San Bruno City Council
January 24, 2023

Chapter 6
Sites
Inventory
Small and Large
Sites 29
Sites smaller than half an acre or greater than ten acres are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated, with sufficient evidence, that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the housing element describes other evidence to HCD that the site is adequate to accommodate housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(A).) Based on the outcomes of the analysis, the element should add or modify programs.

The city imposes a 15% affordable
housing requirement on all
residential developments of 5+
units. This requirement applies to
sites that don't meet the default
density requirement.

1416 of 1863
Chapter 6
Sites
Inventory
Suitability of
Nonvacant Sites 30
The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as former schools, and a gas station; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also support, based on recent development trends, indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.

Additional information has been
added to Chapter 6. Table 6-6
Chapter 6
Sites
Inventory
Suitability of
Nonvacant Sites 31
The housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.

City needs to adopt a resolution Finding included in
resolution
Chapter 6
Sites
Inventory
Tanforan Site 32
The element should describe feasibility and timing of development during the planning period and add or modify programs as appropriate. The element mentions an agreement with the developer for a minimum of 1,000 units but it should describe timing, whether a specific plan is needed, and affordability assumptions on the site. The element should also address any known constraints to development (e.g., airport compatibility) and modify programs to ensure the availability of the site or identify alternative sites.

Added to table 6-6 see page 6-24
1417 of 1863
Chapter 6
Sites
Inventory
Sites Identified
in Multiple
Planning Periods
33 Sites identified in prior planning periods shall not be deemed adequate to accommodate the housing needs for lower-income households unless a program, meeting statutory requirements, requires rezoning within one or three years, whichever is applicable. If utilizing sites outside of the Transit Corridors Specific Plan for the lower-income RHNA, the element should clarify if sites were identified in prior planning periods and if so, which sites and include a program.

The program should ensure sites will meet density requirements and allow by-right
approval for housing developments that include 20 percent or more of its units affordable to lower income households.

Identified sites that require from
previous HE cycles in Table 6-4
see pages 6-13 - 6-
15 Chapter 6
Sites
Inventory
Accessory
Dwelling Units
(ADU)
34 The element projects 345 ADUs over the planning period or approximately 43 ADUs per year over the eight-year planning period.

These
trends are inconsistent with HCD records (6 reported in 2018, 17 in 2019, 7 in 2020,and 70 in 2021) and do not support an assumption of 43 ADUs per year. To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., 6 months) if needed. The element must also address affordability assumptions for ADU projections.

Estimated ADU production has
been revised to be consistent with
HCDs feedback. Monitoring
program added.
page 6-22
Chapter 6
Sites
Inventory
AB 725 35
For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater). (Gov. Code, § 65583.2, subd. (c)(4).) Of the 23 sites in the inventory,
only the two San Marco sites allow
less than four units of housing.

Chapter 6
Sites
Inventory
Quantified
Objectives 36
The element generally did not address this requirement. The element must include quantified objectives for construction, rehabilitation, and conservation by income group, including extremely low-income households. Please see the Building Blocks for additional information.

Quantified objectives section
added. page 6-24
1418 of 1863
Chapter 3
Housing
Constraints &
Resources
Infrastructure 37
While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the RHNA for the planning period and add or modify programs if necessary.

Mostly addressed in chapter 3 but
also mentioned in chapter 6.

Chapter 3
Housing
Constraints &
Resources
Environmental
Constraints 38
While the element generally describes a few environmental conditions within the City, it must describe any other known environmental constraints or conditions within the City that could impact housing development in the planning period.

This section covered flooding,
geology (earthquakes), noise, and
air quality. Hazardous materials
has been added to the discussion.
page 3-32
Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesEmergency
Shelters
39 The element should describe the development standards of the M-1 zone that allows emergency shelters by-right and should provide an analysis of proximity to transportation and services for these sites, hazardous conditions, and any conditions in appropriate for human habitability. In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement
Emergency Shelters: Allow
sufficient parking to accommodate
all staff working in the emergency
shelter, provided that the standards
do not require more parking for
emergency shelters than other
residential or commercial uses
within the same zone, in
compliance with Government Code
Section 65583(a)(4)(A)(ii). Adopt
development standards for
emergency shelters and ensure
they are consistent with State law
per California Government Code
Section 65583(a)(4)(A)(ii).

Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesTranstional
Supportive
Housing
40 Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential
uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (c)(3).) The element must describe and analyze the City’s transitional and supportive housing standards and codes and demonstrate consistency with Section 65583(c)(3) or add or revise programs to comply with the statutory requirements.

Pursuant to Government Code
Section 65583, transitional and
supportive housing types are
required to be treated as
residential uses and subject only to
those restrictions that apply to
other residential uses of the same
type in the same zone. The Zoning
Ordinance allows supportive and
transitional housing in all
residential districts and in all zones
that allow multifamily and mixed
use development including
nonresidential zones, per
1419 of 1863
Government Code Sections 65583
and 65650. Program 21 include
actions to comply with State Law
regarding transitional and
supportive housing types.

Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesBy-Right
Permanent
Supportive
Housing
41 Supportive housing shall be a use by right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.

These uses are defined as
residential care facilities and are
permitted in all zoning districts
where housing is permitted.
page 3-13
Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesLow Barrier
Navigation
Centers
42 While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones. Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate.

Discussion added. page 3-16
Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesSingle Room
Occupancy
(SRO) Units
43 Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate. Program added to allow SROs page 3-17 Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesEmployee
Housing
44 The element must demonstrate the City’s zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and, if necessary, add or modify programs. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone.

Employee Housing
Consistent with Health and Safety
Code Sections 17021.5 and
17021.6, employee housing is
permitted by
right in every residential zone,
including single family zones.

Additionally, in 2012, the City
page 3-17
1420 of 1863
amended its
Zoning Code definitions to define
“family” to include employee
housing.

Chapter 3
Housing
Constraints &
Resources
Zoning for a
Variety of
Housing TypesAccessory
Dwelling Units
45 While the City does have an ADU ordinance, it is currently under review by HCD for consistency with State ADU Law. HCD will provide communication of ADU compliance issues under a separate cover. If necessary, the element should add a program to update the City’s ADU ordinance to comply with state law.

City's ADU ordinance has been
forwarded to HCD for review.

Chapter 3
Housing
Constraints &
Resources
Land Use
Controls 46
The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. The element should analyze the interaction of the General Plan designation for high density residential allowing 24-40 dwelling units an acre, but the R-4 zoning district limits densities to 30 dwelling units an acre and whether the maximum density in the R-4 is a constraint. In addition, the element must analyze whether the garage setbacks apply to multifamily developments and whether they are a constraint on housing. On page 3-6, the element lists parking requirements for “general residential”; it should also clarify whether parking requirements for mixed-use zones differ than the general residential parking requirements and add a program as appropriate. Lastly, the element states that the full build-out of the sites located in the TCP would exceed the maximum of 1,610 units allowed under the current Environmental Impact Report (EIR). The element must analyze whether exceeding the allowed units is a constraint and either adjust capacity assumptions or add programs as appropriate.

Discussion added. Page 3-16
See Program 1-I
Chapter 3
Housing
Constraints &
Resources
Fees and
Exaction 47
While the element describes many fees and the typical deposit range, it must describe all required fees for single family and multifamily housing development, including all impact and regional fees, and analyze their impact as potential constraints on housing supply and affordability. In addition, the analysis should identify the total amount Table 3-10 includes all required
fees for SFD and MFD project
types. A separate section on
Impact Fees has been added but
page 3-24
1421 of 1863
of fees and their proportion to the development costs for both single family and multifamily housing.
these fees are included in the
amounts shown in the table.

Chapter 3
Housing
Constraints &
Resources
Local
Processing and
Permit
Procedures
48 While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information. The analysis should address impacts on housing cost, supply, timing, and approval certainty.

Section added. page 3-9
Chapter 3
Housing
Constraints &
Resources
Design Review 49
The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Discussion added. page 3-16
See Program 1-I
Chapter 3
Housing
Constraints &
Resources
State Density
Bonus Law 50
The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.)
The city's density bonus ord. was
updated in 2021 and is consistent
with state law. Density bonus
section discussion has been
added.
page 3-19
Chapter 3
Housing
Constraints &
Resources
Streamlining
Provisions 51
While the element states that they followed SB 35 procedures for a prior project, it should clarify whether the City has procedures in place consistent with streamlining procedures pursuant to Government Code section 65913.4 and include programs as appropriate.

The City will comply with SB 35
(Gov. Code Section 65913.4) by
maintaining a written policy and
procedure, as well as other
guidance as appropriate, to
streamline the approval process
and standards for eligible projects.

A program has been added to
complete this work within one year
of HE adoption.
page 3-19
1422 of 1863
Chapter 3
Housing
Constraints &
Resources
On/Off-Site
Improvements 52
The element must identify typical subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width), and analyze their impact as potential constraints on housing supply and affordability.

Subdivision improvements included
with off-site improvements. page 3-20
Chapter 3
Housing
Constraints &
Resources
Constraints on
Housing for
Persons with
Disabilities
53 The element identifies approval findings for granting a reasonable accommodation including finding related to impacts on surrounding uses – essentially a conditional use permit finding. However, reasonable accommodation should be a unique exception process from a conditional use permit, especially given its importance in addressing barriers to housing for persons with disabilities. The element should include a program to amend the Reasonable Accommodation Ordinance and remove constraints, including but not limited to the “potential impact on surrounding uses” approval finding.

In addition, while the element states that unlicensed residential care facilities must require a license from the state licensing agency before operation, zoning and standards should simply implement a barrierfree definition of family instead of subjecting, potentially persons with disabilities, to special regulations. Zoning code regulations that isolate and regulate various types of housing for persons with disabilities may pose a constraint on housing choice for persons with disabilities.

The element should include specific analysis of these and any other constraints for impacts on housing for persons with disabilities and add or modify programs as appropriate. Lastly, the element must describe and analyze any definitions of family used in zoning and land use for impacts on housing for persons with disabilities and add or modify programs as appropriate.

A program to update the city's
reasonable accommodation
findings was added to Chapter 7.

See program 4-D on
page 7-23.

Chapter 3
Housing
Constraints &
Resources
Availability of
Financing 54
The element must describe the availability of financing, including private financing and government assistance programs, is generally available in the community.

Homeownership financing and
affordable housing financing
added.
pages 3-27, 3-28
Chapter 3
Housing
Constraints &
Resources
Developed
Densities and
Permit Times
55 The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.

Permitting times and Development
density sections added
pages 3-7, 3-24 - 3-
25 1423 of 1863
Chapter 7
Programs
Program 1-E & 1-
F 56
Programs 1-E (Publicly Post Status Updates) and 1-F (Consolidate Fee Schedules): These programs should clarify how often the listings will be updated.

Programs updated. pp. 7-4 ; same
program label
Chapter 7
Programs
Programs 2-A, 2-
E, 3-B, 4-A, 4-E,
5-B, 8-A
57 Program 2-A (Study the South El Camino Real Corridor), 2-E (SB 9 Implementation Guidelines), 3-B (Displaced Residents), 4-A (Reasonable Accommodations), 4-E (Home Sharing Opportunities), 5-B (Affordable Housing Fund Resources), 8-A (Create an Affirmative Marketing Strategy): These programs should include proactive outreach and specify how often it will occur
throughout the planning period.

All programs have been updated to
include outreach component and
frequency. Some of the goals and
programs were reorganized, the
new program reference numbers
are listed in the following column.

Former 2-A was
incorporated into an
action item in former
2-B and 2-B was
relabeled as 2-A.

Former 3B is New 4-
G; Former 4-A is an
action item in the
New 4-C; Former 4-
E is New 4-M;
Former 5-B is New
3-B; Former 8-A is
an action item under
New 4-A
Chapter 7
Programs Program 2-B 58
Program 2-B (Evaluate Ballot Initiative): This program should include public outreach. In addition, the program must be implemented earlier in the planning period to ensure beneficial impact and include specific commitment to the action.

Included outreach component and
reduced timeframe for
implementation by half. This
program was expanded to include
six specific actions and it was also
combined with Program 2A (Study
the El Camino Corridor) which was
closely related.
pp. 7-6; program 2-A
and 2-B combined
into current program
2-A
Chapter 7
Programs Program 2-C 59
Program 2-C (Support Development of Housing Opportunity Sites):

This program should clarify how often outreach will occur and whether incentives will be provided.

Outreach information and incentive
information included.
pp. 7-6; program is
now 2-B
Chapter 7
Programs Program 2-G 60
Program 2-G (Publicize Affordable Housing Financing Strategies):

The program should clarify how often outreach will occur and sources will be updated.

Programs updated with frequency
information.
pp.7-8; program is
now 2-F
Chapter 7
Programs Program 4-B 61
Program 4-B (Fair Housing Training for Landlords and Tenants): This program should commit to additional trainings during the planning period.

Program updated to minimum of
one training per year.
pp. 22 Same
program label
1424 of 1863
Chapter 7
Programs Program 4-C 62
Program 4-C (Publicize Affordable Housing Financing Strategies):

The program should clarify how often outreach and coordination will occur. In addition, it should include timing of when the in-lieu fee strategy will be developed.

Programs updated with frequency
information and timing for in lieu
fee strategy.

Former 4-B is New
2-F
Chapter 7
Programs Program 4-D 63
Program 4-D (Nexus Study for Affordable Housing Program): The program should include an action and timing to implement the results of the study.

Added implementation action item
and timeframe for implementation
Former 4-D is New
2-I; the language in
2-I was edited and
includes former 4-D
Chapter 7
Programs Program 4-G 64
Program 4-G (Affordable Unit Set-Aside): The program should include implementation beyond research as well as include proactive outreach.

Implementation, outreach, and
timeframes have been added.

Former 4-G is New
4-O
Chapter 7
Programs Program 4-I 65
Program 4-I (Increase Supply of Housing for Large Families): The program should clarify what actions will be taken to encourage large units, such as incentives. The element should also include outreach to developers
This program was added into new
program 2-F on providing housing
for residents with disproportionate
housing needs and ELIs. Outreach
info added. Some options for
incentives were added but will be
further considered.

Former 4-I is New
Action Item under 2-
F.

Chapter 7
Programs Program 5-C 66
Program 5-C (Revise Affordable Housing Ordinance): The program should include back-up actions if the existing action is deemed infeasible.

Back up action and timing
included.

Former 5-C is New
3-C
Chapter 7
Programs Program 5-D 67 Program 5-D (Retain Public Land): This program should clarify what is being implemented and include timing.

Program clarified and timing
included.

Former 5-D is New
3-D
Chapter 7
Programs Program 5-E 68
Program 5-E (Expedite Review of 100% Affordable Housing Projects): The program should clarify what the timing is tied to if the program is continuing.

Revised program, this is a
continuing program.

Former 5-E is
incorporated into 1-
C. Former 5-E and 1-
C were similar
programs. This is
also an action item
under 2-G
(Encourage
production of ELIs)
Chapter 7
Programs Program 6-A 69
Program 6-A (Replacement of Below Market Rate Units): The timing of this program should be earlier in the planning period to ensure beneficial impact.

Timing updated from three years to
one and a half years from
certification.

Former 6-A is New
3-G
1425 of 1863
Chapter 7
Programs Program 8-B 70 Program 8-B (Partner with Local Fair Housing Organizations): The program should include timing of how often training will occur. Added timing of at least annually. Former 8-B is New 4-B Chapter 7
Programs
Program 2-F
(Require a
minimum of
1,000 Housing
Units on
Tanforan Mall
Project):
71 This program should clarify whether incentives will be provided for affordable units, what actions will be implemented to ensure a set aside for persons with disabilities, how often outreach will occur, and clarify what will be implemented within the identified timeframe.

Information was added. See note.
pp. 7-8; see
programs 2-F and 4-
O
Chapter 7
Programs
Program 2-H
(Release RFP for
City-Owned
Sites)
72 The element identified City-owned sites to accommodate a portion of the RHNA. The element should include a program with numerical objectives that ensures compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing and financial assistance. In addition, a similar program should be added for school owned sites.

Expanded this program to include
these items as a part of the
housing development feasibility
study. No program was added for
school owned sites specifically
because these sites have already
completed the disposition process
and have submitted development
applications to the city.

Program 2-I
Chapter 7
Programs

ADD NEW
PROGRAM 73
The element must include a program(s) with specific actions and timelines to assist in the development of housing for extremely lowincome households. The program(s) could commit the City to adopting priority processing, granting fee waivers or deferrals, modifying development standards, granting concessions and incentives for housing developments that include units affordable to extremely low-income households; assisting, supporting or pursuing funding applications; and outreach and coordination with affordable housing developers.

Two new programs added. Program 2-G and
Program 2-H
Chapter 7
Programs

ADD NEW
PROGRAM 74
The element must also include a program(s) to assist in the development of housing for all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, femaleheaded households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

New program added. Program 2-F
1426 of 1863
Chapter 7
Programs
Programs 2-A
and 2-B

HEIGHTS
75 Heights: Programs to address restrictions on heights (Programs 2-A and 2-B) should specifically commit to take an initiative to the ballot by a specified date and complete alternative actions by a specific date if the ballot initiative is not passed.

Program expanded with additional
detail. No backup plan needed
because these units are not
needed to meet our RHNA.

Program 1-L
Chapter 7
Programs
Short Term
Rentals 76
Short Term Rentals: As noted in the element, a program should be added or modified to conduct research and take action as appropriate by a specified date.

New program added. Program 1-H
Chapter 7
Programs

ADD NEW
PROGRAM 77
The element must include a program(s) to conserve and improve the condition of the existing stock, which may include addressing the loss of dwelling units. A program could provide grants for substantial rehabilitation, provide matching grants for homeowner improvements, or implement proactive code enforcement program.

Added program. Program 3-E
Chapter 7
Programs
Program 4-H
(Promote
Accessory
Dwelling Unit
Ordinance):
78 The program should include proactive outreach throughout the planning period. In addition, the program should include incentives beyond the City’s ordinance and webpage and commit to monitor permitted ADUs and affordability every other year and take appropriate action such as adjusting assumptions or rezoning within a specified time (e.g., 6 months) if assumptions are not realized.

This is program 4-P- revised to
incorporate comments.

Former Program 4-H
is new Program 4-P.

Program was
revised.

Chapter 7
Programs
General
Comment 79
As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

Site analysis completed. New
programs added.

New program 2-A
(former 2-A and 2-B)
was revised with new
action items. New
programs 2-G, 2-H,
2-I and 2-K.
1427 of 1863
Chapter 7
Programs
Shortfall of
Adequate Sites 80
If the element does not identify adequate sites to accommodate the regional housing need for lower-income households, it must include a program(s) to identify sites with appropriate zoning to accommodate the regional housing need within the planning period. The program should identify the shortfall by income group, acreage, allowable densities, appropriate development standards and meet all by right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i), including but not limited to permitting multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower income households.

Draft Element submitted to HCD
identified adequate sites to
accommodate the regional housing
need for lower income households.

No additional
program required.

Chapter 7
Programs
General
Comment 81
As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and non-governmental constraints.

Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

Analysis completed and new
programs added.

New programs
added 1-H, 3-E, 3-G
and 3-H.

Chapter 7
Programs
General
Comment 82
As noted in Finding B1, the element must include a complete analysis of Affirmatively Furthering Fair Housing (AFFH). The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends.

Analysis completed and new
programs added.

New AFFH
Programs added 4-
E, 4-H, 4-I, 4-K, 4-O,
4-L, 4-Q, 4-R, and 4-
S.

Chapter 5
Public
Participation
Translation
Services 83
While the element includes a summary of participation including outreach to the community, it must also describe whether translation services were available during public participation including, but not limited to, public workshops, Planning Commission, and City Council meetings.

Materials that were distributed
were translated into Spanish and
the city website uses a translation
plug-in for translating content.

Translation services were available
at 21 Elements meetings but only
available at local meetings upon
prior request.
1428 of 1863
Chapter 1
Introduction
Consistency
with the General
Plan
84 While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period.

General Plan language added. page 1-5
1429 of 1863
Exhibit D
GENERAL PLAN AMENDMENT TO POLICY HS-40
1430 of 1863
General Plan
Policy
Existing Policy Language Proposed Policy Amendment
HS-40 Prohibit new residential
development within the 70+
Airport CNEL areas, as dictated
by Airport Land Use Commission
infill criteria.

Prohibit new residential development within the
70+ Airport CNEL areas, as dictated by Airport
land Use Commission infill criteria, unless, on a
project by project basis, a proposed residential
development is approved through the Local
Agency Override process consistent with the
Public Utilities Code Section 21675.1(d).
1431 of 1863
Exhibit E

CALIFORNIA DEPARTMENT OF HOUSING AND

COMMUNITY DEVELOPMENT (HCD)

REVIEW COMMENTS ON
SAN BRUNO’S 2023-2031 DRAFT HOUSING ELEMENT
UPDATE SUBMITTED JULY 2022
1432 of 1863
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
October 6, 2022
Darcy Smith, Interim Director
Community & Economic Development Department
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
Dear Darcy Smith:

RE: City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of San Bruno’s (City) draft housing element received for review on July 8, 2022, along with revisions received on October 3, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on September 16, 2022 with yourself, Michael Laughlin, Michael Smith, Kristie Woo, and consultant Sabina Mora. In addition, HCD considered comments from San Francisco International Airport, Housing Leadership Council of San Mateo County, and YIMBY Law and Greenbelt Alliance pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).

The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until rezones to accommodate a shortfall of sites pursuant to Government Code section 65583, subdivision (c) (1) and Government Code section 65583.2, subdivision (c) are completed.
1433 of 1863
Darcy Smith, Interim Director

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

HCD appreciates the hard work and cooperation the housing element update team provided during the review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Hillary Prasad, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
1434 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 1 October 6, 2022

APPENDIX

CITY OF SAN BRUNO
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
The review requirement is one of the most important features of the element update. The review of past programs should analyze the City's accomplishments over the previous planning period. This information provides the basis for developing a more effective housing program.

A thorough program-by-program review is necessary to evaluate City's performance in addressing housing goals. While the element includes progress and actual results of implementation of some programs, this analysis must be included for all programs. In addition, the element must provide a description of how the objectives and programs of the updated element incorporate changes resulting from the evaluation.

If the City failed to make adequate sites available to accommodate the regional housing need in the prior planning period, the City must zone or rezone sites to accommodate any unaccommodated need within the first year of the 2023-2031 planning period. (Gov. Code, § 65584.09.) Program 2-A was necessary to demonstrate compliance with the adequate sites requirement in the previous planning period, however it was not completed. To demonstrate adequate sites were made available in the prior planning period, the element must include an analysis or programs demonstrating compliance with the statutory requirements. For additional information, see HCD’s AB 1233 Memorandum at https://www.hcd.ca.gov/hcd-memos and the Building Blocks at https://www.hcd.ca.gov/review-and-revise.

As part of the review of programs in the past cycle, the element must evaluate the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). 1435 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 2 October 6, 2022
B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Integration and Segregation: The element reports some data regarding segregation and integration of race, disability, familial status, and income. The element must evaluate racial patterns at a regional basis, comparing the City to the region. In addition, the element must discuss and analyze data on persons with disabilities for trends over time and patterns across census tracts as well as evaluate patterns at a regional basis.

Lastly, the element must describe and analyze concentrations of income and familial status geographically throughout the City.

Disparities in Access to Opportunity: While the element identified an area of access to education with lower outcomes, it must describe and analyze how that affects fair housing and other factors. In addition, the element should describe and analyze the access to jobs and transit throughout the City and for protected classes. The element must also analyze the areas of poor environmental outcomes and identify actions to address fair housing issues.

Disproportionate Housing Needs Including Displacement: While the element reports some data on disproportionate needs, it should describe any geographic concentration of cost burden and overcrowding by tenure, as well as any concentrations of substandard housing. The element must also describe and analyze areas sensitive to displacement, including displacement risk due to disaster (e.g., earthquake, fire, and flood).

Sites Inventory: While the element analyzed identified sites against some fair housing factors, the element must identify whether sites improve or exacerbate fair housing issues in the City. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups, and how that affects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). If sites exacerbate conditions, the element should identify further program actions that will be taken to promote equitable quality of life throughout the community (e.g., anti-displacement and place-based community revitalization strategies).

Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.
1436 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 3 October 6, 2022

2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Housing Stock Condition: The element must include an estimate of the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including non-profit housing developers or organizations.

Housing Costs: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress in Meeting the Regional Housing Need Allocation (RHNA): The City’s RHNA may be reduced by the number of new units built since June 30, 2022; however, the element must demonstrate their affordability based on actual sales price, rent level, or other mechanisms ensuring affordability (e.g., deed restrictions). The element should also discuss the status, any barriers to development and other relevant factors to demonstrate their availability in the planning period.

Sites Inventory: The element must list sites by parcel number, parcel size, zoning, general plan designation, describing existing uses for nonvacant sites and include a calculation of the realistic capacity of each site. While the element includes most of these requirements, the inventory must include the calculation of units in whole number increments. In addition, sites that are identified for rezone must include existing and proposed general plan and zoning designations. The element must also ensure there are sufficient sites identified in the inventory, either with existing zoning or proposed rezones to meet the lower and moderate income RHNA.

Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions (e.g., recent project examples). For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and typical densities of existing or approved residential developments at a similar affordability level. In addition, the element should describe what factors were included in the realistic capacity assumptions, especially in the mixed-use zones. Currently, the element includes many sites in the transit-oriented development (TOD) which does not include a maximum density. Assumptions of realistic capacity should be supported with examples. Further, some sites in the inventory assume over 200 units an acre (including site 1 on page 6-13). These 1437 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 4 October 6, 2022
assumptions should be supported with examples. Examples to support realistic capacity assumptions should also include affordability levels, and percent of maximum densities.

Finally, the calculation of residential capacity must also account for the likelihood of residential development in zoning where 100 percent nonresidential uses are allowed.

The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses or other relevant factors such as enhanced policies and programs. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Zoning for Lower-Income Households: The element must demonstrate zoning appropriate to accommodate housing for lower-income households. For sites with zoning meeting specified densities or default densities (30 units per acre in San Bruno), no analysis is required. Otherwise, the element must include analysis based on statutory factors. While the element identifies densities of at least 30 units per acre for many of the sites to accommodate housing for lower-income households, other sites do not meet the default density. As a result, if relying on densities less than 30 units per acre to accommodate the lower-income RHNA, an analysis must be included to demonstrate how the zoning encourages the development of units affordable for lowerincome households. Please see HCD’s Building Blocks for more information.

Small and Large Sites: Sites smaller than half an acre or greater than ten acres are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated, with sufficient evidence, that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the housing element describes other evidence to HCD that the site is adequate to accommodate housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(A).) Based on the outcomes of the analysis, the element should add or modify programs.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as former schools, and a gas station; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also support, based on recent development trends, indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.
1438 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 5 October 6, 2022
In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households.

For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.

Tanforan Site: While the element includes some information on this site, it should describe feasibility and timing of development during the planning period and add or modify programs as appropriate. The element mentions an agreement with the developer for a minimum of 1,000 units but it should describe timing, whether a specific plan is needed, and affordability assumptions on the site. The element should also address any known constraints to development (e.g., airport compatibility) and modify programs to ensure the availability of the site or identify alternative sites.

Sites Identified in Multiple Planning Periods: Sites identified in prior planning periods shall not be deemed adequate to accommodate the housing needs for lower-income households unless a program, meeting statutory requirements, requires rezoning within one or three years, whichever is applicable. If utilizing sites outside of the Transit Corridors Specific Plan for the lower-income RHNA, the element should clarify if sites were identified in prior planning periods and if so, which sites and include a program.

The program should ensure sites will meet density requirements and allow by-right approval for housing developments that include 20 percent or more of its units affordable to lower income households.

Accessory Dwelling Units (ADU): The element projects 345 ADUs over the planning period or approximately 43 ADUs per year over the eight-year planning period. These trends are inconsistent with HCD records (6 reported in 2018, 17 in 2019, 7 in 2020, and 70 in 2021) and do not support an assumption of 43 ADUs per year. To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., 6 months) if needed. The element must also address affordability assumptions for ADU projections.

AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater). (Gov. Code, § 65583.2, subd. (c)(4).)
Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to 1439 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 6 October 6, 2022
accommodate the RHNA for the planning period and add or modify programs if necessary.

Environmental Constraints: While the element generally describes a few environmental conditions within the City, it must describe any other known environmental constraints or conditions within the City that could impact housing development in the planning period.

Zoning for a Variety of Housing Types:
• Emergency Shelters: The element should describe the development standards of the M-1 zone that allows emergency shelters by-right and should provide an analysis of proximity to transportation and services for these sites, hazardous conditions, and any conditions in appropriate for human habitability. In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement.
• Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (c)(3).) The element must describe and analyze the City’s transitional and supportive housing standards and codes and demonstrate consistency with Section 65583(c)(3) or add or revise programs to comply with the statutory requirements. • By-Right Permanent Supportive Housing: Supportive housing shall be a use byright in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
• Low Barrier Navigation Centers: While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones. Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate.
• Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate.
• Employee Housing: The element must demonstrate the City’s zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and, if necessary, add or modify programs.

Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone.
• Accessory Dwelling Units: While the City does have an ADU ordinance, it is currently under review by HCD for consistency with State ADU Law. HCD will provide communication of ADU compliance issues under a separate cover. If 1440 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 7 October 6, 2022
necessary, the element should add a program to update the City’s ADU ordinance to comply with state law.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls.

The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. The element should analyze the interaction of the General Plan designation for high density residential allowing 24-40 dwelling units an acre, but the R-4 zoning district limits densities to 30 dwelling units an acre and whether the maximum density in the R-4 is a constraint. In addition, the element must analyze whether the garage setbacks apply to multifamily developments and whether they are a constraint on housing. On page 3-6, the element lists parking requirements for “general residential”; it should also clarify whether parking requirements for mixed-use zones differ than the general residential parking requirements and add a program as appropriate. Lastly, the element states that the full build-out of the sites located in the TCP would exceed the maximum of 1,610 units allowed under the current Environmental Impact Report (EIR). The element must analyze whether exceeding the allowed units is a constraint and either adjust capacity assumptions or add programs as appropriate.

Fees and Exaction: While the element describes many fees and the typical deposit range, it must describe all required fees for single family and multifamily housing development, including all impact and regional fees, and analyze their impact as potential constraints on housing supply and affordability. In addition, the analysis should identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing.

Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information. The analysis should address impacts on housing cost, supply, timing, and approval certainty.

Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and 1441 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 8 October 6, 2022
guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

State Density Bonus Law: The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.)
Streamlining Provisions: While the element states that they followed SB 35 procedures for a prior project, it should clarify whether the City has procedures in place consistent with streamlining procedures pursuant to Government Code section 65913.4 and include programs as appropriate.

On/Off-Site Improvements: The element must identify typical subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width), and analyze their impact as potential constraints on housing supply and affordability.

Constraints on Housing for Persons with Disabilities: The element identifies approval findings for granting a reasonable accommodation including finding related to impacts on surrounding uses – essentially a conditional use permit finding. However, reasonable accommodation should be a unique exception process from a conditional use permit, especially given its importance in addressing barriers to housing for persons with disabilities. The element should include a program to amend the Reasonable Accommodation Ordinance and remove constraints, including but not limited to the “potential impact on surrounding uses” approval finding. In addition, while the element states that unlicensed residential care facilities must require a license from the state licensing agency before operation, zoning and standards should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations. Zoning code regulations that isolate and regulate various types of housing for persons with disabilities may pose a constraint on housing choice for persons with disabilities. The element should include specific analysis of these and any other constraints for impacts on housing for persons with disabilities and add or modify programs as appropriate. Lastly, the element must describe and analyze any definitions of family used in zoning and land use for impacts on housing for persons with disabilities and add or modify programs as appropriate.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) 1442 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 9 October 6, 2022
Availability of Financing: The element must describe the availability of financing, including private financing and government assistance programs, is generally available in the community.

Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.

6. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Persons with Disabilities: While the element quantifies the number of persons with disabilities, it must also analyze their special housing needs. For a complete analysis, the element should discuss challenges faced by the population, the existing resources to meet those needs, an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element. (Gov. Code, § 65583, subd. (c).)
To have a beneficial impact in the planning period and achieve the goals and objectives of the housing element, programs should have specific commitment toward housing outcomes and discrete and early timing (e.g., at least annually or by a specified date).

Many programs list timing as within one year of certification. The timing of these programs should be benchmarked to a known date (e.g., within one year of the planning period). In addition, examples of programs that should be revised include the following:
• Programs 1-E (Publicly Post Status Updates) and 1-F (Consolidate Fee Schedules): These programs should clarify how often the listings will be updated. • Program 2-A (Study the South El Camino Real Corridor), 2-E (SB 9 Implementation Guidelines), 3-B (Displaced Residents), 4-A (Reasonable Accommodations), 4-E (Home Sharing Opportunities), 5-B (Affordable Housing Fund Resources), 8-A (Create an Affirmative Marketing Strategy): These programs should include proactive outreach and specify how often it will occur throughout the planning period.
1443 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 10 October 6, 2022
• Program 2-B (Evaluate Ballot Initiative): This program should include public outreach. In addition, the program must be implemented earlier in the planning period to ensure beneficial impact and include specific commitment to the action. • Program 2-C (Support Development of Housing Opportunity Sites): This program should clarify how often outreach will occur and whether incentives will be provided.
• Program 2-G (Publicize Affordable Housing Financing Strategies): The program should clarify how often outreach will occur and sources will be updated. • Program 4-B (Fair Housing Training for Landlords and Tenants): This program should commit to additional trainings during the planning period. • Program 4-C (Publicize Affordable Housing Financing Strategies): The program should clarify how often outreach and coordination will occur. In addition, it should include timing of when the in-lieu fee strategy will be developed. • Program 4-D (Nexus Study for Affordable Housing Program): The program should include an action and timing to implement the results of the study. • Program 4-G (Affordable Unit Set-Aside): The program should include implementation beyond research as well as include proactive outreach. • Program 4-I (Increase Supply of Housing for Large Families): The program should clarify what actions will be taken to encourage large units, such as incentives. The element should also include outreach to developers. • Program 5-C (Revise Affordable Housing Ordinance): The program should include back-up actions if the existing action is deemed infeasible. • Program 5-D (Retain Public Land): This program should clarify what is being implemented and include timing.
• Program 5-E (Expedite Review of 100% Affordable Housing Projects): The program should clarify what the timing is tied to if the program is continuing. • Program 6-A (Replacement of Below Market Rate Units): The timing of this program should be earlier in the planning period to ensure beneficial impact. • Program 8-B (Partner with Local Fair Housing Organizations): The program should include timing of how often training will occur.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs 1444 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 11 October 6, 2022
to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Program 2-F (Require a minimum of 1,000 Housing Units on Tanforan Mall Project):

This program should clarify whether incentives will be provided for affordable units, what actions will be implemented to ensure a set aside for persons with disabilities, how often outreach will occur, and clarify what will be implemented within the identified timeframe.

Shortfall of Adequate Sites: if the element does not identify adequate sites to accommodate the regional housing need for lower-income households, it must include a program(s) to identify sites with appropriate zoning to accommodate the regional housing need within the planning period. The program should identify the shortfall by income group, acreage, allowable densities, appropriate development standards and meet all by right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i), including but not limited to permitting multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower income households.

Program 2-H (Release RFP for City-Owned Sites): The element identified City-owned sites to accommodate a portion of the RHNA. The element should include a program with numerical objectives that ensures compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing and financial assistance. In addition, a similar program should be added for school owned sites.

3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderateincome households. (Gov. Code, § 65583, subd. (c)(2).) The element must include a program(s) with specific actions and timelines to assist in the development of housing for extremely low-income households. The program(s) could commit the City to adopting priority processing, granting fee waivers or deferrals, modifying development standards, granting concessions and incentives for housing developments that include units affordable to extremely low-income households; assisting, supporting or pursuing funding applications; and outreach and coordination with affordable housing developers.

In addition, the element must also include a program(s) to assist in the development of housing for all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of 1445 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 12 October 6, 2022
housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:

Heights: Programs to address restrictions on heights (Programs 2-A and 2-B) should specifically commit to take an initiative to the ballot by a specified date and complete alternative actions by a specific date if the ballot initiative is not passed.

Short Term Rentals: As noted in the element, a program should be added or modified to conduct research and take action as appropriate by a specified date.

5. The Housing Element shall include programs to conserve and improve the condition of the existing affordable housing stock. (Gov. Code, § 65583, subd. (c)(4).) The element must include a program(s) to conserve and improve the condition of the existing stock, which may include addressing the loss of dwelling units. A program could provide grants for substantial rehabilitation, provide matching grants for homeowner improvements, or implement proactive code enforcement program.

6. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element must include a complete analysis of Affirmatively Furthering Fair Housing (AFFH). The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends.

7. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent... (Gov. Code, § 65583, subd. (c)(7).) Program 4-H (Promote Accessory Dwelling Unit Ordinance): The program should include proactive outreach throughout the planning period. In addition, the program should include incentives beyond the City’s ordinance and webpage and commit to monitor permitted ADUs and affordability every other year and take appropriate action such as adjusting assumptions or rezoning within a specified time (e.g., 6 months) if assumptions are not realized.
1446 of 1863
City of San Bruno’s 6th Cycle (2023-2031) Draft Housing Element Page 13 October 6, 2022
D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved… (Gov. Code, § 65583, subd. (b)(1 & 2).) The element generally did not address this requirement. The element must include quantified objectives for construction, rehabilitation, and conservation by income group, including extremely low-income households. Please see the Building Blocks for additional information.

E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element includes a summary of public participation including outreach to the community, it must also describe whether translation services were available during public participation including, but not limited to, public workshops, Planning Commission, and City Council meetings.

F. Consistency with General Plan
The Housing Element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).) While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period. 1447 of 1863
RESOLUTION NO. 2023 - 01

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

SAN BRUNO RECOMMENDING THAT THE CITY COUNCIL ADOPT A

MITIGATED NEGATIVE DECLARATION

AND MITIGATION MONITORING AND REPORTING PROGRAM
FOR THE 2023 – 2031 HOUSING ELEMENT UPDATE
WHEREAS, State law requires each jurisdiction in California to adopt a General Plan, which includes a Housing Element; and
WHEREAS, the proposed 2023-2031 Housing Element will replace the existing 2015- 2023 Housing Element and will 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, jurisdictions within the San Francisco Bay Area region are required to prepare an update to their Housing Elements for the 2023-2031 planning period; and WHEREAS, the City of San Bruno was allocated 3,165 housing units to plan for over the 2023-2031 planning period; and
WHEREAS, pursuant to Government Code Section 65583(a)(3), the Housing Element Update is a policy document which includes the preparation of an inventory of land suitable and available for residential development, including vacant sites and sites with a realistic and demonstrated potential for redevelopment during the planning period to meet the City’s housing need at the designated income levels; and
WHEREAS, pursuant to the California Environmental Quality Act (CEQA) and Implementing Guidelines, an Initial Study and Draft Mitigated Negative Declaration (IS/MND), dated December 2022, was been prepared by David J. Powers & Associates, Inc. and, based on the type and intensity of land uses and programs identified with the 2023-2031 Housing Element update and the information contained therein, the Initial Study and Draft Mitigated Negative Declaration conclude that the Project, with the proposed mitigation measures, would not have a significant adverse effect on the environment; and WHEREAS, the IS/MND identified that: the 2023-2031 Housing Element update will have no or less than significant impacts on Aesthetics, Agriculture and Forestry Resources, Energy, Geology and Soils, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, Utilities and Service Systems, and Wildfire; the Project’s impacts on Air Quality, Biological Resources, Cultural Resources, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Noise, Transportation, and Tribal Cultural Resources are potentially significant but that all such impacts can be reduced to levels of insignificance by implementation of the mitigation measures identified in the MND; and
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 WHEREAS, the City, as the lead agency for the Project, posted a Notice of Intent on the City's website, filed the Notice of Intent with the County Clerk for posting, directly mailed the Notice of Intent to public agencies and through the State Clearing House (SCH # 2021030357) and requesting parties, and provided copies of the Initial Study/Mitigated Negative Declaration to the public for review and comment for a thirty (30) day period beginning December 9, 2022 and ending January 9, 2023; and WHEREAS, in connection with the approval of a project involving the preparation of an initial study/mitigated negative declaration that identifies one or more potentially significant environmental effects, CEQA requires the decision-making body of the lead agency to incorporate feasible mitigation measures that would reduce those potentially significant environment effects to a less-than-significant level; and WHEREAS, pursuant to CEQA Guideline §15074, whenever a lead agency approves a project requiring the implementation of measures to mitigate or avoid potentially significant effects on the environment. CEQA also requires a lead agency to adopt a mitigation monitoring and reporting program to ensure compliance with the mitigation measures during project implementation. A copy of the Mitigation Monitoring and Reporting Program ("MMRP") for the 2023-2031 Housing Element update, which defines the measures which would be imposed on the Project to mitigate or avoid potentially significant environmental impacts, is attached hereto as Exhibit "B" and incorporated herein by reference; and WHEREAS, a copy of the Initial Study/Mitigated Negative Declaration is set forth in Exhibit "A" and incorporated herein by reference; and
WHEREAS, the Planning Commission serves as an advisory body to the City Council as to the Housing Element Update Project, and in that capacity has reviewed and considered the Mitigated Negative Declaration in draft form in accordance with State CEQA Guidelines Section 15025 (c ); and,
WHEREAS, City’s Department of Community & Economic Development, 567 El Camino Real, San Bruno, CA, 94066, is the custodian of the documents and other materials that constitute the record of proceedings related to the Project and the Initial Study/ Mitigated Negative Declaration; and,
WHEREAS, on January 12, 2023, the Planning Commission considered the Initial Study and Draft Mitigated Negative Declaration, public comments and responses, and the application of all mitigation measures and a proposed Mitigation Monitoring and Reporting Program (MMRP) for the Housing Element project.

NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of San Bruno as follows, based on facts in the staff reports, written and oral testimony, and exhibits presented:

1. That the Planning Commission has independently reviewed and analyzed the Initial Study/Mitigated Negative Declaration and other information in the record and has considered the information contained therein prior to acting upon or DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 recommending approval of the Project. Based on all evidence in the administrative record for the Project, the Commission hereby makes the following specific findings:
a. The draft Initial Study/Mitigated Negative Declaration prepared for the Project has been completed in compliance with CEQA and the CEQA Guidelines.
b. The draft Initial Study/Mitigated Negative Declaration prepared for the Project contains a complete and accurate reporting of the environmental impacts associated with the Project.
c. The Commission has considered the draft Initial Study/Mitigated Negative
Declaration.
d. The draft Initial Study/Mitigated Negative Declaration represents the independent judgment and analysis of the city as lead agency for the Project.
e. The Project will not result in a significant effect upon the environment because the mitigation measures described in the MMRP have been added to the Project as a condition of approval.
f. Based on its review of the whole record before it, there is no substantial evidence in the record supporting a fair argument that the Project will have a significant effect on the environment.

2. Based upon the Draft Mitigated Negative Declaration and comments and testimony received, the Planning Commission hereby finds that there is no substantial evidence that the 2023-2031 Housing Element update, as mitigated, will have a significant effect on the environment.

3. The Planning Commission hereby recommends that the San Bruno City Council adopt the Draft Mitigated Negative Declaration attached hereto as Exhibit A and the Mitigation Monitoring Program attached hereto as Exhibit B.

4. The Secretary of the City of San Bruno Planning Commission is hereby directed to forward to the City Council a certified copy of this resolution together with an attested copy.

Date Planning Commission Chair

ATTEST APPROVED AS TO FORM
Planning Commission Secretary City Attorney
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 1/18/2023
-o0oI, Michael Laughlin, Planning Commission Secretary, do hereby certify that the foregoing Resolution was duly and regularly passed and adopted by the Planning Commission of the City of San Bruno this 12th day of January 2023 by the following vote:

AYES Commissioners:

NOES Commissioners:

ABSENT Commissioners:

RECUSED Commissioners
Durazo, Biasotti, Harmon, Johnson, Kuhn, Lethin
Madden
none
none
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Exhibit A
2023-2031 HOUSING ELEMENT UPDATE

FOR THE CITY OF SAN BRUNO

INITIAL STUDY
AND

DRAFT MITIGATED NEGATIVE DECLARATION
December 2022
Prepared by:

David J. Powers & Associates, Inc.
1736 Franklin Street, Suite 300
Oakland, CA 94612
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Initial Study/Mitigated Negative Declaration
2023-2031 Housing Element Update
December 2022
In Consultation with
Prepared by
lf:ll DAVIDJ.POWERS B~~ & ASSOCIATES, INC.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19

CITY OF SAN BRUNO
Mitigated Negative Declaration
Pursuant to Section 21000 et seq of the Public Resources Code, a Mitigated Negative Declaration is hereby granted for the following project:

1. Project Title: 2023-2031 Housing Element Update

2. Lead Agency Name and Address: City of San Bruno
567 El Camino Real
San Bruno, CA 94066

3. Contact Person and Phone Number: Michael Smith
Senior Planner
[email protected]
650-616-7062

4. Project Location The proposed project would occur entirely within the City of San Bruno, which is located
in northern San Mateo County. The city limits
encompass a 5.49 square-mile area that
stretches 3.5 miles from the relatively flat
eastern areas along Highway 101 to the hilly
western neighborhoods located on the eastern
facing slope of the Coast Ranges.

5. Project Sponsor's Name & Address: City of San Bruno
567 El Camino Real
San Bruno, CA 94066

6. Description of Project: The project proposes to update the Housing Element of the San Bruno General Plan 2025 in
accordance with California Government Code
Section 65583. 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
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 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 3,618 additional housing units
within the City’s jurisdiction.

As required by Government Code Section
65583(a)(3), the Housing Element Update
involves the preparation of an inventory of land
suitable and available for residential
development, including vacant sites and sites
with a realistic and demonstrated potential for
redevelopment during the planning period to
meet the City’s housing need at the designated
income levels. In accordance with the sites
inventory requirements under California
Government Code sections 65583(c), the
project will also include a program that
identifies actions that the City is undertaking or
intends to undertake to implement the policies
and achieve the goals and objectives of the
2023-2031 Housing Element through the
administration of land use and development
controls (including General Plan Amendments
and rezoning).

FINDING
The Community and Economic Development Director finds the project described above will not have a significant effect on the environment in that the attached Initial Study identifies one or more potentially significant effects on the environment for which the project sponsor, before public release of this draft Mitigated Negative Declaration (MND), has made or agrees to make project revisions that clearly mitigate the effects to a less than significant level.

MITIGATION MEASURES INCLUDED IN THE PROJECT TO REDUCE POTENTIALLY

SIGNIFICANT EFFECTS TO A LESS THAN SIGNIFICANT LEVEL
A. AESTHETICS – The project will not have a significant impact on this resource; therefore, no mitigation is required.

B. AGRICULTURE AND FOREST RESOURCES – The project will not have a significant impact on this resource; therefore, no mitigation is required.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 C. AIR QUALITY
MM AIR-3.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to implement the following measures during demolition and construction:
a. Use Tier 4 engines for all off-road equipment greater than 50 horsepower (hp) and operating for more than 20 total hours over the entire duration of construction activities.
b. Use diesel trucks with 2010 or later compliant model year engines during construction.
c. Use renewable diesel during construction.
d. Use low-VOC coatings during construction.
e. Implement BAAQMD best management practices and if
necessary, enhanced measures recommended by BAAQMD.
f. Use portable electrical equipment where commercially available and practicable to complete construction.

Construction contractors shall utilize electrical grid power instead of diesel generators when (1) grid power is available at the construction site; (2) when construction of temporary power lines are not necessary in order to provide power to portions of the site distant from existing utility lines; (3) when use of portable extension lines is practicable given construction safety and operational limitations; and (4) when use of electrical grid power does not compromise construction schedules.

MM AIR-3.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to conduct a construction and operational health risk assessment (HRA) prior to the issuance of discretionary permits that would allow demolition or construction activities to take place (whichever occurs first). If the HRA demonstrates, to the satisfaction of the City, that the health risk exposures for adjacent receptors will be less than BAAQMD project-level thresholds, then additional mitigation would be unnecessary. However, if the HRA demonstrates that health risks would exceed BAAQMD project level thresholds, additional feasible on- and off-site mitigation shall be analyzed to further reduce risks to the greatest extent practicable.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 D. BIOLOGICAL RESOURCES
MM BIO-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites to comply with the following measures:
a. Demolition and nesting substrate (e.g., trees, bushes, grasses, and other vegetation) removal activities shall be scheduled to avoid nesting season (February 1 to August 31). To the extent feasible, construction activities shall be scheduled to occur during the non-nesting season (September 1 through January 31).
b. Prior to issuance of any discretionary permits that would allow construction activities during the nesting season, a qualified biologist shall complete pre-construction surveys for active nests within 14 days of work commencing. The survey area must include the proposed development area and all areas within 300 feet of the development area boundary (“zone of influence”). If active nest, roost, or burrow sites are identified within the zone of influence, a no-disturbance buffer shall be established for all active nest sites prior to commencement of any proposed construction-related activities to avoid
disturbances to migratory bird nesting activities. A nodisturbance buffer constitutes a zone in which construction activities cannot occur. The sizes of the buffers shall be determined by a qualified biologist based on the species, activities proposed near the nest, and topographic and other visual barriers. Buffers shall remain in place until the young have departed the area or fledged and/or the nest is inactive, as determined by the qualified biologist.
c. If work is necessary within a buffer zone of an active bird nest, work may occur under the supervision of a qualified avian biologist. The qualified avian biologist monitoring the construction work shall have the authority to stop work and adjust buffers if any disturbance to nesting activity is observed.

