordable
Units
Total
Units
Funding
Program
Termination
Date
Risk
Level
The Crossing 853 East Commodore Drive 60 300 LIHTC 2059 Low The Crossing Phase I 1101 National Avenue 113 114 LIHTC 2061 Low The Crossing, Phase 2 1101 National Avenue 113 114 LIHTC 2062 Low Archstone San Bruno II 1099 Admiral Court 37 185 LIHTC 2060 Low Source: California Housing Partnership Preservation Database about "at-risk" deed-restricted affordable housing developments in the jurisdictions of San Mateo County
The California Housing Partnership Corporation (CHPC) assists nonprofit and government housing agencies to create, acquire, and preserve housing affordable to lower income households. CHPC maintains a database of units throughout California that use federal funding programs to maintain their affordability. According to CHPC, there are no at-risk affordable housing units in San Bruno listed in their database.

1. QUALIFIED ENTITIES FOR AT-RISK PROPERTIES
An owner of a multi‐family rental housing development with rental restrictions (i.e., is under agreement with federal, State, and local entities to receive subsidies for low‐income tenants), may plan to sell their “at risk” property. HCD has listed qualified entities that may be interested in participating in California's First Right of Refusal Program. If an owner decides to terminate a subsidy contract or prepay the mortgage or sell or otherwise dispose of the assisted housing development, or if the owner has an assisted housing development in which there will be the expiration of rental restrictions, the owner must first give notice of the opportunity to offer to purchase to a list of qualified entities provided to the owner. HCD has listed six entities that may be interested in participating in California's First Right of Refusal Program in San Mateo County:
 ROEM Development Corporation
 Northern California Land Trust, Inc.
 Housing Corporation of America
 Mid‐Peninsula Housing Coalition
 Affordable Housing Foundation
 Alta Housing (previously Palo Alto Housing Corp)
KEY POINTS: ASSISTED HOUSING UNITS AT-RISK AND ENERGY CONSERVATION STRATEGIES  There are 323 assisted units in San Bruno in the Preservation Database. Of these units, none are at High Risk or Very High Risk of conversion. Because the projects were built more recently, and the deed restrictions apply for several decades, none of these developments are at-risk of conversion within the next 10 years.
 There are three main strategies a jurisdiction can employ to promote energy conservation: integrated land use and transportation planning; the adoption of green building standards and practices; and the promotion of energy conservation programs and choices.
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If a development becomes at risk of conversion to market‐rate housing, the City will maintain contact with these organizations and housing providers who may have an interest in acquiring at‐risk units and will assist other organizations in applying for funding to acquire at‐risk units.

Program 4-F of this Housing Element provides for the adoption of an ordinance that provides for tenant and community first right of purchase or right of first refusal. Although the city doesn’t have any affordable units at risk of conversion, Program 3-C proposes a revision to the Affordable Housing Ordinance to ensure that all new affordable housing remains affordable for 99 years or in perpetuity. Increasing the affordability term would prevent the loss of affordable housing in the future. Program 3-G requires replacement of below market rate units lost during any construction, redevelopment, or demolition projects in accordance with state law SB 8 (no net loss).

Z. ENERGY CONSERVATION
Conservation of energy is an important issue in housing development today not only due to the cost of energy, which can be a substantial portion of monthly housing costs for both owners and renters, but also due to an emerging interest in sustainable development, energy independence, and reduction of greenhouse gas emissions in line with new legislation such as AB 32 and SB 375. There are three main strategies a jurisdiction can employ to promote energy conservation: integrated land use and transportation planning; the adoption of green building standards and practices; and the promotion of energy conservation programs and choices. The following section describes opportunities for energy conservation.

1. INTEGRATED LAND USE AND TRANSPORTATION
Energy conservation can be a priority in the overall planning of a city’s land uses and transportation systems.

Planning to provide a range of housing types and affordability near jobs, services, and transit can reduce commutes, traffic congestion, and thus the number of vehicle miles traveled, and vehicle hours traveled.

Promoting infill development at higher densities will also help reach these goals.

The San Bruno 2025 General Plan and the recently adopted Transit Corridors Specific Plan contain many new policies aimed to reduce energy use and associated greenhouse gas emissions, by reducing vehicle miles traveled and trips through infill and transit- and pedestrian-oriented residential and non-residential development (LUD-7, LUD-10, LUD-28, LUD-29, LUD-48); through encouraging alternatives modes of transportation (T-1, T-3, T-4, T-5) including an emphasis on improving options and infrastructure for bicycle use (T-69 through T-74); and through policies to increase energy conservation specifically through green design, retrofitting, and other incentives (PFS-62 through PFS-71). Most of these initiatives that support energy conservation also support the provision of affordable and accessible housing by locating residents near transit and other services, by increasing housing unit densities and varieties which can lower the cost of renting or owning, and by creating a complete transportation system that can accommodate households that cannot afford cars.

2. BUILDING DESIGN STANDARDS AND PRACTICES
There are many opportunities for conserving energy in new and existing homes. Construction of energy efficient buildings does not lower the purchase price of housing. However, housing with energy conservation features should result in reduced monthly occupancy costs as consumption of water and energy is decreased.

Similarly, retrofitting existing structures with energy-conserving features can result in a reduction in utility costs.
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STATE BUILDING CODE STANDARDS
The California Energy Commission was created in 1974 by the Warren-Alquist State Energy Resources Conservation and Development Act (Public Resources Code 25000 et seq.). Among the requirements of the law was a directive for the Commission to adopt energy conservation standards for new construction. The first residential energy conservation standards were developed in the late 1970s (Title 24, Part 6 of the California Code of Regulations) and have been periodically revised and refined since that time. In 2011, California added the California Green Building Standards Code (CALGreen) to the state’s official building code. CALGreen is a new set of building codes, some mandatory, and some voluntary, for all new buildings and renovations. It is the first state level “green” building code to be implemented in the US.

San Bruno adopted the 2019 California Building Code, including the Green Building Code and related Energy Code in 2019. All building projects are held to these updated standards.

REACH CODES
In addition to California state required building codes, cities and counties may adopt more advanced, or enhanced, building codes, which are known as reach codes. Reach Codes are local amendments that exceed the Building Energy Efficiency Standards Code and Green Building Standards Code. The adoption of Reach Codes aims to reduce greenhouse gas emissions (GHGs) by reducing reliance on natural gas and gasoline through refocusing energy consumption towards electrification. California state law allows local governments to impose additional measures beyond the California Building Energy Efficiency and the Green Building Standards Codes through the adoption of Reach Codes. The State requires the Building Code to be updated every three years, with the next code cycle to be effective January 1, 2023. The City adopted a Reach Code ordinance in October 2022 to align with the next code cycle.

OTHER ENERGY CONSERVATION OPPORTUNITIES IN BUILDING STANDARDS AND PRACTICES As described above, the San Bruno 2025 General Plan contains numerous policies that support the development and evolution of green building standards and practices in the city. Examples of energy conservation opportunities include weatherization programs and home energy audits; installation of insulation; installation or retrofitting of more energy-efficient appliances and mechanical or solar energy systems; and building design and orientation that incorporates energy conservation considerations.

For the purposes of this Housing Element, we can elaborate on ways that residential building design can be more energy efficient. Many modern design methods used to reduce residential energy consumption are based on proven techniques in use since the earliest of days of collective settlement. These methods can be categorized in three ways:

1. Building design that keeps natural heat in during the winter and keeps natural heat out during the summer. Such design reduces air conditioning and heating demands. Proven building techniques in this category include:
 locating windows and openings in relation to the path of the sun to minimize solar gain in the summer and maximize solar gain in the winter;
 use of “thermal mass,” earthen materials such as stone, brick, concrete, and tiles that absorb heat during the day and release heat at night;
 “burying” part of the home in a hillside or berm to reduce solar exposure or to insulate the home against extremes of temperature;
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 use of window coverings, insulation, and other materials to reduce heat exchange between the interior of a home and the exterior;
 locating openings and using ventilating devices to take advantage of natural air flow; and  use of eaves and overhangs that block direct solar gain through window openings during the summer but allow solar gain during the winter.

2. Building orientation that uses natural forces to maintain a comfortable interior temperature. Examples include:
 north-south orientation of the long axis of a dwelling;  minimizing the southern and western exposure of exterior surfaces; and  location of dwellings to take advantage of natural air circulation and evening breezes.

3. Use of landscaping features to moderate interior temperatures. Such techniques include:
 use of deciduous shade trees and other plants to protect the home;  use of natural or artificial flowing water; and
 use of trees and hedges as windbreaks.

In addition to these design techniques, other modern or technology-based energy conservation methods include:
 use of solar energy to heat water;
 use of solar panels, photovoltaic technology, and other devices to generate electricity;  window glazing to repel summer heat and trap winter warmth;  weather-stripping and other insulation to reduce heat gain and loss; and  use of energy efficient home appliances.

The city’s abundant sunshine provides an opportunity to use solar energy techniques to generate electricity, heat water, and provide space heating during colder months, as well. Natural space heating can be substantially increased through the proper location of windows and thermal mass.

Program 2-Lof this Housing Element promotes sustainable residential development that is energy efficient and reduces greenhouse gas emissions. It includes several actions focusing on adopting promoting energy efficiency and electrification incentives from PG&E, BayREN, and promoting water conservation and drought-resistant landscaping guidelines and standards.

AA. CONCLUSION
A home meets the standard definition of affordability if it does not cost more than 30% of a household’s income. Housing that costs more than 30% of household income is a more acute problem for lower income households, since there is less discretionary money for other necessities. While individual household income conditions vary, an example can be useful to illustrate affordability conditions for a low-income family in San Mateo County. A four-person family with one parent working fulltime as a cook and the other parent working in retail can afford a monthly rent of about $1,650 (assumes $66,560 annual household income renting a two-bedroom apartment in San Mateo County) and a home sales price of $260,000 (assumes a 3.5% down payment FHA loan). A single-parent family with the adult working as a police officer would be considered moderate-income (100% AMI or $119,700) and can afford a monthly rent of about $2,950 and a home costing $465,000 (assumes a 3.5% down payment FHA loan). Neither of these example households can afford a median priced condominium in San Bruno, costing $520,000 (SAMCAR, 2021 Annual Median Price), or single-family home, which costs $1,377,500 (SAMCAR, 2021 Annual Median Sale Price) or the median city’s rent for a two-bedroom of $3,543 for 2021 (http://www.selfsufficiencystandard.org/california/).
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The cost of living in the Bay Area continues to be significantly higher. The Family Economic Self-Sufficiency Standard measures the minimum income necessary to cover all non-elderly (under 65 years old) and nondisabled individuals or family’s basic expenses—housing, food, childcare healthcare, transportation, and taxes without public or private assistance. Using this standard index, a family of four (2 adults and 2 children) will need to earn $150,620 a year, in 2021, to live and sustain themselves in San Mateo County.39 Though San Mateo County has a robust economy, much of its workforce cannot afford to live within the county.