E. CULTURAL RESOURCES
MM CUL-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Removal or alteration of the commemorative features of California Historic Landmark #934 shall be prohibited, and must be incorporated into any future development proposals for Site 14.
b. As part of the future project-level CEQA analysis of any discretionary permit that would allow the demolition of the DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 existing buildings located at Site 14, a Historic Resource Evaluation (HRE) shall be prepared by a qualified architect or architectural historian approved by the City and meeting the Secretary of the Interior's Professional Qualifications Standards published in the Code of Federal Regulations (36 CFR part 61).

The HRE shall evaluate whether any of the existing buildings meet the definition of a historic resource pursuant to CEQA Guidelines Section 15064.5. If the existing buildings do not meet the definition of a historic resource, demolition may proceed. If the HRE finds that any of the existing buildings at Site 14 meet the definition of a historic resource, demolition of buildings eligible for listing as a historic resource shall be prohibited.
c. In the event that any buildings meeting the definition of a historic resource pursuant to CEQA Guidelines Section
15064.5 are identified, future development proposals for Site 14 shall be reviewed for compliance by a qualified architect or architectural historian approved by the City and meeting the Secretary of the Interior's Professional Qualifications Standards published in the Code of Federal Regulations (36 CFR part 61) with one or both of the following standards prior to issuance of any discretionary permits that would allow modifications to the existing buildings or new construction on Site 14:
• Secretary of Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving,
Rehabilitating, Restoring, and Reconstructing Historic
Buildings; or
• Secretary of Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings
(1995), Weeks and Grimmer.

MM CUL-2.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 to comply with the following measures:
a. If evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5,
including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g., worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all ground-disturbing activity within 100 feet of the resources shall be halted and the City Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation.

The City’s Planning Manager shall consult with the
archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-thanDocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 significant level through data recovery or other methods determined adequate by a qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural
resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.
b. Prior to the initiation of any site preparation and/or the start of construction, the project sponsor shall ensure that all construction workers receive training overseen by a qualified professional archaeologist who is experienced in teaching nonspecialists, to ensure that contractors can recognize archaeological resources in the event that any are discovered during construction.

MM CUL-2.2: Prior to approval, the 2023-2031 Housing Element shall be amended to include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. As part of the future project-level CEQA analysis of any discretionary permits that would allow ground-disturbing activities (e.g., grading, trenching, excavation, etc.) in the archaeological sensitive areas shown on Figure 4.5 1,
exploratory trenching shall be conducted by a qualified archaeologist trained in both local prehistoric and historical archaeology within the proposed area of effect to determine if prehistoric- or historic-era archaeological resources are present.

Explorations shall consist of at least one mechanically dug trench with excavation depths commensurate with the depth of proposed ground-disturbing activities. If any archaeological resources are exposed, these should be briefly documented, tarped for protection, and left in place. The results of the exploratory trenching shall be submitted to the Director of Community and Economic Development or the Director’s
designee. If it is determined by the project archaeologist that the proposed activities could damage an archaeological
resource or that indications of other suspected archaeological resources are present (i.e., darkened soil “midden” representing past human activity), an Archaeological Resources Treatment Plan shall be prepared as described in MM CUL-2.1b below. b. If recommended by the project archaeologist, an
Archaeological Resources Treatment Plan shall be prepared by the project archaeologist that contains, at minimum:
• Identification of the scope of work and range of
subsurface effects (including location map and
development plan), including requirements for
preliminary field investigations.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 • Description of the environmental setting (past and
present) and the historic/prehistoric background of the parcel (potential range of what might be found).
• Monitoring schedules and individuals
• Development of research questions and goals to be
addressed by the investigation (what is significant vs. what is redundant information).
• Detailed field strategy to record, recover, or avoid the finds and address research goals.
• Analytical methods. Report structure and outline of
document contents.
• Disposition of the artifacts.
• Security approaches or protocols for finds.
• Appendices: all site records, correspondence, and
consultation with Native Americans, etc.

Implementation of the treatment plan by the project
archaeologist shall be required prior to the issuance of any permits related to ground-disturbing activities. The treatment plan shall utilize data recovery methods to reduce impacts on subsurface resources. The treatment plan shall be submitted to the Director of Community and Economic Development or
the Director’s designee, along with a summary of the
outcomes of the treatment plan and all associated
documentation and recordation.

MM CUL-2.3: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any discretionary permits that would allow ground-disturbing activities (e.g., grading, trenching, excavation, etc.) within the non-sensitive areas mapped on Figure 4.5 1, the project applicant shall hire a qualified archaeologist to develop a Worker’s Environmental Awareness Program (WEAP) to train the construction crew on the legal requirements for the treatment of cultural resources as well as procedures to follow in the event of a cultural resources discovery. This training program shall be given to the crew before ground disturbing work commences and shall include handouts to be given to new workers.
b. The applicant shall note on all construction plans that require ground disturbing activities that there is a potential for exposing buried cultural resources including prehistoric Native American burials.
c. In the event that potentially significant archaeological resources are encountered during ground-disturbing activities occurring DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 at Site 14, all activity within a 50-foot radius of the find shall be stopped, the Director of Community and Economic
Development or the Director's designee shall be notified, and the project archaeologist shall examine the find. The project archaeologist shall (1) evaluate the find(s) to determine if they meet the definition of an archaeological resource; and (2) make appropriate recommendations regarding the disposition of such finds prior to issuance of building permits. Recommendations could include collection, recordation, and analysis of any significant cultural materials. A report of findings documenting any data recovery shall be submitted to the Director of Community and Economic Development or the Director's
designee and the Northwest Information Center (if applicable).

MM CUL-3.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16, 17, 20, 22 and 23 to comply with the following measures:
a. If human remains are discovered at any project construction site during any phase of construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County Coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section 7050.5 of
California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be
notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains.

The project sponsor shall also retain a professional
archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide
professional assistance to the Most Likely Descendant,
including the excavation and removal of the human remains.

The City of San Bruno shall be responsible for approval of recommended mitigation as it deems appropriate, taking
account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement approved mitigation, to be verified by the City of San Bruno, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.

F. ENERGY – The project will not have a significant impact on this resource; therefore, no mitigation is required.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 G. GEOLOGY AND SOILS – The project will not have a significant impact on this resource; therefore, no mitigation is required.

H. GREENHOUSE GAS EMISSIONS
MM GHG-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring applicants and their contractors to implement the following measures prior to and during construction:
a. Prior to issuance of any discretionary permits that would allow demolition or construction (grading, excavation, building, etc.) activities at the Housing Opportunity Sites, the applicant shall submit a construction management plan that demonstrates that:
• Alternative fueled (e.g. biodiesel, electric)
construction vehicles/equipment shall make up at least
15 percent of the fleet;
• Buildings shall be constructed with local building
materials of at least 10 percent (sourced from within
100 miles of the City limits); and
• Contractors shall recycle and reuse at least 50 percent of construction waste or demolition materials.

MM GHG-1.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to demonstrate adherence with the following design measures prior to issuance of any discretionary permits that would allow construction of residential units:
a. Construction of natural gas infrastructure and the use of natural gas appliances shall be prohibited;
b. Future developments shall include all electric appliances; c. At a minimum, future development shall comply with offstreet electric vehicle requirements in the most recently adopted version of CALGreen Tier 2 requirements.

I. HAZARDS AND HAZARDOUS MATERIALS
MM HAZ-2.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 to comply with the following measure:
a. The City shall require a Phase I Environmental Site
Assessment (Phase I ESA) prior to issuance of any
discretionary permits that would allow ground-disturbing activities, with a Phase II ESA also required if the Phase I ESA indicates evidence of potential site contamination. The DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 City shall also require compliance with the site assessment(s) and any remediation, removal, and disposal requirements for soil, surface water, and/or groundwater contamination
enforced by the Department of Toxic Substances Control
(DTSC), Regional Water Quality Control Board (RWQCB),
San Mateo County Department of Environmental Health
(SMCEHS), California Division of Occupational Safety and Health (CalOSHA), U.S. Environmental Protection Agency
(EPA), and other jurisdictional agencies.

MM HAZ-2.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any discretionary permits that would allow ground-disturbing activities on Site 14 (outside of the area shown on Figure 4.9 1), the project proponent shall obtain a Phase I Environmental Site Assessment (ESA). The Phase I ESA shall be conducted in accordance with the United States Environmental Protection Agency’s All Appropriate Inquiries (AAI) Rule and the latest American Society for Testing and Materials (ASTM International) guidelines, and identify all potential subsurface contaminants warranting further investigation.
b. If the Phase I ESA identifies any potential contaminants warranting further investigation, a Phase II ESA shall be prepared in accordance with the United States Environmental Protection Agency’s AAI Rule and the latest ASTM
International guidelines. As part of the Phase II, a qualified environmental professional (as defined in Title 40 of the California Code of Regulations) shall take soil, soil vapor, and groundwater samples as determined necessary by the
environmental professional in the area of proposed
disturbance at 0.5 feet below ground surface (bgs) to the maximum proposed depth of disturbance. Collected soil
samples shall be tested for all potential contaminants
identified in the Phase I ESA to determine if contaminants exceed California Division of Occupational Safety and Health (Cal/OSHA) exposure limits or San Mateo County
Environmental Health Services (SMCEHS) environmental
screening levels for residential uses.
c. The results of the Phase II ESA shall be provided SMCEHS department. If determined necessary by the SMCEHS, a
Redevelopment Management Plan (RMP) or equivalent shall be prepared and submitted to the SMCEHS and the Director of Community and Economic Development or the Director’s designee that includes 1) an evaluation of whether
redevelopment activities will create new exposure pathways DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 to human health and the environment that pose unacceptable risks, and, if so, how those risks will be mitigated, and 2) a discussion of how contaminated media will be handled and disposed during construction activities. Once approved by the SMCEHS and Community and Economic Development
Department, the RMP or equivalent shall be implemented by a qualified environmental professional. The results of the RMP or equivalent shall be submitted to the SMCEHS and
the Director of Community and Economic Development or
the Director’s designee prior to the issuance of any issuance of any discretionary permits (e.g., grading, construction, occupancy, whichever occurs first).

MM HAZ-5.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any construction or building permits, the applicant shall submit a plan with a list of equipment to be used during construction that includes their height and proposed area of operation to the Director of Community and Economic Development or the Director’s designee. The use of equipment in locations where it would penetrate critical aeronautical surfaces shall be expressly prohibited by any construction or building permits issued. The plan sets shall include a page depicting the critical aeronautical surfaces onsite, a list of all equipment with heights of 55 feet or greater and their respective heights, and informs construction workers that the use of equipment with heights that would penetrate critical aeronautical surfaces is prohibited.
b. Future development at Housing Opportunity Site 14 shall comply with Policy AP-3 of the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP). Buildings with heights in excess of the applicable critical aeronautical surface as shown in Exhibit IV-17 at Housing Opportunity Site 14 shall be prohibited unless the Federal Aviation Administration
determines the proposed building height is not a hazard to air navigation in an aeronautical study prepared pursuant to the filing of Form 7460-1. Proof of compliance with Policy AP-3 of the ALUCP shall be provided to the Director of
Community and Economic Development or the Director’s
designee prior to issuance of any construction or building permits.

J. HYDROLOGY AND WATER QUALITY – The project will not have a significant impact on this resource; therefore, no mitigation is required.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 K. LAND USE AND PLANNING – The project will not have a significant impact on this resource; therefore, no mitigation is required.

L. MINERAL RESOURCES – The project will not have a significant impact on this resource; therefore, no mitigation is required.

M. NOISE
MM NOI-2.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to implement the following measures during demolition and construction:
• 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:
o 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.
o Place operating equipment on the construction site as far as possible from vibration-sensitive receptors.
o Use smaller equipment to minimize vibration levels
below the limits.
o Avoid using vibratory rollers and tampers near
sensitive areas.
o Select demolition methods not involving impact tools. o Modify/design or identify alternative construction
methods to reduce vibration levels below the limits.
o Avoid dropping heavy objects or materials.

N. POPULATION AND HOUSING – The project will not have a significant impact on this resource; therefore, no mitigation is required.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 O. PUBLIC SERVICES – The project will not have a significant impact on this resource; therefore, no mitigation is required.

P. RECREATION – The project will not have a significant impact on this resource; therefore, no mitigation is required.

Q. TRANSPORTATION/TRAFFIC
MM TRN-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites that would generate a sufficient amount of trips according to the City’s traffic analysis guidelines or otherwise warrant analysis as determined by the City to prepare a Transportation Analysis (TA) prior to the issuance of any discretionary permits. Prior to the preparation of the TA, a scope of work outlining the proposed approach to the TA shall be submitted to the Director of Public Works or the director’s designee for review and approval. The TA, at a minimum, shall evaluate the proposed development for consistency with the City’s General Plan and Walk ‘N Bike Plan, review the proposed layout for any geometric design features that may increase hazards (e.g., sight distances, turning radii, etc.), and verify adequate emergency access is provided. The TA shall provide
recommendations addressing any identified inconsistencies, geometric design hazards, or emergency access issues that shall be incorporated into the final design. The TA shall be prepared in accordance with Public Works’ guidance and submitted prior to the approval of any discretionary permits as part of the project-level review of all future development under the Housing Element Update.

R. TRIBAL CULTURAL RESOURCES – Potential impacts to tribal cultural resources would be addressed through mitigation measures MM CUL-2.1, MM CUL-2.2, and MM CUL-2.3, identified above under E. Cultural Resources.

S. UTILITIES AND SERVICE SYSTEMS – The project will not have a significant impact on this resource; therefore, no mitigation is required.

T. WILDFIRE – The project will not have a significant impact on this resource; therefore, no mitigation is required.

U. MANDATORY FINDINGS OF SIGNIFICANCE – With the implementation of the mitigation measures identified above, the project would not degrade the quality of the environment, substantially affect the biological resources, or eliminate important examples of California history or prehistory. The mitigation measures would also ensure that the project’s contribution to cumulative impacts would not be cumulatively considerable, and the project would not cause substantial adverse effects on human beings, either directly or indirectly.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19

PUBLIC REVIEW PERIOD
Before 5:00 p.m. on Monday, January 9th, any person may:

1. Review the Draft MND as an informational document only; or

2. Submit written comments regarding the information and analysis in the Draft MND. Before the MND is adopted, Planning staff will prepare written responses to any comments, and revise the Draft MND, if necessary, to reflect any concerns raised during the public review period. All written comments will be included as part of the Final MND.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update i Initial Study
City of San Bruno December 2022

TABLE OF CONTENTS
Section 1.0 Introduction and Purpose ................................................................................................ 1

1.1 Purpose of the Initial Study .................................................................................................... 1

1.2 Public Review Period ............................................................................................................. 1

1.3 Consideration of the Initial Study and Project ........................................................................ 1

1.4 Notice of Determination ......................................................................................................... 2 Section 2.0 Project Information ......................................................................................................... 3

2.1 Project Title ............................................................................................................................ 3

2.2 Lead Agency Contact ............................................................................................................. 3

2.3 Project Sponsor ....................................................................................................................... 3

2.4 Project Location ...................................................................................................................... 3

2.5 Project-Related Approvals, Agreements, and Permits............................................................ 6 Section 3.0 Project Description .......................................................................................................... 8

3.1 Background ............................................................................................................................. 8

3.2 Project Description ............................................................................................................... 11 Section 4.0 Environmental Setting, Checklist, and Impact Discussion ........................................... 26

4.1 Aesthetics .............................................................................................................................. 27

4.2 Agriculture and Forestry Resources ..................................................................................... 42

4.3 Air Quality ............................................................................................................................ 45

4.4 Biological Resources ............................................................................................................ 70

4.5 Cultural Resources ................................................................................................................ 84

4.6 Energy ................................................................................................................................. 103

4.7 Geology and Soils ............................................................................................................... 112

4.8 Greenhouse Gas Emissions ................................................................................................. 124

4.9 Hazards and Hazardous Materials ...................................................................................... 136

4.10 Hydrology and Water Quality ............................................................................................ 158

4.11 Land Use and Planning ....................................................................................................... 172

4.12 Mineral Resources .............................................................................................................. 181

4.13 Noise and Vibration ............................................................................................................ 183

4.14 Population and Housing ...................................................................................................... 206

4.15 Public Services.................................................................................................................... 210

4.16 Recreation ........................................................................................................................... 225

4.17 Transportation ..................................................................................................................... 229

4.18 Tribal Cultural Resources ................................................................................................... 245 DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update ii Initial Study
City of San Bruno December 2022

4.19 Utilities and Service Systems ............................................................................................. 249

4.20 Wildfire ............................................................................................................................... 267

4.21 Mandatory Findings of Significance .................................................................................. 272 Section 5.0 References ................................................................................................................... 276 Section 6.0 Lead Agency and Consultants ..................................................................................... 282

6.1 Lead Agency ....................................................................................................................... 282

6.2 Consultants ......................................................................................................................... 282 Section 7.0 Acronyms and Abbreviations ...................................................................................... 283 Figures
Figure 2.4-1: Regional Map of the City of San Bruno and Surrounding Area ...................................... 4 Figure 2.4-2: Aerial Photograph of the City of San Bruno .................................................................... 5 Figure 3.2-1: Housing Opportunity Sites ............................................................................................. 12 Figure 3.2-2: Aerial of Sites 1, 3, 13, 20 .............................................................................................. 13 Figure 3.2-3: Aerial of Sites 2, 4, 5, 8, 9, 17, 22, 23 ............................................................................ 14 Figure 3.2-4: Aerial of Sites 7, 11, 12, 15, 21 ...................................................................................... 15 Figure 3.2-5: Aerial of Sites 10 and 16 ................................................................................................ 16 Figure 3.2-6: Aerial of Sites 14, 18, 19 ................................................................................................ 17 Figure 3.2-7: Aerial of Site 6 ............................................................................................................... 18 Figure 3.2-8: City of San Bruno Zoning Map ...................................................................................... 25 Figure 4.3-1: Housing Opportunity Sites and TAC Sources ............................................................... 63 Figure 4.4-1: Vegetative Communities and Special-Status Habitat..................................................... 76 Figure 4.5-1: Areas Sensitive for Historic-Era Archaeological Resources .......................................... 91 Figure 4.5-2: Location of Known Historic Resources Relative to Housing Opportunity Sites ........... 93 Figure 4.7-1: Geologic and Seismic Hazards ..................................................................................... 117 Figure 4.9-1: Sears Automotive Center Site ...................................................................................... 148 Figure 4.10-1: Flooding and Storm Drainage .................................................................................... 166 Figure 4.13-1: Noise Measurement Locations ................................................................................... 189 Figure 4.13-2: Housing Opportunity Sites and SFO 2020 Noise Exposure Contours (dB, CNEL) .. 205 Figure 4.15-1: Police Beat Map ......................................................................................................... 217 Figure 4.20-1: Wildland Fire Hazard Areas ....................................................................................... 270 Tables
Table 3.1-1: City of San Bruno RHNA by Household Income Category ............................................ 10 Table 3.2-1: Inventory of Housing Opportunity Sites ......................................................................... 19 DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update iii Initial Study
City of San Bruno December 2022
Table 3.2-2: Summary of All Identified Housing Units ...................................................................... 23 Table 4.3-1: Health Effects of Air Pollutants ...................................................................................... 45 Table 4.3-2: BAAQMD Plan-Level Air Quality Significance Thresholds1 ........................................ 55 Table 4.3-3: BAAQMD Project-Level Air Quality Significance Thresholds1 .................................... 55 Table 4.3-4: 2017 Clean Air Plan Control Measures Consistency Analysis ....................................... 57 Table 4.3-5: VMT and Population Comparison ................................................................................... 61 Table 4.3-6: Screening Distances from Existing Air Pollutant and TAC Sources1 ............................. 64 Table 4.8-1: BAAQMD GHG Significance Thresholds .................................................................... 127 Table 4.8-2: Calculated GHG Emissions of the Housing Element Update ....................................... 133 Table 4.13-1: Groundborne Vibration Impact Criteria ...................................................................... 184 Table 4.13-2: PM Peak Hour Traffic Volumes and Project Generated Traffic Noise Increases1 ...... 192 Table 4.13-3: Typical Ranges of Construction Noise Levels at 50 Feet, Leq (dBA) ......................... 193 Table 4.13-4: Representative Construction Noise Levels1 ................................................................ 194 Table 4.13-5: Vibration Source Levels for Construction Equipment ................................................ 200 Table 4.13-6: Vibration Source Levels for Construction Equipment and Minimum Safe Setbacks . 201 Table 4.19-1: Capacity at Class III Landfill Facilities ....................................................................... 256 Table 4.19-2: Estimated Water Demand Increase of the Housing Element Update .......................... 261 Table 4.19-3: Summary of Water Demand versus Water Supplies ................................................... 261 Appendices
Appendix A: Air Quality and Greenhouse Gas Assessment
Appendix B: Noise & Vibration Assessment
Appendix C: VMT Analysis
Appendix D: Water Supply Assessment
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 1 Initial Study
City of San Bruno December 2022
SECTION 1.0 INTRODUCTION AND PURPOSE

1.1 PURPOSE OF THE INITIAL STUDY
The City of San Bruno, as the Lead Agency, has prepared this Initial Study for the proposed 2023- 2031 Housing Element Update (“Housing Element Update” or “project”) in compliance with the California Environmental Quality Act (CEQA), the CEQA Guidelines (California Code of Regulations §15000 et. seq.) and the regulations and policies of the City of San Bruno, California.

The project proposes to update the Housing Element of the San Bruno General Plan 2025 in accordance with California Government Code Section 65583. This Initial Study evaluates the environmental impacts that might reasonably be anticipated to result from implementation of the proposed project at a program level. If a subsequent activity would have effects that are not within the scope of this Initial Study, then the City must prepare a new Initial Study leading to a Negative Declaration, a Mitigated Negative Declaration, or an Environmental Impact Report (EIR). Therefore, future development allowed under the Housing Element Update would necessitate subsequent project-level review.

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 3,618 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.

1.2 PUBLIC REVIEW PERIOD
Publication of this Initial Study marks the beginning of a 30-day public review and comment period.

During this period, the Initial Study will be available to local, state, and federal agencies and to interested organizations and individuals for review. Written comments concerning the environmental review contained in this Initial Study during the 30-day public review period should be sent to:

Michael Smith, Senior Planner
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
[email protected]

1.3 CONSIDERATION OF THE INITIAL STUDY AND PROJECT
Following the conclusion of the public review period, the City of San Bruno will consider the adoption of the Initial Study/Mitigated Negative Declaration (MND) for the project at a regularly scheduled meeting. The City shall consider the Initial Study/MND together with any comments DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 2 Initial Study
City of San Bruno December 2022
received during the public review process. Upon adoption of the MND, the City may proceed with project approval actions.

1.4 NOTICE OF DETERMINATION
If the project is approved, the City of San Bruno will file a Notice of Determination (NOD), which will be available for public inspection and posted within 24 hours of receipt at the County Clerk’s Office for 30 days. The filing of the NOD starts a 30-day statute of limitations on court challenges to the approval under CEQA (CEQA Guidelines Section 15075(g)).

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 3 Initial Study
City of San Bruno December 2022
SECTION 2.0 PROJECT INFORMATION

2.1 PROJECT TITLE
2023-2031 Housing Element Update

2.2 LEAD AGENCY CONTACT
Michael Smith, Senior Planner
City of San Bruno
567 El Camino Real
San Bruno, CA 94066
[email protected]

2.3 PROJECT SPONSOR
City of San Bruno
Community and Economic Development Department
567 El Camino Real
San Bruno, CA 94066

2.4 PROJECT LOCATION
The proposed project would occur entirely within the City of San Bruno, which is located in northern San Mateo County. The city limits encompass a 5.49 square-mile area that stretches 3.5 miles from the relatively flat eastern areas along Highway 101 to the hilly western neighborhoods located on the eastern facing slope of the Coast Ranges. The eastern portion of the city is more urbanized and has a greater mix of land uses, while the western portion is primarily occupied by low-density residential development and open space.

The City is bordered by the City of South San Francisco to the north, the City of Millbrae to the south, and the City of Pacifica to the west. Additionally, there are unincorporated lands west and east of the city limits that are controlled by the California Department of Fish and Wildlife (CDFW) and the City and County of San Francisco, respectively.

Regional and aerial maps of the City are shown on Figure 2.4-1 and Figure 2.4-2, respectively.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 6$1
)5$1&,6&2
5LFKPRQG
'LVWULFW
6XQVHW
'LVWULFW
%D\YLHZ
'LVWULFW
0LVVLRQ
'LVWULFW
&KLQDWRZQ
6DQ
)UDQFLVFR
8SSHU
&U\VWDO
6SULQJV
5HVHUYRLU (O *UDQDGD
0LOOEUDH
+DOI 0RRQ
%D\
%XUOLQJDPH
%D\VKRUH
6RXWK 6DQ
)UDQFLVFR
3DFLƬFD
6DQ %UXQR
'DO\ &LW\
2DNODQG
,QW
O $LUSRU
$ODPHGD
2DNODQG
6DQ &DUORV
)RVWHU &LW\
6DQ 0DWHR
5HGZRRG
&LW\
6$1
0$7(2
:RRGVLGH
Source: City of San Bruno Interactive Review Map, May 13, 2022.

Half
Moon
Bay
San
Francisco
Bay
Pacific
Ocean
1 1
1 35
35 82
82 84
92 92
92 101
101
101
280
280
380
880
80 580
280
04 1 8 Miles
City of San Bruno
Pacific Ocean
Monterey Bay
Project Site
San José
Fremont
Oakland
Santa Cruz
Mountain View
Morgan Hill
San José
Sunnyvale
Fremont San Mateo
Redwood City
Livermore
Oakland
San Francisco
Santa Cruz
Mountain View
Morgan Hill
REGIONAL MAP OF SAN BRUNO AND SURROUNDING AREA FIGURE 2.4-1 2023-2031 Housing Element Update
City of San Bruno
4 Initial Study
December 2022
·--· I I ·--·
i,.,--,-----------
N
~
C...1 __ ..,
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Shar p Pa kr Roa d
Mori Ridge Trail
Notch Trail
Sweeney Ridge Trail
Sne athLane Tr ail
San Andreas Trail
San Bruno
Creek
Colma Creek
U P. .R R. .

U.P.R.R.

Centennial Way Trail
Shar
p Pa kr Roa d
M
o
ri
Ridge
Trail
Notch Trail
Sweeney Ridge Trail
Sne
ath
Lane Tr a
il
San Andreas Trail
San Bruno
Creek
Colma Creek
U P. .R R. .

U.P.R.R.

Centennial Way Trail
35 35
82 82
101
101
280
280
380El Camino Real
Skyline Boulevard Skyline Boulevard
Aerial Source: Google Earth Pro, May 13, 2022. Photo Date: Aug. 2020 0 .25 .5 .75 1 Mile City of San Bruno
AERIAL PHOTOGRAPH OF THE CITY OF SAN BRUNO FIGURE 2.4-2 City of San Bruno2023-2031 Housing Element Update 5 Initial Study December 2022
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 6 Initial Study
City of San Bruno December 2022

2.5 PROJECT-RELATED APPROVALS, AGREEMENTS, AND PERMITS

2.5.1 City of San Bruno
The project would require the following discretionary approvals from the City of San Bruno:
• Adoption of the 2023-2031 Housing Element Initial Study and Mitigated Negative Declaration (MND)
• Adoption of the 2023-2031 Housing Element
• Adoption of amendments to the General Plan
• Future legislative actions to implement programs, including rezoning program • Airport Land Use Control Plan (ALUCP) Override

2.5.2 California Department of Housing and Community Development In addition to the discretionary approvals identified above, the 2023-2031 Housing Element will be reviewed by the California Department of Housing and Community Development.

2.5.3 City/County Association of Governments of San Mateo County The Board of Directors of the City/County Association of Governments of San Mateo County (C/CAG) serves as the Airport Land Use Commission for airports within San Mateo County, including San Francisco International (SFO). As discussed in Section 4.9.1.2 and Section 4.13.1.2, Housing Opportunity Sites 14 and 19 are located within the 70-75 dB CNEL (Community Noise Equivalent Level) noise contour, and as shown in Table 3.2-1 are not zoned for residential use.1 Residential land uses are considered incompatible with 70-75 dB CNEL noise contour by the Comprehensive Airport Land Use Compatibility Plan for the Environs of the San Francisco International Airport (ALUCP) if they were not zoned for residential use when the current ALUCP went into effect (November 8, 2012). As such, the C/CAG Board on November 10, 2022 adopted a resolution declaring that the Housing Element Update is inconsistent with the ALUCP with regard to planned housing on Sites 14 and 19. The San Bruno City Council under the ALUCP can override the C/CAG determination of inconsistency; the local agency override process involves three mandatory steps:

1. Holding a public hearing by the local agency on the proposed override action;

2. Making of 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;

3. Approval of the override action by a two-thirds vote of the local agency’s governing body; the override action must include adoption of the specific findings identified in Step 2, above.

There are two key outcomes of a local agency override of a C/CAG Board determination a proposed land use action as inconsistent with the ALUCP:
1 dBA stands for A-weighted sound level; this scale of noise measurement gives greater weight to the frequencies of sound to which the human ear is most sensitive. 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.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 7 Initial Study
City of San Bruno December 2022
• The proposed land use action may proceed, subject to local agency review and permitting processes, as if it had been found consistent with this ALUCP by the C/CAG Board. • If a city or county overrides a decision of the Airport Land Use Commission C/CAG Board relating to a publicly owned airport that is not operated by that city or county, the agency operating the airport “shall be immune from liability for damages to property or personal injury caused by or resulting directly or indirectly from the public agency’s decision to override the commission’s action or recommendation” (see Pub. Util. Code, Section 21678).

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 8 Initial Study
City of San Bruno December 2022
SECTION 3.0 PROJECT DESCRIPTION

3.1 BACKGROUND

3.1.1 San Bruno General Plan 2025
Since 1969, the State of California has required all California cities and counties to have a General Plan (California Government Code Section 65300). The General Plan is a state-required legal document that each planning agency in California prepares and the legislative body of each county and city adopts to provide a comprehensive, long-term plan for the physical development of the county or city. A General Plan must include the following seven mandatory elements specified in Government Code Section 65302: a) land use, b) circulation, c) housing, d) conservation, e) open space, f) noise, and g) safety. The General Plan is the City’s official policy for its future character, form, and quality of development. The General Plan describes the amount, type and phasing of development needed to achieve the City’s social, economic, and environmental goals. It is the policy framework for decision making on both private development projects and City capital expenditures.

The current General Plan (“General Plan 2025”) and associated EIR were adopted by the City Council in 2009. The Housing Element includes 23 Housing Opportunity Sites, some of which are already designated for housing as part of the current General Plan. Housing Opportunity Sites 6, 8, 10, 16, and 18 would conform with the City’s General Plan and Municipal Code; Site 19 would comply with the City’s General Plan but require a conforming rezoning to the Transit Oriented District (TOD) zoning district.

Since the adoption of the General Plan 2025, the City has adopted two long-range planning documents, including the Transit Corridors Plan (adopted in February 2013) and the Bayhill Specific Plan (adopted in October 2021). These plans in relationship to the Housing Opportunity Sites identified in the Housing Element Update (refer to Figure 3.2-1 and Section 3.2.1) are discussed below.

3.1.1.1 Transit Corridors Plan
The Transit Corridors Plan (TCP) outlines detailed policies, design guidelines and development standards to steer future public and private realm improvements in the TCP area. The boundaries of the TCP area in relationship to the Housing Opportunity Sites identified by the Housing Element Update are shown on Figure 3.2-1.

As shown on Figure 3.2-1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The environmental effects of buildout of the TCP, including residential development at the Housing Opportunity Sites located within the TCP area at the densities assumed by the Housing Element Update, were analyzed in 2013 at a programmatic level in the San Bruno Transit Corridors Plan Environmental Impact Report (“TCP EIR”). The TCP EIR concluded that implementation of the TCP would result in significant and unavoidable impacts as regards historic resources, noise, and on intersection level of service (LOS). All other impacts were determined to be less than significant with mitigation incorporated. With the advent of 2018 amendments to CEQA resulting from Senate Bill 743 (SB 743), impacts to intersection LOS are no longer considered impacts under CEQA.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 9 Initial Study
City of San Bruno December 2022

3.1.1.2 Bayhill Specific Plan
The Bayhill Specific Plan establishes a new policy and regulatory framework for guiding private and public development within an approximately 92.2-acre area bounded by Interstate 280 to the west, Interstate 380 to the north, properties fronting El Camino Real to the east, and San Bruno Avenue West to the south. The boundaries of the Bayhill Specific Plan area in relationship to the Housing Opportunity Sites identified by the Housing Element Update are shown on Figure 3.2-1.

As shown on Figure 3.2-1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. The environmental effects of buildout of the Bayhill Specific Plan, including residential development at the Housing Opportunity Sites located within the Bayhill Specific Plan area at the densities assumed by the Housing Element Update, were analyzed in 2021 at a programmatic level in the Environmental Impact Report for the Bayhill Specific Plan Including the Phase I Development (“Bayhill Specific Plan EIR”). The Bayhill Specific Plan EIR concluded that implementation of the Bayhill Specific Plan would result in significant and unavoidable air quality and vehicle miles traveled impacts. All other impacts were determined to be less than significant with mitigation incorporated.

3.1.2 Housing Element
As noted above, the Housing Element is one of seven state-mandated General Plan elements. The required contents of a housing element are set forth in California Government Code Section 65583.

Among other requirements, housing elements are required to adequately plan to meet their existing and projected housing needs, including their share of the “regional housing need”. The law recognizes that in order for the private sector to adequately address housing needs and demand, local governments must adopt land use plans and regulatory schemes that provide opportunities for, and do not unduly constrain, housing development. Specifically, Section 65583 states that the Housing Element shall consist of “…an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources and scheduled programs for the preservation, improvement, and development of housing.” The Housing Element must also contain a schedule of actions that the local government is undertaking to implement the goals and objectives (i.e., the city’s required contribution to the provision of housing for the region). State law requires that the Housing Element be updated periodically, usually every eight years. It is subject to detailed statutory requirements and mandatory review by the California Department of Housing and Community Development (HCD).

The City’s current housing element (San Bruno Housing Element 2015-2023) was adopted by the City Council in April 2015 and certified by HCD. The adopted housing element covers the period between January 31, 2015 and January 1, 2023. State law requires all nine Bay Area counties and the local jurisdictions therein to update their respective housing elements to account for their regional housing needs allocation (discussed below in Section 3.1.3 ) and submit them to HCD by January 31, 2023. The City of San Bruno’s proposed housing element update is discussed in detail below in Section 3.2 .

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 10 Initial Study
City of San Bruno December 2022

3.1.3 Regional Housing Needs Allocation
Under state law, the HCD is required to allocate a region’s share of the projected statewide housing need to its council of governments, based on California Department of Finance population projections and regional population forecasts. The Association of Bay Area Governments (ABAG) is the regional authority charged with preparing the regional housing needs allocation (RHNA), which quantifies the housing need for local jurisdictions in the San Francisco Bay Area. Once the region’s fair share of regional housing need is determined, the housing need is allocated amongst all of the jurisdictions (cities/counties) within that region, and the city’s fair share of regional housing need is calculated for each established planning horizon.

The City of San Bruno’s fair share of the regional housing need for 2023 to 2031 was calculated as 3,165 housing units. Additionally, the No Net Loss Law (California Government Code Section 65863) requires that enough sites are available at all times throughout the RHNA planning period to meet a jurisdiction’s remaining unmet housing needs for each income category. To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, HCD recommends jurisdictions create a buffer in the housing element inventory of at least 15 percent (equivalent to an additional 475 units allocated to the City of San Bruno for the 2023-2031 period). Table 3.1-1 below presents the City’s RHNA and 15 percent buffer broken down by household income category.

Table 3.1-1: City of San Bruno RHNA by Household Income Category Household Income Category1 RHNA 15 Percent
Buffer
Combined
Housing Targets2
Very Low (<50% AMI) 704 106 810
Low (50-80% AMI) 405 61 466
Moderate (80-120% AMI) 573 86 659
Above Moderate (>120% AMI) 1,483 222 1,705
Total Housing Units 3,165 475 3,640
Source: Association of Bay Area Governments. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031. December 2021.

Notes:
1 The AMI (area median income) in San Mateo County as of 2022 was $166,000. Source: U.S. Department of Housing & Urban Development Office of Policy Development & Research . “FY 2022 Income Limits Documentation System”. Accessed October 25, 2022.
https://www.huduser.gov/portal/datasets/il/il2022/2022summary.odn 2 Combined targets calculated by adding the City’s RHNA with the proposed 15 percent buffer.

3.1.4 Existing Conditions
In the current RHNA cycle, which spans January 31, 2015 to January 31, 2023, the City of San Bruno was allocated 1,155 housing units, including 358 very-low, 161 low-, 205 moderate-, and 431 above moderate income housing units. As reported in the latest Annual Housing Element Progress Report, the City of San Bruno as of December 31, 2021 has permitted 284 housing units during the Fifth RHNA cycle, including 20 very-low, 96 low-, 68 moderate-, and 100 above moderate-income DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 11 Initial Study
City of San Bruno December 2022
units, bringing the City’s total housing stock to 15,922 units. Within the City of San Bruno, there are a total of approximately 42,656 residents and 16,696 households, and an estimated 2.64 residents per household.[2][3]

3.2 PROJECT DESCRIPTION
As required by Government Code Section 65583(a)(3), the Housing Element Update involves the preparation of an inventory of land suitable and available for residential development, including vacant sites and sites with a realistic and demonstrated potential for redevelopment during the planning period to meet the City’s housing need at the designated income levels (shown in Table

3.1-1). In accordance with the sites inventory requirements under California Government Code sections 65583(c), the project will also include a program that identifies actions that the City is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the 2023-2031 Housing Element through the administration of land use and development controls (including General Plan Amendments and rezoning). These project elements are discussed below.

The Housing Element Update does not propose or approve any specific developments (i.e., construction of housing or related infrastructure) that could directly result in physical changes to the environment.

3.2.1 Housing Sites Inventory
In total, the City has identified 23 Housing Opportunity Sites that could be redeveloped with approximately 2,709 housing units. The locations of these Housing Opportunity Sites are shown on Figure 3.2-1, and aerials of individual groupings of Sites are shown on Figure 3.2-2 through Figure

3.2-7. Table 3.2-1 below reports the address and the approximate number of units that could be developed at each site under the proposed 2023-2031 Housing Element, as well as the current and proposed General Plan land use designation and zoning district. 2 California Department of Finance. “E-1 Population Estimates for Cities, Counties, and the State – January 1, 2021 and 2022.” Accessed August 4, 2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-andhousing-estimates-for-cities-counties-and-the-state-2020-2022/ 3 United States Census Bureau. Quick Facts, San Bruno city, California. Accessed October 24, 2022. https://www.census.gov/quickfacts/fact/table/sanbrunocitycalifornia/PST040219#qf-flag-X DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 21
18 19
20 22
23 Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User Community
Key to Sites
ATT Building
Bank of America
Bayhill Shopping Center
Car Sales Lot
Citibank
Engvall MS
Former Budget Motel
Former Edgemont ES
IHOP Restaurant
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
Chilli's Restaurant
Vacant Site
Bedroom Express
San Bruno Gas
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 ±
00 0.25 .5 1
Miles
Prepared July 30, 2022
18 19
20 21
22 23
Key to Boundaries
City Limits
Bayhill Specific Plan Boundary
TransitOrientedDevelopmentOverlay
General Plan
Amendment
Site
HOUSING OPPORTUNITY SITES FIGURE 3.2-1
City of San Bruno2023-2031 Housing Element Update 12 Initial Study December 2022
"Cl
Ir
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
t=J ,---,
l---1
D
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 San Bruno Avenue West
Trae er Avenue
Bayhill Drive
Elm Avenue
Elm Avenue
Grundy Lane
Cherry Avenue
Cherry Avenue
Cedarwood Court
Sycamore Avenue Acacia Avenue
Cypress Avenue
Angus Avenue West
Kains Avenue
El Camino Real
Hensley Avenue
Euclid Avenue
Camino Plaza
San Bruno Avenue West
Traeger Avenue
Bayhill Drive
Bayhill Drive
Elm Avenue
Elm Avenue
Grundy Lane
Cherry Avenue
Cherry Avenue
Cedarwood Court
Sycamore Avenue Acacia Avenue
Cypress Avenue
Angus Avenue West
Kains Avenue
El Camino Real
Hensley Avenue
Euclid Avenue
Camino Plaza
82 82
280
380
1 20
13 3
Aerial Source: Google Earth Pro, Oct. 19, 2022. Photo Date: n/a 0 100 400 800 Feet
801-851 Traeger Avenue
899 El Camino Real
851 Cherry Avenue
1 840 San Bruno Avenue
3 13
20 AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITES 1, 3, 13 & 20 FIGURE 3.2-2 City of San Bruno2023-2031 Housing Element Update 13 Initial Study December 2022
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 El Camino Real
Linden Avenue
Elm Avenue
Acacia Avenue
Linden Avenue
Angus Avenue West
San Mateo Avenue
Mastick Avenue
Mastick Avenue
Sylvan Avenue
Sylvan Avenue
Huntington Avenue
1st Avenue
Florida Avenue
Taylor Avenue
Chapman Avenue
Jenevein Avenue
Jenevein Avenue
Hazel Avenue
Cypress Avenue
Beech Avenue
Poplar Avenue
El Camino Real
Linden Avenue
Elm Avenue
Acacia Avenue
Linden Avenue
Angus Avenue West
Angus Avenue West
San Mateo Avenue
Mastick Avenue
Mastick Avenue
Sylvan Avenue
Sylvan Avenue
Huntington Avenue
1st Avenue
Florida Avenue
Taylor Avenue
Chapman Avenue
Crystal Springs Ave
Jenevein Avenue
Jenevein Avenue
Hazel Avenue
Cypress Avenue
Beech Avenue
Poplar Avenue
U.P.R.R.

U.P.R.R.
82 82
2 5
8 9
4 17
22 23
Aerial Source: Google Earth Pro, Oct. 21, 2022. Photo Date: n/a 0 100 400 600 800 Feet
2 465 San Mateo Avenue
4 529 El Camino Real
5 475 San Mateo Avenue
8 500 Acacia Avenue
9 590 El Camino Real
17 333 El Camino Real
22 426 El Camino Real
23 401 San Mateo Avenue
AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITES 2, 4, 5, 8, 9, 17, 22 & 23 FIGURE 3.2-3 City of San Bruno2023-2031 Housing Element Update 14 Initial Study December 2022
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 El Camino Real
San Bruno Avenue West
San Bruno Avenue West
Kains Avenue
Elm Avenue
Linden Avenue
Camino Plaza
San Bruno Avenue East
Hensley Avenue
Green Avenue
Easton Avenue
Masson Avenue
Mills Avenue
Huntington Avenue
Huntington Avenue
San Mateo Avenue
San Mateo Avenue
1st Avenue
El Camino Real
San Bruno Avenue West
San Bruno Avenue West
Kains Avenue
Elm Avenue
Linden Avenue
Camino Plaza
San Bruno Avenue East
Hensley Avenue
Green Avenue
Easton Avenue
Masson Avenue
Mills Avenue
Huntington Avenue
Huntington Avenue
San Mateo Avenue
San Mateo Avenue
1st Avenue
U.P.R.R.

U.P.R.R.

Euclid Avenue
82 82
7 12
11 15 Aerial Source: Google Earth Pro, Oct. 21, 2022. Photo Date: n/a 21 0 50 300 400 600 Feet
7 850 El Camino Real
11 750 El Camino Real
12 750 El Camino Real
15 170 San Bruno Avenue West
21 104 San Bruno Avenue West
AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITES 7, 11, 12, 15 & 21 City of San Bruno2023-2031 Housing Element Update 15 Initial Study December 2022
FIGURE 3.2-4
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 San Marco Avenue
San Luis Avenue
Santa Dominga Avenue
Santa Lucia Avenue
Santa Lucia Avenue
San Anselmo Avenue South
El Camino Real
Linden Avenue
Poplar Avenue
San Marco Avenue
San Luis Avenue
Santa Dominga Avenue
Santa Lucia Avenue
Santa Lucia Avenue
San Anselmo Avenue South
El Camino Real
Linden Avenue
Poplar Avenue
82 82
16 10
Aerial Source: Google Earth Pro, Oct. 20, 2022. Photo Date: n/a 0 25 150 200 300 Feet
10 116 San Marco Avenue
16 San Marco Avenue
AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITES 10 & 16
City of San Bruno2023-2031 Housing Element Update 16 Initial Study December 2022
FIGURE 3.2-5
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 82 82 380
380
Sneath Lane
Huntington Avenue
Huntington Avenue
South Maple Avenue
Tanforan Avenue
Bayshore Circle
Buena Vista Ave Dollar Avenue Herman Street Herman Street San Mateo Avenue San Mateo Avenue
Shaw Road
Scott Street
Forest Lane
El Camino Real
Sneath Lane
Commodore Drive
National Avenue
Noor Avenue
Rockwood Drive
Sneath Lane
Huntington Avenue
Huntington Avenue
South Maple Avenue
Tanforan Avenue
Bayshore Circle
Buena Vista Ave Dollar Avenue Herman Street Herman Street San Mateo Avenue San Mateo Avenue
Shaw Road
Scott Street
Forest Lane
El Camino Real
Sneath Lane
Commodore Drive
National Avenue
Noor Avenue
Rockwood Drive
Centennial Way Trail
U.P.R.R.

U.P.R.R.
14 18
19 14
1122-1150 El Camino Real
1292 Huntington Avenue
Aerial Source: Google Earth Pro, Oct. 19, 2022. Photo Date: n/a 0 100 400 600 1,000 Feet
1151 El Camino Real
1101 El Camino Real
14 18
19 AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITES 14, 18 & 19 FIGURE 3.2-6 City of San Bruno2023-2031 Housing Element Update 17 Initial Study December 2022
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 ngva our
Sneath Lane
Sneath Lane
Quail Point Ci cr el
Catalpa Way
Toyon Way
Rollingwood Drive
Picadilly Place
Boardwalk
Drive
Boardwalk Avenue
Engvall Court
Sneath Lane
Sneath Lane
Quail Point Ci cr el
Catalpa Way
Toyon Way
Rol
l
i
n
g
wood
Drive
Picadilly Place
Boardwalk
D
rive
BoardwalkAvenue
San Bruno Creek San Bruno Creek
380
280
280
6 Aerial Source: Google Earth Pro, Oct. 20, 2022. Photo Date: n/a 0 50 300 400 600 Feet 6 2101 Sneath Lane
AERIAL PHOTOGRAPH OF HOUSING OPPORTUNITY SITE 6
City of San Bruno2023-2031 Housing Element Update 18 Initial Study December 2022
FIGURE 3.2-7
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Table 3.2-1: Inventory of Housing Opportunity Sites
Site ID –
Existing Use Address (APN)
General Plan Designation Zoning District Site
Acreage
Housing Unit
Capacity1
Existing Proposed Existing Proposed
1 - AT&T
Building*
840 San Bruno
Avenue
(020-071-050)
TOD TOD TOD-2 TOD-2 1.6 320
2 – Bank of
America*
465 San Mateo
Avenue
(020-362-180)
TOD TOD CBD CBD 0.5 45
3 – Bayhill
Shopping
Center^
851 Cherry
Avenue (020-
012-190)
Regional
Office
Regional
Office BNC BNC 9.2 210
4 –
Automobile
retail*
529 El Camino
Real (2
) TOD TOD TOD-2 TOD-2 1.4 72
5 – Citibank*
475 San Mateo
Avenue (020-
361-240)
TOD TOD CBD CBD 0.7 60
6 – San Bruno
Golf Center
2101 Sneath
Lane
(019-270-260; -
270)
Low-Density
Residential
Low-Density
Residential R-1 R-1 21.1 118
7 – Vacant
Motel*
850 El Camino
Real (020-116-
310)
TOD TOD TOD-2 TOD-2 0.6 60
8 – Edgemont
Elementary
School
500 Acacia
Avenue (020-
253-050)
Low-Density
Residential
Low-Density
Residential R-1 R-1 2.2 16
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Table 3.2-1: Inventory of Housing Opportunity Sites
Site ID –
Existing Use Address (APN)
General Plan Designation Zoning District Site
Acreage
Housing Unit
Capacity1
Existing Proposed Existing Proposed
9 – Restaurant
/Parking Lot*
590 El Camino
Real (020-145-
010; -020; -030;
-470)
TOD TOD TOD-2 TOD-2 0.6 42
10 – Vacant
Lot
117 San Marco
Avenue (021-
172-130)
Low-Density
Residential
Low-Density
Residential R-2 R-2 0.2 2
11 – Melody
Toyota Lot*
750 El Camino
Real (020-126-
050; -140)
TOD TOD TOD-2 TOD-2 0.4 41
12 – Melody
Toyota
Showroom*
750 El Camino
Real (020-126-
200)
TOD TOD TOD-2 TOD-2 0.3 34
13 – Office
Building^
801-851 Traeger
Avenue (020-
017-020)
Regional Office Regional
Office BRO BRO 6.1 205
14 – Tanforan
Shopping
Center3
1122-1150 El
Camino Real
(014-316-240;
-300; -330; -360)
1292 Huntington
Avenue (014-
311-060)
Regional
Commercial
Regional
Commercial P-D P-D 44 1,000
15 – Vacant
Lot*
170 San Bruno
Avenue (020-
111-160)
TOD TOD TOD-1 TOD-1 0.3 42
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Table 3.2-1: Inventory of Housing Opportunity Sites
Site ID –
Existing Use Address (APN)
General Plan Designation Zoning District Site
Acreage
Housing Unit
Capacity1
Existing Proposed Existing Proposed
16 – Vacant
Lot
San Marco
Avenue (021-
172-120)
Low-Density
Residential
Low-Density
Residential R-2 R-2 0.1 2
17 –
Walgreens*
333 El Camino
Real (020-293-
030)
TOD TOD TOD-2 TOD-2 1.3 150
18 – Medical
Office
1101 El Camino
Real (020-013-
200)
High-Density
Residential
High-Density
Residential P-D P-D 0.1 15
19 –
Veterinary
Office
1151 El Camino
Real (020-013-
100)
Multi-Use
Residential
Focus
Multi-Use
Residential
Focus
C-N TOD 0.6 60
20 –
Restaurant*
899 El Camino
Real (020-019-
080)
TOD TOD TOD-2 TOD-2 1.3 100
21 – Vacant
Lot*
104 San Bruno
Avenue (020-
111-150)
TOD TOD TOD-1 TOD-1 0.2 26
22 – Retail*
426 El Camino
Real (020-362-
240)
TOD TOD CBD CBD 0.3 49
23 – Gas
Station*
401 San Mateo
Avenue (020-
362-210)
TOD TOD CBD CBD 0.2 40
Total 2,709
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Table 3.2-1: Inventory of Housing Opportunity Sites
Site ID –
Existing Use Address (APN)
General Plan Designation Zoning District Site
Acreage
Housing Unit
Capacity1
Existing Proposed Existing Proposed
Notes:
1 The reported housing unit capacity is based on a combination of site acreage; floor area ratio, height, and density restrictions associated with the site’s land use designation and zoning district; and/or projects currently proposed at the sites identified. 2 APNs include: 020-256-090; -100; -130; -140; -150; -160; -170; -180; -190; -250; -260; -270; -280; -320; -340; -350. 3 The Tanforan Shopping Center site is the only identified housing opportunity site that would require a General Plan Amendment and rezoning. * Indicates a site located within the Transit Corridors Plan area. ^ Indicates a site located within the Bayhill Specific Plan area.