As this chapter has demonstrated, despite a slowdown in population growth in recent years, additional housing is needed to accommodate housing demand among all income groups and in particular for lower income groups. Rising housing costs have contributed directly to the outmigration of residents to more affordable markets as well as displacement of existing lower income residents. Meanwhile, continued job growth has consistently fueled a tight housing market and higher housing costs. This Housing Needs Assessment focuses on identifying the housing needs in San Bruno and highlights some of the policies and programs (described in more detail in Chapter 7) that will help to address those needs. 39 Home – Self Sufficiency Standard.
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3 HOUSING CONSTRAINTS AND RESOURCES
This chapter describes the potential constraints applied by local, state, and federal governments, the private market, infrastructure, and the natural environment to the timing or expansion of San Bruno’s residential development. Additionally, potential resources available through local, state, and federal programs are also discussed. This chapter is designed to address the requirements of Government Code Section 65583(a)(5).

Government regulations can potentially constrain the supply of housing available in a community if the regulations limit the opportunities to develop housing, impose requirements that unnecessarily increase the cost to develop housing, or make the development process so arduous as to discourage housing developers.

State law requires housing elements to contain an analysis of the governmental constraints on housing maintenance, improvement, and development (Government Code Section 65583(a)(5)). Non-governmental constraints (required to be analyzed under Government Code Section 65583(a)(5)) cover land prices, construction costs, and financing. While local governments cannot control prices or costs, identification of these constraints can be helpful to San Bruno in formulating housing programs.

A. GOVERNMENTAL CONSTRAINTS
Housing affordability is affected by factors in both the private and public sectors. Although local ordinances and policies are enacted to protect the health and safety of citizens and further the general welfare, it is useful to periodically reexamine them to determine their continued relevance and if they constitute a barrier to the maintenance, improvement, or development of housing. Actions by the City can have an impact on the price and availability of housing in San Bruno. Land use controls, site improvement requirements, building codes, fees, and other local programs intended to improve the overall quality of housing may serve as a constraint to housing development. These governmental constraints can limit the operations of the public, private, and non-profit sectors, making it difficult to meet the demand for affordable housing and limiting supply in the region. All City zoning regulations, development standards, specific plans, and fees are posted online and available to the public, consistent with the requirements of Assembly Bill (AB) 1483. This section describes existing governmental constraints and the ways in which the City has worked to reduce or remove them over the last Housing Element cycle.
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1. LAND USE REGULATIONS
SAN BRUNO 2025 GENERAL PLAN
The land use categories of the San Bruno 2025 General Plan allow residential growth at various density levels.

The General Plan Land Use Diagram is included as Figure 3-1. Below is a summary of land use categories that allow residential use:
 Very Low Density Residential. Single-family detached residential development at a density of 0.1 to 2.0 units per acre; innovative development patterns, preservation of natural features, pedestrian paths, and other amenities are encouraged.
 Low Density Residential. Single-family detached development at a density of 2.1 to 8.0 units per acre; single-family attached development may be allowed where clustering permits additional open space.  Medium Density Residential. Residential development at a density of 8.1 to 24.0 units per acre; allows for single-family detached and attached housing, small-lot and zero-lot-line development, and duplexes.  High Density Residential. Allows single-family attached and multi-family residential development at a density of 24.1 to 40.0 units per acre; includes ancillary uses such as rooming and boarding houses, sanitariums, and rest homes.
 Central Business District (Downtown Mixed Use). Allows 3.0 base maximum floor-area-ratio (FAR) combined for all uses (residential and non-residential), with no separate residential density limitation.

Downtown Mixed Use permits one or more of a variety of uses, including: retail sales; hotels; eating and drinking establishments; personal and business services; professional and medical offices; financial, insurance, and real estate offices; theaters and entertainment uses; educational and social services; and government offices. Active uses are required at the ground level, and residential use is permitted on second and upper floors only. Wholesale trade, drive-through facilities, and auto-related uses are prohibited.
 Transit-Oriented Development (TOD). Allows 2.0 base maximum FAR combined for residential and/or non-residential, and no FAR limit for parcels of 20,000 square feet or larger, as outlined in the Transit Corridors Plan. In addition to FAR limits, no maximum residential density is required for individual residential projects. This classification permits a variety of uses, either individually or in mix with other permitted uses, including retail sales; eating and drinking establishments; personal and business services; professional and medical offices; financial, insurance, and real estate offices; hotels and motels; educational and social services; government offices; and residential. This designation is generally applied in key corridors such as San Bruno Avenue and El Camino Real in areas with proximity to BART and Caltrain stations.
 Multi Use – Residential Focus. Allows 2.0 base maximum FAR combined for residential and/or nonresidential, 3.0 maximum for parcels of 20,000 square feet or larger, with non-residential use not exceeding 0.6 FAR. Residential density shall not exceed 40.0 units per acre (before state-mandated affordable housing density bonus). The City may grant a discretionary bonus of up to 8.0 units per acre for projects that undertake public right-of-way streetscape improvements in accordance with criteria established by the City. Multi Use – Residential Focus extends south along El Camino Real from Crystal 779 of 1863
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Figure 3-1 San Bruno 2025 General Plan Land Use Diagram Source: City of San Bruno, General Plan, 2022.
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Springs Road, placing emphasis on multi-family housing in new development projects. Multi Use – Residential Focus permits one or more of a variety of uses, including: multi-family and attached singlefamily housing; eating and drinking establishments; personal and business services; hotels and motels; and financial, insurance, and real estate offices. New retail uses are only conditionally allowed to ensure that such activities are concentrated in existing retail districts.  Neighborhood Commercial. Residential units are conditionally permitted on upper floors as part of a mixed-use development with commercial uses; overall maximum FAR for all uses is 1.2 FAR (with no separate residential density limitation).
 Bayhill Mixed-Use Overlay. The Bayhill Shopping Center provides neighborhood-serving commercial goods and services to nearby residents as well as the Plan Area’s many office workers. Retaining and expanding retail shopping and other services is an important goal of the Plan. The site’s large surface parking area provides an opportunity for intensification of commercial use and the addition of housing.

The Mixed-Use Overlay allows for residential development provided the current amount of commercial use on the site is not reduced. Housing may be developed in standalone buildings or above commercial space in a mixed-use building. A total of 210 units could be developed throughout the Bayhill Shopping Center and the adjacent property located at 899 Cherry Avenue.  Bayhill Residential Overlay. The Residential Overlay provides for residential development on two properties (801-851 Traeger Avenue and 1111 Bayhill Drive) along the San Bruno Avenue frontage within Bayhill Regional Office. Housing may be provided combined with office uses permitted under the base BRO designation or as a standalone use, replacing office buildings. Up to 363 housing units are allowed. The amount of office square footage allowed on these sites is reduced when housing is built, as described in the Land Use Policies.

TRANSIT CORRIDORS PLAN
The City adopted the Transit Corridors Plan in February 2013 that focuses on high-density commercial and residential uses along the city’s transit corridor streets of El Camino Real, San Bruno Avenue, and San Mateo Avenue, adjacent to the Caltrain Station on San Bruno Avenue. The Plan implements the City’s 2009 General Plan Update which added transit-oriented development and mixed-use land use classifications. The Plan includes design guidelines, development regulations, parking standards, and an implementation strategy that will facilitate development of mixed-use projects in the area. The plan encourages ground floor commercial uses in areas with an existing strong retail concentration and at significant corner locations. Residential only uses are allowed. The plan provides for a maximum of 1,610 housing units within the plan area. Subsequent environmental review would be required to increase the maximum number of units. Most of the properties identified in the sites inventory in Chapter 7 are located within the TCP, accounting for 1,056 housing units.

Staff anticipates that full build out of the sites inventory would exceed the 1,610 housing units analyzed in the TCP EIR.

PARKING
In 2020, the City updated its parking requirements by incorporating parking policies and regulatory measures as adopted in the City’s General Plan and Transit Corridors Plan into the Zoning Ordinance. The updated parking requirements allow various parking reduction options such as mechanical stackers, in-lieu fees, tandem parking configurations and a reduced parking requirement for multi-family residential uses. The standards applicable to residential uses is shown in Table 3-1 below. Prior to the ordinance change, two parking spaces were required for all new dwelling units in the city, regardless of dwelling unit type or location.

A subsequent zoning code update in 2021 removed parking areas from counting against floor area 781 of 1863
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calculations. This change helped developers obtain more floor area in their projects for other uses, such as housing.

The community and economic development director shall determine the off-street parking requirements for a land use not listed in the parking table below. The director’s determination may be based on off-street parking requirements of similar uses, or the director may require the preparation of a parking demand study and/or a TDM plan to determine the parking requirement for an unlisted use.

Neighborhood parking is a concern of San Bruno residents adjacent to the city’s major commercial thoroughfares. Though San Bruno’s updated parking requirements are similar to the parking requirements in other cities in San Mateo County, they could still be considered a barrier to the development of affordable housing. Recent development applications and inquiries indicate that a lower parking space per unit ratio has been requested by housing developers, usually one parking space per unit, or less, regardless of number of bedrooms. Fewer parking spaces can increase the affordability of housing by lowering construction costs and allowing more units, particularly when the housing is transit-accessible and caters to smaller households that have less demand for parking. As most of the opportunity sites in this Housing Element cycle are infill redevelopment in transit accessible commercial corridors, this finding may apply to many of these parcels.

Since the City requires a minimum of 15% of units in every development to be affordable units, developers are consistently requesting a reduction in parking by requesting a concession pursuant to state density bonus law and generally providing parking at a 1:1 ratio. Furthermore, AB 2097, which eliminates minimum parking requirements for all uses located within a ½-mile of public transit, will take effect on January 1, 2023. This legislation would impact most of the housing sites identified in the sites inventory.

TABLE 3-1 RESIDENTIAL PARKING REQUIREMENTS
Use Category Land Uses Number of Required Parking Spaces General Residential
Multi-Family Residential Units
(Rental or Condominiums)
Studio and one-bedroom units: one space per unit
Two or more-bedroom units: two parking spaces per unit
Guest parking: one space per 10 units
Single-Family Homes, Duplexes,
and Triplexes
Two covered off-street parking spaces, defined as two-car garage or carport spaces, per dwelling unit
Source: City of San Bruno Community Development Department, Zoning Ordinance, 2022.

PLANNED DEVELOPMENT DISTRICT
The purpose of the P-D Planned Development District is to allow a mixture of land uses, density, or design relationships with a more flexible approach than is otherwise permitted in the City’s base zoning regulations.

The P-D process is initiated by the property-owner/developer, at which time the City Council establishes a P-D district based on a preliminary development plan. A Planned Development Permit is then issued for all uses within the district, which in turn allows the City and the developer flexibility in development standards and provision of amenities. Additionally, because land use planning, design, and environmental review occur simultaneously, the P-D zone enables the City to approve multiple uses in one consolidated process.