I I
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 23 Initial Study
City of San Bruno December 2022
In addition to the 23 opportunity sites that are anticipated to accommodate approximately 2,709 housing units, the City has identified 669 units that have been approved and are expected to be permitted during the 2023-2031 Housing Element cycle, as well as 240 accessory dwelling units (ADUs), for a total of 3,618 units.4
A summary of the housing units by household income category is provided in Table 3.2-2.

Table 3.2-2: Summary of All Identified Housing Units
Inventory Type
Household Income Category
Total
Very Units -Low Low Moderate AboveModerate
2023-2031 Housing
Element Update 571 335 479 1,324 2,709
Pipeline Projects 38 47 32 553 669
ADUs 72 72 72 24 240
Total Units 681 454 583 1,900 3,618

3.2.2 General Plan Amendments and Rezoning

3.2.2.1 Housing Opportunity Site 14
Housing Opportunity Site 14 would require a General Plan Amendment and rezoning in order to complete buildout of the Housing Element Update. Housing Opportunity Site 19 would require a conforming rezoning to the TOD zoning district. Residential development of the other 21 Housing Opportunity Sites at the densities prescribed in the Housing Element Update are already allowed under their existing General Plan land use designations and zoning districts.

The Tanforan Shopping Center at Site 14 is planned for a maximum of 1,000 housing units which are not currently permitted at the site. Staff anticipates a master planning process for a transit-oriented, mixed-use development on the site that includes residential, office, and retail uses. On October 5, 2022, the property owner of Site 14 submitted a preliminary application to demolish the existing mall (excluding the Target and Century at Tanforan buildings) and redevelop the site with 1,000 housing units, an approximately two million square-foot office (life science) campus, and retail uses. The redevelopment of the property would be subject to amending the City’s General Plan and amending the current P-D zoning district to incorporate potential additional uses such as office, housing, and retail land uses. The application will be processed by City staff, including completion of project-level CEQA environmental review, reviewed and recommended by Planning Commission before the City Council makes the final decision on the required discretionary approvals.

At this time, the specific land use designation and zoning district for which a General Plan Amendment and rezoning of Site 14 would be required is not known; as such, this Initial Study analyzes the reasonably foreseeable redevelopment of Site 14 with up to 1,000 residential units. The anticipated future amendment of Site 14’s land use designation and zoning district would be 4 Pipeline units are those that have undergone CEQA review separately and received their discretionary entitlements, but have not yet received building permits.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 24 Initial Study
City of San Bruno December 2022
evaluated for potential environmental impacts to confirm whether the GPA and rezoning are consistent with the conclusions of this Initial Study/MND or whether supplemental CEQA review would be required.

3.2.2.2 Amendment of General Plan Policy HS-40
General Plan Policy HS-40 currently reads as follows:
“Prohibit new residential development within the 70+ Airport CNEL areas, as dictated by Airport Land Use Commission infill criteria.”
The Housing Element Update would amend General Plan Policy HS-40 to read:
“Prohibit new residential development within the 70-75 Airport CNEL areas, as dictated by Airport Land Use Commission infill criteria, unless, on a project by project, a proposed residential development is approved through the Local Agency Override process consistent with the Public Utilities Code Section 21675.1(d).”
The revision to General Plan Policy HS-40 would allow for the future development of Housing Opportunity Sites 14 and 19 with residential uses. As documented in Section 4.13.1 under Impact NOI-3, modern noise insulation methods and materials can achieve a 45 dBA CNEL interior noise level as required by Title 24, Part 2 of the California Building Code, Policy NP-4.1 of the ALUCP, and Policy HS-35 of the San Bruno General Plan. Accordingly, amendment of General Plan Policy HS-40 to allow for the redevelopment of Sites 14 and 19 with residential uses would result in acceptable interior noise levels for future residents, and is not evaluated further in this Initial Study.

3.2.2.3 Amendment of R-2 Zoning District
The R-2 zoning district, as described in Section 12.96.070 of the San Bruno Municipal Code, currently allows one dwelling unit for every 2,900 square feet of lot area. The Housing Element Update would amend Section 12.96.070 to allow two dwelling units on all R-2 zoned parcels regardless of lot size, and require a minimum of two dwellings units per vacant lot for new development.

A study by ECONorthwest on behalf of the City determined that this amendment would result in approximately 10 new dwelling units distributed throughout the City.5 The future location of these 10
additional units is not reasonably foreseeable at this time, but it is anticipated that due to the distribution of R-2 zoned lots throughout the City (refer to Figure 3.2-8), these 10 additional units would not be grouped together such that the combined construction or operation of these units would cumulatively contribute to an environmental impact.
5 ECONorthwest. Scenario Analysis Results. July 2022.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
R-1 R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1 R-1 R-1 R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1 R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1 R-1 R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
O
O
O
U
M-1
M-1
M-1
A-R
C-N
R-1
C-N
C-N
R-1
R-2
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1 R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
C-N
C-N
C-N
C-N
C-N
R-4
R-4
R-4
R-4 R-4
R-4
R-4
R-4
P-D
C-N
O
R-1
R-1 R-1
P-D
P-D
P-D
P-D
R-2
R-2
R-2
R-2
R-2
R-2
R-2 R-2
R-2
R-2 R-2
R-2 R-2
R-2 R-2
R-2
R-2 R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2 R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-2
R-1
R-2
R-2 R-2
R-2
R-2
R-2
R-2
C-B-D

C-B-D C-B-D
C-B-D
M-1 M-1
M-1 M-1
M-1 M-1
P-D
O
R-1
R-1
R-1
C-N
R-3
R-3
R-3
R-3
R-2
R-2
R-2
R-1
R-1
R-1
R-1
P-D
R-1
R-1
R-1
R-1
R-1
R-1
R-1
R-1
C-N
R-1
O
P-D
P-D
P-D
R-1
P-D
P-D
R-1
R-1
O
O
O
U
R-1
R-1
R-1
R-1
U
R-1
R-1
R-1
O
U
U
U
U
TOD2
TOD2
TOD2
TOD2 P-D
P-D
P-D
P-D
CC
TOD2
TOD2
TOD2
TOD2
R-1
MXR
MXR
MXR
MXR
MXR
MXR
MXR
MXR
MXR
MXR
MXR
C-B-D
C-B-D

C-B-D C-B-D
TOD2
TOD2
TOD2
C-B-D

C-B-D C-B-D
C-B-D
TOD2
TOD2
TOD1
TOD1
TOD1 TOD1
TOD1 TOD1 TOD2 P-D
TOD1
C-B-D
TOD1
TOD1
TOD1
TOD1
TOD2
TOD1
TOD1 TOD1 TOD1 TOD1 TOD1
R-1
TOD1
TOD1

TODS TODS
TOD1 TOD1 TOD1 TOD1 TOD1
TODS
TODS
TOD1
TOD1
TOD2
TOD2
P-D
TOD2
MXR
MXR
MXR
MXR
R-3
R-3
R-4
TOD1
BRO
BRO
BRO
BRO
BNC
BRO
BRO
BRO
TODS
P-D
¤£101
¤£101
¨¦§280
¨¦§380
§¨¦380
¨¦§280
ÄÆ35
ÄÆ35
ÄÆ35

KAINS AVE

SNEATH LN

CLAREMONT DR

OLYMPIC DR

MASTICK AVE

HER M AN ST

WALNUT AVE

SEQUOIA AVE

HAMPTON CT

ANGUS AVE W

HUNTINGTON AVE

EARL AVE

SAN FELIPE AVE

BAYHILL DR

SANTA LUCIA AVE

CRESTMOOR DR

ROLLINGWOOD DR

SAN ANTONIO AVE

SAN ANSELMO AVE S

SYLVAN AVE

ROSEWOOD DR

OAKMONT DR

MONTEREY DR

VALLEYWOOD DR

COLLEGE DR

HUNTINGTON AVE

TRAEGER AVE

CAMINO PLAZA

PRINCETON DR

ELSTON DR

WHITMAN WY

ELM AVE
7TH AVE

SUSAN DR

FLEETWOOD DR

MADISON AVE

MORELAND DR

CHERRY AVE

CRYSTALSPRINGS RD

GRUNDY LN

EL CAMINO REAL

SAN BRUNO AVE W

SAN BRUNO AVE E

CRYSTAL SPRINGS RD

JENEVEIN AVE

SHARP PARK RD

CHERRY AVE

WESTBOROUGH BLVD

SAN MATEO AVE

COLLEGE DR

HUNTINGTON AV E

SNEATH LN

CALIFORNIA

GOLF CLUB

SAN FRANCISCO

INTERNATIONAL

AIRPORT

MILLBRAE

COUNTRY
CLUB
PARK

UNINCORPORATED
DALY
CITY
DALY
CITY

PACIFICA

SOUTH SAN

FRANCISCO
±
0 500 1,000 1,500 2,000 250 Feet
Legend
Residential Zones
R-1, Single Family Residential
R-2, Low Density Residential
R-3, Medium Density Residential
R-4, High Density Residential
Mixed Use Zones
CBD, Central Business District
TODS, TOD-Station Office
TOD1, Medium Density Mixed Use
TOD2, High Density Mixed Use
MXR, Multi Use--Residential Focus
CC, Civic Center
Bayhill Specific Plan Zones
Bayhill Neighborhood Commercial (BNC)
Bayhill Regional Office (BRO)
All Other Zones
C-N, Neighborhood Commercial
A-R, Administrative and Research
M-1, Industrial
P-D, Planned Development
O, Open Space
U, Unclassified
Specific Plans / Overlay Zones
Bayhill Mixed Use Overlay
Bayhill Residential Overlay
Bayhill Specific Plan
Transit Corridors Area
Source: City of San Bruno, November 7, 2021.

CITY OF SAN BRUNO ZONING MAP FIGURE 3.2-8
2023-2031 Housing Element Update
City of San Bruno
25 Initial Study
December 2022
• ,.J~
'
~ /
\
\ --
•
\
\ ~
~
(
____,
-
-
-
-
-
-
-
-
-
-
-
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 26 Initial Study
City of San Bruno December 2022
SECTION 4.0 ENVIRONMENTAL SETTING, CHECKLIST, AND

IMPACT DISCUSSION
This section presents the discussion of impacts related to the following environmental subjects in their respective subsections:

4.1 Aesthetics

4.2 Agriculture and Forestry Resources

4.3 Air Quality

4.4 Biological Resources

4.5 Cultural Resources

4.6 Energy

4.7 Geology and Soils

4.8 Greenhouse Gas Emissions

4.9 Hazards and Hazardous Materials

4.10 Hydrology and Water Quality

4.11 Land Use and Planning

4.12 Mineral Resources

4.13 Noise

4.14 Population and Housing

4.15 Public Services

4.16 Recreation

4.17 Transportation

4.18 Tribal Cultural Resources

4.19 Utilities and Service Systems

4.20 Wildfire

4.21 Mandatory Findings of Significance
The discussion for each environmental subject includes the following subsections:
• Environmental Setting – This subsection 1) provides a brief overview of relevant plans, policies, and regulations that compose the regulatory framework for the project and 2) describes the existing, physical environmental conditions at the project site and in the surrounding area, as relevant.
• Impact Discussion – This subsection 1) includes the recommended checklist questions from Appendix G of the CEQA Guidelines to assess impacts and 2) discusses the project’s impact on the environmental subject as related to the checklist questions. For significant impacts, feasible mitigation measures are identified. “Mitigation measures” are measures that will minimize, avoid, or eliminate a significant impact (CEQA Guidelines Section 15370). Each impact is numbered to correspond to the checklist question being answered. For example, Impact BIO-1 answers the first checklist question in the Biological Resources section.

Mitigation measures are also numbered to correspond to the impact they address. For example, MM BIO-1.3 refers to the third mitigation measure for the first impact in the Biological Resources section.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 27 Initial Study
City of San Bruno December 2022

4.1 AESTHETICS

4.1.1 Environmental Setting

4.1.1.1 Regulatory Framework
State
Senate Bill 743
Senate Bill (SB) 743 was adopted in 2013 and requires lead agencies to use alternatives to level of service (LOS) for evaluating transportation impacts, specifically vehicle miles traveled (VMT). SB 743 also included changes to CEQA that apply to transit-oriented developments, as related to aesthetics and parking impacts. Under SB 743, a project’s aesthetic impacts will no longer be considered significant impacts on the environment if:
• The project is a residential, mixed-use residential, or employment center project, and • The project is located on an infill site within a transit priority area.6 SB 743 also clarifies that local governments retain their ability to regulate a project’s aesthetics impacts outside of the CEQA process.

Streets and Highway Code Sections 260 through 263
The California Scenic Highway Program (Streets and Highway Code, Sections 260 through 263) is managed by Caltrans. The program is intended to protect and enhance the natural scenic beauty of California highways and adjacent corridors through special conservation treatment.

In San Mateo County, there are three state-designated scenic highways, including California State Route 1 (SR 1) segment between south of Half Moon Bay to the Santa Cruz County line, California State Route 35 (SR 35) segment between State Route 92 (SR 92) intersection to Santa Cruz County Line, and Interstate 280 (I-280) segment near the City of San Bruno to Santa Clara County line. I-280 is the only state-designated scenic highway within the San Bruno city limits. 6 Pursuant to Public Resources Code 21061.3: An “infill site” is defined as “a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses.” Pursuant to Public Resources Code 21099(a)(7): A “transit priority area” is defined as “an area within 0.5 mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations.”
Pursuant to Public Resources Code 21064.3: A “major transit stop” means “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.”
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 28 Initial Study
City of San Bruno December 2022
Regional and Local
County of San Mateo General Plan
The County of San Mateo General Plan states that Crystal Springs Road, El Camino Real (from Easton Drive to Crystal Springs Road), and Sharp Park Road are County-designated scenic roads.7

City of San Bruno General Plan
A scenic corridor is defined in the San Bruno General Plan as a “roadway or highway with unique or distinctive physical or cultural features”. The General Plan identifies one state-designated scenic corridor, I-280, and one local scenic corridor, Skyline Boulevard (Highway 35), which is also eligible for designation as a State Scenic Highway. San Bruno recognizes Sneath Lane, Crystal Springs Road, and Sharp Park Road as local scenic corridors. The City is also a participant in the Grand Boulevard Initiative, which seeks to turn El Camino Real into a “grand boulevard of meaningful destinations” with high quality building designs.

The City of San Bruno General Plan identifies views from hills to the north and west as a prominent visual backdrop. Scenic vistas include views from San Bruno Mountain, Sweeney Ridge, and Skyline College, which is recessed into the hillsides and is shielded from view.

The City’s General Plan contains the following relevant policies:

Policies Description
LUD-E Ensure that new development, especially in residential neighborhoods, is sensitive to existing uses, and is of the highest quality design and construction.

LUD-3 During Plan review, protect the residential character of established neighborhoods by ensuring that new development conforms to surrounding design and scale.

LUD-4 Strengthen residential integrity in viable neighborhoods within the city’s Redevelopment Area by eliminating incompatible uses and by facilitating upgrading of deteriorated structures.

LUD-7 Require any subdivision or development involving construction of more than five units, regardless of the number of parcels, to undergo design review. Require provision of open spaces and pedestrian connections within multifamily projects, as well as an active street frontage along arterial roadways.

LUD-8 Develop and implement standards in the City’s Zoning Ordinance and Subdivision Regulations that minimize the visual dominance of garages in multifamily complexes. Use the following design techniques:
• Locate garages and carports to the rear of parcels;
• Provide access to tuck-under parking from the side or rear of parcels, particularly along major arterial roadways;
• Screen tuck-under parking with landscaping or other buffering techniques; and • Continue to allow shared driveway configurations, as appropriate. 7 San Mateo County. General Plan. November 1986.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 29 Initial Study
City of San Bruno December 2022
Policies Description
LUD-12 Improve the visibility of Downtown from El Camino Real through a variety of techniques that may include signage, lighting, landscape treatment, or provision of plaza or building design that “announces” Downtown.
• Require buildings along the intersection to present attractive and pleasant facades where visible from El Camino Real, including windows, displays and entryways (transparency) at ground level.
• Incorporate a historical marker to identify the intersection as the beginning of the California State Highway system.
• Improve the visibility of Downtown by expanding streetscaping and amenities to parcels on the west side of El Camino Real. Install directional signage or banners along El Camino Real to announce Downtown. Consider use of signage arching over El Camino Real were Caltrans to abandon State Highway designation for El Camino Real.
• Place clearly marked crosswalks and traffic lights to ensure the safety of residents and visitors entering Downtown from across El Camino Real. • Work with Caltrans and other agencies to modify El Camino Real street design to implement traffic calming measures that ensure safe pedestrian and bicycle access to Downtown.

LUD-15 Require pedestrian-oriented building design, including zero front setbacks (except where noted for public plazas), awnings, and building entries facing the street – to complement the city’s Downtown streetscape improvements.

LUD-21 Strengthen the identity of the existing internal “street” network in The Shops at Tanforan and Towne Center. Encourage transition of these two centers into an outdoor/indoor shopping “district,” as illustrated in Figure 2-6. Implement the following design techniques:
• Promote reuse and infill of existing surface parking lots. • Strengthen the existing internal street network (as shown in the concept diagram) to promote walkability between stores, services, and restaurants. • Ensure that the street network links the two shopping centers and preserves the visibility of the existing shopping complexes from El Camino Real. • Design all new commercial spaces to be located and oriented toward the walkable internal streets and toward Sneath Lane, with clear connections to enclosed mall entrances.
• Create fluid and visible pedestrian connections to and from the San Bruno BART Station.
• In accordance with Ordinance 1284, consider construction of necessary parking structures to replace existing surface parking lots. Locate parking structures along the edges of the shopping district to minimize vehicular traffic on internal pedestrian-oriented streets.
• Improve landscaping along El Camino Real to differentiate and announce the “district” from other developments along El Camino Real. • Incorporate gateway features on El Camino Real near the northern edge of Towne Center where San Bruno’s northern boundary exists.
• Develop a uniform signage plan to coordinate signs along the internal shopping streets with signs along El Camino Real.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 30 Initial Study
City of San Bruno December 2022
Policies Description
• Coordinate with the San Bruno Chamber of Commerce to market the new “district” as a regional marketplace.

LUD-25 Coordinate new development at the BART and Caltrain station areas with surrounding residential neighborhoods through landscaping, feathered building heights (taller buildings near stations and shorter buildings near existing residences), pedestrian connections, and other such techniques.

LUD-33 Plant additional street trees along the existing buffer between Huntington Avenue and the residential frontage road due east of the San Bruno BART Station.

LUD-44 Require multi-use developments along El Camino Real to provide a pedestrian-friendly environment along the street frontage, as follows:
• Require a minimum ground floor transparency requirement for all development north of Crystal Springs Road.
• Encourage pedestrian-scale architectural articulation (that is, awnings at appropriate heights).
• Require that buildings are located adjacent to the sidewalk, and that main entries are oriented toward the sidewalk.
• Locate parking lots at the side or rear of parcels. Buffer parking areas from the sidewalk with landscaping.
• Minimize curb cuts and parking access from El Camino Real. • Limit front setbacks to create an active street frontage.

LUD-49 Minimize building setbacks, orient building entrances toward the street (not parking lots), and vary features along the building façades on San Bruno Avenue.

LUD-69 Conduct a design review of all development in “Areas visible from all sites” in Figure 2-3 to ensure it is not visually over-dominant.

LUD-70 Provide incentives for developers to create view corridors from El Camino Real and Sneath Lane toward new internal open spaces at The Shops at Tanforan and Towne Center.

LUD-72 Require buildings in Downtown and in Transit-oriented Development district to screen mechanical equipment on the roof with non-glaring materials.

LUD-73 Require buildings with a continuous façade of 100 feet or longer to use non-reflective materials to minimize adverse impact of glare.

T-18 Require right-of-way landscaping to be maintained at an appropriate scale, so as to not reduce visibility at intersections.

T-25 Coordinate with Caltrans, San Mateo County, and adjacent cities in order to maintain a consistent approach in applying scenic conservation standards in roadway design, improvements, and maintenance.

T-26 Continue to limit widening, modification, or realignment of the City’s scenic corridors, consistent with Ordinance 1284. Preserve large trees and other natural features, limit signage, maintain wide setbacks, and reduce traffic speeds along these roadways.

T-27 Continue to support beautification efforts along Interstate 280, an officially designated State Scenic Highway.

T-28 Recognize and protect the following as local scenic corridors:
• Skyline Boulevard, State Scenic Highway
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 31 Initial Study
City of San Bruno December 2022
Policies Description
• Crystal Springs Road, County Scenic Road
• Sharp Park Road, County Scenic Road
• Sneath Lane
T-29 Review and update the City’s Scenic Corridor Protection Program for I-280, Skyline Boulevard, and future State-designated scenic highways.

T-30 Improve the appearance of the following streets:
• El Camino Real: Continue landscaping the median strips and review projects for good design. Coordinate landscaping design with neighboring jurisdictions. • San Mateo Avenue: Continue implementation of the Street Beautification Plan in conjunction with merchants and property owners.
• San Bruno Avenue (west of El Camino Real): Retain trees on Bayhill property along San Bruno Avenue, consistent with the City’s Tree Preservation policy. • Huntington Avenue/railroad tracks: Continue landscaping along both sides of the railroad tracks.

T-32 Encourage design of public and private development to frame vistas of the Downtown, public buildings, parks, and natural features.

T-33 Promote and facilitate planting of shade trees along all streets within San Bruno, through public education, developer incentives, and general beautification funds. Tree specifics should be selected to create a unified image and an effective canopy.

T-42 Do not allow parking lots to dominate the frontage of mixed-use streets, interrupt pedestrian routes, or negatively impact surrounding neighborhoods.

T-76 Require construction of sidewalks at least five (5) feet wide along newly built streets within San Bruno, and four (4) feet wide on older streets to preserve street character in older neighborhoods.

T-77 Create a pedestrian-oriented setting along the Pedestrian Emphasis Zones (see Figure 4-6) through potential construction of the following public improvements:
• Brick pavers to make sidewalks look more distinct;
• Street trees to soften the environment and provide color and shade; • Human-scale street lights for enhanced aesthetics and illumination; • Banners and flags to make the area look more festive and cheerful; and • Benches to give people a place to sit, rest, and watch what goes on around them.

T-78 Allow new development to contribute to the Pedestrian Emphasis Zones (Figure 4-6) through construction of off-site improvements.

OSR-28 Preserve Crestmoor Canyon in a natural state. Minimize changes to natural landforms, topography, rock outcroppings, mature tree stands, and other vegetation, while accommodating a multi-use trail and supporting facilities. Exceptions may be made for any necessary changes in order to improve slope stability.

OSR-32 During plan review, assure that development on city lands is compatible with preservation of Crestmoor Canyon, Junipero Serra Park, San Francisco Peninsula Watershed lands, Golden Gate National Recreation Area, and San Francisco International Airport wetlands in a natural state.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 32 Initial Study
City of San Bruno December 2022
Policies Description
OSR-33 Balance fire prevention goals with the preservation of the mature tree stands along the city’s scenic corridors, including Sneath Lane, Skyline Boulevard, I-280, and Crystal Springs Road, consistent with the Tree Preservation Ordinance and Ordinance 1284.

Landscaping of public rights-of-way along these corridors should complement the natural state.

OSR-34 Protect mature trees, as feasible, during new construction and redevelopment. Require identification of all trees over six inches in diameter and approval of landscaping plans during design review.

ERC-2 Preserve as open space those portions of property which have significant value to the public as scenic resources, aesthetic, or recreation purposes.

ERC-3 Protect natural vegetation in park, open space, and scenic areas as wildlife habitat, to prevent erosion, and to serve as noise and scenic buffers.

ERC-9 Preserve mature trees and vegetation, including wildflowers, within open canyon areas and along the city’s scenic roadways.

ERC-10 Require incorporation of native plants into landscape plans for new development as feasible – especially in areas adjacent to natural areas, such as canyons or scenic roadways (Figure 6-1). Require preservation of mature trees, as feasible, during design and construction.

ERC-12 Balance the need for fire safety and invasive plant species management with new considerations along the city’s scenic corridors. Encourage buildings to be located outside of the tree’s drip-line or 12 feet from the tree trunk, whichever is greater, and/or incorporating special techniques to minimize root damage, etc.

ERC-40 Ensure that new development adjacent to historic structures is compatible with the character of the structure and the surrounding neighborhood.

PFS-24 Require provision of attractive, convenient recycling bins and trash enclosures in grouped development projects (i.e., multi-family residential projects, office complexes, and commercial shopping centers).

PFS-65 Require new development to incorporate passive heating and natural lighting strategies if feasible and practical. These strategies should include, but are not limited to, the following:
• Using building orientation, mass and form, including façade, roof, and choice of building materials, color, type of glazing, and insulation to minimize heat loss during winter months and heat gain during the summer months; • Designing building openings to regulate internal climate and maximize natural lighting, while keeping glare to a minimum; and
• Reducing heat-island effect of large concrete roofs and parking surfaces.

City of San Bruno Municipal Code
Title 12, Land Use, Article III, Zoning of the San Bruno Municipal Code sets forth specific design guidelines, height limits, building density, building design and landscaping standards, architectural features, and open space and setback requirements.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 33 Initial Study
City of San Bruno December 2022
Residential Design Guidelines
Title 12 of the San Bruno Municipal Code requires that all changes to the exterior design of singlefamily and two-family residences in the City requiring discretionary approval or a building permit be consistent with San Bruno's Residential Design Guidelines. The Residential Design Guidelines identify basic design principles to be followed by all residential exterior improvements, additions, and new construction projects, as well as specific guidance on a wide variety of architectural considerations, such as neighborhood compatibility, setbacks, materials and colors, etc.

Tree Preservation Policies
Chapter 8.24 of the City of San Bruno Municipal Code, “Street Trees and Other Plantings” regulates the planting and maintenance of trees and other plantings in and along the public streets, ways, and public easements within the city. Chapter 8.25, “Heritage Trees”, protects certain trees located on private property within the City of San Bruno, including:

1. Any native bay (Umbellularia californica), buckeye (Aesculus species), oak (Quercus species), redwood (Sequoia sempervirens), or pine (Pinus radiata) tree that has a diameter of six inches or more measured at fifty-four inches above natural grade;

2. Any tree or stand of trees designated by resolution of the city council to be of special historical value or of significant community benefit;

3. A stand of trees, the nature of which makes each dependent on the others for survival; or

4. Any other tree with a trunk diameter of ten inches or more, measured at fifty-four inches above natural grade.

Ordinance 1284
Adopted in June 1977, this ordinance limits building heights to 50 feet or three stories unless approved by City voters and prohibits increases of residential densities in areas zoned residential as of 1974.

Transit Corridors Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP identifies five “Character Areas” with unique visual characters and development objectives: San Mateo Avenue, El Camino Real, Huntington Avenue, Station Area, and the Central Business District. Additionally, the TCP includes development standards and design guidelines that govern future private development actions in the TCP area.

Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Three of the Bayhill Specific Plan includes mandatory “Urban Design Policies” and discretionary “Urban Design Guidelines” which are intended to serve as the design review criteria for future private development within the Bayhill Specific Plan area.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 34 Initial Study
City of San Bruno December 2022

4.1.1.2 Existing Conditions
General Plan and Municipal Code Conforming Sites
Residential development at the densities proposed by the Housing Element Update (refer to Table

3.2-1) are allowed at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 under their existing General Plan land use designation and zoning district regulations, and therefore no General Plan amendments or rezoning is required. The existing conditions at these sites related to aesthetics are discussed below.

Housing Opportunity Site 6
Housing Opportunity Site 6 is currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. No potentially historic buildings or rock outcroppings are present on-site, although a significant number of mature trees are present. The existing golf driving range operates approximately 60-foot tall pole mounted lights that generate substantial amounts of light and glare when operational post-sunset. During the day and post-close of business, the site generates little to no light and glare.

Site 6 is bordered by I-280 (a state-scenic highway) to the east and the Crestmoor Canyon open space areas in all other directions. Beyond Crestmoor Canyon are single-family residences to the west, north, and south as well as two gas stations across Sneath Lane to the north. Since the project site is recessed into the hillside, views of Sweeney Ridge and San Bruno Mountain are limited. Due to intervening vegetation and topography, Site 6 is only minimally visible from I-280 and is not visible from any other state-, county-, or locally-designated scenic road or corridor. Light and glare generated by car headlights on I-280 and lighting of the single-family residences and gas stations in the surrounding area are consistent with these types of uses.

Housing Opportunity Site 8
Housing Opportunity Site 8 is currently developed with the former Edgemont Elementary School campus. The campus consists of two one-story gabled-roof buildings with rooftop solar panels, a surface parking lot, and a playground area. Light and glare generated by the campus buildings are consistent with the light and glare generated by surrounding single-family residential development.

Site 8 is mapped within a Transit Priority Area (TPA).
8 Site 8 is located in an urbanized area surrounded on all sides by one-story single-family residential development. No potentially historic buildings or rock outcroppings are present on-site, although a number of mature trees are present. Due to distance and/or intervening development and topography, views of Sweeney Ridge and San Bruno Mountain are limited, and none of the state-, county, or locally-designated scenic corridors or roadways are visible from Site 8. 8 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 35 Initial Study
City of San Bruno December 2022
Housing Opportunity Sites 10 and 16
Housing Opportunity Sites 10 and 16 are vacant dirt lots that are located adjacent to each other on San Marco Avenue. Access to San Marco Avenue is provided via El Camino Real. No potentially historic buildings or rock outcroppings are present on-site, although a number of mature trees are present. Since Sites 10 and 16 are undeveloped and they do not currently generate any light or glare; light and glare in the surrounding area is typical of urbanized areas. Sites 10 and 16 are mapped within a TPA.9
Sites 10 and 16 are located in an urbanized area developed with mostly single-family residential development and various commercial uses along the El Camino Real corridor to the immediate west of the sites. Due to distance and/or intervening topography and development around Sites 10 and 16, views of Sweeney Ridge and San Bruno Mountain are extremely limited, and there are no views to and from I-280. Sites 10 and 16 are not visible from any state-, county-, or locally-designated scenic corridor or roadway.

Housing Opportunity Site 18
Housing Opportunity Site 18 is developed with a two-story flat-roofed brick building with sloped awnings over the first level, a surface parking lot, and a plaza at the corner of West 1st Street and Commodore Drive. No potentially historic buildings or rock outcroppings are present on-site, although a number of mature trees are present. Minimal amounts of light and glare are generated by the existing development, which is minimally lighted at nighttime and has limited amounts of glass on the building exterior. Site 18 is mapped within a TPA.10 Opposite Site 18 across El Camino Real to the east is the Shops at Tanforan development, which is located within Housing Opportunity Site 14, discussed below. Commercial uses are present to the north and south along El Camino Real, and multi-family residential developments and the Marine Corps Reserve Center are located west of the project site. Due to distance and/or intervening topography and development, Site 18 is not visible from Sweeney Ridge or I-280. However, Site 18 is visible from the San Bruno Mountain and Sneath Lane, a locally-designated scenic corridor, to the north. Light and glare generated by surrounding uses and traffic along El Camino Real and surrounding roadways are typical of urbanized areas.

Housing Opportunity Site 19
Housing Opportunity Site 19 is developed with a single-story flat-roofed building and surface parking lot. No potentially historic buildings, rock outcroppings, or mature trees are present on-site.

Minimal amounts of light and glare are generated by the existing development, which is minimally 9 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5 10 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 36 Initial Study
City of San Bruno December 2022
lighted at nighttime and has limited amounts of glass on the building exterior. Site 19 is mapped within a TPA.11
Site 19 is located approximately 300 feet north of Site 18. As noted above, the Shops at Tanforan development is located to the east, commercial uses are present to the north and south along El Camino Real, and multi-family residential developments and the Marine Corps Reserve Center are located to the west. Due to distance and/or intervening topography and development, Site 19 is not visible from Sweeney Ridge or I-280. Like Site 18, Site 19 is visible from the San Bruno Mountain and Sneath Lane, a locally-designated scenic corridor, to the north. Light and glare generated by surrounding uses and traffic along El Camino Real and surrounding roadways are typical of urbanized areas.

Transit Corridors Plan Area Sites
As discussed in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP area is fully urbanized and characterized by diverse land uses, building forms, parcel sizes and surface parking lots. As discussed in Section 4.1.1.1, the TCP divides the TCP area into five character areas with unique visual characters and development objectives: San Mateo Avenue, El Camino Real, Huntington Avenue, Station Area, and the Central Business District. All Transit Corridor Plan sites are mapped within a TPA.12 Various vantage points throughout the TCP area have views of the western and northern ridgelines, including Sweeney Ridge to the west and San Bruno Mountain to the north, both of which are identified as scenic vistas in the City’s General Plan. None of the state-, county-, or locallydesignated scenic roads/corridors (refer to Section 4.1.1.1) intersect the TCP area, although portions of the TCP area may be partially visible from these roadways.

Lighting within the TCP area includes those sources common to urban areas, including street and freeway lights, parking lot lighting, building lighting, illuminated signs, vehicle headlamps and interior lighting visible through windows. Existing sources of glare in and around the TCP area are also those common to such urban areas, including reflection of sunlight and artificial light off of windows, buildings and other surfaces in the day, and glare from inadequately shielded and improperly directed light sources at night.

Bayhill Specific Plan Area Sites
As discussed in Section 3.1.1.2, Housing Opportunity Sites 3 and 13 are located within the urbanized Bayhill Specific Plan area. The Bayhill Specific Plan area is approximately 92.2 acres in size and encompasses the Bayhill Office Park, Bayhill Shopping Center, and Marriott Courtyard Hotel. Most of the Bayhill Specific Plan area was developed in the 1970s, and streets and buildings reflect the suburban, auto-oriented character of development at the time. Stand-alone buildings are surrounded 11 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5 12 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 37 Initial Study
City of San Bruno December 2022
by large parking lots. Most buildings are concrete and glass, with “blocky” forms typical of 1970s and 1980s commercial building design. Heights range from one-story retail buildings in the Bayhill Shopping Center, to six-story buildings at 900 and 850 Cherry Avenue. Landscape features include frontage lawns, roadway medians, and parking lot islands with a focus on screening and shading the considerable expanses of surface parking. Site 13 is mapped within a TPA.13 Due to distance and/or intervening development and topography, views of Sweeney Ridge and San Bruno Mountain from the Bayhill Specific Plan area are limited. None of the state-, county-, or locally-designated scenic roads/corridors (refer to Section 4.1.1.1) intersect the Bayhill Specific Plan area; however, I-280 is adjacent to the western border of the Bayhill Specific Plan area. Views from I-280 of the Bayhill Specific Plan area are extremely limited due to screening from intervening vegetation that borders the northbound I-280 lanes.

Existing buildings include night lighting in addition to security lights that remain illuminated through the night. Surface parking lots are well lit. Glass and reflective surfaces on buildings and vehicles, on streets, and in parking lots contribute to a limited amount of glare that is typical of a suburban office park. Due to the urbanized nature of the surrounding area, a substantial amount of ambient nighttime lighting currently exists, affecting views of the nighttime sky.

Housing Opportunity Site 14
Housing Opportunity Site 14 consists of 1122-1188 El Camino Real/300 Tanforan Shopping Center (APNs: 014-316-240; -300; -330; -360), which is developed with the Shops at Tanforan shopping mall, and 1292 Huntington Avenue (APN: 014-311-060), which is located opposite the Shops at Tanforan across the Sneath Lane/Huntington Avenue intersection and is developed with a vacant paved lot.

The Shops at Tanforan development occupies a 44-acre super-block bounded by Sneath Lane to the north, Huntington Avenue to the east, Interstate 380 (I-380) to the south, and El Camino Real to the west. The Shops at Tanforan consists of a 970,000 square-foot shopping mall with building heights of up to 126 feet, nine inches above mean sea level (AMSL), which is surrounded by aboveground parking garages and surface parking lots. In 2005, the Shops at Tanforan underwent major renovations, and is of modern, conventional construction and design. The Shops at Tanforan generates a substantial amount of light associated with lighting of the mall and surrounding parking lots at night, but only limited amounts of glare due to the lack of large uninterrupted expanses of glass. Site 14 is mapped within a TPA.14
Housing Opportunity Site 14 is located adjacent to Sneath Lane, and is visible from San Bruno Mountain and Sweeney Ridge. Visibility from any other county- or locally-designated scenic corridor or roadway is limited. Site 14 is located within a heavily urbanized area and is surrounded by single-family residential development to the east across Huntington Avenue and south across I13 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5 14 Metropolitan Transportation Commission. “Transit Priority Areas (2021)”. Accessed October 21, 2022. https://www.arcgis.com/apps/mapviewer/index.html?panel=gallery&suggestField=true&layers=370de9dc4d65402d 992a769bf6ac8ef5
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 38 Initial Study
City of San Bruno December 2022
380 freeway, multi-family residential and commercial uses and the Marine Corps Reserve Center to the west, and a wide variety of development to the north, including the San Bruno Towne Center retail plaza, hotels, movie theatres, and other commercial and retail uses. Due to the urbanized nature of the surrounding area, light sources include street and freeway lights, parking lot lighting, building lighting, illuminated signs, vehicle headlamps, and interior lighting visible through windows. Glare sources include reflection of sunlight and artificial light off of windows, buildings and other surfaces in the day, and inadequately shielded and improperly directed light sources at night.

4.1.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Except as provided in Public Resources Code
Section 21099, would the project:
1) Have a substantial adverse effect on a scenic
vista?
2) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
3) In non-urbanized areas, substantially degrade
the existing visual character or quality of
public views of the site and its surroundings? 15
If the project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality?
4) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
Impact AES-1: The project would not have a substantial adverse effect on a scenic vista. (Less than Significant Impact)
San Bruno Mountain, Sweeney Ridge, and Skyline College are identified as scenic vistas in the City’s General Plan. Crystal Springs Road, El Camino Real (from Easton Drive to Crystal Springs Road), and Sharp Park Road are County- and locally-designated scenic roads, and Sneath Lane is a locally-designated scenic corridor. As documented in Section 4.1.1.2, all of the Housing Opportunity Sites (with the exception of Sites 3 and 6) are located within a transit priority area (TPA), and therefore impacts on scenic vistas associated with future residential and mixed-use residential development at these sites are considered less than significant pursuant to SB 743.

Due to distance and/or intervening development and topography, views of Sweeney Ridge and San Bruno Mountain from Sites 3 and 6 are limited. Pursuant to General Plan Policy LUD-7, any future 15 Public views are those that are experienced from publicly accessible vantage points. □
□
□
□
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 39 Initial Study
City of San Bruno December 2022
residential projects proposed at Sites 3 and 6 would be subject to design review, where it would be reviewed to ensure consistency with General Plan and Municipal Code regulations governing scenic quality (refer to Section 4.1.1.1 and the discussion under Impact AES-3). Further, future development at Sites 3 and 6 would also be subject to the 50-foot height restrictions placed on new development by Ordinance 1284. Therefore, while the orientation and density of development at Sites 3 and 6 may change, views from San Bruno Mountain and Sweeney Ridge would be fundamentally unchanged in comparison with existing conditions.

For the reasons stated above, buildout of the Housing Element Update would not have a substantial adverse effect on a scenic vista.

Impact AES-2: The project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. (Less than Significant Impact)
There is one state-designated scenic highway in San Bruno (I-280). As noted under Impact AES-1, all of the Housing Opportunity Sites (with the exception of Sites 3 and 6) are located within a TPA, and therefore impacts to scenic resources within a state scenic highway associated with future residential and mixed-use residential development at these sites are considered less than significant pursuant to SB 743.

Views from I-280 of Sites 3 and 6 are extremely limited due to screening from intervening vegetation that borders I-280; Site 6 is further obscured due to its location uphill of I-280. The only scenic resources present at Sites 3 and 6 are trees, which, if removed, would be replaced in accordance with the requirements outlined in San Bruno Municipal Code sections 8.24.090 and 8.25.050 (refer to Section 4.4.1.1 Regulatory Framework).16 Since existing trees on Sites 3 and 6 do not contribute to views from I-280 redevelopment of these sites with residential uses would not damage scenic resources within a state scenic highway.

For the reasons stated above, buildout of the Housing Element Update would not damage scenic resources within a state scenic highway.

Impact AES-3: The project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings. The project would not conflict with applicable zoning and other regulations governing scenic quality. (Less than Significant Impact)
As documented in Section 4.1.1.2, all of the Housing Opportunity Sites identified in the Housing Element Update are within urbanized areas, with the exception of Site 6 which is designated for housing under the current General Plan and Municipal Code regulations. As noted under Impact AES-1, all of the Housing Opportunity Sites (with the exception of Sites 3 and 6) are located within a TPA, and therefore impacts to visual character, public views, and scenic quality associated with 16 Street trees and heritage trees are required to be replaced by either two twenty-four-inch box size trees or one thirty-six-inch box size tree for each tree removed.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 40 Initial Study
City of San Bruno December 2022
future residential and mixed-use residential development at these sites are considered less than significant pursuant to SB 743.

Redevelopment of Sites 3 and 6 would be subject to design review by General Plan Policy LUD-7, where it would be reviewed to ensure consistency with General Plan and Municipal Code regulations governing scenic quality. Applicable General Plan policies (refer to Section 4.1.1.1, above) would include LUD-E, LUD-3, LUD-4, LUD-8, LUD-12, LUD-21, LUD-25, LUD-33, LUD-44, LUD-70, LUD-72, LUD-73, T-18, T-25, T-26, T-28, T-30, T-32, T-33, T-42, T-76, T-77, T-78, OSR-33, OSR-34, ERC-9, ERC-10, ERC-12, ERC-40, PFS-24, and PFS-65. Future development at Sites 3 and 6 would also be subject to the Municipal Code regulations identified in Section 4.1.1.1, including the various design guidelines and tree preservation policies, and the 50-foot height restriction imposed by Ordinance 1284. Further, future development at Site 3 under the Housing Element Update would be required to adhere to the mandatory “Urban Design Policies” provided in the Bayhill Specific Plan. The design review process would ensure that future development at Site 3 would not conflict with the aforementioned zoning and other regulations governing scenic quality, and that future development at Site 6 does not degrade the existing visual character or quality of public views of Site 6 and its surroundings.

For the reasons stated above, buildout of the Housing Element Update would not conflict with applicable zoning and other regulations governing scenic quality, or degrade the existing visual character or quality of public views of the site and its surroundings.

Impact AES-4: The project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Less than Significant Impact)
As noted under Impact AES-1, all of the Housing Opportunity Sites (with the exception of Sites 3 and 6) are located within a TPA, and therefore light- and glare-related impacts associated with future residential and mixed-use residential development at these sites are considered less than significant pursuant to SB 743.

As discussed in Section 4.1.1.2, substantial light and glare exists at Housing Opportunity Site 3 and the surrounding area that is typical to urbanized areas. Less light and glare is present at Site 6, which is in the vicinity of residential uses and gas stations as well as undeveloped areas that do not generate any light or glare. Among other things, Site 6 is developed with approximately 60-foot-tall pole mounted lights that generate substantial light and glare post-sundown.

As discussed under Impact AES-3, all future development under the Housing Element Update would be subject to design review, where it would be reviewed to ensure consistency with General Plan and Municipal Code regulations governing scenic quality (including those related to light and glare).

Applicable General Plan policies concerning light and glare include LUD-72, which requires buildings to screen rooftop mechanical equipment with non-glaring materials, and LUD-73, which requires buildings with a continuous façade of 100 feet or longer to use non-reflective materials to minimize adverse impact of glare. Redevelopment at Site 3 would be subject to the mandatory “Urban Design Policies” provided in the Bayhill Specific Plan governing light fixtures, including DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 41 Initial Study
City of San Bruno December 2022
Policies 3-17, 3-20, and 3-26, which require shielding light and glare from exterior site lighting, shielding internal building lighting, and minimizing the reflectivity of building wall surfaces and glazing, respectively. Further, redevelopment of Site 6 is anticipated to remove the pole mounted lights and potentially reduce post-sundown light and glare. Accordingly, future development at Sites 3 and 6 would not generate substantial glare that would adversely affect day or nighttime views in the area.

For the reasons stated above, buildout of the Housing Element Update would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 42 Initial Study
City of San Bruno December 2022

4.2 AGRICULTURE AND FORESTRY RESOURCES

4.2.1 Environmental Setting

4.2.1.1 Regulatory Framework
State
Farmland Mapping and Monitoring Program
The California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP) assesses the location, quality, and quantity of agricultural land and conversion of these lands over time. Agricultural land is rated according to soil quality and irrigation status. The best quality land is identified as Prime Farmland. In CEQA analyses, the FMMP classifications and published county maps are used, in part, to identify whether agricultural resources that could be affected are present on-site or in the project area.17
California Land Conservation Act
The California Land Conservation Act (Williamson Act) enables local governments to enter into contracts with private landowners to restrict parcels of land to agricultural or related open space uses.

In return, landowners receive lower property tax assessments. In CEQA analyses, identification of properties that are under a Williamson Act contract is used to also identify sites that may contain agricultural resources or are zoned for agricultural uses.18 Fire and Resource Assessment Program
The California Department of Forestry and Fire Protection (CAL FIRE) identifies forest land, timberland, and lands zoned for timberland production that can (or do) support forestry resources.19 Programs such as CAL FIRE’s Fire and Resource Assessment Program and are used to identify whether forest land, timberland, or timberland production areas that could be affected are located on or adjacent to a project site.20,
21 17 California Department of Conservation. “Farmland Mapping and Monitoring Program.” Accessed October 24, 2022. http://www.conservation.ca.gov/dlrp/fmmp/Pages/Index.aspx. 18 California Department of Conservation. “Williamson Act.” Accessed October 24, 2022. http://www.conservation.ca.gov/dlrp/lca. 19 Forest Land is land that can support 10 percent native tree cover and allows for management of forest resources (California Public Resources Code Section 12220(g)); Timberland is land not owned by the federal government or designated as experimental forest land that is available for, and capable of, growing trees to produce lumber and other products, including Christmas trees (California Public Resources Code Section 4526); and Timberland Production is land used for growing and harvesting timber and compatible uses (Government Code Section 51104(g)).
20 California Department of Forestry and Fire Protection. “Fire and Resource Assessment Program.” Accessed October 24, 2022. http://frap.fire.ca.gov/. 21 City of San Bruno. San Bruno General Plan. March 2009.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 43 Initial Study
City of San Bruno December 2022

4.2.1.2 Existing Conditions
There is no Prime, Unique, or Farmland of Statewide Importance or forest land (including timberland) within the City of San Bruno.22 As shown in Table 3.2-1, none of the Housing Opportunity Sites are zoned for agricultural or forestry (including timberland) use. All of the Housing Opportunity Sites are designated as “Urban and Built-Up Land” on the San Mateo County Important Farmlands 2018 Map. Common examples of “Urban and Built-Up Land” are residential, institutional, industrial, commercial, landfill, golf course, airports, and other utility uses. None of the Housing Opportunity Sites are under a Williamson Act contract and there are no existing agricultural or forestry resources on or in the vicinity of the sites.