San Bruno’s largest Planned Development site is the former U.S. Navy site, now called The Crossing. Since 1999, the City has worked with the developer and consultants to prepare a U.S. Navy Site and Its Environs Specific Plan (January 2001, amended January 2002 and August 2005), entered into a Development Agreement (February 2002), and has granted building permits for all four phases of residential construction, resulting in the completion of 1,063 multi-family apartments. All four phases are complete as of 2011. Other large Planned Development projects under construction or approved include Skyline College, approved for 782 of 1863
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70 units in 2018 and completed in 2022, and Mills Park, approved for 427 units in 2020 and currently awaiting building permit submittal.

While the P-D allows development flexibility, it is a lengthier review process since it is a legislative act that requires City Council approval.

COMPREHENSIVE AIRPORT LAND USE COMPATIBILITY PLAN FOR THE ENVIRONS OF SAN FRANCISCO INTERNATIONAL AIRPORT (SFO ALUCP)
San Francisco International Airport (SFO) is located just east of San Bruno and is a major housing development constraint for neighborhoods located in the eastern portion of the city. The purpose of the SFO ALUCP is to provide for the orderly growth of the airport and the surrounding areas to minimize the public’s exposure to excessive noise and safety hazards. The SFO ALUCP is administered by the Airport Land Use Commission (ALUC) which is given authority to specify how land near airports is to be used based on the following concerns:
 Aircraft Noise Impact Reduction – To reduce the potential number of future airport area residents who could be exposed to noise impacts from airport and aircraft operations.  Safety of Persons on the Ground and in Aircraft in Flight – To minimize the potential number of future residents and land use occupants exposed to hazards related to aircraft operations and accidents.  Height Restrictions/Airspace Protection – To protect the navigable airspace around the Airport for the safe and efficient operation of aircraft in flight.
 Overflight Notification – To establish an area within which aircraft flights to and from the Airport occur frequently enough and at a low enough altitude to be noticeable by sensitive residents. Within this area, real estate disclosure notices shall be required, pursuant to state law.

California law requires that, after an ALUC has adopted its ALUCP, affected local governments must update their general plans, specific plans, and land use regulations to be consistent with the ALUCP. Alternatively, local governments may take steps, provided by law, to override part or all of the ALUCP as it relates to their jurisdiction. If the local government fails to take either action, then it must submit all land use development actions or facility master plans within the airport influence area to the ALUC for review (Public Utilities Code [PUC] Section 21676.5(a)). San Bruno is required to submit all land use development actions and master plans, including this Housing Element, to the ALUC for review. If any portion of the plan is found to be inconsistent with the SFO ALUCP, then the ALUC will determine the project inconsistent with their policies and the City will be notified of the inconsistency. If the City wants to adopt the Housing Element without changing it to address the ALUC’s determination, then it may override the ALUC’s decision with a two-thirds vote of its governing body. San Bruno is proposing housing at the Tanforan site, which is an incompatible land use per the ALUCP due to noise, so the City anticipates needing to approve an ALUC override.

Figure 3-2 shows the SFO ALUCP Map of Noise Compatibility Zones and the location of the Tanforan site within the zones.

With knowledge of the site constraints imposed by the SFO ALUCP, City Council adopted the Reimagining Tanforan Fact Sheet on July 27, 2021, articulating its vision for the redevelopment of Tanforan. The document included a vision of 1,000 housing units on the site in addition to other uses, signifying the City’s support for housing on the site through a master planning process.

Staff anticipates commencing with the ALUC review process in Fall 2022. The local override would be considered by Council at the same time as the Housing Element adoption. * 783 of 1863
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Figure 3-2 SFO ALUCP Map of Noise Compatibility Zones
Source: Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport, November 2012. 784 of 1863
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ZONING REGULATIONS
In March of 2021, San Bruno completed Phase II of the Zoning Code update. Among the many updates made was the rezoning of properties within the Transit Corridors Plan Area for consistency with the General Plan and the specific plan itself. A summary of the City’s zoning development standards is shown in Table 3-2. Since the rezoning was completed, the City has received 4 housing development proposals.

Within the mixed-use zoning districts, requirements mirroring the TCP development standards such as setbacks and stepbacks are included. Providing more objective design standards, with flexibility, would provide a more certain entitlement structure for the development community. A program has been added to adopt objective design standards.

The development standards for the residential districts rely upon the residential density for the General Plan land-use classification, which is applicable when developing large sites, such as the Engvall and Glenview Terrace projects, and an FAR is prescribed in R-1 and R-2 districts to control building size. There is no prescribed FAR within R-3 and R-4 districts. Minimum yard and lot coverage requirements are then applied in all residential districts. Other than FAR, the City has identified the minimum lot area per dwelling unit requirement in residential districts as an impediment to the creation of additional housing units. A standard size lot in San Bruno is 5,000 square feet. Since the lot area required per unit is 2,900 square feet in the R-2 zone, a standard size lot would not be permitted to have two dwelling units. A standard size lot in a R-3 district would only be permitted to have two dwelling units since the minimum lot area per unit is 1,950 square feet. A standard size lot in a R-4 district would be permitted to have three dwelling units, since the minimum lot area required per unit is 1,450 square feet. Permitting two dwellings in the R-2 District, regardless of lot size, would make it feasible to add more housing in the district. Additionally, base FAR requirements (.55 is the base FAR requirement), which generally allow 2,750 square feet of gross floor area and 2,200 square feet of lot coverage for a 5,000 square foot lot, are the same floor area standards applicable to the R-1 district, and apply regardless of housing type. The FAR requirement could be relaxed in the R-2 District to provide more development potential. This change would require a General Plan amendment to increase the residential density for the low-density residential land-use classification. Furthermore, this increase in the number of dwelling units per acre would require a vote of the people pursuant to Ordinance 1284, discussed later in this chapter. Other development standards (e.g., front and side setback, rear yard) for residential districts are comparable to development standards in other San Mateo County jurisdictions and are not perceived to be constraints to housing development.