4.2.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance
(Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use?
2) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
3) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g)), timberland
(as defined by Public Resources Code Section
4526), or timberland zoned Timberland
Production (as defined by Government Code
Section 51104(g))?
4) Result in a loss of forest land or conversion of
forest land to non-forest use?
5) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of Farmland
to non-agricultural use or conversion of forest
land to non-forest use?

4.2.2.1 Agricultural and Forestry Analysis
As documented in Section 4.2.1.2, there is no Prime, Unique, or Farmland of Statewide Importance or forest land (including timberland) within the City of San Bruno, and none of the Housing 22 California Department of Conservation. “Farmland Mapping and Monitoring Program.” Accessed October 24, 2022. http://www.conservation.ca.gov/dlrp/fmmp/Pages/Index.aspx. □
□
□
□
□
□
□
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 44 Initial Study
City of San Bruno December 2022
Opportunity Sites are zoned for agricultural or forestry (including timberland) use. Therefore, the Housing Element Update as a whole would have no impact on agricultural or forestry resources.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 45 Initial Study
City of San Bruno December 2022

4.3 AIR QUALITY
The following discussion is based, in part, on an Air Quality and Greenhouse Gas Assessment prepared for the Housing Element Update by Illingworth & Rodkin, Inc. A copy of this report, dated September 2022, is attached to this Initial Study as Appendix A.

4.3.1 Environmental Setting

4.3.1.1 Background Information
Criteria Pollutants
Air quality in the Bay Area is assessed related to six common air pollutants (referred to as criteria pollutants), including ground-level ozone (O3), nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), sulfur oxides (SOx), and lead.23 Criteria pollutants are regulated because they result in health effects. An overview of the sources of criteria pollutants and their associated health are summarized in Table 4.3-1. The most commonly regulated criteria pollutants in the Bay Area are discussed further below.

Table 4.3-1: Health Effects of Air Pollutants
Pollutants Sources Primary Effects
Ozone (O3) Atmospheric reaction of organic gases
with nitrogen oxides in sunlight
• Aggravation of respiratory and
cardiovascular diseases
• Irritation of eyes
• Cardiopulmonary function impairment
Nitrogen
Dioxide (NO2)
Motor vehicle exhaust, high
temperature stationary combustion,
atmospheric reactions
• Aggravation of respiratory illness
• Reduced visibility
Fine
Particulate
Matter (PM2.5)
and Coarse
Particulate
Matter (PM10)
Stationary combustion of solid fuels,
construction activities, industrial
processes, atmospheric chemical
reactions
• Reduced lung function, especially in
children
• Aggravation of respiratory and
cardiorespiratory diseases
• Increased cough and chest discomfort
• Reduced visibility
Toxic Air
Contaminants
(TACs)
Cars and trucks, especially dieselfueled; industrial sources, such as chrome platers; dry cleaners and service
stations; building materials and
products
• Cancer
• Chronic eye, lung, or skin irritation
• Neurological and reproductive
disorders
High O3 levels are caused by the cumulative emissions of reactive organic gases (ROG) and NOX.

These precursor pollutants react under certain meteorological conditions to form high O3 levels.

Controlling the emissions of these precursor pollutants is the focus of the Bay Area’s attempts to 23 The area has attained both state and federal ambient air quality standards for CO. The project does not include substantial new emissions of sulfur dioxide or lead. These criteria pollutants are not discussed further.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 46 Initial Study
City of San Bruno December 2022
reduce O3 levels. The highest O3 levels in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources.

PM is a problematic air pollutant of the Bay Area. PM is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM10) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM2.5). Elevated concentrations of PM10 and PM2.5 are the result of both region-wide emissions and localized emissions.

Toxic Air Contaminants
TACs are a broad class of compounds known to have adverse health effects. They include but are not limited to criteria pollutants. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, diesel fuel combustion, and commercial operations (e.g., dry cleaners).

TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter [DPM] near a freeway).

Diesel exhaust is the predominant TAC in urban air and is estimated to represent about three-quarters of the cancer risk from TACs. Diesel exhaust is a complex mixture of gases, vapors, and fine particles. Medium- and heavy-duty diesel trucks represent the bulk of DPM emissions from California highways. The majority of DPM is small enough to be inhaled into the lungs. Most inhaled particles are subsequently exhaled, but some deposit on the lung surface or are deposited in the deepest regions of the lungs (most susceptible to injury).24 Chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the California Air Resources Board (CARB).

Sensitive Receptors
Some groups of people are more affected by air pollution than others. CARB has identified the following persons who are most likely to be affected by air pollution: children under 16, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, and elementary schools.

4.3.1.2 Regulatory Framework
Federal and State
Clean Air Act
At the federal level, the United States Environmental Protection Agency (EPA) is responsible for overseeing implementation of the Clean Air Act and its subsequent amendments. The federal Clean Air Act requires the EPA to set national ambient air quality standards for the six common criteria pollutants (discussed previously), including PM, O3, CO, SOx, NOx, and lead. 24 California Air Resources Board. “Overview: Diesel Exhaust and Health.” Accessed October 24, 2022. https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 47 Initial Study
City of San Bruno December 2022
CARB is the state agency that regulates mobile sources throughout the state and oversees implementation of the state air quality laws and regulations, including the California Clean Air Act.

The EPA and the CARB have adopted ambient air quality standards establishing permissible levels of these pollutants to protect public health and the climate. Violations of ambient air quality standards are based on air pollutant monitoring data and are determined for each air pollutant.

Attainment status for a pollutant means that a given air district meets the standard set by the EPA and/or CARB.

Risk Reduction Plan
To address the issue of diesel emissions in the state, CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. In addition to requiring more stringent emission standards for new on-road and off-road mobile sources and stationary diesel-fueled engines to reduce particulate matter emissions by 90 percent, the plan involves application of emission control strategies to existing diesel vehicles and equipment to reduce DPM (in addition to other pollutants). Implementation of this plan, in conjunction with stringent federal and CARB-adopted emission limits for diesel fueled vehicles and equipment (including off-road equipment), will significantly reduce emissions of DPM and NOX.

Regional
2017 Clean Air Plan
The Bay Area Air Quality Management District (BAAQMD) is the agency primarily responsible for assuring that the federal and state ambient air quality standards are maintained in the San Francisco Bay Area. Regional air quality management districts, such as BAAQMD, must prepare air quality plans specifying how state and federal air quality standards will be met. BAAQMD’s most recently adopted plan is the Bay Area 2017 Clean Air Plan (2017 CAP). The 2017 CAP focuses on two related BAAQMD goals: protecting public health and protecting the climate. To protect public health, the 2017 CAP describes how BAAQMD will continue its progress toward attaining state and federal air quality standards and eliminating health risk disparities from exposure to air pollution among Bay Area communities. To protect the climate, the 2017 CAP includes control measures designed to reduce emissions of greenhouse gases (GHGs) that are potent climate pollutants in the near term, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.25 CEQA Air Quality Guidelines
The BAAQMD CEQA Air Quality Guidelines are intended to serve as a guide for those who prepare or evaluate air quality impact analyses for projects and plans in the San Francisco Bay Area.

Jurisdictions in the San Francisco Bay Area Air Basin utilize the thresholds and methodology for assessing air quality impacts developed by BAAQMD within their CEQA Air Quality Guidelines.

The guidelines include information on legal requirements, BAAQMD rules, methods of analyzing impacts, and recommended mitigation measures.
25 BAAQMD. Final 2017 Clean Air Plan. April 20, 2017.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 48 Initial Study
City of San Bruno December 2022
Local
City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating air quality impacts resulting from planned development within the City, including the following:

Policies Description
ERC-E Contribute to regional attainment by improving ambient air quality levels within San Bruno.

ERC-13 Through environmental review, assure that all projects affecting resources of regional concern (e.g., the San Francisco garter snake habitat, water and air quality, the San Francisco Fish and Game Reserve) satisfy regional, State and federal laws.

ERC-25 Maintain and improve air quality by requiring project mitigation, such as Transportation Demand Management (TDM) techniques, where air quality impacts are unavoidable.

ERC-26 Require dust abatement actions for all new construction and redevelopment projects.

ERC-28 Incorporate air quality beneficial programs and policies into local planning and development activities, with a particular focus on subdivision, zoning, and site design measures that reduce the number and length of single-occupant automobile trips.

ERC-29 Promote demonstration projects to develop new strategies to reduce motor vehicle emissions.

Projects may include low emission vehicle fleets and LEV refueling infrastructure.

ERC-30 Encourage new residential developments to incorporate measures such as shuttle services to major employment centers, commercial areas and transit areas, and provision of adequate transit facilities.

ERC-31 Prepare a Greenhouse Gas Emissions Reduction Plan, focusing on feasible actions the City can take to minimize the adverse impacts of Plan implementation on climate change and air quality. The Plan will include but will not be limited to:
• An inventory of all known, or reasonably discoverable, sources of greenhouse gases (GHGs) that currently exist in the City and sources that existed in 1990. In determining what is a source of GHG emissions, the City may rely on the definition of “greenhouse gas emissions source” or “source” as defined in section 38505 of the California Global Warming Solutions Act (“AB 32”) or its governing regulations.

The inventory may include estimates of emissions drawing on available information from State and regional air quality boards, supplemented by information obtained by the City.
• A projected inventory of the new GHGs that can reasonably be expected to be emitted in the year 2025 due to the City’s discretionary land use decisions pursuant to the 2025 General Plan Update, as well as new GHGs emitted by the City’s internal government operations. The projected inventories will include estimates, supported by substantial evidence, of future emissions from planned land use and information from state and regional air quality boards and agencies. • A target for the reduction of those sources of future emissions reasonably attributable to the City’s discretionary land use decisions under the 2025 General Plan and the City’s internal government operations, and feasible GHG emission reduction measures whose purpose shall be to meet this reduction target by regulating those DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 49 Initial Study
City of San Bruno December 2022
Policies Description
sources of GHG emissions reasonably attributable to the City’s discretionary land use decisions and the City’s internal government operations.

ERC-32 Coordinate air quality planning efforts with local, regional, and State agencies. Support the Bay Area Air Quality Management District’s efforts to monitor and control air pollutants from stationary sources.

ERC-33 Require all large construction projects to mitigate diesel exhaust emissions through use of alternate fuels and control devices.

ERC-34 Require that adequate buffer distances be provided between odor sources and sensitive receptors, such as schools, hospitals, and community centers.

LUD-22 Ensure that vehicular, transit, bicycle, and pedestrian access to the city’s regional retail centers is convenient, efficient, and safe. Coordinate transportation improvements with the new San Bruno BART station and SamTrans.

LUD-26 During the Zoning Ordinance Update, create a transit-oriented zoning district surrounding the BART and Caltrain stations, and along the El Camino Real and San Bruno Avenue transit corridor. Within the district, reduce building setbacks, increase development intensities, require pedestrian connections, reduce parking requirements, and consider establishment of minimum development intensities.

PFS-60 Develop and implement a Green Building Design Ordinance and design guidelines for climate- oriented site planning, building design, and landscape design to promote energy efficiency. These standards may include, but are not limited to, the following:
• Require the use of Energy Star® appliances and equipment in new residential and commercial development, and new City facilities;
• Require all new City facilities and new residential development to incorporate green building methods meeting the equivalent of LEED Certified “Silver” rating or better; and
• Require all new residential development to be pre-wired for optional photovoltaic roof energy systems and/or solar water heating.

The Ordinance will allow variances to site or building requirements—building setbacks, lot coverage, and building height—that will enable use of alternative energy sources, such as passive heating and/or cooling.

PFS-61 Require that all new development complies with California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6).

PFS-62 Provide incentives for retrofitting existing homes and businesses for improved energy efficiency, such as passive solar and/or cooling devices.

PFS-63 Require new development to incorporate passive heating and natural lighting strategies if feasible and practical. These strategies should include, but are not limited to, the following:
• Using building orientation, mass and form, including façade, roof, and choice of building materials, color, type of glazing, and insulation to minimize heat loss during winter months and heat gain during the summer months;
• Designing building openings to regulate internal climate and maximize natural lighting, while keeping glare to a minimum; and
• Reducing heat-island effect of large concrete roofs and parking surfaces.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 50 Initial Study
City of San Bruno December 2022
Policies Description
PFS-64 Enforce landscape requirements that facilitate efficient energy use or conservation, such as drought-resistant landscaping and/or deciduous trees along southern exposures.

PFS-65 Require developers and builders to distribute information regarding energy efficiency (such as the Home Energy Guide available from the California Energy Commission) to all new homeowners.

PFS-66 Initiate a marketing campaign where energy efficiency information is distributed to all City employees and residents. Provide information on how, what type, and where to plant trees to reduce energy demand. Make such information available at all public locations such as City Hall and the Public Library.

PFS-67 Offer incentives (such as expedited permit processing, density bonuses, site variances) to support implementation of photovoltaic and other renewable energy technologies that provide a portion of the City’s energy needs, or for projects that result in energy savings of at least 20-percent when compared to the energy consumption that would occur under similar projects built to meet the minimum standards of the energy code.

PFS-68 Facilitate environmentally sensitive construction practices by:
• Restricting use of chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and halons in mechanical equipment and building materials; • Promoting use of products that are durable and allow efficient end-of-life disposal (e.g. reusable, recyclable, biodegradable);
• Promoting the purchase of locally or regionally available materials; and • Promoting the use of cost-effective design and construction strategies that reduce resource and environmental impacts.

T-1 Develop incentives for San Bruno government and private employers to institute staggered working hours, compressed work week, homebased telecommuting, carpooling, use of transit, alternative fuel vehicles, and bicycling to employment centers to reduce vehicle miles traveled and the associated traffic congestion and air pollution.

T-3 Encourage provision of bicycle facilities such as weather protected bicycle parking, direct and safe access for pedestrians and bicyclists to adjacent bicycle routes and transit stations, showers, and lockers for employees at the worksite, secure short-term parking for bicycle.

T-4 Encourage major employers of the city to provide shuttle service for employees from worksite to food service establishments, commercial areas, and transit stations, to reduce the number of automobile trips.

T-5 Provide assistance to regional and local ridesharing organizations; advocate legislation to maintain and expand incentives (e.g., tax deductions/credits).

T-20 Study the potential benefit of implementing High Occupancy Vehicle (HOV) and carpool lane along major arterials.

T-40 Consider reduced parking standards within transit corridors and station areas in recognition of their proximity to high frequency transit service, mix of land uses, and walkable environment.

T-42 Do not allow parking lots to dominate the frontage of mixed-use streets, interrupt pedestrian routes, or negatively impact surrounding neighborhoods.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 51 Initial Study
City of San Bruno December 2022
Policies Description
T-48 Incorporate a dedicated pedestrian crossing and flashing street markers at the new four-way signal installed on El Camino Real connecting The Crossing with The Shops at Tanforan and the San Bruno BART station.

T-50 Consider developing a shuttle service to provide reliable, consistent, and convenient access between the BART and Caltrain stations and other destinations within the city, including Bayhill Office Park, Skyline College, Downtown, schools and neighborhoods in the western and southern portions of the city.

T-53 Coordinate with the Peninsula Corridor Joint Powers Board to ensure design of the planned San Bruno Avenue Caltrain Station (and Grade Separation Project) that will accommodate such regional transit improvements.

T-57 Work with SamTrans to schedule the routing of public transit in San Bruno so that a majority of residents are within walking distance of transit stops.

T-59 Encourage SamTrans to configure bus transit service to serve connections with other transit systems (BART, Caltrain, SFO, and other bus lines).

T-62 Seek community input in establishing transit routes and schedules.

T-64 Work with SamTrans to plan the local system with built-in flexibility for increases in service in accordance with increases in demand. Coordinate with local school districts on possible joint transit usage.

T-66 Design arterial and collector streets to facilitate safe pedestrian crossings to transit stops.

Provide crosswalks at all signalized arterial intersections.

T-69 Continue to work toward dedication and/or installation of bicycle lanes throughout the city in accordance with Figure 4-4, to enhance recreational opportunities and make bicycling a more viable transportation alternative. Implement bicycle route improvements including signing, striping, paving, and provision of bicycle facilities at employment sites, shopping centers, schools, and public facilities.

T-71 Provide bicycle parking facilities in Downtown, Bayhill Office Park, BART and Caltrain Stations, The Shops at Tanforan and Towne Center, parks, schools, and other key destinations. Review bicycle standards as part of the Zoning Ordinance Update.

T-72 Identify and mark safe bicycle routes providing connections between the BART and Caltrain stations, and the following regional trail networks:
• Bay Ridge Trail
• Sweeney Ridge Trail
• Bay Trail
• San Andreas Trail
• Sawyer Camp Trail
T-73 Coordinate with the Bicycle and Pedestrian Committee to promote safe cycling programs, sponsored rides, and other community outreach programs geared toward cyclists.

T-75 Link sidewalks directly to building entrances. Avoid routes through parking lots or at the rear of residential developments.

T-77 T-77 Create a pedestrian-oriented setting along the Pedestrian Emphasis Zones (refer to Figure 4-6 in the San Bruno General Plan) through potential construction of the following public improvements:

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 52 Initial Study
City of San Bruno December 2022
Policies Description
• Brick pavers to make sidewalks look more distinct;
• Street trees to soften the environment and provide color and shade; • Human-scale street lights for enhanced aesthetics and illumination; • Banners and flags to make the area look more festive and cheerful; and • Benches to give people a place to sit, rest, and watch what goes on around them.

T-78 Allow new development to contribute to the Pedestrian Emphasis Zones (refer to Figure 4-6 in the San Bruno General Plan) through construction of off-site improvements.

T-79 Prioritize improvements to sidewalks and other walking paths adjacent to public school facilities where children and youth are likely to use them on a daily basis.

T-80 Install safety improvements for pedestrian crossings along El Camino Real. Such improvements may include bulb-outs at the corners, crossing medians, and signal synchronization.

Transit Corridors Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. Chapter Seven of the TCP includes the following policies designed to reduce emissions associated with vehicle traffic.

Policies Description
Trans-F Develop and implement a Transportation Demand Management (TDM) Program that reduces the amount of peak period motor vehicle traffic and encourages the use of modes other than the single-occupant vehicle.

Trans B-1 Provide a local circulator shuttle service between the Downtown, BART station, and Caltrain station, with potential stops at the San Francisco International Airport Trans C-2 Provide a network of bicycle priority streets that provide linkages throughout the Plan area. As appropriate, bicycle priority streets should provide traffic-calming measures to limit vehicle travel and speeds.

Trans C-4 Implement a citywide bicycle parking ordinance that specifies bicycle parking, locker, and shower requirements.

Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Six of the Bayhill Specific Plan includes mandatory “Environmental Quality Policies”, including the following which pertain to air quality.

Policy 6-9
Policy 6-9 requires projects during construction to use tier 4 equipment on off-road equipment meeting certain parameters, diesel trucks model 2010 or later, renewable diesel, low volatile organic compounds (VOC) coatings, portable electrical equipment given certain conditions are met, and implementation of fugitive dust best management practices.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 53 Initial Study
City of San Bruno December 2022
Policy 6-10
Policy 6-10 requires projects that exceed BAAQMD criteria air pollutant emissions screening criteria and thresholds of significance to pay for criteria air pollutant emission offsets.

Policy 6-11
Policy 6-11 requires residential and childcare projects to install high-efficiency filters and mitigate health risk impacts to the extent feasible.

Policy 6-13
Policy 6-13 requires projects to reduce air pollutant emissions generated during operation of future developments to be mitigated through the use of best practices, such as using low-emission generators, develop and adhere to loading plans that minimized truck idling, use green commercial products, and use all-electric landscaping equipment when feasible.

4.3.1.3 Existing Conditions
The Bay Area is considered a non-attainment area for ground-level O3 and PM2.5 under both the federal Clean Air Act and state Clean Air Act. The area is also considered nonattainment for PM10 under the state act, but not the federal act. The area has attained both state and federal ambient air quality standards for CO. As part of an effort to attain and maintain ambient air quality standards for O3 and PM10, BAAQMD has established thresholds of significance for these air pollutants and their precursors. These thresholds are for O3 precursor pollutants (ROG and NOX), PM10, and PM2.5, and apply to both construction period and operational period impacts.

4.3.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Conflict with or obstruct implementation of
the applicable air quality plan?
2) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or state ambient air quality
standard?
3) Expose sensitive receptors to substantial
pollutant concentrations?
4) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?

4.3.2.1 Thresholds of Significance
Plan-level impacts to air quality associated with buildout of the General Plan, TCP, and Bayhill Specific Plan were previously evaluated in their respective EIRs. However, since air quality impacts □
□
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 54 Initial Study
City of San Bruno December 2022
are not localized, it is necessary to evaluate the cumulative air quality impacts of the Housing Element as a whole. Accordingly, the discussion under Impact AIR-1 evaluates whether the Housing Element would conflict with the control strategy measures provided in the applicable air quality plan (the 2017 Clean Air Plan – refer to Section 4.3.1.1). Further, no individual project is sufficient in size to, by itself, result in the non-attainment of ambient air quality standards, and criteria air pollutant emissions contribute to regional emissions of such pollutants. Therefore, impacts associated with criteria air pollutant emissions are, by their nature, cumulative and must be evaluated accordingly.

For this reason, the discussion presented under Impact AIR-2 below evaluates whether buildout of all Housing Opportunity Sites at the densities assumed by the Housing Element Update would result in a cumulatively considerable net increase of ROG, NOX, PM10, and PM2.5 emissions using the planlevel thresholds provided in the BAAQMD CEQA Air Quality Guidelines. Additionally, consistent with the plan-level thresholds provided in the BAAQMD CEQA Air Quality Guidelines (refer to Section 4.3.1.1), this Initial Study evaluates whether the Housing Element as a whole would expose sensitive receptors to substantial pollutant concentrations (see Impact AIR-3) or result in odors that would adversely affect a substantial number of people. The BAAQMD plan-level thresholds are shown below in Table 4.3-2.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 55 Initial Study
City of San Bruno December 2022
Table 4.3-2: BAAQMD Plan-Level Air Quality Significance Thresholds1 Impact Threshold of Significance
Criteria Air Pollutant and Precursor Emissions 1. Consistency with Current Air Quality Plan control measures

2. Projected vehicle miles traveled (VMT) or
vehicle trip increase is less than or equal to
projected population increase
Health Risks Land use diagram identifies special overlay zones around existing and planned sources of
TACs and PM2.5, including special overlay
zones of at least 500 feet (or Air Districtapproved modeled distance) on each side of all freeways and high-volume roadways, and
plan identifies goals, policies, and objectives
to minimize potentially adverse impacts. For
this analysis – overlay zones are based on
potential for sources to result in the following
impacts:

1. Excess cancer risk >10.0 chances per
million

2. Annual PM2.5 Concentration > 0.3 µg/m3

3. Hazard Index >1.0
Odors Identify the location, and include policies to
reduce the impacts, of existing or planned
sources of odors
1 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines.

May 2017.

For informational purposes only, the BAAQMD project-level thresholds that would be applied to future individual projects are shown in Table 4.3-3.

Table 4.3-3: BAAQMD Project-Level Air Quality Significance Thresholds1 Pollutant
Construction
Thresholds Operation Thresholds
Average Daily
Emissions
(pounds/day)
Annual Daily
Emissions
(pounds/year)
Annual Average
Emissions (tons/year)
Criteria Air Pollutants
ROG, NOx 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 56 Initial Study
City of San Bruno December 2022
Table 4.3-3: BAAQMD Project-Level Air Quality Significance Thresholds1 Pollutant
Construction
Thresholds Operation Thresholds
Average Daily
Emissions
(pounds/day)
Annual Daily
Emissions
(pounds/year)
Annual Average
Emissions (tons/year)
CO Not Applicable 9.0 ppm (eight-hour) or 20.0 ppm (one-hour) Fugitive Dust
Dust Control
Measures/Best
Management Practices
Not Applicable
Health Risks and Hazards for New Sources (within a 1,000-foot Zone of Influence) Health Hazard Single Source Combined Cumulative Sources Excess Cancer Risk 10 per one million 100 per one million Hazard Index 1.0 10.0
Incremental Annual PM2.5 0.3 µg/m3 0.8 μg/m3 (average)
1 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines. May 2017.

Impact AIR-1: The project would not conflict with or obstruct implementation of the applicable air quality plan. (Less than Significant Impact) As discussed in Section 4.3.1.1, the applicable air quality plan is the 2017 CAP. A project is considered consistent with the 2017 CAP if, a) the plan supports the primary goals of the 2017 CAP; b) includes relevant control measures; and c) does not interfere with implementation of 2017 CAP control measures.26
The goals of the 2017 CAP are to 1) protect public health by progressing towards the attainment of air quality standards and eliminating health risks, and 2) protect the climate. As discussed under Impact AIR-2, the Housing Element, when considered at a program or plan level, would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment. As discussed under Impact AIR-3, the project would not expose sensitive receptors to substantial pollutant concentrations. As discussed in Section 4.8 Greenhouse Gas Emissions under Impact GHG-1 and Impact GHG-2, the project would not generate GHG emissions that would have a significant impact on the environment, nor would it conflict with any plan, policy, or regulation adopted for the purpose of reducing GHGs. Therefore, the project would support the primary goals of the 2017 CAP. Additionally, General Plan policies (refer to Section 4.3.1.2 and the consistency analysis in Table 4.3-4) and mitigation measures MM AIR-3.1, MM AIR-3.2, MM GHG-1.1, and MM GHG-1.2 would require future residential development under the Housing Element Update to implement relevant control measures for controlling criteria air pollutant and GHG emissions and to 26 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines. May 2017.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 57 Initial Study
City of San Bruno December 2022
ensure that sensitive receptors are not exposed to substantial pollutant concentrations. Therefore, the project includes relevant control measures. Further, as documented in Table 4.3-4, the project is consistent with all of the control measures provided in the 2017 CAP.

Table 4.3-4: 2017 Clean Air Plan Control Measures Consistency Analysis Applicable Control Strategy Measure Consistency Analysis Transportation Control Measures
TR1: Clean Air Teleworking Initiative:

Develop teleworking best practices for
employers and develop additional strategies to
promote telecommuting. Promote teleworking
on Spare the Air Days.

Implementation of the Housing Element
Update would not inhibit teleworking. Future
residents would benefit from incentives for
public and private employers to offer
telecommuting opportunities provided under
General Plan Policy T-1 (refer to Section

4.3.1.2). (Consistent)
TR2: Trip Reduction Programs:

Implement the regional Commuter Benefits
Program (rule 14-1) that requires employers
with 50 or more Bay Area employees to
provide commuter benefits. Encourage trip
reduction policies and programs in local
plans, e.g., general and specific plans while
providing grants to support trip reduction
efforts. encourage local governments to
require mitigation of vehicle travel as part of
new development approval, to adopt transit
benefits ordinances in order to reduce transit
costs to employees, and to develop innovative
ways to encourage rideshare, transit, cycling,
and walking for work trips. Fund various
employer-based trip reduction programs.

Implementation of the Housing Element
would not result in employment generating
uses or conflict with the Commute Benefits
Program. General Plan policies T-1, T-3, T-4,
T-5, T-20, T-57, and T-69 (refer to Section

4.3.1.2) encourage trip reduction policies and
programs. (Consistent)
TR 5: Transit Efficiency and Use:

Improve transit efficiency and make transit
more convenient for riders through continued
operation of 511 Transit, full implementation
of Clipper® fare payment system and the
Transit Hub Signage Program.

Control measure TR-5 is a regionally
implemented measure, and General Plan
policies T-1, T-4, T-50, T-53, T-57, T-59, T62, and T-64 (refer to Section 4.3.1.2) support transit efficiency and use. Pursuant to the
discussion in Section 4.17 Transportation
under Impact TRN-1, the project would not
conflict with any program, plan, ordinance, or
policy addressing transit facilities.
(Consistent)
TR7: Safe Routes to Schools and Safe Routes to
Transit:

Provide funds for the regional Safe Routes to
School and Safe Routes to Transit Programs.

Implementation of the Housing Element would
not conflict with the Safe Routes to School or
Transit Programs, and General Plan policies T21, T-42, T-48, T-57, T-64, T-66, T-69. T-78, DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 58 Initial Study
City of San Bruno December 2022
Table 4.3-4: 2017 Clean Air Plan Control Measures Consistency Analysis Applicable Control Strategy Measure Consistency Analysis and T-79 (refer to Section 4.3.1.2) support
these programs. Pursuant to the discussion in
Section 4.17 Transportation under Impact
TRN-1, the project would not conflict with any
program, plan, ordinance, or policy addressing
transit facilities. (Consistent)
TR8: Ridesharing, Last-Mile Connection:

Promote carpooling and vanpooling by
providing funding to continue regional and
local ridesharing programs, and support the
expansion of carsharing programs. Provide
incentive funding for pilot projects to evaluate
the feasibility and cost-effectiveness of
innovative ridesharing and other last-mile
solution trip reduction strategies. Encourage
employers to promote ridesharing and
carsharing to their employees.

Implementation of the Housing Element would
not result in employment generating uses, and
General Plan policies T-1, T-4, T-5, T-20, T50, T-57, T-62, and T-64 (refer to Section

4.3.1.2) would support ridesharing and
improve first- and last-mile connections.
(Consistent)
TR9: Bicycle and Pedestrian Access and
Facilities:

Encourage planning for bicycle and pedestrian
facilities in local plans, e.g., general and
specific plans, fund bike lanes, routes, paths
and bicycle parking facilities.

Pursuant to the discussion in Section 4.17.1
Transportation under Impact TRN-1,
implementation of the Housing Element
Update would not conflict with any program,
plan, ordinance, or policy addressing bicycle or
pedestrian facilities. Further, General Plan
policies T-3, T-69, T-71, T-72, T-73, T-75, T77, T-78, and T-80 (refer to Section 4.3.1.2) support the creation and maintenance of new
and existing bicycle and pedestrian facilities.
(Consistent)
TR10: Land Use Strategies:

Support implementation of Plan Bay Area,
maintain and disseminate information on
current climate action plans and other local
best practices, and collaborate with regional
partners to identify innovative funding
mechanisms to help local governments
address air quality and climate change in their
general plans.

As discussed in Section 4.11 Land Use and
Planning and Section 4.14 Population and
Housing, the Housing Element Update
addresses the City’s regional housing needs
allocation upon which Plan Bay Area 2050 is
based; therefore, the project directly supports
implementation of Plan Bay Area 2050.

Further, General Plan policies LUD-9, LUD22, LUD-23, LUD-26, T-81, and T-83 (refer to Section 4.3.1.2) further support
implementation of Plan Bay Area 2050.
(Consistent)
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 59 Initial Study
City of San Bruno December 2022
Table 4.3-4: 2017 Clean Air Plan Control Measures Consistency Analysis Applicable Control Strategy Measure Consistency Analysis TR13: Parking Policies:

Encourage parking policies and programs in
local plans, e.g., reduce minimum parking
requirements; limit the supply of off-street
parking in transit-oriented areas; unbundle the
price of parking spaces; support
implementation of demand-based pricing
(such as “SF Park”) in high-traffic areas.

The Housing Element Update does not include
any parking policies or programs that would
conflict with Measure TR13. Further, General
Plan policies LUD-8, LUD-19, T-23, T-34, T38, and T-40 (refer to Section 4.3.1.2) support parking policies that encourage use of
alternative modes of transportation.
(Consistent)
Building Control Measures
BL1: Green Buildings:

Collaborate with partners such as KyotoUSA
to identify energy-related improvements and
opportunities for onsite renewable energy
systems in school districts; investigate
funding strategies to implement upgrades.

Identify barriers to effective local
implementation of the CALGreen (Title 24)
statewide building energy code; develop
solutions to improve
implementation/enforcement. Work with
ABAG’s BayREN program to make
additional funding available for energyrelated projects in the buildings sector.

Engage with additional partners to target
reducing emissions from specific types of
buildings.

As discussed in Section 4.6 Energy, the
Housing Element Update would not result in
wasteful, inefficient, or unnecessary
consumption of energy resources, or conflict
with or obstruct any renewable energy or
energy efficiency plans. Proposed Housing
Element Program 7-A would adopt a local
ordinance which requires more stringent
building standards and Electric Vehicle (EV)
parking spaces than those imposed at the state
level through Title 24 of the California Energy
Code. Future development under the Housing
Element would be constructed at minimum in
accordance with Title 24 requirements.

Further, General Plan policies PFS-62, PFS-63,
and PFS 64 (refer to Section 4.3.1.2) support
the construction of green buildings.
(Consistent)
BL2: Decarbonize Buildings:

Explore potential Air District rulemaking
options regarding the sale of fossil fuel-based
space and water heating systems for both
residential and commercial use. Explore
incentives for property owners to replace their
furnace, water heater or natural-gas powered
appliances with zero-carbon alternatives.

Update Air District guidance documents to
recommend that commercial and multi-family
developments install ground source heat
pumps and solar hot water heaters.

As discussed in Section 4.8 Greenhouse Gas
Emission under Impact GHG-2, future
residential development under the Housing
Element Update would be required to be fully
electric. Further, General Plan policies PFS-64,
PFS-68, and PFS-69 (refer to Section 4.3.1.2)
support building and landscaping
decarbonization. Accordingly, implementation
of the Housing Element Update would support
the decarbonization of buildings. (Consistent)
BL4: Urban Heat Island Mitigation:

Develop and urge adoption of a model
ordinance for “cool parking” that promotes
Implementation of the Housing Element
Update is anticipated to replace existing nonresidential uses with substantial amounts of DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 60 Initial Study
City of San Bruno December 2022
Table 4.3-4: 2017 Clean Air Plan Control Measures Consistency Analysis Applicable Control Strategy Measure Consistency Analysis the use of cool surface treatments for new
parking facilities, as well existing surface lots
undergoing resurfacing. Develop and promote
adoption of model building code requirements
for new construction or re-roofing/roofing
upgrades for commercial and residential
multi-family housing. Collaborate with expert
partners to perform outreach to cities and
counties to make them aware of cool roofing
and cool paving techniques, and of new tools
available.
surface parking in favor of underground or
podium garages; therefore, the Housing
Element Update is anticipated to reduce the
urban heat island effect. Further, General Plan
policies PFS-65, PFS-66, and T-40 (refer to
Section 4.3.1.2) would support the reduction of
urban heat island effects through building and
landscaping design. (Consistent)
Natural and Working Lands Measures
NW2: Urban Tree Planting:

Develop or identify an existing model
municipal tree planting ordinance and
encourage local governments to adopt such an
ordinance. Include tree planting
recommendations the Air District’s technical
guidance, best practices for local plans and
CEQA review.

As discussed in Section 4.4 Biological
Resources under Impact BIO-5, future
development under the Housing Element
Update would be required to obtain Heritage
Tree and Street Tree removal permits as
required by the City’s Municipal Code, and
conform with the replacement requirements
outlined in San Bruno Municipal Code sections

8.24.090 and 8.25.050. Further, General Plan
policies PFS-66 and PFS-68 (refer to Section

4.3.1.2) support urban tree planting.
(Consistent)
Waste Management Measures
WA4: Recycling and Waste Reduction:

Develop or identify and promote model
ordinances on community-wide zero waste
goals and recycling of construction and
demolition materials in commercial and
public construction projects.

Future construction under the Housing
Element Update would be required by
Assembly Bill 939 to divert 75 percent of solid
waste generated. Further, General Plan policies
ERC-19, ERC-20, PFS-22, PFS-23, PFS-24,
and PFS-25 (refer to Section 4.3.1.2) support
Measure WA4. (Consistent)
Water Measures
WR2: Support Water Conservation:

Develop a list of best practices that reduce
water consumption and increase on-site water
recycling in new and existing buildings;
incorporate into local planning guidance.

As discussed in Section 4.19 Utilities under
Impact UTL-2, sufficient water supplies are
available to serve future development under
the Housing Element Update. Further, General
Plan policies ERC-24, PFS-12, PFS-13, PFS14, PFS-18, and PFS-19 (refer to Section

4.3.1.2) support water conservation.
(Consistent)
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 61 Initial Study
City of San Bruno December 2022
For the reasons outlined above, the Housing Element Update would not conflict with or obstruct implementation of the applicable air quality plan.

Impact AIR-2: The project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. (Less than Significant Impact)
As discussed in Section 4.3.1.3, the Bay Area is considered a non-attainment area for ground-level ozone and PM2.5 under both the Federal Clean Air Act and the California Clean Air Act. The area is also considered non-attainment for PM10 under the California Clean Air Act, but not the federal act.

The area has attained both state and federal ambient air quality standards for carbon monoxide. As part of an effort to attain and maintain ambient air quality standards for ozone and particulate matter (i.e., PM2.5 and PM10), BAAQMD has established plan- and project-level thresholds of significance for these air pollutants and their precursors. These thresholds are for ozone precursor pollutants (ROG and NOx), PM10, and PM2.5 and apply to both construction period and operational period impacts for projects.

Pursuant to the plan-level thresholds of significance for criteria air pollutant emissions and their precursors shown in Table 4.3-2, plans that are 1) inconsistent with the control measures provided in the 2017 CAP, or 2) would increase VMT at a rate that would exceed the rate of population increase, are considered to have a significant and unavoidable criteria air pollutant emissions impact. As documented under Impact AIR-1, the Housing Element Update would be consistent with the 2017 CAP. Further, as shown in Table 4.3-5, buildout of the Housing Element would increase VMT by

16.1 percent (and reduce VMT by .07 per capita) and increase population by 16.8 percent (and increase the population by 7,150 residents), and therefore the increase in VMT would not exceed the increase in population as a result of the project.[27][28] Table 4.3-5: VMT and Population Comparison
Scenario (Year) Population1 Daily Trips2 Daily VMT2 VMT per capita2
Existing Conditions (2022) 42,656 -- 516,991 12.12
Existing plus Housing
Element Update (2031) 49,806 14,451 600,421 12.05
27 The Housing Element results in 9,552 residents when considering approved pipeline units and ADUs, however the VMT and population comparison considers the 23 Housing Opportunity Sites, and does not factor in pipeline units, since these have already undergone project-level analysis of their criteria air pollutant emissions in comparison with project- and cumulative-level thresholds, or ADUs since their future location is not reasonably foreseeable and as such the VMT associated with these units cannot be estimated. 28 After completion of the analysis presented in this Initial Study, the number of units assumed at Sites 8 and 21 increased by one unit each, the number of units assumed at Site 22 decreased by one unit, and the number of pipeline units decreased by one unit, resulting in a net increase of one unit and two residents assumed at the Housing Opportunity Sites (2,708 units versus 2,709 units, 7,150 residents versus 7,152 residents) and no increase in the total number of units and residents assumed for the Housing Element Update as a whole (3,618 units and 9,552 residents total). This change would not affect any of the conclusions presented herein this Initial Study.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 62 Initial Study
City of San Bruno December 2022
Net Change +7,1503 +14,451 +83,430 -0.07
Source: Illingworth & Rodkin, Inc. San Bruno 2023-2031 Housing Element Update Air Quality & Greenhouse Gas Assessment. September 14, 2022.

Notes:
1 Refer to Section 4.14 of this Initial Study.
2 Source: Hexagon Transportation Consultants, Inc. Refer to Section 4.17 of this Initial Study. 3 After completion of the analysis presented in this Initial Study, the number of units assumed at Sites 8 and 21 increased by one unit each, the number of units assumed at Site 22 decreased by one unit, and the number of pipeline units decreased by one unit, resulting in a net increase of one unit and two residents assumed at the Housing Opportunity Sites (2,708 units versus 2,709 units, 7,150 residents versus 7,152 residents) and no increase in the total number of units and residents assumed for the Housing Element Update as a whole (3,618 units and 9,552 residents total). This change would not affect any of the conclusions presented herein this Initial Study.

For the reasons outlined above, implementation of the Housing Element would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard.

Impact AIR-3: The project would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant Impact with Mitigation Incorporated)
Community Health Risk
As discussed under Impact AIR-1, one of the goals of the 2017 CAP is to eliminate health risks associated with substantial pollutant concentrations. Project impacts related to increased community health risk can occur either by introducing a new source of TACs with the potential to adversely affect existing sensitive receptors in the project vicinity or by significantly exacerbating existing cumulative TAC impacts.

Per BAAQMD guidance, only sensitive receptors within 1,000 feet of TAC sources are at risk of health risk impacts associated with new development. All of the proposed Housing Opportunity Sites are located within 1,000 feet of residential uses, and as shown on Figure 4.3-1, in proximity to highways/freeways, high-volume roadways, and stationary sources of air pollutants and TACs.

I I I I
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Source: Illingworth & Rodkin, Inc., 2022.

Legend
San Bruno Housing Key Sites
Permitted Stationary Sources
Caltrain
Busy Roadways
Highways
San Bruno City Limits
35 82
82 101
280
280
380
HOUSING OPPORTUNITY SITES AND TAC SOURCES FIGURE 4.3-1
City of San Bruno2023-2031 Housing Element Update 63 Initial Study December 2022
1111 *
c::::J
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 64 Initial Study
City of San Bruno December 2022
Consistent with the BAAQMD-plan level thresholds, Housing Opportunity Sites located within overlay zones of existing air pollutant and TAC sources are identified in Table 4.3-6.

Table 4.3-6: Screening Distances from Existing Air Pollutant and TAC Sources1 Distance to Screening Threshold
Source
Cancer
Risk
Hazard
Index
Annual
PM2.5
Potentially Affected
Housing Opportunity
Sites
Roadway: Interstate
280
300 ft west -- 300 ft west
3, 6 1,000 ft east -- 1,200 ft east
Roadway: Interstate
380
500 ft north -- 400 ft north
3, 6, 13, 14, 18, 19, 20
1,400 ft south -- 1,000 ft
south
Roadway: El
Camino Real 300 ft -- 300 ft
1, 2, 4, 5, 7, 9, 10, 11,
12, 14, 16, 17, 18, 19,
20, 22, 23
Roadway: Sneath
Lane 100 ft -- 100 ft 6, 14, 19
Roadway: San
Bruno Ave 150 ft -- 150 ft 1, 3, 12, 13, 15, 21
Railroad: Caltrain
500 ft west -- -- 14, 15, 21
3,600 ft east -- --
Stationary: #18040
The Shops at
Tanforan–
Generators
100 ft -- -- 14
Stationary: #200385
SF Police Credit
Union– Generators
130 ft -- -- 3, 13
Stationary: #103134
San Bruno Kwik
Serv – GDF
230 ft -- 0 3
Stationary: #109025
Tanforan Shell– GDF 140 ft -- 0 14, 18, 19
Stationary: #110666
ARCO Facility
#00743 – GDF
125 ft -- 0 10, 16
Stationary: #110761
Rollingwood
Chevron – GDF
175 ft -- 0 6
Stationary: #111596
Unocal #0109 – GDF 160 ft -- 0 2, 5, 23
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 65 Initial Study
City of San Bruno December 2022
Table 4.3-6: Screening Distances from Existing Air Pollutant and TAC Sources1 Distance to Screening Threshold
Source
Cancer
Risk
Hazard
Index
Annual
PM2.5
Potentially Affected
Housing Opportunity
Sites
Stationary: #112375
Rollingwood 76 -
Sahbhagi Corp –
GDF
100 ft -- 0 6
Stationary: #112418
San Bruno Shell –
GDF
190 ft -- 0 1, 12
Source: Illingworth & Rodkin, Inc. San Bruno 2023-2031 Housing Element Update Air Quality & Greenhouse Gas Assessment. September 14, 2022.

Notes:
1 Only existing sources of air pollutants and TAC sources that present potential health risk issues at the proposed Housing Opportunity Sites are reported in this table; a full list of air pollutant and TAC sources is provided in Table 7 of Appendix A.

Community Health Risk from Construction
Construction equipment and associated heavy-duty truck traffic generates DPM, which is a known TAC. The primary community risk impact issues associated with construction emissions are cancer risk and exposure to PM2.5. DPM poses both a potential health and nuisance impact to nearby receptors.

TACs generated during construction of future development under the Housing Element Update could combine with the TAC sources shown in Figure 4.3-1 and expose existing sensitive receptors to substantial pollutant concentrations. General Plan Policy ERC-33, which requires all large construction projects to mitigate diesel exhaust emissions through use of alternate fuels and control devices, would support the 2017 CAP goal of reducing and eliminating health risks associated with future construction completed under the Housing Element Update. General Plan policies ERC-25, ERC-26, ERC-28, and ERC-30 (see discussion below under Community Health Risk from Operation and Fugitive Dust) would further support achievement of this goal by reducing cumulative health risks, including construction health risks, associated with implementation of the Housing Element Update. However, since (at this time) specific construction plans and schedules for future development under the project are not known, it is not possible to quantify the individual and cumulative impacts associated with future development. Therefore, in order to determine whether future construction could result in individually or cumulatively significant impacts, health risk assessments, consistent with policy ERC-33, would need to be prepared for each individual project completed under the Housing Element Update.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 66 Initial Study
City of San Bruno December 2022
Mitigation Measures:

MM AIR-3.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to implement the following measures during demolition and construction:
a. Use Tier 4 engines for all off-road equipment greater than 50 horsepower (hp) and operating for more than 20 total hours over the entire duration of construction activities.
b. Use diesel trucks with 2010 or later compliant model year engines during construction.
c. Use renewable diesel during construction.
d. Use low-VOC coatings during construction.
e. Implement BAAQMD best management practices and if necessary, enhanced measures recommended by BAAQMD.
f. Use portable electrical equipment where commercially available and practicable to complete construction. Construction contractors shall utilize electrical grid power instead of diesel generators when (1) grid power is available at the construction site; (2) when construction of temporary power lines are not necessary in order to provide power to portions of the site distant from existing utility lines; (3) when use of portable extension lines is practicable given construction safety and operational limitations; and (4) when use of electrical grid power does not compromise construction schedules.

MM AIR-3.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to conduct a construction and operational health risk assessment (HRA) prior to the issuance of discretionary permits that would allow demolition or construction activities to take place (whichever occurs first). If the HRA demonstrates, to the satisfaction of the City, that the health risk exposures for adjacent receptors will be less than BAAQMD project-level thresholds, then additional mitigation would be unnecessary. However, if the HRA demonstrates that health risks would exceed BAAQMD project level thresholds, additional feasible on- and off-site mitigation shall be analyzed to further reduce risks to the greatest extent practicable.

Consistent with BAAQMD plan-level thresholds of significance for health risks, this Initial Study has identified overlay zones for sources of air pollutants and TACs, and goals, policies and objectives to minimize potentially adverse impacts associated with future construction activities. Therefore, community health risk associated with construction of future development under the Housing Element Update would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant Impact with Mitigation Incorporated)
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 67 Initial Study
City of San Bruno December 2022
Community Health Risk from Operation
Implementation of the Housing Element Update would result in the Housing Opportunity Sites identified in Table 3.2-1 being redeveloped with new or higher density residential uses. Residential uses primarily generate light-duty vehicle traffic (i.e., gasoline- or electric-powered) as opposed to other types of land uses (e.g., distribution centers, quarries, manufacturing facilities, etc.) that generate heavy-duty vehicle traffic (i.e., diesel-powered) that are the primary source of trafficgenerated TAC impacts.

Pursuant to BAAQMD guidance, roadways with less than 10,000 average daily trips (ADT) are considered a low-impact source of TACs.29 Conservatively, without factoring in the net difference in trips generated by existing uses present at the Housing Opportunity Sites, implementation of the Housing Element Update on the 23 Housing Opportunity Sites is projected to result in 14,451 ADT.
30 Based on the total number of trips and projected number of trips that would be added to major roadway segments at AM and PM peak hours, and the distribution of the Housing Opportunity Sites and associated distribution of trips, the project is not anticipated to cause any roadways not already in excess of 10,000 ADT to exceed 10,000 ADT. As noted above, trips generated by the project would be primarily light-duty, and vehicle traffic is increasingly electric-powered (refer to Section 4.6 Energy and Section 4.8 Greenhouse Gas Emissions). Vehicle trips generated by future development under the Housing Element Update would be further reduced by:
• General Plan Policy ERC-25, which requires projects with air quality impacts to implement TDM techniques;
• General Plan Policy ERC-28, which requires local planning and development activities to incorporate subdivision, zoning, and site design measures that reduce the number and length of single-occupant automobile trips;
• General Plan Policy ERC-30, which encourages new residential developments to incorporate measures such as shuttle services to major employment centers, commercial areas and transit areas, and provide adequate transit facilities.

In addition to vehicle traffic, future development under the project may include testing and emergency operation of diesel generators. Installation and operation of diesel generators requires a permit from BAAQMD, which requires generators to be operated in accordance with BAAQMD rules and regulations that would ensure sensitive receptors are not significantly exposed to generator emissions.

In addition to the reasons outlined above, cumulative health risks would be reduced through implementation of MM AIR-3.1 above, and future development would be required to complete a HRA prior to construction that ensures operation of future development does not result individually 29 Bay Area Air Quality Management District (BAAQMD). Recommended Methods for Screening and Modeling Local Risks and Hazards, Version 3.0. May 2012. 30 After completion of the analysis presented in this Initial Study, the number of units assumed at Sites 8 and 21 increased by one unit each, the number of units assumed at Site 22 decreased by one unit, and the number of pipeline units decreased by one unit, resulting in a net increase of one unit and two residents assumed at the Housing Opportunity Sites (2,708 units versus 2,709 units, 7,150 residents versus 7,152 residents) and no increase in the total number of units and residents assumed for the Housing Element Update as a whole (3,618 units and 9,552 residents total). This change would not affect any of the conclusions presented herein this Initial Study.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 68 Initial Study
City of San Bruno December 2022
or cumulatively in health risks for sensitive receptors in excess of BAAQMD project-level thresholds.