DEVELOPMENT DENSITY
During the last cycle of 2015 through 2023, San Bruno entitled over 703 housing units in major residential projects.

Six-hundred and four of those units were attached multi-family units and the remaining 99 units were in two residential subdivisions (Skyline College, Glenview Terrace). All of the sites were approved at the maximum density permitted by the zoning district. The TCP sites are not subject to dwelling unit density restrictions, which accounts for most of the multi-family sites. 271 El Camino Real is the only multi-family site subject to dwelling unit density restrictions (40 units per acre), and it was approved at the maximum density. The residential subdivisions were rezoned as part of the project entitlement with approved densities exceeding Low-density Residential requirements (2.1 – 8.0 units/acre). The Skyline College subdivision is unique because it included both a detached single-family component and a multi-family component. For detached single-family subdivisions, developers generally request smaller lot development, 3,300 square feet on average as opposed to 5,000 square feet., and relaxation of setback and yard requirements. What these approved projects show is that developers are interested in developing residential units to the highest density permitted.
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TABLE 3-2 CITY OF SAN BRUNO PROPERTY DEVELOPMENT REGULATIONS FOR RESIDENTIAL DISTRICTS R-1/R-1-D R-2 R-3 R-4
Minimum Building Site Required (sq ft) 5,000 interior lot 6,000 corner lot
5,000 interior lot
6,000 corner lot
5,000 interior lot
6,000 corner lot
5,000 interior lot
6,000 corner lot
Minimum Lot Area per Unit (sq ft) n/a 2,900 1,950 1,450 Minimum Lot Width (ft) 50 interior lot
60 corner lot
50 interior lot
60 corner lot
50 interior lot
60 corner lot
50 interior lot
60 corner lot
Maximum Lot Coverage 80% impervious surface
40% structures
85% impervious surface
55% structures
85% impervious surface
60% structures
85% impervious surface
60% structures
Minimum Yards (ft)
Front 15 15 15 15
Side 5 interior sides
10 street sides
5 interior sides
10 street sides
5 interior sides
10 street sides
5 interior sides
10 street sides
Rear 10 10 10 10
Minimum Setback from Sidewalk to Garage (ft) 20 20 20 20 Maximum Height (ft) 26 – 30 26 - 30 50 ft or 3 stories, whichever is most restrictive
50 ft or 3 stories,
whichever is most restrictive
Parking (see parking Table 3-1 above)
Source: City of San Bruno Community Development Department, Zoning Ordinance, 2022. 786 of 1863
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TABLE 3-3 CITY OF SAN BRUNO PROPERTY DEVELOPMENT REGULATIONS FOR MIXED-USE DISTRICTS CBD TOD-S TOD-1 TOD-2 CC MX-R
Maximum Storefront Width (ft) 25 100 100 100 100 100
Maximum FAR
Parcels less than 20,000 sq ft 2.0 2.0 2.0 2.0 2.0 2.0
Parcels 20,000 sq ft or greater n/a n/a n/a n/a n/a Residential: 3.0 Nonresidential: 0.6
Minimum Setbacks (ft)
Front 10 5 5 5 15 5
Street Side 5 5 5 5 10 5
Rear if adjacent to R-1 or R-2 10 10 10 10 10 10
Minimum Stepbacks (ft)
Facing Corridor Street 15 ft above 3rd story 15 ft above 4th story 15 ft above 3rd story 15 ft above 4th story 15 ft above 4th story n/a Adjacent to R-1 or R-2 15 ft above 3rd story 15 ft above 3rd story 15 ft above 3rd story 15 ft above 3rd story 15 ft above 3rd story n/a Maximum Height (ft) 55 ft and 5 stories 65 ft and 5 stories; 90 ft or 7 storiesa 65 ft and 5 stories 70 ft and 5 stories 70 ft and 5 stories 50 ft and 3 stories Minimum Required Open Space (sq ft) per
Residential Unit 40 40 40 40 40 40
Parking Location and Buffers
Surface
Underground (Partially)
Underground (Completely)
Surface Adjacent to Street-Facing Property
Line
Landscaped Buffer
On-Site Loading Area
Shall be located to the rear or side of buildings. May not be located between a building and a street-facing property line.

May match the setbacks of the main structure. The maximum height of a parking podium is 5 ft from finished grade.

No setbacks requirement. Shall accommodate installation of private utilities on private property and dedicate public utility easements, as needed.

Shall be screened along the public right-of-way with a decorative wall, hedge, trellis, and/or landscaping at least 3 ft.

At least 3 ft in width and 6 ft in height shall be provided for any surface parking lot abutting a residential zoning district.

Shall be located to the side and rear of buildings and shall be sufficiently screened from the public right-of-way. a Maximum building height allowed west of San Mateo Avenue.

Source: City of San Bruno Community and Economic Development Department, Zoning Ordinance, 2022. 787 of 1863
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REASONABLE ACCOMMODATIONS
Both the Federal Fair Housing Act (FHA) and the California Fair Employment and Housing Act (FEHA) mandate that cities include “reasonable accommodations” in their land use regulations when necessary to provide housing for disabled persons (42 U.S.C. Section 3604(f)(3)(B); Government Code Section 12927(c)(1), 12955(1)). Reasonable Accommodation is to provide reasonable exceptions to zoning and land use regulations (such as minimum setbacks) if the reason is for improving the accessibility of one’s home. These fair housing requirements are included in California’s Title 24 regulations, which are currently enforced by the City through its Zoning Ordinance (SMBC

12.240), building codes, plan review, and site inspections processes.