Consistent with BAAQMD plan-level thresholds of significance for health risks, this Initial Study has identified overlay zones for sources of air pollutants and TACs, and goals, policies and objectives to minimize potentially adverse impacts associated with operational activities. Therefore, community health risk associated with operation of future development under the Housing Element Update would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant Impact with Mitigation Incorporated)
Fugitive Dust
Construction activities, particularly during site preparation and grading, would temporarily generate fugitive dust in the form of PM10 and PM2.5. Sources of fugitive dust would include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site would deposit mud on local streets, which could be an additional source of airborne dust after it dries. The BAAQMD CEQA Air Quality Guidelines consider these impacts to be less than significant if the following best management practices are implemented.

BAAQMD Best Management Practices:
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
• All haul trucks transporting soil, sand, or other loose material off-site shall be covered. • All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. • All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph). • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
• Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. • All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

Implementation of the BAAQMD best management practices identified above is required by General Plan Policy ERC-26 and MM AIR-3.1. Therefore, fugitive dust generated during construction of DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 69 Initial Study
City of San Bruno December 2022
future development under the Housing Element Update would not expose sensitive receptors to substantial pollutant concentrations.

Health Risks from Criteria Air Pollutants
In a 2018 decision (Sierra Club v. County of Fresno), the state Supreme Court determined CEQA requires that when a project’s criteria air pollutant emissions would exceed applicable thresholds and contribute a cumulatively considerable contribution to a significant cumulative regional criteria pollutant impact, the potential for the project’s emissions to affect human health in the air basin must be disclosed. State and federal ambient air quality standards are health-based standards, and exceedances of those standards result in continued unhealthy levels of air pollutants. As stated in the 2017 BAAQMD CEQA Air Quality Guidelines, air pollution by its nature is largely a cumulative impact. No single project is sufficient in size, by itself, to result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. In developing thresholds of significance for air pollutants, BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project has a less than significant impact for criteria pollutants, it is assumed to have no adverse health effect.

As discussed under Impact AIR-2, buildout of the Housing Element Update would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard. Criteria air pollutant emissions associated with buildout of the TCP and Bayhill Specific Plan would be further reduced with implementation of the mitigation measures identified in Section 4.3.2.1. Therefore, criteria air pollutants generated by implementation of the project would not expose sensitive receptors to substantial pollutant concentrations.

Impact AIR-4: The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. (Less than Significant Impact)
Construction activities associated with buildout of the Housing Element Update would generate localized emissions of diesel exhaust during construction equipment operation and truck activity.

These emissions may be noticeable from time to time by adjacent receptors; however, the odors would be localized and temporary and are not likely to affect people off-site. Odors associated with the application of paints and coatings may also be noticeable on occasion by adjacent receptors.

Painting and coating of the project would occur during daytime hours only, would be localized, and would be generally confined to the project site. These odors would also be temporary.

Odors are generally considered an annoyance rather than a health hazard. Land uses that have the potential to be sources of odors that generate complaints include, but are not limited to, wastewater treatment plants, landfills, composting operations, and food manufacturing facilities. Implementation of the Housing Element would only lead to buildout of residential uses, which do not generate objectionable odors or any other type of emissions that could adversely affect a substantial number of people.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 70 Initial Study
City of San Bruno December 2022

4.4 BIOLOGICAL RESOURCES

4.4.1 Environmental Setting

4.4.1.1 Regulatory Framework
Federal and State
Endangered Species Act
Individual plant and animal species listed as rare, threatened, or endangered under state and federal Endangered Species Acts are considered special-status species. Federal and state endangered species legislation has provided the United States Fish and Wildlife Service (USFWS) and the California Department of Fish and Wildlife (CDFW) with a mechanism for conserving and protecting plant and animal species of limited distribution and/or low or declining populations. Permits may be required from both the USFWS and CDFW if activities associated with a proposed project would result in the take of a species listed as threatened or endangered. To “take” a listed species, as defined by the State of California Fish and Game Code Section 86, is “to hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill” these species. “Take” is more broadly defined by the federal Endangered Species Act (16 United States Code (USC) 1532) to include harm of a listed species.

In addition to species listed under state and federal Endangered Species Acts, Sections 15380(b) and (c) of the CEQA Guidelines provide that all potential rare or sensitive species, or habitats capable of supporting rare species, must be considered as part of the environmental review process. These may include plant species listed by the California Native Plant Society and CDFW-listed Species of Special Concern.31
Migratory Bird Treaty Act
The federal Migratory Bird Treaty Act (MBTA) prohibits killing, capture, possession, or trade of migratory birds except in accordance with regulations prescribed by the Secretary of the Interior.

Hunting and poaching are also prohibited. This includes direct and indirect acts, except for harassment and habitat modification, which are not included unless they result in direct loss of birds, nests, or eggs. The CDFW also protects migratory and nesting birds under California Fish and Game Code Sections 3503, 3503.5, and 3800. The CDFW considers causing abandonment and/or loss of reproductive efforts through disturbance on bird species to be a “taking”. 31 A “Species of Special Concern” is a species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following criteria:
• Is extirpated from the State or, in the case of birds, is extirpated in its primary season or breeding role; • Is listed as Federally-, but not State-, threatened or endangered; meets the State definition of threatened or endangered but has not formally been listed;
• Is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status; • Has naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for State threatened or endangered status.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 71 Initial Study
City of San Bruno December 2022
Sensitive Habitat Regulations
Wetland and riparian habitats are considered sensitive habitats under CEQA. They are also afforded protection under applicable federal, state, and local regulations, and are generally subject to regulation by the United States Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), CDFW, and/or the USFWS under provisions of the federal Clean Water Act (e.g., Sections 303, 304, 404) and State of California Porter-Cologne Water Quality Control Act.

California Fish and Game Code
Streambeds and banks, as well as associated riparian habitat, are regulated by the CDFW per Section 1602 of the Fish and Game Code. Work within the bed or banks of a stream or the adjacent riparian habitat requires a Streambed Alteration Agreement from the CDFW. Sections 3503, 3503.5, and 3513 protect native birds and raptor nests when in active use.

Local
City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating biological impacts resulting from planned development within the City, including the following:

Policies Description
LUD-33 Plant additional street trees along the existing buffer between Huntington Avenue and the residential frontage road due east of the San Bruno BART Station.

LUD-73 Require buildings with a continuous façade of 100 feet or longer to use non-reflective materials to minimize adverse impact of glare.

OSR-28 Preserve Crestmoor Canyon in a natural state. Minimize changes to natural landforms, topography, rock outcroppings, mature tree stands, and other vegetation, while accommodating a multi-use trail and supporting facilities. Exceptions may be made for any necessary changes in order to improve slope stability.

OSR-29 Prevent erosion in Crestmoor Canyon through planting of native species along steep slopes and drainage swales.

OSR-32 During plan review, assure that development on city lands is compatible with preservation of Crestmoor Canyon, Junipero Serra Park, San Francisco Peninsula Watershed lands, Golden Gate National Recreation Area, and San Francisco International Airport wetlands in a natural state.

OSR-33 Balance fire preventions goals with the preservation of the mature tree stands along the city’s scenic corridors, including Sneath Lane, Skyline Boulevard, I-280, and Crystal Springs Road, consistent with the Tree Preservation Ordinance and Ordinance 1284. Landscaping of public rights-of-way along these corridors should complement the natural state.

OSR-34 Protect mature trees, as feasible, during new construction and redevelopment. Require identification of all trees over six inches in diameter and approval of landscaping plans during design review.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 72 Initial Study
City of San Bruno December 2022
Policies Description
OSR-38 Require open space easements or deed restrictions on undevelopable property. Through the plan review process, require recordation of open space easement, deed restriction, dedication or other legal means of permanently restricting development of open space lands.

ERC-A Preserve open space essential for the conservation of San Bruno’s natural resources – including vegetation, wildlife, soils, water, and air.

ERC-B Protect the natural environment, including wildlife, from destruction during new construction or redevelopment within San Bruno.

ERC-C Recognize areas of overlapping jurisdiction with respect to open space and environmental resources, and coordinate the City’s actions with efforts of surrounding cities, agencies, and San Mateo County.

ERC-1 Preserve as open space those lands which are identified, through environmental review, as sensitive habitat areas. Require setbacks to deve1opment as buffer areas, as appropriate.

ERC-2 Preserve as open space those portions of property which have significant value to the public as scenic resources, aesthetic, or recreation purposes.

ERC-3 Protect natural vegetation in park, open space, and scenic areas as wildlife habitat, to prevent erosion, and to serve as noise and scenic buffers.

ERC-5 Preserve critical habitat areas and sensitive species within riparian corridors, hillsides, canyon areas, tree canopies, and wetlands that are within the City’s control (Figure 6-1).

Protect declining or vulnerable habitat areas from disturbance during design and construction of new development.

ERC-6 Preserve wetland habitat in the San Francisco Bay Margins along the eastern edge of city land as permanent open space (Figure 6-1). Where jurisdiction allows, establish buffer zones at the edge of wetland habitats and identify buffer zones as areas to restrict development.

Environmental concerns should be addressed during stormwater maintenance activities.

ERC-7 Ensure that construction adjacent to open canyon areas is sensitive to the natural environment. Preserve the natural topography and vegetation.

ERC-8 If development occurs adjacent to a wetlands area, ensure that a qualified biologist has conducted a wetlands delineation in accordance with federal and State guidelines.

ERC-9 Preserve mature trees and vegetation, including wildflowers, within open canyon areas and along the city’s scenic roadways.

ERC-10 Require incorporation of native plants into landscape plans for new development as feasible – especially in areas adjacent to natural areas, such as canyons or scenic roadways (Figure 6- 1). Require preservation of mature trees, as feasible, during design and construction.

ERC-11 Prohibit the use of any new non-native invasive plant species in any landscaped or natural area. Develop a program for abatement of non-native invasive species in open space or habitat areas.

ERC-12 Balance the need for fire safety and invasive plant species management with new considerations along the city’s scenic corridors. Encourage buildings to be locked outside of the tree’s drip-line or 12 feet from the tree trunk, whichever is greater, and/or incorporating special techniques to minimize root damage, etc.

ERC-13 Through environmental review, assure that all projects affecting resources of regional concern (e.g., the San Francisco garter snake habitat, water and air quality, the San Francisco Fish and Game Reserve) satisfy regional, State and federal laws.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 73 Initial Study
City of San Bruno December 2022
Policies Description
ERC-14 Preserve wetlands habitat and associated species in compliance with the federal “no net loss” policy using mitigation measures such as:
• Avoidance of sensitive habitat areas;
• Clustering of development away from wet lands;
• Transfer of development rights for preservation of existing sensitive lands; and/or • Compensatory in-kind mitigation, such as restoration or creation.

ERC-15 Consult with the California Department of Fish and Game to determine significant habitat areas. Identify priorities for acquisition or maintenance of open space areas based on biological or environmental concerns.

ERC-16 Conduct presence/absence biological surveys for sensitive plant and animal species in natural areas prior to any construction activities proposed adjacent to or within identified natural areas (Figure 6-1). If no special status species are detected during these surveys, then construction-related activities may proceed. If listed special status species are found with the construction zone, then avoid these species and their habitat or consult with U.S. Fish and Wildlife Service and/or California Department of Fish and Game.

ERC-17 If construction activities, including tree removal activities, are required adjacent to or within natural areas (Figure 6-1), then avoid activities during March through June unless a bird survey is conducted to determine that the tree is unused during the breeding season by avian species that are protected under California Fish and Game Codes 3503, 3503.5, and 3511.

ERC-18 Coordinate efforts with the San Mateo County Flood Control District, Caltrans, Golden Gate National Recreation Area, San Francisco Airport, Peninsula Watershed lands, and Junipero Serra County Park to develop or preserve and manage interconnecting wildlife movement corridors.

PFS-34 Identify and remove mature and/or diseased Eucalyptus trees in rights-of-way and other open areas, if they pose a fire hazard or other threat to health and safety.

City of San Bruno Municipal Code
Chapter 8.24 of the City of San Bruno Municipal Code, “Street Trees and Other Plantings”, regulates the planting and maintenance of trees and other plantings in and along the public streets, ways, and public easements within the city. Chapter 8.25, “Heritage Trees”, protects certain trees located on private property within the City of San Bruno, including:
• Any native bay (Umbellularia californica), buckeye (Aesculus species), oak (Quercus species), redwood (Sequoia sempervirens), or pine (Pinus radiata) tree that has a diameter of six inches or more measured at 54 inches above natural grade; • Any tree or stand of trees designated by resolution of the city council to be of special historical value or of significant community benefit;
• A stand of trees, the nature of which makes each dependent on the others for survival; or • Any other tree with a trunk diameter of ten inches or more, measured at 54 inches above natural grade.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 74 Initial Study
City of San Bruno December 2022
Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Six of the Bayhill Specific Plan includes mandatory “Urban Design Policies”, including the following which pertain to biological resources.

Policy 3-2
Policy 3-2 requires street trees, lighting, landscaping, and other amenities be provided by new development along their entire street frontages. Among other requirements, Policy 3-2 requires trees removed during construction to be replaced at a minimum ratio of 1:1.

Policy 6-26
In order to avoid or minimize impacts to nesting birds during nesting season (identified as February 1 to August 31), Policy 6-26 requires construction activities to either occur outside of nesting season, or a pre-construction survey must be conducted for active nests. If any active nests are identified, Policy 6-26 prescribes measures for protecting nests (i.e., establishing no-disturbance buffer zones).

4.4.1.2 Existing Conditions
Although urbanization has removed much of the City’s original vegetation, San Bruno includes several distinct vegetative communities, including coyote brush scrub, freshwater wetland, willow riparian, mixed-oak woodland, eucalyptus woodland, mixed pine-oak-eucalyptus woodland, and nonnative grassland. The location of vegetative communities (including wetlands) and special-species habitat within the City of San Bruno relative to the identified Housing Opportunity Sites is shown on Figure 4.4-1. No portion of the City of San Bruno is within the boundaries of a habitat conservation plan; the nearest region under a conservation plan is San Bruno Mountain to the north of the City limits.

General Plan and Municipal Code Conforming Sites
Residential development at the densities proposed by the Housing Element Update (refer to Table

3.2-1) are allowed at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 under their existing General Plan land use designation and zoning designation, and therefore no General Plan amendments or rezoning is required. The existing conditions at these sites related to biological resources are discussed below.

Housing Opportunity Site 6
Housing Opportunity Site 6 is currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. As shown on Figure 4.4-1, the majority of Site 6 is mapped as urban/highly disturbed land cover; however, small undeveloped portions along the southern and eastern border provide potential habitat for sensitive species and nesting birds.

The site is bordered by I-280 to the east and the Crestmoor Canyon open space areas in all other directions. Beyond Crestmoor Canyon are single-family residences to the west, north, and south as well as two gas stations across Sneath Lane to the north. The areas southwest of Site 6 are mapped as DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 75 Initial Study
City of San Bruno December 2022
potential sensitive species and nesting bird habitat, while the areas southeast of Site 6 are mapped as potential nesting bird habitat only. An aboveground channelized portion of San Bruno Creek transitions belowground at the westernmost border of Site 6; San Bruno Creek remains underground until emptying into the San Bruno Canal, located approximately 1.75 miles east of Site 6.

Housing Opportunity Site 8
Housing Opportunity Site 8 is currently developed with the former Edgemont Elementary School campus. The campus consists of two one-story gabled-roof buildings with rooftop solar panels, a surface parking lot, and a playground area. As shown on Figure 4.4-1, Site 8 and the surrounding area is mapped as urban/highly disturbed land cover and do not contain any vegetative communities, wetlands, or habitat suitable for special status species. There are a number of mature trees present on site. The nearest waterway is Crystal Springs Creek, located approximately 0.5-miles south of Site 8.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 19 21
20 7
12 6
9 4
2 8
5 23
22 17
10 18
13 14
3 1
15 11
16 Freshwater Forested/Shrub
Freshwater Emergent Wetland
California Red-Legged Frog
Mission Blue Butterfly
White-Rayed Pentachaeta
Saltmarsh Common Yellowthroat
Potential Sensitive Species
Inaccessible Site
Potential Nesting Birds
City Limits
Source: Environmental Science Associates, 2002;
California Natural Diversity Database; Dyett &
Bhatia, 2002, 2003.

FEET
0 500 1000 2000 10
acres
Bayhill Specific
Plan Boundary
Transit Oriented
Development Overlay
VEGETATIVE COMMUNITIES AND SPECIAL SPECIES HABITAT FIGURE 4.4-1 City2023-2031 Housing Element Update
of San Bruno
76 Initial Study
December 2022
----1
-.... -.... _
I
I
I
I
fB
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 77 Initial Study
City of San Bruno December 2022
Housing Opportunity Sites 10 and 16
Housing Opportunity Sites 10 and 16 are vacant dirt lots that are located adjacent to each other on San Marco Avenue. As shown on Figure 4.4-1, the sites and surrounding area are mapped as urban/highly disturbed land cover and do not contain any vegetative communities, wetlands, or habitat for special status species. Minimal vegetation (including trees and shrubs) is present on-site.

The nearest waterway is Crystal Springs Creek, approximately 0.55-miles west of Sites 10 and 16.

Housing Opportunity Site 18
Housing Opportunity Site 18 is developed with a two-story building, pedestrian plaza, and surface parking lot. As shown on Figure 4.4-1, Site 18 and the surrounding area is mapped as urban/highly disturbed land cover and does not contain any vegetative communities, wetlands, or habitat for special status species. Site 18 is well-landscaped, consisting of numerous mature trees, shrubs, and groundcover. The nearest waterway is the San Bruno Canal, located approximately 0.75-miles east of Site 18.

Housing Opportunity Site 19
Housing Opportunity Site 19 is developed with a single-story building and surface parking lot. As shown on Figure 4.4-1, Site 19 and the surrounding area is mapped as urban/highly disturbed land cover and does not contain any vegetative communities, wetlands or habitat for special status species.

Site 19 is poorly landscaped with no mature trees and minimal shrubbery. The nearest waterway is the San Bruno Canal, located approximately 0.75-miles east of Site 19.

Transit Corridors Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP area is fully urbanized and characterized by diverse land uses, building forms, parcel sizes and surface parking lots. According to the TCP EIR, no riparian habitat, wetlands, wildlife corridors, or other sensitive natural communities are present within the TCP area.32 Large Monterey pine, Monterey cypress, blue gum eucalyptus and oak trees are present throughout the TCP area that could provide nesting habitat for urban adapted birds and certain bat species.

Bayhill Specific Plan Area Sites
As noted in Section 3.1.1.2, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. The Bayhill Specific Plan area is approximately 92.2 acres in size and encompasses the Bayhill Office Park, Bayhill Shopping Center, and Marriott Courtyard Hotel. At the time of preparation of the Bayhill Specific Plan EIR, an isolated 11-acre portion of the Bayhill Specific Plan area was vacant and dominated by non-native vegetation (primarily eucalyptus trees); this area is currently being developed. Biological surveys prepared as part of the Bayhill Specific Plan EIR determined that no habitat suitable for special status species, riparian habitat, wetlands, wildlife corridors, or other sensitive natural communities are present with the Bayhill Specific Plan area. Mature trees and other vegetation are present within the Bayhill Specific Plan area, including 32 City of San Bruno. San Bruno Transit Corridors Plan Draft Environmental Impact Report. Page 15-4. March 2012.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 78 Initial Study
City of San Bruno December 2022
native and non-native trees. Most of the trees are ornamental landscaping in roadway medians and parking lot islands.

Housing Opportunity Site 14
Housing Opportunity Site 14 consists of 1122-1188 El Camino Real/300 Tanforan Shopping Center, which is developed with the Shops at Tanforan shopping mall, and 1292 Huntington Avenue, which is located opposite the Shops at Tanforan across the Sneath Lane/Huntington Avenue intersection and is developed with a vacant paved lot. Vegetation at the Shops at Tanforan is minimal, consisting primarily of street trees and landscaping with almost no interior vegetation; landscaping at 1292 Huntington Avenue is non-existent besides a row of shrubbery. As shown on Figure 4.4-1, Site 14 and the surrounding area is mapped as urban/highly disturbed land cover and does not contain any vegetative communities, wetlands, or habitat for special status species. The nearest waterway is the San Bruno Canal, located approximately 0.5-miles east of Site 14.

4.4.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate, sensitive,
or special status species in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
(CDFW) or United States Fish and Wildlife
Service (USFWS)?
2) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the CDFW
or USFWS?
3) Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means?
4) Interfere substantially with the movement of
any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
5) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
□ □ □
□ □ □
□ □ □
□ □ □
□ □ □
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 79 Initial Study
City of San Bruno December 2022
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
6) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
Impact BIO-1: The project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. (Less than Significant Impact with Mitigation Incorporated)
Special Status Species
As documented in Section 4.4.1.2, none of the Housing Opportunity Sites (with the exception of Site 6, discussed below) have habitat present on site, or are located near habitat, that would support special status species, and therefore, implementation of the Housing Element would not have a substantial adverse effect, either directly or through habitat modifications, on any special status species.

Site 6 is 21.1 acres, located on the south side of Sneath Lane west of I-280 freeway, and currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. The majority of Housing Opportunity Site 6 is urban/highly disturbed land cover; however, the areas southwest of Site 6 are mapped as potential sensitive species and nesting bird habitat, while the areas southeast of Site 6 are mapped as potential nesting bird habitat only. An aboveground channelized portion of San Bruno Creek transitions belowground at the westernmost border of Site 6.

The Housing Element anticipates Site 6 would be redeveloped with approximately 118 single-family homes. Future residential development envisioned by the Housing Element on Site 6 would not substantially affect special status species by adhering to the various General Plan policies listed in Section 4.4.1.1, including ERC-1, which requires preservation of open space land identified as sensitive habitat areas, and setbacks to development as buffer areas, ERC-5, which requires preservation of critical habitat areas and sensitive species within riparian corridors, and ERC-16, which requires biological surveys for development adjacent to or within an identified natural area, such as riparian corridors. (Less than Significant Impact) Nesting Birds and Migratory Raptors
As discussed in Section 4.4.1.2, trees are located on and adjacent to many of the Housing Opportunity Sites, that could serve as nesting habitat for birds, including migratory birds and raptors.

Nesting birds are among the species protected under provisions of the Migratory Bird Treaty Act and California Fish and Game Code Sections 3503, 3503.5, and 2800. Disturbances caused by demolition □ □ □
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 80 Initial Study
City of San Bruno December 2022
and/or construction activities during the breeding season could result in the loss of fertile eggs or nest abandonment. Furthermore, tree removal during the nesting season (February 1st through August 31st) could potentially impact protected raptors and/or other protected migratory birds. Any loss of fertile bird eggs, individual nesting eggs, or any activities resulting in nest abandonment during construction would constitute a significant impact.

Mitigation Measures:

MM BIO-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites to comply with the following measures:
a. Demolition and nesting substrate (e.g., trees, bushes, grasses, and other vegetation) removal activities shall be scheduled to avoid nesting season (February 1 to August 31). To the extent feasible, construction activities shall be scheduled to occur during the nonnesting season (September 1 through January 31). b. Prior to issuance of any discretionary permits that would allow construction activities during the nesting season, a qualified biologist shall complete pre-construction surveys for active nests within 14 days of work commencing. The survey area must include the proposed development area and all areas within 300 feet of the development area boundary (“zone of influence”). If active nest, roost, or burrow sites are identified within the zone of influence, a nodisturbance buffer shall be established for all active nest sites prior to commencement of any proposed construction-related activities to avoid disturbances to migratory bird nesting activities. A nodisturbance buffer constitutes a zone in which construction activities cannot occur. The sizes of the buffers shall be determined by a qualified biologist based on the species, activities proposed near the nest, and topographic and other visual barriers. Buffers shall remain in place until the young have departed the area or fledged and/or the nest is inactive, as determined by the qualified biologist. c. If work is necessary within a buffer zone of an active bird nest, work may occur under the supervision of a qualified avian biologist. The qualified avian biologist monitoring the construction work shall have the authority to stop work and adjust buffers if any disturbance to nesting activity is observed.

Implementation of MM BIO-1.1 would ensure that future redevelopment of the Housing Opportunity Sites does not result in the loss of fertile or nesting eggs or nest abandonment. MM BIO-1.1a would prohibit demolition and nesting substrate removal activities during nesting season, which would ensure that nesting does not occur during the nesting season while construction activities may be ongoing. Impacts to nesting birds and raptors would be avoided entirely if all demolition, nesting substrate removal, and construction activities can be scheduled during the non-nesting season. Prior to the initiation of any construction activities during nesting season, implementation of MM BIODocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 81 Initial Study
City of San Bruno December 2022

1.1b would require active nests be identified and no-disturbance buffer zones established by a qualified biologist, which would prevent any construction activities that could result in the loss of fertile or nesting eggs or nest abandonment. Any construction activities within these buffer zones would only be permitted under the supervision of a qualified avian biologist, who would have the authority to stop work should any activities that could result in the loss of fertile or nesting eggs or nest abandonment to occur. For these reasons, implementation of the Housing Element as amended by MM BIO-1.1 would ensure that future residential development at all sites would have a less than significant impact on nesting birds and migratory raptors. (Less than Significant Impact with Mitigation Incorporated)
Impact BIO-2: The project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS. (Less than Significant Impact)
As documented in Section 4.4.1.2, none of the Housing Opportunity Sites (with the exception of Site 6, discussed below) are located on or adjacent to any riparian corridors or other sensitive natural community.

Site 6 is 21.1 acres, located on the south side of Sneath Lane west of I-280 freeway, and currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. The majority of Housing Opportunity Site 6 is urban/highly disturbed land cover; however, an aboveground channelized portion of San Bruno Creek transitions belowground at the westernmost border of Site 6; San Bruno Creek remains underground until emptying into the San Bruno Canal, located approximately 1.75 miles east of Site 6. The Housing Element anticipates Site 6 would be redeveloped with approximately 118 single-family homes. Future residential development envisioned by the Housing Element on Site 6 would not substantially affect the portion of San Bruno Creek that is above ground on or near the site by adhering to the various General Plan policies listed in Section

4.4.1.1, including ERC-1, which requires preservation of open space land identified as sensitive habitat areas, and setbacks to development as buffer areas, ERC-5, which requires preservation of critical habitat areas and sensitive species within riparian corridors, ERC-10, which requires native plants in landscape plans and preservation of mature trees adjacent natural areas, ERC-11, which prohibits non-native plant species in landscape plans in natural areas or sensitive habitats, and ERC16, which requires biological surveys for development adjacent to or within an identified natural area, such as riparian corridors.

Impact BIO-3: The project would not have a substantial adverse effect on state or federally protected wetlands through direct removal, filling, hydrological interruption, or other means. (No Impact)
As documented in Section 4.4.1.2, none of the Housing Opportunity Sites contain wetlands, and therefore implementation of the Housing Element would not result in substantial adverse effects on state or federally protected wetlands.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 82 Initial Study
City of San Bruno December 2022
Impact BIO-4: The project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Less than Significant Impact)
As documented in Section 4.4.1.2, none of the Housing Opportunity Sites (with the exception of Site 6) provide any habitat that could serve as a corridor or nursery for resident or migratory wildlife outside of the birds discussed in Impact BIO-1. The absence of any waterways on the Housing Opportunity Sites (other than Site 6) precludes the potential to impact any resident or migratory fish species. Therefore, future residential development at the Housing Opportunity Sites would not interfere substantially with the movement of any species, with established native resident or migratory wildlife corridors, or the use of native wildlife nursery sites.

As noted previously, Housing Opportunity Site 6 is urban/highly disturbed land cover; however, an aboveground channelized portion of San Bruno Creek transitions belowground at the westernmost border of Site 6. To the extent that the channelized San Bruno Creek functions as a wildlife corridor, implementation of the various General Plan policies discussed above under Impact BIO-2 (ERC-1, ERC-5, ERC-10, ERC-11, and ERC-16), would ensure that future residential development envisioned by the Housing Element on Site 6 would not substantially affect the portion of San Bruno Creek that is above ground on or near the site and the use of that portion of San Bruno Creek as a wildlife corridor.

Impact BIO-5: The project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Less than Significant Impact)
As discussed in Section 4.4.1.2, trees are located on and adjacent to many of the Housing Opportunity Sites. Future redevelopment of the Housing Opportunity Sites may require the removal of trees, including heritage and street trees, that are present on-site, or construction could impact trees on adjacent properties, such as shared property lines. Prior to removal of any protected trees, residential projects on the Housing Opportunity Sites would be required to obtain Heritage Tree and Street Tree removal permits as required by the City’s Municipal Code. The future housing projects would also be required to conform with the replacement requirements outlined in San Bruno Municipal Code sections 8.24.090 and 8.25.050.33 Additionally, adherence to General Plan policy OSR-34, which requires protection of mature trees during new construction and redevelopment, would ensure that trees intended to remain on a site or adjacent to a site, would be protected from construction activity. Accordingly, future residential development of the Housing Opportunity Sites would not lead to any conflict with any local policies or ordinances protecting biological resources, including tree preservation policies or ordinances.
33 Street trees and heritage trees are required to be replaced by either two twenty-four-inch box size trees or one thirty-six-inch box size tree for each tree removed.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 83 Initial Study
City of San Bruno December 2022
Impact BIO-6: The project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (No Impact) No portion of the City of San Bruno is located within the boundaries of an adopted conservation plan area. Thus, there are no possible conflicts for the Housing Element with the provisions of any adopted conservation plans.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 84 Initial Study
City of San Bruno December 2022

4.5 CULTURAL RESOURCES
The following discussion is based, in part, on a Cultural Resources Sensitivity Report prepared for the project by Archaeological/Historical Consultants. The report, dated September 2022, is on file with the Community and Economic Development Department.

4.5.1 Environmental Setting

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

The NRHP is the nation’s master inventory of historic resources that are considered significant at the national, state, or local level. The minimum criteria for determining NRHP eligibility include:
• The property is at least 50 years old (properties under 50 years of age that are of exceptional importance or are contributors to a district can also be included in the NRHP); • It retains integrity of location, design, setting, materials, workmanship, feeling, and associations; and
• It possesses at least one of the following characteristics:
o Association with events that have made a significant contribution to the broad patterns of history;
o Association with the lives of persons significant in the past; o Distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant, distinguishable entity whose components may lack individual distinction; or o Has yielded, or may yield, information important to prehistory or history.

California Register of Historical Resources
The guidelines for identifying historic resources during the project review process under CEQA are set forth in Public Resources Code Section 21084.1 and CEQA Guidelines Section 15064.5(a). These provisions of CEQA create three categories of historical resources: mandatory historical resources; presumptive historical resources; and resources that may be found historical at the discretion of the lead agency. These categories are described below.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 85 Initial Study
City of San Bruno December 2022
• Mandatory Historical Resources. A resource the State Historical Resources Commission lists on the CRHR, or the State Historical Resources Commission determines to be eligible for listing in the CRHR, is defined by CEQA to be a historical resource. Resources are formally listed or determined eligible for listing by the State Historical Resources Commission in accordance with the procedures set forth in the provisions of state law relating to listing of historical resources.34 If a resource has been listed in the CRHR, or formally determined to be eligible for listing by the State Historical Resources Commission under these procedures, it is conclusively presumed to be a historical resource under CEQA. • Presumptive Historical Resources. A resource included in a local register of historic resources as defined by state law35 or identified as significant in a historical resource survey meeting the requirements of state law,36 shall be presumed to be historically or culturally significant. The lead agency must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. • Discretionary Historical Resources. A resource that is not determined to be a significant historical resource under the criteria described above, may, in the discretion of the lead agency, be found to be a significant historical resource for purposes of CEQA, provided its determination is supported by substantial evidence in light of the whole record. The CEQA Guidelines further provide that generally, a lead agency should consider a resource historically significant if the resource is found to meet the criteria for listing on the CRHR, including the following:
o Criterion 1 (Events): The resource is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history and cultural heritage of California or the United States; or o Criterion 2 (Persons): The resource is associated with the lives of persons important to local, California, or national history; or
o Criterion 3 (Architecture): The resource embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values, or
o Criterion 4 (Information Potential): The resource has the potential to yield information important to the prehistory or history of the local area, California, or the nation.37 Historical resources eligible for listing in the CRHR must meet one of the criteria of significance described above and retain enough of their historic character or appearance to be recognizable as 34 Set forth in Public Resources Code Section 5024.1 and 14 California Code of Regulations (CCR) Section 4850, et. seq.
35 Set forth in Public Resources Code Section 5020.1(k), a local register of historical resources is a list of properties officially designated or recognized as historically significant by a local government pursuant to a local ordinance or resolution.
36 Under Public Resources Code Section 5024.1(g), a resource can be identified as significant in a historical resources survey and found to be significant by the State Office of Historic Preservation (i.e., listed in the CRHR) if three criteria are met: (1) the survey has or will be included in the State Historic Resources Inventory; (2) the survey and documentation were prepared in accordance with State Office of Historic Preservation procedures and requirements; and (3) the State Office of Historic Preservation has determined the resource has a significance rating of Category 1 to 5 on Form 523.
37 CEQA Guidelines Section 15064.5(a)(3) and California Office of Historic Preservation Technical Assistance Series #6. Accessed October 24, 2022.
http://www.ohp.parks.ca.gov/pages/1069/files/technical%20assistance%20bulletin%206%202011%20update.pdf.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 86 Initial Study
City of San Bruno December 2022
historical resources and to convey the reasons for their significance. A resource that has lost its historic character or appearance may still have sufficient integrity for the CRHR if it maintains the potential to yield significant scientific or historical information or specific data.

The concept of integrity is essential to identifying the important physical characteristics of historical resources and in evaluating adverse changes to them. Integrity is defined as “the authenticity of a historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource's period of significance.” The process of determining integrity is similar for both the California and National Registers, and the same seven variables or aspects to define integrity are used to evaluate a resource's eligibility for listing. These seven characteristics include: 1) location, 2) design, 3) setting, 4) materials, 5) workmanship, 6) feeling, and 7) association.

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

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

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

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

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 87 Initial Study
City of San Bruno December 2022
Public Resources Code Sections 5097 and 5097.98
Section 15064.5 of the CEQA Guidelines specifies procedures to be used in the event of an unexpected discovery of Native American human remains on non-federal land. These procedures are outlined in Public Resources Code Sections 5097 and 5097.98. These codes protect such remains from disturbance, vandalism, and inadvertent destruction, establish procedures to be implemented if Native American skeletal remains are discovered during construction of a project, and establish the Native American Heritage Commission (NAHC) as the authority to resolve disputes regarding disposition of such remains.

Pursuant to Public Resources Code Section 5097.98, in the event of human remains discovery, no further disturbance is allowed until the county coroner has made the necessary findings regarding the origin and disposition of the remains. If the remains are of a Native American, the county coroner must notify the NAHC. The NAHC then notifies those persons most likely to be related to the Native American remains. The code section also stipulates the procedures that the descendants may follow for treating or disposing of the remains and associated grave goods.

Local
City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating cultural impacts resulting from planned development within the City, including the following:

Policies Description
ERC-F Preserve and enhance historic and cultural resources within the city, particularly within the historic Downtown area.

ERC-36 Preserve historic structures and resources during reuse and intensification within the city’s older neighborhoods.

ERC-37 Designate the vicinity of Taylor Avenue, San Mateo Avenue, and El Camino Real as the beginning of the State Highway System as a historic landmark with a marker (Figure 6-2).

ERC-38 Work cooperatively with the owners of The Shops at Tanforan to preserve the historic marker on site (Figure 6-2).

ERC-39 Continue to protect archaeological sites and resources from damage. Require that areas found to contain significant indigenous artifacts be examined by a qualified archaeologist for recommendations concerning protection and preservation.

ERC-40 Ensure that new development adjacent to historic structures is compatible with the character of the structure and the surrounding neighborhood.

ERC-42 If demolition of a historical building is necessary for safety reasons, attempt to preserve the building façade for adaptive reuse during reconstruction. Offer funding through the Redevelopment Agency for façade preservation projects.

ERC-44 If, prior to grading or construction activity, an area is determined to be sensitive for paleontological resources, retain a qualified paleontologist to recommend appropriate actions. Appropriate action may include avoidance, preservation in place, excavation, documentation, and/or data recovery, and shall always include preparation of a written report documenting the find and describing steps taken to evaluate and protect significant resources.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 88 Initial Study
City of San Bruno December 2022
Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Six of the Bayhill Specific Plan includes mandatory “Environmental Quality Policies”, including the following which pertain to cultural resources.

Policy 6-27
Policy 6-27 requires preparation of an Archaeological Monitoring Plan (AMP) by a qualified professional archaeologist prior to any project-related ground disturbance that outlines areas of archaeological sensitivity, if any, and includes protocol to follow if unanticipated archaeological or tribal cultural resources are encountered.

Policy 6-28
Policy 6-28 requires construction contractors to be trained in recognizing archaeological and tribal cultural resources.

Policy 6-29
Policy 6-29 requires all work to stop immediately if archaeological or tribal cultural resources are discovered during construction.

Policy 6-30
Policy 6-30 includes similar protections for human remains of Native American origin discovered during construction.

4.5.1.2 Existing Conditions
Archaeological Resources
Archaeological resources are traces of human occupation and activity. In Northern California, human occupation extends back to at least 9,000-11,500 years with Native American occupation and use of the Bay Area extending over 5,000-8,000 years and possibly longer. Native Americans at the time of Euro-American contact tended to live along the alluvial terraces and along historic Bay margins, there is potential for the discovery of Native American cultural resources within the City. Native American cultural resources have also been found in San Mateo County near sources of fresh water, including streams and creeks.

General Plan and Municipal Code Conforming Sites
Residential development at the densities proposed by the Housing Element Update (refer to Table 3.2 1) are allowed at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 under their existing General Plan land use designation and zoning designation, and therefore no General Plan amendments or rezoning is required. The existing conditions at these sites related to archaeological resources are discussed below.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 89 Initial Study
City of San Bruno December 2022
Housing Opportunity Site 6
Housing Opportunity Site 6 is currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. As discussed in Section 4.4.1.2, San Bruno Creek is located adjacent west of Site 6, indicating a moderate sensitivity for prehistoric archaeological resources.

Housing Opportunity Site 8
Housing Opportunity Site 8 is currently developed with the former Edgemont Elementary School campus. Site 8 is not adjacent to any waterways and has been extensively developed, and therefore has a low sensitivity for archaeological resources.

Housing Opportunity Sites 10 and 16
Housing Opportunity Sites 10 and 16 are vacant dirt lots that are located adjacent to each other on San Marco Avenue in an urbanized area developed with mostly single-family residential development and various commercial uses along the El Camino Real corridor to the immediate west of the sites. Based on historic aerials, Sites 10 and 16 have previously been developed with singlefamily residential uses.38 Due to the proximity of Sites 10 and 16 to historic Bay margins, the sites have a moderate sensitivity for archaeological resources. According to Figure 6-2 of the General Plan (refer to Figure 4.5-2), there are known historic resources in the vicinity of Sites 10 and 16, and therefore there is the potential for historic-era archaeological resources to be present at these sites.

Housing Opportunity Site 18
Housing Opportunity Site 18 is developed with a two-story office building. Although Site 18 has previously been developed, its proximity to the historic extent of San Bruno Creek and historic Bay margins suggests a moderate sensitivity for archaeological resources. In addition, Site 18 is located west opposite El Camino Real from the historic location of the (since demolished) JapaneseAmerican Tanforan Assembly Center, discussed below under Site 14, and therefore may contain historic-era archaeological resources.

Housing Opportunity Site 19
Housing Opportunity Site 19 is developed with a single-story building and surface parking lot.

Although Site 19 has previously been developed, its proximity to the historic extent of San Bruno Creek and historic Bay margins suggests a moderate sensitivity for archaeological resources. In addition, Site 19 is located west opposite El Camino Real from the historic location of the (since demolished) Japanese-American Tanforan Assembly Center, discussed below under Site 14, and therefore may contain historic-era archaeological resources. 38 Historic Aerials by NetrOnline. “Historic Aerials Viewer”. Accessed September 12, 2022. https://www.historicaerials.com/viewer.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 90 Initial Study
City of San Bruno December 2022
Transit Corridors Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. According to the San Bruno TCP EIR, numerous Native American resources have been recorded in the general vicinity, and the three creeks that historically traversed the TCP area, and the area’s location along the Bay margin, indicate that the TCP area has a high archaeological sensitivity.

Based on a March 2003 Historic Resources Inventory of the San Bruno Redevelopment Project Area (refer to Figure 4.5-2), there are 10 historical resources within the TCP area and four historical resources immediately adjacent to the TCP area. Sites within the TCP area are sensitive for historicera archaeological resources.

Bayhill Specific Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. According to the Bayhill Specific Plan EIR, there are four previously recorded pre-contact habitation sites, and the historic extent of San Bruno Creek intersected the Bayhill Specific Plan area. As a result, sites within the Bayhill Specific Plan area are sensitive for undiscovered prehistoric and historic-era archaeological resources.

Housing Opportunity Site 14
Housing Opportunity Site 14 consists of 1122-1188 El Camino Real/300 Tanforan Shopping Center, which is developed with the Shops at Tanforan shopping mall, and 1292 Huntington Avenue, which is located opposite the Shops at Tanforan across the Sneath Lane/Huntington Avenue intersection and is developed with a vacant paved lot.

Historically, Site 14 was used for horse raising and grazing since the early days of the Spanish occupation on the Peninsula. Site 14 lies within the former Tanforan Racetrack complex, which opened in 1899 and held races of all types, from horse races to races between cars and airplanes, before it burned down in 1964. The Tanforan Racetrack was the takeoff site of the first flight ever on the West Coast and the first ever aircraft carrier takeoff and landing in 1911, from the U.S.S.

Pennsylvania. During World War II, the Tanforan Racetrack was converted into the Tanforan Assembly Center, a detention camp for Japanese Americans. The Tanforan Assembly Center was one of 13 temporary detention camps in California and is a Registered Historic Landmark, #934. Though the racetrack and associated buildings were removed when the site was redeveloped as a shopping mall in 1971, all of the parcels within Site 14 are located within the mapped area of the Tanforan Assembly Center.

The Cultural Resources Sensitivity Report concluded that Site 14 has a low sensitivity for prehistoric-era archaeological resources due to lack of nearby waterways and the fact that the nearest archaeological resource recovery site is located over 2,000 feet away. Due to Site 14’s association with the Tanforan Racetrack and Tanforan Assembly Center, the areas shown on Figure 4.5-1 are sensitive for historic-era archaeological resources.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update
City of San Bruno
91 Initial Study
December 2022
Source: Archaeological/Historical Consultants.

AREAS SENSITIVE FOR HISTORIC-ERA ARCHAEOLOGICAL RESOURCES FIGURE 4.5-1 01 '4!3:I 6!3:30
0 500 1,000 ft
Legend
[_:J Opportunity Site 14
D Project Parcels
- Archaeological Sensitivity
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 92 Initial Study
City of San Bruno December 2022
Historic Resources
In March 2003, the City conducted a Historic Resources Inventory which mapped historic resources within the Redevelopment Area (refer to Figure 3-1 in the General Plan), which encompassed all Housing Opportunity Sites with the exception of Sites 3, 6, and 13. Figure 4.5-2 of this Initial Study shows the location of all mapped historic resources within the Redevelopment Area relative to the Housing Opportunity Sites.

General Plan and Municipal Code Conforming Sites
As shown on Figure 4.5-2, there are no historic resources present on Housing Opportunity Sites 6, 8, 10, 16, 18, and 19; however, several historic buildings are located between 250 to 650 feet from Sites 10 and 16.

Transit Corridors Plan Area Sites
As discussed above, a March 2003 Historic Resources Inventory of the San Bruno Redevelopment Project Area identified 10 listed historical resources within the Transit Corridors Area and 4 listed historical resources immediately adjacent to the Transit Corridors Area. As shown Figure 4.5-2, there are no historic resources present on Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 22 and 23. At the time of the Historic Resources Inventory, the building located on Site 21 was identified as a historic resource; this building was demolished in 2008. As such, there is no longer a historic resource present at Site 21.

Bayhill Specific Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. According to the Bayhill Specific Plan EIR, none of the existing buildings within the Bayhill Specific Plan area are eligible for listing or listed on any federal, state, or local register of historic resources.

Housing Opportunity Site 14
As discussed above, Site 14 consists of 1122-1188 El Camino Real/300 Tanforan Shopping Center, which is developed with the Shops at Tanforan shopping mall, and 1292 Huntington Avenue, which is located opposite the Shops at Tanforan across the Sneath Lane/Huntington Avenue intersection and is developed with a vacant paved lot. The original Shops at Tanforan development was originally constructed in 1971; it underwent major renovations in 2005 which included a new entrance and expansion at the west elevation and extensive tenant improvements to the Century Theatre and associated parking lot (1188 El Camino Real) were added in 2007.

As discussed previously in this section, during World War II, the Tanforan Racetrack was converted into the Tanforan Assembly Center, a detention camp for Japanese Americans. The Tanforan Assembly Center was one of 13 temporary detention camps in California and is a California Historic Landmark (#934.09). The racetrack and associated buildings were removed when the site was redeveloped as a shopping mall in 1971. The listing of the site as a California Historic Landmark #934.09 is commemorative, given none of the features related to the Tanforan Assembly Center remain, i.e. no integrity exists for historic resources related to the center.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 19 21
20 7
12 6
9 4 2 8
5 23
22 17
10 18
13 14
3 1
15 11
16 FEET
10 0 500 1000 2000
acres
Historic Resource
Contributing Building
in a Historic District
California point of
historical interest
Cupid’s Row Historic District
Historic margin of San Francisco
Bay (extent of wetlands)
City Limits
Source: City of San Bruno, Historical Resource Inventory:

San Bruno Redevelopment Project , March 2003
Bayhill Specific
Plan Boundary
Transit Oriented
Development Overlay
LOCATION OF KNOWN HISTORIC RESOURCES RELATIVE TO HOUSING OPPORTUNITY SITES FIGURE 4.5-2 City2023-2031Housing Element Update
of San Bruno
93 Initial Study
December 2022
·----·
•
-
•••••• *
DEB
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 94 Initial Study
City of San Bruno December 2022
California Historic Landmark #934.09 is identified by the Tanforan Assembly Center Private Marker located at 1150 El Camino Real in front of the western entrance to the Shops at Tanforan.

At the time of the 2003 Historic Resources Inventory (which occurred prior to the 2005 renovations), the Shops at Tanforan development was less than 50 years in age, and found to be ineligible for listing on any federal, state, or local register of historic resources. The Shops at Tanforan are now greater than 50 years in age, although extensive alterations and new construction have occurred over time that have altered the integrity of the site from its 1971 condition. As shown on Figure 4.5-2, Site 14 is not located within a historic district.

4.5.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Cause a substantial adverse change in the
significance of a historical resource pursuant
to CEQA Guidelines Section 15064.5?
2) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to CEQA Guidelines Section
15064.5?
3) Disturb any human remains, including those
interred outside of dedicated cemeteries?
Impact CUL-1: The project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated)
As discussed in Section 4.5.1.2, a Historic Resources Inventory was prepared in March 2003 which mapped historic resources within the Redevelopment Area (refer to Figure 3-1 in the General Plan), which encompassed all Housing Opportunity Sites with the exception of Sites 3, 6, and 13. Of the Housing Opportunity Sites mapped, only Site 21 was developed with a historic resource. This resource was subsequently demolished in 2008.

As discussed in Section 4.5.1.2, Site 14 is the former site of the Tanforan Assembly Center, California Historic Landmark #934.09, which commemorates the historic use of the site as a detention camp for Japanese Americans during World War II. None of the features related to the Tanforan Assembly Center remain. California Historic Landmark #934.09 is identified by the Tanforan Assembly Center Private Marker located at 1150 El Camino Real in front of the western entrance to the Shops at Tanforan. The site is currently developed with the Shops at Tanforan development, which was not identified as a historic resource in the 2003 Historic Resource Inventory or mapped within a historic district, as the current development dates from 1971. Properties under 50 years in age must be of ‘exceptional importance’ in order to be eligible for listing as a historic resource. In 2003, the Shops at Tanforan were 32 years old, and were not found to constitute an □
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 95 Initial Study
City of San Bruno December 2022
historic resource as part of the 2003 inventory. Although the Shops at Tanforan were not identified as historic in the 2003 inventory and subsequently underwent major renovations in 2005, the Shops at Tanforan are now more than 50 years old and may now be eligible under the criteria for properties greater than 50 years in age (refer to Section 4.1.1.1).

It is reasonably foreseeable that future development proposals for redevelopment of Site 14 with residential uses may entail the demolition of the Shops at Tanforan and/or the removal of California Historic Landmark #934.09, or the construction of development around Shops at Tanforan that could reduce its potential historic significance.

Mitigation Measures:

MM CUL-1.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Removal or alteration of the commemorative features of California Historic Landmark #934 shall be prohibited, and must be incorporated into any future development proposals for Site 14.
b. As part of the future project-level CEQA analysis of any discretionary permit that would allow the demolition of the existing buildings located at Site 14, a Historic Resource Evaluation (HRE) shall be prepared by a qualified architect or architectural historian approved by the City and meeting the Secretary of the Interior's Professional Qualifications Standards published in the Code of Federal Regulations (36 CFR part 61).