The San Bruno City Council adopted a Reasonable Accommodation Ordinance in 2014 (Ordinance 1825), amending the City’s Zoning Ordinance to provide exceptions in zoning and land use for housing for persons with disabilities in compliance with state law. A request for reasonable accommodation may be made by any person with a disability, their representative, or any entity, when the application of the zoning ordinance or other land use regulations, policy, or practice acts as a barrier to fair housing opportunities. The ordinance requires a separate application and allows the community development director or designee to grant a reasonable accommodation request based on consideration of the following findings:

A. Whether the housing which is the subject of the request will be used by an individual with a disability thereunder;
B. Whether the request for reasonable accommodation is necessary to make specific housing available to an individual with a disability;
C. Whether the requested reasonable accommodation would impose an undue financial or administrative burden on the City;
D. Whether the requested reasonable accommodation would require a fundamental alteration in the nature of a city program or law, including but not limited to land use and zoning; E. Potential impacts on surrounding uses;
F. Physical attributes of the property and structures; and G. Other reasonable accommodations that may provide an equivalent level of benefit.

Reasonable accommodation requests that are consistent with setback exceptions can be approved ministerially at time of building permit review. For example, a request for building a wheelchair ramp is processed over the counter and requires only a building permit if it complies with the Code exception which allows a ramp to extend 6 feet into the 15-foot front yard setback. Additionally, all building permits submitted in San Bruno are reviewed against the current California Building Code, as adopted by the City. No local amendments to these codes would diminish the ability of the City to accommodate persons with disabilities. Retrofits and building improvements made according to the Americans with Disabilities Act (ADA) are reviewed by the Building Division.

RESIDENTIAL CARE FACILITIES (INCLUDING SUPPORTIVE AND TRANSITIONAL HOUSING) Health and Safety Code Sections 1267.8, 1566.3, and 1568.08 require local governments to treat licensed group homes and residential care facilities with six or fewer residents no differently than other by-right single-family housing uses. “Six or fewer persons” does not include the operator, the operator’s family, or persons employed as staff. Local agencies must allow these licensed residential care facilities in any area zoned for residential use and may not require licensed residential care facilities for six or fewer persons to obtain conditional use permits or variances that are not required of other family dwellings.
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The City updated its Zoning Ordinance in March 2021 to ensure consistency with fair housing laws. The update included an amendment to regulate “special residential care facilities” that is consistent with state law. Residential care facilities of any size are allowed by right in the R-1, R-2, R-3, and R-4 residential zones. “Residential care facility” means a licensed residential facility providing social and personal care for residents. Examples include children’s homes, supportive and transitional houses, orphanages, rehabilitation centers, self-help group homes, and transitional housing for homeless individuals. The definition of a residential care facility excludes facilities where medical care is a core service provided to residents, such as nursing and convalescent homes. A large residential care facility is a residential care facility for seven or more persons. A small residential care facility is a residential care facility for less than seven persons. Regardless of the number of patients allowed in a residential care facility, residential care facility is seen the same as any residential use. The Fire Department and Building Division inspect the residential care facility for compliance with codes as part of the building permit process. No noticing (or community input) is required for the establishment of a new or renovated residential care facility.

Unlicensed residential facilities are subject to the same permitting requirements but must obtain a license from the state licensing agency before commencing operation.

Residential care facilities are allowed in any zoning district in San Bruno and there is no requirement for minimum distances from one to another residential care facility. There is no explicit requirement that would preclude a specific type of special residential care facility to be established, which could include supportive, transitional, or emergency housing. Supportive and transitional housing are permitted just as any other residential uses. Residential care facilities differ from boarding homes which are dwellings, other than a hotel, where lodging and meals for three or more persons is provided for compensation with a host for a rental period of thirty or more consecutive calendar days.

2. ORDINANCE 1284 HEIGHT AND DENSITY LIMITS
Ordinance 1284 was adopted by City Council in June 1977 and imposed city-wide height and density limits that constrain higher density residential development in the city. The Ordinance was intended to preserve the existing character of San Bruno by requiring voter approval for certain buildings.

Under Ordinance 1284, permits and approvals cannot be issued to allow construction of the following types of buildings, projects, and improvements, unless approved by a majority of voters at a regular or special election:
 Buildings or other structures exceeding 50 feet in height.  Buildings or other structures exceeding three stories in height.  Buildings or other structures, modifications or redevelopment thereof in residential districts which increase the number of dwelling units per acre or occupancy, within each acre or portion thereof, in excess of limits permitted on October 10, 1974, under the then existing Zoning Chapter of the City of San Bruno;  Multi-story parking structures or buildings; or
 Buildings or other structures, modifications, or redevelopment thereof which encroach upon, modify, widen, or realign the following streets hereby designated as scenic corridors: Crystal Springs Road between Oak Avenue and Junipero Serra Freeway, or Sneath Lane from El Camino Real to existing westerly city limits.

Each of the five restrictions under Ordinance 1284 places additional limits regarding future residential development within the city. However, the City has a considerable amount of housing capacity within the TCP area that is also within close proximity to public transit to facilitate future housing production.