The HRE shall evaluate whether any of the existing buildings meet the definition of a historic resource pursuant to CEQA Guidelines Section 15064.5. If the existing buildings do not meet the definition of a historic resource, demolition may proceed. If the HRE finds that any of the existing buildings at Site 14 meet the definition of a historic resource, demolition of buildings eligible for listing as a historic resource shall be prohibited.
c. In the event that any buildings meeting the definition of a historic resource pursuant to CEQA Guidelines Section 15064.5 are identified, future development proposals for Site 14 shall be reviewed for compliance by a qualified architect or architectural historian approved by the City and meeting the Secretary of the Interior's Professional Qualifications Standards published in the Code of Federal Regulations (36 CFR part 61) with one or both of the following standards prior to issuance of any discretionary permits that would allow modifications to the existing buildings or new construction on Site 14:
• Secretary of Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings; or
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 96 Initial Study
City of San Bruno December 2022
• Secretary of Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer.

Implementation of MM CUL-1.1 would ensure that prior to any activities which could cause a substantial adverse change in the significance of any historic resources that may be present at the Shops at Tanforan development located on Site 14, a Historic Resources Evaluation would be prepared that determines whether any of the existing buildings at Site 14 meet the definition of a historic resource pursuant to CEQA Guidelines Section 15064.5. Demolition, modification, or construction activities which could adversely affect the significance any buildings eligible for listing as a historic resource would require the completion of project-level CEQA review, including consideration of preservation and adaptive reuse alternatives. Therefore, implementation of the Housing Element as amended by MM CUL-1.1 would ensure that future redevelopment of Site 14 would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5.

Impact CUL-2: The project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. (Less than Significant Impact with Mitigation Incorporated) General Plan and Municipal Code Conforming Sites
As documented in Section 4.5.1.2, Sites 6, 10, 16, 18, and 19 are sensitive for prehistoric- and/or historic-era archaeological resources. While Site 8 has a low sensitivity for either prehistoric- or historic-era archaeological resources, the potential remains for archaeological resources to be encountered during ground-disturbing activities associated with future development at Site 8 and Sites 6, 10, 16, 18, and 19.

Mitigation Measures:

MM CUL-2.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 to comply with the following measures:
a. If evidence of an archaeological site or other suspected cultural resource as defined by CEQA Guideline Section 15064.5, including darkened soil representing past human activity (“midden”), that could conceal material remains (e.g., worked stone, worked bone, fired clay vessels, faunal bone, hearths, storage pits, or burials) is discovered during construction related earth-moving activities, all ground-disturbing activity within 100 feet of the resources shall be halted and the City Planning Manager shall be notified. The project sponsor shall hire a qualified archaeologist to conduct a field investigation. The City’s Planning Manager shall consult with the archaeologist to assess the significance of the find. Impacts to any significant resources shall be mitigated to a less-than-significant level through data recovery or other methods determined adequate by a DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 97 Initial Study
City of San Bruno December 2022
qualified archaeologist and that are consistent with the Secretary of the Interior’s Standards for Archaeological documentation. Any identified cultural resources shall be recorded on the appropriate DPR 523 (A-J) form and filed with the NWIC.
b. Prior to the initiation of any site preparation and/or the start of construction, the project sponsor shall ensure that all construction workers receive training overseen by a qualified professional archaeologist who is experienced in teaching non-specialists, to ensure that contractors can recognize archaeological resources in the event that any are discovered during construction.

With implementation of MM CUL-2.1, any undiscovered subsurface archaeological resources encountered during construction would be identified, evaluated and appropriately treated in accordance with the recommendations of a qualified archaeologist. Accordingly, the buildout of Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 would not cause a substantial adverse change in the significance of an archaeological resource. (Less than Significant Impact with Mitigation Incorporated)
Transit Corridors Plan Area Sites
As discussed in Section 4.5.1.2, the TCP EIR concluded that the TCP area (which encompasses Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 22 and 23) is sensitive for prehistoricand historic-era archaeological resources. Future development at the Housing Opportunity Sites within the TCP area would be required to adhere to the following mitigation measure imposed by the TCP EIR.
• TCP Mitigation Measure 7-1: If prehistoric or historic-period archaeological resources are encountered during future grading or excavation in the Transit Corridors Area, work shall avoid altering the materials and their context until a qualified professional has evaluated, recorded and determined appropriate treatment of the resource, in consultation with the City.

Project personnel shall not collect cultural resources. Cultural resources shall be recorded on DPR 523 historic resource recordation forms. If it is determined that the proposed development could damage a unique archaeological resource, mitigation shall be implemented in accordance with Public Resources Code Section 21083.2 and Section 15126.4 of the CEQA Guidelines, with a preference for preservation in place.

The Housing Element Update would not change any of the development assumptions of the TCP EIR, which concluded that implementation of the above mitigation measures would reduce potential impacts to prehistoric- and historic-era archaeological resources to a less than significant level.

Accordingly, buildout of the Housing Opportunity Sites within the TCP area would have a less than significant impact on archaeological resources with adherence to TCP Mitigation Measure 7-1 as required by the TCP EIR. (Less than Significant Impact with Mitigation Incorporated) Bayhill Specific Plan Area Sites
Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Future development within the Bayhill Specific Plan area would be required to comply with the General DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 98 Initial Study
City of San Bruno December 2022
Plan and Bayhill Specific Plan policies identified in Section 4.5.1.1, specifically, General Plan Policy ERC-39 and Bayhill Specific Plan policies 6-27, 6-28, and 6-29. Prior to any project-related ground disturbance, Policies 6-27 and 6-28 require construction contractors to be trained in recognizing archaeological and tribal cultural resources, and preparation of an AMP by a qualified professional archaeologist prior to any project-related ground disturbance that outlines areas of archaeological sensitivity, if any, and includes protocol to follow if unanticipated archaeological or tribal cultural resources are encountered. Policy 6-29 requires all work to stop immediately if archaeological or tribal cultural resources are discovered during construction, and Policy ERC-39 requires areas found to contain significant indigenous artifacts be examined by a qualified archaeologist for recommendations concerning protection and preservation. Adherence with the aforementioned policies would ensure that any undiscovered subsurface archaeological resources encountered during construction would be identified, evaluated and appropriately treated in accordance with the recommendations of a qualified archaeologist. Accordingly, the buildout of Housing Opportunity Sites 3 and 13 would not cause a substantial adverse change in the significance of an archaeological resource. (Less than Significant Impact)
As discussed in Section 4.5.1.2, the Cultural Resources Sensitivity Report concluded that Site 14 has a low sensitivity for prehistoric-era archaeological resources, but is sensitive for historic-era archaeological resources associated with the Tanforan Racetrack and Tanforan Assembly Center in the areas shown on Figure 4.5-1. Ground-disturbing activities associated with future development of Site 14 have the potential to encounter and destroy undiscovered subsurface prehistoric and historicera archaeological resources, if present on site.

Mitigation Measures:

MM CUL-2.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. As part of the future project-level CEQA analysis of any discretionary permits that would allow ground-disturbing activities (e.g., grading, trenching, excavation, etc.) in the archaeological sensitive areas shown on Figure 4.5-1, exploratory trenching shall be conducted by a qualified archaeologist trained in both local prehistoric and historical archaeology within the proposed area of effect to determine if prehistoric- or historicera archaeological resources are present. Explorations shall consist of at least one mechanically dug trench with excavation depths commensurate with the depth of proposed ground-disturbing activities. If any archaeological resources are exposed, these should be briefly documented, tarped for protection, and left in place. The results of the exploratory trenching shall be submitted to the Director of Community and Economic Development or the Director’s designee. If it is determined by the project archaeologist that the proposed activities could damage an archaeological resource or that indications of other suspected archaeological resources are present (i.e., darkened soil “midden” representing past human activity), an Archaeological Resources Treatment Plan shall be prepared as described in MM CUL-2.1b below.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 99 Initial Study
City of San Bruno December 2022
b. If recommended by the project archaeologist, an Archaeological Resources Treatment Plan shall be prepared by the project archaeologist that contains, at minimum:
• Identification of the scope of work and range of subsurface effects (including location map and development plan), including requirements for preliminary field investigations.
• Description of the environmental setting (past and present) and the historic/prehistoric background of the parcel (potential range of what might be found).
• Monitoring schedules and individuals
• Development of research questions and goals to be addressed by the investigation (what is significant vs. what is redundant information).
• Detailed field strategy to record, recover, or avoid the finds and address research goals.
• Analytical methods.
• Report structure and outline of document contents.
• Disposition of the artifacts.
• Security approaches or protocols for finds.
• Appendices: all site records, correspondence, and consultation with Native Americans, etc.

Implementation of the treatment plan by the project archaeologist shall be required prior to the issuance of any permits related to ground-disturbing activities. The treatment plan shall utilize data recovery methods to reduce impacts on subsurface resources. The treatment plan shall be submitted to the Director of Community and Economic Development or the Director’s designee, along with a summary of the outcomes of the treatment plan and all associated documentation and recordation.

MM CUL-2.3: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any discretionary permits that would allow ground-disturbing activities (e.g., grading, trenching, excavation, etc.) within the non-sensitive areas mapped on Figure 4.5-1, the project applicant shall hire a qualified archaeologist to develop a Worker’s Environmental Awareness Program (WEAP) to train the construction crew on the legal requirements for the treatment of cultural resources as well as procedures to follow in the event of a cultural resources discovery. This training program shall be given to the crew before ground disturbing work commences and shall include handouts to be given to new workers.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 100 Initial Study
City of San Bruno December 2022
b. The applicant shall note on all construction plans that require ground disturbing activities that there is a potential for exposing buried cultural resources including prehistoric Native American burials. c. In the event that potentially significant archaeological resources are encountered during ground-disturbing activities occurring at Site 14, all activity within a 50-foot radius of the find shall be stopped, the Director of Community and Economic Development or the Director's designee shall be notified, and the project archaeologist shall examine the find. The project archaeologist shall (1) evaluate the find(s) to determine if they meet the definition of an archaeological resource; and (2) make appropriate recommendations regarding the disposition of such finds prior to issuance of building permits. Recommendations could include collection, recordation, and analysis of any significant cultural materials.

A report of findings documenting any data recovery shall be submitted to the Director of Community and Economic Development or the Director's designee and the Northwest Information Center (if applicable).

Implementation of MM CUL-2.1a would require exploratory trenching to be conducted prior to any future development proposed within the archaeologically sensitive areas shown on Figure 4.5-1. If any archaeological resources or indications of archaeological resources are identified, MM CUL-2.1b would require preparation of an Archaeological Resources Treatment Plan that would ensure all archaeological resources present in the archaeologically sensitive areas of Site 14 that could be affected by future development are identified, evaluated, and appropriately treated in accordance with the recommendations of a qualified archaeologist and the requirements of CEQA.

Although it is unlikely that undiscovered subsurface archaeological resources are present in the nonsensitive areas of Site 14 shown on Figure 4.5-1, implementation of MM CUL-2.2a and 2.2b would ensure workers are alerted to the potential presence of archaeological resources and trained to follow the proper procedures in the event of a discovery. MM CUL-2.2c would ensure that any resources encountered are identified, evaluated, and appropriately treated in accordance with the recommendations of a qualified archaeologist and the requirements of CEQA.

For the reasons outlined above, implementation of the Housing Element as amended by MM CUL2.1 and MM CUL-2.2 would ensure that future residential development at Site 14 does not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5.

Impact CUL-3: The project would not disturb any human remains, including those interred outside of dedicated cemeteries. (Less than Significant Impact with Mitigation Incorporated)
Housing Opportunity Sites 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16, 17, 20, 22 and 23 Human graves are most often associated with prehistoric occupation sites. As discussed in Section

4.5.1.2 Existing Conditions, no known prehistoric sites are present at any of the Housing Opportunity Sites. However, the potential exists for human remains, including Native American remains, to be DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 101 Initial Study
City of San Bruno December 2022
unearthed during future development under the Housing Element Update, specifically during grounddisturbing activities (e.g., grading, trenching, excavation, etc.).

Mitigation Measures:

MM CUL-3.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16, 17, 20, 22 and 23 to comply with the following measures:
a. If human remains are discovered at any project construction site during any phase of construction, all ground-disturbing activity within 100 feet of the resources shall be halted and the City’s Planning Manager and the San Mateo County Coroner shall be notified immediately, according to Section 5097.98 of the State Public Resources Code and Section 7050.5 of California’s Health and Safety Code. If the remains are determined by the County coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. The project sponsor shall also retain a professional archaeologist with Native American burial experience to conduct a field investigation of the specific site and consult with the Most Likely Descendant, if any, identified by the NAHC. As necessary, the archaeologist may provide professional assistance to the Most Likely Descendant, including the excavation and removal of the human remains.

The City of San Bruno shall be responsible for approval of recommended mitigation as it deems appropriate, taking account of the provisions of State law, as set forth in CEQA Guidelines section 15064.5(e) and Public Resources Code section 5097.98. The project sponsor shall implement approved mitigation, to be verified by the City of San Bruno, before the resumption of ground-disturbing activities within 100 feet of where the remains were discovered.

Implementation of MM CUL-3.1 would ensure that any human remains encountered during future development are subject to timely identification, analysis, documentation, and removal in accordance with state and local laws. Therefore, implementation of the Housing Element as amended by MM CUL-3.1 would ensure that future residential development at Sites 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16, 17, 20, 22 and 23 would not disturb any human remains.

Bayhill Specific Plan Area Sites
Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Future development within the Bayhill Specific Plan area would be required to comply with the Specific Plan policies identified in Section 4.5.1.1, specifically, Policy 6-30. If human remains are encountered during construction, Policy 6-30 requires construction activities in the area of discovery and surrounding vicinity to cease until the county coroner has been notified and all applicable legal requirements have been implemented. If human remains of Native American origin are discovered during ground-disturbing activities, construction contractors are required to comply with state laws DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 102 Initial Study
City of San Bruno December 2022
regarding the disposition of Native American burials, which fall within the jurisdiction of the Native American Heritage Commission as required by Public Resources Code Section 5097. Adherence with Policy 6-30 as required by the Bayhill Specific Plan would ensure that any human remains encountered during future development at Sites 3 and 13 are subject to timely identification, analysis, documentation, and removal in accordance with state and local laws. Accordingly, buildout of Sites 3 and 13 would not disturb human remains. (Less than Significant Impact).

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 103 Initial Study
City of San Bruno December 2022

4.6 ENERGY
The following discussion is based, in part, on an Air Quality and Greenhouse Gas Assessment prepared for the Housing Element Update by Illingworth & Rodkin, Inc. A copy of this report, dated September 2022, is attached to this Initial Study as Appendix A.

4.6.1 Environmental Setting

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

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

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

California Building Standards Code
The California Building Energy Efficiency Standards (California Energy Code) is under Title 24, Part 6 and is overseen by the California Energy Commission (CEC). This code includes design requirements to conserve energy in new residential and non-residential developments, while being cost effective for homeowners. The Energy Code is enforced and verified by cities during the planning and building permit process. The current energy efficiency standards (2019 Energy Code) replaced the 2016 Energy Code as of January 1,2020.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 104 Initial Study
City of San Bruno December 2022
The California Green Building Standards Code (CALGreen Code) is part of the California Building Standards Code under Title 24, Part 11. The CALGreen Code provides sustainable construction standards that involve planning/design, energy efficiency, water efficiency resource efficiency, and environmental quality. These green building standard codes are mandatory statewide and are applicable to residential and non-residential developments. The most recent CALGreen Code (2019 California Building Standard Code) was effective as of January 1, 2020.

Requirements for electric vehicle (EV) charging infrastructure are set forth in Title 24, Part 11 of the California Code of Regulations and are regularly updated on a 3-year cycle. The CALGreen standards consist of a set of mandatory standards required for new development, as well as two more voluntary standards known as Tier 1 and Tier 2. The CalGreen standards have recently been updated (2022 version) to require deployment of additional EV chargers in various building types, including multifamily residential and nonresidential land uses. They include requirements for both EV capable parking spaces and the installation of Level 2 EV supply equipment for multifamily residential and nonresidential buildings. The 2022 CALGreen standards include requirements for both EV readiness and the actual installation of EV chargers. The 2022 CALGreen standards include both mandatory requirements and more aggressive voluntary Tier 1 and Tier 2 provisions.

Advanced Clean Cars Program
CARB adopted the Advanced Clean Cars program in 2012 in coordination with the EPA and National Highway Traffic Safety Administration. The program combines the control of smogcausing pollutants and GHG emissions into a single coordinated set of requirements for vehicle model years 2015 through 2025. The program promotes development of environmentally superior passenger cars and other vehicles, as well as saving the consumer money through fuel savings.39 Regional and Local
Peninsula Clean Energy 2018 Integrated Resource Plan
Peninsula Clean Energy adopted the 2018 Integrated Resource Plan on December 14, 2017 to provide guidance for serving the electricity needs of the residents and businesses in the County, all while fulfilling regulatory requirements over a 10-year period from 2018-2027. The plan contains the following strategic goals that are relevant to the Housing Element Update:
• Design a diverse power portfolio that is greenhouse gas free:
o 100% GHG free by 2021;
o 100% Renewable Portfolio Standard (RPS)-eligible renewable energy by 2025; o Minimum of 20 MWs of new local power by 2025.
• Stimulate development of new renewable energy projects and clean-tech innovation in San Mateo County and California through Peninsula Clean Energy’s procurement activities • Implement programs to further reduce greenhouse gas emissions by investing in programs such as local clean power production, electric vehicles, energy efficiency, and demand 39 California Air Resources Board. “The Advanced Clean Cars Program.” Accessed October 24, 2022. https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars-program DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 105 Initial Study
City of San Bruno December 2022
response, and partnering effectively with local businesses, schools, and nonprofit organizations
Peninsula Clean Energy meets its renewable energy requirements with a combination of RPS-eligible energy products. According to the 2018 Integrated Resource Plan, Peninsula Clean Energy procured enough renewable energy to meet a 50 percent voluntary target as of 2017. The proportion of Peninsula Clean Energy’s resource mix that is sourced from bundled renewable energy products will significantly increase as Peninsula Clean Energy transitions toward 100 percent renewable energy content in 2025. Based on targeted renewable energy percentages, Peninsula Clean Energy intends to significantly outpace California’s annual RPS procurement mandates throughout the 2018-2027 planning period.

City of San Bruno General Plan
Various policies and actions of the City of San Bruno General Plan have been adopted for the purpose of avoiding or mitigating energy impacts resulting from planned development within the City, including the following:

Policies Description
PFS-62 Develop and implement a Green Building Design Ordinance and design guidelines for climate-oriented site planning, building design, and landscape design to promote energy efficiency. These standards may include, but are not limited to, the following:
• Require the use of Energy Star ® appliances and equipment in new residential and commercial development, and new City facilities;
• Require all new City facilities and new residential development to incorporate green building methods meeting the equivalent of LEED Certified “Silver” rating or better; and
• Require all new residential development to be pre-wired for optional photovoltaic roof energy systems and/or solar water heating.

The Ordinance will allow variances to site or building requirements—building setbacks, lot coverage, and building height—that will enable use of alternative energy sources, such as passive heating and/or cooling.

PFS-63 Require that all new development complies with California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6).

PFS-65 Require new development to incorporate passive heating and natural lighting strategies if feasible and practical. These strategies should include, but are not limited to, the following:
• Using building orientation, mass and form, including façade, roof, and choice of building materials, color, type of glazing, and insulation to minimize heat loss during winter months and heat gain during the summer months;
• Designing building openings to regulate internal climate and maximize natural lighting, while keeping glare to a minimum; and
• Reducing heat-island effect of large concrete roofs and parking surfaces.

PFS-66 Enforce landscape requirements that facilitate efficient energy use or conservation, such as drought-resistant landscaping and/or deciduous trees along southern exposures.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 106 Initial Study
City of San Bruno December 2022
Policies Description
PFS-70 Facilitate environmentally sensitive construction practices by:
• Restricting use of chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and halons in mechanical equipment;
• Promoting use of products that are durable and allow efficient end-of-life disposal (e.g. reusable, recyclable, biodegradable);
• Promoting the purchase of locally or regionally available materials; and • Promoting the use of cost-effective design and construction strategies that reduce resource and environmental impacts.

PFS-71 Convert street lights and traffic signals to LED and other more efficient technologies as they become available.

Transit Corridors Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP includes development standards and design guidelines that govern future private development actions in the TCP area, including the following which pertain to energy.

Policies Description
A10-11 Encourage the installation of solar panels on roof-decks of parking structures, both as shading devices for vehicles and as a sustainable energy source.

A10-12 Provide preferred parking for alternative energy vehicles and charging stations for electric powered vehicles. Provide dedicated parking for car-share vehicles.

A14-1 Orient courtyards, open spaces and façades to the south to maximize heat gain and natural sunlight
A14-2 Minimize building heights on the north side of developments to reduce shadows.

A14-8 Provide operable windows wherever possible to allow passive ventilation, heating and cooling.

A15-5 Encourage solar panels on building rooftops and/or façades to supplement the energy source.

A15-8 Encourage the use of “cool and/or green” roofs to reduce heat island effect and thereby reduce the heat transferred into the building below. Cool roofs consist of materials that effectively reflect the sun’s energy. Alternatively, green roofs achieve the same purpose and include vegetation to harvest rainwater for reuse and diminish runoff.

Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Six of the Bayhill Specific Plan includes mandatory “Environmental Quality” policies, including the following which pertain to energy.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 107 Initial Study
City of San Bruno December 2022
Policy 3-25
Policy 3-25 requires projects to integrate solar panels, natural light and ventilation, cool/green roofs and walls, sustainable building materials, and building placement and orientation that allows for natural cooling and passive solar heating into building designs.

Policy 6-15
Policy 6-15 requires projects to meet LEED Silver Certification requirements or equivalent, employ electric space and water heating appliances, and cover 30 percent of their roofs with solar panels.

Policy 6-17
Policy 6-17 encourages projects to participate in local government- and utility-run programs to promote energy efficiency and reduce GHG emissions.

4.6.1.2 Existing Conditions
Total energy usage in California was approximately 6,957 trillion British thermal units (Btu) in the year 2020, the most recent year for which this data was available.40 Out of the 50 states, California is ranked second in total energy consumption and 49th in energy consumption per capita. The breakdown by sector was approximately 21 percent (1,508 trillion Btu) for residential uses, 19.6 percent (1,358 trillion Btu) for commercial uses, 24.6 percent (1,701 trillion Btu) for industrial uses, and 34 percent (2,356 trillion Btu) for transportation.41 This energy is primarily supplied in the form of natural gas, petroleum, nuclear electric power, and hydroelectric power which originate from a diverse set of international, national, state and regional sources.

Electricity
Electricity in San Mateo County in 2020 was consumed primarily by the non-residential sector (60 percent), with the residential sector consuming 40 percent. In 2020, a total of approximately 4,166 gigawatt hours (GWh) of electricity was consumed in San Mateo County.42 Peninsula Clean Energy is a public and locally controlled electricity provider for the County of San Mateo. Electricity provided by Peninsula Clean Energy is delivered through PG&E transmission lines. Commercial and residential customers in San Mateo County are included in the Peninsula Clean Energy service area and can choose to have 50 to 100 percent of their electricity supplied from carbon-free and renewable sources. Customers are automatically enrolled in the ECOplus plan, which generates its electricity from 100 percent carbon-free sources, with at least 50 percent from renewable sources. Customers have the option to enroll in the ECO100 plan, which generates its electricity from 100 percent carbon-free, renewable sources.43 40 United States Energy Information Administration. “California Energy Consumption by End-Use-Sector, 2020.” Accessed October 24, 2022. https://www.eia.gov/state/?sid=CA#tabs-2. 41 Ibid. 42 California Energy Commission. Energy Consumption Data Management System. “Electricity Consumption by County.” Accessed October 24, 2022. http://ecdms.energy.ca.gov/elecbycounty.aspx. 43 Peninsula Clean Energy. “Frequently Asked Questions.” Accessed October 24, 2022. https://www.peninsulacleanenergy.com/faq/.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 108 Initial Study
City of San Bruno December 2022
Natural Gas
PG&E provides natural gas services within San Mateo. In 2020, approximately two percent of California’s natural gas supply came from in-state production, while the remaining supply was imported from other western states and Canada.44 In 2020 California used 2,144 trillion Btu of natural gas.45 In 2020, San Mateo County used less than one percent of the state’s total consumption of natural gas (total of 200 million therms of natural gas).46 Fuel for Motor Vehicles
In 2019, 15.4 billion gallons of gasoline were sold in California.47 The average fuel economy for light-duty vehicles (autos, pickups, vans, and sport utility vehicles) in the United States has steadily increased from about 13.1 miles per gallon (mpg) in the mid-1970s to 25.4 mpg in 2020.48 Federal fuel economy standards have changed substantially since the Energy Independence and Security Act was passed in 2007. That standard, which originally mandated a national fuel economy standard of 35 miles per gallon by the year 2020, was updated in April 2022 to require all cars and light duty trucks achieve an overall industry average fuel economy of 49 mpg by model year 2026.49,50

4.6.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project construction
or operation?
2) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?
44 California Gas and Electric Utilities. 2020 California Gas Report. Accessed July 20, 2022. https://www.socalgas.com/sites/default/files/2020-
10/2020_California_Gas_Report_Joint_Utility_Biennial_Comprehensive_Filing.pdf. 45 United States Energy Information Administration. “California Energy Consumption Estimate, 2020.” Accessed July 20, 2022. https://www.eia.gov/state/?sid=CA#tabs-2. 46 California Energy Commission. “Natural Gas Consumption by County.” Accessed July 20, 2022. http://ecdms.energy.ca.gov/gasbycounty.aspx. 47 California Department of Tax and Fee Administration. “Net Taxable Gasoline Gallons.” Accessed July 20, 2022. https://www.cdtfa.ca.gov/dataportal/dataset.htm?url=VehicleTaxableFuelDist. 48 United States Environmental Protection Agency. The 2021 EPA Automotive Trends Report: Greenhouse Gas Emissions, Fuel Economy, and Technology since 1975. November 2021. 49 United States Environmental Protection Agency. “Summary of the Energy Independence and Security Act.” Accessed July 20, 2022. https://www.epa.gov/laws-regulations/summary-energy-independence-and-security-act . 50 United States Department of Transportation. “USDOT Announces New Vehicle Fuel Economy Standards for Model Year 2024-2026.” Accessed July 20, 2022. https://www.nhtsa.gov/press-releases/usdot-announces-newvehicle-fuel-economy-standards-model-year-2024-2026 □ □ □
□ □ □
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 109 Initial Study
City of San Bruno December 2022
Impact EN-1: The project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. (Less than Significant Impact) Construction-Related Energy Consumption
Construction associated with future development under the Housing Element Update would result in the temporary usage and consumption of electricity to power electric construction equipment, mobile offices, or water delivered to construction sites; gasoline and diesel fuel used for transportation of workers and haul trucks to and from construction sites; and fuel used for operation of off-road equipment. Construction-related energy usage and consumption would be dispersed over the course of the 2023-2031 buildout period, and would vary based on the level of activity, length of construction period, specific construction operations, types of equipment, and number of personnel.

Since the timing and intensity of the construction activity required for future development projects under the Housing Element Update is not yet known, energy consumption by future development cannot be quantified.

The overall construction schedule and process is designed to be efficient in order to avoid excess monetary costs. That is, equipment and fuel would not be used wastefully on the project site because of the added expense associated with renting the equipment, maintaining it, and fueling it. Further, the Housing Opportunity Sites are located in urbanized areas in proximity to roadways, construction supplies, and workers, making it more efficient than construction occurring in outlying, undeveloped areas. Therefore, energy consumption by construction of future development would not be wasteful, inefficient, or unnecessary.

In addition to the above, policies and measures have been identified throughout this Initial Study that would ensure that energy consumption during construction is not wasteful, inefficient, or unnecessary. General Plan Policy ERC-26 and MM AIR-3.1 would require equipment to be shut off when not in use or reduce idle times to five minutes at maximum. The Bayhill Specific Plan includes Mitigation Measure AQ-3, which requires 50-hp plus construction equipment with a projected operation time of 20 hours or more to use renewable diesel; and Mitigation Measure GHG-1, which requires 15 percent of the construction fleet to be alternatively fueled; Mitigation Measure NOI-1, which prohibits idling of construction equipment at night. For these reasons, construction of future development under the Housing Element Update would not be wasteful, inefficient, or unnecessary. (Less than Significant Impact)
Operation-Related Energy Consumption
For purposes of this analysis, buildout of the Housing Opportunity Sites at the densities assumed by the Housing Element Update is anticipated to result in the construction of six single-family residences, 967 low-rise apartment units, and 1,735 mid-rise apartment units.51 Once constructed, 51 At the time of analysis, the technical studies prepared for the Housing Element Update assumed buildout would result in six single-family residences, 967 low-rise apartment units, and 1,735 mid-rise apartment units. The City now anticipates that buildout of the Housing Element Update would result in 138 single-family detached, 836 lowrise apartment, and 1,735 mid-rise apartment units, which corresponds with an additional 363 daily vehicle trips.

This represents an increase of approximately two percent, which the Air Quality, Greenhouse Gas Emissions, Noise, DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 110 Initial Study
City of San Bruno December 2022
gasoline would be consumed during vehicle trips by future residents, which is anticipated to be primarily light-duty vehicles. Electricity would be consumed by future development in order to power buildings. Consistent with MM GHG-1.2 (refer to Impact GHG-1 in Section 4.8.1.2 Greenhouse Gas Emissions), natural gas infrastructure and appliances would be prohibited in future residential development at the Housing Opportunity Sites, and therefore the natural gas consumption assumed by CalEEMod was converted to electricity.

Without factoring in gasoline and electricity consumed by existing uses, buildout of the Housing Opportunity Sites is conservatively anticipated to result in the annual consumption of 1,198,896 gallons of gasoline and 10,690,376 kWH (equivalent to 10.7 GWh) of electricity.52 In comparison with gasoline consumption statewide (the cumulative area of effect), the project’s gasoline consumption would be less than 1/10000th of a percent.53 Traffic generated by the proposed residential uses would be primarily light-duty vehicles, which are the most efficient from a fuel economy perspective, and an increasingly substantial portion of project-generated traffic would be electric vehicles. In comparison with electricity consumption countywide (the cumulative area of effect), the project’s energy consumption would be less than 1/100th of a percent. Additionally, future development would be constructed in accordance with Part 6 and Part 11 of Title 24, which would reduce the demand for energy resources by incorporating sustainability features that would promote energy efficiency and increase reliance on renewable energy sources. Adherence with policies provided in the General Plan, TCP, and Bayhill Specific Plan and mitigation measures provided in their respective EIRs and this Initial Study to avoid or reduce air pollutant and GHG emissions and reduce consumption of energy resources would further ensure that consumption of electricity would not be wasteful, inefficient, or unnecessary. For these reasons, buildout of the Housing Element Update would not result in the wasteful, inefficient, or unnecessary consumption of energy resources. (Less than Significant Impact)
Impact EN-2: The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant Impact) State and local renewable energy and energy efficiency plans that are applicable to the Housing Element Update are discussed in Section 4.6.1.1. Future development under the Housing Element Update would be subject to current energy efficiency standards set forth in Title 24. In addition, all residents in San Bruno are automatically enrolled in the Peninsula Clean Energy ECOplus plan, which provides customers with electricity that is generated from 50 percent renewable sources and 100 percent carbon-free sources. Additionally, future residential development at the Housing Opportunity Sites would be required to be fully electric (i.e., no consumption of natural gas) by MM GHG-1.2, which would ensure future development is able to take full advantage of the 100 percent renewable or GHG-free electricity generated by Peninsula Clean Energy through implementation of Vibration, and Transportation consultants have confirmed would not change the conclusions presented in this Initial Study and Appendices A, B, and C. Appendix D and the associated water supply analysis is unaffected by this change.
52 Electricity based on projected natural gas and electricity consumption outputs provided in Appendix A. September 14, 2022. Gasoline estimation based conservatively on 2020 average fuel economy (25.4 mpg) and 30,451,950 annual VMT.
53 Gasoline consumption does not factor in the 240 ADUs, since their future location is not reasonably foreseeable, and therefore VMT cannot be estimated.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 111 Initial Study
City of San Bruno December 2022
its 2018 Integrated Resource Plan. For these reasons, implementation of the Housing Element Update would not conflict with a state or local plan for renewable energy or energy efficiency.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 112 Initial Study
City of San Bruno December 2022

4.7 GEOLOGY AND SOILS

4.7.1 Environmental Setting

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

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

California Building Standards Code
The California Building Standards Code (CBC) prescribes standards for constructing safe buildings.

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

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

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 113 Initial Study
City of San Bruno December 2022
Public Resources Code Section 5097.5
Paleontological resources are the fossilized remains of organisms from prehistoric environments found in geologic strata. They range from mammoth and dinosaur bones to impressions of ancient animals and plants, trace remains, and microfossils. These materials are valued for the information they yield about the history of the earth and its past ecological settings. California Public Resources Code Section 5097.5 specifies that unauthorized removal of a paleontological resource is a misdemeanor. Under the CEQA Guidelines, a project would have a significant impact on paleontological resources if it would disturb or destroy a unique paleontological resource or site or unique geologic feature.

Local
City of San Bruno General Plan
Various policies and actions of the City of San Bruno General Plan have been adopted for the purpose of avoiding or mitigating geology and soils impacts resulting from planned development within the City, including the following:

Policies Description
ERC-44 If, prior to grading or construction activity, an area is determined to be sensitive for paleontological resources, retain a qualified paleontologist to recommend appropriate actions. Appropriate action may include avoidance, preservation in place, excavation, documentation, and/or data recovery, and shall always include preparation of a written report documenting the find and describing steps taken to evaluate and protect significant resources.

HS-B Reduce the potential for damage from geologic hazards through appropriate site design and erosion control.

HS-C Reduce the potential for damage from seismic hazards through geotechnical analysis, hazard abatement, emergency preparedness, and recovery planning.

HS-1 Regulate development, including remodeling or structural rehabilitation, to assure adequate mitigation of safety hazards on sites having a history or threat of slope instability, erosion, subsidence, seismic dangers (including those resulting from liquefactions, ground failure, ground rupture), flooding, and/or fire hazards.

HS-2 Review and revise the City’s Building Code, Zoning Ordinance, and Subdivision requirements to safeguard against seismic, geologic, and safety hazards. Mitigation should include:
• Minimal grading and removal of natural vegetation to prevent erosion and slope instability. Cleared slopes should be replanted with vegetation. • Proper drainage control to prevent erosion of the site and affected properties. • Careful siting and structural engineering in unstable areas. • Consideration of flooding and fire hazards in siting and designing new development.

HS-3 Require geotechnical investigation of all sites, except single-family dwellings, proposed for development in areas where geologic conditions or soil types are subject to landslide risk, slippage, erosion, liquefaction, or expansive soils. (Require submission of DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 114 Initial Study
City of San Bruno December 2022
Policies Description
geotechnical investigation and demonstration that the project conforms to all recommended mitigation measures prior to City approval.

HS-4 Prevent soil erosion by retaining and replanting vegetation, and by siting development to minimize grading and land form alteration.

HS-5 Require preparation of a drainage and erosion control plan for land alteration and vegetation removal on sites greater than 10,000 sq. ft. in size.

HS-7 Development in areas subject to seismic hazards, including ground shaking, liquefaction, and seismically-induced landslides (Figure 7-2) will comply with guidelines set forth in the most recent version of the California Division of Mines and Geology Special Publication 117.

HS-9 In accordance with the Alquist-Priolo Special Studies Zones Act, do not permit structures across an active fault (Figure 7-2) or within 50 feet of an active fault, except single-family wood frame dwellings where no other location on a lot is feasible. Require any new development to contract with geotechnical engineers to reduce potential damage from seismic activity.

HS-10 Recommend a geologic report by a qualified geologist for construction or remodeling of all structures, including single-family dwellings, proposed within 100 feet of a historically active or known active fault (Figure 7-2). Geologic reports should recommend minimum setbacks, siting and structural safety standards, to reduce potential seismic hazards. Geologic reports must be filed with the State Geologist by the City within 30 days of receipt.

HS-22 Require that construction-related grading and other activities comply with the Association of Bay Area Governments’ (ABAG) Manual of Standards for Erosion and Sediment Control Measures and with the California Stormwater Quality Association (CASQA), Stormwater Best Management Practice Handbook for Construction.

City of San Bruno Municipal Code
Title 12, Land Use, Article I, Excavation and Grading, of the San Bruno Municipal Code sets forth general provisions, permitting requirements, grading regulations, and specific elements required in requested soil and engineering reports, including:
• An adequate description of the geology of the site;
• Conclusions and recommendations regarding the effect of geologic conditions on the proposed development;
• Opinions and recommendations covering the adequacy of sites to be developed by the proposed grading;
• Data regarding the nature, distribution, strength, and in place relative compaction of existing soils;
• Conclusions and recommendations for grading procedures and design criteria for corrective measures when necessary;
• Ground water conditions;
• Data on erodibility of the soil;
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 115 Initial Study
City of San Bruno December 2022
• Draft specifications for erosion control measures. For purposes of such draft specifications, reference is made to Association of Bay Area Governments Manual for Surface Runoff Control Measures, pages 1-45, through 1-151, inclusive. (Ord. 1369 § 1, 1981; prior code § 9-1.7(a))
Bayhill Specific Plan
Various policies in the Bayhill Specific Plan have been adopted for the purpose of avoiding or mitigating geology and soils impacts resulting from planned development within the Bayhill Specific Plan area, including the following:

Policies Description
3-3 Require Naturalistic Site Grading and Earthwork. Site grading shall create a naturalistic appearance, without dramatic terracing, berming, and other obvious earthwork approaches. Mounding earth shall be used only to accommodate differentials between first floor building elevations and adjacent sidewalk grades, and to accommodate trees and other planting above underground parking garages. 6-31 Require that all applicants proposing development projects involving the development of new foundations for buildings within the Plan Area prepare a site-specific geotechnical exploration as part of the design process for the building. The exploration shall include borings and laboratory soil testing to provide data for preparation of specific recommendations regarding grading, foundation design, and drainage for the proposed development. The geotechnical explorations shall be subject to review and approval by the San Bruno Public Works Department.
6-32 Require that all applicants proposing to undertake excavation, drilling, or pile-driving activities for new buildings within the Plan Area retain a qualified paleontologist prior to the start of any ground-disturbing activities. The paleontologist should be qualified as defined by the Society for Vertebrate Paleontology and experienced in teaching nonspecialists. The qualified paleontologist shall train all construction personnel who are involved with earthmoving activities, including the site superintendent, regarding the possibility of encountering fossils, the appearance and types of fossils that are likely to be seen during construction, and proper notification procedures should fossils be encountered. Procedures to be conveyed to workers include halting construction within 50 feet of any potential fossil find and notifying a qualified paleontologist, who shall evaluate the significance. The qualified paleontologist shall also make periodic visits during earthmoving in high sensitivity sites to verify that workers are following the established procedures
6-33 Require that all applicants undertaking earth moving projects within the Plan Area adequately respond to the discovery of paleontological resources.

4.7.1.2 Existing Conditions
Geology
San Bruno is located within the Coast Ranges geomorphic province formed by the Franciscan, Merced, and Colma assemblages, which are principally composed of marine sedimentary and DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 116 Initial Study
City of San Bruno December 2022
volcanic rocks, as well as deposits of sandstone, claystone, siltstone, gravel, sand, silt, and clay. The eastern portion of the City is former marginal tideland filled in with artificial fill material.

Seismicity
San Bruno is located within the seismically active San Francisco Bay Area region. The faults in this region are capable of generating earthquakes of magnitude 7.0 or higher. Major active faults in the region include the San Andreas (adjacent), the San Gregorio-Hosgri (eight miles southwest), the Hayward (18 miles east) the Calaveras (25 miles east), Concord-Green Valley (30 miles northeast), and Healdsburg-Rodgers Creek (36 miles north).

Soils
According to the General Plan EIR, San Bruno is characterized by three major soil associations: the Sunnyvale-Castro, Elkhorn-Colma, and Sweeney-Mindego. The Sunnyvale-Castro association underlies the eastern side of San Bruno, west of the San Francisco International Airport. These soils occur on nearly level, low portions of the valley and originally developed from fine-textured alluvium. They drain slowly due to clay content and have developed under surface water runoff and high groundwater levels. In general, these soils have dark clay surface layers with calcareous or limecemented subsoils. The Elkhorn-Colma association underlies San Bruno between El Camino Real and I-280. These soils occur on five to 15 percent slopes in areas of San Mateo County. These soils drain well due to sand clay mixtures, and erosion can be a problem on steeper slopes. Soils of the Sweeney-Mindego association occur on slopes ranging from 30 to 70 percent and underlie the upland areas on the western side of San Bruno. These soils developed from igneous rock and can be well drained due to silt-sand-clay mixtures.54
On-Site Geologic Conditions
General Plan and Municipal Code Conformant Sites
Housing Opportunity Site 6
Housing Opportunity Site 6 generally slopes from the south to the north with steeper slopes along the eastern and western boundaries. According to maps prepared by the CGS, the site is not within an Alquist-Priolo Earthquake Fault Zone. The project site is mapped by the CGS within a Liquefaction Landslide Overlay Zone.55 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).
54 City of San Bruno. San Bruno 2025: General Plan Draft Environmental Impact Report. Page 3-158. December 2008.
55 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 19 21
20 7
12 6
9 4
2 8
5 23
22 17
10 18
13 14
3 1
15 11
16 FEET
0 500 1000 2000 10
acres
Sources: Alquist-Priolo Earthquake Fault Zone Map San
Francisco South, Montara Mountain Quads. Pampeyan,
E.H., Geologic Map of the Montara Mountain
Quadrangle, San Mateo County, California, USGS
Miscellaneous Investigation Series, Map I-2390
1:24,000, 1994. Wagner, E.J., Bortungo, E.J., McJunkin, R.D., Geologic Map of San Francisco-San Jose
Quadrangle, California, 1:250,000, 1991.

Fault trace (dashed where concealed
or uncertain
Boundary ofAlquist-Priolo Earthquake
Fault Zone
High to Very High Susceptibility of
Liquefaction
Moderately Expansive Soils
Areas Susceptible to Erosion
Flood Zone
Highly Susceptible to Landslides
Moderately Susceptible to Landslides
City Limits
Bayhill Specific
Plan Boundary
Transit Oriented
Development Overlay
GEOLOGIC AND SEISMIC HAZARDS FIGURE 4.7-1
City2023-2031 Housing Element Update
of San Bruno
117 Initial Study
December 2022
I
I

I '----------I
I
\!
ffi
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 118 Initial Study
City of San Bruno December 2022
Housing Opportunity Site 8
Housing Opportunity Site 8 and the surrounding area is generally flat. According to maps prepared by the CGS, the site is not within an Alquist-Priolo Earthquake Fault Zone or Landslide Hazard Zone.56 The project site is mapped by the CGS within a Liquefaction Zone.57 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).

Housing Opportunity Sites 10 and 16
Housing Opportunity Sites 10 and 16 and the surrounding area is generally flat. According to maps prepared by the CGS, the sites are not within an Alquist-Priolo Earthquake Fault Zone, Landslide Hazard Zone, or Liquefaction Zone.58 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).

Housing Opportunity Site 18
Housing Opportunity Site 18 and the surrounding area is generally flat. According to maps prepared by the CGS, the site is not within an Alquist-Priolo Earthquake Fault Zone or Landslide Hazard Zone.59 The project site is mapped by the CGS within a Liquefaction Zone.60 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).

Housing Opportunity Site 19
Housing Opportunity Site 19 and the surrounding area is generally flat. According to maps prepared by the CGS, the site is not within an Alquist-Priolo Earthquake Fault Zone or Landslide Hazard Zone.61 The project site is mapped by the CGS within a Liquefaction Zone.62 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).

Transit Corridors Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP area is flat and is not subject to landslides. None of the TCP area sites are within an Alquist-Priolo Earthquake Fault Zone.63 The potential San Bruno Fault traverses the center of the Transit Corridors Area in a north-south alignment. There is evidence to suggest that the San Bruno fault may not exist, or at least that it is not as significant as initially proposed.64 Housing Opportunity Sites 1, 4, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are mapped by the 56 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 57 Ibid. 58 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 59 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 60 Ibid. 61 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 62 Ibid. 63 City of San Bruno. San Bruno Transit Corridors Plan Environmental Impact Report. June 2012. 64 Ibid.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 119 Initial Study
City of San Bruno December 2022
CGS within a Liquefaction Zone.65 Expansive soils are likely to be encountered within the Transit Corridors Area given the underlying Colma Formation and the Sunnyvale-Castro soils association.

Bayhill Specific Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. None of the Bayhill Specific Plan sites are within an Alquist-Priolo Earthquake Fault Zone.66 According to maps prepared by CGS, Housing Opportunity Site 3 is located within an Earthquake Fault Zone and Landslide Zone.67 Housing Opportunity Site 13 is located within a Liquefaction Zone.68 According to maps prepared for the General Plan, the sites have moderately expansive soils (refer to Figure 4.7-1).

Historic groundwater elevation within the Bayhill Specific Plan range from approximately 10 to more than 50 feet below ground surface (bgs), varying likely with seasonality, weather conditions, and irrigation.69
Housing Opportunity Site 14
Housing Opportunity Site 14 and the surrounding area is generally flat. According to maps prepared by the CGS, the site is not within an Alquist-Priolo Earthquake Fault Zone or Landslide Hazard Zone.70 The project site is mapped by the CGS within a Liquefaction Zone.71 According to maps prepared for the General Plan, the site has moderately expansive soils (refer to Figure 4.7-1).

Paleontological Resources
As discussed above, the City is divided into three distinct geological areas. The area east of I-280 is underlain by deposits of the Colma Formation, which is Quaternary-aged (about 1 million years old), the area west of I-280 but east of Skyline Boulevard is underlain by deposits of the Merced Formation, which is Pliocene-aged (3 to 11 million years old), and finally, the area west of Skyline Boulevard is underlain by deposits of sheared Franciscan Assemblage sandstone, which are Cretaceous-aged (65 to 136 million years old). All of the Housing Opportunity Sites (with the exception of Site 6) are located on the Colma Formation; Site 6 is located on the Merced Formation.

There are no recorded fossil recovery sites in the City of San Bruno.72 65 Ibid. 66 City of San Bruno. Bayhill Specific Plan including Phase I Development. Final EIR. October 2021. 67 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 68 Ibid. 69 City of San Bruno. Bayhill Specific Plan including Phase I Development. Final EIR. October 2021. 70 California Geological Survey. California Earthquake Hazards Zone Application (EQ ZAPP). Accessed August 12, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/ 71 Ibid. 72 Macrostrat. “Geologic Map”. Accessed October 22, 2022. https://macrostrat.org/map/layers#x=- 122.4&y=37.608&z=11.72&show=fossils
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 120 Initial Study
City of San Bruno December 2022

4.7.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Directly or indirectly cause potential
substantial adverse effects, including the risk
of loss, injury, or death involving:
- Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the area
or based on other substantial evidence of a
known fault (refer to Division of Mines
and Geology Special Publication 42)?
- Strong seismic ground shaking?
- Seismic-related ground failure, including
liquefaction?
- Landslides?
2) Result in substantial soil erosion or the loss of
topsoil?
3) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse?
4) Be located on expansive soil, as defined in the
current California Building Code, creating
substantial direct or indirect risks to life or
property?
5) Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems where sewers are
not available for the disposal of wastewater?
6) Directly or indirectly destroy a unique
paleontological resource or site or unique
geological feature?
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
~
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 121 Initial Study
City of San Bruno December 2022
Impact GEO-1: The project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic-related ground failure, including liquefaction; or landslides. (Less than Significant Impact)
Fault Rupture
As discussed in Section 4.7.1.2, none of the Housing Opportunity Sites are within an Alquist-Priolo Earthquake Fault Zone. While existing faults are located in the region, Housing Opportunity Sites are outside of the fault zone for any regional fault systems, and loss, injury, or death from fault ruptures would not occur on the sites. Per General Plan policy HS-3, residential development on the Housing Opportunity Sites would be supported by geotechnical investigations of all sites, except single-family dwellings, proposed for development in areas where geologic conditions or soil types are subject to landslide risk, slippage, erosion, liquefaction, or expansive soils. Residential developments would be required to submit a geotechnical investigation and demonstrate that the project conforms to all recommended mitigation measures prior to City approval. (Less than Significant Impact) Ground Shaking
All of the Housing Opportunity Sites are located within the seismically active San Francisco Bay region. The faults in this region can generate earthquakes of magnitude 7.0 or higher. During an earthquake, very strong ground shaking could occur. In accordance with the CBC, City’s General Plan, and Municipal Code, future redevelopment of the Housing Opportunity Sites would be built using standard engineering and seismic safety design techniques, in accordance with the CBC, as well as applicable Building and Fire Codes adopted by the City of San Bruno to avoid or minimize potential damage from seismic shaking. Conformity with the aforementioned regulations would ensure less than significant impacts from seismically-induced ground shaking. (Less than Significant Impact)
Ground Failure
Soil liquefaction can be defined as ground failure or loss of strength that causes otherwise solid soil to take on the characteristics of a liquid. This phenomenon is triggered by earthquake or ground shaking that causes saturated or partially saturated soils to lose strength, potentially resulting in the soil’s inability to support structures. Soils most susceptible to liquefaction are loose, non-cohesive soils that are saturated and are bedded with poor drainage, such as sand and silt layers bedded with a cohesive cap. Lateral spreading typically occurs as a form of horizontal displacement of relatively flat-lying soil toward an open or “free” face such as an open body of water, channel, or excavation.

This movement is often associated with liquefaction and commonly occurs on gentle slopes in seismically active regions. Lateral spread presents a significant hazard to the integrity of buildings and other structures.

Housing Opportunity Sites 1, 4, 6, 7, 8, 9, 11, 12, 13, 14, 15, 17, 18, 19, 20, 21, 22, and 23 are mapped by the CGS within Liquefaction and/or Landslide Hazard Zones. Conformance with the DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 122 Initial Study
City of San Bruno December 2022
CBC, the City’s General Plan policies and Municipal Code requirements, and the recommendations of a site-specific geotechnical report (of which preparation and compliance with is required by the CBC and the General Plan Policy HS-3) would reduce the risk of seismically-induced liquefaction, lateral spreading, and landsliding at the Housing Opportunity Sites to a less than significant level. (Less than Significant Impact)
Impact GEO-2: The project would not result in substantial soil erosion or the loss of topsoil. (Less than Significant Impact)
Ground disturbance during buildout of the Housing Opportunity Sites is expected to occur during demolition, grading, site preparation, and construction activities. These activities could increase the exposure of on-site soils to wind and water erosion. The San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit (MRP), urban runoff policies, and the Municipal Code are the primary means of enforcing erosion control measures through the grading and building permit process. In accordance with the CBC and City’s General Plan and Municipal Code (refer to Section 4.7.1.1), future development under the Housing Element Update would be required to submit a site-specific geotechnical report, which would include erosion control measures.

In addition, future development under the Housing Element Update would prepare a Storm Water Pollution Prevention Plan (SWPPP) which would formally document sediment and erosion control measures to be implemented during construction in compliance with the NPDES General Permit for Construction Activities. Future development would reduce post-construction soil erosion by managing stormwater runoff in compliance with the MRP. With adherence to the policies and regulations outlined in Section 4.10, Hydrology and Water Quality, the Housing Element Update would not substantially increase soil erosion on-site or contribute to the loss of topsoil.

Impact GEO-3: The project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. (Less than Significant Impact)
As discussed under Impact GEO-1, multiple Housing Opportunity Sites are located within a Liquefaction and/or Landslide Hazard Zone; expansive soils may also be present at the Housing Opportunity Sites. By conforming with the applicable regulations and the recommendations of the site-specific geotechnical report (refer to Impact GEO-1), future development under the Housing Element Update would not result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 123 Initial Study
City of San Bruno December 2022
Impact GEO-4: The project would not be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property. (Less than Significant Impact)
Expansive soils possess a “shrink-swell” characteristic. Shrink-swell is the cyclic change in volume (expansion and contraction) that occurs in fine-grained clay sediments from the process of wetting and drying. Structural damage may result over a long period of time, usually the result of inadequate soil and foundation engineering or the placement of structures directly on expansive soils. Although expansive soils can be a hazard, it is generally mitigated through adherence with the standard engineering and building practices and techniques specified in the CBC as well as the applicable elements of City building and fire codes. The City of San Bruno’s Municipal Code, Chapter 12.12 Soils and Engineering Geology Report, requires that a geotechnical investigation complete with design and construction recommendations be approved prior to City approval of the project.

Conformance with the City’s Municipal Code would ensure that impacts resulting from expansive soils present at the Housing Opportunity Sites are reduced to a less than significant level.

Impact GEO-5: The project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. (No Impact)
All of the Housing Opportunity Sites are located in developed areas of San Bruno where sewers are available to dispose of wastewater. Future development under the Housing Element Update would not need to support septic tanks or alternative wastewater disposal systems.

Impact GEO-6: The project would not directly or indirectly destroy a unique paleontological resource or site or unique geological feature. (Less than Significant Impact) Grading and excavation during construction of future development under the Housing Element Update could however result in significant impacts, if any unknown unique paleontological resources were discovered. As discussed above, preparation of a site-specific geotechnical investigation is required by the CBC and the City’s General Plan and Municipal Code (refer to Section 4.7.1.1) prior to issuance of any permits allowing ground-disturbing activities that could encounter paleontological resources. Sites determined to be paleontologically sensitive would be required by General Plan Policy ERC-44, to retain a qualified paleontologist to recommend appropriate actions. Appropriate action may include avoidance, preservation in place, excavation, documentation, and/or data recovery, and shall include preparation of a written report documenting the find and describing steps taken to evaluate and protect significant resources. With adherence to state and local regulations, future development under the Housing Element Update would identify and preserve any undiscovered paleontological resources encountered during construction, and ensure that impacts to paleontological resources would be less than significant.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 124 Initial Study
City of San Bruno December 2022

4.8 GREENHOUSE GAS EMISSIONS
The following discussion is based, in part, on an Air Quality and Greenhouse Gas Assessment prepared for the Housing Element Update by Illingworth & Rodkin, Inc. A copy of this report, dated September 2022, is attached to this Initial Study as Appendix A.

4.8.1 Environmental Setting

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

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

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

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

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

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 125 Initial Study
City of San Bruno December 2022

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

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

CARB is now in the process of updating the Scoping Plan to assess the state’s progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The Proposed 2022 Scoping Plan Update focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities. A draft of this scoping plan was released on May 10, 2022.

Executive Order B-55-18
In 2018, a new statewide goal was established to achieve carbon neutrality as soon as possible, but no later than 2045, and to maintain net negative emissions thereafter. CARB and other relevant state agencies are tasked with establishing sequestration targets and create policies/programs that would meet this goal. The Draft 2022 Scoping Plan Update addresses Executive Order (EO) B-55-18 and would cost-effectively achieve carbon-neutrality by 2045 or earlier.

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

Consistent with the requirements of SB 375, the Metropolitan Transportation Commission (MTC) partnered with the Association of Bay Area Governments (ABAG), BAAQMD, and the Bay Conservation and Development Commission to prepare the region’s Sustainable Communities Strategy (SCS) as part of the Regional Transportation Plan process. The SCS is referred to as Plan Bay Area 2050. Plan Bay Area 2050 establishes a course for reducing per capita GHG emissions DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 126 Initial Study
City of San Bruno December 2022
through the promotion of compact, high-density, mixed-use neighborhoods near transit, particularly within identified Priority Development Areas (PDAs).

California Building Standards Code
The California Building Energy Efficiency Standards (California Energy Code) is under Title 24, Part 6 and is overseen by the California Energy Commission (CEC). This code includes design requirements to conserve energy in new residential and non-residential developments, while being cost effective for homeowners. This Energy Code is enforced and verified by cities during the planning and building permit process. The current energy efficiency standards (2019 Energy Code) replaced the 2016 Energy Code as of January 1,2020.

The California Green Building Standards Code (CALGreen Code) is part of the California Building Standards Code under Title 24, Part 11. The CALGreen Code provides sustainable construction standards that involve planning/design, energy efficiency, water efficiency resource efficiency, and environmental quality. These green building standard codes are mandatory statewide and are applicable to residential and non-residential developments. The most recent CALGreen Code (2019 California Building Standard Code) was effective as of January 1, 2020.

Requirements for electric vehicle (EV) charging infrastructure are set forth in Title 24 of the California Code of Regulations and are regularly updated on a 3-year cycle. The CALGreen standards consist of a set of mandatory standards required for new development, as well as two more voluntary standards known as Tier 1 and Tier 2. The CalGreen standards have recently been updated (2022 version) to require deployment of additional EV chargers in various building types, including multifamily residential and nonresidential land uses. They include requirements for both EV capable parking spaces and the installation of Level 2 EV supply equipment for multifamily residential and nonresidential buildings. The 2022 CALGreen standards include requirements for both EV readiness and the actual installation of EV chargers. The 2022 CALGreen standards include both mandatory requirements and more aggressive voluntary Tier 1 and Tier 2 provisions.

Regional and Local
Bay Area Air Quality Management District
BAAQMD is the regional government agency that regulates sources of air pollution within the nine San Francisco Bay Area counties. The BAAQMD regulates GHG emissions through the following plans, programs, and guidelines.
2017 Clean Air Plan
To protect the climate, the 2017 CAP (prepared by BAAQMD) includes control measures designed to reduce emissions of methane and other super-GHGs that are potent climate pollutants in the nearterm, and to decrease emissions of carbon dioxide by reducing fossil fuel combustion.

CEQA Air Quality Guidelines
The BAAQMD CEQA Air Quality Guidelines are intended to serve as a guide for those who prepare or evaluate air quality impact analyses for projects and plans in the San Francisco Bay Area. The jurisdictions in the San Francisco Bay Area Air Basin utilize the thresholds and methodology for DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 127 Initial Study
City of San Bruno December 2022
assessing GHG impacts developed by BAAQMD within the CEQA Air Quality Guidelines. The guidelines include information on legal requirements, BAAQMD rules, methods of analyzing impacts, and recommended mitigation measures.

CEQA Thresholds of Significance for Climate Impacts
The BAAQMD CEQA Air Quality Guidelines (see discussion above) also included thresholds of significance for greenhouse gas emissions. For projects that are not located within a jurisdiction with an adopted GHG Reduction Strategy or projects that would be inconsistent with an adopted GHG Reduction Strategy, the Guidelines recommended a GHG emissions threshold of 1,100 metric tons (MT) or 4.6 MT per year per capita. These thresholds were developed based on meeting the 2020 GHG target of reducing statewide GHG emissions 80 percent below 1990 levels as set forth in the scoping plan that addressed AB 32. Interpolation of the 2020 GHG target through the year 2031 (when buildout of the Housing Element Update would be complete) results in a GHG emissions significance threshold of 2.7 MTCO2e per year per capita.

On April 20, 2022, BAAQMD adopted new qualitative thresholds for assessing the impacts that projects and plans would have on climate change. BAAQMD provided a justification report that described these new qualitative thresholds that are recommended for lead agencies to consider when approving projects or plans through the CEQA process.73 For land use projects, BAAQMD developed plan- and project-level thresholds that evaluate the significance of operational GHG emissions based on its effect on the State’s efforts to meet the identified long-term climate goals. These thresholds are identified in Table 4.8-1 below.

Table 4.8-1: BAAQMD GHG Significance Thresholds
Plan-Level Thresholds
A. Meet the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045; or
B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).

Project-Level Thresholds
A. Projects must include, at a minimum, the following project design elements:

1. Buildings
a. The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).
b. The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b)of the State CEQA Guidelines.

2. Transportation
a. Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan 73 Bay Area Air Quality Management District. CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. April 2022.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 128 Initial Study
City of San Bruno December 2022
(currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts.
b. Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).

City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating greenhouse gas emissions impacts resulting from planned development within the City, including the following:

Policies Description
T-F Provide efficient local transit—such as a shuttle system—to the BART and Caltrain stations to avoid dependence on individual motor vehicles.

ERC-13 Through environmental review, assure that all projects affecting resources of regional concern (e.g., the San Francisco garter snake habitat, water and air quality, the San Francisco Fish and Game Reserve) satisfy regional, State and federal laws.

ERC-25 Maintain and improve air quality by requiring project mitigation, such as Transportation Demand Management (TDM) techniques, where air quality impacts are unavoidable.

ERC-31 Prepare a Greenhouse Gas Emissions Reduction Plan, focusing on feasible actions the City can take to minimize the adverse impacts of Plan implementation on climate change and air quality. The Plan will include but will not be limited to:
• An inventory of all known, or reasonably discoverable, sources of greenhouse gases (GHGs) that currently exist in the City and sources that existed in 1990. In determining what is a source of GHG emissions, the City may rely on the definition of “greenhouse gas emissions source” or “source” as defined in section 38505 of the California Global Warming Solutions Act (“AB 32”) or its governing regulations.

The inventory may include estimates of emissions drawing on available information from State and regional air quality boards, supplemented by information obtained by the City.
• A projected inventory of the new GHGs that can reasonably be expected to be emitted in the year 2025 due to the City’s discretionary land use decisions pursuant to the 2025 General Plan Update, as well as new GHGs emitted by the City’s internal government operations. The projected inventories will include estimates, supported by substantial evidence, of future emissions from planned land use and information from state and regional air quality boards and agencies. • A target for the reduction of those sources of future emissions reasonably attributable to the City’s discretionary land use decisions under the 2025 General Plan and the City’s internal government operations, and feasible GHG emission reduction measures whose purpose shall be to meet this reduction target by regulating those sources of GHG emissions reasonably attributable to the City’s discretionary land use decisions and the City’s internal government operations.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 129 Initial Study
City of San Bruno December 2022
Policies Description
ERC-33 Require all large construction projects to mitigate diesel exhaust emissions through use of alternate fuels and control devices.

Transit Corridors Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. Chapter Seven of the TCP includes the following policies designed to reduce emissions associated with vehicle traffic.

Policies Description
Trans-F Develop and implement a Transportation Demand Management (TDM) Program that reduces the amount of peak period motor vehicle traffic and encourages the use of modes other than the single-occupant vehicle.

Trans B-1 Provide a local circulator shuttle service between the Downtown, BART station, and Caltrain station, with potential stops at the San Francisco International Airport Trans C-2 Provide a network of bicycle priority streets that provide linkages throughout the Plan area. As appropriate, bicycle priority streets should provide traffic-calming measures to limit vehicle travel and speeds.

Trans C-4 Implement a citywide bicycle parking ordinance that specifies bicycle parking, locker, and shower requirements.

Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. In addition to the Bayhill Specific Plan policies designed to reduce air quality impacts (refer to Section 4.3.1.2), Chapter Six of the Bayhill Specific Plan includes mandatory “Environmental Quality Policies”, including the following which pertain to greenhouse gas emissions.

Policy 6-14
Policy 6-14 requires all future development within the Bayhill Specific Plan area to reduce construction-related GHG emissions by implementing the recommended best management practices provided in BAAQMD’s 2017 CEQA Guidelines.

Policy 6-15
Policy 6-15 requires all future development within the Bayhill Specific Plan to achieve LEED Silver Certification or equivalent, use electric space and water heaters, employ solar panels on 30 percent of the roof, and implement recycling and reusable produce use programs.

Policy 6-16
Policy 6-16 requires all future development within the Bayhill Specific Plan that does not comply with Policy 6-15 to purchase GHG mitigation credits equivalent to the GHG emissions reductions that would be provided by implementation of Policy 6-15.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 130 Initial Study
City of San Bruno December 2022
Policy 6-17
Policy 6-17 encourages building owners within the Bayhill Specific Plan to engage in PG&E Energy Efficiency and/or San Mateo County Energy Efficiency programs.

4.8.1.3 Existing Conditions
Unlike emissions of criteria and toxic air pollutants, which have regional and local impacts, emissions of GHGs have a broader, global impact. Global warming is a process whereby GHGs accumulating in the upper atmosphere contribute to an increase in the temperature of the earth and changes in the weather patterns.

The U.S. EPA reported that in 2018, total gross nationwide GHG emissions were 6,676.6 million metric tons (MMT) carbon dioxide equivalent (CO2e).74 These emissions were lower than peak levels of 7,416 MMT that were emitted in 2007. CARB updates the statewide GHG emission inventory on an annual basis where the latest inventory includes 2000 through 2017 emissions.75 In 2017, GHG emissions from statewide emitting activities were 424 MMT. The 2017 emissions have decreased by 14 percent since peak levels in 2004 and are 7 MMT below the 1990 emissions level and the State’s 2020 GHG limit. Per capita GHG emissions in California have dropped from a 2001 peak of 14.1 MT per person to 10.7 MT per person in 2017. The most recent Bay Area emission inventory was computed for the year 2011.76 The Bay Area GHG emission were 87 MMT. As a point of comparison, statewide emissions were about 444 MMT in 2011.

4.8.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Generate greenhouse gas (GHG) emissions,
either directly or indirectly, that may have a
significant impact on the environment?
2) Conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing
the emissions of GHGs?
74 United States Environmental Protection Agency. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990- 2018. Accessed October 24, 2022. https://www.epa.gov/sites/production/files/2020-04/documents/us-ghg-inventory2020-main-text.pdf 75 California Air Resources Board. 2019 Edition, California Greenhouse Gas Emission Inventory: 2000 – 2017.

Accessed October 24, 2022. https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2017/ghg_inventory_trends_00-

17.pdf
76 Bay Area Air Quality Management District. Bay Area Emissions Inventory Summary Report: Greenhouse Gases Base Year 2011. Accessed October 24, 2022. http://www.baaqmd.gov/~/media/files/planning-andresearch/emission-inventory/by2011_ghgsummary.pdf □
□ □
□ □
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 131 Initial Study
City of San Bruno December 2022

4.8.2.1 Approach to Greenhouse Gas Emissions Analysis
The discussion under Impact GHG-1 evaluates whether the GHG emissions generated by buildout of all Housing Opportunity Sites at the densities assumed by the Housing Element Update would exceed a 2.7 MTCO2e per year per capita threshold (refer to the discussion in Section 4.8.1.2 under “CEQA Thresholds of Significance for Climate Impacts”). Additionally, since the City of San Bruno does not have an adopted GHG Reduction Strategy, the discussion under Impact GHG-2 assesses, based on the latest BAAQMD thresholds of significance for climate impacts, whether the project would meet the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045. Consistent with this approach, the discussion under Impact GHG-2 analyzes whether the Housing Element Update as a whole would conflict with AB 32, SB 32, Senate Bill 375 and Plan Bay Area 2050, and the 2017 Clean Air Plan.

Impact GHG-1: The project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant Impact with Mitigation Incorporated)
Construction-Related GHG Emissions
Construction of future development under the Housing Element Update would result in the temporary generation of GHG emissions. Emissions would originate from mobile and stationary construction equipment exhaust and employee and haul truck vehicle exhaust. Construction-related GHG emissions would vary substantially depending on the level of activity, length of the construction period, specific construction operations, types of equipment, and number of personnel.

BAAQMD has not established a quantitative threshold for assessing construction-related GHG emissions. Rather, BAAQMD recommends evaluating whether construction activities would conflict with statewide emission reduction goals and implement feasible Best Management Practices. Mitigation Measure GHG-1.1 below would require future development under the Housing Element Update to comply with these measures; accordingly, construction of future development would not generate GHG emissions that would have a significant impact on the environment. (Less than Significant Impact with Mitigation Incorporated)
Mitigation Measures:

MM GHG-1.1: Prior to approval, the 2023-2031 Housing Element shall be include a policy requiring applicants and their contractors to implement the following measures prior to and during construction:
a. Prior to issuance of any discretionary permits that would allow demolition or construction (grading, excavation, building, etc.) activities at the Housing Opportunity Sites, the applicant shall submit a construction management plan that demonstrates that:
• Alternative fueled (e.g. biodiesel, electric) construction vehicles/equipment shall make up at least 15 percent of the fleet; DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 132 Initial Study
City of San Bruno December 2022
• Buildings shall be constructed with local building materials of at least 10 percent (sourced from within 100 miles of the City limits); and
• Contractors shall recycle and reuse at least 50 percent of construction waste or demolition materials.

Operational-Related GHG Emissions
Buildout of the Housing Opportunity Sites identified in Table 3.2-1 at the densities assumed by the Housing Element Update would result in the construction of 2,709 housing units, including an estimated six single-family residences, 967 low-rise apartment units, and 1,735 mid-rise apartment units.77 GHG emissions generated by buildout of all the Housing Opportunity Sites through the year 2031 was estimated using the California Emissions Estimator Model (CalEEMod) Version 2020.4.0 and compared to the 2.7 MTCO2e per year per capita threshold identified in Sections 4.8.1.2 and

4.8.2.1 above. The methodology, data inputs, assumptions, and results are described further in Appendix A. Table 4.8-2 below shows the annual and per year per capita emissions resulting from operation of future development under the Housing Element Update. 77At the time of analysis, the technical studies prepared for the Housing Element Update assumed buildout would result in six single-family residences, 967 low-rise apartment units, and 1,735 mid-rise apartment units. The City now anticipates that buildout of the Housing Element Update would result in 138 single-family detached, 836 lowrise apartment, and 1,735 mid-rise apartment units, which corresponds with an additional 363 daily vehicle trips.

This represents an increase of approximately two percent in the number of vehicle trips, which the Air Quality, Greenhouse Gas Emissions, Noise, Vibration, and Transportation consultants have confirmed would not change the conclusions presented in this Initial Study and Appendices A, B, and C. Appendix D and the associated water supply analysis are unaffected by this change.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 133 Initial Study
City of San Bruno December 2022
Table 4.8-2: Calculated GHG Emissions of the Housing Element Update Source Category GHG Emissions (MTCO2e)
Area 139
Energy Consumption 1,812
Mobile 7,032
Solid Waste Generation 629
Water Usage 240
Total MTCO2e 9,852
Project Population1 7,1502
Project Per Year Per Capita Emissions 1.38 MTCO2e/year/per capita Significance Threshold 2.7 MTCO2e/year/per capita
Exceed Threshold? No
Source: Illingworth & Rodkin, Inc. San Bruno 2023-2031 Housing Element Update Air Quality & Greenhouse Gas Assessment. September 14, 2022.

Notes:
1 Refer to Section 4.14 Population and Housing of this Initial Study. 2 After completion of the analysis presented in this Initial Study, the number of units assumed at Sites 8 and 21 increased by one unit each, the number of units assumed at Site 22 decreased by one unit, and the number of pipeline units decreased by one unit, resulting in a net increase of one unit and two residents assumed at the Housing Opportunity Sites (2,708 units versus 2,709 units, 7,150 residents versus 7,152 residents) and no increase in the total number of units and residents assumed for the Housing Element Update as a whole (3,618 units and 9,552 residents total). This change would not affect any of the conclusions presented herein this Initial Study.

As shown in Table 4.8-2, GHG emissions generated by buildout of the Housing Element Update would not generate GHG emissions in excess of the interpolated 2031 MTCO2e per year per capita threshold. Further, the emissions reported in Table 4.8-2 are conservative, since they do not take into account the GHG emissions generated by existing uses or the GHG reductions that would be achieved with adherence to the policies and mitigation measures identified in the General Plan, TCP, and Bayhill Specific Plan and their associated EIRs. Therefore, the project would support state goals for reducing emissions to 40 percent below 1990 levels by 2030.

As noted in the 2022 CARB Scoping Plan, approximately 35 percent of California’s GHG reduction potential is from local activities that local governments have authority over.78 Accordingly, while reducing GHG emissions associated with private development is a critical component in achieving carbon neutrality, even reducing GHG emissions associated with private development to net zero through direct mitigation or purchase of equivalent GHG credits (which would be economically infeasible) cannot by itself achieve carbon neutrality. As discussed above, GHG emissions generated by buildout of the Housing Opportunity Sites at the densities assumed in the Housing Element would be well below the interpolated 2031 MTCO2e per year per capita threshold, demonstrating that the project is aligned with the state’s goal of achieving carbon neutrality. Future development under the 78 California Air Resources Board. Draft 2022 Scoping Plan Update, Appendix D. May 10, 2022.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 134 Initial Study
City of San Bruno December 2022
Housing Element Update can further support the state’s goal of carbon neutrality with implementation of the following mitigation measure.

Mitigation Measures:

MM GHG-1.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at all Housing Opportunity Sites to demonstrate adherence with the following design measures prior to issuance of any discretionary permits that would allow construction of residential units:
a. Construction of natural gas infrastructure and the use of natural gas appliances shall be prohibited;
b. Future developments shall include all electric appliances; c. At a minimum, future development shall comply with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2 requirements.

Application of the design measures identified in MM GHG-1.2 would ensure that all future residential development under the Housing Element Update would be consistent with BAAQMD’s project-level thresholds for building design. Additionally, as discussed in Section 4.17 Transportation under Impact TRN-2, buildout of the Housing Element Update would reduce VMT by 0.07 VMT per capita, and all future development would result in a VMT per resident 15 percent or greater below the regional average. Accordingly, future development under the Housing Element Update would be consistent with the plan- and project-level thresholds set forth by BAAQMD that are designed to support the State’s long-term goal of carbon neutrality. For these reasons, the project would not generate GHG emissions that would have a significant impact on the environment. (Less than Significant Impact with Mitigation Incorporated)
Impact GHG-2: The project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. (Less than Significant Impact)
AB 32 and SB 32
AB 32 as originally adopted in 2006 set forth targets that would reduce statewide GHG emissions to 1990 levels by 2020. SB 32 amended AB 32 and set forth targets to reduce statewide GHG emissions to 40 percent below the 1990 level by 2030. As discussed under Impact GHG-1, the project supports the State’s short-term goal of achieving a 40 percent reduction in GHG emissions below 1990 levels by 2030. Further, the Housing Element Update would support the State’s long-term goal of achieving carbon neutrality by 2045. Accordingly, the project would not conflict with AB 32 or SB 32. (Less than Significant Impact)
SB 375 and Plan Bay Area 2050
As discussed in Section 4.8.1.2, Plan Bay Area 2050 is the SB 375-mandated SCS for the ninecounty Bay Area region, which encompasses the City of San Bruno. Plan Bay Area 2050 establishes DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 135 Initial Study
City of San Bruno December 2022
a course for reducing per capita GHG emissions through the promotion of compact, high-density, mixed-use neighborhoods near transit, particularly within identified Priority Development Areas (PDAs).

With the exception of Housing Opportunity Sites 6 and 8, all of the Housing Opportunity Sites are located within a PDA.79 The Transportation Analysis (refer to Appendix C) analyzed the VMT generated by future development at Sites 6 and 8, and found that the VMT per resident would be 15 percent below the regional average or greater. As a whole, the Housing Element Update would reduce VMT by 0.07 VMT per resident. Further, the Housing Element Update addresses the City’s regional housing needs allocation upon which Plan Bay Area 2050 is based; therefore the project directly supports implementation of Plan Bay Area 2050 and by extension, SB 375. (Less than Significant Impact)
2017 Clean Air Plan
As discussed in detail in Section 4.4 Air Quality under Impact AIR-1, the Housing Element Update is consistent with the 2017 Clean Air Plan. (Less than Significant Impact) 2022 CARB Scoping Plan
As discussed under Impact GHG-1, the project supports the State’s short-term goal of achieving a 40 percent reduction in GHG emissions below 1990 levels by 2030 and the State’s long-term goal of achieving carbon neutrality. Therefore, the project would not conflict with the 2022 CARB Scoping Plan. (Less than Significant Impact)
79 Metropolitan Transportation Commission. “Priority Development Areas (Plan Bay Area 2050)”. Accessed October 6, 2022. https://opendata.mtc.ca.gov/datasets/priority-development-areas-plan-bay-area-2050 DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 136 Initial Study
City of San Bruno December 2022

4.9 HAZARDS AND HAZARDOUS MATERIALS

4.9.1 Environmental Setting

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

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

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

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

Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980. This law created a tax on the chemical and petroleum industries and provided broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. Over five years, $1.6 billion was collected and the tax went to a trust fund for cleaning up abandoned or uncontrolled hazardous waste sites. CERCLA accomplished the following objectives:
• Established prohibitions and requirements concerning closed and abandoned hazardous waste sites;
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 137 Initial Study
City of San Bruno December 2022
• Provided for liability of persons responsible for releases of hazardous waste at these sites; and
• Established a trust fund to provide for cleanup when no responsible party could be identified.

The law authorizes two kinds of response actions:
• Short-term removals, where actions may be taken to address releases or threatened releases requiring prompt response; and
• Long-term remedial response actions that permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life-threatening. These actions can be completed only at sites listed on the EPA’s National Priorities List.

CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the National Priorities List.

CERCLA was amended by the Superfund Amendments and Reauthorization Act on October 17, 1986.80
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, is the principal federal law in the United States governing the disposal of solid waste and hazardous waste. RCRA gives the EPA the authority to control hazardous waste from the “cradle to the grave.” This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also sets forth a framework for the management of non-hazardous solid wastes.

The Federal Hazardous and Solid Waste Amendments (HSWA) are the 1984 amendments to RCRA that focused on waste minimization, phasing out land disposal of hazardous waste, and corrective action for releases. Some of the other mandates of this law include increased enforcement authority for the EPA, more stringent hazardous waste management standards, and a comprehensive underground storage tank program.81
Government Code Section 65962.5
Section 65962.5 of the Government Code requires CalEPA to develop and update a list of hazardous waste and substances sites, known as the Cortese List. The Cortese List is used by state and local agencies and developers to comply with CEQA requirements. The Cortese List includes hazardous substance release sites identified by the Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB).82
80 United States Environmental Protection Agency. “Superfund: CERCLA Overview.” Accessed October 24, 2022. https://www.epa.gov/superfund/superfund-cercla-overview. 81 United States Environmental Protection Agency. “Summary of the Resource Conservation and Recovery Act.” Accessed October 22, 2022. https://www.epa.gov/laws-regulations/summary-resource-conservation-and-recoveryact. 82 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed October 24, 2022. https://calepa.ca.gov/sitecleanup/corteselist/.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 138 Initial Study
City of San Bruno December 2022
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) of 1976 provides the EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics, and pesticides. The TSCA addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon, and leadbased paint.

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

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

The EPA began phasing out use of friable asbestos products in 1973 and issued a ban in 1978 on manufacture, import, processing, and distribution of some asbestos-containing products and new uses of asbestos products.83 The EPA is currently considering a proposed ban on ongoing use of asbestos.84 National Emission Standards for Hazardous Air Pollutants (NESHAP) guidelines require that potentially friable ACMs be removed prior to building demolition or remodeling that may disturb the ACMs.

HSC Division 13, Section 19827.5
California Health and Safety Code Section 19827.5 prohibits the issuance of demolition permits prior to the receipt of a written asbestos notification confirming that the building that has been submitted to the United States Environmental Protection Agency or to a designated state agency, or both, pursuant to Part 61 of Title 40 of the Code of Federal Regulations, or the successor to that part. The permit may be issued without the applicant submitting a copy of the written notification if the applicant declares that the notification is not applicable to the scheduled demolition project. 83 United States Environmental Protection Agency. “EPA Actions to Protect the Public from Exposure to Asbestos.” Accessed October 24, 2022. https://www.epa.gov/asbestos/epa-actions-protect-public-exposure-asbestos 84 Ibid.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 139 Initial Study
City of San Bruno December 2022
CCR Title 8, Section 1532.1
The United States Consumer Product Safety Commission banned the use of lead-based paint in 1978.

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

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

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

With the adoption of the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit (MRP) by the San Francisco Bay Regional Water Quality Control Board on November 19, 2015, Provision C.12.f requires that permittees develop an assessment methodology for applicable structures planned for demolition to ensure PCBs do not enter municipal storm drain systems.85 Municipalities throughout the Bay Area are currently modifying demolition permit processes and implementing PCB screening protocols to comply with Provision C.12.f. Buildings constructed between 1950 and 1980 that are proposed for demolition must be screened for the presence of PCBs prior to the issuance of a demolition permit. Single-family homes and wood-frame structures are exempt from these requirements.

Bay Area Air Quality Management District
BAAQMD is vested with authority to regulate airborne pollutants through both inspection and law enforcement, and is to be notified 10 days in advance of any proposed demolition or abatement work.

The BAAQMD regulates the demolition of buildings and structures that may contain asbestos. The provisions that cover these operations are found in BAAQMD Regulation 11, Rule 2: Hazardous Materials; Asbestos Demolition, Renovation and Manufacturing. Individual project contractors are required to implement standard state and federal procedures for asbestos containment and worker safety. The demolition or removal of asbestos-containing building materials is subject to the limitations of BAAQMD Regulation 11, Rule 2. The rule requires special handling of asbestoscontaining material (e.g., by keeping materials continuously wetted). Rule 2 prohibits any visible emissions of asbestos-containing material to outside air. Individual project applicants are required to consult with the BAAQMD’s Enforcement Division prior to commencing demolition of a building containing asbestos materials.
85 California Regional Water Quality Control Board. San Francisco Bay Region Municipal Regional Stormwater NPDES Permit. November 2015.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 140 Initial Study
City of San Bruno December 2022
San Mateo County Comprehensive Airport Land Use Plan
The ALUCP for the Environs of the San Francisco International Airport (SFO), prepared by the City/County Association of Governments of San Mateo County (C/CAG), is a State-mandated land use compatibility plan that addresses the compatibility of surrounding land uses in local jurisdictions with airport operations.

The ALUCP establishes safety compatibility policies to protect public health and safety by minimizing the public’s exposure to the risk associated with potential aircraft accidents in the airport vicinity. The ALUCP identifies five safety compatibility zones in the vicinity of SFO.

The ALUCP also establishes airport vicinity height limitations to protect public safety, health, and welfare by ensuring that aircraft can safely fly in the airspace around an airport and to protect the operational capability of airports. As noted in the ALUCP, the height of new development must be maintained below critical aeronautical surfaces.

Noise compatibility policies described within the ALUCP are intended to minimize the exposure of residents and occupants of future noise-sensitive development to excessive noise. CNEL noise contours identify areas where noise exposure is great enough to warrant land use controls to promote noise compatibility. The ALUCP includes forecasted 2015 and 2020 CNEL noise contours. Included in the ALUCP are policies and standards to protect people living in the vicinity of SFO from the effects of aircraft noise. Policy NP-2, Airport/Land Use Compatibility Criteria, establishes criteria to determine the compatibility of proposed land uses in the Airport Noise Compatibility Zones.

Commercial uses, including office and general retail, are considered compatible with noise levels up to 75 dB. Public and institutional uses are generally considered to be conditionally compatible with noise levels up to 70 dB and generally incompatible with noise levels above 70 dB. Residential uses are compatible with noise levels below 65 dB, conditionally compatible with noise levels between 65 and 70 dB, and generally incompatible with noise levels in excess of 70 dB.

San Mateo County Office of Emergency Services
The San Mateo County Office of Emergency Services maintains the Countywide Emergency Operations Plan (EOP). Revised in May 2015, the EOP establishes policies and procedures and assigns responsibilities to ensure the effective management of operations in the event of an emergency.

City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating impacts of hazards and hazardous materials resulting from planned development within the City, including the following:

Policies Description
LUD-E Ensure that new development, especially in residential neighborhoods, is sensitive to existing uses, and is of the highest quality design and construction.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 141 Initial Study
City of San Bruno December 2022
Policies Description
LUD-76 Assure that new development mitigates impacts on existing public services, including transit services, water, sewer, and storm drainage systems, police and fire protection, libraries, and parks and recreation facilities.

OSR-33 Balance fire prevention goals with the preservation of the mature tree stands along the city’s scenic corridors, including Sneath Lane, Skyline Boulevard, I-280, and Crystal Springs Road, consistent with the Tree Preservation Ordinance and Ordinance 1284.

Landscaping of public rights-of-way along these corridors should complement the natural state.

ERC-12 Balance the need for fire safety and invasive plant species management with new considerations along the city’s scenic corridors. Encourage buildings to be locked outside of the tree’s drip-line or 12 feet from the tree trunk, whichever is greater, and/or incorporating special techniques to minimize root damage, etc.

ERC-19 Regulate new development – specifically industrial uses – as well as construction and demolition practices to minimize pollutant and sediment concentrations in receiving waters and ensure waterbodies within San Bruno and surface water discharged into San Francisco Bay meets or exceeds relevant regulatory water quality standards.

ERC-20 Require implementation of Best Management Practices to reduce accumulation of nonpoint source pollutants in the drainage system originating from streets, parking lots, residential areas, businesses, and industrial operations.

ERC-21 Continue programs to inform residents of the environmental effects of dumping household waste, such as motor oil, into storm drains that eventually discharge into San Francisco Bay.

ERC-22 Regularly measure and monitor water quality in San Bruno’s surface water to ensure maintenance of high quality water for consumption by humans and other species throughout the region.

ERC-23 Regulate new development to minimize stormwater runoff rates and volumes generated by impervious surfaces, and maximize recharge of local groundwater aquifers when feasible. Utilize the recommendations provided in the Bay Area Stormwater Management Agency’s Start at the Source Design Guidance Manual for Stormwater Quality Protection.

ERC-24 Require that new development incorporate features into site drainage plans that reduce impermeable surface area and surface runoff volumes. Such features may include:
• Additional landscaped areas including canopy trees and shrubs; Reducing building footprint;
• Removing curbs and gutters from streets and parking areas where appropriate to allow stormwater sheet flow into vegetated areas;
• Permeable paving and parking area design;
• Stormwater detention basins to facilitate infiltration; and • Building integrated or subsurface water retention facilities to capture rainwater for use in landscape irrigation and other non-potable uses.

HS-C Reduce the potential for damage from seismic hazards through geotechnical analysis, hazard abatement, emergency preparedness, and recovery planning.

HS-E Ensure the health, safety, and welfare of San Bruno residents by requiring appropriate use, disposal, and transport of hazardous materials.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 142 Initial Study
City of San Bruno December 2022
Policies Description
HS-G Ensure that all development heeds safety precautions from the San Francisco International Airport.

HS-23 Ensure appropriate clean-up of all former commercial and industrial sites according to relevant regulatory standards prior to reuse.

HS-24 Control the transport of hazardous substances to minimize potential hazards to the local population. Identify appropriate regional and local routes for transportation of hazardous materials, and require that fire and emergency personnel can easily access these routes for response to spill incidents.

HS-25 Review and revise City regulations regarding manufacturing, storage, and usage of hazardous materials as necessary to minimize potential hazards.

HS-26 Restrict siting of businesses that use, store, process, or dispose of large quantities of hazardous materials in areas subject to seismic fault rupture or strong ground shaking (Figure 7-2).

HS-27 Initiate a public awareness campaign—through flyers, website, and mailings—about household hazardous waste management, control, and recycling through San Mateo County programs and San Bruno Garbage.

HS-28 Require that lead-based paint and asbestos surveys be conducted by qualified personnel prior to structural demolition or renovation, in buildings constructed prior to 1980.

HS-29 Require abatement of lead-based paint and asbestos prior to structural renovation and demolition, and compliance with all State, federal, OSHA, Bay Area Air Quality Management District, and San Mateo County Health, Environmental Health Division rules and regulations.

HS-30 Regulate development on sites with known or suspected contamination of soil and/or groundwater to ensure that construction workers, the public, future occupants, and the environment are adequately protected from hazards associated with contamination, in accordance with federal, State, and local rules, regulations, policies, and guidelines.

HS-31 Require that developers compact infill soil following the removal of underground storage tanks.

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-39 Pursue mitigation of noise impacts from the San Francisco International Airport to the fullest extent possible. Support and advocate for operational practices, changes to aircraft, new technologies, and physical improvements that would reduce the area in San Bruno impacted by aircraft noise.

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.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 143 Initial Study
City of San Bruno December 2022
Ordinance 1284
Adopted in June 1977, this ordinance limits building heights to 50 feet or three stories unless approved by City voters and prohibits increases of residential densities in areas zoned residential as of 1974.

Policies Description
HS-48 Work together with other affected cities, the Airport Land Use Commission, and San Mateo County to achieve further reduction of SFO airport-generated noise and safety concerns.

HS-49 Require all new development to comply with FAR Part 77 and San Mateo County CALUP height restriction and safety compatibility standards, in accordance with Airport Land Use Commission guidelines.

HS-50 Actively and aggressively participate in forums and discussions regarding operations and expansion plans for San Francisco International Airport. Seek local representation on task forces, commissions, and advisory boards established to guide airport policies and programs.

HS-51 Require all new development to comply with FAR Part 77 height restriction standards, in accordance with Airport Land Use Commission guidelines.

PFS-F Provide adequate public safety services for all San Bruno properties – including police protection, fire suppression, emergency medical care, and emergency management.

PFS-26 Ensure adequate staffing and facilities for the City’s Police and Fire departments to achieve desired levels of service, particularly surrounding transit areas and along urbaninterface hazard areas.

PFS-30 Require installation and maintenance of fire protection measures in high-risk and urbaninterface areas:
• Proper siting and access;
• Brush clearance (non-fire resistant landscaping 50 feet from structures); • Use of fire resistive materials (pressure-impregnated, fire resistive shingles or shakes);
• Landscaping with fire resistive species; and
• Installation of early warning systems (alarms and sprinklers).

PFS-31 Ensure adequate fire water pressure as a condition of approval for all new development projects.

PFS-32 Require installation of residential sprinklers in areas with steep slopes and/or diminished access.

PFS-35 Require installation of automatic sprinkler systems in all hotel, motel, and other overnight lodging facilities, in mixed commercial/residential uses, and in apartment buildings of three or more units.

PFS-39 Minimize risks to single-access residential neighborhoods by providing alternative access for fire and other emergency personnel.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 144 Initial Study
City of San Bruno December 2022
Ordinance 1446
Adopted in November 1984, Ordinance 1446 gives “the City of San Bruno the authority to approve the enlargement or extension of existing buildings and the construction of new buildings and structures in the Tanforan Park Shopping Center without further voter approval; provided that the height of any such building or structure shall not exceed the height of the tallest building or structure existing at the time of adoption of the ordinance”. The highest structure existing at the time of adoption was the Target building, which is at an elevation of 126 feet and 9 inches AMSL. If any proposed building height exceeds the current allowance, such proposal would require City Council to place such request on a future ballot measure.

Bayhill Specific Plan
As noted in Section 3.1.1.1, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Chapter Six of the Bayhill Specific Plan includes mandatory “Environmental Quality” policies, including the following which pertain to hazards and hazardous materials.

Policy 6-7
Policy 6-7 requires new development with hazardous materials on site to create digital pre-incident plans. These plans shall be distributed to the San Bruno Fire Department as a condition of approval of a development entitlement prior to the issuance of a certificate of occupancy for the project site.

Policy 6-8
Policy 6-8 requires any dewatering conducted during construction to be subject to review and approval by the County of San Mateo’s Groundwater Protection Program.

4.9.1.2 Existing Conditions
General Plan and Municipal Code Conforming Sites
Residential development at the densities proposed by the Housing Element Update (refer to Table 3.2 1) are allowed at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 under their existing General Plan land use designation and zoning designation, and therefore no General Plan amendments or rezoning is required. The existing conditions at these sites related to hazards and hazardous materials are discussed below.

Housing Opportunity Site 6
Housing Opportunity Site 6 is currently developed with multiple uses, including a privately operated golf driving range, parking lot storage for a private bus operator, and a maintenance building for the San Bruno Park School District. Site 6 is not on the Cortese List.86 The nearest school is the Crestmoor Canyon Stratford School, located 0.18-miles south of Site 6. The nearest airport, SFO, is located approximately 2.05 miles east of Site 6, which is beyond the outer boundary of safety compatibility zones and CNEL noise contours established in the ALUCP. Critical aeronautical 86 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed October 24, 2022. https://calepa.ca.gov/sitecleanup/corteselist/.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 145 Initial Study
City of San Bruno December 2022
surfaces at Site 6 are 150 feet above ground level (AGL) or greater. As shown on Figure 4.20-1, Site 6 is located within a Wildland Fire Hazard Area.

Housing Opportunity Site 8
Housing Opportunity Site 8 is currently developed with the former Edgemont Elementary School campus. Site 8 is not on the Cortese List.87 The nearest school is Allen Elementary, located approximately 0.05-miles north of Site 8. SFO is located approximately 1.10-miles east of Site 8, which is located beyond the outer boundary of safety compatibility zones and CNEL noise contours established in the ALUCP. Critical aeronautical surfaces at Site 8 are 150 feet AGL or greater. As shown on Figure 4.20-1, Site 8 is not located within a Wildland Fire Hazard Area or Wildland/Urban Interface Area.

Housing Opportunity Sites 10 and 16
Housing Opportunity Sites 10 and 16 are vacant dirt lots that are located adjacent to each other on San Marco Avenue. Sites 10 and 16 are not on the Cortese List. 88 The nearest school is the City Park
Stratford School located 0.3-miles west of Sites 10 and 16. SFO is located approximately one mile northeast of Sites 10 and 16, which are located beyond the outer boundary of safety compatibility zones and CNEL noise contours established in the ALUCP. Critical aeronautical surfaces at Sites 10 and 16 are 100 feet AGL or greater. As shown on Figure 4.20-1, Sites 10 and 16 are not located within a Wildland Fire Hazard Area or Wildland/Urban Interface Area.

Housing Opportunity Site 18
Housing Opportunity Site 18 is developed with a two-story office building, pedestrian plaza, and surface parking lot. Site 18 is not on the Cortese List. 89 The nearest school is the El Portal Special
Education School, located approximately 0.3-miles west of Site 18. SFO is located approximately

1.3-miles east of Site 18, which is located beyond the outer boundary of the safety compatibility zones established in the ALUCP, but within the 65 dB CNEL noise contour. Critical aeronautical surfaces at Site 18 are 65 feet AGL or greater. As shown on Figure 4.20-1, Site 18 is not located within a Wildland Fire Hazard Area or Wildland/Urban Interface Area.

Housing Opportunity Site 19
Housing Opportunity Site 19 is developed with a single-story pet hospital and surface parking lot.

Site 19 is not on the Cortese List.90 The nearest school is the El Portal Special Education School, located approximately 0.3-miles west of Site 19. SFO is located approximately 1.10-miles east of Site 19, which is located beyond the outer boundary of the safety compatibility zones established in the ALUCP, but within the 70-75 dB CNEL noise contour. Critical aeronautical surfaces at Site 19 are 65 feet AGL or greater. As shown on Figure 4.20-1, Site 19 is not located within a Wildland Fire Hazard Area or Wildland/Urban Interface Area.
87 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed October 24, 2022. https://calepa.ca.gov/sitecleanup/corteselist/. 88 Ibid. 89 Ibid. 90 Ibid.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 146 Initial Study
City of San Bruno December 2022
Transit Corridors Plan Area Sites
As noted in Section 3.1.1.1, Housing Opportunity Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23 are located within the TCP area. The TCP EIR identified a total of 26 sites that were on the Cortese List, including Housing Opportunity Sites 11, 12, 15, and 23. Since the certification of the TCP EIR in 2012, none of the other Housing Opportunity Sites located within the TCP have been added to the Cortese List.

The eastern boundary of the TCP area is located approximately 0.5-miles west of SFO; all of the Housing Opportunity Sites located within the TCP are located beyond the outer boundary of safety compatibility zones and CNEL noise contours established in the ALUCP. Critical aeronautical surfaces in the TCP area are 100 feet AGL in height or greater.

As shown on Figure 4.20-1, none of the TCP Housing Opportunity Sites are located within a Wildland Fire Hazard Area or a Wildland/Urban Interface Area.

Bayhill Specific Plan Area Sites
As noted in Section 3.1.1.2, Housing Opportunity Sites 3 and 13 are located within the Bayhill Specific Plan area. Sites 3 and 13 are not on the Cortese List.

The eastern boundary of the Bayhill Specific Plan area is located approximately 1.3-miles west of SFO; Sites 3 and 13 are located beyond the outer boundary of safety compatibility zones and CNEL noise contours established in the ALUCP. Critical aeronautical surfaces at Sites 3 and 13 are 150 feet AGL in height or greater.

As shown on Figure 4.20-1, a small portion of Site 3 is within a Wildland/Urban Interface Area, while Site 13 is not located within a Wildland Fire Hazard Area or a Wildland/Urban Interface Area.

Housing Opportunity Site 14
Housing Opportunity Site 14 consists of 1122-1188 El Camino Real/300 Tanforan Shopping Center, which is developed with the Shops at Tanforan shopping mall, and 1292 Huntington Avenue, which is located opposite the Shops at Tanforan across the Sneath Lane/Huntington Avenue intersection and is developed with a vacant paved lot. The original Shops at Tanforan development was originally constructed in 1971; it underwent major renovations in 2005 and the Century Theatre and associated parking lot were added in 2007. The original Shops at Tanforan Development included a variety of retail uses, including a Sears department store and the associated Sears Automotive Center, which were located in the northeast corner of the site to the west of the existing Century Theatre building. 1292 Huntington Avenue has historically been undeveloped.

Historically, Site 14 was used for horse raising and grazing since the early days of the Spanish occupation on the Peninsula. Tanforan Racetrack, which opened in 1899, was the takeoff site of the first flight ever on the West Coast. Tanforan was also the site of the first ever aircraft carrier takeoff and landing in 1911, from the U.S.S. Pennsylvania. The Tanforan Racetrack held races of all types, from horse races to races between cars and airplanes, before it burned down in 1964. In 1965, the site was used as a golf course.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 147 Initial Study
City of San Bruno December 2022
The northeast corner of Site 14 (see Figure 4.9-1) where the former Sears Automotive Center operated is on the List of Leaking Underground Storage Tank (LUST) Sites, which is one of the lists compiled pursuant to Government Code Section 65962.5.91 Subsurface soil, soil vapor, and groundwater investigations identified soil and soil vapor contaminated within benzene, and groundwater contaminated with light non-aqueous phase liquids (LNAPL).92 The primary sources of contamination (underground petroleum storage tanks) were removed in 1985 and 2001; a secondary source of petroleum hydrocarbons was discovered between the San Bruno Police Department building at 1177 Huntington Avenue and the Century Theatre building. This secondary source was remediated between August 2019 and September 2019.93
Site 14’s listing is classified as “Open – Verification Monitoring”, and a monitoring and sampling program is ongoing to confirm successful completion of site cleanup. As of December 2019, no LNAPLs or sheen has been observed in any of the monitoring wells on-site, and benzene levels have been reduced below the San Mateo County Department of Environmental Health (SMCEHS) target low-threat closure criteria of 1,000 µg/L. Destruction of all remaining monitoring wells and disposal of investigation derived waste, followed by case closure, is expected by December 2023. Future development within the area shown in Figure 4.9-1 would be required to submit a Redevelopment Management Plan that includes 1) an evaluation of whether redevelopment activities will create new exposure pathways to human health and the environment that pose unacceptable risks, and, if so, how those risks will be mitigated, and 2) a discussion of how contaminated media will be handled and disposed during construction activities.94
Site 14 is located 1.10-miles northwest of the runway termination point of SFO, which places Site 14 within the 70-75 dB CNEL noise contour and Safety Compatibility Zone 4. The critical aeronautical surfaces at Site 14 are between 55 to 90 feet AGL, equivalent to 125 to 145 feet AMSL. The nearest school is the El Portal Special Education School, located approximately 0.35-miles west of Site 14.