Ordinance 1284 is most restrictive to existing residential zoned parcels because of the limits imposed on increased densities (See below for a description of the treatment of second units specifically). This is because the ordinance was designed as a preservation measure. However, Ordinance 1284 is not considered a major constraint to affordable housing development in this Housing Element because most identified housing opportunity sites are located in the 789 of 1863
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TCP area where height limits have increased due to the passage of Measure N, as described in the next section below. Height limits of 50 feet still apply in other parts of the city, but in general the provisions of Ordinance 1284 are limited in scope and applicability for these parcels. For instance, Ordinance 1284 does not prohibit any of the following along the target corridors:
 Rezoning areas from commercial to residential use at any residential density standard.  Permitting mixed-use development on commercially zoned properties at any residential density standard.  Residential redevelopment on former school sites, consistent with zoning; and  Below ground (more than 50% below grade) parking facilities.

Ordinance 1284 impacts existing low-density residential housing sites such as the former Engvall school site. Per Ordinance 1284, the Engvall school site, which has a low-density General Plan designation, cannot be upzoned to increase the number of dwelling units per acre. However, a planned unit permit (PUP) can be utilized to encourage creative use of land and open space by permitting carefully controlled relief from the strict application of the provisions of existing zoning districts. The PUP allows flexibility and diversification in the relationship of various buildings, structures, and open spaces in planned building groups. While the PUP can be used to create attached single-family dwellings, it cannot be used to increase overall housing density or create multi-family housing.

Due to the built-out nature of San Bruno, the ability to construct multi-story parking structures in other parts of the city is limited less by Ordinance 1284 than by available parcel size. More likely candidates for parking facilities are in the TCP area where development sites have the potential for consolidation, such as the San Bruno Gas site adjacent to the Bedroom Express site. The passage of Measure N has removed the constraints to constructing above-ground multi-story parking structures in the TCP area.

Potential constraints to housing development as a direct result of declaring Crystal Springs Road and Sneath Lane as scenic corridors are also minimal. Major adjacent properties include the Golden Gate National Cemetery, City Park, Junipero Serra County Park, and interstate highway rights-of-way, all of which are already unsuitable locations for housing development. Moreover, the designation of these two roadways does not prohibit development, but merely the widening of the roadways themselves.

Although high densities are permitted by the General Plan along major corridors (with no limit on density for individual development projects in the TOD designation), some development professionals have indicated that the building height limit of Ordinance 1284 (50 feet and three stories) is a potential constraint on the feasibility of developing high-density housing along commercial corridors outside of the TCP area.

Sites identified in this Housing Element are feasible at the specified densities whether or not Ordinance 1284 remains in effect. However, changes to Ordinance 1284 would make the development of housing throughout the community more economically feasible outside of the identified sites.

3. MEASURE N
The City Council placed a ballot measure, Measure N, the Economic Enhancement Initiative, on the November 4, 2014 ballot to amend Ordinance 1284 and facilitate the implementation of the Transit Corridors Plan. San Bruno voters approved Measure N overwhelmingly with 67.3% of the vote. The revised development standards allowed the development of multi-family housing along major commercial streets within about a ½-mile of the new San Bruno Caltrain station.

Measure N modifies Ordinance 1284 to permit the following:
 Buildings exceeding the current 50-foot or three-story maximum height as follows: up to 70 feet or five stories along El Camino Real, up to 65 feet or five stories along San Bruno Avenue, up to 55 feet or four stories along San Mateo Avenue, and up to 90 feet or seven stories in the Caltrain station area. 790 of 1863
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 Rezoning of 42 low-density residential parcels to become a part of the TCP area and allow higher density residential development.
 Above-ground, multi-story parking garages.

A similar effort to Measure N would need to be approved by voters to increase heights outside the Transit Corridors Plan boundaries or increase residential densities in any of the city’s residential districts. As previously stated, none of the density assumptions for the sites identified in the inventory in Chapter 7 are dependent on changes to Ordinance 1284. It is mentioned here as an option requiring further exploration.

4. ACCESSORY DWELLING UNITS (ADUS)
Ordinance 1898, adopted by City Council in March 2021, makes the City’s ADU Ordinance consistent with state ADU laws. ADU applications are processed through a ministerial process, without discretionary review or hearing.

Most ADUs were approved without any additional parking. ADU size and setback requirements are consistent with state law, but larger units would be subject to additional review. ADUs over 750 square feet are subject to the City’s development impact fees at a proportional rate.

The City issued building permits for 68 ADUs in 2021, a significant increase over the previous year. A potential reason for the substantial increase is that in 2020 the City was still requiring a separate planning review for ADUs and 51 ADU approvals were issued but only seven were issued building permits. ADU production is measured based on building permits issued. The City removed the two-step review process in March 2021, no longer requiring a separate ADU planning entitlement process which has led to a significant increase in building permits issued for ADUs in 2021, even though the overall number of ADU applications submitted remained consistent. Projecting forward, staff estimates ADU construction to be more in line with the City’s 2020 and 2021 production of 51 to 68 units per year.

5. MANUFACTURED AND FACTORY-BUILT HOUSING
State law limits the extent to which cities and counties can regulate the installation of manufactured homes, including mobile homes. Government Code Section 65852.3 requires that cities allow installation of certified manufactured homes on foundation systems on lots zoned for conventional single-family residences. This section and Government Code Section 65852.4 generally require that manufactured homes be subject to the same land use regulations as conventional homes. Government Code Section 65852.7 deems mobile home parks to be a permitted use in all areas planned and zoned for residential use. Manufactured and factory-built housing is permitted in all residential zoning districts. Because of the high cost of land, manufactured housing is not commonly placed on private property.

San Bruno City CouncilJanuary 24, 2023

San Bruno City Council
January 24, 2023