As shown on Figure 4.20-1, a portion of Site 14 is located within a Wildland/Urban Interface Area. 91 California Environmental Protection Agency. “Cortese List Data Resources.” Accessed October 24, 2022. https://calepa.ca.gov/sitecleanup/corteselist/. 92 Nonaqueous phase liquids (NAPLs) are hydrocarbons that exist as a separate, immiscible phase when in contact with water and/or air. Light nonaqueous phase liquids (LNAPLs) have densities less than that of water. LNAPLs represent potential long-term sources for continued ground-water contamination at many sites. Source: United States Environmental Protection Agency. Light Nonaqueous Phase Liquids. June 2015. 93 AECOM. Corrective Plan Implementation Report. April 2020. 94 Gwinn, Brian. Hazardous Materials Specialist, Groundwater Protection Program, San Mateo County Environmental Health Services Department. Email communication dated September 8, 2022.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 Source: AECOM, April 2017.

N
Site
Location
6HDUV$XWRPRWLYH
&HQWHU6LWH
SEARS AUTOMOTIVE CENTER SITE FIGURE 4.9-1
2023-2031 Housing Element Update
City of San Bruno
148 Initial Study
December 2022
~,u.T,oNAI AlltPORT ~ t
~ sanFnoneiKO
tA11pon
~ ,-<,
0 '7-"'!' _,; , /
';
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 149 Initial Study
City of San Bruno December 2022

4.9.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
2) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
3) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
4) Be located on a site which is included on a list
of hazardous materials sites compiled pursuant
to Government Code Section 65962.5 and, as
a result, would it create a significant hazard to
the public or the environment?
5) For a project located within an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, result in a safety hazard
or excessive noise for people residing or
working in the project area?
6) Impair implementation of or physically
interfere with an adopted emergency response
plan or emergency evacuation plan?
7) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury,
or death involving wildland fires?
Impact HAZ-1: The project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. (Less than Significant Impact)
Construction of future development under the Housing Element Update would involve the routine transport, use, and disposal of hazardous materials such as fuel, solvents, paints, oils, grease, and caulking. Such transport, use, and disposal must be compliant with the RCRA, U.S. Department of Transportation hazardous materials regulations, and Cal/OSHA regulations. In addition, the San Bruno General Plan contains several policies (refer to Section 4.9.1.2) that ensure hazardous materials are appropriately transported, used, and disposed of. Therefore, the transport, use, or □
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 150 Initial Study
City of San Bruno December 2022
disposal of hazardous materials during future construction activities would not create a significant hazard to the public or the environment.

Operation and maintenance of residential uses do not involve the use of acutely hazardous materials.

Potentially hazardous materials, including cleaning supplies, maintenance chemicals, and herbicides and pesticides for landscape maintenance, can be expected to be used by future residential development at the Housing Opportunity Sites. The transport, use, and disposal of these materials would be subject to the federal, state, and local laws and regulations identified above. Future residential development may include emergency diesel generators to be used in case of emergency; under Health and Safety Code 25507(a)(1)(A), the project would be required to establish and implement a Hazardous Materials Business Plan if the amount of diesel fuel stored on-site exceeds 55 gallons. Adherence with the aforementioned existing laws and regulations would ensure that the routine transport, use, or disposal of hazardous materials by future development under the Housing Element Update would not create a significant hazard to the public or the environment.

Impact HAZ-2: The project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. (Less than Significant Impact with Mitigation Incorporated)
Demolition
Based on the age of many of the existing buildings located on the Housing Opportunity Sites, hazardous materials such as ACMs, lead-based paint, and PCBs may be present in building materials.

General Plan Policy HS-28 requires lead-based paint and asbestos surveys be conducted prior to building demolition, and General Plan Policy HS-29 requires the abatement of all lead-based paint and asbestos prior to building demolition. Abatement activities would be conducted in accordance with Section 19827.5 of the California Health and Safety Code, BAAQMD regulations (specifically Regulation 11, Rule 2, Hazardous Materials; Asbestos Demolition, Renovation and Manufacturing) and Cal/OSHA requirements. Provision C.12.f of the NPDES MRP requires screening for the presence of PCBs prior to the demolition of any buildings constructed between 1955 and 1980.

Accordingly, all lead-based paint, ACMs, and PCBs present in building materials at Site 14 would be identified and disposed of in accordance with the TSCA and General Plan policies HS-24, thus ensuring that demolition of existing buildings at the Housing Opportunity Sites does not create a significant hazard to the public or environment through the release of ACMs, lead-based paint, and PCBs. (Less than Significant Impact)
Soil Contamination
General Plan and Municipal Code Conforming Sites
As documented in Section 4.9.1.2, there is no known soil contamination at Housing Opportunity Sites 6, 8, 10, 16, 18, or 19, and none of these sites are on the Cortese List. None of the existing uses at these sites are known sources of soil contamination. However, it is possible that soil contamination associated with past uses of these sites exists. If contaminated soil is present at these sites, grounddisturbing activities could expose construction workers and the public to health hazards from physical contact with contaminated materials or hazardous vapors. Improper handling or storage of DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 151 Initial Study
City of San Bruno December 2022
contaminated soil and groundwater can further expose the public to these hazards, or potentially spread contamination through surface water runoff or air-borne dust. In addition, contaminated groundwater can spread downgradient, potentially contaminating subsurface areas of surrounding properties.

Mitigation Measures:

MM HAZ-2.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 to comply with the following measure:
a. The City shall require a Phase I Environmental Site Assessment (Phase I ESA) prior to issuance of any discretionary permits that would allow ground-disturbing activities, with a Phase II ESA also required if the Phase I ESA indicates evidence of potential site contamination. The City shall also require compliance with the site assessment(s) and any remediation, removal, and disposal requirements for soil, surface water, and/or groundwater contamination enforced by the Department of Toxic Substances Control (DTSC), Regional Water Quality Control Board (RWQCB), San Mateo County Department of Environmental Health (SMCEHS), California Division of Occupational Safety and Health (CalOSHA), U.S. Environmental Protection Agency (EPA), and other
jurisdictional agencies.

Adherence with MM HAZ-2.1 during construction of future development at Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 would ensure that any contaminated soil present at these sites is identified and remediated in accordance with federal, state, and local regulations and requirements imposed by the DTSC, RWQCB, SMCEHS, CalOSHA, and the EPA. Therefore, future development of Housing Opportunity Sites 6, 8, 10, 16, 18, and 19 would not create a significant hazard to the public or the environment. (Less than Significant Impact with Mitigation Incorporated) Transit Corridors Plan Area Sites
As documented in Section 4.9.1.2, the TCP EIR identified a total of 26 sites in the TCP area that were on the Cortese List, including Housing Opportunity Sites 11, 12, 15, and 23. Since the certification of the TCP EIR in 2012, none of the other Housing Opportunity Sites located within the TCP have been added to the Cortese List. The TCP EIR imposed the following mitigation measure to ensure that future development within the TCP area, including at Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23, would not create a significant hazard to the public or the environment. • TCP Mitigation Measure 8-1: California Department of Toxic Substances Control (DTSC) remedial investigations and actions have occurred or are ongoing on the remaining 11 active sites and 15 closed sites (in some cases, a hazardous materials site closure notice may contain land use restrictions limiting future use of the site as a result of residual contamination that may exist). Development involving disturbance or re-use of one of these 26 sites cannot proceed until required remediation actions have been completed to DTSC satisfaction. The DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 152 Initial Study
City of San Bruno December 2022
DTSC may impose land use restrictions, which prevent the use of the property for residential, school, hospital, or day care purposes, on some sites, if warranted. In connection with each discretionary development approval application that the City initially determines could expose construction workers or occupants to hazardous materials contamination related to one of these sites, the City shall require a Phase I environmental site assessment (Phase I ESA) prior to property development, with a Phase II ESA also required if the Phase I ESA indicates evidence of potential site contamination. The City shall also require compliance with the site assessment, remediation, removal, and disposal requirements for soil, surface water, and/or groundwater contamination enforced by the DTSC, Regional Water Quality Control Board (RWQCB), San Mateo County Department of Environmental Health, California Division of Occupational Safety and Health (CalOSHA), U.S. Environmental Protection Agency (EPA), and other jurisdictional agencies.

Consistent with the conclusions of the TCP EIR, adherence with TCP Mitigation Measure 8-1 as required by the TCP EIR would ensure future development under the Housing Element Update at Sites 1, 2, 4, 5, 7, 9, 11, 12, 15, 17, 20, 21, 22, and 23, would not create a significant hazard to the public or the environment. (Less than Significant Impact) Bayhill Specific Plan Area Sites
As documented in Section 4.9.1.2, there is no known soil contamination at Sites 3 and 13, and neither site is on the Cortese List. Future development at Sites 3 and 13 would be required by the General Plan and Specific Plan policies to remove and remediate any contaminated soil encountered during ground-disturbing activities at an approved disposal facility in accordance with federal, state, and local regulatory requirements. Consistent with the conclusions of the Bayhill Specific Plan EIR, adherence with federal, state, and local regulations (refer to Section 4.9.1.1) would ensure that future development of Sites 3 and 13 under the Housing Element Update would not create a significant hazard to the public or the environment. (Less than Significant Impact) Housing Opportunity Site 14
As discussed in Section 4.9.1.2, subsurface soil, soil vapor, and groundwater beneath the northeast corner of Site 14 (refer to Figure 4.9-1) is contaminated with benzene and LNAPLs below SMCEHS thresholds. Per the SMCEHS, remediation has been completed pending the conclusion of a sampling and monitoring program, and destruction of all remaining monitoring wells and disposal of investigation derived waste, followed by case closure, is expected by December 2023. Prior to future development within the area shown in Figure 4.9-1, the SMCEHS would require the project proponent to submit a Redevelopment Management Plan that includes 1) an evaluation of whether redevelopment activities will create new exposure pathways to human health and the environment that pose unacceptable risks, and, if so, how those risks will be mitigated, and 2) a discussion of how contaminated media will be handled and disposed during construction activities.95 Accordingly, redevelopment of this portion of Site 14 would not create a significant hazard to the public or the environment.
95 Gwinn, Brian. Hazardous Materials Specialist, Groundwater Protection Program, San Mateo County Environmental Health Services Department. Email communication dated September 8, 2022.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 153 Initial Study
City of San Bruno December 2022
The remainder of Site 14 may be contaminated with chemicals used in landscape maintenance and by petroleum hydrocarbons associated with the past use of the site by vehicles and aircraft. Additionally, there may be historic or existing dry-cleaning operations that were or are located in the surrounding area that could have resulted in subsurface contamination of Site 14 with dry cleaning chemicals, such as the chlorinated solvents perchloroethylene (PCE) and trichloroethene (TCE). Contaminated soil, soil vapor, and groundwater encountered and/or disturbed during construction could adversely affect construction workers and nearby sensitive receptors, if appropriate control measures are not implemented.

Mitigation Measures:

MM HAZ-2.2: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any discretionary permits that would allow ground-disturbing activities on Site 14 (outside of the area shown on Figure 4.9-1), the project proponent shall obtain a Phase I Environmental Site Assessment (ESA). The Phase I ESA shall be conducted in accordance with the United States Environmental Protection Agency’s All Appropriate Inquiries (AAI) Rule and the latest American Society for Testing and Materials (ASTM International) guidelines, and identify all potential subsurface contaminants warranting further investigation. b. If the Phase I ESA identifies any potential contaminants warranting further investigation, a Phase II ESA shall be prepared in accordance with the United States Environmental Protection Agency’s AAI Rule and the latest ASTM International guidelines. As part of the Phase II, a qualified environmental professional (as defined in Title 40 of the California Code of Regulations) shall take soil, soil vapor, and groundwater samples as determined necessary by the environmental professional in the area of proposed disturbance at 0.5 feet below ground surface (bgs) to the maximum proposed depth of disturbance. Collected soil samples shall be tested for all potential contaminants identified in the Phase I ESA to determine if contaminants exceed California Division of Occupational Safety and Health (Cal/OSHA) exposure limits or San Mateo County Environmental Health Services (SMCEHS) environmental screening levels for residential uses.
c. The results of the Phase II ESA shall be provided SMCEHS department.

If determined necessary by the SMCEHS, a Redevelopment Management Plan (RMP) or equivalent shall be prepared and submitted to the SMCEHS and the Director of Community and Economic Development or the Director’s designee that includes 1) an evaluation of whether redevelopment activities will create new exposure pathways to human health and the environment that pose unacceptable risks, and, if so, how those risks will be mitigated, and 2) a discussion of how contaminated media will be handled and disposed during construction activities. Once DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 154 Initial Study
City of San Bruno December 2022
approved by the SMCEHS and Community and Economic Development Department, the RMP or equivalent shall be implemented by a qualified environmental professional. The results of the RMP or equivalent shall be submitted to the SMCEHS and the Director of Community and Economic Development or the Director’s designee prior to the issuance of any issuance of any discretionary permits (e.g., grading, construction, occupancy, whichever occurs first).

Implementation of MM HAZ-2.2a would require the preparation of a Phase I ESA that identifies all potential subsurface contaminants which could create a significant hazard to the public (i.e., construction workers, future residents, adjacent receptors) or the environment. Implementation of MM HAZ-2.2b and MM HAZ-2.2c would ensure that the lateral and vertical extents of any existing subsurface contamination are defined and remediated to the satisfaction of the SMCEHS, which is the CUPA for San Mateo County (refer to the discussion in Section 4.9.1.1). Accordingly, implementation of the Housing Element as amended by MM HAZ-2.2 would ensure that future residential development at Site 14 would not create a significant hazard to the public or the environment. (Less than Significant Impact with Mitigation Incorporated) Impact HAZ-3: The project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. (Less than Significant Impact with Mitigation Incorporated)
A number of the Housing Opportunity Sites are located within a quarter-mile of school facilities.

Residential uses do not emit hazardous emissions. As discussed under Impact HAZ-1, hazardous materials used during construction and operation would be transported, used, and disposed of in accordance with the RCRA, U.S. Department of Transportation hazardous materials regulations, Cal/OSHA regulations, and the City’s General Plan (refer to Section 4.9.1.1). All diesel fuel stored at the Housing Opportunity Sites would be managed in accordance with Health and Safety Code 25507(a)(1)(A). Further, as discussed under Impact HAZ-2, adherence with federal, state and local regulations and mitigation measures MM HAZ-2.1 and HAZ-2.2 would ensure that future development does not create a significant hazard to the public or the environment. For these reasons, future development under the Housing Element Update would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 155 Initial Study
City of San Bruno December 2022
Impact HAZ-4: The project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment. (Less than Significant Impact with Mitigation Incorporated) As documented in Section 4.9.1.2, Housing Opportunity Sites 11, 12, 14, 15, and 23 are on the Cortese List. Per the discussion under Impact HAZ-2, redevelopment of these sites would not create a significant hazard to the public or environment with implementation of MM HAZ-2.2 and adherence to TCP Mitigation Measure 8-1. Implementation of the aforementioned mitigation measures would ensure that future development of these sites under the Housing Element Update would not create a significant hazard to the public or environment.

Impact HAZ-5: The project would be located within an airport land use plan. The project would not result in a safety hazard or excessive noise for people residing or working in the project area. (Less than Significant Impact with Mitigation Incorporated)
As discussed in Section 2.5.3 City/County Association of Governments of San Mateo County, Section 4.11 Land Use and Planning under Impact LU-2, and Section 4.13 Noise and Vibration under Impact NOI-3, residential uses at all of the Housing Opportunity Sites (with the exception of Sites 14 and 19) are compatible with the noise contours identified in the ALUCP. Residential uses at all of the Housing Opportunity Sites are compatible with the safety compatibility zones identified in the ALUCP. Existing height restrictions of 50 feet (maximum of 90 feet for sites located in the TCP area) for future development on the Housing Opportunity Sites (with the exception of Site 14, which has a height restriction of 126 feet and nine inches AMSL pursuant to Ordinance 1446) would ensure building heights would not exceed critical aeronautical surfaces.

As documented in Section 4.9.1.2, Housing Opportunity Sites 14 and 19 are located within the 70-75 dB CNEL noise contour. As discussed in Section 4.13.2 under Impact NOI-3, the Noise and Vibration Assessment (refer to Appendix B) concluded that reducing interior noise levels to 45 dBA (as required by the California Building Standards Code, San Bruno General Plan, and ALUCP) in future residential development at Sites 14 and 19 is feasible using readily available building techniques. Future residential development at Sites 14 and 19 would be required by General Plan Policy HS-35 to comply with relevant noise insulation standards to achieve an indoor noise level of 45 dB CNEL or less. Although Sites 14 and 19 are located within a 70-75 dB CNEL contour and would require a Local Agency Override of the ALUCP (refer to the discussion in Section 2.5.3), redevelopment of Sites 14 and 19 with residential uses that comply with the 45 dB noise insulation requirements would not result in excessive noise exposure for future residents of Sites 14 and 19.

The critical aeronautical surfaces at Site 14 range between 55 to 90 feet AGL, equivalent to 125 to 145 feet AMSL. Building heights at Site 14 are limited to 126 feet, nine inches AMSL by Ordinance 1446 (refer to Section 4.9.1.1). Because the 2023-2031 Housing Element is a policy document and not a specific development proposal, the airspace compatibility policies of the ALUCP do not directly apply. However, future building heights at the Housing Opportunity Sites (including Site 14) would be required to comply with SFO Policy AP-3, which states that building heights must be the DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 156 Initial Study
City of San Bruno December 2022
“lower of (1) the height shown on the SFO critical aeronautical surfaces map (Exhibits IV-17 and IV18), 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.” The use of construction equipment (such as building cranes) or the construction of buildings with heights in excess of 55 feet AGL could pose a safety hazard to construction workers and future residents.

Mitigation Measures:

MM HAZ-5.1: Prior to approval, the 2023-2031 Housing Element shall include a policy requiring future development at Housing Opportunity Site 14 to comply with the following measures:
a. Prior to the issuance of any construction or building permits, the applicant shall submit a plan with a list of equipment to be used during construction that includes their height and proposed area of operation to the Director of Community and Economic Development or the Director’s designee. The use of equipment in locations where it would penetrate critical aeronautical surfaces shall be expressly prohibited by any construction or building permits issued. The plan sets shall include a page depicting the critical aeronautical surfaces on-site, a list of all equipment with heights of 55 feet or greater and their respective heights, and informs construction workers that the use of equipment with heights that would penetrate critical aeronautical surfaces is prohibited.
b. Future development at Housing Opportunity Site 14 shall comply with Policy AP-3 of the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (ALUCP).

Buildings with heights in excess of the applicable critical aeronautical surface as shown in Exhibit IV-17 at Housing Opportunity Site 14 shall be prohibited unless the Federal Aviation Administration determines the proposed building height is not a hazard to air navigation in an aeronautical study prepared pursuant to the filing of Form 7460-1. Proof of compliance with Policy AP-3 of the ALUCP shall be provided to the Director of Community and Economic Development or the Director’s designee prior to issuance of any construction or building permits.

MM HAZ-5.1a would ensure that no construction or building permits are issued that would allow the use of construction equipment on Site 14 that could penetrate critical aeronautical surfaces, and that construction workers are informed on where the use of equipment with heights of 55 feet or greater is prohibited. Adherence with MM HAZ-5.1b would ensure no buildings are constructed that exceed critical aeronautical surfaces or would result in a hazard to air navigation according to the FAA.

Accordingly, implementation of the Housing Element as amended by MM HAZ-5.1 would ensure that future residential development at Site 14 would not result in a safety hazard for future workers or residents within the project area.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 157 Initial Study
City of San Bruno December 2022
Impact HAZ-6: The project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. (Less than Significant Impact)
The City of San Bruno is within the San Mateo County Emergency Operations Plan area. Under the Emergency Operations Plan, cities are responsible for responding to emergencies within their jurisdiction. As discussed in Section 4.15 Public Services under Impact PS-1 and Impact PS-2, future residential development under the Housing Element Update would pay development impact fees that would contribute to funding the construction of new and expanded fire and police facilities to help the City’s fire and police departments maintain and/or achieve their respective performance objectives. Further, during an emergency, the City would be able to request additional aid from the San Mateo County Emergency Operation Center, including additional personnel and equipment.

Accordingly, future development under the Housing Element Update would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Impact HAZ-7: The project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. (Less than Significant Impact)
As shown on Figure 4.20-1, Site 6 is located within a Wildland Fire Hazard Area, and Sites 3 and 14 are bordered by a Wildland/Urban Interface Area. Adherence with General Plan Policy PFS-30 would require future development at Sites 3, 6, and 14 to install and maintain a variety of fire protection measures, and all construction would be required by the City’s Municipal Code to be built to 2019 California and International Fire Code standards with fire suppression systems. Further, as discussed in Section 4.15 under Impact PS-1, fire protection services are adequate to meet new demand generated by redevelopment of Sites 3, 6, and 14. For these reasons, future development under the Housing Element Update would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 158 Initial Study
City of San Bruno December 2022

4.10 HYDROLOGY AND WATER QUALITY

4.10.1 Environmental Setting

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

Under Section 303(d) of the federal Clean Water Act, the SWRCB and RWQCBs are required to identify impaired surface water bodies that do not meet water quality standards and develop total maximum daily loads (TMDLs) for contaminants of concern. The list of the state’s identified impaired surface water bodies, known as the “303(d) list” can be found on the on the RWQCB’s website.96
National Flood Insurance Program
The Federal Emergency Management Agency (FEMA) established the National Flood Insurance Program (NFIP) to reduce impacts of flooding on private and public properties. The program provides subsidized flood insurance to communities that comply with FEMA regulations protecting development in floodplains. As part of the program, FEMA publishes Flood Insurance Rate Maps (FIRMs) that identify Special Flood Hazard Areas (SFHAs). An SFHA is an area that would be inundated by the one-percent annual chance flood, which is also referred to as the base flood or 100- year flood.

Statewide Construction General Permit
The SWRCB has implemented an NPDES General Construction Permit for the State of California (Construction General Permit). For projects disturbing one acre or more of soil, a Notice of Intent (NOI) must be filed with the RWQCB by the project sponsor, and a Storm Water Pollution Prevention Plan (SWPPP) must be prepared by a qualified professional prior to commencement of construction and filed with the RWQCB by the project sponsor. The Construction General Permit includes requirements for training, inspections, record keeping, and, for projects of certain risk levels, monitoring. The general purpose of the requirements is to minimize the discharge of pollutants and to protect beneficial uses and receiving waters from the adverse effects of construction-related storm water discharges.
96 San Francisco Regional Water Quality Control Board. “The 303(d) List of Impaired Water Bodies.” Accessed August 11, 2022. https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/TMDLs/303dlist.html.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 159 Initial Study
City of San Bruno December 2022
Regional and Local
San Francisco Bay Basin Plan
The San Francisco Bay RWQCB regulates water quality in accordance with the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan lists the beneficial uses that the San Francisco Bay RWQCB has identified for local aquifers, streams, marshes, rivers, and the San Francisco Bay, as well as the water quality objectives and criteria that must be met to protect these uses. The San Francisco Bay RWQCB implements the Basin Plan by issuing and enforcing waste discharge requirements, including permits for nonpoint sources such as the urban runoff discharged by a City’s stormwater drainage system. The Basin Plan also describes watershed management programs and water quality attainment strategies.

Municipal Regional Permit Provision C.3
The San Francisco Bay RWQCB re-issued the Municipal Regional Stormwater NPDES Permit (MRP) in May 2022 to regulate stormwater discharges from municipalities and local agencies (copermittees) in Alameda, Contra Costa, San Mateo, and Santa Clara Counties, and the cities of Fairfield, Suisun City, and Vallejo.97 Under Provision C.3 of the MRP, new and redevelopment projects that create or replace 5,000 square feet or more of impervious surface area are required to implement site design, source control, and Low Impact Development (LID)-based stormwater treatment controls to treat post-construction stormwater runoff. LID-based treatment controls are intended to maintain or restore the site’s natural hydrologic functions, maximizing opportunities for infiltration and evapotranspiration, and using stormwater as a resource (e.g. rainwater harvesting for non-potable uses). The MRP also requires that stormwater treatment measures are properly installed, operated, and maintained.

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

Projects may be deemed exempt from these requirements if: (1) the post-project impervious surface area is less than, or the same as, the pre-project impervious surface area; (2) the project is located in a catchment that drains to a hardened (e.g., continuously lined with concrete) engineered channel or channels or enclosed pipes, which extend continuously to the Bay, Delta, or flow-controlled reservoir, or, in a catchment that drains to channels that are tidally influenced; or (3) the project is located in a catchment or subwatershed that is highly developed (i.e., that is 70 percent or more impervious).98
97 California Regional Water Quality Control Board San Francisco Region. Municipal Regional Stormwater NPDES Permit, Order No. R2-2022-0018, NPDES Permit No. CAS612008. May 11, 2022 98 The Hydromodification Applicability Maps developed the permittees under Order No. R2-2009-0074 were prepared using this standard, adjusted to 65 percent imperviousness to account for the presence of vegetation on the photographic references used to determine imperviousness. Thus, the maps for Order No. R2-2009-0074 are accepted as meeting the 70 percent requirement.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 160 Initial Study
City of San Bruno December 2022
Municipal Regional Permit Provision C.12.f
Provision C.12.f of the MRP requires co-permittee agencies to implement a control program for PCBs that reduces PCB loads by a specified amount during the term of the permit, thereby making substantial progress toward achieving the urban runoff PCBs wasteload allocation in the Basin Plan by March 2030.99 Programs must include focused implementation of PCB control measures, such as source control, treatment control, and pollution prevention strategies. Municipalities throughout the Bay Area are updating their demolition permit processes to incorporate the management of PCBs in demolition building materials to ensure PCBs are not discharged to storm drains during demolition.

Buildings constructed between 1950 and 1980 that are proposed for demolition must be screened for the presence of PCBs prior to the issuance of a demolition permit. Single-family residential and wood frame structures are exempt.

San Mateo Countywide Water Pollution Prevention Program The San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) was established in 1990 to reduce the pollution carried by stormwater into local creeks, San Francisco Bay, and the Pacific Ocean. The program is a partnership of the C/CAG, each incorporated city and town in the county, and the County of San Mateo, which share a common National Pollutant Discharge Elimination System permit. The SMCWPPP includes pollution reduction activities for construction sites, illegal discharges and illicit connections, new development, and municipal operations. The program also includes a target pollutant reduction strategy and monitoring program.

San Mateo County Flood Control District
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.

City of San Bruno General Plan
Various policies in the City’s General Plan have been adopted for the purpose of avoiding or mitigating impacts on hydrology and water quality resulting from planned development within the City, including the following:

Policies Description
ERC-A Preserve open space essential for the conservation of San Bruno’s natural resources – including vegetation, wildlife, soils, water, and air.

ERC-D Reduce pollution levels within the surface water that San Bruno discharges into the San Mateo County Flood Control District, then into San Francisco Bay.

ERC-3 Protect natural vegetation in park, open space, and scenic areas as wildlife habitat, to prevent erosion, and to serve as noise and scenic buffers. 99 California Regional Water Quality Control Board San Francisco Region. Municipal Regional Stormwater NPDES Permit, Order No. R2-2022-0018, NPDES Permit No. CAS612008. May 11, 2022 DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 161 Initial Study
City of San Bruno December 2022
Policies Description
ERC-4 Encourage the use of Best Management Practices in conserving the city’s valuable water supply sources.

ERC-18 Coordinate efforts with the San Mateo County Flood Control District, Caltrans, Golden Gate National Recreation Area, San Francisco Airport, Peninsula Watershed lands, and Junipero Serra County Park to develop or preserve and manage interconnecting wildlife movement corridors.

ERC-19 Regulate new development – specifically industrial uses – as well as construction and demolition practices to minimize pollutant and sediment concentrations in receiving waters and ensure waterbodies within San Bruno and surface water discharged into San Francisco Bay meets or exceeds relevant regulatory water quality standards.

ERC-20 Require implementation of Best Management Practices to reduce accumulation of nonpoint source pollutants in the drainage system originating from streets, parking lots, residential areas, businesses, and industrial operations.

ERC-23 Regulate new development to minimize stormwater runoff rates and volumes generated by impervious surfaces, and maximize recharge of local groundwater aquifers when feasible. Utilize the recommendations provided in the Bay Area Stormwater Management Agency’s Start at the Source Design Guidance Manual for Stormwater Quality Protection.

ERC-24 Require that new development incorporate features into site drainage plans that reduce impermeable surface area and surface runoff volumes. Such features may include:
• Additional landscaped areas including canopy trees and shrubs; • Reducing building footprint;
• Removing curbs and gutters from streets and parking areas where appropriate to allow stormwater sheet flow into vegetated areas;
• Permeable paving and parking area design
• Stormwater detention basins to facilitate infiltration; and • Building integrated or subsurface water retention facilities to capture rainwater for use in landscape irrigation and other non-potable uses.

HS-D Protect sites subject to flooding hazards by implementing storm drainage improvements, and by requiring building design and engineering that meets or exceeds known flood risk requirements.

HS-5 Require preparation of a drainage and erosion control plan for land alteration and vegetation removal on sites greater than 10,000 sq. ft. in size.

HS-16 Design and engineer new or redevelopment projects in potential flood hazard areas (e.g., Belle Air Park) to withstand known flood risk.

HS-18 Require developers to implement erosion and sedimentation control measures to maintain an operational drainage system, preserve drainage capacity, and protect water quality.

HS-20 Retain existing open space areas that serve as detention ponds in order to retain stormwater, recharge aquifers, and prevent flooding.

HS-22 Require that construction-related grading and other activities comply with the Association of Bay Area Governments’ (ABAG) Manual of Standards for Erosion and Sediment Control Measures and with the California Stormwater Quality Association (CASQA), Stormwater Best Management Practice Handbook for Construction.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 162 Initial Study
City of San Bruno December 2022
City of San Bruno Urban Runoff Management Policies
Policies related to the management of urban runoff within the City are included in Title 10 of the San Bruno Municipal Code, Municipal Services, and Title 12, Land Use. Best Management Practices as defined in Chapter 10.12, Water Quality Controls, which reduce the presence of pollutants in the stormwater are outlined in Chapter 10.18, Storm Water Management and Discharge Control. 1) No person shall throw, deposit, leave, maintain, keep, or permit to be thrown, deposited, placed, left or maintained, any refuse, rubbish, garbage, or other discarded or abandoned objects, articles, and accumulations, in or upon any street, alley, sidewalk, storm drain inlet, catch basin, conduit or other drainage structure, business place, or upon any public or private lot of land in the city, so that the same might be or become a pollutant, except in containers or in lawfully established dumping grounds.
2) Standard for Parking Lots and Similar Structures. Persons owning or operating a parking lot, gas station pavement or similar structure shall clean those structures as frequently and thoroughly as practicable in a manner that does not result in discharge of pollutants to the city storm sewer system.
3) Best Management Practices for New Developments and Redevelopments. Any construction contractor performing work in the city shall endeavor, whenever possible, to provide filter materials at the catch basin to retain any debris and dirt flowing into the city’s storm sewer system. City may establish controls on the volume and rate of storm water runoff from new developments and redevelopments as may be appropriate to minimize the discharge and transport of pollutants.
4) Compliance with Best Management Practices. Where best management practices guidelines or requirements have been adopted by the city for any activity, operation, or facility which may cause or contribute to storm water pollution or contamination, illicit discharges, and/or discharge of non-storm water to the storm water system, every person undertaking such activity or operation, or owning or operating such facility shall comply with such guidelines or requirements as may be identified by the director of public works. (Ord. 1558 § 1, 1994) Provisions for the minimization of the adverse effects of water runoff are also included in Title 12 “Land Use”, Article I “Excavation and Grading, Chapter 12.12 “Soils and Engineering Geology Report” and 12.16 “Grading Regulations”. As an attached element of the grading plan, Subsection

12.12.050 “Erosion Control” requires an erosion control plan containing:
“Calculations showing estimated surface water runoff on the site and maintenance of non-vegetative erosion control measures. Vegetative control measures shall be in accordance with Association of Bay Area Governments Manual for Surface Runoff Control Measures, pages 1-50 through 1-57, inclusive. (Ord. 1369 § 1, 1981; prior code § 9-1.7(f))” Per Subsection 12.16.030, “Grading progress and inspection”, swales or ditches on terraces shall have a minimum gradient of three percent and shall be paved with reinforced concrete not less than three inches in thickness. They shall have a minimum paved width of five feet. A single run of swale or ditch shall not collect runoff from a tributary area exceeding fifteen thousand square feet (projected) without discharging into a down drain. Sediment basins may also be required by the city DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 163 Initial Study
City of San Bruno December 2022
engineer to detain runoff and trap sediment during construction until slope erosion planting has been established.

City of San Bruno Storm Drain Master Plan
To identify and address potential flood risks in the City of San Bruno, a Storm Drain Master Plan was adopted by the City in June 2014. In addition to updating the City’s flood control guiding document, the Master Plan defines a new Capital Improvement Program to address the storm drain system’s capacity deficiencies.

Transit Corridors Plan
Various policies in the TCP have been adopted for the purpose of avoiding or mitigating hydrology and water quality impacts resulting from planned development within the TCP area, including the following:

Policies Description
A13-1 Ensure that all projects comply with the Municipal Regional Stormwater Permit as required by the National Pollutant Discharge Elimination System (NPDES) program.

A13-2 Encourage Low Impact Development (LID) techniques to infiltrate, store, detain, evapotranspire, and/or biotreat stormwater runoff close to its source.

A13-3 Minimize impervious surfaces such as concrete, asphalt and hardscaping, especially for surface parking lots. Utilize permeable joint pavers, porous concrete and asphalt, reinforced grass pavement (turfcrete), cobblestone block A13-5 Include project features to reduce pollution at its source including covered trash, recycling, and loading facilities.

A13-6 Utilize landscaping that minimizes irrigation and runoff, promotes surface infiltration where possible, minimizes the use of pesticides and fertilizers, and incorporates appropriate sustainable landscaping practices.

A13-7 Ensure adequate tree canopies in the front setbacks of private development and in parking lots, greenways, parks, and plazas to slow and reduce the amount of rainfall that falls to the ground.

A13-8 Encourage the use of green roofs and water collection devices, such as cisterns and rain barrels, to capture water from the building for re-use.

A13-9 Consider incorporating water collection devices, detention areas, and drain spouts into architectural features, water features, or artwork A13-10 Incorporate any required stormwater treatment measures early in the site planning process to ensure that they will be effective and attractive.

A15-4 Encourage planting strips along the street edges that are designed to act as functional stormwater management systems in the form of “urban bioswales”.

Stormwater is directed into the planter strips to irrigate landscaping while filtering and reducing stormwater runoff.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 164 Initial Study
City of San Bruno December 2022
Policies Description
A6-2 Install naturally drained, landscaped stormwater planters where possible, including on sidewalks, medians, bulbouts, parks and plazas, and traffic circles.

A6-3 Encourage the use of permeable pavers around tree wells instead of impervious materials to increase infiltration of stormwater runoff.

Bayhill Specific Plan
Various policies in the Bayhill Specific Plan have been adopted for the purpose of avoiding or mitigating hydrology and water quality impacts resulting from planned development within the Bayhill Specific Plan area, including the following:

Policies Description
5-15 Minimize Runoff.
a. Require new development to demonstrate no net increase in runoff from development, during both construction and operational phases. b. Applicants proposing new development shall prepare Drainage Report(s) for City’s review and approval prior to issuance of a grading, building, site development or any construction permits. All development, including interim conditions during construction and interim conditions with temporary improvements, within the Project Site is required to address stormwater management and implement stormwater control measures, including but not limited to on-site detention facilities, capture and re-use measures, green roofs, and/or other measures approved by the City, designed to maintain or reduce current, pre-development, surface runoff and stormwater discharge to the public storm drain system.
5-16 Employ Low-Impact Design. Require new development to incorporate low-impact design (LID), such as natural drainage systems and groundwater recharge features, consistent with stormwater permit requirements and the Green Infrastructure Plan.

Utilize LID techniques to infiltrate, store, detain, evapotranspire, and/or bio-treat stormwater runoff close to its source, where feasible.
5-17 Design new private open spaces, plazas, streetscapes, and landscaped areas in the public right-of-way for stormwater management and the efficient use of water. 5-18 Implement trash capture. Require new development to implement trash capture devices on site to reduce trash loads by 100 percent prior to discharging stormwater into the public storm drain system. Require new development to provide trash capture in public stormwater catch basins along the project frontage and any public stormwater catch basins newly installed as part of the development. Cover trash, recycling, and loading areas.
5-19 Utilize sustainable landscaping practices and principles that minimize irrigation and runoff, as well as the use of pesticides and fertilizers 6-8 Protect groundwater supplies from chemical pollution. Developers and property owners shall ensure that any development occurring on parcels where dewatering is needed (anticipated but not limited to parcels 5, 9, 12, 13, 14, or 15, see Figure 2-2) is DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 165 Initial Study
City of San Bruno December 2022
Policies Description
subject to review and approval by the County of San Mateo’s Groundwater Protection Program (see also, Policies 6-19 through 6-25).
6-18 Maintain high levels of water quality within the Westside Basin. Developers shall support the water quality of the Westside Basin by utilizing sustainable landscaping practices that minimize irrigation and runoff, promoting surface infiltration, and minimizing use of pesticides and fertilizers, where possible. 6-19 Require groundwater monitoring well installation and sampling prior to dewatering activity.* For any development proposing excavation and dewatering, project proponents shall install groundwater monitoring wells in the public right-of-way or easement and collect and test samples prior to dewatering activity. Wells are to be drilled as deep as the garage depth being proposed.
6-20 Require project proponents to provide estimates of construction dewatering duration, rates, volumes, methods, radius of impact, and disposal plan as part of project consideration and provide updated evaluations during construction. Require that an independent consultant monitor and confirm validity of the estimates during construction after dewatering efforts are underway and site conditions are better understood at a frequency determined by the City. The project shall be phased such that groundwater extractions do not exceed more than 8.5 percent of total designated max pumping volume allocation for the City of San Bruno from the South Westside Basin (i.e., less than 200 AF per year or less than 1,000 AF over 5 years). 6-24 Ensure that dewatering water quality is monitored and the presence of contaminants such as hydrocarbons and VOCs is ascertained. If petroleum hydrocarbons or VOCs are detected in dewatering water obtain a Fuel and VOC General Permit from the RWQCB prior to discharge of dewatering water to the storm drain. 6-32 Require that all applicants proposing to undertake excavation, drilling, or pile-driving activities for new buildings within the Plan Area retain a qualified paleontologist prior to the start of any ground-disturbing activities.
6-33 Require that all applicants undertaking earth moving projects within the Plan Area adequately respond to the discovery of paleontological resources.

4.10.1.2 Existing Conditions
Hydrology and Drainage
San Bruno’s Public Works Department Streets and Stormwater Division operates and maintains the storm drainage system in the City. The City’s existing storm drain network in shown in Figure

4.10-1. The City of San Bruno contains six watersheds that drain the City. The City’s primary drainage basins – San Bruno Creek (Watershed A), Crystal Springs Creek (Watershed B), and Huntington Creek (Watershed C) encompass 80 percent of San Bruno’s land area.

DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 19 21
20 7
12 6
9 4
2 8
5 23
22 17
10 18
13 14
3 1
15 11
16 FEET
0 500 1000 2000 10
acres
Potential Flood Zone
Watershed Boundary
Storm Drain Lines
Included in South San Francisco
Storm Drain System
Included in Millbrae Storm Drain System
Creek
City Limits
Source: Bissel & Karn, 1991; Environmental
Science Associates, 1999
*
**
Bayhill Specific
Plan Boundary
Transit Oriented
Development Overlay
FLOODING AND STORM DRAINAGE FIGURE 4.10-1
City2023-2031 Housing Element Update
of San Bruno
166 Initial Study
December 2022
·----·
ffi
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 167 Initial Study
City of San Bruno December 2022
Water Quality
San Bruno’s storm drain system prevents flooding by channeling stormwater runoff into San Mateo County Flood 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; 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.100 Groundwater
Prior to 2016, groundwater comprised 50 percent of the City’s water supply, but the City’s water supply is now predominantly sourced (90 percent) from the San Francisco Public Utilities Commission (SFPUC) and North Coast County Water District (NCCWD) with the remaining supply (10 percent) provided from groundwater from the Westside Groundwater Basin. The surface water supply is supplied from five surface water supply turnouts. The groundwater is extracted from four wells in the central portion of the 40 square mile South Westside Groundwater Basin area. A fifth well is under construction and anticipated to be complete in 2022.101 Between 2019 and 2020, the City of San Bruno supplied 3.12 million gallons per day of water to 11,902 customers, with an average water demand of 69 gallons per resident.102 The City’s 2021 Urban Water Management Plan stated the City has adequate water supplies to support the City’s water demands during normal years, but that the City’s Water Shortage Contingency Plan would need to be implemented during single- and multiple-dry year scenarios in order to reduce demand to the level of available supplies.103
Flooding and Other Hazards
The City of San Bruno has no areas designated by FEMA as 100-year floodplain. 104 A small portion of eastern San Bruno is within the 500-year floodplains; however, none of the Housing Opportunity Sites are within the 500-year floodplain.105
A tsunami is a large tidal wave caused by an underwater earthquake or volcanic eruption. Tsunamis affecting the Bay Area can result from offshore earthquakes within the Bay Area. Tsunami inundation maps for San Mateo County show that San Bruno is not within a tsunami inundation area.106
100 Ibid. 101 City of San Bruno. Water System Master Plan. December 2021. 102 3,120,000 gallons / 45,257 residents = 68.9 gallons per resident. 103 City of San Bruno. 2020 Urban Water Management Plan. November 2021. 104 City of San Bruno. San Bruno General Plan. Adopted March 24, 2009. Page 7-6. 105 Federal Emergency Management Agency. "FEMA Flood Map Service Center Search All Products - San Mateo County All Jurisdictions." Accessed September 7, 2022. https://msc.fema.gov/portal/advanceSearch. 106 California Geological Survey. Tsunami Hazard Area Map. Accessed July 28, 2022. https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/?extent=- 13734968.0269%2C4446045.3469%2C13500153.4761%2C4550305.4535%2C102100&utm_source=cgs+active&utm_content=sanmateo DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 168 Initial Study
City of San Bruno December 2022
A seiche is defined as a standing wave generated by rapid displacement of water within an enclosed body of water (such as a reservoir, lake, or bay) due to an earthquake that triggers land movement within the water body or landsliding into or beneath the water body. The nearest enclosed body of water is San Andreas Lake, none of the Housing Opportunity Sites are located in the vicinity of this water body.

4.10.2 Impact Discussion
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less than
Significant
Impact
No Impact
Would the project:
1) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?
2) Substantially decrease groundwater supplies or
interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?
3) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river or
through the addition of impervious surfaces, in
a manner which would:
- result in substantial erosion or siltation onor off-site; - substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or off-site;
- create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
- impede or redirect flood flows?
4) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
5) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
□
IZI
IZI
IZI
IZI
□
□
□
□
□
□
□
□
□
DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 169 Initial Study
City of San Bruno December 2022

4.10.2.1 Approach to Hydrology and Water Quality Analysis Hydrology and water quality impacts from future housing development would be limited to the watershed in which the Housing Opportunity site is located. As discussed in Section 4.10.1.2, San Bruno is divided into six watersheds that drain the City. The City’s primary drainage basins – San Bruno Creek (Watershed A), Crystal Springs Creek (Watershed B), and Huntington Creek (Watershed C) encompass 80 percent of San Bruno’s land area. The cumulative effect of residential development at all of the Housing Opportunity Sites on hydrology and water quality is discussed in Section 4.21, Mandatory Findings of Significance.

Impact HYD-1: The project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. (Less than Significant Impact)
The water quality of streams, creeks, ponds, and other surface water bodies can be greatly affected by pollution carried in contaminated surface runoff. Pollutants from unidentified sources, known as nonpoint source pollutants, are washed from streets, construction sites, parking lots, and other exposed surfaces into storm drains. Urban stormwater runoff often contains contaminants such as oil and grease, plant and animal debris (e.g., leaves, dust, animal feces, etc.), pesticides, litter, and heavy metals. In sufficient concentration, these pollutants have been found to adversely affect the aquatic habitats to which they drain.

Construction Activities
Future construction activities, such as grading and excavation, may result in temporary impacts to surface water quality. When disturbance to underlying soils occurs, the surface runoff that flows across the site may contain sediments that are ultimately discharged into the storm drainage system.

Future development of Housing Opportunity Sites that would disturb more than one acre of soil would trigger conformance with the Construction General Permit, which would require an NOI to be submitted to the RWQCB and a SWPPP must be developed to establish methods for controlling discharge associated with construction activities. Future development under the Housing Element Update would also be required to comply with the City’s Municipal Code (Chapter 12.16 Grading Regulations) which requires projects to prepare and implement an erosion control plan, thereby ensuring future development complies with local and regional regulations regarding the reduction of pollutants in stormwater. Accordingly, future development under the Housing Element Update in accordance with the Construction General Permit, the City’s Municipal Code and General Plan policies would not result in significant construction-related water quality impacts. (Less than Significant Impact)
Post-Construction
Future development under the Housing Element Update would be subject to Provision C.3 of the MRP. This requires the incorporation of site design, source control and runoff treatment controls to reduce the rates, volumes and pollutant loads of runoff from the project. Further, future development under the Housing Element Update would also be required to comply the City’s Urban Runoff Management Policies, which ensures new developments follow local and regional regulations regarding the reduction of pollutants in stormwater and implement City Best Management Practices DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 170 Initial Study
City of San Bruno December 2022
(BMP), such as stormwater filters, to reduce such pollutants. Therefore, the Housing Element Update would have a less than significant impact on post-construction water quality. (Less than Significant Impact)
Impact HYD-2: The project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. (Less than Significant Impact)
Groundwater levels can fluctuate due to variations in rainfall and other factors. Groundwater from the Westside Groundwater Basin supplies approximately 10 percent of the City’s water supply. At this time, specific development details are not known for future development at the Housing Opportunity Sites. In the event that below-grade excavations are expected to encounter groundwater, redevelopment of the site would require dewatering in accordance with the City’s Groundwater Discharge Regulations outlined in Section 10.12 of the Municipal Code.

The Housing Element Update would rely on existing sources of water and the city’s existing water delivery system (refer to Section 4.19 Utilities and Service Systems for a discussion of the project’s water demand as it relates to supplies). The Housing Element Update would not establish new groundwater sources or result in a substantial depletion of aquifers relied upon for local water supplies. For these reasons, the Housing Element Update would not result in a significant groundwater impact.

Impact HYD-3: The project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows. (Less than Significant Impact)
As shown on Figure 4.10-1, there are no watercourses that intersect any of the Housing Opportunity Sites, therefore, the Housing Element Update would not alter the course of any waterways. An aboveground channelized portion of San Bruno Creek transitions belowground at the westernmost border of Site 6; San Bruno Creek remains underground until emptying into the San Bruno Canal, located approximately 1.75 miles east of Site 6.

Future construction at the Housing Opportunity Sites could temporarily alter stormwater drainage patterns. Any erosion associated with future development of the Housing Opportunity Sites would be managed in accordance with the City’s Municipal Code (refer to Impact HYD-1). Stormwater runoff would be minimized in accordance with the Construction General Permit and SWPPP. Postconstruction, future development under the Housing Element Update would be subject to Provision C.3 of the MRP and the City’s Urban Runoff Management Policies, which ensures new DocuSign Envelope ID: D97C2B4E-2934-461D-9685-34E874ADBB19 2023-2031 Housing Element Update 171 Initial Study
City of San Bruno December 2022
developments follow local and regional regulations regarding the reduction of pollutants in stormwater and implement City BMPs, such as stormwater filters, to reduce such pollutants. With adherence to the City’s Municipal Code, Provision C.3 of the MRP, and the Construction General Permit, the rate at which stormwater runoff enters the City’s storm drainage system from Housing Opportunity Sites would be reduced, thereby minimizing the risk of potential flood events. The Housing Element Update would, therefore, not substantially alter the drainage pattern of the site or area in a manner which would result in on or offsite erosion, flooding, or runoff impacts.

Impact HYD-4: The project would not risk release of pollutants due to project inundation in flood hazard, tsunami, or seiche zones. (Less than Significant Impact) None of the Housing Opportunity Sites are located in a 100-year floodplain or within a tsunami inundation zone. None of the Housing Opportunity Sites are located near a standing body of water where seiches could occur. Therefore, the Housing Element Update would not risk release of pollutants due to project inundation.